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Washington EPR Guide
Recycling Reform Act (SB 5284, 2025)
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
Early fee schedule published Oct 1, 2026 — 2027 early-fee rates $0.002–$0.030/lb across 8 simplified material categories, funding program development and startup until the full program begins. PRO pays Ecology for initial implementation Sep 1, 2026 and annually beginning May 1, 2027.
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:
- 1Manufacturer (if sold under manufacturer's brand or no brand)
- 2Licensee (if licensed to manufacture/sell under another's brand)
- 3Brand owner
- 4Importer of record into the US for sale in WA
- 5Person who first distributes the item in or into WA
- 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 (<$5M global OR <1 ton into state)
- ✕B2B packaging (explicit — distributed to commercial entity for production)
- ✕Packaging with 65%+ recycling rate (70% after 2030)
- ✕Infant formula, medical food, fortified nutritional supplements
- ✕Drugs/medical devices/biologics (FDA regulated)
- ✕EPA-regulated pesticides/FIFRA products
- + 6 more exemptions
Fee Rates (Washington)
2027 early-fee rates per pound from CAA's Oct 1, 2026 schedule. Early fees fund program development and startup — they are not final program rates (full program begins later).
Simplified groupings for estimation. The official CAA schedule has material categories — see the downloadable rate schedule PDF below for exact rates by material type.
| Material | Rate ($/lb) |
|---|---|
| Paper/Fiber (corrugated cardboard) | $0.01 |
| Paper/Fiber (paperboard & mixed paper) | $0.01 |
| Glass & Ceramics | $0.00 |
| Metal (aluminum) | $0.01 |
| Metal (steel/tin) | $0.01 |
| Rigid Plastic (all rigid) | $0.01 |
| Non-recyclable rigid plastic (charged at Rigid Plastic rate) | $0.01 |
| Flexible Plastic (all film) | $0.03 |
| Non-recyclable flexible plastic (charged at Flexible Plastic rate) | $0.03 |
⚠ Washington 2027 fees are early fees only — final program rates come later. Download CAA 2027 fee schedule (PDF) →
Calculate Your Washington Fees →Key Deadlines
| Date | What's Due | Status |
|---|---|---|
| Jan 1, 2026 | Producers must appoint a PRO | PASSED |
| Feb 15, 2026 | Register with CAA for WA | PASSED |
| Mar 1, 2026 | PRO must register with Ecology on behalf of producers | PASSED |
| May 31, 2026 | Interim Producer Report (Simplified Reporting Categories) | PASSED |
| Jul 1, 2026 | Producers must be member of PRO or register as independent PRO | PASSED |
| Sep 1, 2026 | PRO makes one-time payment to Ecology | PASSED |
| Dec 31, 2026 | Preliminary needs assessment | UPCOMING |
| May 1, 2027 | PRO annual payment to Ecology begins + early fee obligations begin (annual) | FUTURE |
| Dec 31, 2027 | Full needs assessment | FUTURE |
| Oct 1, 2028 | PRO proposes draft plan with performance targets | FUTURE |
| Jul 1, 2029 | Ecology approves PRO plan | FUTURE |
| Mar 1, 2029 | No unregistered producer may introduce covered materials | FUTURE |
| Jan 1, 2030 | Program implementation begins | FUTURE |
Official Resources
Washington Department of Ecologyecology.wa.gov/waste-toxics/reducing-recycling-waste/our-recycling-programs/recycling-reform-actCAA Washingtoncircularactionalliance.org/circular-action-alliance-washingtonProducer Resource Centercircularactionalliance.orgWashington — Circular Action Alliancecircularactionalliance.org2027 WA Early Fee Schedulecircularactionalliance.org2027 Washington Early Fees Scheduleeprfeecheck.comRCW 70A.208app.leg.wa.gov
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