This article appeared in the February 2024 issue of Resource Recycling. Subscribe today for access to all print content.

Two of the four states that passed extended producer responsibility (EPR) laws for packaging have selected the Circular Action Alliance (CAA) to serve as their producer responsibility organization (PRO), and the other two states will accept applications in the next two years. 

The CAA is a national nonprofit group formed to fulfill PRO requirements in various states. It was formed by some of the biggest brand names in the packaging sphere and aims to be the approved PRO in all states that have EPR for paper and packaging. 

The founders include The Coca-Cola Company, General Mills, Keurig Dr Pepper, Procter & Gamble, Nestlé and several other heavyweights. 

Colorado and California officially selected CAA as their PRO, and Maryland selected the group to sit in the PRO seat on an advisory council over a needs assessment in the state. Though Maryland has not passed EPR for packaging, the needs assessment project is widely seen as part of a larger push to move toward EPR in the state in future years.

CAA has submitted a letter of intent in Oregon, and challengers have lately removed themselves from the running. In that state, interested PROs submit their entire plan for the program as an
application, and the state will then choose one—or a combination of several plans—that it feels will serve it best. The deadline is March 31, 2024. 

Maine will not release its request for proposal (RFP) for PRO involvement until late 2025. 


The California Department of Resources Recycling and Recovery (CalRecycle) announced on January 8 that CAA will serve as the PRO under its EPR law, SB 54. It will be responsible for developing and submitting a producer responsibility plan, source reduction plan, annual budget and annual reports to CalRecycle as well as submitting data and setting fees for participant producers. 

In a statement to Resource Recycling, CAA said it was “honored to be selected as the PRO in California.” 

“We look forward to supporting all producers as they prepare to comply with SB 54 and to working collaboratively with CalRecycle, the Advisory Board, local governments, recyclers and the many stakeholders who will play a role in delivering the requirements of the law,” CAA said.

In a press release, Charlie Schwarze, CAA board chair and senior director of sustainability at Keurig Dr Pepper, added that the appointment “further advances our vision to build a circular economy for packaging at scale across the United States.”

“CAA is composed of some of the most respected companies in food, beverage, consumer goods and retail that have come together to deliver harmonized best-in-class compliance services, scale innovation and build systems that help both companies and consumers waste less and recycle more,” Schwarze said. 

CalRecycle plans to start holding workshops in the coming months on its draft rules for SB 54. The regulations will be fully adopted in 2025, and the first recycling rate deadlines will occur in 2026, ramping up through 2032. 


Colorado was the first state to select a PRO in May 2023. 

At the time, CAA noted in its letter of intent that “to ensure that we can deliver on timelines and requirements outlined in the statute, we have assembled a team of EPR experts with experience in the development, implementation and operation of producer responsibility programs in North America.” 

Since May, CAA has been working to carry out the state’s needs assessment with assistance from HDR Engineering and Eunomia Research and Consulting. Colorado’s EPR advisory board members have been expressing concerns about the accuracy of data used in the scenario modeling. 

The advisory board also decided to hold more frequent meetings in recent months to keep up with the pace of the information-
gathering process, as the findings were set to be finalized by January 30 and cover the recycling services currently provided in the state and the needs that are not being met. 

A plan for the program, which will set minimum recycling rate targets for 2030 and 2035, is due by February 1, 2025. The full program is intended to roll out in 2026. 


Maine officially started its formal EPR rulemaking process in late December by submitting its draft rules to the state Board of Environmental Protection. Now, the board is expected to adopt the routine/technical rules and approve the provisional adoption of major substantive rules by summer 2024. 

Final adoption of the major substantive rules will take place by the spring or summer of 2025. At that point, an RFP will go out for the creation of a stewardship organization, the entity through which producers will fulfill their requirements under the law. 

Maine has taken a different approach to EPR than the other three states in the U.S., namely by asking producers to directly reimburse cities and towns for recycling and disposal expenses.


Oregon was the first of the four states to approve an initial set of rules for the program on November 16, but there are a few months yet to go before the PRO landscape becomes clear. 

The Oregon Environmental Quality Commission adopted the first of two major administrative rulemakings for the Plastic Pollution and Recycling Modernization Act, covering standards for compensation for local governments, requirements for PROs, standards for responsible end markets and the first iteration of the statewide recycling acceptance lists. 

Initially, four groups indicated interest in serving as PROs and submitting a plan as an application, but now, CAA is the only group listed on the state site. Reverse Logistics Group was removed in the last week of January. 

To formally apply, prospective PROs will pay a fee to submit their plans by the end of March, leaving the state to choose either one PRO’s plan or a combination of the plans, which would then require the groups to work together to carry out the state’s vision. 

The latest date for the state to make a choice or to ask for revised plans, is September 27, 2024. If the state does ask for revised plans, the deadline to decide on the new plans would be February 24, 2025.

The selected plan will be implemented on July 1, 2025.

Marissa Heffernan is an associate editor at Resource Recycling and can be contacted at [email protected].