Key Takeaways

  • The Oregon Department of Environmental Quality (DEQ) this month approved aResponsible End Market Plan Amendmentsubmitted by Circular Action Alliance (CAA), the producer responsibility organization, following an extended consultation period.
  • The updated versionestablishes baseline processes for third-party certification and PRO verification. DEQ also adjusted performance standards within the verification criteria and introduced variance handling for self-declarations and verification of glass furnaces.
  • CAA said it is currently developing a timeline and documentation requirements for phased implementation of the REM. In an email statement, CAA Communications Specialist Kieran Singh Nashad said, "With the approval of the interim verification methods proposed in the amendment, related guidance documents are actively being developed."

Deep Dive

Ensuring recyclables reachresponsible end marketshas been a core principle of the state's push for packaging extended producer responsibility (EPR), especially becauseOregon recyclerswere severely impacted by China's 2017 "National Sword" policy. The REM focuses on ensuring environmental benefits while minimizing harm to public health and worker health and safety, but developing viable standards early on proved challenging. Although Oregon DEQ launched the EPR program in 2025, itdelayed REM enforcement until 2026。

DEQ Product Stewardship Program Manager Cheryl Grabham wrote in theapproval letter, "Since the initial draft was submitted in August 2025, CAA and DEQ have worked closely to shape this amendment into a thoughtful compromise that balances industry and public interests and serves as a core policy of the Recycling Modernization Act."

CAA believes the updated version "provides a clearer starting point for end markets and downstream facilities to begin the new verification framework, increasing transparency and accountability across the recycling value chain," CAA said in anannouncementreleased Tuesday, noting the DEQ decision came after collaboration among DEQ, CAA, the Oregon Recycling System Advisory Council, local governments, service providers, and end market operators.

In preparation for audits that will be part of the verification process, CAA will assess technical assistance needs, Nashad said.

Among the seven states that have passed packaging EPR laws, all but Maine include REM provisions in their programs. Going forward, compliance efforts for end market entities—whether processors, transporters, brokers, or other players in the supply chain—could become more streamlined: As CAA anticipates packaging EPR expansion in the U.S., the organization is working to standardize responsible end market verification nationwide.

CAA opened the public comment period for itsdraft certification standardearlier this month. According to CAA, once the national standard is adopted, end market entities could undergo a single audit every three years rather than multiple audits on a state-by-state basis.