Circular Action Alliance, the producer responsibility organization dedicated to implementing state-level extended producer responsibility laws for paper and packaging in the U.S., has released new online guidance for producers.

So far, seven U.S. states (and nine Canadian provinces) have adopted EPR laws for packaging, with several more launching needs assessments and other preliminary measures. These laws require producers to register with the designated producer responsibility organization, report packaging data and pay fees based on the amount and type of packaging materials they introduce into the market.

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CAA is the only PRO selected to execute these laws so far. The organization is responsible for defining producer obligations under packaging EPR laws and participation in the PRO as needed for compliance. These policies set forth specific requirements for three key stages in the process:

  • The Registration Policy establishes standards for producers seeking EPR compliance services from CAA in states where CAA operates as a PRO.
  • The Reporting Policy outlines the requirements for producers to report the supply data necessary for determining EPR program fees.
  • The Payment Policy establishes standards for participants in making payments to CAA.

Getting started with EPR compliance can be confusing, because different state law define “producer” a little differently – not to mention the different requirements and exceptions. That’s why registering with CAA is critical to compliance.

“When you register with us – and even prior to – as part of helping you understand whether you should register, we’re trying to provide convenient access to those definitions so that people can … take their own unique business model and apply it against those definitions,” Geoff Inch, CAA’s senior vice president of producer services, told PPAI Media in a 2024 interview.

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It’s important to note that these packaging EPR laws apply to anyone doing business in the states where the laws are in effect, even if it’s just fulfilling an e-commerce order.

Although similar in goals and scope, the seven different state laws have different fee collection requirements and timelines, as previously noted. Oregon is the first state where the materials collection program – and its fees – took effect on July 1. Colorado follows in January 2026 and California in January 2027, and both have key deadlines coming up fast:

Colorado: Producers selling packaging, paper products and food serviceware into Colorado must report supply data to CAA by July 31.

California: Companies that sell, distribute or ship single-use packaging in California must register by September 5. The registration portal opens August 1.

CAA is also seeking input from registered producers on:

  • The draft California Interim State Addendum, which is an interim agreement that outlines membership requirements for producers participating in California’s packaging EPR program.
  • CAA’s fee-setting methodology for early fees, which has been refined based on producer feedback.
  • Review the draft and fee-setting methodology and provide feedback through CAA’s CAISA survey page through August 15.

Key Takeaways for Promo

The two most important steps your company can take now are to register with the designated PRO for each state to ensure compliance and to collect your company’s packaging data and prepare to report it according to state-specific criteria and deadlines. (So far, only CAA has been selected across the seven states, but other PROs or SOs may emerge.)

PPAI is working to develop industry-specific guidance help members navigate these regulations. In the meantime, CAA provides guidance for producers in its Producer Resource Center. CAA and any other PRO should be able to help determine whether your company qualifies as a “producer” and any resulting obligations under each state law, as well as estimate potential fees.

For questions or suggestions on regulatory or government affairs issues, please contact Rachel Zoch. PPAI’s public affairs manager, at RachelZ@ppai.org.