On Oregon DEQ's producer status list? What it means and what to do
Oregon DEQ publishes a quarterly "producer status list" as part of enforcing the state's packaging law, the Recycling Modernization Act. Under the enforcement process, producers that are flagged to DEQ and don't correct after a warning letter are listed. If your company is on it, settle it quickly: either show DEQ you're exempt (for example under $5 million in global revenue, or under 1 metric ton of packaging into Oregon), or register with the Circular Action Alliance (CAA), report and pay. DEQ's contact for corrections is rethinkrecycling@deq.oregon.gov.
What the list is
Who publishes it: Oregon DEQ writes it. It is hosted on CAA's Oregon page, not on DEQ's own site.
Format: a PDF with one column, "Producer Name". There are no addresses, reasons or categories. An asterisk next to a name means the producer's submission is under DEQ review.
How often: DEQ says it will be updated quarterly.
Latest list: as of September 4, 2026, with 198 producers, 3 of them asterisked.
History: the first list was dated April 9, 2026, with roughly 250 to 300 names. No July 2026 list was found, so September's is the second. Roughly 187 April names were dropped and 81 added.
How producers end up on it
Oregon's process: CAA flags a producer to DEQ after 3 months of failed collection, with 90 days' notice. DEQ then sends a Warning Letter with an Opportunity to Correct, giving 30 days. Producers that don't correct are listed. Separately, Oregon requires producers that aren't exempt to register with CAA before selling covered products into the state, and failing to register or join a PRO is a Class I violation.
For packaging that holds the product, the producer is normally the brand owner. A brand that has a co-packer make its product and sets the packaging specs counts as the producer. For shipping boxes and fill, it's whoever packs and ships the item to the consumer.
Oregon's exemption tests
Meeting any one of these exempts you:
Less than $5,000,000 in global gross revenue in your most recent fiscal year.
Less than 1 metric ton of covered products sold or distributed into Oregon in the most recent calendar year.
Bottle-bill beverage manufacturers selling under 5 metric tons of covered products into Oregon.
501(c)(3) nonprofits and public bodies.
A restaurant or food cart that isn't the producer of its food serviceware.
A single retail location with no online sales, not part of a franchise or chain.
Revenue and tonnage are added up across "associated producers": companies with more than 50% common ownership, controlled groups, family ownership and trusts. Exempt producers don't register, report or pay, and there is no exemption form. DEQ recommends registering if you're near the thresholds.
Penalties
Up to $25,000 per violation per day.
Oregon's Department of Justice can sue to bar sales of a non-compliant producer's products.
Late registrants with CAA must report and pay for every prior period they were obligated, with interest.
Oregon's law was upheld in full by a federal district court on August 27, 2026. An appeal to the 9th Circuit was filed on September 24, 2026, with no stay reported.
Check whether you're already registered: CAA publishes a searchable registry of Oregon producer members (PDF, about 3,900 names, updated September 22, 2026).
If you're exempt, gather the evidence (revenue for your most recent fiscal year, including associated companies, or pounds shipped into Oregon) and email DEQ at rethinkrecycling@deq.oregon.gov.
If someone else is the producer (for example the brand owner whose products you resell), say so to DEQ with the details.
If you're not exempt, register with CAA (free), then report and pay, including prior periods. Producers with 10 metric tons or less can use 2027 flat fees of $700 to $3,100.
Check the next quarterly list to confirm your name has been removed or asterisked.
Not sure which states you owe? Revenue and tonnage tests differ in every state.