Sources are legislature pages only. Washington: the session-law text could not be read; I used the legislature's Final Bill Report (leg.wa.gov), which summarizes the enacted act (C 316 L 25). Maryland statute text came from the enrolled chapter PDF (text extracted locally; some words garbled but numbers checked).
| Fact | Draft | Official | Source | Status |
|---|---|---|---|---|
| Small producer: revenue | under $5M | gross revenue under $5M, most recent fiscal year (ORS 459A.863(32)(c)) | ORS page above | verified |
| Small producer: tonnage | under 1 metric ton | under 1 metric ton sold in/into Oregon, last calendar year (32)(d) | same | verified |
| Beverage makers | under 5 metric tons | same (32)(e) | same | verified |
| Annual report May 31 | May 31 each year | Statute: the PRO's annual report is due July 1 (ORS 459A.887). No May 31 producer date in statute | same | corrected (May 31 unverified) |
| CAA approved 2025-02-21 | date | not on statute page | none found | unverified |
| Fact | Draft | Official | Source | Status |
|---|---|---|---|---|
| Small-producer exemption | set by rulemaking | Act excludes "de minimis" volumes; no numeric threshold in the report; $5M (inflation-adjusted) only for agricultural employers' own-brand sales | Final Bill Report | unverified (no number) |
| Registration | 2026-07-01 | Producers and PROs register with Ecology by 2026-03-01; producers must be in a PRO (or individual plan) by 2026-07-01 | Final Bill Report | corrected |
| Annual fees begin | 2027-05-01 | Ecology sets the annual PRO registration fee by 2027-03-31 and yearly after; 2027-05-01 appeared only in an earlier House version | Final Bill Report | corrected |
| Program plan | 2028-10-01 | Draft PRO plan by 2028-10-01 | Final Bill Report | verified |
| Fact | Draft | Official | Source | Status |
|---|---|---|---|---|
| De minimis | under 1 ton or under $2M global gross revenue | same (115A.1441, "De minimis producer") | revisor page | verified |
| Registration 2025-07-01 | PRO registration | Producers must be PRO members after 2025-07-01 (115A.1448 subd. 1); PRO registers by 2026-07-01 and each Jan 1 (115A.1443 subd. 1; subd. 3 also says Jan 1, 2025 for the initial PRO) | revisor page | corrected |
| Reports 2026-05-31 | simplified report | No such date in statute; PRO annual report starts 2029-04-01 (115A.1456) | revisor page | unverified |
| Needs assessment | 2026-12-31 | By 2026-12-31 and every 5 years (115A.1450) | revisor page | verified |
| Stewardship plan | 2028-10-01 | same (115A.1451) | revisor page | verified |
| Funding starts 2029-02-01 | funding | Reimbursement to service providers of at least 50% of net cost by 2029-02-01, 75% by 2030, 90% by 2031; PRO registration fee from 2029-01-01; producers need a PRO agreement after 2029-01-01 | revisor page | corrected (wording) |
| Fact | Draft | Official | Source | Status |
|---|---|---|---|---|
| De minimis | under 1 ton or under $2M global gross revenue | same (new 9-2501 definition "De minimis producer") | Ch. 431 | verified |
| "Primary packaging only" | yes | Not in the definition I could read; unconfirmed | Ch. 431 | unverified |
| Registration 2026-07-01 / 2026-05-31 | conflicting | Not in chapter text; chapter sets the date for the sales prohibition and reporting by MDE regulation | Ch. 431 | unverified |
| Plans due | 2028-07-01 | By 2028-07-01 and every 5 years (9-2505(B)(1); bill text struck April 1, 2027) | Ch. 431 | verified |
| Sales ban 2028-10-29 | date | Statute: the ban applies from a date set in MDE regulations (9-2505) | Ch. 431 | corrected |
leginfo.legislature.ca.gov returned 403 to curl; not bypassed. Statute and regulation text (PRC 42041, 14 CCR 18980.5.2) not read directly; I relied on the CalRecycle pages, which cite them.
| Fact | Draft | Official | Source | Status |
|---|---|---|---|---|
| Small-producer exemption | gross annual sales under $1M | "gross annual sales of less than $1 million may apply to be exempt from most of the law's reporting and fee requirements"; must plan for all packaging recyclable/compostable by 2032 | exemptionsexclusions page | verified |
| Must register to claim | register with CalRecycle | Register in PEPRS as a Packaging EPR producer, then file the small producer exemption application (14 CCR 18980.5.2) | same | verified |
| CAA approved as first PRO | approved | "Circular Action Alliance has been approved to serve as the first Producer Responsibility Organization (PRC 42061.5)" | packaging-epr page | verified |
| CAA plan received | 2026-10-13 | "On October 13, 2026, CalRecycle received" the plan | same | verified |
| Review period | 75 days | "CalRecycle has 75 days to review the plan" | same | verified |
| Comments due | 2026-11-13 (Aug 14 from a secondary source conflicts) | Comments through November 13, 2026 to packaging@calrecycle.ca.gov, subject "PRO Plan Comments"; Aug 14 not on page | same | verified |
| Advisory Board meeting | 2026-11-06 | Listed under Upcoming Events | same | verified |
| Registration closed | 2026-06-01 | Not on pages read | none | unverified |
| 2025-data reports due | 2026-05-31 | Not on pages read | none | unverified |
| First fund payment | 2027-03-01 | Not on pages read | none | unverified |
| Program start | by 2027-01-01 | Not on pages read (page says only the Covered Material Categories List update is due by 2027-01-01) | none | unverified |
This is the 2022 enacted text (C.R.S. 25-17-701 et seq.). Later amendments and the current C.R.S. page were not checked. cdphe.colorado.gov returned 403; not bypassed.
| Fact | Draft | Official | Source | Status |
|---|---|---|---|---|
| De minimis / exemption | set by CDPHE rule, inflation-adjusted yearly; figure unverified | Statute sets it: under $5M realized gross total revenue (excluding on-premises alcohol sales) in prior year, or under 1 ton of covered materials sold into CO (25-17-713(1)(a),(b)). Also exempt: governments, nonprofits, small ag employers, licensed retail food establishments, builders. The Commission adjusts the dollar limit by rule each July 1 for Denver CPI (713(2)). Current adjusted figure not found | HB22-1355 | corrected (statute gives $5M base; current figure unverified) |
| Participation required | not in draft | From 2025-07-01 producers may not sell covered products unless in the program (25-17-708(1)) | same | verified (added) |
| Dues | due by Jan 1 yearly, first 2026-01-01 | Dues by a date set by the PRO "no later than January 1, 2026" and annually after by a PRO-set date (25-17-709(1)(a)) | same | corrected |
| PRO is CAA, since 2023-05-01 | date | Statute names no organization or date | none | unverified |
| Registration closed | 2024-10-01 | Not in statute | none | unverified |
| Supply data due | 2025-07-31 | Not in statute | none | unverified |
| Fact | Draft | Official | Source | Status |
|---|---|---|---|---|
| Revenue exemption | under $2M first 3 years, then $5M | Reversed: exempt under $2M prior-year gross revenue, except under $5M during the window starting 1 calendar year after the DEP-stewardship organization contract's effective date and ending 3 years after that date (2146(2)(A)) | statute page | corrected |
| Tonnage exemption | under 1 ton | Under 1 ton of packaging material in/into Maine, prior year (2(B)). Also exempt: over 50% of revenue from salvage/closeout goods (2(C)) | same | verified |
| Perishable food | first 15 tons | First 15 tons of packaging for perishable food (statute text read) | same | verified |
| How the PRO is chosen | DEP contracting a stewardship org | DEP selects one stewardship organization by RFP (10-year term) after initial rules (2146(3)) | same | verified |
| Contract status / no PRO yet | none confirmed | Statute does not say whether a contract exists; DEP page not read | none | unverified |
| Registration end of 2026 | expected | No such date in statute | none | unverified |
Verified 21, corrected 9, unverified 15 (45 facts). This pass: CA verified 7, corrected 0, unverified 4; CO verified 1, corrected 2, unverified 3; ME verified 3, corrected 1, unverified 2. Earlier pass: OR/WA/MN/MD verified 10, corrected 6, unverified 6. Not checked: PRO (CAA) claims other than CA approval.