Oregon’s packaging EPR program has its first list of noncompliant producers.
On April 9, the Oregon Department of Environmental Quality (DEQ) released its inaugural quarterly producer status list under the Recycling Modernization Act, flagging 250 companies for failing to register, report and/or pay fees required under the law.
Penalties for noncompliance can reach $25,000 per day, and the Oregon Department of Justice may move to prohibit the sale of noncompliant products in the state.
The list includes some recognizable household names: Yamaha Motor, Mercedes-Benz North America, Ingersoll Rand, Trident Seafoods, Papa John’s, Hobby Lobby and Jack in the Box are among the noncompliant producers identified.
Circular Action Alliance (CAA), the producer responsibility organization overseeing program implementation, initiated the enforcement process by notifying producers under ORS 459A.869(10)(a). Companies on the list received 90 days’ notice from CAA, followed by formal warning letters from DEQ issued March 5, starting a 30-day correction clock. The 250 producers listed had not come into compliance by the end of that period.
The ruling came shortly after a US District Court order on April 1 clarified that a preliminary injunction barring enforcement applied only to members of the National Association of Wholesaler-Distributors (NAW) who held that membership as of February 6, 2026.
The injunction stemmed from a February 6 ruling by Judge Michael H. Simon of the US District Court for the District of Oregon, who granted NAW’s motion for a preliminary injunction pausing enforcement of the RMA against its members while a constitutional challenge to the law proceeds. That trial is currently scheduled for July 13, 2026.
DEQ has made clear it intends to press forward against producers outside the injunction’s scope. When additional trade associations formally requested a broader enforcement pause in February, the agency responded that there was no basis for refunding fees and that the statutes requiring payment remain in effect.
