CAA’s California, Oregon, Colorado, and Washington 2027 EPR Producer Fee and Due Schedules Released – Changes of Note for Producers

On October 1, 2026, Circular Action Alliance (“CAA”), the producer responsibility organization for California, Oregon, Colorado, Washington, and two other states with packaging extended producer responsibility (“EPR”) programs, released the 2027 California Producer Fee Schedule, the 2027 Oregon Producer Fee Schedule, the 2027 Colorado Producer Dues Schedule, and the 2027 Washington Early Fees Schedule.

EPR Fee and Due Schedule Overview

In Oregon, CAA has substantially lowered per-pound fees for many material categories, reflecting program reserve drawdowns and the return of previously collected Special Investments in Materials (“SIM”) fees through the 2027 rates. Colorado’s changes are more mixed: some categories have decreased, but others face material increases, including expanded or foamed polystyrene food-service containers (172¢ to 209¢/lb), HDPE/LDPE flexible packaging and film (48¢ to 62¢/lb), and plastic small format packaging (52¢ to 66¢/lb). The Colorado program’s use of the term “dues” is synonymous with the other programs’ “fees.”

California’s 2027 fee schedule presents a different budgeting picture: its listed base fees are generally lower than the highest Oregon and Colorado rates, but they are preliminary and nonbinding pending program plan approval. Additionally, the base fee may be increased for applicable packaging containing plastic components though California’s separate reuse investment and Plastic Pollution Prevention and Packaging Producer Responsibility (“PPMF”) charges, including a weight-based fee on plastic components and a per unit component fee. Producers should therefore avoid assuming that a lower listed California base rate translates directly into a lower overall cost.

California fees and Colorado dues include passive eco-modulation factors that will automatically be applied to producer invoices based on supply data. In California, materials with a higher recycling rate than the statutory 2028 target of 30-percent will receive a 5-percent reduction in fees (a bonus), while materials that are neither recyclable nor compostable will receive a 5-percent increase in fees (a malus). In Colorado, CAA will also implement a 5-percent reduction in dues for materials with high recycling rates, and a 5-percent increase in dues for materials that disrupt recycling. Uniquely for Colorado, materials on the Additional Material List (“AML”) must have dues at least 20-percent higher than the average of similar Minimum Recyclable List (“MRL”) materials, and materials that are not collected must have dues at least 10-percent higher than the average of similar AML materials. Additional guidance on these Colorado factors is expected but not currently publicly available.  

Washington’s 2027 early fees will fund program development, startup, and regulatory costs, but not the full costs of the eventual operating program. The comparatively low rates range from 0.2¢/lb for “Glass & Ceramics” to 2.5¢/lb for “Flexible Plastic.”  At 1.7¢/lb, the separate “Compostable Materials” category is notable given the challenges facing plastics designed for compostability in California (for example, see EPR Group Consulting, National Organic Program Requirement for Compostability Label). However, Washington’s early fee classification does not establish that compostable packaging will be accepted for collection or composting; that will depend on the state’s collection lists and eventual program design. Producers should treat these rates as an initial program funding measure, rather than a reliable indicator of future material-specific costs or collection outcomes.

Looking ahead, producers may expect two invoices for their 2025 data year reporting annual fees for California, Oregon, and Colorado, with half billed in January 2027 and the second half in July 2027. Each invoice will list fees by material category. California producers will also receive a PPMF invoice in January. For all six active EPR states, 2026 data year reporting is expected to be due to CAA by May 31, 2027.

Below is a table showing selected material fee changes and rates by pound for California, Oregon, and Colorado.

Material Category	CA 27 base fee	OR 26	OR 27	CO 26	CO 27	Producer impact
Glass bottles/jars	2¢	10¢	0¢	4¢	5¢	OR eliminates the fee; CO increases slightly.
Aluminum containers	1¢	6¢	-9¢	2¢	5¢	OR’s negative rate may result in a credit or refund, subject to CAA clarification.
Steel containers	2¢	10¢	4¢	7¢	11¢	OR decreases; CO increases.
Aseptic/gable-top cartons	7¢	17¢	3¢	13¢	14¢	Substantial OR reduction; slight CO increase.
Corrugated cardboard	3¢	8¢; non-consumer 0¢	2¢; non-consumer 0¢	8¢	10¢	OR decreases; CO increases.
Waxed corrugated cardboard	4¢ without plastic; 19¢ with plastic	—	—	25¢	32¢	CO rate increases materially.
Paper small format	4¢ without plastic; 26¢ with plastic	44¢	15¢	22¢	21¢	Substantial OR reduction; CA rate depends on plastic components.
Molded-pulp food-serviceware	2¢ without plastic; 8¢ with plastic (molded fiber)	—	43¢	26¢	35¢	CO increases; OR adds a distinct category.
PET clear/natural bottles, jugs, and jars	12¢	25¢	19¢	15¢	18¢	OR decreases; CO increases.
PET rigid thermoforms	15¢	57¢	29¢	17¢ clear; 50¢ colored	19¢ clear; 44¢ colored	OR and CO clear PET rates decrease; CO colored PET also decreases.
HDPE clear/natural bottles, jugs, and jars	10¢	9¢	-4¢	14¢	22¢	OR’s negative rate may result in a credit or refund, subject to CAA clarification; CO increases.
HDPE nursery pots/trays	—	35¢	18¢	79¢	40¢	Large OR and CO decreases.
PP bottles, jugs, and jars	16¢	38¢	21¢	20¢	21¢	OR decreases; CO increases slightly.
PP containers	12¢	62¢ for Other Rigid Containers, Cups, Plates, Trays	40¢ for Other Rigid Containers, Cups, Plates, Trays	20¢	21¢	OR decrease; slight CO increase.
PP squeeze tubes	—	—	—	73¢	58¢	Material CO decrease.
HDPE/LDPE flexible packaging and film	HDPE 26¢; LDPE clear non-bag film 25¢; other LDPE flexible/film 24¢	43¢	12¢	48¢	62¢	Large OR decrease; CO increases materially.
PP flexible packaging and film	27¢	102¢	56¢	64¢	69¢	OR decreases; CO increases.
Plastic laminates	25¢ for pouches/ envelopes; 24¢ other forms	102¢	56¢	74¢	78¢	Large OR decrease; CO increases.
Plastic small format	19¢	28¢	41¢ for PE/PP caps and lids and HDPE package handles; 78¢ for other small format	52¢	66¢	OR splits the category and both new rates exceed the former 28¢ rate; CO increases.
Plastic containers for automotive fluids, pesticides/ herbicides, and hazardous materials	—	63¢	48¢	52¢	66¢	OR decreases; CO increases.
Expanded/foamed PS food-service containers	14¢	138¢	74¢	172¢	209¢	Significant OR decrease and CO increase.
PS cushioning, white	—	72¢	59¢	156¢	190¢	OR decrease; CO increase.
PS cushioning, colored	—	138¢	74¢	172¢	209¢	Significant OR decrease and CO increase.
Wood/other organic materials	3¢ untreated without plastic; 18¢ treated/ painted or with plastic	105¢	48¢	84¢	88¢	Large OR decrease; CO increases slightly.

Notes on the table: “—” means the category was not included in the comparison or a directly comparable rate was not identified. Even for generally overlapping material categories, statutory and CAA reporting definitions may vary. California figures are base fees only; additional reuse-investment and PPMF charges may apply to packaging containing plastic components. California’s 2027 rates are preliminary and nonbinding pending program-plan approval. The table does not include Washington’s early fee rates, which are limited to eight broad material categories (“Metal,” “Rigid Plastic,” etc.).

Specific Fee Changes of Note

Oregon’s negative rates for “Aluminum Containers” and “HDPE (#2) – Bottles, Jugs and Jars (Clear/Natural)” suggests that CAA will credit or reimburse producers reporting quantities in either category, although the fee schedule does not establish the mechanics for any credit or refund. Oregon also materially reduced its optional flat fees for eligible low-volume producers supplying less than 10 metric tons of covered materials. By contrast, Colorado’s flat dues increased across all four volume tiers: for example, the lowest tier increased from $800 to $900, and the highest from $3,600 to $4,100. Producers should confirm their eligibility for flat fee options and compare those fees against the variable fees applicable to their material mix before selecting a payment method.

Producers supplying high volumes of materials with reduced Oregon rates may see meaningful year-over-year savings without changing their packaging. Those savings should not, however, be assumed across states or material categories. In addition to the Colorado increases noted above, several other Colorado categories rose, including waxed corrugated cardboard (25¢ to 32¢/lb), molded-pulp food-serviceware (26¢ to 35¢/lb), and HDPE clear/natural bottles, jugs, and jars (14¢ to 22¢/lb). Colorado’s 2027 schedule also anticipates updated eco-modulation guidance incorporating Colorado Department of Public Health and Environment bonus benchmarks alongside existing eco-modulation factors. Future eco-modulated fees and credits may further affect costs as these programs evolve.

Oregon’s 2027 schedule also separates “Plastic - Small Format - PE and PP caps and lids, HDPE package handles” from the remaining “Plastic - Small Format” category. The former has a 2027 fee rate of 41¢/lb, while the latter has a rate of 78¢/lb; the 2026 rate for the combined category was 28¢/lb. Producers with substantial quantities of small plastic components, including closures, caps, and lids, should map their packaging inventory to the revised categories and assess the resulting fee impact. CAA also added “Other Paper Packaging - Molded Pulp Food Serviceware” in Oregon at 43¢/lb, requiring affected producers to report those materials in the distinct category.

Conclusion

Across the four states, producers should review the 2027 schedules against their current material classifications, reported weights, and budget assumptions; assess whether category changes require updates to packaging inventories or reporting systems; and evaluate any available flat fee options.

EPR Group Consulting can help producers interpret state-specific fee schedules, review material classifications and reporting assumptions, estimate year-over-year fee impacts, and identify issues to address as CAA’s programs and eco-modulation requirements develop.