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Responsible End Markets

Recycling begins at the curb when you put things in your bin, rather than ending there. Beyond the processing facilities that sort our commingled recyclables are factories (end markets) that turn that recyclable material into products or feedstock to make new products. Whether or not recycling is environmentally beneficial, in large part, depends upon what happens at these end markets.

As of July 1, 2025, materials collected for recycling in Oregon must go to responsible end markets where “...recycling or recovery of materials or the disposal of contaminants is conducted in a way that benefits the environment and minimizes risks to public health and worker health and safety" (ORS 459A.863(29)). This obligation lies with the producers of packaging – organized together within the Producer Responsibility Organization – and with commingled recycling processing facilities. The policy establishes new transparency, auditing, and market development requirements for obligated parties to set a robust bar for what is considered “recycled" in and from Oregon.

How it works

  • The PRO and processing facilities must report on where the materials that they processed went.
  • If their reporting indicates that material is going to an irresponsible entity, the obligated entity(ies) must take action to resolve the problem.
  • The PRO is expected to cover the costs incurred to resolve end market issues, with its financial obligation capped by a “practicable" financial threshold set in rule (OAR 340-090-0670(5)). If a claim of impracticability is submitted by the PRO and accepted by DEQ, the material in question is subject to possible delisting.
  • DEQ oversees implementation, ensuring that statutory and rule requirements are met, that the PRO follows its program plan, and that the processing facilities operate in accordance with the requirements of their permits.

Implementation milestones

  • 2022-2023 – Oregon's Environmental Quality Commission adopted new statewide lists of materials to be recycled in Oregon – the Uniform Statewide Collection List and the PRO Recycling Acceptance List. By law, the availability of responsible end markets was among the criteria considered when developing recycling lists.
  • Feb. 21, 2025 – DEQ approved the program plan submission from PRO Circular Action Alliance, which includes a comprehensive vision to verify (through on-site auditing) that end markets used by CAA and CRPFs, as well as other facilities downstream of CRPFs, meet the responsibility standard established in OAR 340-090-0670(2).
  • July 1, 2025 - All downstream facilities used by commingled recycling processing facilities and the PRO must self-attest that they meet the requirements for responsible end markets and are compliant, transparent, environmentally-sound, and achieving adequate yields. Note: a six-month (July 1- Dec. 31, 2025) stay of enforcement applies to processing facilities that seek DEQ's acknowledgement and prove that they have no other option but to send materials to a non-self attested market.
  • Beginning July 1, 2025 - Local governments and their service providers must ensure that any materials collected for recycling are delivered to a processing facility that has a DEQ-issued permit or certification.
  • Beginning Aug. 15, 2025 – CRPFs are required to report their outbound shipments to downstream entities (e.g. first receivers in the recycling supply chains) on a monthly basis.
  • Dec. 2025 – Processing facilities and the PRO must begin reporting quarterly to DEQ on where materials go downstream of collection and sorting (e.g. beyond first receivers through to the end market and disposal locations).
  • June 30, 2027 – A qualified, independent, third-party auditor under contract with the PRO must verify that all end markets and other downstream facilities receiving recyclables from Oregon meet the responsible end market standard. The detailed standard for verification is included in the PRO's program plan and may be amended through the plan approval or amendment process.
  • 2028 – The PRO must ensure that 25% of plastic packaging and food serviceware supplied into the state is being recycled. Only materials recycled at responsible end markets can count toward the achievement of the goal.

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DEQ is organizing three upcoming webinars that will cover different aspects of the responsible end market obligation. Find information and registration links for the webinars below. Materials from these webinars will also be posted to this site following the webinars' completion.

Responsible End Market Basics – Webinar 1: Sept. 25, 2025
Oregon DEQ and approved producer responsibility organization Circular Action Alliance presented the basics of Oregon's responsible end market policy, including information on upcoming deadlines and updates. The intended audience for this webinar was recycling processors, brokers, and end markets. This was the first webinar in a two-part series.

Disposition Reporting for Commingled Recycling Processing Facilities: Sept. 30, 2025
In this webinar, Oregon DEQ explained at a high level how commingled recycling processing facilities can generate their quarterly disposition reports to DEQ. DEQ also provided updates on the CRPF acknowledgement process and transactional reporting during this webinar.

Responsible End Market Basics – Webinar 2: Oct. 14, 2025
Oregon DEQ and approved producer responsibility organization Circular Action Alliance will present the basics of Oregon's responsible end market policy, including information on upcoming deadlines and updates. The intended audience for this webinar is recycling processors, brokers, and end markets. This is the second webinar in a two-part series, which will repeat information from the first webinar in its first half, and present new information in its second half.


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  • ​Oregon Responsible End Market Screening and Self-Attestation Form
    To be used by the PRO, permitted and certified commingled recycling processing facilities, and producers seeking the exemption for private recycling under ORS 459A.869(13). These entities must seek self-attestation from the downstream facilities in their supply chains, as defined in OAR 340-090-0670(2)(a).

  • Oregon Responsible End Market Acknowledgement Form A
    To be used by CRPFs to document shipments of material to a market that has not yet self-attested, due to circumstances beyond the facility's control, such as limited market capacity or the unavailability of appropriate REMs for a select material.

  • Oregon Responsible End Market Acknowledgement Form B​
    To be used by material brokers, secondary processors, or other entitles included in OAR 340-090-0670(2)(a) that need to temporarily send material to a non-self attested market due to circumstances beyond the facility's control. Note: Form B submissions are made on behalf of commingled recycling processing facilities with which the material originated.​

Current list of self-attested facilities:



Contact

For PRO and producer inquiries:

Nicole Portley
Program Plan Lead
503-839-9323

For inquiries regarding commingled recycling processing facilities:

Steven Chang
Natural Resource Specialist 3
971-803-2493

For inquiries from end markets and other downstream facilities:

Justin Gast
Materials Management Specialist
503-869-4786

Inquiries may also be routed to approved PRO Circular Action Alliance at: rem.support@circularaction.org