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. Each state has around 60 categories.^3,4

How rates compare

Cents per pound. Selected categories from CAA's published schedules.^3,4,6 Category definitions differ slightly between states, so treat these as indicative.

A worked example

Take an illustrative snack brand that sells the same packaging mix into Oregon and Colorado: 190,000 pounds in each state.

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. Bonus A, from the 2026 fee year, reduces fees by 10% for a SKU whose evaluation is disclosed, up to $20,000. More bonuses start from 2027.^7,8
• Colorado uses both. Design features that disrupt recycling add 5%; materials not on the state's Minimum Recyclables List cost at least 20% more; materials with high recycling rates get 5% off.^6,9
• California, 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.^10,11 CAA's May 2026 illustration spreads it across producers by plastic weight and by number of plastic components, roughly 17¢ per pound of plastic plus a small charge per component.¹² 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 2027.⁶
• 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.¹³

Below these levels, most producers are exempt entirely. 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, or reporting packaging that is excluded (like transport packaging removed before the consumer receives the product, rated 0¢ in Oregon).³
• Under-reporting, which can lead to back-billing with penalties and interest under CAA's policies, and to reports being rejected and resubmitted.¹⁴

How to lower your fees

1. Check your category coding. It is the fastest win and needs no packaging change.
2. Claim exclusions you're entitled to, such as transport packaging and, in Oregon, 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, Producer resource center. circularactionalliance.org
6. Circular Action Alliance, Colorado 2027 dues schedule (Oct. 1, 2026). circularactionalliance.org
7. Circular Action Alliance, Oregon eco-modulation and Bonus A overview (June 2025). PDF
8. Oregon DEQ, Life cycle impact evaluation. oregon.gov/deq
9. 6 CCR 1007-2, Part 1, Section 18 (producer responsibility rules). law.cornell.edu
10. Cal. Pub. Res. Code §42064 (Plastic Pollution Mitigation Fund). california.public.law
11. CalEPA, SB 54 Plastic Pollution Mitigation Fund. calepa.ca.gov
12. Circular Action Alliance, California illustrative fees (May 1, 2026). PDF
13. 38 M.R.S. §2146 (stewardship program for packaging). legislature.maine.gov
14. Holland & Knight, “2026 EPR reporting lessons learned,” July 2026. hklaw.com

What changed

• 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.