Do you sell packaged products under your brand name in California, Colorado or Oregon? Then your company likely has a legal obligation to register with the Circular Action Alliance (CAA), a nonprofit Producer Responsibility Organization (PRO) dedicated to implementing extended producer responsibility (EPR) laws for paper and packaging across the United States. Registration is free and must be completed by July 1, 2024.

To date, four states have enacted packaging recycling laws: California, Colorado, Maine and Oregon. These states are in the process of deciding how to implement their laws, and which participants in the chain of distribution have obligations under the laws. At this point, California and Colorado have approved CAA to be the PRO to implement their respective paper and packaging EPR laws, and Oregon is expected to approve CAA as its PRO by late 2024. Maine will not accept PRO applications until late 2025.

Each state’s law is different. ISPA encourages members to consult with legal counsel to decide exactly what your obligations are under each law. In general, companies that sell packaged products under their brand names in these four states will be required to fund programs to recycle the packaging material. Some states are expected to regulate only packaging on the finished product, but others may regulate packaged components as well as additional packaging that an online retailer might add to a finished product. Meanwhile, those companies that have obligations under the laws must register with CAA by July 1, 2024 by completing the Covered Producer Registration Form.

Penalties may apply if you miss this deadline. In Colorado, unless you intend to submit your own program plan, the state may fine you if you do not register with CAA by July 1, 2024.Registered companies will also receive updates from CAA as each state proceeds to launch its program. Since the definition of who is a producer with registration obligations differs slightly from state to state, the form provides some information to help a company confirm whether it has a registration obligation.

Companies may update their registration information as needed. For more information, please visit CAA’s website. If you have additional questions, please email [email protected].