Oregon is the first state to require a Life Cycle Assessment (LCA) as part of its Extended Producer Responsibility (EPR) regulation, formally known as The Plastic Pollution and Recycling Modernization Act. While several other states have enacted EPR laws, Oregon stands apart by requiring detailed, product-level environmental impact assessments rather than only general reporting and registration.
This regulation positions Oregon as a national leader in EPR policy. As of now, the Top 25 producers in the state must complete LCAs for 1% of their products. Over time, this level of detail is expected to expand to smaller producers and additional states, making early preparation a strategic advantage.
What is EPR
Extended Producer Responsibility (EPR) is a policy framework that requires or incentivizes producers to take responsibility for the environmental impacts of their products across the entire lifecycle. The goal is to encourage product designs that reduce waste, improve recyclability, and minimize overall environmental footprint.
EPR regulations exist globally and vary by jurisdiction, with compliance requirements spanning product design, packaging, recycling, reporting, and environmental disclosure.
Who does Oregon’s EPR impact?
Oregon’s Plastic Pollution and Recycling Modernization Act requires the Top 25 largest producers in the state to disclose the environmental impacts of 1% of their product portfolio on a biennial basis. The first disclosure deadline is December 31, 2026. The final list of affected companies will be published by March 31, 2026, but currently 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
How do I prepare for EPR?
Companies affected by Oregon EPR include manufacturers, importers, and distributors (producers) and will need to pay fees based on the environmental impact of the products’ packaging. An LCA can help producers identify opportunities to reduce the environmental impact of their packaging (and reduced associated fees).
Companies that fall under Oregon EPR and need to conduct LCAs must begin preparing now. Identifying applicable products and collecting accurate supply chain data are critical first steps. Data collection is often the largest obstacle, particularly for organizations with complex, multi-tiered supply chains. Early supplier engagement is essential to ensure data availability, accuracy, and verification.
- Identify required products
- Establish an internal team
- Map supply chains and data sources
- Engage suppliers early
- Choose LCA tools and partners
Companies outside of the Top 25 listed above are still subjected to Oregon EPR. Products covered under Oregon's Recycling Modernization Act (packaging, paper, and food serviceware) must:
- Register with an approved Producer Responsibility Organization
- Report data to the PRO on their supply of covered products in or into the state
- Pay membership fees to the PRO
Reports must be submitted to CAA (Circular Action Alliance) for 2025 data by May 31, 2026.
What is a Life Cycle Assessment?
A Life Cycle Assessment (LCA) evaluates a product or service’s environmental impact across its entire lifecycle, commonly referred to as “cradle to grave.” This includes five key stages:
- Raw Material Acquisition: Extraction of resources
- Manufacturing/Processing: Production of the product
- Transportation: Moving materials and products
- Use Phase: Energy/water consumption during operation
- End-of-Life: Disposal, recycling, or incineration
LCAs provide detailed, product-level environmental insights using measurable impact indicators, which may include:
- Climate Change
- Human Toxicity
- Ozone Depletion
- Acidification
- Eutrophication
- Water Use
- Lands Use
By evaluating multiple impact factors, LCAs offer a holistic view of environmental performance, extending beyond carbon emissions to capture broader ecological and human health considerations.
How do I perform an LCA?
Traditionally, LCAs have been time-intensive, costly, and resource-heavy, making them difficult to scale across large product portfolios. However, advances in AI-driven LCA platforms now enable organizations to conduct LCAs faster, at lower cost, and at scale. Modern platforms address the most common challenges:
- Data Collection: AI tools automate data gathering, fill data gaps, and match emission factors—dramatically reducing manual effort.
- Cost: Traditional LCAs often require extensive consulting services. AI-driven platforms significantly reduce costs while delivering reliable, high-quality results.
- Time: Manual LCAs can take weeks or months. AI-powered analysis enables rapid assessments, allowing companies to respond quickly as supply chains evolve.
- Expertise: Many organizations lack in-house sustainability teams. AI platforms reduce technical barriers, enabling teams to focus on decision-making rather than data processing.
Benefits Beyond Compliance
Performing LCAs for products opens up insights for companies that have benefits beyond regulatory compliance:
- Identify Hotspots: Pinpoint the most impactful lifecycle stages to guide targeted improvements.
- Optimize Transportation: Streamline logistics to reduce emissions and costs.
- Reduce Costs: Improve efficiency in materials, manufacturing, and distribution.
- Build Customer Trust: Transparent, data-backed reporting strengthens credibility and reduces greenwashing risks.
- Increase Supply Chain Resilience: Sustainable sourcing and energy strategies reduce risk from resource scarcity and market volatility.
- Strengthen ESG Reporting: LCAs provide measurable, defensible data for regulatory disclosures and investor reporting.
When leveraged strategically, LCAs can become a competitive advantage, positioning organizations as sustainability leaders.
Moving Forward
Oregon’s EPR program represents a significant shift toward product-level environmental accountability in the United States. While the requirements may appear complex, companies that act early, engage suppliers, and establish robust data processes will be best positioned for long-term success. Preparing now not only reduces compliance risk but also enables smarter product design and more sustainable business practices.
How CarbonBright Can Streamline EPR
CarbonBright is an AI-driven LCA platform designed to simplify and scale product life cycle assessments. The platform generates reports aligned with regulatory and certification requirements, enabling organizations to assess environmental impacts from cradle to grave—an undertaking that is often time- and cost-prohibitive.
CarbonBright supports organizations without dedicated sustainability teams, as well as experienced teams looking to move faster and operate at scale. By automating complex calculations and data management, the platform delivers actionable, data-backed insights so organizations can focus on reducing impact rather than chasing data—an essential advantage in today’s dynamic and interconnected supply chains.
Ready to get started? Contact CarbonBright today.
Frequently Asked Questions (FAQ)
What is Oregon’s Extended Producer Responsibility (EPR) program?
Oregon’s EPR program, formally known as the Plastic Pollution and Recycling Modernization Act, requires producers to report product-level environmental impacts using Life Cycle Assessments (LCAs). It is the first U.S. state to mandate detailed LCA reporting for certain producers.
Who is affected by Oregon’s EPR requirements?
The Top 25 largest producers in Oregon must disclose the environmental impacts of 1% of their product portfolio. The list includes companies like Walmart, Amazon, PepsiCo, and McDonald’s. The first disclosure deadline is December 31, 2026.
What is a Life Cycle Assessment (LCA)?
An LCA evaluates a product’s environmental impact across its entire lifecycle—from raw material extraction to disposal. It measures impacts like climate change, human toxicity, water use, and land use to provide a holistic view of environmental performance.
How do I prepare my company for Oregon’s EPR requirements?
Preparation involves:
- Identifying products subject to LCA
- Establishing an internal sustainability or compliance team
- Mapping supply chains and data sources
- Engaging suppliers early to gather accurate data
- Choosing LCA tools or partners to perform assessments
How can my company perform an LCA efficiently?
AI-driven LCA platforms, like CarbonBright, streamline data collection, automate calculations, reduce costs, and accelerate reporting. These tools make it feasible to scale LCAs across large product portfolios without extensive in-house expertise.
What are the benefits of conducting LCAs beyond compliance?
LCAs provide actionable insights to:
- Identify high-impact stages in the product lifecycle
- Optimize transportation and logistics
- Reduce costs in materials and manufacturing
- Strengthen ESG reporting and investor credibility
- Build customer trust through transparent environmental reporting
- Increase supply chain resilience
