What Is a PRO? EPR Guide for Brands

If your brand sells packaged products in any state with an EPR packaging law, you are legally required to register with a Producer Responsibility Organization (PRO). But most brands have never heard of a PRO — and the name alone creates confusion. This guide explains what a PRO is, what it does, which one covers your state, and what you need to do next.

What is a Producer Responsibility Organization?

A Producer Responsibility Organization (PRO) is the entity designated by each state to administer the EPR packaging compliance program on behalf of producers. The PRO collects registration data, receives annual packaging weight reports, calculates and invoices fees, and distributes collected funds to recycling infrastructure within the state.

Think of it this way: the state passes the law and defines the rules, but the PRO is the organization that actually runs the program. Producers don't pay fees directly to the state — they pay the PRO, which then allocates the money to municipalities, recyclers, and infrastructure projects as required by law.

In most US EPR states, the PRO is Circular Action Alliance (CAA), a non-profit producer responsibility organization formed by major brands and packaging companies to fulfill EPR obligations. Maine uses the term “Stewardship Organization” instead of PRO, but the role is identical.

What does a PRO actually do?

A PRO's responsibilities are defined by each state's law, but generally include:

• Producer registration — Creates and manages the portal where brands sign up, provide business information, and declare themselves as obligated producers.
• Data collection — Receives annual packaging weight reports from producers, broken down by material type (plastic, glass, aluminum, paper, etc.).
• Fee calculation and invoicing — Applies the state's fee schedule and eco-modulation credits/maluses to calculate each producer's total obligation.
• Revenue disbursement — Distributes collected fees to municipalities, recycling programs, and infrastructure projects as mandated by the state's EPR law.
• Stewardship planning — Develops and submits stewardship plans to state agencies, outlining recycling targets, source reduction goals, and program budgets.
• Reporting to the state — Provides compliance data, program performance metrics, and financial reports to the overseeing state agency.

The PRO is not a government agency — it's an independent organization that the state has approved or designated to run the operational side of EPR compliance. The state agency (like CalRecycle, Oregon DEQ, or CDPHE) provides oversight and enforcement, while the PRO handles day-to-day operations.

PRO vs. State Agency — what's the difference?

In practice, you interact with the PRO for registration, reporting, and fee payment. The state agency is who enforces the law and penalizes non-compliance.

Which PRO covers your state?

Every EPR state has a designated PRO. Here's the current mapping:

Key takeaway:Circular Action Alliance is the PRO for 6 of 7 EPR states. Maine's Stewardship Organization is still being selected through an RFP process.

Circular Action Alliance — the PRO for most states

Circular Action Alliance (CAA) is a non-profit producer responsibility organization formed by leading consumer goods and packaging companies. It was created specifically to serve as the designated PRO for US EPR packaging laws, and is currently the approved or sole PRO in:

• California — CAA is the approved PRO under CalRecycle oversight
• Oregon — CAA is the approved PRO under Oregon DEQ oversight
• Colorado — CAA is the approved PRO under CDPHE oversight
• Minnesota — CAA is designated, registration open
• Maryland — CAA is active; state allows multiple PROs
• Washington — CAA is the designated PRO under Ecology oversight

If you sell packaged products into any of these six states, you register with CAA — but you must register separately for each state. A single CAA registration does not cover all states. Each state has its own reporting requirements, fee schedules, and deadlines.

Register at circularactionalliance.org and select the relevant state program(s).

Maine — Stewardship Organization (PRO equivalent)

Maine's EPR law (LD 1541) uses the term “Stewardship Organization” instead of “Producer Responsibility Organization,” but the function is the same. The Maine DEP is currently running an RFP process to select the SO, with a decision expected by mid-2026.

Circular Action Alliance has also registered in Maine, but the final selection is pending. Producers selling into Maine should monitor the Maine DEP EPR page for updates on the SO selection and registration timeline.

How to register with a PRO — step by step

Registration is the first mandatory step for EPR compliance. Here's what you need to do:

1. Determine your obligations — Check which states you sell packaged products into and whether you meet the revenue or volume threshold. Use our free Am I Covered? tool to find out in 60 seconds.
2. Visit the PRO registration portal — For CAA states, go to circularactionalliance.org and select each state where you need to register. For Maine, monitor the DEP website for the SO selection announcement.
3. Provide your business information — Legal name, EIN, brand names, contact details, and a list of packaging materials you sell into the state.
4. Submit packaging weight data — Total weight by material type (recyclable plastic, non-recyclable plastic, corrugated cardboard, paperboard, glass, aluminum, steel). This is required for fee calculation.
5. Claim eco-modulation credits — If applicable, document mono-material packaging, PCR content, consumer recycling labels, or source reduction efforts to reduce your fees. See 7 strategies to reduce your EPR fees →
6. Pay fees and maintain compliance — After registration and reporting, the PRO will issue fee invoices based on your packaging data and the state's fee schedule. Estimate your fees with our calculator.

Common PRO mistakes brands make

• Registering in one state and thinking you're done — You must register separately for each state. A California CAA registration does not cover Oregon or Colorado.
• Thinking registration equals compliance — Registration is step one. Annual reporting and fee payment are separate requirements.
• Waiting until the deadline — PRO registration portals can be slow near deadlines. Register early and start collecting packaging data now.
• Assuming small businesses are exempt — Exemption thresholds vary by state and many only exempt very small brands ($1M-$5M revenue). Check your exemption status →
• Not documenting eco-modulation credits — You can reduce fees by 15-30% with eco-modulation, but you need documentation. Claim these credits during reporting.
• Confusing the PRO with the state agency — You interact with the PRO for registration, reporting, and fee payment. The state agency enforces the law and can fine you for non-compliance.

Upcoming states and new PROs

EPR packaging laws are expanding rapidly. Three more states have active bills:

• Illinois (HB 3386) — Bill in progress. If enacted, a PRO selection process will follow.
• New Jersey (S3398) — Bill in progress. Similar PRO designation process expected.
• New York — Broader EPR bill in committee. Early planning recommended.

As each state enacts its law, it will designate or approve a PRO (likely CAA in most cases). If you sell packaged products in these states, start collecting packaging data now — the lead time for compliance can be 6-12 months.

Key PRO registration deadlines

Don't miss these critical dates:

See the full deadline calendar →

PRO FAQ