Our experts Sarah Edwards and Simon Hann explore the intricacies of Oregon’s Extended Producer Responsibility program, and the benefits life cycle assessments offer producers.
A growing number of US states are introducing Extended Producer Responsibility (EPR) for packaging programs, and as a result businesses need to understand what they entail and how they can cost efficiently comply.
Oregon is the first state to have approved the Producer Responsibility Organization’s (PRO) Program Plan and started to implement the program. The program is different to others in several ways, including the required use of lifecycle assessments (LCA) for some producers and bonuses for the voluntary use of LCAs.
Mandatory and voluntary use of LCAs in Oregon
EPR shifts the responsibility of waste management financing from governments to producers, requiring producers to fund the collection and processing of their products and report on their progress.
Under Oregon’s EPR program, LCAs are one mechanism being used to encourage producers to design and use packaging with lower environmental impacts. LCAs make up one of the five factors for ecomodulation in the graduated producer fee structure and are mandatory for the top 25 largest producers – which Oregon’s Department of Environmental Quality (DEQ)announced at the end of August 2025. These companies must perform an evaluation of at least 1% of the covered products that producers sell or distribute in the state. This evaluation must be available on the PRO website and repeated every two years. The PRO is an entity that producers join to meet their EPR obligations. LCA’s also need to be peer reviewed.
Oregon’s DEQ Waste and Recycling Life Cycle Evaluation Rule OAR 340-090-0910(3) also requires its designated PRO, to grant bonuses to producers that voluntarily complete LCAs, of one or more covered materials. Bonus A covers disclosure on up to 10SKUs and offers a 10% discount on base fees for all materials in the SKU up to $20,000. This will be granted starting in the January 2026 program year following an LCA report completed in August 2025. After this, producers submit reports and bonus applications on May 31st of each year.
Bonus B covers changes to and switching out existing packaging that significantly reduce environmental impacts, starting in the 2027 program year. It is indexed to Bonus A on an SKU or batch of up to 10 SKUs, with three tiers capped at $50,000 per SKU or batch.
Finally, Bonus C will be granted to producers that conduct an LCA that demonstrates substantial impact reductions achieved by switching from single-use packaging to reusable/refillable packaging formats for a product SKU or batch of related SKUs. Submissions for bonuses B and C will start May 31st, 2026.
Oregon’s LCA are unusual and more comprehensive than many typical LCAs. For instance, Oregon explicitly requires tracking plastic leakage and its physical impacts throughout the product life cycle, albeit with a much lower weighting compared with more established impacts such as Climate Change. The state also requires that producers quantify methane leakage, which may occur at various points along the oil and gas supply chain – a specific reference to the emerging understanding around upstream emissions from plastics production
LCA’s as mechanisms for demonstrating environmental performance and wider corporate sustainability reporting
Whilst LCAs require upfront investment and are only voluntary for some, producers should not be discouraged as they offer a host of benefits beyond compliance and possible bonuses in Oregon.
As the requirements of corporate sustainability reporting grow – with both the EU’s Corporate Sustainability Reporting Directive and the US Securities and Exchange Commission Climate Disclosure Rule being introduced in the last year – robust product data will be key for producers who are aiming to stay competitive. LCAs require complete supply chain analysis and rich data, of which improved operational efficiency is often a byproduct.
LCAs highlight hotspots where processes are sub-optimal, resources are wasted, and areas have a high environmental impact. Using this data, producers can improve productivity by streamlining processes, looking to reduce costs and environmental impact at the same time. LCAs can also pay dividends by driving research, innovation, and development in sustainable design.
Transparency builds trust with communities and consumers, which strengthens commercial resilience and brand reputation.
Why now and what next?
EPR is a regulatory lever to support the design of more sustainable products. It also enables more households to have access to recycling services, while providing consistency on what can be collected for recycling. Meanwhile, it covers the cost of education and funds the development of infrastructure to process materials for recycling, replacing virgin material and supporting reusable packaging systems. Ultimately EPR drives down material use.
Oregon’s EPR program puts non-compliant companies at risk of civil penalties, and the program will soon kick into action, with affected producers required to submit LCA reports in the fall of 2025. LCAs are a lengthy process, sometimes taking up to 6 months to complete, especially if the data is not coherent or readily available. It’s important for producers to engage early and seek support from EPR and LCA experts if they need it.
Eunomia has been at the forefront of the development of EPR in the US, supporting analysis that has informed and shaped policy and regulations and provides the necessary data through the needs assessment process to enable the PRO to set fees.
Our LCA team goes beyond just crunching numbers. We bring deep technical knowledge of materials, manufacturing processes, waste systems and importantly material leakage, ensuring that our assessments are grounded in real-world understanding – not just model outputs. Our expertise extends across packaging policy, EPR schemes, and regulatory landscapes, allowing us to embed each assessment within its broader policy and market context.
Life cycle thinking underpins everything we do. We don’t produce LCAs in isolation; we use them as tools to support science-based, pragmatic decision-making. Whether it’s informing product design, guiding sustainable procurement, or shaping policy interventions, our work is focused on delivering insight, not just data. That’s why clients trust us to help them make sense of complex systems and take meaningful action. Get in touch with one of our experts like Simon to discuss your EPR and LCA requirements.
