What Local Governments Need to Know About Washington’s Recycling Reform Act

The Recycling Reform Act, Chapter 70A.208 RCW, passed in 2025, is the most significant change to Washington’s residential recycling system in decades. It establishes an Extended Producer Responsibility (EPR) program that shifts financial responsibility for the recycling of consumer packaging and paper products (i.e., boxes, bottles, and cans made from cardboard, paper, plastic, metal, and glass) from local governments and state residents to the product producers.

Washington currently has similar programs for electronics (E-Cycle), paints (PaintCare), mercury-containing lights (LightRecycle), and medications (Safe Medication Return).

This blog provides an overview of the state’s new legal requirements, implementation timelines, and how local governments fit into the equation.

Background

As noted at the beginning of the new law, Washington’s statewide waste recovery rate has been generally static since 2011. See RCW 70A.208.010(1)(a).

Washington is also not meeting the statewide recycling goal of 50% established in 1989. See RCW 70A.208.010(1)(a).

Furthermore, the legislature recognizes that many residents, particularly those who live in rural areas and in multifamily residences, do not have access to convenient or affordable curbside recycling.

The Recycling Reform Act seeks to reduce waste, encourage reuse, expand recycling access, and increase the state’s recycling rate.

What Is an Extended Producer Responsibility (EPR) Program?

EPR programs use financial incentives to encourage producers to design environmentally friendly products by holding producers responsible for the costs of managing their products at the end of their lifecycle.

Washington joins six other states with packaging and paper product EPR programs, including California, Colorado, Maine, Maryland, Minnesota, and Oregon. Additionally, several other states are in the process of developing EPR legislation.

How Does Washington’s EPR Program Work?

Product producers join and pay fees to a nonprofit producer responsibility organization based on the volume of packaging or paper products they introduce into Washington. The Circular Action Alliance (CAA) is the producer responsibility organization representing producers in Washington. The CAA will assess producer fees based on the type of materials used by each producer. The rate structure incentivizes the use of recyclable materials.

The CAA will use these fees to fund existing, improved, and expanded residential recycling service, including funding needs assessment studies to help identify system improvements. Most importantly, the CAA will fund and draft the program plan, which will address program implementation and establish recycling performance targets.

Additionally, the CAA will provide grants for reusable packaging and reuse infrastructure, which local governments may be eligible to apply for.

Product producers must report the materials they produce or sell within a specific reporting period, including material types, weights, and recyclability characteristics.

Recyclables are still processed with existing “service providers.” Pursuant to RCW 70A.208.020(43), a “service provider” is a government entity that provides, contracts for, or otherwise arranges for another party to provide recycling services.

In order to qualify for cost reimbursement under the program, service providers must annually report the materials processed, including the quantity, quality, and end markets. These reporting requirements are discussed in more detail later in the blog.

The Washington State Department of Ecology (Ecology) provides oversight and enforcement of the program. Ecology will also establish statewide collection lists to promote standardized recycling collection across the state (RCW 70A.208.090).

An advisory council will provide ongoing feedback about program startup, implementation, and operation to Ecology and the CAA.

For more information, see Ecology’s Recycling Reform Act webpage.

Implementation Timeline

The Recycling Reform Act will be implemented in three phases over the next five years.

Phase 1: Program startup (2025-2027)

Program startup includes development of statewide collection lists, rulemaking, producer and service provider registration and reporting, establishment of the advisory council, and a statewide needs assessment study.

Ecology's Preliminary Needs Assessment is open for public comment through October 30, 2026.

Phase 2: Program development (2028-2029)

Ecology will adopt rules and the CAA will submit a draft program plan with performance targets for review by the advisory council and Ecology.

The CAA will roll out the packaging reuse and infrastructure grant program. After March 2029, producers who are not members of the CAA cannot sell their products in the state.

Phase 3: Program implementation (2030 and beyond)

Residents will receive increased access and reduced costs for recycling services.

The CAA will reimburse service providers, invest in infrastructure improvements, and submit annual program reports.

Pursuant to RCW 70A.208.170, if service providers can demonstrate compliance with the performance targets in the program plan, they are reimbursed by the CAA as follows:

• No less than 50% of net costs by February 15, 2030;
• No less than 75% of net costs by February 15, 2031; and
• No less than 90% of net costs by February 15, 2032.

What Role Do Local Governments Play?

While many of the new requirements target the producers of packaging and paper products, local governments play a critical role as recycling “service providers.” See RCW 70A.208.020(43) and RCW 70A.208.070.

By January 31, 2026, and annually thereafter, each service provider that intends to seek reimbursement for recycling services must register with Ecology (RCW 70A.208.070).

As part of the registration process, service providers report the total costs to provide recycling services, as well as the number of recyclables managed during the preceding calendar year (RCW 70A.208.070). This information is also used by Ecology to inform statewide needs assessment studies.

Finally, please note that the Recycling Reform Act does not impact local government’s existing legal authority to regulate or contract directly with recycling service providers.

For more information about service provider registration, see Ecology’s Registration Users Guide and Registration webpage.

Local Government Next Steps

Local governments should work with their agency attorney to evaluate whether existing recycling contracts need to be amended to comply with the Recycling Reform Act. Agencies should pay specific attention to the service provider responsibilities under RCW 70A.208.080 and the reporting requirements under RCW 70A.208.070.

Looking forward, local governments should also start evaluating:

• How local collection programs compare with the preliminary statewide collection lists;
• How future funding opportunities could be used to support local infrastructure improvement projects, particularly with respect to underserved areas; and
• How it will participate in Ecology’s needs assessment study and upcoming rulemaking to ensure local concerns are adequately addressed.

Conclusion

While it will take several years for this new recycling system to roll out, it brings great promise to local governments, Washington residents, and the environment.

Ecology anticipates the following benefits under the Recycling Reform Act:

• Increased curbside recycling from 83% of Washington residents to more than 95% of residents;
• Reduced household recycling bills by at least 90% after 2032 when the program reimbursement rate reaches the highest level;
• Increased recovery of consumer recyclables from the current 40% to an expected 66%; 
• Standardized recycling collection across the state; and
• Decreased greenhouse gas emissions by about 565,000 metric tons per year due to more recycled materials used in manufacturing.

For more information about the Recycling Reform Act, sign up for Ecology’s newsletter, which includes regular program updates and public participation opportunities.