On October 1, the Circular Action Alliance (CAA) published final 2027 EPR fees for California, Colorado and Oregon, plus Washington's first early fees. For a general understanding of the 2027 fees, read our post Your 2027 EPR Fees Are Here: Here's How to Budget for Them.
At rePurpose, we applied those fees to the packaging data of a select group of our customers across all four states. Then we compared the results against what each brand expected to pay: a low-to-high estimate range built from either last year's final fees or CAA's earlier illustrative (draft) fees. With that base of real customer data, patterns emerged that the published rates alone don't reveal.
Same rates, same states, very different outcomes. Some brands are paying far less than they budgeted. Others are paying more. A few are paying less this year but should expect a jump next year.
So why the spread? Packaging mix matters more than the state a brand sells in. Your fee comes down to three things: what your packaging is made of, how much of it you sell in each state, and what each state charges per material. You can't control the rates, and you can't easily change where you sell. But you can control your packaging mix. And in our analysis, it shaped fees more than anything else, because each material's rates moved so differently. Here's how that played out across the four states.
Fee trends we’re seeing across rePurpose producers
We compared final 2027 fees with the ranges based on CA's illustrative fees and the CO, OR and WA estimates that have been available in the rePurpose app. Here's the summary view of what we saw across the producers in our analysis.
Lesson 1: Your packaging mix matters more than your state
EPR fees are charged per pound of packaging, and every material has its own rate. When rates shift, they don't shift evenly. That's why two brands selling in the same states can get opposite results.
Take two of our customers.
Brand A uses mostly flexible plastic and multi-layer pouches. In California, the draft fee for multi-layer laminates was 58¢ to 148¢ per pound. The final rate came in at 24¢. Oregon cut its laminate rate almost in half, too. Across all four states, Brand A landed about 18% below the low end of its expected range.
Brand B packages mostly in glass. Glass moved in every direction at once. California's glass bottle rate came in at double the draft low. Colorado's glass rate rose 25%. Oregon's glass rate dropped to effectively zero. Brand B's total landed inside its range, but only because Oregon's drop canceled out increases elsewhere.
The pattern held across the group:
- Laminates and specialty films (multi-layer pouches, wrappers, and plastic films) fared best in every state. Their rates dropped the most, or in Colorado, rose the least.
- Glass was the least predictable. Its fees went up in some states and down in others. And because glass is heavy, even a tiny rate change adds up fast across millions of pounds.
- Rigid plastic like containers and tubs landed slightly above the low end in California, then moved up again with an added plastic fee.
- Fiber and paperboard nudged fees up a little for nearly everyone, but rarely changed the overall picture.
Even within one material, the details matter. One customer with mostly flexible packaging expected a big California cut like Brand A. But their film was a plain, common type with a lower draft rate to begin with, so the cut was smaller. They landed inside their range, not below it. "Flexible-heavy" alone doesn't predict your fees. The specific material categories do.
Lesson 2: Small plastic parts drove up costs for beauty and personal care brands
Caps, lids, pumps and other plastic pieces 2 inches or smaller went against the trend: they cost more in Colorado and Oregon, even as many other materials rose only slightly or got cheaper.
- In Colorado, the small-format plastic rate rose 27%.
- In Oregon, where most fees fell sharply, small-format plastic went up. One category split into two, and the higher of the new rates is nearly three times the old one.
In our analysis, this hit beauty, personal care and other small-pack brands hardest. Two of our customers in that space were the only ones whose Oregon fees went up, despite a statewide average drop of nearly half. If your products ship with lots of small closures and components, it’s reasonable to assume these lines will cost more.
Lesson 3: Headline numbers don't tell you what you'll pay
California's "10% below" isn't a 10% cut for everyone. CAA announced that California's overall budget came in about 10% below the low end of its draft range. But part of every California fee goes to a plastic pollution fund that's set by law at $500M a year. That amount can't go down, and its per-pound rate came in higher than expected. So the biggest savings landed on a few materials: multi-layer pouches, specialty films and treated wood.
For our customers, that played out unevenly: 4 of 10 came in below their low estimate. Six came in above it. Two brands, one mostly glass and one mostly rigid plastic foodservice packaging, each paid nearly $200K more than their low estimate.
That said, these materials, pouches and films, are not necessarily the smart switch. Even after the cut, laminates are still among the most expensive materials per pound: 24¢ in California, versus about 2–3¢ for glass and cardboard. They're also hard to recycle. California and Colorado both charge extra for that, and Colorado's surcharge on laminates went up for 2027. Before changing your packaging for fee savings, model the full picture first. The rePurpose Packaging Simulator shows how a switch affects both your EPR fees and your SB 54 source reduction goals, so you don't trade one problem for another.
Additionally, Oregon's big drop is mostly one-time. Oregon fees fell 48% for our customers, but CAA is funding that by returning about $80M in reserves. Without that one-time credit, 2027 fees would have been only about 13% lower than 2026. Roughly three-quarters of the savings won't carry into 2028. Brands that treat 2027 as the new normal will be under-budgeted next year.
Our glass-heavy customer is the clearest example. Its Oregon fees dropped 94% in 2027. That drop is the main reason its multi-state total stayed in range. If the credit doesn't repeat, its overall fees will likely climb in 2028.
Lesson 4: Lots of plastic pieces means a bigger January bill
How much you pay matters. So does when.
In California, most fees are split evenly between a January invoice and a July invoice. But the $500M plastic fund fee is billed entirely in January, and part of it is charged per plastic component, not just per pound.
That means brands with many small plastic pieces get front-loaded bills. Three of our customers with high component counts, two beauty brands and a foodservice brand, will see 80% to 82% of their annual California fees on the January invoice. Brands with fewer, heavier components see a more even split.
For finance teams, that's the difference between a predictable expense and a cash flow surprise at the start of the year.
Why the fee schedules alone won't show you this
CAA's published fee schedules list rates. Hundreds of them, by state, by material category, by fee type. What they don't tell you is what those rates mean for your business.
The fee patterns we’re sharing are not visible in the fee schedules on their own. They only come into focus when you:
- Apply every rate to a brand's actual packaging data, category by category
- Compare the results against the draft rates and prior-year fees
- Understand each state’s program changes (e.g. what’s a lasting change versus a one-time credit?)
- Look across many brands with different packaging profiles to see what's a trend and what's a one-off
That's the work our team did for this analysis. Because we support 200+ brands with their EPR compliance, we can see patterns across real packaging portfolios that no single brand, and no rate schedule, shows on its own. It's also why our customers are hearing about their 2027 fees, and what to expect in 2028, before the invoices arrive.
See what 2027 fees mean for your packaging
You don't need to run a multi-brand analysis to get these insights for your own business. The rePurpose Fee Calculator applies the latest EPR rates to your packaging profile, so you can see which materials and states drive your fees, and where to focus your budget planning.
If you're a registered producer with CAA, you can find the 2027 published fees in the CAA producer portal. Our Fee Calculator helps you understand what's driving those numbers and what to plan for next.
Budgeting season is here, and 2028 planning starts now. A few questions worth asking:
- Which of your packaging materials saw the biggest rate changes?
- How much of your Oregon savings is one-time?
- How much of your California bill lands in January?
Find your next step
Haven't reported yet? Start with your data. Accurate packaging data is the first step toward compliance and knowing your fees. Talk with our team to get your packaging data in order.
Already reported? See what your fees mean. The rePurpose platform takes the data you already have, and the Fee Calculator turns it into the insights you need for budgeting. Plus, get started on the 2027 reporting cycle now. Your packaging data is the foundation for every fee you'll pay.
Already a rePurpose customer? Your 2027 fees are live. They're now in the rePurpose Fee Calculator. Open your app to find your number.
Thinking about changing your packaging? Use the rePurpose Packaging Simulator to see how a change could affect your fees, recyclability, and plastic reduction goals before you make it.
Frequently asked questions
When were the final 2027 EPR fees published?
The Circular Action Alliance (CAA) published final 2027 fees for California, Colorado and Oregon on October 1, along with Washington's first early fees. California's rates remain preliminary until CalRecycle approves the program plan.
Why might my fees differ from what I budgeted?
Rates changed by material, not evenly across the board. In our analysis, what a brand's packaging is made of did more to shape its fees than which states it sells in.
Which materials saw the biggest changes?
Among the brands we analyzed, multi-layer pouches and specialty films saw the largest decreases. Small plastic parts like caps and pumps cost more in Colorado and Oregon. Glass was mixed, rising in some states and falling in others.
Will Oregon's lower fees continue in 2028?
Probably not at this level. Much of Oregon's 2027 drop comes from a one-time return of about $80 million in program reserves. CAA does not expect the reduced rates to carry into 2028.
Should I switch to materials with lower rates?
Not without testing it first. A lower rate this year doesn't mean a material is the best long-term choice, especially if it's hard to recycle. The rePurpose Packaging Simulator can help you model a change before you make it.
When will I be invoiced?
In California, program fees are split 50/50 between January and July, but all plastic fund fees are billed in January. Colorado and Oregon are split 50/50 between January and July. Washington's early fees are due in full in early 2027.
Where can I find my 2027 fees?
Registered producers can find the published fee schedules in the CAA producer portal. rePurpose customers can also see their fees in the rePurpose Fee Calculator.
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