CAA participant dates and state filings are different records
Circular Action Alliance’s 2026 planning table identifies separate participant reports for Oregon, Colorado, and California. Those completed planning checkpoints are not one uniform state filing deadline, and a calendar entry is not proof that an account submitted, paid, or received a response. The useful move now is to verify each entity’s current account-level status and preserve its source record and receipt.
| Program | CAA participant record | Official state context |
|---|---|---|
| Oregon | CY2025 annual supply report | Oregon DEQ distinguishes the internal CAA reporting process from state-agency obligations. |
| Colorado | CY2025 annual supply report | The approved plan uses producer reporting for the next dues cycle; the program and 2026 dues are active. |
| California | Baseline, annual supply, and annual source-reduction records | CalRecycle filings and producer-to-PRO actions remain separate status records. |
CAA Reporting Policy V2 sets 11:59 p.m. Pacific as the default cutoff and generally recognizes a weekend or holiday report date on the next business day unless state law or a state addendum says otherwise. PackClose records the controlling source and check date instead of reusing an undated deadline from a prior cycle.
Sources rechecked 2026-09-04: CAA Producer Resource Center; CAA Reporting Policy V2; Oregon DEQ producer guidance; California final regulations; CalRecycle source-reduction guidance.
What is operational now, and what comes next
Oregon: operational since July 1, 2025
Covered producers register, report supply to CAA, and pay fees. The identified 25 largest producers have a December 31, 2026 life-cycle disclosure deadline for 1% of covered-product SKUs. Small-producer status can remove registration, reporting, and fee duties; most exempt volumes are omitted, but the private-recycling exemption requires gross supply reporting before the approved deduction.
Colorado: dues and implementation are live
CAA’s final plan was approved December 9, 2025; 2026 dues began in January 2026 (January 1). The approved plan schedules the announcement of 2027 dues rates for October 1, 2026. Colorado’s statutory small-producer revenue threshold is adjusted annually for CPI, so an old unadjusted dollar figure should not be treated as the current threshold. The plan’s ten-ton-or-less flat-dues path is not the same as the statutory under-one-ton exemption.
California: regulations are effective and the plan is still moving
Permanent regulations took effect May 1, 2026. CAA submitted a plan for public review, and CalRecycle guidance identifies October 13 as the next PRO-plan milestone and January 1, 2027 as the approval target. Billing and filing status remain account-specific and should be verified directly. California reporting also adds plastic-only weight and plastic-component counts. Its source-reduction percentages are collective PRO-level targets, not a uniform percentage assigned to every producer.
Sources rechecked 2026-09-04: Oregon program status; Oregon life-cycle evaluation; Oregon exemptions; CAA Colorado; approved Colorado plan; CalRecycle SB 54 status; California plan review.
The useful move now: make every total reproducible
PackClose applies a data close, borrowed from accounting: reconcile what was reported against what sales and packaging records support, connect every sampled number to its source, and produce a substantiation pack another person can follow. That gives teams:
- Repeatable weight math from units, component weights, allocation, and rounding.
- Faster validation responses from a source-linked workpaper and preserved version.
- Cleaner handoffs across packaging, finance, compliance, consultants, and the next reporting cycle.
The component-level data guide shows the shape of the underlying records; the Status & Exposure Scanner gives you a first read in the browser, and the $2,500 CAA Evidence Readiness Scan turns a qualified sample into a QA-checked workpaper in five business days after cleared payment and complete inputs.