What Oregon Cities and Counties Need to Know About Recycling Modernization Act (RMA) EPR Compliance

Oregon’s recycling landscape has fundamentally changed.

Oregon Recycling Modernization Act (RMA) implementation began on July 1 2025, creating new opportunities to make recycling easier and expanding access and upgrade facilities. While the law brings new funding, from producers and manufacturers of packaged items, for cities and counties across the state through Producer Responsibility Organizations (PROs), it also introduces strict contamination reduction mandates that require systematic monitoring and documentation.

For Oregon jurisdictions, the challenge is clear: how do you effectively track contamination, implement targeted interventions, and prove program effectiveness to access PRO funding—all while managing the day-to-day demands of waste operations? The Oregon Department of Environmental Quality (DEQ) has now provided the framework, establishing both ambitious targets and practical pathways for local governments to meet their obligations.

Two Distinct Contamination Goals

DEQ’s approach recognizes that not all contamination is made equal. Some contaminants pose greater risks than others, leading to two distinct statewide goals that local governments must adopt.

Goal #1: Zero High-Risk Contaminants

High-risk materials, such as syringes, non-empty pressurized gas cylinders, batteries, explosives and medical waste, pose significant threats to staff, equipment and facilities. The goal for these materials is zero. These items create immediate dangers at processing facilities and can cause fires, equipment damage, and serious worker injuries.

Goal #2: 10% Overall Contamination

As of August 2025, Oregon’s contamination rate sits at 15.5%. DEQ has established a goal of 10% overall contamination, with incremental milestones of 12.5% by 2030 and 10% by 2033. These are aspirational goals without regulatory penalties, but demonstrating progress will be essential for accessing PRO funding and proving program effectiveness.

The Three-Category Framework for Compliance

Oregon law requires local governments subject to Opportunity to Recycle requirements to establish contamination reduction programs that include elements from three distinct categories. This framework ensures a balanced approach combining education, feedback and accountability.

Category A: Customer-Facing Materials and Methods

Jurisdictions must implement at least one customer-facing approach that is “responsive to the needs of diverse populations.” This means that materials must be accessible regardless of background, ability, language preference or access to technology.

Approved methods vary by sector and include:

  • Container labels and standardized colors for bins
  • Cart inspections with customer feedback (2-4 rounds per year)
  • Cart and “Oops!” tags with contamination messaging
  • Multilingual signage in commercial and multifamily enclosures
  • Technical assistance including site visits
  • Apartment champions serving as on-site resources
  • On-board truck cameras or on-site camera systems
  • Educational mailers and broad-based media campaigns

Communities can focus on single-family residential, commercial, multifamily, depot collection or implement broad campaigns reaching all customer types.

Category B: Standards for Providing Feedback

Once contamination is identified, jurisdictions must provide timely, documented feedback using DEQ-approved standards. All three approved standards require:

  • Documentation of identified contamination and feedback provided
  • Multiple feedback methods (cart tags, doorstep information, email, text, phone calls, mail or in-person conversation)
  • Rapid response timelines (same day to five business days depending on method)
  • Accessibility for diverse populations

Feedback must be prompt, clear and accessible. At multifamily properties, feedback goes to property managers and identified generators, or to managers alone when the contamination source is unknown.

Category C: Service or Financial Consequences

For generators who are significant and repeated sources of contamination despite receiving targeted feedback, jurisdictions must have standards for applying consequences.

DEQ defines “significant contamination” as high-risk contaminants, tanglers (hoses, cords, wires), bagged materials or egregious misuse. “Repeated contamination” occurs at least three times within six months.

Approved consequence standards include:

  • Documented contamination with responsive feedback
  • Multiple outreach attempts using different methods
  • Remedy options (educational videos, recycling pledges, tenant lease agreements)
  • Warning letters with verified receipt
  • Contamination fees and/or temporary container removal

Consequences must not disproportionately impact people based on background, ability, or location, and must be set at the lowest possible corrective level.

Funding and Implementation

PROs can provide up to $3 per capita to fund local contamination reduction efforts. Eligible costs include planning, staffing and contractor engagement, though only staff time devoted to contamination reduction programming qualifies. Program evaluation costs are capped at 10% of eligible expenses.

Jurisdictions can focus on a single sector given funding limitations, though multiple sectors can be addressed if desired. DEQ encourages strategies that eventually reach all customers within chosen sectors—for example, inspecting one quarter of residential carts each year to reach everyone over four years.

What This Means for Your Jurisdiction

If your jurisdiction has yet to develop a contamination reduction program, now is the time. Successful compliance requires:

  • Establishing Baseline Data: Know your current contamination rates, types of contaminants and problem areas before you can demonstrate improvement.
  • Systematic Monitoring: Ongoing tracking to identify patterns, measure intervention effectiveness and adjust strategies.
  • Documentation Systems: Every inspection, feedback instance, and consequence must be documented to access PRO funding.
  • Culturally Responsive Outreach: Materials must use clear language, include translations for commonly spoken languages and represent Oregon’s diverse communities.

The jurisdictions that will succeed are those investing in systems that capture granular data during regular operations, identify contamination patterns in real time and generate documentation supporting PRO funding applications.

Moving Forward with RMA

Oregon’s contamination reduction requirements represent both a challenge and an opportunity. With clear statewide goals, an approved framework of program elements and PRO funding, jurisdictions have the resources and structure they need to build effective programs.

Zabble’s technology is proven in California and we’re ready to help Oregon jurisdictions meet their contamination reduction requirements. Schedule a demo to see how Zabble can help your city monitor contamination, document compliance and access PRO funding.

Our Latest Blog Posts

What Oregon Cities and Counties Need to Know About Recycling Modernization Act (RMA) EPR Compliance

For Oregon jurisdictions, the challenge is clear: how do you effectively track contamination, implement targeted interventions, and prove program effectiveness to access PRO funding—all while managing the day-to-day demands of waste operations?

Monday, December 1, 2025

Zero Waste

Zabble Wants to Play with Your Garbage

This blog post discusses Zabble's team visits to key partners, PSSI, Stanford and UCSF, to observe a day in their lives and how they use Zabble's products for zero waste initiatives. At PSSI, Zabble's team rode along with garbage and recycling truck drivers, observing challenges like route changes and contamination. They learned about the importance of real-time communication and notifications for addressing these issues. At UCSF, the team witnessed manual waste sorting and the need for technology that works offline. They also saw how Zabble's "Alerts" feature helps communicate contamination and hazardous items. The blog concludes with the value of these visits and the vision for Zabble 3.0, which aims to provide more granular insights and proactive engagement for achieving zero waste.

Wednesday, April 23, 2025

Artificial Intelligence

How Zabble's Object Detection Model Stacks Up Against Industry Benchmarks

A summary of Zabble's AI object detection models development process and how we use industry metrics and benchmarks to develop, test and evaluate our AI systems.

Wednesday, April 2, 2025