Dive Brief:
- The Oregon Department of Environmental Quality this month approved producer responsibility organization Circular Action Alliance’s program plan amendment on responsible end markets following an extended consultation process.
- The updated version establishes a benchmarking process for third-party certifications and PRO verifications. DEQ also made some adjustments to performance criteria in the verification standard, and highlighted a variance for glass furnace self-attestation and verification.
- CAA says it’s now working on timelines and documentation expectations for the phased-in approach on REMs. “Guidance is actively under development now that the interim verification approach proposed in the amendment has been approved,” said Kieran Singh Nashad, communications specialist with CAA, in an emailed statement.
Dive Insight:
Ensuring responsible end markets for recyclables has been a core tenet of the state’s push for packaging EPR, especially because Oregon recyclers were heavily impacted by fallout from China’s 2017 National Sword policy. The focus on REMs is to ensure environmental benefits while minimizing risks to public health and worker health and safety, but getting to a workable standard early on was challenging. While Oregon DEQ launched the EPR program in 2025, it delayed REM enforcement until 2026.
“Since the time of first draft submission in August 2025, CAA and DEQ have worked quite closely together to craft this amendment as a thoughtfully-conceived compromise among industry and public interests on a centerpiece policy of the Recycling Modernization Act,” DEQ’s Cheryl Grabham, manager for the product stewardship program, wrote in the approval letter.
CAA believes the updated version “creates a clearer starting point for launching a new verification framework for end markets and downstream facilities, increasing transparency and accountability across the recycling value chain,” CAA wrote in an announcement Tuesday, saying that DEQ’s decision followed collaboration between DEQ, CAA, the Oregon Recycling System Advisory Council, local governments, service providers and end market operators.
In preparation for audits, which are part of the verification process, CAA will assess the need for technical assistance, Nashad said.
In the seven states that have already passed packaging EPR laws, all but Maine’s program include REM provisions. Compliance could get a little simpler for end market entities — whether processors, transporters, brokers or others in the supply chain — in the future: As CAA anticipates packaging EPR expanding in the U.S., the organization is trying to standardize responsible end market verification nationally.
CAA opened the public comment period for its draft certification standard earlier this month. According to CAA, once a national standard is adopted, end market entities could undergo a single audit process once every three years, rather than multiple state-by-state.
