On Monday, Feb. 9, 聽Circular Action Alliance (CAA) Oregon submitted an updated Responsible End Market (REM) program plan amendment to the Oregon Department of Environmental Quality (DEQ), advancing implementation of Oregon鈥檚 Recycling Modernization Act by strengthening how recyclable materials are verified as responsibly recycled聽鈥� a cornerstone of the Recycling Modernization Act.
The amendment聽strikes the right balance of achieving the regulatory and statutory requirements while also offering a practical starting point for engaging and educating the recycling industry on聽new requirements. This approach聽allows end market verification to begin聽immediately聽within聽the system, while work聽continues on聽a formal, harmonized REM certification standard intended for broad adoption across U.S. packaging extended producer responsibility (EPR) programs.
鈥淥regon has been a national leader in defining Responsible End Markets, and this amendment strengthens that leadership聽with聽a practical approach we can implement right away,鈥� said Jeff聽Fielkow, Chief Executive Officer of Circular Action Alliance.听鈥淏y聽advancing聽a solution聽that is both rigorous and workable for end markets, we鈥檙e聽establishing聽a聽harmonized聽system that聽fully聽supports聽Oregon鈥檚聽priorities聽while聽building聽a framework聽that聽producers, processors and recyclers can rely on聽over聽the long term.鈥�
The submission strengthens聽Oregon鈥檚聽interim verification approach聽and supports the development of a聽comprehensive,聽auditable standard for聽eventual聽consideration by the Environmental Quality Commission (EQC). This approach enables near-term accountability while聽laying聽the foundation for a permanent,聽consistent聽REM standard that can be scaled nationally.
Key highlights of the amendment include:
- Affirms REM principles.聽The amendment is designed to meet the REM requirements of transparency, compliance, environmental聽soundness聽and adequate yields. CAA聽remains聽committed to a practical, enforceable standard that protects proprietary information and helps聽maintain聽market stability.
- Interim pathway, then formal standard.聽The amendment creates an interim verification pathway until a formal third-party standard is developed with an ANSI-accredited standards developer and considered by the EQC.
- Built for Oregon, with聽a path to聽national harmonization.聽The verification approach meets Oregon鈥檚 regulatory requirements and is structured to support consistent REM verification across packaging EPR states, advancing a harmonized national framework.听CAA鈥檚聽long-term vision is a standard that meets Oregon鈥檚 requirements聽and those of other聽EPR states.
- One of the most comprehensive聽assessments聽to date.聽Based on CAA鈥檚 review of existing EPR verification practices, the proposed approach is聽among the most comprehensive end market assessments聽across聽jurisdictions聽with packaging EPR,聽in some areas exceeding current verification practices in the EU and Canada.
鈥淥regon led by putting Responsible End Markets into law, and this amendment moves that work forward聽in a way that meets the spirit of the law and will bring assurance to Oregonians that their participation in recycling is not causing undue burden to the environment and other communities,鈥� said Kim Holmes, Executive Director of CAA Oregon. 鈥淥ur goal is聽to聽develop聽a robust system that upholds Oregon鈥檚 requirements and gives end markets confidence to participate at scale.鈥�
DEQ聽and the Oregon Recycling System Advisory Council聽(ORSAC)聽will聽review the amendment聽and聽provide approval, conditional聽approval聽or send it back to CAA for聽additional聽work. If sent back, CAA will have聽a final聽opportunity to聽submit聽a聽third version聽of the amendment, which聽DEQ聽can accept or direct聽binding聽changes.听While the process advances,聽CAA will continue working with end markets聽and other聽interested parties.
As DEQ reviews the amendment, interested parties have an opportunity to help shape the future of their recycling system. The DEQ public comment period is open from Feb. 23, 2026, through Mar. 27, 2026. We encourage all interest holders to share their feedback to advance strong, transparent, and accountable REM standards by attending an Oregon Recycling Council Meeting and emailing DEQ at聽[email protected].
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