Oregon’s EPR Program: New Grace Period Gives Producers One Last Chance to Comply

Under Oregon’s landmark EPR law, producers were expected to submit packaging, paper, and food-service ware data to CAA by March 31, 2025. Now, the CAA has extended a grace period through April 30, 2025, allowing late reporting without immediate penalty. However, noncompliant companies are not in the clear. This week, CAA will forward a list of non-reporting entities to the Oregon Department of Environmental Quality (DEQ), which is authorized to initiate civil enforcement actions.

Why This Extension Matters

Data submitted during the grace period will still count toward CAA’s fee rate calculations for the upcoming compliance cycle. And for producers, there’s a clear incentive: the more data reported in each material category, the lower the per-ton fee for that category.

This structure rewards participation. When more producers report, costs are distributed more broadly. When fewer do, compliant companies shoulder a disproportionate financial burden. In short: participation lowers fees—for everyone.

Regulatory Enforcement Is Imminent

Despite the extension, the state’s July 1, 2025 EPR program start date remains unchanged. After that, all covered producers must:

• Pay fees based on the weight and material of packaging sold into Oregon
• Begin transitioning packaging toward recyclable, compostable, or reusable alternatives
• Prepare for ongoing reporting requirements in future compliance years

The DEQ has the authority to assess civil penalties for companies that continue to withhold data or ignore their obligations, adding urgency to the April 30 grace period.

Who Needs to Act?

Oregon’s EPR program applies broadly. Companies subject to the law include those that:

• Manufacture or sell packaged goods to Oregon consumers
• Provide disposable food-service ware, including utensils, containers, and cups
• Distribute paper products, whether for packaging or general use
• Ship products to Oregon-based businesses or consumers

Importantly, compliance responsibility lies with the brand owner or importer—not necessarily the retailer.

A Warning to Producers Nationwide

Oregon’s EPR rollout is being closely watched by regulators and sustainability advocates across the country. Several other states—California, Colorado, and Maine among them—have passed or are actively developing EPR legislation for packaging. The structure, enforcement, and results of Oregon’s program are likely to serve as a model or cautionary tale.

For companies selling into multiple states, this moment presents a strategic inflection point. Waiting could prove costlier than taking action now.

Strategic Compliance Is Smart Compliance

To avoid regulatory penalties and control future compliance costs, companies should:

• Submit data before April 30 to reduce 2025 fees
• Audit product packaging for future reporting readiness
• Stay engaged with CAA communications and Oregon DEQ updates
• Plan for eco-modulated fees that reward environmentally preferable packaging

Early compliance not only helps reduce immediate costs—it also builds organizational readiness for upcoming changes in material design, product labeling, and supply chain transparency.

Bottom Line: The grace period may offer a short reprieve, but enforcement is on the horizon. Producers have until April 30, 2025, to align with Oregon’s EPR program or face potentially steep consequences.