Key takeaway
What This Development Means
Circular Action Alliance has published Oregon's 2027 producer fee schedule for packaging, paper and food serviceware. Producers will receive two invoices, while material rates reflect programme costs and reserve drawdowns.
Which Products Are Covered By Oregon's Producer Fee Schedule?
The programme covers packaging, printing and writing paper and food serviceware supplied in or into Oregon, subject to statutory producer definitions and exemptions. Producers should classify each material using CAA guidance rather than relying on a product's marketing description.
Does The 2027 Fee Schedule Settle The Oregon EPR Litigation?
No. The district court upheld the law, and an appeal has been filed. The schedule implements the current programme. National Association of Wholesaler-Distributors members affected by earlier preliminary relief should obtain advice on their specific position.
Source basis: Circular Action Alliance, Oregon 2027 Producer Fees Schedule (1 October 2026)
Circular Action Alliance (CAA), Oregon's only approved producer responsibility organisation, has published the Oregon 2027 producer fee schedule. The schedule applies to the 2027 programme year under the Plastic Pollution and Recycling Modernization Act and translates producers' reported supply data into material-specific financial obligations.
CAA will issue 50% of each producer's annual invoice in January 2027 and the remaining 50% in July. Rates are calculated using producer-reported supply, CAA's national fee-setting method, projected programme needs, material-management costs and approved material strategies. Oregon's Department of Environmental Quality states that the 2027 cycle uses 2025 supply data reported to CAA.
Material Rates Reflect Reserve Reductions As Well As Operating Cost
CAA says approximately $80 million in programme reserves and $3 million in previously collected specifically identified material fees are being returned to producers through reduced rates. The schedule therefore shows a base rate and reserve drawdowns before the final per-pound rate.
Final rates vary substantially by material. Examples include $0.01 per pound for newspapers and several other printing-paper categories, $0.83 for ceramics, $0.11 for aluminium foil and moulded containers, $0.33 for aluminium aerosols, $0.12 for flexible high-density or low-density polyethylene items, and $0.56 for other flexible films.
Glass bottles and jars show a $0.00 final rate after reserve drawdowns. These examples are not a substitute for classifying every reporting category in the official schedule.
CAA forecasts that 88 cents of every fee dollar will support collection, processing and education or outreach. Processing accounts for 40 cents, collection 37 cents and education or outreach 11 cents. The remainder supports regulatory and administrative functions and other programme costs.
Low-Volume Producers Can Elect Flat Fees
Producers supplying no more than 10 metric tonnes of covered material into Oregon can use graduated flat fees:
- $700 for one to 2.5 tonnes
- $1,300 for 2.5 to five tonnes
- $2,200 for five to 7.5 tonnes
- $3,100 for 7.5 to 10 tonnes
The schedule notes that the first two tiers are also available to producers with more than $10 million in gross revenue. Small producers meeting the statutory definition in ORS 459A.863(32) remain exempt from producer obligations.
A separate private-recycling exemption can remove qualifying responsibly recycled material from fee calculations. The claim window for 2027 fees closed on 31 March 2026. The next annual claims process is expected to open in January 2027.
The underlying law remains in effect. A federal district court upheld it against constitutional challenge on 27 August 2026, and an appeal was filed on 24 September. Earlier preliminary relief concerned a defined group of National Association of Wholesaler-Distributors members, and its post-judgment effect is not expressly resolved in the judgment. Affected members should take legal advice rather than assume either universal exemption or universal enforcement protection.
Data Quality Now Affects Cash Flow Twice A Year
Producers should reconcile 2025 tonnage, product categorisation, exemptions and legal-entity responsibility against the schedule before January invoicing. Oregon can impose up to $25,000 per day for failure to register or join a producer responsibility organisation.
Reserve drawdowns suppress some 2027 rates and may not recur. Businesses should separate this year's cash reduction from the underlying cost of each material when comparing packaging-design options or forecasting later years under extended producer responsibility.
Related Foresight coverage explains PPWR producer-register harmonisation, New Zealand agrichemical and farm-plastics product stewardship and PPWR implementation guidance.
Summary
Oregon's 2027 schedule provides the rates and invoice timing needed for near-term planning. Producers should reconcile 2025 supply data, material categories, exemptions and flat-fee eligibility before the January 2027 invoice is calculated and approved.
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