What Happens When Companies Pay for Packaging Waste? | Kim Holmes

In this episode, Cory Connors talks with Kim Holmes about Oregon's landmark position as the first U.S. state to implement Extended Producer Responsibility (EPR) for packaging. Kim traces her path into sustainability — from a paralegal detour to a master's in urban studies at Portland State University, through hands-on recycling and waste characterization work with Community Environmental Services — before landing in her current role leading Oregon's CAA team. She breaks down what a producer responsibility organization actually does, how Oregon's "shared responsibility" model differs from other states, and what's driving the buildout of the Recycle On network of drop-off sites across the state.

Key Topics Discussed:

• Kim's career path into recycling and sustainability policy
• What the Circular Action Alliance is and how it supports producer compliance across Oregon, California, Colorado, Maine, Minnesota, and Washington
• Oregon's shared responsibility model between producers, local governments, and haulers
• The Recycle On brand: public education, outreach, and drop-off collection network
• How producer fees are calculated and why they vary state to state
• Buildout of Oregon's 144 planned collection points, including partnerships with transfer stations and Southern Oregon Goodwill
• Materials accepted at drop-off centers (film, rigid plastics, foil, shredded paper, glass) versus the curbside system
• How Recycle On differs from Oregon's Bottle Bill deposit system
• The NAW constitutional challenge to Oregon's EPR law and its narrow preliminary injunction
• EPR's long track record internationally (Canada, Europe, and beyond) versus its newness in the U.S.
• Recent wins: roll cart rollouts in The Dalles, new truck deliveries in Southern Oregon, and transportation cost reimbursement for rural communities
• The Contamination Audit Center and Contamination Reduction Funding mechanism
• Working toward a national responsible end-market verification standard with SCS Global
• How other states are watching Oregon's implementation and where harmonization may emerge

Resources Mentioned:

• Recycle On Oregon page 
• Oregon Department of Environmental Quality (DEQ)
• SCS Global

Contact:

Listeners can learn more about Oregon's EPR programs, find drop-off locations, and get in touch with the Circular Action Alliance team at recycleon.org/oregon.

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Transcript

0:06

Welcome to Sustainable Packaging with Cory Connors presented by Atlantic Packaging. I'm your host, Cory Connors. In today's episode, I connected with the Oregon Executive Director of the Circular Action Alliance, Kim Holmes. As the first US state to implement extended producer responsibility, they are leading the way and we can learn a lot from them. I'd also like to thank our sponsors, 3M and Specright. We couldn't do this show without them. Welcome to Sustainable Packaging. I'm so excited to have my friend Kim Holmes, the Oregon Executive Director for the Circular Action Alliance. Kim, how are you? I'm doing great. Thanks for having me, Cory. You've got an impressive career in sustainability. We used to rub shoulders at different events and now you've settled into a role in Oregon. Can you talk to us a little bit about your background and why you focused on sustainability? Yeah, I think working in the environmental field has always been of interest to me. Actually, when I moved out to Oregon back in 2000, I'd originally thought about doing environmental law at Lewis and Clark and decided to work at a law firm. And I was a paralegal. And then after about a year decided I did not want to be a lawyer and sought a different graduate program and settled at Portland State University doing a master's in urban studies with a concentration of policy analysis and was really fortunate to hook up with a unique group there called Community Environmental Services. And it was an organization that took primarily graduate students and linked them to contracts with local governments that worked on solid waste recycling, green purchasing and green team projects. And so that's where I really fell in love with recycling. So we did a wide range of things from single family weight studies to waste characterization studies, report writing and technical services to businesses of all sizes and including the Port of Portland. So got really good experience there. And then just the opportunities continued to lend itself to growing in this field. So it was great. And I would say community environmental services incubated just a powerhouse of talent of folks that are still in the industry today that I work closely with in this capacity. So I think it really speaks to the importance of providing professional development training opportunities for young people who are interested in this field. I totally agree that there's something in the water here in the Northwest that produces people like you and me that really care about this environment and the world and our fellow humans. And we want to make things more comfortable and more sustainable. Thank you for the work that you're doing. It's impressive and it's exciting. I want to talk about the Circular Action Alliance. What is the CAA for people that don't know and tell us what you do? Yeah, so Circular Action Alliance is a nonprofit producer responsibility organization. We were formed by some of the largest global brands in anticipation of needing to meet their compliance obligations. I think in Oregon, Colorado, and Maine, I think those were the first three to pass their EPR bills in 2021. So being forward looking, the CAA was developed and we have grown. We are the pro, not just in Oregon, but California, Colorado, Maine, Minnesota, and Washington. And so really the goal is to make producer compliance across all of these states as convenient and easy as possible for them while building state teams that offer very specific and targeted compliance programs. It's such a huge undertaking and the people I've spoken with from Circular Action Alliance are very busy and I know you're the same. You have a team working with you here in Oregon. Tell us what makes Oregon a little bit different and maybe tell us about Recycle On, which is an Oregon specific program. Yeah, so here in Oregon, we do have the honor of being the first to implement in the country. But I think what's going to be really exciting over the next few years is to see Colorado's will be implementing later this year, California will be coming online, and then we've got another pack of states coming up behind that. So it's really exciting to see how EPR can play out in different systems so we can start to learn about what works and what doesn't work. What makes Oregon unique, though, is that we are a shared responsibility model. So the producers have obligations to support a part of the system, local governments in partnership with their hauler service providers. They have obligations to fulfill under the law as well. So we've really, really made it front and center, our work in Oregon that we partner. very closely with our hauler and local government partners. We are only as successful as they will be. So we really see this as a collaborative effort with the system. The Recycle On brand, it's our public facing education and outreach brand. It's also the brand that we're using for our drop off sites, our collection points for the materials that the pro is responsible for uh accepting and managing. People can also find information about recycling on our recycleon.org website as well. And some of the program materials as well. That's excellent. So to step back a little bit, producer responsibility organization is the nonprofit, what your circular action alliance is the nonprofit that will collect the funds from the extended producer responsibility fees or taxes that go to the producers, which are the people that sell items into Oregon. from anywhere in the world. The companies that make products that have packaging will have a small tax on each one and that money will go to Circular Action Alliance and Recycle On to be used to improve recycling and make a more circular economy. Is that kind of the basics of it? That's a good way to summarize it. would say what one thing that is unique from state to state is sometimes the definition of who an obligated producer is and the definition of a covered product. And so the producer responsibility organization also helps producers navigate what their obligation is from state to state. I will note that fees, we call them the fees that producers pay for their covered products. They will vary from state to state because there are different compliance obligations from state to state. So for in Colorado, the producer responsibility organization is responsible for kind of reimbursement and covering the cost of the system. Where in Oregon, we're responsible for covering a portion of the curbside system, building out this really unique network of collection points that we'll be managing as the pro. And then most of the states also have a responsible end market obligation. So When producers look at the fees from state to state and wonder why they may be different, it is reflective of what it costs to fulfill the compliance obligation on their behalf in each of those states. It's pretty amazing and it's a huge undertaking. Can you tell us a little bit more about these drop-off centers and when they'll be ready and what kinds of materials will you accept at the drop-off centers? Yeah, we are particularly excited about this. And like I mentioned, Oregon is the only state so far that has this type of provision. So we are obligated to develop this network of collection points across the states to meet the convenience standard requirements. As those requirements are currently set, we need about 144 collection points across the state. Really, the goal is to ensure that people have good and equal access to these recycling operations. opportunities, whether they reside in Portland, or Baker City in Eastern Oregon. So we are developing, we've already begun our rollout of sites. We currently have 26 collection points open right now, primarily in Southern Oregon and Central Oregon and the Deschutes County Bend area. And we'll be very rapidly, and Eastern Oregon, we've moved to Eastern Oregon and will be very rapidly beginning to scale up on the I-5 corridor between Lane Lane County and the metro region. here over the course of this year and into the next. So we have until the end of 2027 to meet our compliance obligations. The types of materials that we're collecting there are the materials that don't necessarily right now play well in the curbside system. There may be sortation issues at the MRF, for example. So some of those materials include things like polyethylene film, polypropylene and polyethylene caps and lids, plastic. package handles, kind of like the six pack and four pack carriers, the rigid ones, plastic buckets, which are also included in the curbside program, but the DEQ wanted to make sure there was plenty of opportunity both through drop-off and curbside, pressed foil products, aluminum foil, and shredded paper. And in some of our locations, we'll also be providing glass collection. We have created an incentive system where glass is a material at this time that's managed by the pro. And so we wanted to make sure that we are preserving the best access possible. So for communities that do offer curbside collection of glass, are offering a incentive for them to continue ah that service because we think curbside is the most convenient. But we are working very hard to make sure these drop off locations are also convenient. We're looking at locations where all of them at this time and the goal is to have them co-located. where there's some other sort of commercial activity. So for example, in Southern Oregon, and what we'll widely around the state is co-location with like transfer stations. So people are already hauling materials to the transfer station. They're already in the practice of bringing some recyclables there. So that's a convenient way for to expand access to recycling. We've also partnered with Southern Oregon Goodwill. So just like making a donation to Goodwill, people can bring most of these items, not glass, but most of these other items to those locations. And we have separate glass collection points in those areas. So all that to say, the points will not look the same, kind of in rural Oregon versus metropolitan Portland, perhaps. So we are working to figure out what the best fit is for each of the communities that we move into. That sounds incredible. And I've always thought Goodwill was a great idea to partner with for this kind of thing, because people are already bringing things that they consider unnecessary in their homes. And so might as well bring in the waste as well to Goodwill and help them. They've been on the podcast before and they've had some successful programs. I think this makes perfect sense to partner with them. Nice job. You mentioned a financial incentive a couple times. Is this anything like our famous bottle drop program, our deposit system, or is it something different? So it is different. ah We are big supporters of our historic bottle bill. We have a very, very successful bottle bill and the longest operating bottle bill in the country. And so there is a financial incentive to get people to participate that through the deposit return system. This is different. We don't offer a financial incentive for people to participate and bring materials, uh but what we do know is recycling is part of the ethos of being an Oregonian, right? Oregonians want to recycle. And so uh really by just offering them good access and consistent access across the country, we do think we'll see very strong participation in the program. And we are beginning to see in some of the ones that we rolled out early in Southern Oregon, people are very excited to have these in their communities. It feels good to be a part of the solution as a person that recycles myself. I enjoy it. like the process of sorting. I like to feel good about myself. Like, hey, I'm contributing for my little part here. Is that kind of the feedback you're getting from the people that are involved in the program when you talk to them? Yeah, people are enthusiastic about recycling more, particularly, you know, when we're bringing them to locations like uh our first opening was at a recycling facility in Ashland. So they've got a very enthusiastic community. This center has been operating for decades. And so people were very, very excited to see just the expansion of materials that they could bring there and knowing too. that as we're building the Recycle On brand, that they're bringing it into a system that has accountability and responsibility and transparency in end markets. So also part of the Recycle On brand is helping to rebuild some of that trust in recycling. So people can feel good about engaging and participating and being enthusiastic about it. It's nice to be a leader in this space as an Oregonian, as part of this group. So I'm really impressed with what you're doing and the team at Circular Action Alliance. I did want to talk about something a little more controversial. And this is kind of a long question here, but I'll read it. In July 2025, a major trade association, the National Association of Wholesalers Distributors, filed a constitutional challenge to Oregon's law. raising issues that are expected to reverberate across other states implementing similar frameworks. Can we talk about this National Association of Wholesalers, it's a lawsuit basically, right? Is that, that's what's happening? Yeah, I mean, I can't comment in depth on the lawsuit, but what I can say is in February, there was an initial hearing. At that hearing, the judge uh dismissed some of the claims and did ultimately create issue a preliminary injunction against enforcement, DEQ enforcement of uh members of NAW. CA is not a party to the lawsuit. are not a defendant, but certainly have been monitoring it. In our view, it's a narrow preliminary injunction. There is a scheduled trial date in July, where we're very much looking forward to resolution on this. And what I can tell you is with that narrow preliminary injunction, we have not changed any of our plans in terms of the speed of our rollout or what our goals are for the year. So our work remains unchanged. despite the fact that this lawsuit is currently underway. That's good news because I think a lot of us were concerned that it would really throw a wrench into things. And of course I understand why people want to push back. Some of these costs will be passed on to companies and uh they're concerned with those effects on their businesses. But I think if we could, we can all pitch in together and make this really successful. So that's great news. Nice job. And it is good to remind everyone that while packaging, EPR for packaging is new in the US, packaging EPR has existed globally for decades, right? A strong foundation of programs in Canada, Europe, I believe even Russia has had packaging EPR for some time, right? So these are not new programs to producers, particularly those that have a global footprint. It's just new here in the US. Right. That's a really good point. And I think we should talk about some more of the positive benefits of EPR. Can you talk about some of the things that are positive effects of EPR extended producer responsibility? Yeah, so again, each program is unique, so I can speak to some of the positive things happening here in Oregon. We've had some very exciting milestones in this past few weeks. The Dalles, Oregon just got their roll carts delivered. That's an investment that producers were making. So they're transitioning from Kirby's to roll carts, and they're expanding their list, what we call the uniform statewide collection list. And so that is the vision that any community over 4,000 in population will have the same access to recycling across the state. We had our first trucks delivered down in southern Oregon. You'll see a press release about that very soon, about new programs launching there. So we are seeing new services come to communities that were previously underserved or not served at all in recycling. Another, I think, real benefit and a piece that I'm excited about with the program is the transportation. reimbursement. So for communities that have to transport their mixed recyclables more than 50 miles from their community to a material recovery facility or what we have renamed them here in Oregon, a commingle recycling processing facility or a CRPF. uh I see this funding mechanism as like the great equalizer. Transportation costs from Eastern Oregon to the Portland metro region where many of the permitted CRPFs are currently operating. was previously cost prohibitive. And one of the primary reasons they didn't have recycling. And so when you take away uh that cost to the system, again, it improves access for all and really equalizes the cost of recycling for the ratepayers, whether again, you're in Baker City or Portland, Oregon. So that's a really exciting part. We have the recycle on centers that's expanding what can be recycled. Also, we are doing a lot of work to ensure that The markets that materials are going to are responsible end markets. We've been working very closely with DEQ on our recent program plan amendment that details our interim verification program until our standard, our national standard is being developed working with SCS Global. So we'll have a formal standard that we can, our vision is to apply that across all the states we're operating on. to ensure that the materials that people are recycling are not going to communities and burdening other communities around the world or damaging the environment. So, and then I guess one final piece that we also think is very exciting and continues to be the star of the show is the Contamination Audit Center that we've opened. Yeah, so we are actually processing 100 samples or more from across the state on a monthly basis. So we'll be working to bring those in, sort them down to over 120, 22 material categories or so. And then we give that data back to communities. And so they can really see what their contamination levels are down to the root if they'd like to. And so they can do some very targeted outreach. There's another funding mechanism that we have in place to drive down contamination. That's the contamination reduction funding. So the pro pays $3 per capita. for local governments or their service providers to use to address contamination, which creates cost for the whole system. So we're getting that money deployed to communities as well. So with that money, coupled with the data that we're receiving from the audit center, we really hope that we can improve the overall quality of the materials that are coming into the system and then leaving to go to end markets in Oregon as well. That's what it's all about, I think, is number one, making it consistent. And I think that's what is exciting about the Recycling Modernization Act is that it will be consistent across the whole Oregon state. And I think, like you mentioned, you're going to service areas that have never had recycling before, or even maybe waste collection. now, instead of, you know, I'm... a couple streets over, know it's different what they collect. And to me, in I'm outside of Portland in the Milwaukee area. And to me, that's so it's different because of the different counties. So I'm excited to see that those rules will be standardized. I think. Do you think that that's what's going to happen across other states to you? Are you are you being reached out to by other states and saying, hey, what's working, Kim? What's not working? Are they kind of copying us as one of the leaders or are they uh learning from our mistakes? So I've a bit had Oregon blinders on us. We're focused on implementation. So I can't speak too much to kind of the direction other states are going. What I can say is, as a national organization, one of the benefits is that we are constantly sharing best practices and materials. So for example, the education outreach materials that we are charged with producing in Oregon and local governments and haulers can access at no cost, right? We're creating a standard look and feel for how we communicate. about recycling to residents and businesses, that look and feel will be translated to other states where it can be. So we are seeing just through our operational implementation, some of those things naturally translate. We also know too that regulators are speaking frequently with each other and also sharing information about what's working well, what's not working well. You know, and then I think as states implement and mature, we'll be going through rulemaking phases, right? And I know very much we as an organization want to look for opportunities for harmonization in implementation, both to create efficiencies, to make sure that best practices are being implemented across the states. So I think we'll naturally see some of that harmonization occurring. I also think too, we've seen a bit of a slowdown. in terms of the rate of new laws being passed this legislative session. So I think some states are taking a bit of a sit back and see approach to see which models might be emerging. So there's less retooling that needs to be done, right? You can already go out and say like, I want that model. I know it's going to work for my state. That makes a lot of sense to kind of sit back and wait and see, does this one work or this one doesn't work? like you mentioned before, extended producer responsibility isn't a new thing. They've been doing it for 20 years in Canada and I think even longer in other places. So it works. We know it works. We just have, how do we implement it here in the U S to make it successful? Nice job. Keep up the good work. Anything else you wanted to tell us about, as consumers that we should be focused on or as packaging companies we should know about? Yeah, mean just, uh you know, the overall message that packaging EPR works and it's working in Oregon and producer dollars are really funding meaningful change here on the ground and we'll be seeing that in all of the states that we're operating. So appreciate the all of the producer engagement and really the engagement of our partners. As I said at the offset, we are only as successful as the haulers and local government. that work with us. So really look forward to continuing to collaborate with them to make this a long-term success for Oregon. Well, keep up the great work. How do people get in touch with you and your team at the Oregon Circular Action Alliance? So the best way for people to get in touch with us is through our website, recycleon.org. slash Oregon. There you can find lots of information about ah what's available in different communities and the progress of the team across the state and some contact info. Well, great job, Kim. Thank you. And thank you to all the people who are involved with this program. Thank you for the people at the DEQ that have been working for years on this, well in advance of even the formation of the CAA. And I just want to congratulate all of you for the work that you're doing, because I think it's incredible. Thank you. It's a very exciting time to be working in recycling in Oregon. We'll have to have another show here in six months or a year and talk about kind of the progress of what's changed maybe. Would you be okay with that? All right, deal. Thank you.