Oregon's Recycling Modernization Act: A Plain English Compliance Guide
Oregon's Recycling Modernization Act is the first US packaging EPR law to actually start invoicing producers. Here is what it covers, who it applies to, and what producers selling into Oregon need to do in 2026.
By Kevin Kai Wong, Managing Partner at gCurv Technologies
April 8, 202611 min read
What the Recycling Modernization Act actually does
Oregon's Recycling Modernization Act (RMA), signed in 2021, was the first US packaging EPR law to enter operation. It shifts the cost of managing packaging, paper products, and food serviceware away from Oregon ratepayers and onto the producers who place those materials on the Oregon market. Unlike California, which is still in its data-collection phase in 2026, Oregon is already invoicing producers based on the data they reported in the prior cycle.
The mechanism follows the standard EPR pattern: producers join an approved Producer Responsibility Organization (PRO), report the covered material they place on the Oregon market, and pay fees that fund collection, sortation, processing, and recycling improvements across the state.
Who is a producer under the RMA
The RMA's producer test is the entity with the most direct economic relationship to the covered material in Oregon. In practice that is:
1. The brand owner whose name appears on the package, if it has US operations. 2. If the brand owner has no US operations, the importer of record into the United States. 3. If neither applies, the distributor or seller that first places the goods on the Oregon market.
There are de minimis thresholds for very small producers; consult the current DEQ guidance for the exact small-producer cutoff before assuming you are exempt.
What the RMA covers
Covered materials under the RMA include packaging in all three layers (primary, secondary, tertiary), paper products, and certain food serviceware. The sweep is broad: pouches, films, bottles, jars, cartons, e-commerce mailers, void fill, pallet wrap, and most paper-based packaging are in scope. Reusable transport packaging like wood pallets and IBC totes is generally out of scope, as is medical packaging that meets specific carve-outs.
If you sell physical products into Oregon, assume your packaging is in scope until you have positively classified it otherwise.
How fees work in Oregon
Fees are set and collected by the approved PRO (Circular Action Alliance is the active PRO for most producers). Like other US programs, fees layer:
- A base rate per material category in dollars per metric ton, with rates that reflect the actual cost of recovery in Oregon.
- An eco-modulation adjustment that rewards higher PCR content and recyclable design, and penalizes designs that contaminate streams.
- A truing-up reconciliation at the end of each cycle to align reported volumes with audited volumes.
For worked examples by company size, see Oregon EPR Costs by Company Size.
The 2026 reporting calendar
The RMA's calendar runs on an annual cycle. Key dates in 2026, which should be verified against the current Oregon DEQ published timeline:
- Q1 2026annual registration confirmation with the PRO.
- Q2 2026annual data submission for the prior calendar year's covered material.
- Q3, Q4 2026invoicing for the current cycle, based on the most recent reported data.
The exact day-of-month dates have shifted across implementation cycles, so confirm the current cycle's calendar with your PRO and with DEQ before each submission window opens.
What "compliant" looks like in Oregon
A compliant Oregon operating model in 2026 has the same six pieces that California requires:
1. A registered producer entity with the right PRO membership. 2. SKU-level packaging data tagged for Oregon-bound volume. 3. A defensible state-attribution methodology. 4. Audit trail for every PCR claim. 5. Change-control on packaging redesigns. 6. A fee budget line that scales with volume and material mix.
The Oregon-specific wrinkle is that you are paying real fees in 2026, not modeling future fees. Reconciliation gaps between what you reported and what your invoice says become real cash conversations very quickly.
For a side-by-side with California, Maine, and Colorado, see Maine, Oregon & Colorado EPR Compared and EPR Laws in the US: State Regulations 2026.
How Packgine helps
Packgine ingests SKU-level packaging data, classifies it against Oregon material categories and recyclability rules, models fees including eco-modulation, prepares Oregon-format reports, and reconciles invoices against reported volumes. The same dataset feeds California, Maine, Colorado, Maryland, Washington, and Minnesota.
Related reading
Run an Oregon fee model on your portfolio or book a working session.
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