Circular Action Alliance: The PRO Running Most US Packaging EPR Programs
Circular Action Alliance is the approved producer responsibility organization in Colorado, Oregon, Minnesota, and Maryland, and the de facto operator for most US packaging EPR. Here is what producers actually deal with when CAA is their PRO.
By Kevin Kai Wong, Managing Partner at gCurv Technologies
April 3, 20269 min read
Who CAA is
Circular Action Alliance (CAA) is a nonprofit producer responsibility organization (PRO) formed by a coalition of consumer goods companies to operate packaging EPR programs in the United States. It is the approved or selected PRO in Colorado, Oregon, Minnesota, and Maryland, and is the only PRO currently operating at multi-state scale for packaging in the US.
For most producers selling nationally, CAA is the organization you will register with, report to, and pay fees to across multiple state programs.
Where CAA operates
As of 2026, CAA is the approved or operating PRO in:
- Coloradosole approved PRO for the statewide program operated under HB 22-1355.
- Oregonapproved PRO under the Plastic Pollution and Recycling Modernization Act (SB 582).
- Minnesotaselected PRO under the Packaging Waste and Cost Reduction Act.
- Marylanddesignated PRO under HB 254.
CAA is also engaged in stakeholder processes in additional states considering EPR.
Maine runs a different model, the state contracts directly with a stewardship organization rather than having producers join a PRO, so CAA is not the operator there. California uses a PRO model, but CAA is not the approved PRO in California; CalRecycle approved a separate organization.
What CAA does for producers
In each state where CAA operates, it performs the operational functions of the PRO:
- Producer registration and member onboarding
- Collection of producer reports (tonnages, materials, formats)
- Fee calculation and invoicing under the state's eco-modulation rules
- Contracting with haulers, MRFs, and processors
- Investments in collection and recycling infrastructure
- Reporting to the state regulator
- Public-facing education and outreach
Producers join CAA as members, submit data through CAA's reporting portal, and pay invoices issued by CAA. The state sets the rules; CAA executes them.
What CAA does not do
CAA does not eliminate the producer's legal responsibility. The producer is still the regulated entity under state law. If your data is wrong, your fees are wrong. If you fail to register, you are still in violation, being a CAA member does not cure non-registration.
CAA also does not harmonize the rules across states. Each state's program has its own definitions, fee schedules, deadlines, and eco-modulation factors. CAA operates each program according to that state's plan. A producer reporting through CAA in four states is still effectively filing four reports against four different rule sets, even if the portal is shared.
What changes for producers when CAA is the PRO
Joining CAA generally means:
- One membership relationship that covers multiple states
- A shared portal and reporting cadence (with state-specific differences inside)
- Consolidated invoicing in some cases, separate invoicing in others
- A single counterparty for questions, audits, and dispute resolution
It does not mean a single fee, a single deadline, or a single set of rules. Producers still need state-by-state cost models and state-specific data tagging.
What to do in 2026
If you sell into Colorado, Oregon, Minnesota, or Maryland:
- Confirm your CAA membership status in each state where you have producer obligations.
- Map your internal SKU and packaging data to CAA's reporting categories for each state.
- Track each state's deadlines separately, CAA's portal will surface them, but the legal obligation is yours.
- Budget for fee variability: eco-modulation factors differ by state, and CAA passes those through.
How Packgine helps
Packgine ingests your packaging data once and produces state-specific reports aligned to each program's categories, including the formats CAA expects in each state, so you can submit through CAA without re-mapping data four times.
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