Mandatory Life Cycle Assessments in Oregon’s Packaging EPR Program

In this article, our very own Mitch Webster explains how Oregon’s Extended Producer Responsibility (EPR) for packaging program requires mandatory life cycle assessment (LCA) reports for the top 25 producers in the program.

Over the last two years, The Packaging School team has been closely tracking the development of packaging extended producer responsibility (EPR) programs across the United States and around the world—publishing dozens of articles along the way.

While many industry professionals are familiar with “EPR basics”—PRO (producer responsibility organization) registration, data reporting timelines, and related requirements—confusion remains around ecomodulation programs, particularly the role life cycle assessments (LCA) play in US EPR systems.

If you aren’t familiar with LCAs for packaging, please take a look at this quick guide to ensure the best reading experience.

In this article, we examine the current status of ecomodulation in Oregon, with particular attention to the mandatory LCAs required for the program’s top 25 producers.

Voluntary Ecomodulation in Oregon

Although we previously published a deep dive on Oregon’s three ecomodulation bonuses, this article steps back to provide a broader overview of ecomodulation and the voluntary bonuses within the program.

Ecomodulation Explained

Ecomodulation, often referred to as eco-modulated fees, is a design-based incentive mechanism built into EPR programs that adjusts producer fees to either reward or penalize packaging design changes.

Instead of prioritizing compliance alone or designing strictly for recycling, ecomodulation encourages producers to evaluate their packaging systems more holistically. The goal is to improve environmental performance across the full life cycle—from cradle to grave. While EPR programs traditionally emphasize the “grave,” or end-of-life management, ecomodulation helps shift attention upstream to earlier design and material decisions.

These strategies may include increasing post-consumer recycled (PCR) content, optimizing material selection, or reducing broader environmental impacts demonstrated through an LCA.

While each EPR program structures its bonuses and penalties differently, ecomodulation should be viewed as more than a compliance lever. When implemented effectively, it drives measurable packaging design improvements—pushing EPR beyond a simple compliance checklist.

Oregon Ecomodulation Explained

As outlined in our guide to Oregon’s ecomodulation bonuses, the state’s EPR program currently includes three voluntary ecomodulation bonuses tied to completing and submitting third-party-reviewed LCAs.

Here’s how this works in practice (for Bonus A):

Producers in Oregon can conduct and submit a third-party reviewed LCA of a primary packaging system to receive up to $20,000 USD in ecomodulation bonuses per SKU (stock keeping unit) assessed, credited toward their 2026 EPR fee payments. This credit reduces EPR fees for that SKU in the following year, creating a financial incentive for producers to perform and submit LCAs.

Here’s an overview of the three bonuses available for producers in Oregon:

Bonus A allows Oregon producers to submit up to ten third-party-reviewed LCA reports (covering a single SKU or a batch of SKUs) by May 31, 2026. Each submission can unlock up to $20,000 USD in credits toward 2027 EPR fees, for a maximum total reward of $200,000 USD per producer.

Bonus B allows Oregon producers to submit comparative LCAs and supporting data demonstrating a reduction in the environmental impact of a primary packaging system by May 31, 2026. Producers can receive up to $50,000 USD in bonuses per SKU, with a maximum of 10 submissions per producer, for a potential total of $500,000 USD in credits toward 2027 fees.

Bonus C allows Oregon producers to submit voluntary comparative LCAs demonstrating environmental impact reductions achieved by transitioning from single-use plastic (SUP) packaging to reusable or refillable systems. Report submissions must be submitted to the CAA by May 31, 2026, with approved submissions earning credits toward 2027 EPR fees.

To learn more about the voluntary bonuses available to producers in Oregon’s EPR program, click here.

Now that you have a grasp of ecomodulation and Oregon’s voluntary LCA bonuses, let’s explore how LCAs are used on a mandatory basis for the program’s top 25 producers.

Mandatory LCAs in Oregon

Aside from voluntary, LCA-related ecomodulation bonuses, Oregon’s program also requires mandatory LCAs for select producers—the top 25—based on the total weight of covered products supplied into Oregon. And who are these top producers? Let’s take a look.

The Top 25 Producers in Oregon

According to the Oregon Department of Environmental Quality (DEQ), the preliminary list of 25 producers required to conduct LCAs on 1% of their covered SKUs every two years includes:

Albertsons Companies, Inc.
Amazon.com Services, LLC
Berry Global, Inc.
Conagra Brands, Inc.
Conopco, Inc.
Constellation Brands
Costco Wholesale Corporation
E&J Gallo Winery
General Mills, Inc.
McDonald’s USA, LLC
NESTLÉ USA, INC.
North Pacific Paper Company, LLC
Pactiv Evergreen, Inc.
PepsiCo, Inc.
Staples, Inc.
Sysco Corporation
Target Corporation
The Campbell’s Company
The Coca-Cola Company
The Procter & Gamble Company
Trader Joe’s Company
US Foods, Inc.
Walmart Inc.
WestRock Company
WinCo Foods, LLC

The Oregon DEQ notes that the list will be finalized “on or before” March 31, 2026 and is “subject to change resulting from Circular Action Alliance (CAA) validation of producer reporting and producers submitting corrections to their supply reporting to CAA.”

For up-to-date changes to this list, click here.

What’s Required for the 25 Producers

Citing an FAQ document provided by the Oregon DEQ:

"The Plastic Pollution and Recycling Modernization Act establishes requirements for the top 25 largest producers in the state to fulfill an obligation to evaluate and disclose environmental impacts of 1% of their covered products on a biennial basis."

The first deadline is December 31, 2026. This deadline requires the 25 producers to perform LCAs on 1% of their SKUs based on 2024 supply data submitted initially in 2025.

The select producers must evaluate primary, secondary, and tertiary packaging systems associated with the assessed SKUs. For example, if the SKU is a bottled beverage product, the LCA would need to include:

Primary Packaging: PET bottle purchased by consumer at retail store
Secondary Packaging: 6-pack LDPE shrink wrap for PET bottles
Tertiary Packaging: Wooden pallets used to transport 6-pack LDPE shrink wrap

The FAQ specifies how producers must determine the top 1% of SKUs to be assessed, stating:

"The top 1% of SKUs is the top 1% of unique sellable Stock Keeping Units (SKUs) ranked by number of units sold or distributed in or into the state."

The FAQ provides further clarification, explaining that the top 1% of SKUs are determined by the number of units sold, not by sales revenue, and provides the following formula for producers to solve for x:

1% = (x) / (total number of SKUs sold in Oregon)

In addition, the Oregon DEQ also specifies that, as with voluntary LCAs, these mandatory LCAs must be third-party verified by an independent, qualified party. They also make it clear that LCAs are to be reviewed and scored along the European Union’s Product Environmental Footprint scoring method.

Some highlights of these complex LCA requirements include:

Conforming to the general requirements of ISO 14044: 2006 Sections 5.1 and 5.2 and ISO 14040
Defining the functional unit as the “amount of covered product used to contain one cubic meter of product” or “1 square meter of coverage” (for products that cover or wrap)
Conducting the LCA on a “cradle-to-grave” basis
Including a full Life Cycle Inventory Analysis (LCI), including plastic leakage based on Plastic Footprint Network (PFN) methodology
Disclosing all 16 impact categories defined by EU’s Product Environmental Footprint Method
Providing a summary file in Excel format

You can read more in a guidance document provided by Oregon’s DEQ here.

If you decide to explore the FAQ, note that the Oregon DEQ refers to LCA as "LCE” (Life Cycle Evaluation)—we chose to use LCA as we feel it is a more recognizable term.

Key Considerations

If you or your organization is new to packaging LCAs, the process can feel daunting. You might be wondering: How am I supposed to model my packaging systems—from cradle (raw material extraction) to grave (end of life)—and everything in between using software?

Here are three key considerations:

1. LCAs Take Time—Start Preparing Now

A webinar from Trayak—makers of a leading LCA software—claims that the packaging LCA process for Oregon’s program can take up to 14 weeks.

The breakdown was presented in the following stages:

Pre-Planning
Data Modeling: 2 weeks
Report Writing: 4 weeks
Critical Review (Third Party): 8 weeks
Report Submission to CAA

This means that organizations planning to submit voluntary LCAs for Oregon’s ecomodulation Bonuses A, B, or C should begin the process as soon as possible to meet the May 31, 2026 deadline.

For the top 25 producers, the deadline is later—December 31, 2026—but the scope and number of LCAs required means it is advisable to begin the process as early as possible. LCAs often require coordination and data gathering from suppliers across the value chain, so starting early and ensuring optimized data flows can make the deadline feel more manageable.

2. LCAs Quantify more than Emissions

Before diving into a LCA—whether for an EPR program or an R&D endeavor—it is essential to understand what a packaging LCA can quantify.

The Packaging School team values LCAs for many reasons, but a core benefit is their ability to help avoid “carbon tunnel vision” in sustainable packaging efforts. As the name suggests, “carbon tunnel vision” refers to the myopic focus of packaging and sustainability teams on reducing carbon emissions, often overlooking other important environmental externalities such as water use, eutrophication, ecotoxicity, and biodiversity impacts.

When conducted properly, an LCA can reveal up to 16 different environmental impact categories associated with packaging systems. Before diving into the LCA process, we recommend becoming familiar with the 16 impact categories in the European Union’s Product Environment Footprint method here.

3. Oregon’s LCA Requirements Are Complex

The LCA reports mandated by Oregon’s SB 582 require additional analyses that are not typically quantified in conventional LCAs.

These requirements include the following inventory analyses:

Plastic leakage (macroplastics & microplastics)
Methane leakage
Biogenic carbons
Hazardous waste disposal
Non-hazardous waste disposal

Similar to the main LCA, Trayak emphasizes that inventories must capture all “input and output flows across the entire lifecycle” (cradle to grave).

Aside from these inventories, the Oregon DEQ also requires a Hazardous Substance Statement and a Human Health Impact Statement related to the assessed SKUs.

For more on this, we recommend reaching out to the Trayak team here.

Helpful Resources

Below are some resources for further information on the program and the role of LCA in Oregon’s EPR for packaging program:

Oregon DEQ: LCE Page
Oregon DEQ: Large Producer LCE FAQ PDF
Oregon DEQ: LCE for Top 25 Larger Producers Guidance PDF
Oregon DEQ’s LCA Specialist: Peter Canepa | 503-229-6037
Trayak Webinar Series on LCA and Oregon EPR