How EPR fees are calculated

The short answer

Where the rates come from

In Oregon and Colorado, Circular Action Alliance (CAA) sets rates in roughly five steps:^1,2

1. Add up the cost of the recycling system it must fund: collection, transport, processing and expansion.
2. Add the program's other costs: education, the state agency's oversight costs, reserves and administration.
3. Assign those costs to each material, based on how much it costs to collect and process.
4. Subtract what each material is worth when it's sold as a recycled commodity.
5. Divide by the pounds producers reported, which gives a rate in cents per pound for each category.

That's why materials that are expensive to handle and worth little afterward, like multi-layer pouches and foam, carry the highest rates, while cardboard and aluminum, which are cheap to recycle and valuable, carry the lowest. Oregon and Colorado each have around 60 categories; California's 2027 schedule has 95.^3,4,5

How rates compare

Cents per pound. Selected categories from CAA's published schedules.^3,4,7 Category definitions differ slightly between states, so treat these as indicative.

CAA published Oregon's 2027 schedule on October 1, 2026. Of the 60 categories in both years' schedules, 58 fell, 28 of them by half or more, mainly because CAA is returning about $80 million of reserves through lower rates. One rose: small-format plastic, from 28¢ to 78¢ (2026 schedule, page 2; 2027 schedule, page 3). PE film went from 43¢ to 12¢, PP film and laminates from 102¢ to 56¢, clear PET bottles from 25¢ to 19¢, and glass to zero.^3,8 That shows how much rates can move from year to year, for reasons that have nothing to do with your packaging. The Oregon guide has both years side by side.

A worked example

Take an illustrative snack brand that sells the same packaging mix into Oregon and Colorado: 190,000 pounds in each state. The example uses Oregon's 2026 rates; Oregon's 2027 rates for all four materials are lower.

Illustrative only. Real bills depend on exact category coding, eco-modulation and each state's reported volumes.

Two things stand out. Flexible plastic is about a third of the weight but more than three-quarters of the cost. And the same packaging costs different amounts in different states, and costs more in Colorado in 2027 than in 2026.

A single change shows the lever. If the pouches in Oregon could be redesigned as mono-material PE film (rated 43¢ instead of 102¢), the same 20,000 pounds would cost $8,600 instead of $20,400, a saving of $11,800 a year in one state.

Eco-modulation

Eco-modulation adjusts the base rate to reward or penalize design choices. Each state does it differently:

• Oregon uses bonuses only, tied to life cycle evaluations (studies of a package's environmental impact from production to disposal). Bonus A, from the 2026 fee year, reduces fees by 10% for a SKU whose evaluation the producer discloses, up to $20,000 per SKU and ten SKUs per producer. More bonuses start from 2027.^9,10
• Colorado uses both bonuses and surcharges. Design features that disrupt recycling add 5%; materials not on the state's Minimum Recyclables List cost at least 20% more, and materials that aren't collected at all pay a further premium; materials with high recycling rates get 5% off.^7,11
• California builds two adjustments into its preliminary 2027 rates: 5% off for materials whose recycling rate is above the 2028 target, and 5% more for materials that are neither recyclable nor compostable. They are already in the published rates, so there is nothing to add.⁵
• Minnesota, Maryland and Maine all require eco-modulation, but the details aren't final.

California's extra layer

California adds a second charge on top of program fees. The PRO must pay $500 million a year into the Plastic Pollution Mitigation Fund from 2027 through 2036.^12,13 CAA's preliminary 2027 schedule passes this cost to producers as 26¢ per pound of plastic plus 0.1¢ per plastic component, on top of program fees and on a separate invoice in January. It also adds a reuse investment fee of 3¢ per pound of plastic.⁵ That makes plastic considerably more expensive in California than anywhere else, and it means the number of plastic pieces matters, not just weight.

Flat fees and small producers

Several states offer simpler fees for low volumes:

• Colorado lets producers supplying 10 short tons or less pay a flat amount, from $900 to $4,100 for 2027.⁷
• Oregon offers a flat-fee option for some lower-volume producers; see CAA's schedule for eligibility.³
• Maine caps low-volume producers (1 to 15 tons) at $500 a ton and $7,500 a year.¹⁴

Separately, the smallest producers are exempt entirely, usually those under a revenue limit or under 1 ton a year into the state. The thresholds are in each state guide.

Why data quality matters

Your fee is only as accurate as your data. Two common problems cost money in opposite directions:

• Over-reporting, by putting packaging in a more expensive category than it belongs. In Oregon, for example, corrugated boxes removed before the product reaches the consumer (“transport corrugated”) have their own category at 0¢. Reporting them with other corrugated cost 8¢ a pound in 2026.³
• Under-reporting, which can lead to back-billing with penalties and interest under CAA's policies, and to reports being rejected and resubmitted.¹⁵

How to lower your fees

1. Check your category coding. It is the fastest win and needs no packaging change.
2. Claim the exemptions and zero-rated categories you're entitled to, such as Oregon's transport corrugated category and its exemption for privately recycled material.
3. Reduce weight by right-sizing boxes, thinner films and fewer components.
4. Switch materials where it makes sense, especially away from multi-layer flexible packaging and foam.
5. Use the bonuses, such as Oregon's life cycle evaluation bonus and Colorado's recyclability adjustments.
6. Plan two years ahead, because that is when the change will show up in your bill.

Related guides

Sources

1. Circular Action Alliance, Oregon fee setting explained (May 2025). PDF
2. C.R.S. 25-17-705 (producer dues). colorado.public.law
3. Circular Action Alliance, Oregon 2026 fee schedule (published Oct. 29, 2025). circularactionalliance.org
4. Circular Action Alliance, Colorado 2026 dues schedule (Oct. 13, 2025). circularactionalliance.org
5. Circular Action Alliance, California 2027 fee schedule, preliminary (Oct. 1, 2026). circularactionalliance.org
6. Circular Action Alliance, Producer resource center. circularactionalliance.org
7. Circular Action Alliance, Colorado 2027 dues schedule (Oct. 1, 2026). circularactionalliance.org
8. Circular Action Alliance, Oregon 2027 Fee Schedule (Oct. 1, 2026). circularactionalliance.org
9. Circular Action Alliance, Oregon eco-modulation and Bonus A overview (June 2025). PDF
10. Oregon DEQ, Life cycle impact evaluation. oregon.gov/deq
11. 6 CCR 1007-2, Part 1, Section 18 (producer responsibility rules). law.cornell.edu
12. Cal. Pub. Res. Code §42064 (Plastic Pollution Mitigation Fund). california.public.law
13. CalEPA, SB 54 Plastic Pollution Mitigation Fund. calepa.ca.gov
14. 38 M.R.S. §2146 (stewardship program for packaging). legislature.maine.gov
15. Holland & Knight, “2026 EPR reporting lessons learned,” July 2026. hklaw.com

What changed

• October 11, 2026 Oregon: corrected how we describe the 2027 rate changes. 58 of the 60 categories in both schedules fell, and small-format plastic rose.
• October 11, 2026 California: the reuse investment fee is exactly 3¢ per pound of plastic, eco-modulation is built into the preliminary 2027 rates, and the Mitigation Fund charge comes on a separate January invoice.
• October 9, 2026 Second review: Oregon producer status list counts and the September 4 list, California's reuse and source-reduction fee, Bonus A caps, and source links.
• October 5, 2026 Corrected and updated after a source-by-source review, including the 2027 fee schedules published October 1, 2026.
• October 2, 2026 First published.

General information, not legal advice. This guide summarizes laws, rules and program documents as we read them on the review date above. These programs change often, and how a law applies depends on your products, contracts and facts. For a formal opinion, consult counsel. Producer Desk is not a law firm.