Circular Action Alliance: The US Packaging PRO

Last reviewed: 31 August 2026. Reviewed by Kevin Kai Wong, Packgine packaging compliance lead.

Correction: Updated 31 August 2026 to reflect CalRecycle's designation of Circular Action Alliance as California's first producer responsibility organization. An earlier version of this page incorrectly stated that CAA was not the approved PRO in California.

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 California, Colorado, Oregon, Minnesota, and Maryland, and is the only PRO currently operating at multi-state scale for packaging in the US. Its official website is circularactionalliance.org; the older circularaction.org address redirects there.

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:

• California, approved to serve as the state's first producer responsibility organization under PRC 42061.5.

• Colorado, sole approved PRO for the statewide program operated under HB 22-1355.

• Oregon, approved PRO under the Plastic Pollution and Recycling Modernization Act (SB 582).

• Minnesota, selected PRO under the Packaging Waste and Cost Reduction Act.

• Maryland, designated PRO under SB 901.

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. Treat Maine as structurally different from the PRO states rather than assuming the same registration and reporting mechanics apply.

California: CAA is the approved PRO

CalRecycle states that "Circular Action Alliance serves as California's first producer responsibility organization (PRO) in charge of implementing the state's packaging producer responsibility law." That approval sits under PRC 42061.5, and it follows SB 54 (Allen, 2022), signed by Governor Gavin Newsom on 30 June 2022.

Producers have three compliance routes in California: apply to participate in the CAA PRO plan, submit an independent producer application, or obtain a small producer exemption. Independent producers must hold a CalRecycle-approved plan under 14 CCR 18980.7.

This is where a common misreading occurs. CalRecycle's page section headed "Independent Producers Approved by CalRecycle" lists individual producers who may comply on their own, without joining a PRO plan, where they can demonstrate to CalRecycle that certain recycling-rate and source-reduction goals have been met. Those entries are individual producers holding their own approved plans. They are not a competing producer responsibility organization, and their presence does not displace CAA as the state's approved PRO.

Reporting runs through PEPRS, the Packaging Extended Producer Responsibility System, CalRecycle's online portal for producer registration, data submission and compliance tracking. Accounts are created through WebPass. There are two reporting routes: reporting via the PRO, where CAA manages registration, reporting and submission of certain exemptions and exclusions on the producer's behalf; or self-reporting through PEPRS, which applies to producers in the PRO plan who have elected to self-report and to producers complying individually.

CAA submitted its Producer Responsibility Organization Plan to the Advisory Board on 15 June 2026, and CalRecycle lists the PRO Plan itself as coming in 2026. On 1 May 2026 the Office of Administrative Law approved the permanent regulations and filed them with the Secretary of State, effective upon filing, and CalRecycle published updated producer guidance the same day. On 31 December 2025 CalRecycle published an updated Covered Material Categories List under PRC 42061(e), including recyclability and compostability determinations per covered material category and a first-ever recycling rate determination per category under PRC 42061(b); the next update is due by 1 January 2027.

CalRecycle has also published Covered Material Categories Reporting Guidance (1 September 2025), Source Reduction Reporting Guidance (4 August 2026), and Guidance for Submitting a Categorically Excluded Materials Notice for Food and Agricultural Commodity Packaging (27 August 2026).

The statutory targets producers are working toward: 10% less single-use plastic by 1 January 2027; 30% of single-use plastic recycled by 1 January 2028; 20% less and 40% recycled by 1 January 2030; and 25% less, 65% recycled, and 100% of single-use packaging and plastic food service ware recyclable or compostable by 1 January 2032.

Sources: CalRecycle, packaging EPR and producer guidance, retrieved 31 August 2026.

## 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 California, Colorado, Oregon, Minnesota, or Maryland, starting with California as the largest programme:

• 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.

Related reading

• What a PRO Does in EPR: Roles, Responsibilities, and Producer Obligations

• One PRO or Many? How Producer Organization Choice Varies by State

• Seven US States with Active Packaging EPR in 2026: A Status Map

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