Our North America Director and Private Sector Lead Sarah Edwards, and Managing Consultant Simon Hann, explore the potential environmental, social, and economic benefits of Oregon’s extended producer responsibility Program Plan and Life Cycle Assessments.
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, more importantly, why they matter.
Since 2019, we have been providing evidence-based research that has informed the developments of EPR in the US, including working with Circular Action Alliance (CAA) – the designated Producer Responsibility Organization (PRO) for paper and packaging in the states that have appointed a PRO. We’ve also worked with the State departments developing the regulations, commissioning the Needs Assessment. Our Life Cycle Assessments (LCA) team has also been inputting into the implementation of the LCA requirement under Oregon’s Plastics Pollution and Recycling Modernization Act.
Oregon is the first state to have introduced its approved EPR Program Plan and launched EPR for paper and packaging. The state program is different to other EPR programs in a number of different ways, one of which is the required use of LCAs. The program plan came into force on July 1st, and what happens next will offer a template for others looking to introduce EPR. So, what will Oregon gain from introducing EPR for packaging and LCAs?
Oregon’s program plan and LCAs
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, LCA’s 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, who 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’s website and repeated every two years1.
Oregon’s DEQ Waste and Recycling Life Cycle Evaluation Rule OAR 340-090-0910(3) also requires its designated PRO, CAA, to grant bonuses to the voluntary disclosure of lifecycle environmental impacts 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 January 2026 program year following an LCA report completed in August 2025. Following 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 impact, 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 be starting May 31st, 2026.
LCA’s as mechanisms for demonstrating environmental performance
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, from Oregon’s PRO bonuses to operational efficiency. So, what does this mean for producers 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 robust data, of which improved operational efficiency is often a byproduct.
Oregon’s LCA requirements under its EPR program 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.
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. Meanwhile, transparency builds trust with communities and consumers, which strengthens commercial resilience and brand reputation.
Why now?
Oregon’s EPR program will put non-compliant companies at risk of civil penalties from the DEQ. However, EPR is not only a regulatory necessity; it is a key to sustainable progress with multiple environmental, economic, and social benefits. It encourages the use of more sustainable materials and practices, lowers contamination rates in recycling facilities, supports the development of infrastructure to meet collection standards, and will lead to an increase of reusable packaging systems, ultimately driving down material use.
The program will soon kick into action, with affected producers required to submit LCA reports in the fall of 2025. On September 1st, the CAA will remit the first set of administrative fees to the Department of Environmental Quality (DEQ). LCAs are a lengthy process, sometimes taking up to 6 months to complete, especially if the data is not coherent or readily available. Companies need to start planning soon to leave enough time to gather the data needed to comply.
Producers who engage early will take the lead in a rapidly changing world. Being prepared will help them to avoid fines associated with non-compliance, unlock economic, operational, environmental, and social benefits, and be a part of Oregon’s leadership towards a sustainable future and circular economy.
Why Eunomia?
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, and waste systems, 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.
