A federal court blocked Oregon from enforcing its EPR law against certain producers. Before you exhale, here's what that actually means.

In February 2026, a federal court issued a preliminary injunction blocking Oregon from enforcing its Recycling Modernization Act against members of the National Association of Wholesaler-Distributors. We've gotten a lot of questions about what it means for EPR compliance planning.

Short answer: less than you might hope.

What actually happened

The case (NAW v. Oregon) challenges Oregon's EPR law on due process and interstate commerce grounds. The court agreed there were enough legitimate legal questions to warrant temporarily blocking enforcement against NAW members while the case moves toward a full trial on the merits.

That's meaningful for NAW members specifically. For everyone else, Oregon's program is still operational. And for anyone reading it as a signal that EPR is going away broadly, we firmly believe that's not what this is.

Three things the injunction does not do

It doesn't apply to all producers. The injunction covers NAW members (a specific trade organization) not the entire universe of CPG brands. If you're not a NAW member, the injunction doesn't change your compliance obligations in Oregon.

It doesn't affect any other state programs. Colorado is invoicing. California's January 2027 launch date has not moved. Maryland and Washington have July 2026 registration deadlines. The injunction is Oregon-specific and preliminary.

It doesn't resolve the underlying case. A preliminary injunction means the court found enough merit to pause enforcement while the case is heard, but not that Oregon's program is unlawful. The full trial will determine that.

What this actually tells us

Litigation around a new regulatory framework is normal. The first major program in the country facing a legal challenge from a well-funded trade association was probably inevitable. What's notable is that it's happening in one state, around one specific set of legal arguments, and it hasn't slowed the legislative momentum in California, Colorado, the Northeast, or anywhere else.

Seven states have passed these laws. The Northeast is next. There's federal harmonization legislation under discussion. This is where packaging regulation is going.

What we'd tell any brand right now

If you're using the Oregon injunction as a reason to pause your EPR planning, that's a risk. Your California data collection window is closing. Your Colorado obligations are already live. The eco-modulation design choices that will determine your fee profile for the next several years are the ones you're making right now.

The brands that are going to come out of this period in the best shape are the ones that used 2026 to get their packaging data clean, understand their fee exposure, and make the material decisions that move them out of the Malus zone. The injunction doesn't change that math.