How to File the Oregon Producer Data Report (SB 582)
May 19, 2026 · 11 min read
Oregon's EPR program is further along than most — fees are already being invoiced, and the CY 2024 reporting deadline has passed. If you sell packaged products into Oregon and haven't filed, you need to act now. This guide covers everything you need to file accurately and handle late compliance.
At a glance
If you missed the CY 2024 deadline
The CY 2024 Producer Data Report was due March 31, 2025. That deadline has passed. Oregon DEQ has published a list of 250+ non-compliant producers. Penalties are up to $25,000/day. File immediately with best-available data for CY 2024 — late filing is far better than continued non-compliance.
Step 1: Confirm you are obligated
You must file if you are a “producer” under SB 582 — brand owner, licensee, importer of record, or first distributor of a packaged product sold into Oregon — and your aggregated global gross revenue exceeds $5 million. There is no volume threshold; revenue alone determines exemption.
Aggregation matters: if your company and its associated entities (parent, subsidiaries, brands under common ownership) together exceed $5M globally, each entity is obligated individually. You cannot split revenue across entities to stay under the threshold.
NAW injunction: The Natural Awakenings Worldwide (NAW) injunction limits enforcement against NAW members only. All other producers remain fully subject to penalties. The trial is set for July 13, 2026 — do not assume the injunction protects you unless you are an NAW member as of February 6, 2026.
Step 2: Understand Oregon's broader scope
Oregon covers more material types than California:
Covered in Oregon
- Single-use packaging (consumer-facing)
- Tertiary/shipping packaging (B2B + B2C)
- Printed paper / writing paper
- Food service ware (all materials)
Exempt in Oregon
- Under $5M global revenue (aggregated)
- Beverage containers under OR bottle bill
- Packaging with 65%+ recycling rate (70% after 2030)
Printed paper is a category unique to Oregon. If you sell catalogs, directories, or office paper into Oregon, you must report that weight separately from packaging materials.
Step 3: Map your materials to Oregon categories
Oregon uses approximately 60 material categories under the Recycling Modernization Act. The major groups are:
| Category | Examples | Est. Fee ($/lb) |
|---|---|---|
| Readily recyclable plastic | PET (#1), HDPE (#2), PP (#5) containers | $0.07–0.18 |
| Non-recyclable plastic | PS (#6), PVC (#3), multi-layer pouches | $0.33–0.66 |
| Corrugated cardboard | Shipping boxes, corrugated trays | $0.02–0.07 |
| Paperboard | Cartons, folding boxes, labels | $0.04–0.11 |
| Glass | Bottles, jars | $0.02–0.07 |
| Aluminum | Cans, foil, closures | $0.02–0.04 |
| Steel | Cans, drums, strapping | $0.04–0.09 |
Step 4: Calculate weight by material for Oregon
The calculation follows the same approach as other states, but use your Oregon-specific revenue percentage:
Calculation: Weight per unit × national units sold × OR revenue % = Oregon weight per material category.
Example: 50,000 kg total PET nationally. At 3% OR revenue: 50,000 × 0.03 = 1,500 kg PET reported to Oregon.
Don't reuse your CA percentage for OR. Oregon has a smaller population and likely a different revenue split. Use your actual Oregon revenue data from your accounting system. If you sell through distributors, request sell-through data by state.
Step 5: Handle late filing for CY 2024
If you missed the March 31, 2025 deadline for CY 2024 data, here is your playbook:
- File immediately. Do not wait. Late filing with estimates is infinitely better than non-filing with $25,000/day exposure.
- Use 2024 data. Pull your 2024 sales records, packaging purchase orders, and shipping data for CY 2024. Do not substitute 2025 data.
- Document your methodology. Explain in the CAA portal notes that this is a late filing and describe your data sources. “Best data available” is the legal standard.
- File the CY 2025 report separately. The May 31, 2026 deadline for CY 2025 data is a separate filing. Do not combine the two.
- Consider requesting abatement. If DEQ contacts you about penalties, you can request a penalty abatement based on good-faith voluntary compliance. Filing before they contact you is the strongest evidence of good faith.
Step 6: Register and submit through CAA
All Oregon EPR reports are filed through the CAA Producer Portal:
- Go to circularactionalliance.org/producer-resource-center
- Create a producer account (if not already registered)
- Select Oregon as a covered state
- Complete the Annual Supply Report form — enter weight by material category in pounds
- Include your revenue allocation methodology
- Submit before May 31, 2026 (CY 2025 data) — or immediately if filing late for CY 2024
Oregon fees are already active — CAA has published fee rates and is invoicing producers. Your Supply Report data directly determines your invoice amount.
Oregon vs. other EPR states — key differences
| Feature | Oregon | California | Colorado |
|---|---|---|---|
| Exemption | <$5M global | <$1M CA | <$5.5M OR <1 ton |
| Printed paper | Covered | Not covered | Covered |
| B2B packaging | Covered | Covered | Exempt |
| PCR reporting | Not required | Not required | Mandatory |
| Source reduction | Not required | Required | Not required |
| Recycling rate exemption | 65% (70% after 2030) | 70% | None |
| Penalties | $25,000/day | $50,000/day | $5,000 + $1,500/day |
Filing checklist
- Confirm your aggregated global revenue exceeds $5M (obligated) or document exemption
- Inventory all packaging components per SKU — including printed paper and food service ware
- Assign each component to an Oregon material category (~60 categories)
- Calculate weight per component per unit (grams → pounds)
- Calculate national totals × Oregon revenue percentage for each category
- If late for CY 2024: prepare 2024 data separately from 2025 data
- Register with CAA Producer Portal (if not already done)
- Enter weight data and revenue allocation method in portal
- Submit CY 2025 report before May 31, 2026 (and CY 2024 immediately if late)
Official resources: CAA Oregon Portal · Oregon DEQ Producer Responsibility · CAA Producer Resource Center · EPR Fee Check — Oregon