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Washington

Recycling Reform Act (SB 5284, 2025)

Registration Phase
PRO
Circular Action Alliance
Agency
Washington Department of Ecology
Exemption
Under $5M global revenue OR less than 1 ton of covered materials (EITHER qualifies)
Fees
Program begins January 2030. PRO plan due Oct 2028.
Penalties
Up to $1K/day (1st violation), up to $10K/day (2nd+)

Who is a “producer”?

Under SB 5284, a “producer” is determined in the following order of responsibility:

  1. 1Manufacturer (if sold under manufacturer's brand or no brand)
  2. 2Licensee (if licensed to manufacture/sell under another's brand)
  3. 3Brand owner
  4. 4Importer of record into the US for sale in WA
  5. 5Person who first distributes the item in or into WA
  6. 6Publisher (for paper products — magazines, catalogs, directories)

B2B packaging is explicitly exempt in Washington.

What's covered

Covered

  • ✓Consumer packaging (plastic, glass, paper, metal)
  • ✓Paper products
  • ✓Single-use food/beverage items
  • ✓Online/e-commerce sales (noncommercial use)

Not Covered / Exempt

  • ✕De minimis producers (<$5M global OR <1 ton into state)
  • ✕B2B packaging (explicit — distributed to commercial entity for production)
  • ✕Packaging with 65%+ recycling rate (70% after 2030)
  • ✕Infant formula, medical food, fortified nutritional supplements
  • ✕Drugs/medical devices/biologics (FDA regulated)
  • ✕EPA-regulated pesticides/FIFRA products
  • + 6 more exemptions

Key Deadlines

DateWhat's DueStatus
Jan 1, 2026Producers must appoint a PROPASSED
Feb 15, 2026Register with CAA for WAPASSED
Mar 1, 2026PRO must register with Ecology on behalf of producersPASSED
Jul 1, 2026Producers must be member of PRO or register as independent PROUPCOMING
Sep 1, 2026PRO makes one-time payment to EcologyUPCOMING
Dec 31, 2026Preliminary needs assessmentUPCOMING
Mar 31, 2027Annual registration fee determined by EcologyFUTURE
Dec 31, 2027Full needs assessmentFUTURE
Oct 1, 2028PRO proposes draft plan with performance targetsFUTURE
Jul 1, 2029Ecology approves PRO planFUTURE
Mar 1, 2029No unregistered producer may introduce covered materialsFUTURE
Jan 1, 2030Program implementation beginsFUTURE

Official Resources

Washington Department of Ecologyecology.wa.gov/waste-toxics/reducing-recycling-waste/our-recycling-programs/recycling-reform-actCAA Washington Portalcircularactionalliance.org/circular-action-alliance-washington

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