2025 marks a major year for the packaging industry in the United States, as the state of Oregon became the first US state to launch an Extended Producer Responsibility (EPR) for packaging program on July 1st—the Plastic Pollution and Recycling Modernization Act (SB 582).
With six other states implementing laws—California, Colorado, Minnesota, Maine, Maryland, and Washington—all eyes will be on Oregon to see how the program functions and how producers are impacted. EPR for packaging programs have been active around the world for decades, spanning continents like Europe, Africa, South America, Asia, and more.
Aside from typical EPR requirements like extensive reporting, fees for different packaging materials, and an emphasis on consumer education, Oregon’s Department of Environmental Quality (DEQ) and the Circular Action Alliance (CAA) have also baked ecomodulation bonuses into the program plans to incentivize producers to take packaging sustainability a step further.
Oregon’s DEQ and the CAA, the Producer Responsibility Organization (PRO) selected to manage Oregon’s program, laid out these ecomodulation bonuses in three formats—Bonus A, Bonus B, and Bonus C. In the rest of this piece, we will explore these bonuses, the timelines, and what you need to know to unlock them. But to start, let's briefly explore the concept and philosophy around ecomodulation in EPR for packaging.
What is Ecomodulation?
Ecomodulation (also known as eco-modulated fees) is a mechanism within EPR laws that rewards producers for going beyond basic compliance (reporting, fee payments, etc.) in regard to their packaging.
Through bonuses—in the form of reduced EPR fees—producers are incentivized to make packaging improvements such as increasing post-consumer recycled (PCR) content, enhancing recyclability, and exploring and reducing the overall environmental impacts of their covered packaging systems (through life cycle assessments).
For example, if you’re a producer in Oregon, you can conduct and submit a third-party reviewed life cycle assessment (LCA) of a primary packaging solution to unlock up to $20,000 USD in ecomodulation bonuses per SKU assessed, which is credited toward your 2026 EPR fee payments.
To qualify, you must meet the basic requirements of Oregon’s EPR program (reporting, fee payments, etc.), but can voluntarily work to unlock fee reductions through LCA and other ecomodulation levers. Ultimately, ecomodulation encourages producers to not view EPR as a burdensome compliance checklist, but as a catalyst to upgrade packaging systems to reduce environmental impacts and win rewards in the process.
The bonus we explored in the example is Oregon’s Ecomodulation Bonus A, which has a submission deadline of August 15th, 2025. Let’s explore this bonus opportunity and the two others in more detail.
Ecomodulation Bonus A
With Oregon being the first EPR for packaging program to kick off in the United States, producers and compliance teams dealing with EPR for the first time are facing uncertainty and growing pains—leading to many organizations focusing on meeting basic compliance requirements instead of diving into ecomodulation opportunities.
However, Oregon’s Bonus A is a lucrative opportunity to reduce EPR fees for 2026 and help teams navigate the trade-offs of sustainable packaging decisions through the submission of voluntary LCA reports.
The Basics
Bonus A allows producers in Oregon to submit up to ten third-party reviewed LCA reports (1 SKU or a batch of SKUs) by August 15th, 2025 to unlock up to $20,000 USD in credit on 2026 fees, with a total of $200,000 in rewards possible.
Producers who plan to submit a batch of SKUs (multiple LCAs) must ensure the analyzed packages are primary packaging, in the same product or product category, have the same material composition, and more.
Additionally, LCAs submitted for Bonus A must analyze 16 different environmental impact categories and additional plastic-related impacts, span cradle-to-grave impacts, and be third-party reviewed.
It is also important to note that each SKU or batch of SKUs can only be used for one bonus (A, B, or C) in a given year and have a 3-year period until you can analyze them again for bonuses. For more information on the requirements for Bonus A (which will be available for 2026 as well), we recommend emailing Producer.Support@circularaction.org or exploring the CAA’s Producer Resource Center.
The Timeline
Submissions for Bonus A for 2025 (fee reductions for 2026 fees) are due to the CAA by August 15th, 2025.
If you haven’t conducted the LCAs yet and finished the third-party review process, it might be too late to submit by the deadline, as the third-party review process can take months. If you are interested in planning ahead and exploring Bonus A in 2026 (for 2027 fee reductions), we recommend reaching out to the CAA for more information on how Bonus A will work in 2026.
The Reward
As we highlighted above, for each compliant LCA (by SKU) submitted, producers can receive up to $20,000 USD in EPR fee reductions for the following year—with the ability to submit 10 LCAs (batch of SKUs), the total potential bonus is $200,000 USD.
Producers can unlock bonuses equal to 10% of the base EPR fees for materials associated with a specific SKU, with a cap of $20,000 USD per SKU regardless of the 10% of base fees.
Example: If a producer submitted an LCA of a packaging system (SKU) with $50,000 USD in base EPR fees related to its materials, they could unlock a $5,000 USD bonus (10% of base fees). With the $20,000 USD cap per SKU, even if the base fees were $500,000 USD, the max a producer could receive is $20,000 USD, even though 10% of base fees would be $50,000 USD.
For more information on the bonus and calculations, we recommend reaching out to the CAA.
Reach the end of this article to learn more about our packaging LCA software training module that can help your team unlock Bonus A and other LCA-related bonuses in Oregon and beyond.
Need a refresher on LCA or new to the space entirely? Check out our intro to LCA guide here.
Ecomodulation Bonus B
Similar to Bonus A, Oregon’s Bonus B allows producers to submit voluntary LCAs to the CAA by May 2026, but Bonus B must show impact reductions related to a packaging improvement or update.
The Basics
Bonus B enables producers in Oregon to submit comparative LCAs and data that demonstrate a reduction in environmental impact of a primary packaging system by May 2026 to unlock up to $50,000 USD in bonuses per SKU, with up to 10 submissions per producer—making the maximum total bonus $500,000 USD (credit towards 2027 fees).
Unlike Bonus A, which requires a cradle-to-grave LCA but not a comparison, Bonus B requires a comparative LCA that shows the before and after of your packaging system, highlighting the quantified improvements made from redesigns and optimization efforts.
Luckily, many LCA softwares, including EcoImpact COMPASS by Trayak, allow you to run comparative LCAs and generate ISO 14040/44 reports with ease.
The Timeline
The deadline for the Bonus B LCA submissions is May 2026; we expect more information from the CAA on Bonus B in the coming months. We recommend reaching out to Producer.Support@circularaction.org if you have Bonus B-related questions.
The Reward
Like Bonus A, Bonus B is awarded on a per SKU basis but with a higher bonus ceiling. As outlined above, for each compliant comparative LCA submitted by May 2026, producers can earn up to $50,000 USD in bonuses (credited toward 2027 EPR fees)—with the option to submit 10 LCAs (SKU batch) for a total of $500,000 USD in bonuses.
While Bonus A is calculated as 10% of the base EPR fees for materials in a given SKU (capped at $20,000 USD), Bonus B will use a three-tiered structure based on the level of demonstrated impact reduction.
As of now, the details on the “Impact Reduction Tiers” are being finalized, and we expect additional guidance from the CAA later this year alongside a submission date for Bonus B.
While it is hard to get started on Bonus B due to uncertainty around requirements, having an understanding of tools, software solutions, and partnerships with third-party reviewers beforehand will have you prepared to take action and submit reports by May 2026 for larger bonuses.
As with Bonus A and other EPR questions, we recommend reaching out to Producer.Support@circularaction.org if you have additional questions.
Ecomodulation Bonus C
Like Bonus B, Oregon’s ecomodulation Bonus C is still in development—but here is what we know as of July 2025.
The Basics
Bonus C will enable producers to submit voluntary comparative LCAs that demonstrate impact reductions related to switching from single-use plastic (SUP) packaging solutions to reusable or refillable packaging systems, with report submissions due to the CAA by May 2026 (with bonuses credit towards 2027 EPR fees).
Similar to Bonus B, Bonus C will require comparative LCAs to demonstrate impact reductions achieved by transitioning from single-use plastic (SUP) packaging to reusable, refillable, or other circular packaging formats. Like all bonuses, these LCA reports must be ISO 14040/44-compliant and third-party reviewed.
The Timeline
As of July 2025, the deadline for report submissions is May 2026. Like Bonus B, we expect additional guidance on requirements and deadlines in the coming months. As always, reach out to Producer.Support@circularaction.org with any questions you might have about Bonus C and how to prepare.
The Reward
As of July 2025, we do not have any clarity on the bonus amount and what will be counted as “reusable” or “refillable” packaging systems. We expect more information to be released on Bonus C in the coming months.
Comprehensive Oregon Ecomodulation Timeline
For your convenience, here is a timeline of all deadlines for Oregon Bonuses A, B, and C:
August 15, 2025:
Submissions for Bonus A due to the Circular Action Alliance (CAA) portal.
May 2026:
Submissions for Bonus B and C due to the Circular Action Alliance (CAA) portal.
Summer 2026:
Producers who submitted reports for Bonus A will receive fee reductions on related SKUs (up to $20,000 USD per SKU) towards 2026 EPR fees.
Summer 2027:
Producers who submitted comparative reports for Bonus B and C will receive fee reductions on related SKUs (more info to come this year) towards 2027 EPR fees.
Due to the complexity around LCA requirements and bonuses, we recommend starting as early as possible if you are planning to unlock Bonus A, B, or C. It is also important to note that these bonus opportunities may become available again—reach out to CAA for more information on this front.
Packaging LCA Training to Unlock Bonuses
As we have discussed, Oregon (and other states likely) is leaning on life cycle assessments as a tool for ecomodulation and to encourage producers to go above and beyond to transform their packaging systems to reduce impacts, improve recyclability, and lessen the burden on Oregon’s waste management infrastructure.
If you are new to the LCA and ecomodulation world and it’s all feeling a bit daunting, you are not alone. EPR compliance is challenging and cumbersome enough as it is, and it will only grow in complexity in the coming years when the six other US states implement their programs.
So, if you are feeling lost and looking for tools to help with overall EPR compliance and ecomodulation . . . look no further.
The Packaging School has a number of online, self-paced training solutions designed to help your team stay ahead of EPR shifts and make the most of ecomodulation bonus opportunities.
In our online Certificate of Sustainable Packaging program, we explore frameworks, strategies, and tools that can help you navigate the trade-offs of packaging decisions, from cradle to grave and everything in between. A key highlight of this program is an LCA training module that explores how to use EcoImpact COMPASS (by Trayak) to run single and comparative LCAs on packaging systems. As an ISO 14040/44-compliant platform with the ability to generate reports with ease, COMPASS has the capacity to assist with Oregon bonuses (aside from third-party review).
If you are interested in learning more about this program, feel free to book a demo call here!
Interested in reading more about EPR for packaging? Check out our extensive content index here.
