EPR Deep Dive: Oregon
Background
The Oregon Recycling Modernization Act (RMA) overhauls the state's recycling system and shifts a portion of recycling system costs from consumers to producers. Here, Snaplinc Consulting outlines key elements of the RMA, its business implications, and steps to ensure regulatory alignment.
Key Components
The Oregon EPR act introduces significant changes to how recycling is managed and funded in the state. These changes fall under two key areas that impact businesses:
Producer Responsibility Organizations (PROs): Companies impacted by the act must join a PRO. PROs will collect fees from companies to fund the end of certain material’s lives, which includes processing and recycling.
Circular Action Alliance (CAA) is in position to become the PRO for Oregon. CAA intends to submit a third and final program plan in December 2024 before being confirmed as the state’s PRO.
Education and Outreach: Businesses must ensure that their packaging complies with clear recycling instructions to avoid consumer confusion and decrease contamination.
Who is Affected
The Oregon EPR act impacts all businesses that are legally determined to be “producers” of residential and commercial packaging, printing and writing paper, and food serviceware.
Pertinent Dates
March 31, 2025: Producers must report data covering the 2024 calendar year.
There are 62 draft data reporting categories included in CAA’s Oregon program plan, still subject to Oregon Department of Environmental Quality approval.
Benefits and Opportunities
Though Oregon’s EPR act creates new responsibilities for businesses, it also presents several opportunities:
Sustainability Leadership: Companies that adapt early to these regulations can position themselves as sustainability leaders in their industry. Demonstrating compliance and proactive engagement with EPR can enhance a firm’s reputation, driving customer loyalty and potential new market opportunities.
Cost-Efficiency: Over time, streamlined recycling systems may reduce overall waste management costs for businesses, especially with more efficient recycling infrastructure and standardized processes.
Innovation in Packaging: Companies may explore the development of eco-friendly packaging solutions, reducing the long-term environmental impact of their products.
Penalties for Non-Compliance
Reputational damage: The PRO plans to publish a list of non-compliance member organizations. Brands will suffer reputational damage from lack of compliance.
Fines up to $25,000 per day: Oregon’s Department of Environmental Quality can fine non-compliant producers up to $25,000 per day, based on violator size, history, impact, intent, efforts to correct, and economic benefit of non-compliance.
Recommended Compliance Strategies
As leaders in the EPR compliance realm, Snaplinc Consulting recommends implementing a comprehensive compliance strategy as soon as possible. We recommend completing the following steps:
Early Engagement with PROs: Ensure your company is registered with a PRO and begin assessing the financial implications of new recycling responsibilities.
Packaging Audits: Conduct a thorough review of your company’s packaging materials. Transition to more sustainable and recyclable options where possible to minimize fees and improve compliance.
Employee and Consumer Education: Train your employees on the new recycling standards and ensure that your product packaging communicates clear recycling instructions to consumers.
Technology Investments: Invest in packaging innovation and recycling technologies to meet the act’s requirements while staying ahead of competitors.
Data Collection: Review the 62 draft data reporting categories included in CAA’s Oregon program plan and begin collecting data for the 2024 calendar year.
How Snaplinc Consulting Can Support
Navigating the complexities of the Oregon EPR act requires a strategic approach; Snaplinc supports brands in achieving full compliance while maximizing opportunities. We provide tailored solutions that help companies not only meet regulatory requirements but also align with broader sustainability goals. Here’s how we can help:
Comprehensive Compliance Audits: We conduct detailed assessments of your current packaging materials and waste management practices to identify areas where changes are needed to comply with the act. This includes evaluating recyclability, sustainability, and the efficiency of your waste streams.
Producer Responsibility Organization (PRO) Navigation: We guide you through the process of joining a PRO, ensuring that your business understands its responsibilities and selects the most cost-effective and compliant approach.
Packaging Redesign and Innovation: Our team helps you transition to sustainable, recyclable, and compliant packaging solutions. We provide insights into material alternatives and design strategies that reduce environmental impact while meeting the act’s stringent recycling requirements.
Training and Internal Education: We offer comprehensive training programs for your team to ensure they understand the new recycling standards and can implement best practices across your organization.
Consumer Communication and Labeling: Our experts assist with creating clear, compliant labeling for your products, ensuring that consumers know how to properly recycle your packaging, thus reducing contamination and improving recycling rates.
Ongoing Monitoring and Reporting: As the act evolves, we provide ongoing support to keep your business up to date with any regulatory changes. We also assist in submitting reporting to demonstrate compliance and environmental performance to regulators and stakeholders.
Conclusion
Oregon’s Recycling Modernization Act represents a significant shift toward producer responsibility, with far-reaching implications for businesses. Businesses must prioritize compliance by collaborating with PROs, rethinking packaging strategies, and investing in recycling innovation. Embracing these changes not only ensures regulatory compliance but also aligns your company with broader sustainability trends that can enhance both corporate image and financial performance.
By taking these steps, businesses can turn compliance into an opportunity for growth, innovation, and leadership in sustainability.
For more information on the act and how your business can prepare, visit Oregon’s Recycling Modernization Act Resources.