Oregon’s Packaging and Paper Recycling program (Recycling Modernization Act, SB 582 of 2021, ORS 459A.860–459A.975) is the furthest along of the three states this practice opens with.

Status at last review (2026-09-21)

• Program live since July 1, 2025. Annual supply reporting and fees are active — not planning-phase. (CAA Oregon; DEQ RMA program page.)
• 2026 fee schedule published — estimates against it are current-schedule estimates. 2027 schedule expected October 2026; treat as expected, not published, until CAA posts it.
• Small-producer shorthand: under 1 metric ton into Oregon or under $5M global gross revenue, subject to associated-producer rules — run the state-specific screen, never reuse another state’s test.
• Producer status lists are point-in-time. DEQ publishes a dated producer status list; a listing is a dated agency status, not an adjudicated offense. Verify the newest list before acting on it.
• Litigation: on August 27, 2026 the federal district court rejected the constitutional challenge in National Association of Wholesaler-Distributors v. Feldon, No. 3:25-cv-01334-SI, after trial; the earlier preliminary injunction was dissolved. Treat as a district-court judgment; keep checking for appeal or new orders.

What this means for a brand

• If you sell packaged products into Oregon and are not small-producer-excluded, assume registration, annual reporting via CAA, and fee invoices are current duties — confirm your entity’s status with CAA/DEQ, not with a blog post.
• Report by aggregating state supply by material category; keep component-level packaging records as the defensible underlying method with rule citations.

Sources (retrieved 2026-09-21)

• ORS chapter 459A — https://www.oregonlegislature.gov/bills_laws/ors/ors459a.html
• DEQ producer page — https://www.oregon.gov/deq/recycling/pages/producers-of-covered-products.aspx
• DEQ RMA program — https://www.oregon.gov/deq/recycling/pages/modernizing-oregons-recycling-system.aspx
• CAA Oregon — https://circularactionalliance.org/oregon
• 2026 Oregon fee schedule — https://circularactionalliance.org/s/OR-2026-Fee-Schedule-Public.pdf
• NAW v. Feldon docket — https://www.courtlistener.com/docket/70967634/national-association-of-wholesaler-distributors-v-feldon/

Data/compliance support only — not legal advice. Confirm current authority before relying.