One PRO or Many? How Producer Organization Choice Varies by State
Some US states allow only one approved PRO. Others permit multiple. The choice, or lack of one, affects fees, contracts, and how much portability you have between programs.
By Kevin Kai Wong, Managing Partner at gCurv Technologies
March 31, 20268 min read
Why this matters
US packaging EPR programs share a structure, producers join a producer responsibility organization (PRO), report through it, and pay fees through it, but they differ on a question that shapes the producer's experience: is there only one PRO, or can a producer choose among several?
The answer affects your contract terms, your leverage on fees, your data portability, and your operational complexity.
Single-PRO states
Most US packaging EPR programs in 2026 are single-PRO in practice:
- Coloradoone PRO is approved by the state to operate the program (Circular Action Alliance).
- Oregonone PRO is approved (Circular Action Alliance) under the state's program plan.
- Minnesotaone PRO is selected by the state (Circular Action Alliance).
- Marylandone designated PRO (Circular Action Alliance).
In these states, a producer does not have a choice of PRO. You join the approved PRO or you are out of compliance. The benefit is simplicity. The cost is no negotiating leverage on fees or contract terms, the state sets the rules and the PRO executes them.
Multi-PRO states
A smaller set of states permit multiple PROs to be approved, with producers choosing among them:
- California (SB 54)the statute permits the state to approve more than one PRO. In practice, CalRecycle has approved one PRO to date, but additional PROs may be approved over time.
In a multi-PRO regime, producers can in principle compare PROs on fee structure, services, and operational fit. In practice, the state still sets fee floors, eco-modulation rules, and reporting requirements, so PRO competition is bounded.
State-run / contracted models
Maine is the outlier. Under LD 1541, the state contracts with a stewardship organization to run the program. Producers do not "join" a PRO in the usual sense, they pay reimbursement fees to the state-administered program based on tonnages.
This is operationally simpler in some ways (no PRO membership negotiation) but offers no producer choice and no PRO-side advocacy.
What this means operationally
For most producers selling nationally:
- In Colorado, Oregon, Minnesota, and Maryland, you join Circular Action Alliance. There is no decision to make.
- In California, you join the approved PRO. Watch for additional PRO approvals; that may create a choice in future years.
- In Maine, you register and report directly into the state-administered scheme.
- In Washington, confirm the current PRO model and approval status under the Recycling Reform Act before each reporting cycle.
The "choice" of PRO is rarely a real lever in 2026. The real levers are data quality, eco-modulation positioning, and category mapping, all of which sit with the producer regardless of which PRO is in front of them.
What to do in 2026
- Confirm the approved or selected PRO in each state where you have obligations.
- Don't budget time or legal spend on PRO selection in single-PRO states, there is no decision to make.
- In multi-PRO states, evaluate PROs on reporting portal quality, fee transparency, and audit support, not on headline fee promises.
- Maintain your own packaging data system. Whichever PRO you join, the data has to be yours.
How Packgine helps
Packgine keeps your packaging data in your system of record, then exports the formats each PRO and each state require. If a state adds a second PRO, or if you switch PROs in a multi-PRO state, your data and reporting workflow do not have to start over.
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