Circular Action Alliance in Washington: What the PRO Does for Producers

What is Circular Action Alliance, and who says what about it?

CAA describes itself as a nonprofit, producer-led organization. Three sources speak about CAA, and they differ in weight.

• The statute. Chapter 70A.208 RCW defines a PRO in RCW 70A.208.020(30), sets producer duties in RCW 70A.208.040 and sets what a PRO files with Ecology. Ecology's page applies the name Recycling Reform Act to chapter 70A.208 RCW, a name absent from the chapter's own text.
• Ecology. Its producer page says: "The Circular Action Alliance is the PRO representing producers in Washington. We encourage all potentially obligated producers to register with CAA." It also calls CAA "the first point of contact for producer reporting guidance."
• CAA. Its about page describes a nonprofit, producer-led organization, founded in 2022 and guided by producers representing the food, beverage, consumer goods, restaurant and retail industries. Its Washington page says Ecology announced on March 4, 2026 that CAA will represent producer interests and serve as the nonprofit PRO on the advisory council.

The legal duties come from the statute. The encouragement is Ecology's wording, and CAA's forms and policies are CAA's own. The statute gives a producer two routes: be a member of a PRO registered in this state, or register as a PRO that will implement an individual plan (RCW 70A.208.040(1)(a)). The PRO guide covers how many PROs the statute allows.

What does CAA publish about joining?

At this article's last verification date, Ecology's page said: "Producer registration is open on Circular Action Alliance's website." CAA's registration page says producers begin with an Account Registration Form, completed once for each obligated producer. The form asks for:

• Confirmation that the company is an obligated producer, based on its understanding of the legal definitions.
• The producer's legal business name.
• The EIN/CAIN associated with the company.
• The name and EIN/CAIN of the parent company.
• A Primary Contact, the first point of contact for communications with CAA.
• An Authorized Representative, who is authorized to bind the company and sign legal contracts.

After the form and the Participant Producer Agreement (PPA), CAA says you gain access to the Producer Portal, where producers complete registrations for each state they are obligated in. CAA adds that it will communicate additional next steps to the primary contact, including details on fees and data collection when they become available. The page also says: "There is no cost to register with CAA." That sentence covers registering, not fees.

Two limits apply. At this article's last verification date the page's opening sentence named California, Colorado, Oregon and Minnesota laws and did not name Washington, so ask CAA which steps apply to a Washington registration. And the first item on the form is your own call: CAA says it "is not able to provide legal advice or make this determination for you."

CAA's Washington page words the registration date two ways. Its FAQ says producers "must register with a PRO by July 1, 2026." Its milestone list says producers must be a member of a registered PRO or register as a PRO with an individual plan "after July 1, 2026." The statute says "after" in RCW 70A.208.040(1)(a), and the deadlines article follows the statute.

Read CAA's Producer Policies as well. CAA says it maintains policies that define producer obligations and participation in the PRO. They set what a producer must meet to remain in good standing with CAA's participation agreements. The bar in RCW 70A.208.040(2) is written for a "member in good standing with a registered producer responsibility organization," and RCW 70A.208.020 does not define good standing. The statute does not say whether CAA's standing and the statute's standing are the same, so ask Ecology before you treat one as the other.

What do producers report, and what does the PRO report to Ecology?

Producers report data to the PRO, and the PRO reports to Ecology. Ecology's page lists four producer obligations: register with an approved PRO, report data to it, pay it membership fees and comply with the law's requirements.

CAA's reporting page says producers must submit reports to CAA on the quantities of covered materials supplied into applicable states, entered on CAA's Producer Portal. It lists sales, packaging weights, brands represented and affiliated or associated producers among the information a report needs. It also says reporting requirements vary by state, and its worked example dates are for Oregon. Use the deadlines article for Washington dates.

The PRO's own filings go to Ecology:

• The PRO's yearly registration under RCW 70A.208.030(2) calls for a list of member producers with written agreements and copies of those agreements. After the first year of registration, it also calls for a list of all brands of each producer's covered materials introduced.
• The annual report under RCW 70A.208.200(1) includes covered materials introduced by type, total producer fees collected and an independent financial audit. It also lists producers found out of compliance and the PRO's actions to return them to compliance. Ecology must make annual reports available for public review and comment for at least 30 days (RCW 70A.208.060(6)).
• A PRO must also expel a producer if efforts to return it to compliance fail, and must notify Ecology (RCW 70A.208.040(3)(g)).

This table sorts out what stays with the producer.

What does membership cost?

No Washington fee amount appears in the statute or, at this article's last verification date, on any CAA page cited here. RCW 70A.208.160(1) lets a registered PRO charge each member a fee by market share or another method it determines to be equitable. The eco-modulation article covers the fee rules after a plan is approved. Ecology's page says Circular Action Alliance "will set the producer fees and is required to set modulated fees that incentivize packaging that is recycled or composted under the program plan." CAA's Washington page says it "will establish an early fee structure and timeline for initial (pre-program) producer fees." Its fee-setting page says fee rates "will vary by state due to differing state requirements and program costs."

A figure from another state is therefore not a Washington figure. Ask CAA for Washington figures in writing, and build a budget only when you have them.

Common questions

What is Circular Action Alliance?

CAA describes itself as a nonprofit, producer-led organization. Ecology's producer page names it the PRO for Washington producers, as quoted above. CAA is a private organization, not a government agency. Its own pages set its sign-up steps, and the statute's duties are in RCW 70A.208.040.

Is Circular Action Alliance the only PRO in Washington?

The statute allows Ecology to register only one PRO for the first plan implementation period, apart from an individual producer registered as a PRO (RCW 70A.208.030(3)). Ecology's page names CAA. It also lists Interchange 360 as an approved group planning an alternative collection program for petroleum and lubricants, and does not call it a PRO.

How do I register with Circular Action Alliance?

Ecology says registration is open on CAA's website. CAA says producers begin with an Account Registration Form, then sign the Participant Producer Agreement to reach the Producer Portal. The form asks for company and parent company details and two contacts. At this article's last verification date, CAA's registration page named California, Colorado, Oregon and Minnesota laws, so confirm the Washington steps with CAA.

What does membership cost?

The statute sets no amount, and none appears on the CAA pages cited here. RCW 70A.208.160(1) lets a registered PRO charge members by market share or another equitable method. Ecology says CAA will set the producer fees. CAA says registering costs nothing and that fee rates vary by state. Ask CAA for Washington figures in writing.

What does the PRO report and to whom?

The PRO reports to Ecology. Its yearly registration lists member producers and includes copies of their written agreements. It also submits a plan and, later, an annual report covering materials introduced, producer fees collected, an independent financial audit and producers found out of compliance. Producers report their own data to the PRO.

What to do next

1. Confirm you are a producer. Use the coverage checklist and the de minimis test. CAA's form asks you to confirm this yourself.
2. Choose your route. RCW 70A.208.040(1)(a) offers membership in a registered PRO or an individual plan. Ask Ecology or a lawyer if unsure.
3. Gather the form data first. Have the legal business name, EIN/CAIN, parent company details, a primary contact and an authorized representative ready.
4. Read before you sign. Ask for the Participant Producer Agreement and read CAA's Producer Policies.
5. Start a supply file. Our own method, not a CAA form: for each product you introduce into Washington, keep sales, packaging weights by material, brands and affiliated producers.
6. Track dates and ask in writing. Put the dates from the deadlines article in your calendar, and ask CAA in writing which Washington steps and fees apply.

I am a Distinguished Committee Member of the SWANA Sustainable Materials Management Technical Division and a juror for the NYSAR3 Recycling Leadership Awards, both since 2023.

Before you open any registration form, the Washington EPR Compliance Assessment can walk through whether you are the producer and which route fits. Send your product list and supplier names beforehand.

Get the Washington EPR Compliance Assessment

General information, not legal advice.