Packaging EPR Update: Week of September 21, 2026

Comment Period  |  OR

Oregon DEQ has opened comment on CAA’s third amendment to its approved 2025 to 2027 program plan. Five changes are proposed, and one reaches producers directly: the covered material categories change. The plan states that its Table 21 categories are what producers report against and what sets the 2027 fee schedule, so this is a reclassification with a price attached.

Read in the plan at pages 189 to 190, the changes are one rename and four splits:
• “PET (#1) Thermoformed Containers, Cups, Plates, Trays” is broken up and recombined with PET lids, giving “PET (#1) Thermoformed Containers”, accepted on the statewide collection list, and “PET (#1) Lids, Cups, Plates, and Trays”, not accepted
• “Aluminum Foil and Molded Containers” splits into “Aluminum Foil” and “Aluminum Molded Containers”
• “PP (#5) Tubs, Pails and Buckets, Nursery pots & trays” splits into two
• “HDPE (#2) Tubs, Nursery pots & trays” splits into two
• the long plastic-containers-for-hazardous-materials category is renamed “Plastic Packaging, Hazardous or Special Products”

What this means for you: if you sell PET thermoforms, PET lids or cups, aluminum foil or molded aluminum, or PP and HDPE tubs or nursery pots into Oregon, your material moves to a different line. The PET split is the sharpest: thermoformed containers land on the accepted list while lids, cups, plates and trays do not. CAA says it needs approval by December 2026 so the new categories reach the producer portal before 2027 reporting opens. Comments go to RethinkRecycling@deq.oregon.gov by 5:00 p.m. Pacific on October 19, 2026. Nothing is decided yet and nothing changes today. Source: Oregon DEQ, Plastic Pollution and Recycling Modernization Act (read September 20, 2026); CAA proposed amended program plan, Table 21 and pages 189 to 190, read in full.

Comment Period  |  CA

CalRecycle holds an informational workshop on September 29, 2026, 10 a.m. to 12 p.m., to set out the proposed scope and design of the coming update to its materials recovery facility characterization study, and to take public feedback. That study is what SB 343 requires CalRecycle to revise in 2027 and every five years after, and its data is what manufacturers must use to decide whether a package may carry a recyclability claim in California. CalRecycle says future studies will be designed to align better with the SB 54 covered material categories.

What this means for you: this is a design consultation, not a rule, and nothing you must do changes on September 29. It matters because the scope chosen now decides which materials get measured, and a material that is not measured cannot clear the recyclability test later. Source: CalRecycle, SB 343 Accurate Recycling Labels (read September 20, 2026).

Legislative  |  CA

Governor Newsom vetoed SB 1180 (Allen) on September 20, 2026. It would have governed how money in the California Plastic Pollution Mitigation Fund may be spent: prioritizing the communities most burdened by plastic pollution, capping grantee indirect costs, widening who may receive grants, and requiring a published annual expenditure list. The fund is unaffected, and the PRO’s duty to remit $500 million a year to it from 2027 through 2037 comes from SB 54, not this bill.

AB 2253, which would restrict credit-based mass balance accounting behind recycled content claims from January 1, 2030, was presented to the Governor on September 10 and was still undecided on September 20. He has until September 30.

What this means for you: nothing changes today. The mitigation surcharge you pay through the PRO is untouched, because SB 1180 governed spending out of the fund rather than payments into it. Watch AB 2253 this month only if you make recycled content claims. Source: Office of the Governor of California, legislative update (September 20, 2026).

Comment Period  |  CA, CAA

Circular Action Alliance is taking comment from August 26 to October 24, 2026 on the draft California Funding and Services Agreement and its Project Schedules. These are the contracts CAA will pay recycling and reuse service providers under, and CAA addresses the invitation to California recycling and reuse interest holders.

What this means for you: if you are a producer, nothing you must do changes, and this is not the program plan comment period, which closed August 14. It is worth knowing because what CAA agrees to pay service providers is the largest single input into the fees producers are later charged, and this is the only public window on those terms. If you run recycling or reuse services in California, this one is aimed at you. Source: Circular Action Alliance, California (read September 20, 2026).