California’s Plastic Pollution Prevention and Packaging Producer Responsibility Act requires producers of residential and commercial single-use packaging and plastic single-use food service ware to participate in a Producer Responsibility Organization (PRO).

Through the PRO, producers are responsible for funding the end-of-life management of these materials, including their processing and recycling. The legislation also requires the PRO to contribute $500 million annually to the state, beginning in 2027 and continuing through 2037, with those funds deposited into the California Plastic Pollution Mitigation Fund.

On January 5, 2024, CalRecycle designated Circular Action Alliance (CAA) as California’s first and only PRO.

Colorado’s Producer Responsibility Program for packaging and paper products requires covered producers to join a Producer Responsibility Organization (PRO). Through the PRO, producers must finance and oversee the end-of-life management of covered materials, including collection, processing, recycling, and composting activities.

On May 1, 2023, the Colorado Department of Public Health & Environment (CDPHE) approved Circular Action Alliance (CAA) as the PRO responsible for administering Colorado’s Extended Producer Responsibility (EPR) law for packaging and paper products. CDPHE subsequently approved CAA’s final program plan on December 9, 2025.

Maryland’s Environment – Statewide Recycling Needs Assessment and Producer Responsibility for Packaging Materials Act directed the Maryland Department of the Environment (MDE) to conduct a statewide recycling needs assessment. The law also established an Advisory Council to support the development of a legislative proposal for an Extended Producer Responsibility (EPR) program for packaging and called for the appointment of a single nonprofit Producer Responsibility Organization (PRO) to represent producer interests.

On October 18, 2023, MDE selected Circular Action Alliance (CAA) to represent producers and serve as the state’s sole nonprofit PRO on the State Producer Responsibility Advisory Council. In May 2025, Maryland enacted SB 901, establishing an Extended Producer Responsibility (EPR) program for packaging and paper products. This legislation followed SB 222 (2023), which required MDE to conduct the recycling needs assessment, create the Advisory Council, and appoint a nonprofit PRO.

In 2025, MDE reaffirmed CAA as the PRO responsible for developing and implementing the first five-year program plan required under SB 901. Maryland also adopted regulations for the program, which take effect on May 25, 2026.

Minnesota’s Packaging Waste and Cost Reduction Act requires producers of packaging, food packaging, and paper products to become members of a Producer Responsibility Organization (PRO). Through the PRO, producers must partially fund the end-of-life management of covered materials, including recycling programs.

On February 18, 2025, the Minnesota Pollution Control Agency (MPCA) confirmed Circular Action Alliance’s (CAA) registration to implement the state’s EPR program. Producers are required to join a PRO registered with MPCA by July 1, 2025.

Maine’s LD 1541 requires producers of consumer packaging materials to register with a Stewardship Organization (SO)*. Through the SO, producers are responsible for funding the end-of-life management of packaging materials, including reimbursements to participating municipalities for the management of both readily recyclable and non-readily recyclable packaging.

Circular Action Alliance (CAA) intends to respond to Maine’s Request for Proposals (RFP) to serve as the state’s Stewardship Organization.

*LD 1541 uses the term Stewardship Organization instead of Producer Responsibility Organization.

Oregon’s Plastic Pollution and Recycling Modernization Act requires producers of residential and commercial packaging, printing and writing paper, and food service ware to join a Producer Responsibility Organization (PRO). Through the PRO, producers must fund the end-of-life management of covered materials, including processing and recycling activities.

CAA Oregon is currently the only PRO with an approved program plan in the state. The Oregon Department of Environmental Quality (DEQ) approved CAA’s plan on February 21, 2025.

On March 4, 2026, the Washington State Department of Ecology (ECY) announced that Circular Action Alliance (CAA) would represent producer interests and serve as the nonprofit Producer Responsibility Organization (PRO) on the Recycling Reform Act Advisory Council.

Washington’s Recycling Reform Act, enacted in 2025, established a statewide system for implementing and financing the collection, transportation, and processing of covered packaging and paper products for reuse, recycling, and composting.

Under the law, producers of residential packaging, paper products, and food service ware must join and financially support a nonprofit PRO. As Washington’s designated PRO, CAA will collaborate with the Advisory Council, local governments, and solid waste service providers to develop a program plan and implement the statewide program by 2030.