Active Program

Washington Packaging EPR: Producer Compliance Guide

Washington's E2SSB 5284 (2025) -- the Recycling Reform Act -- requires producers to be members of the Circular Action Alliance PRO by July 1, 2026, with no mandatory fees until 2029-2030. Washington's de minimis threshold of less than $5 million global revenue does not take effect until January 1, 2031 -- producers below that level are not exempt before that date. Enforcement by Washington Ecology begins March 1, 2029; companies not enrolled in CAA by that date cannot legally sell covered products in Washington. The cost-share ramp is 50% by February 15, 2030, 75% by February 15, 2031, and 90% by February 15, 2032.

Governing Law
E2SSB 5284 - Recycling Reform Act (2025)
Fee Start
2029–2030
Max Penalty
Ecology enforcement
Administering Agency
Washington Ecology
PRO / Administrator
Circular Action Alliance
De Minimis
<$5M revenue (effective Jan 1, 2031)
Fees are not yet active. Amounts shown are projections based on Oregon's published 2025-26 rates at the Washington program multiplier (1.02x). Actual rates will be set when the program plan is approved.

Fee Schedule by Material

Base rates before eco-modulation. Final fee = Tonnage x Rate x Eco-Modulation Multiplier. All amounts are projections; actual rates set upon program plan approval.

Material / Packaging TypeRate / Metric TonTier
Aluminum, cans $122 (est.) Tier 1
Clear PET (#1) $510 (est.) Tier 2-3
HDPE Natural (#2) $184 (est.) Tier 1
Steel $204 (est.) Tier 2-3
Uncoated Paper/Board $163 (est.) Tier 1
Corrugated $163 (est.) Tier 1
HDPE Pigmented (#2) $653 (est.) Tier 4
PP (#5) $775 (est.) Tier 4
Glass $204 (est.) Tier 2-3
LDPE Film / Mono-PE $877 (est.) Tier 4
PS Rigid (#6) $1,979 (est.) Tier 4
Expanded Polystyrene $2,815 (est.) Tier 4

Eco-Modulation Factors

○ SpeculativeProjected/estimated. Eco-modulation rules are not yet finalized in this state.

Source: E2SSB 5284 (2025), Recycling Reform Act. Eco-mod required; program plan (~2028) not yet approved; factors not established.

Eco-modulation adjusts fees based on packaging design and recyclability attributes.

Fee Reductions (Bonuses)

Expected (not finalized): lower fee for recyclable formats / PCR content

Fee Increases (Maluses)

Expected (not finalized): higher fee for EPS / non-recyclable materials

Multiplier floor: Not established - program plan pending

ℹ️
SPECULATIVE for eco-mod. No mandatory fees until 2029-2030. PRO membership required by July 1, 2026; enforcement begins March 1, 2029. The statute requires eco-modulation, but specific factors/rates will be set in the PRO program plan and are not yet established.

Key Dates and Timeline

May 31, 2026
Simplified Supply Report due
Jul 1, 2026
Producers must be PRO members
Sep 1, 2026
CAA one-time payment to Ecology
Oct 1, 2028
PRO submits program plan
Mar 1, 2029
Ecology begins enforcement
Feb 15, 2030
50% cost-share milestone; full fees begin
Feb 15, 2031
75% cost-share milestone
Feb 15, 2032
90% cost-share milestone

Covered Products Scope

Consumer-facing packaging of all material types and paper products. Scope largely mirrors other CAA-administered states. De minimis threshold: <$5M global revenue (effective Jan 1, 2031). Covered materials list to be finalized during PRO program plan development (due Oct 2028).

Exemptions and Exclusions

The following categories may be fully or partially exempt from producer obligations in Washington. Verify applicability with the CAA producer portal or Washington Ecology before excluding any materials from supply reports.

De Minimis (Small Producer)
<$5M global revenue AND <1 MT placed on market. Agricultural producers have a separate tailored threshold - confirm with WA Dept. of Ecology.
B2B / Tertiary Packaging
Tertiary/transport packaging used exclusively B2B excluded
Medical Device and Pharmaceutical
Packaging for prescription drugs and FDA-regulated medical devices excluded
Agricultural Packaging
Agricultural producers: separate de minimis threshold applies - verify current threshold with WA Ecology or CAA
Hazardous Materials Packaging
Packaging for hazardous materials under state/federal regulations excluded
Washington program enacted May 2025 and is in ramp-up phase. Full exemption rules still being developed. Verify with WA Dept. of Ecology or CAA portal before relying on any exemption.

Frequently Asked Questions

What is the July 1, 2026 deadline in Washington?
Washington producers must be enrolled as members of the Circular Action Alliance PRO by July 1, 2026. This is a direct producer obligation -- non-compliant producers are out of compliance as of that date, even though enforcement does not begin until March 1, 2029.
When does Washington's de minimis threshold take effect?
Washington's de minimis threshold of less than $5 million in global revenue does not take effect until January 1, 2031. Before that date, producers below $5 million are not automatically exempt. Always note the 2031 effective date.
When does Washington EPR enforcement begin?
Washington Ecology begins enforcement on March 1, 2029. Companies not enrolled in CAA by that date cannot legally sell covered products in Washington. The first mandatory fee payments begin February 15, 2030 (50% cost-share milestone).
What type of supply report does Washington require?
Washington requires a Simplified Supply Report showing aggregated weight by material category. The 2025 supply report was due May 31, 2026.