The idea of a single organization that could handle packaging compliance across every market a brand sells into sounds appealing. But as Extended Producer Responsibility (EPR) laws multiply around the world, the reality is far more complicated than the pitch. Here is what brands need to know about the "global PRO" concept, why the Circular Action Alliance is shaping the conversation, and what you can actually do right now to stay ahead.
A "global PRO" refers to a hypothetical single, cross-border Producer Responsibility Organization (PRO) dedicated to helping brands manage Extended Producer Responsibility (EPR) obligations for paper and packaging across many countries at once. The concept has gained traction as more jurisdictions adopt EPR laws, and brands face a growing patchwork of compliance requirements. In theory, a global PRO would consolidate registration, fee payment, reporting, and program plan management under one roof.
As of mid-2026, however, no single PRO is legally recognized as a global PRO for all markets. In the United States, the Circular Action Alliance (CAA) is the closest thing to a multi-jurisdiction model. The Circular Action Alliance CAA helps businesses comply with EPR laws for packaging and currently serves as a PRO in six U.S. states. While CAA is not global, its structure is influencing how a future cross-border model might look.
Many brands remain skeptical. Common concerns include fear of one-size-fits-all fee structures that ignore local recycling realities, limited transparency in how program plans allocate funds, the risk of paying into both a global organization and separate local PROs, and worry that recycled-content or recyclability targets may not align with real-world packaging design constraints.
For brands navigating this uncertainty, a packaging partner like Paper Tube Co. can help. Our focus on recyclable, paper-based, FSC-certified packaging with minimal plastic positions brands well under current and likely future EPR rules, whether compliance is managed by state-level PROs, a national system, or eventually a global model.
The rest of this article unpacks how PROs work today, how the "global PRO" concept is emerging from models like the Circular Action Alliance, and the practical steps brands can take now while the rules are still evolving.
Extended producer responsibility started in Europe decades ago, when governments decided that the companies placing packaging on the market, not taxpayers or municipalities, should fund what happens to that packaging after use. EPR policies shift the burden of managing packaging waste to producers, covering everything from collection and sorting to recycling and responsible disposal.
Over the past five years, this concept has spread rapidly across North America and parts of Asia. Global brands that once only dealt with European packaging rules now face a growing number of U.S. state laws, Canadian provincial programs, and emerging frameworks in other regions. Naturally, many are asking: could a single, global producer responsibility organization simplify all of this?
Before answering that question, it helps to define two terms you will see throughout this article:
Extended Producer Responsibility refers to laws that make producers fund end-of-life management of their packaging and paper. These laws typically require producers to pay fees, meet recycling or recyclability targets, and report the types and quantities of packaging they put on the market.
AProducer Responsibility Organization (PRO) is a collective, usually nonprofit entity that manages compliance, fee collection, and program plans on behalf of many producers. Think of it as a shared compliance service that handles the paperwork, payments, and coordination so individual brands do not have to do it alone.
Today's landscape is state-by-state and country-by-country, not global. In the U.S., several states have passed EPR laws for paper and packaging in recent years:
|
State |
Law |
Key Milestone |
|
California |
SB 54 (Plastic Pollution Prevention and Packaging Producer Responsibility Act) |
Permanent regulations effective May 1, 2026; 100% recyclable or compostable packaging by 2032 |
|
Colorado |
HB 22-1355 (Producer Responsibility Program for Statewide Recycling) |
PRO appointed May 2023; program plan implementation by June 2026 |
|
Oregon |
Oregon's Recycling Modernization Act |
Program plan approved Feb 2025; first producer-funded program launched July 2025 |
|
Minnesota |
HF 3911 (Packaging Waste and Cost Reduction Act) |
All packaging must be recyclable, reusable, refillable, or compostable by 2032 |
|
Maryland |
SB 901 / SB 222 |
Regulations effective May 25, 2026; producer registration by July 1, 2026 |
|
Washington |
Packaging law passed in 2025; draft program plan due 2028 |
Internationally, the EU has long-standing packaging EPR and is tightening rules under the Packaging and Packaging Waste Regulation (PPWR), which will impose new recyclability, recycled content, and reuse requirements across member states from 2025 through 2030.
This is where the Circular Action Alliance enters the picture. The Circular Action Alliance is a U.S. nonprofit producer-led organization dedicated to implementing effective extended producer responsibility laws for paper and packaging. CAA was founded in 2022 by 20 producers from various industries spanning food, beverage, consumer goods, and retail industries. Founding members include companies such as Amazon, Procter & Gamble, Coca-Cola, Unilever, Walmart, and Nestlé USA.
CAA is the only approved PRO for U.S. EPR laws and is the organization approved or selected in California, Colorado, Maryland, Minnesota, Oregon, and Washington. In Oregon, the DEQ approved CAA's program plan on February 21, 2025, making it possible for Oregon's first producer-funded recycling program for paper and packaging to begin in July 2025. For Washington, a draft program plan is due in 2028 for implementation in 2030, and producers must register with CAA by July 1, 2026.
While CAA is not a global PRO, its multi-state model-shared producer portal, harmonized fee-setting guidance, and coordinated program plans are shaping expectations for how cross-border EPR services might work. CAA's Oregon program plan and its upcoming Washington draft are examples of how one action alliance structure can manage many jurisdictions.
As more countries and U.S. states adopt producer responsibility EPR laws for packaging, pressure is growing for some form of "global PRO." But legal frameworks remain national, not international, and that gap is exactly what makes brands cautious.
Understanding how CAA operates in the U.S. is key to imagining what a future global PRO might do-and why brands are already raising concerns. CAA provides streamlined compliance services across multiple states and operates compliance programs in multiple U.S. states, making it the most useful real-world reference point for the global PRO conversation.
The core functions of a modern producer-led organization, CAA, include:
Producer registration. CAA registers obligated producers under state-specific EPR laws for paper and packaging in California, Colorado, Oregon, Minnesota, Maryland, and Washington. In Colorado, for example, producers had to sign a Participant Producer Agreement and submit supply reports byJuly 31, 2025, to the Colorado Department of Public Health & Environment.
Data collection and reporting. CAA manages producer data collection via a shared producer portal and reporting system. CAA tracks packaging data and verifies responsible end markets for recycled content across all states where it operates.
Program plan development. CAA prepares and submits program plans to regulators, such as the Recycling Modernization Act program plan in Oregon and California's SB 54 initial program plan.
Under Oregon's Recycling Modernization Act, producers of packaging, paper, and food serviceware must join a PRO. CAA Oregon is the only organization with an approved program plan.Oregon DEQ's February 21, 2025, approval allowed the state's first producer-funded recycling program to begin in July 2025. EPR aims to expand curbside recycling for hundreds of thousands of Oregon residents. The program has expanded curbside recycling, added RecycleOn Centers in communities like Hood River and The Dalles, and is supported through producer fees collected by CAA.
CAA Oregon uses a Primary Funding Agreement (PFA) for communities, local governments, and service providers, not for producers themselves. Individual addenda cover specific funding streams such as glass incentives, transportation support, and collection system expansion.
The digital workflow is straightforward: a fillable PFA is emailed to CAA, reviewed and edited as needed, signed via Ironclad, and then portal access is granted. From there, consultation on addenda happens through CAA specialists. This structure could be mirrored in other states and, hypothetically, in other countries, creating a semi-standard global template.
EPR fees collected fund improvements to local recycling infrastructure, including sorting technology, end-market development, and public education campaigns.
CAA runs weekly producer onboarding and consultation webinars that explain registration, Participant Producer Agreements, and state addenda. Producers receive detailed guidance on fee methodologies, including:
Base fees by packaging type
Eco-modulation fees adjusted to reward easier-to-recycle packaging formats
State-specific surcharges, such as California's Plastic Pollution Mitigation Fund
Ongoing outreach includes monthly emails with milestones, reporting tips, and updated producer registration lists provided to agencies like Oregon DEQ and the Department of Public Health in Colorado. Led by CEO Jeff Fielkow, the organization CAA is committed to delivering harmonized best-in-class compliance services across every state where it operates. CAA aims to harmonize compliance standards across states so that producers do not face wildly different processes in each jurisdiction.
At its core, CAA's mission is to support an effective circular economy for paper and packaging by funding modern sorting infrastructure, responsible end markets, and public education. CAA aims to promote a circular economy through improved recycling practices. Its multi-state governance structure and founding members from the food, beverage, consumer goods, and retail industries look similar to what a cross-regional or global producer responsibility organization might require.
CAA also works closely with a state producer responsibility advisory council in Oregon and engages other interested parties-recyclers, municipalities, and environmental groups-in its program plan development. These advisory processes help advance transparency and accountability.
Despite these strengths, brands are increasingly cautious about any move toward a single, global PRO model. The next section explains why.
Brands, especially those exporting products in paper and packaging, want less complexity. Nobody enjoys managing registration deadlines, fee calculations, and material reporting across six U.S. states, let alone dozens of countries. But many are wary of concentrating so much power and responsibility in one global PRO or alliance. Their concerns are specific, practical, and worth understanding.
EPR laws and fee schedules are currently tailored to local realities. Oregon's EPR program focuses heavily on expanding access to recycling in rural areas. Colorado's law emphasizes reimbursement targets for municipalities. California's SB 54 includes aggressive plastic reduction and reuse mandates.
EPR fee structures incentivize companies to adopt sustainable packaging design, but those incentives only work when they reflect what local infrastructure can actually handle. A global PRO could be tempted to standardize its fee methodology across markets, leading to misalignment with local recycling capabilities and unfair costs for certain formats or materials.
Brands worry that eco-modulated fees could penalize innovative designs that are recyclable in one country but not yet accepted in another. A paper tube with a particular coating might score well in Oregon's modernized system but face penalties in a jurisdiction with less advanced sorting technology.
Producers already struggle to follow complex program plans like those CAA files in Oregon or under SB 54 in California. These plans include technical modeling, infrastructure investment forecasts, and end-market verification rules.
Scaling this to a global level could make it harder for small and mid-sized brands to track where their money goes or challenge incorrect assumptions about their packaging. Interested parties, including recyclers, municipalities, and environmental advocates, already push for greater transparency at the state level. Some brands fear a global PRO could become an opaque "black box" with limited regulatory oversight in any single country, making it difficult to represent producer interests effectively.
A global PRO would still need to comply with national and state laws, which might require local registration, reporting, and participation in domestic PROs. Without tightly harmonized rules, brands could end up funding both a global organization and multiple local PROs, especially where regulators insist on domestic oversight.
Consider a concrete scenario: a brand selling in the U.S., EU, and Canada might still have to deal with CAA in several U.S. states, national PROs in EU member states, and a separate Canadian system-even if a global PRO promised end-to-end coverage. The single PRO concept only works if every jurisdiction recognizes it, and that legal alignment does not exist today.
Many current PROs, including the Circular Action Alliance, are producer-led but heavily guided by state agencies such as CalRecycle, Oregon DEQ, and the Washington Department of Ecology. This oversight provides checks and balances.
At a global scale, governance could become even more distant from local communities and recyclers, raising questions about whose producer interests are prioritized when program plans are written or amended. Brands also worry about reputational risk if they are tied to a global PRO that underperforms on recycling outcomes or fails to support responsible end markets.
Ambitious targets for recycled content, reuse, and recyclability must be balanced with food safety, product protection, and retail presentation. A global PRO might push aggressive, uniform design-for-recycling rules that do not reflect differences in climate, logistics, or local consumer expectations.
This connects directly to Paper Tube Co.'s experience: premium paper tubes, rigid boxes, and glass options can drastically reduce plastic, but the exact mix of materials, closures, and labels that qualifies as "recyclable" still differs by country and even by U.S. state. A multi-layer laminated material might be compostable under one jurisdiction's definition but rejected by recyclers in another.
Brands are not opposed to coordination. They want any move toward a global PRO or circular action alliance to be transparent, accountable, and flexible enough to reflect real-world packaging and recycling conditions.
Regardless of whether or when a true global PRO appears, the safest strategy for brands is to design packaging that performs well under today's leading EPR laws for paper and packaging. Laws in Oregon, Colorado, California, Washington, Minnesota, Maryland, and the EU share common themes: reward recyclability, penalize complexity, and push toward circular materials. Brands that align with those themes now will be better prepared for whatever compliance structure comes next.
Here are practical steps to implement right away:
Shift to paper-first packaging. Especially FSC-certified papers, for categories where plastic has been the default. Paper and cardboard generally receive more favorable treatment under most EPR fee systems.
Simplify material mixes. Using mono-material paperboard tubes instead of multi-layer plastic laminates, where possible, helps brands score better under eco-modulated fee systems.
Prioritize clear recyclability. Packaging that is curbside-accepted in Oregon's modernized system or compatible with common MRFs (material recovery facilities) will likely be rewarded, whether fees are set by state-level PROs like CAA or a future cross-border alliance.
As a sustainable custom packaging partner, Paper Tube Co. specializes in eco-friendly paper tubes, rigid and folding boxes, pouches, and limited tin and glass options. We regularly track developments in EPR laws for paper and packaging in U.S. states, including CAA program updates, producer resource center guidance, and regulatory calendars, to inform our structural engineering and material choices.
Our design services, which include R&D, prototyping, and brand identity work, can help brands test configurations that reduce plastic, improve recyclability, and prepare for potential fee modulation under future PRO systems.
|
Recommendation |
Why It Matters |
|
FSC-certified, high-recycled-content paper |
Aligns with recycled content mandates inCalifornia andMinnesota |
|
Avoid metalized foils and complex laminates |
Reduces contamination risk and simplifies MRF processing |
|
Vegetable-based inks and water-based adhesives |
Favored in responsible end-market standards; reduces contamination |
|
Reusable or refill-friendly formats |
Addresses reuse quotas in states like Minnesota (all packaging refillable, reusable, recyclable, or compostable by 2032) |
|
Documented packaging composition |
Simplifies registration and reporting to PROs such as the Circular Action Alliance |
Beyond packaging design, brands need to build internal compliance capacity:
Designate an EPR compliance function. Create a cross-functional team combining sustainability, packaging, and finance expertise. This does not need to be a large team-even one dedicated owner who tracks obligations can prevent missed deadlines.
Participate in CAA consultation webinars and producer onboarding sessions. Engage in processes such as Oregon's 2028–2032 program plan consultations and the state producer responsibility advisory council meetings to understand how fee structures and definitions are evolving.
Track key regulatory dates. Producers must register with CAA by July 1, 2026, for Washington and Maryland. Colorado has its own registration and reporting windows. Oregon publishes updated producer status lists. A centralized compliance calendar is essential.
The appeal of a well-run global PRO is real, but for now, brands gain the most by investing in better packaging design, reliable data, and strategic partnerships with suppliers like Paper Tube Co., which are already oriented toward circularity. The organizations and laws shaping EPR today are building the infrastructure that any future global model would need to build on.
These questions address practical concerns that may not have been fully covered above, focusing on how a possible global PRO model might affect packaging decisions and compliance strategies.
As of mid-2026, there is no single, legally recognized global PRO that can replace national or state-level PROs. What exists instead are cross-border networks and multi-state organizations like the Circular Action Alliance that coordinate compliance in several jurisdictions. CAA currently serves as the PRO in six U.S. states, but it does not have legal authority outside the United States. Any future global PRO would need formal recognition from regulators in each country or state where it operates.
It is unlikely in the near term. EPR laws are written and enforced at the state or national level. Even if a global PRO emerged, it would almost certainly need to work through or alongside local organizations such as CAA in U.S. states like Oregon, Colorado, and California. State agencies retain oversight of program plans, fee structures, and performance targets, and they are unlikely to cede that authority to an international body without significant legal reform.
Start by choosing simple, mono-material paper packaging where possible-this simplifies both recycling and reporting. Work with suppliers like Paper Tube Co. that can provide detailed material breakdowns and recyclability guidance. Sign up for PRO producer resource centers and email updates to receive plain-language explanations of new requirements.
Paper and cardboard often receive more favorable fee treatment than plastics in many EPR systems, but fee levels still depend on several factors: recyclability in local programs, contamination risks, the presence of coatings or mixed materials, and whether the material is actually accepted at local MRFs. A paper tube with a heavy plastic liner, for example, might not qualify for the same favorable rates as a mono-material paperboard tube. The key is to evaluate each design against the specific program criteria in your target markets.
Paper Tube Co. monitors developments in EPR laws for paper and packaging, including updates from the Circular Action Alliance, Oregon DEQ, CalRecycle, and other regulators. We incorporate this knowledge into material selection, structural engineering, and client advice so that brands can be confident their packaging is moving in the right direction for future fees and reporting. Our R&D and prototyping capabilities allow us to test new configurations quickly, helping brands stay ahead of regulatory shifts rather than scrambling to catch up.
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