Editor’s note: For a deeper look at how CAA grew from a startup with zero employees to the backbone of US packaging EPR policy, read our full feature in the upcoming print edition of Resource Recycling.
The Circular Action Alliance (CAA) didn’t have a blueprint.
When the producer responsibility organization (PRO) formally incorporated as a 501(c)3 nonprofit in December 2022, no comparable entity existed in the United States. Paper and packaging EPR was new territory, and the infrastructure to implement it was being built from scratch by people who, in many cases, had to be found in Canada and Europe because the domestic expertise didn’t exist yet.
CAA relied on consultants in the beginning, making its first full hire in April of 2024. Since then, the organization has ballooned to 170 employees, with active programs in Oregon, Colorado and California and reporting deadlines that rolled through Minnesota, Washington and Maryland on May 31, 2026. More states are on the lineup.
As the organization scales, so does the persistent question of what CAA actually is, and its role in the ecosystem of extended producer responsibility (EPR) legislation.
Can we build it?
The confusion is understandable. CAA sits at the intersection of being a nonprofit, compliance vehicle and the only multi-state producer responsibility organization in the United States.
Jeff Fielkow, CAA’s CEO, offers the clearest definition: “We take the law, and we build a plan that will help producers to achieve compliance under that law.”
Role distinction matters. CAA does not set EPR targets. It does not lobby for new legislation. It does not issue penalties. The states enforce while CAA implements. When a producer violates compliance requirements, enforcement falls to state agencies, not CAA.
“People say, ‘Well, are you part of the government, or can you enforce a penalty on me?’ ” he said. “That’s not our role. We’re building. We support the producers.”
Fielkow describes it as putting on a construction hat, alluding to “Bob the Builder,” a popular US children’s series. Legislators write the statute, regulators write the rules and CAA builds the program plan that translates both into operational reality.
Authority song
Critics including environmental groups have been challenging California’s SB 54 framework and argue that CAA holds too much authority over fee-setting with insufficient public accountability. The organization disputes that characterization directly.
“We’ve been transparent. We continue to be transparent. We will always be transparent,” Fielkow said. “Everything we’ve ever done — when we build a program plan or an idea — we take it to public consultation. We’ve had thousands of people on our webinars. We post our documents publicly. We take feedback from interested parties all the time, and we make those changes. There’s never been anything done in a secretive manner.”
On fee-setting specifically, Fielkow said the biggest driver of cost for producers isn’t CAA’s methodology, it’s noncompliance.
Producers who don’t register push up costs for those who do, he said. “If the three of us went out and bought a pizza and one of us didn’t pay the bill, my bill’s high. But if we split the bill equally, it’s reasonable for everybody,” he said.
CAA’s program plans are public documents that require state approval before taking effect. The organization is also required by law to publicly report which producers have registered with CAA. Enforcement authority stops there.
No slowing down
The compliance picture is constantly moving. May 31 reporting deadlines passed for Minnesota, Washington and Maryland, designed to establish baselines for eventual fee calculations. Oregon is operating in its second year of full implementation. Colorado launched recently. California’s 2027 implementation is already driving rapid internal scaling at CAA.
Washington and Maryland remain in the emerging-state category, still finalizing regulatory frameworks. Maine is in the process of selecting a PRO. CAA is already drafting an early version of Maryland’s program plan, even though the state doesn’t go live until July 2028.
“There’s no slowing down here,” Fielkow said. “There’s always something we’re building, and there’s always something we’re implementing, and there’s always something we’re operating.”
Fielkow acknowledged that producer compliance across multiple states is one of the steeper learning curves CAA is managing. The organization’s approach is a unified portal that allows producers registered in one state to add coverage in additional states by clicking through a state-specific agreement without starting over.
Producers who need help locating their own data, such as tracing packaging materials through supply chains, are directed to third-party consultants rather than CAA. The organization’s role is limited to making it easy to upload and report data once producers have it, Fielkow said.
The road ahead
CAA’s position on future policy is cemented in implementation. The organization does not advocate for EPR in states that haven’t passed laws. It won’t form a position on what “good” EPR looks like in a legislative context.
“We are not a lobbying firm that goes to states that don’t have law,” Fielkow said. “We’ll provide purely facts if somebody asks what good EPR looks like, but that’s it.”
For now, the organization is focused on deepening implementation in existing states, building toward California’s complex 2027 launch and developing the internal competency to stand up new state programs without starting from zero each time.
“Starting the first state was probably still easier than starting the third state, which is California,” Fielkow said. “But starting states four, five and six will be relatively easy, because we already know how to build program plans.”
