In December 2025, we hosted a live session where we explored the unique features of Oregon’s Recycling Modernization Act.
This innovative piece of legislation focuses on using Extended Producer Responsibility (EPR) and Life Cycle Assessments (LCAs) to change the way producers in Oregon approach packaging design.
Get up to speed quickly on how this new Act affects different categories of producers, how to apply for ecomodulation benefits, how to use LCAs to your advantage, why a standard LCA will not satisfy requirements, and how to limit your liability.
About Oregon’s Recycling Modernization Act
A growing number of US states are introducing Extended Producer Responsibility (EPR) for packaging programs, with varying levels of responsibility and cost to producers.
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 life cycle assessments (LCA) for some producers and bonuses for the voluntary use of LCAs.
The Act requires the top 25 largest producers in the state to evaluate and disclose the life cycle impacts of the top 1% of their products every 2 years. It also establishes three bonus schemes available to all producers who:
- Submit an LCA voluntarily
- Demonstrate that they have taken action to significantly reduce their impact, or
- Introduce reusable or refillable formats.
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.
Having the correct strategy in place and understanding how you can most cost-efficiently comply will be essential for producers affected by these regulations. As LCAs can take up to 6 months to complete and must be submitted by May 31, 2026 in order to qualify for a bonus scheme, it’s important for producers to engage early and seek support from EPR and LCA experts if they need it.
Brands who take the right steps now can position themselves for significant cost-savings in 2027. We have written a full article explaining the timings and different bonus programs here.
Eunomia is a global leader in EPR and the only consultancy to have worked on all needs assessments for states in the US. We go beyond crunching numbers, bringing deep technical expertise to help guide organizations on strategy, reporting, and cost-efficient compliance.
We have completed or are in the processing of completing needs assessments for the following states in the US:
- Colorado
- Maryland
- Oregon
- Illinois
- Minnesota
- California x 2 Collections Processing and End markets and Source reduction
What you will learn:
- The key concepts behind Oregon’s EPR program
- How the program affects your company and products
- Key deadlines and reporting requirements
- How to conduct your LCA to comply with Oregon’s requirements
- The benefits of voluntary disclosure
- How to qualify for ecomodulation bonus schemes
- The risks of non-compliance
- Future outlook for EPR in Oregon – what comes next?
Who should watch:
- Senior leaders who produce, import, distribute and use packaging, printing and writing paper, or food service ware in Oregon
- Sustainability team members at organizations that produce, import, distribute, and use packaging, printing and writing paper, or food serviceware in Oregon, including:
- Directors/Managers of Sustainability
- Packaging designers
- Packaging Engineers/Packaging Sustainability Managers
- Environmental Compliance Managers/Regulatory Affairs Managers
- Corporate Social Responsibility (CSR) Leads/ESG Managers
- Product Stewardship Managers
- Supply Chain Sustainability Managers
- Anyone interested in policy developments around packaging and sustainability in the US – whether private or public sector or NGO. However, the focus of the event will remain on how the regulations will affect businesses.