State EPR Laws: March 31 Oregon Registration Deadline & Delay in California

March 12, 2025 | Toy Association staff is closely monitoring the progression of enacted Extended Producer Responsibility (EPR) laws for paper and packaging throughout the U.S., focusing on compliance requirements for its members. Below are the latest updates in Oregon and California:

Oregon
Oregon’s EPR program will start on July 1, 2025, however, there is an upcoming March 31, 2025 reporting deadline for producers to register and submit their supply data with the state’s producer responsibility program, Circular Action Alliance (CAA). This applies to toy manufacturers that sell product in Oregon so that they can continue to sell, offer for sale, import, or distribute covered materials under the state’s EPR law. Click here to register or contact [email protected] with any questions.

CAA is also working to implement EPR laws as the PRO for California, Colorado, Maryland, and Minnesota.

California
In a major development, California Gov. Gavin Newsom has delayed the implementation of the state’s SB 54 law. Also known as the Plastic Pollution Prevention and Packaging Producer Responsibility Act, SB 54 is the largest comprehensive packaging EPR program in the country. Signed in 2022, the legislation requires plastic and packaging companies to cut single-use plastic packaging by 25 percent and ensure recyclability or compostability by 2032. It also shifts the financial responsibility for waste management from consumers and local governments to producers. However, just as regulators were set to finalize the rules on March 8, Newsom instructed negotiators — including CalRecycle, which is responsible for implementing SB 54 in the state — to restart the process.

“The Governor is directing CalRecycle to restart these regulations to ensure California’s bold recycling law can achieve its goal of cutting plastic pollution and is implemented fairly,” Daniel Villaseñor, Newsom’s deputy director of communications, said in a statement to the Los Angeles Times.

The Toy Association™ submitted comments to CalRecycle last year expressing significant concerns and addressing industry priorities on this issue.

The Toy Association will continue to keep the industry apprised of ongoing developments regarding state Extended Producer Responsibility (EPR) laws. For more information on The Toy Association’s advocacy initiatives at the state level or to join the State Government Affairs Committee, contact The Toy Association’s Charlotte Hickcox.