Fwd: Announcement of Oregon's Large Producers

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Jeanette Hardison

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Aug 19, 2025, 3:13:16 PMAug 19
to Waste Prevention Action Team | Corvallis Sustainability Coalition
This lists the top 25 producers doing business in Oregon that have the least environmentally friendly packaging, now subject to the new DEQ State rules around the Recycling Modernization Act. 

This should get interesting. There have already been lawsuits by wholesalers...

Jeanette 

---------- Forwarded message ---------
From: DEQ Online Subscriptions <or...@public.govdelivery.com>
Date: Tue, Aug 19, 2025, 9:42 AM
Subject: Announcement of Oregon's Large Producers
To: <Hardi...@gmail.com>

Hello,

Pursuant to OAR 340-090-0700(3) of the Recycling Modernization Act, approved Producer Responsibility Organization Circular Action Alliance has reported to DEQ the list of the top 25 (“large”) producers in the state by interim market share (weight of covered product supplied into the state in aggregate across material categories in 2024).   

DEQ is publishing the list in order to put the producers on notice that they will likely be subject to the requirement to conduct and disclose life cycle evaluation on 1% of their products by December 31, 2026, pursuant to ORS 459A.944(2) and OAR 340-090-0910(2), allowing the producers to begin working on the evaluations now. The list is still subject to change resulting from CAA validation of producer reporting and producers submitting corrections to their supply reporting to CAA. The final, definitive list of producers subject to the reporting requirement will be issued at the beginning of April 2026, resulting from final market share reporting for the 2024 data year submitted by CAA to DEQ by March 31, 2026, pursuant to OAR 340-090-0700(5)(a).  

Reporting guidance for large producers will be published in early 2026. In the meantime, producers may refer to the Bonus A ecomodulation guidance posted to CAA’s website, as the life cycle evaluation methodological and project report formatting requirements for Bonus A are very similar to those for large producer reports. When identifying products subject to the 1% reporting requirement, producers should follow rule OAR 340-090-0900(2)(a), lumping their SKUs together across associated producers (e.g. parent companies and their subsidiaries) and selecting the top 1% by number of units sold or distributed into Oregon in 2024.

Top 25 Producers in Alphabetical Order:  

1. Albertsons Companies, Inc.   
2. Amazon.com Services, LLC    
3. Berry Global, Inc.   
4. Conagra Brands, Inc.   
5. Conopco Inc.   
6. Constellation Brands,   
7. Costco Wholesale Corporation   
8. E&J Gallo Winery   
9. General Mills, Inc.   
10. McDonald's USA, LLC   
11. NESTLÉ USA, INC.   
12. North Pacific Paper Company LLC   
13. Pactiv Evergreen, Inc.   
14. PepsiCo, Inc.   
15. Staples, Inc.   
16. Sysco Corporation   
17. Target Corporation   
18. The Campbell's Company   
19. The Coca-Cola Company   
20. The Procter & Gamble Company   
21. Trader Joe's Company   
22. US Foods, Inc.   
23. Walmart Inc.   
24. WestRock Company   
25. WinCo Foods, LLC   

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