CAA has submitted updated REM program plan in Oregon

In early February, the Circular Action Alliance (CAA) Oregon submitted an updated Responsible End Market (REM) program plan amendment to the Oregon Department of Environmental Quality (DEQ). The move advances implementation of Oregon’s Recycling Modernization Act by strengthening how recyclable materials are verified as responsibly recycled, which is a cornerstone of the Recycling Modernization Act. 

According to CAA, the amendment balances the need to achieve the regulatory and statutory requirements of the law while also offering a practical starting point for engaging and educating the recycling industry on new requirements. It allows end-market verification to begin while work continues on a formal, harmonized REM certification standard intended for broad adoption across U.S extended producer responsibility (EPR) programs for packaging.

In addition to Oregon, EPR legislation for packaging is being enacted in California, Colorado, Maine, Minnesota, Maryland and Washington.

“Oregon has been a national leader in defining Responsible End Markets, and this amendment strengthens that leadership with a practical approach we can implement right away,” says CAA CEO Jeff Fielkow. “By advancing a solution that is both rigorous and workable for end markets, we’re establishing a harmonized system that fully supports Oregon’s priorities while building a framework that producers, processors and recyclers can rely on over the long term.”

CAA says the submission strengthens Oregon’s interim verification approach and supports the development of a comprehensive, auditable standard for eventual consideration by the Environmental Quality Commission (EQC).

The amendment accomplishes a number of objectives, the organization says:

• Affirms REM principles. The amendment is designed to meet the REM requirements of transparency, compliance, environmental soundness and adequate yields, with CAA adding that it remains committed to a practical, enforceable standard that protects proprietary information and helps maintain market stability.
• Interim pathway, then formal standard. The amendment creates an interim verification pathway until a formal third-party standard is developed with an ANSI-accredited standards developer and considered by the EQC.
• Built for Oregon, with a path to national harmonization. The verification approach meets Oregon’s regulatory requirements and is structured to support consistent REM verification across packaging EPR states, advancing a harmonized national framework. CAA adds that its long-term vision is to produce a standard that meets Oregon’s requirements and those of other EPR states.
• One of the most comprehensive assessments to date. Based on CAA’s review of existing EPR verification practices, the proposed approach is among the most comprehensive end-market assessments across jurisdictions with packaging EPR, in some areas exceeding current verification practices in the EU and Canada.

Kim Holmes, executive director of CAA Oregon, says, “Oregon led by putting Responsible End Markets into law, and this amendment moves that work forward in a way that meets the spirit of the law and will bring assurance to Oregonians that their participation in recycling is not causing undue burden to the environment and other communities. Our goal is to develop a robust system that upholds Oregon’s requirements and gives end markets confidence to participate at scale.”

Public comments can be submitted through March 27, 2026. Interest holders can share their feedback by attending an Oregon Recycling Council Meeting, emailing DEQ at  RethinkRecycling@deq.oregon.gov or visiting RecyclingAct.Oregon.gov to learn more. 

DEQ and the Oregon Recycling System Advisory Council (ORSAC) will review the amendment and provide approval, conditional approval or send it back to CAA for additional work. If the proposal is sent back to  CAA, the organization will have a final opportunity to submit a third version of the amendment, which DEQ can accept or direct binding changes. While the process advances, CAA says it will continue working with end markets and other interested parties.

While the U.S. District Court in Oregon dismissed multiple claims against the Oregon Department of Environmental Quality (DEQ) and issued a narrow preliminary injunction in the National Association of Wholesaler‑Distributors (NAW) lawsuit challenging Oregon’s RMA in early February, this injunction temporarily pauses DEQ enforcement of the RMA against producers who are members of NAW. A hearing on the matter is scheduled for July.

CAA is not a party to this lawsuit and says its focus remains on continuing to implement Oregon’s RMA and other EPR programs.