Extended Producer Responsibility
Oregon’s Eco-modulations
What are Oregon’s Eco-modulation bonuses?
Oregon has implemented a graduated fee structure known as eco-modulation as part of its Extended Producer Responsibility (EPR) program. This approach is designed to incentivize producers to reduce the environmental and human health impacts of their packaging by offering potential fee credits.
All eco-modulation bonuses are based on Life Cycle Assessment (LCA) and must follow DEQ’s established LCA standards. Participation in these bonus programs is voluntary.
What are the benefits of applying for the bonuses?
Producers that implement qualifying packaging improvements may be eligible for credits that help offset required EPR fees. The value of these credits depends on the type and scale of improvements demonstrated through an LCA.
Through portfolio-level analysis, Trayak can help identify which bonuses may be most beneficial and evaluate where credits can be maximized.
Eco-modulation Bonuses
Bonus A
Bonus A requires the completion and disclosure of an LCA covering up to 10 SKUs. The LCA must be completed after July 2025 and applies only to non-exempt primary packaging materials. This bonus provides a credit equal to 10% of base fees, with a maximum of $20,000 per qualifying LCA report.
Bonus B
Bonus B requires an LCA demonstrating at least a 10% reduction in environmental impact resulting from a packaging improvement. This improvement may apply to a single SKU or a batch of similar SKUs and must have been implemented after December 31, 2024. The bonus applies only to non-exempt primary packaging materials, with credits of up to $50,000 per LCA depending on the level of impact reduction achieved.
Bonus C
Bonus C requires an Life Cycle Assessment (LCA) demonstrating impact reductions achieved by transitioning from single-use packaging to reusable or refillable packaging. To be eligible, the changes must have been implemented after December 31, 2024.
The level of impact reduction is determined by the breakeven point at which the reusable or refillable packaging performs better than the single-use alternative. As part of the LCA report, a breakeven analysis must be included to qualify for this bonus.
How can I batch my SKUs?
SKUs can be grouped within a single LCA when they use the same material and have a similar packaging format. This approach allows producers to evaluate multiple products efficiently while reducing the time and cost associated with conducting separate assessments.
