World Wide Gourmet Foods

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Circular Action Alliance (CAA) & Packaging EPR: What Brand Owners Need to Do in 2025–2027

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Packaging Recycling

Extended Producer Responsibility (EPR) laws for packaging and paper are rolling out across the U.S. CAA—the nonprofit, producer-led Producer Responsibility Organization (PRO)—has been approved or registered to implement these laws in several states and is building a single portal and set of processes to keep compliance manageable. Circular Action Alliance

Below is what brand owners need to know—who must report, what to report, key state timelines, and small-producer exemptions.

What CAA Is (and why it matters)

CAA is the designated or registered PRO for:

Brand Owner Responsibilities (common threads)

  1. Determine if you’re the “producer.” In most cases, the brand owner is responsible; importers or manufacturers can be obligated in certain supply chains. (See each state’s producer definition.) Circular Action Alliance
  2. Register with CAA (unless exempt) and sign the Producer Participation Agreement (PPA) plus state addenda for each state where you sell covered products. Circular Action Alliance+1
  3. Report “supply data.” This is the weight and types of covered materials you supplied into each state during the reporting year (by material, sometimes by component). Accuracy matters—the data informs your fees. Circular Action Alliance+1
  4. Pay EPR fees/dues (eco-modulated over time) to fund statewide recycling/composting systems. State program plans and fee schedules flow from your reported data. Recycling Today
  5. Keep records & update corrections promptly if you discover issues in submitted reports. Squarespace

What Reporting Looks Like (high level)

  • Scope: consumer-facing packaging, packaging components, paper products (state nuances apply). Oregon+1
  • Data fields: company info + quantitative material weights by category; methodology notes; sometimes recycled content details. Squarespace
  • Submission: through the CAA Producer Portal after signing the PPA + state addendum(s). Oregon

State-by-State: Timelines & What’s Due

Oregon (Recycling Modernization Act)

Colorado (HB 22-1355)

  • Registration: Required with CAA (initially by Oct 1, 2024). Circular Action Alliance
  • 2024 supply data deadline: July 31, 2025 (to set 2026 fees). CDPHE+1
  • Fees/funding begin: January 2026 program start. PPAI

California (SB 54)

  • CAA approved as first PRO; rulemaking is ongoing. CalRecycle
  • Big statutory targets by 2032: 100% recyclable/compostable packaging; 25% plastic source reduction; 65% single-use plastic recycling. Circular Action Alliance
  • Forthcoming reporting: Draft materials indicate producer registration/data reporting framework; preliminary reporting is expected to begin in late 2025 (watch CalRecycle updates). DLA Piper+1

Minnesota (Packaging Waste & Cost Reduction Act – 2024)

Maine (Stewardship Program for Packaging – 2021)

  • Rules adopted: Dec 5, 2024; program build-out underway. GovDelivery
  • Anticipated cadence: State expects to select a stewardship organization around 2026; producers to report 2026 data in May 2027 and be invoiced July 2027; municipal payments begin Oct 2027. Maine+1

Small-Producer Exemptions (who’s not reporting/paying—for now)

Important: Exemptions vary by state and can change. Always confirm current thresholds before you decide not to register.

  • Oregon: Exempt if global revenue ≤ $5M or < 1 metric ton of covered products in Oregon in the prior year. Restaurants/very small single-site retailers are also exempt. Oregon+1
  • Colorado: Exempt if prior-year gross total revenue < $5M or < 1 ton of covered materials supplied in Colorado; the small-producer threshold is CPI-adjusted annually by CDPHE. epr.sustainablepackaging.org+1
  • California (SB 54 draft regs): Small producers with < $1M in California gross sales may apply for an exemption; CalRecycle proposes a two-year exemption term (renewable), with details finalized via rulemaking. CalRecycle+2Beveridge & Diamond PC+2
  • Minnesota: De minimis if global revenue < $2M or < 1 ton of covered materials annually in Minnesota. KTS Law+1
  • Maine: Exempt if in-state revenue < $2M or < 1 ton of packaging. Transitional relief: for 1–3 years after the program contract, producers with < $5M revenue are exempt; low-volume (1–15 tons) may pay a flat fee. epr.sustainablepackaging.org

Quick Compliance Checklist (multi-state sellers)

  1. Map your footprint. Identify where your products/shipments create obligations (CA, CO, OR, MN now; ME queues up). Circular Action Alliance
  2. Confirm exemption status per state (revenue & tonnage). If not exempt, continue. epr.sustainablepackaging.org+4Oregon+4epr.sustainablepackaging.org+4
  3. Register with CAA and sign the PPA + state addenda to unlock the reporting portal(s). Circular Action Alliance+1
  4. Assemble supply data (2024 for CO/OR cycles; CA/MN per current instructions). Keep methodologies and source files. Circular Action Alliance+1
  5. Submit reports by each state’s deadline; address any validation issues quickly; retain records. Circular Action Alliance+1

Bottom line

  • If you sell into Oregon or Colorado, reporting has already begun; fees start funding systems in 2025–2026. Environment America+1
  • California and Minnesota are building out with registration and early reporting now and heavier obligations ramping in the next 1–3 years. DLA Piper+1
  • Maine is next, with producer reporting and invoices slated 2027. Maine

How World Wide Gourmet Foods Can Help

At World Wide Gourmet Foods, we know firsthand how complex packaging regulations can feel—especially as EPR requirements expand across multiple states with different rules and timelines.

We work closely with brand partners not only to manufacture and package products, but also to stay ahead of compliance requirements. Here’s how we can support you:

  • Education & Guidance: We track evolving CAA and state deadlines, exemption thresholds, and reporting requirements and can walk you through what applies to your brand.
  • Data Preparation: Because we already source and manage many packaging materials, we can help you ask the correct questions of your packaging vendors so that you can correctly prepare your reports.
  • Process Alignment: We can advise on sustainable packaging options that may reduce long-term fees under eco-modulated structures.
  • Partnership Approach: Whether you’re a large brand or a small producer testing the waters, we’ll help you understand your responsibilities—and where you’re exempt—so you can focus on growing your business while remaining compliant.
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