Oregon is effectively the first EPR state, with a fairly well developed structure at this point, and into their second year of collecting fees with CAA as their PRO.
Oregon is now in their enforcement phase of EPR implementation, calling out 250 non-compliant producers in the state by name. I believe these are producers who registered with CAA and failed to complete reporting or pay associated fees. Some recognizable names on their list include Hobby Lobby, Mercedes Benz, and Papa John’s Pizza. I suspect they will be coming after producers who failed to register next. Penalties in Oregon for non-compliance are up to $25,000 per violation PER DAY, which can add up to a lot of commas and zeros real fast if they decide to throw the book at you. Oregon Calls Out Noncompliant Producers as Packaging EPR Enforcement Era Begins | Environmental Law and Policy Monitor