Cosmetica
Packaging EPRWA

Washington packaging producer responsibility

SB 5284 — Recycling Reform Act (Laws of 2025, ch. 316)

Washington's Recycling Reform Act (SB 5284, Laws of 2025, chapter 316; RCW 70A.208) was signed May 17, 2025 and took effect July 27, 2025. Producers had to appoint a Producer Responsibility Organization by January 1, 2026 and must be members after July 1, 2026; the Department of Ecology announced Circular Action Alliance as the PRO in March 2026. CAA submits its program plan by October 1, 2028 and implements it by January 1, 2030 or within six months of approval.

Last updated:

All EPR states
Producer Responsibility Organization
Circular Action Alliance (CAA)

Who is a producer in Washington?

Generally the brand owner of the product placed in covered packaging. Small producers below the law's thresholds are exempt; check the current thresholds with the Department of Ecology.

Materials covered

  • Plastic, glass, metal, paper packaging
  • Cosmetic primary and secondary packaging

Producer obligations

  • Be a member of Circular Action Alliance, the PRO, after July 1, 2026
  • Submit the interim producer report to CAA; the 2026 report, on calendar-year 2025 data, was due May 31, 2026
  • Pay CAA's membership fees
  • Comply with the program plan once Ecology approves it

Compliance timeline

  1. Active

    Statute signed

    SB 5284 became Laws of 2025, chapter 316, effective July 27, 2025.

  2. Active

    Producers appoint a PRO

    Each producer had to appoint a Producer Responsibility Organization.

  3. Active

    CAA announced as PRO

    The Department of Ecology announced Circular Action Alliance as Washington's PRO.

  4. Reporting begins

    Interim producer report

    Producers' 2026 interim report to CAA in the simplified reporting categories, on calendar-year 2025 data.

  5. Active

    PRO membership required

    After this date a producer must be a member of a registered PRO.

  6. Upcoming

    Program plan due

    The PRO submits its program plan to Ecology for approval.

  7. Upcoming

    Plan implemented

    The PRO implements the approved plan by this date, or within six months of approval if later.

How Cosmetica helps

Cosmetica coverage for Washington

Cosmetica builds Washington's CAA interim producer report workbook, in the simplified reporting categories, from your packaging BOMs and per-state sales, and marks every packaging weight that is an estimate. It does not calculate fees.

Primary sources

EPR statutes and rules are evolving. Verify the latest dates, fee schedules, and de minimis thresholds with the state agency before relying on this summary for compliance decisions.