With Extended Producer Responsibility (EPR) regulations taking effect across the U.S., small and medium-sized businesses (SMBs) in the Consumer Packaged Goods (CPG) sector must navigate complex compliance requirements. 

Oregon’s EPR law requires producers to manage and report packaging waste, with a key filing deadline of March 31, 2025. This guide simplifies the compliance process, helping businesses determine their obligations and reporting options.

Section One: Understanding Producer Classification

Oregon categorizes producers based on global gross revenue and total weight of covered materials sold in the state:

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Exempt Producers: Small businesses with less than $5M in revenue and less than 5 metric tons of covered materials sold.

• Low-Volume Producers: Companies below the $10M revenue threshold or selling less than 5 metric tons.
• High-Volume Producers: Companies exceeding both $10M revenue and 5 metric tons of materials.

High-volume producers must submit detailed weight-based reports, while low-volume producers have simplified reporting options.

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Section Two: Identifying the Best Reporting Option For You

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Three Reporting Options for Low-Volume Producers

Oregon offers three ways for low-volume producers to comply:

1. Comprehensive Reporting (Most Accurate & Cost-Effective)

• Requires reporting actual packaging weights by material category.
• Ensures precise fee calculation and potential cost savings.
• Best for brands planning to scale beyond $10M in revenue.

       Steps to Comply:

• Identify all affiliates, brands, and subsidiaries.
• Use an approved methodology (SMRM, ABOM) to calculate packaging weights.
• Categorize and report total material weight to the Circular Action Alliance (CAA).

2. Flat Fee Reporting (Simpler, but Less Optimized)

• Companies report total packaging weight without material breakdown.
• Fees are tiered based on total estimated weight.
• Easier administration, but potentially higher costs than weight-based reporting.

        Steps to Comply:

• Identify all affiliates and subsidiaries.
• Estimate total packaging weight using accepted methodologies.
• Submit data and pay the applicable flat fee.

3. No Reporting, Highest Flat Fee (Costliest & Least Flexible)

• Producers can skip reporting altogether by paying the highest applicable flat fee.
• Eliminates data collection but often results in overpayment.

        Who Chooses This?

• Companies struggling with packaging data collection.
• Brands seeking the simplest but most expensive compliance route.

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Reporting for High-Volume Producers

Companies that exceed $10M in revenue and 5 metric tons must complete a detailed reporting process:

• Calculate Supply Volumes – Track sales and packaging weight data.

• Use Accepted Weight Calculation Methods – SMRM (preferred), ABOM, or sector calculators.

• Categorize & Report Data – Submit material-specific weights to CAA.

This data-intensive process ensures compliance but requires robust tracking systems.

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Why Specific Material Reporting (SMRM) is the Best Choice

rePurpose Global encourages producers to adopt the Specific Material Reporting Method (SMRM), which:

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✔ Ensures accurate fee calculations (no overpayments).

✔ Aligns with future EPR regulations across other states.

✔ Helps brands qualify for eco-modulated incentives (lower fees for sustainable materials).

✔ Enhances supply chain transparency and sustainability insights.

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While ABOM (Average Bill of Materials) offers an estimated approach, it lacks precision and may result in higher costs over time.

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Key Deadlines & Compliance Checklist

📅 March 31, 2025 – First Oregon EPR report due.

📌 What You Need to Do Now:‍

☑ Determine your producer classification.

☑ Choose a reporting method.

☑ Gather sales and packaging weight data.

☑ Submit reports via the CAA Producer Portal.

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Check out our ultimate guide to Oregon EPR compliance, made for small and medium businesses.

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How rePurpose Global Can Help

Navigating EPR regulations can be challenging, but rePurpose Global offers a packaging compliance software platform that simplifies reporting and ensures cost-efficient compliance. Our tools help brands:

✔ Automate packaging weight tracking.

✔ Ensure accurate fee calculations.

✔ Stay ahead of regulatory changes.

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Take action today to avoid last-minute compliance stress!

Check out the EPR packaging module.

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