MASON, OH – February 3rd, 2026
As Extended Producer Responsibility (EPR) programs continue to evolve, producers face increasingly complex reporting requirements. Oregon’s EPR program takes a more novel approach to eco-modulation and environmental impact disclosure by incorporating life cycle assessments (LCAs). Whether you’re preparing documentation for Oregon’s eco-modulation bonuses or fulfilling Top 25 Producer LCA disclosure obligations, understanding the framework is essential for compliance and potential cost savings. This comprehensive guide breaks down the six main categories of Oregon’s Life Cycle Evaluation (LCE) requirements—from defining your report boundaries to securing critical third-party review.
LCA Requirements
Report Scope
The report boundaries follow standard LCA practices, including adherence with ISO 14040 and ISO 14044. The Oregon DEQ has specified the following requirements in defining the scope of the report:
Packaging Level – All three levels of packaging (primary, secondary, and tertiary) should be included in the assessment, but not the product itself – unless it is a covered material. It is important to note that components that are not covered materials, such as pallets, must also be included.
Functional Unit – The functional unit for Oregon LCA reports depends on the type of packaging. For packaging that contains a product, the functional unit should be the amount of packaging required to contain 1 m3 of product. For packaging that covers a product, the functional unit should be the amount of packaging required to cover 1 m2 of product. There are, of course, exceptions to this rule, such as in the case of things like printed materials or utensils. In these cases, the functional unit would likely be based on item count, but it’s important to confirm your functional unit with the DEQ and CAA to ensure compliance.
System Boundaries – Oregon LCA reports should be cradle-to-grave, meaning that they include impacts from raw material extraction to disposal at end-of-life, inclusive of manufacturing, transportation, and processing at the different life cycle stages.
Method and Results
Method – Oregon LCE guidelines require the use of the Environmental Footprint method, which is comprised of 16 environmental indicators:
- Climate Change
- Ozone depletion
- Human toxicity, cancer
- Human toxicity, non-cancer
- Particulate matter
- Ionizing radiation, human health
- Photochemical ozone formation, human health
- Acidification
- Eutrophication, terrestrial
- Eutrophication, freshwater
- Eutrophication, marine
- Ecotoxicity, freshwater
- Land use
- Water use
- Resource use, minerals and metals
- Resource use, fossils
Results – The impact assessment results from the above method must be divided into 4 modules based on the structure in ISO 21930. Modules A and C are required for all reports, Module B is required for reusable formats, and Module D is optional for all reports.
Module A – Product and Distribution Stages: This module consists of A1 – A4, which include impacts from material extraction and production, manufacturing, and transportation.
Module B – Use Stage: This module is only required for covered materials that are reusable. It consists of B1 – B3, which include impacts from washing and sterilization, and transportation associated with reuse, such as that for returning for washing and redistribution to the consumer.
Module C – End-of-Life Stage: This module consists of C2 – C4, which include impacts from transportation of waste for processing, waste processing, and disposal or recovery activities.
Module D – Beyond Product Life Cycle: Module D is not a life cycle stage and represents any benefits or loads that occur outside of the system boundary, including but not limited to those from landfilling, incineration, composting, recycling, reuse, energy recovery, or material substitution.
Sensitivities
There are 2 required sensitivity analyses for Oregon LCE reports: Electricity grid mix and Recycling allocation methodology.
Additional sensitivity analyses may be performed, which can be used to identify impact-reduction opportunities that support eligibility for Bonus B (substantial impact reduction).
Inventories
There are 5 required inventory analyses in the Oregon LCE guidelines:
- Biogenic Carbon
- Methane Leakage
- Plastic Leakage
- Hazardous Waste Disposal
- Non-Hazardous Waste Disposal
These inventories must be reported across the same modules as the impact assessment, including the input and output flows across the entire life cycle.
There are 2 inventories that stand out in particular due to their relative novelty in the LCA field: Methane Leakage and Plastic Leakage. Methane Leakage refers to the leakage that occurs primarily at natural gas wellheads, pipelines, transportation, refineries, and production facilities, and it is becoming an increasingly common consideration in life cycle assessment.
Plastic Leakage is inclusive of mismanaged waste, and Oregon’s guidelines require 2 modules from the Plastic Footprint Network: macroplastics from plastic packaging and microplastics from tires. It’s also important to note that Plastic Leakage is required for creating the normalized and weighted single score that determines the impact reduction for Bonuses B and C.
Assessments and Statements
Oregon LCE guidelines require that producers must perform a Hazardous Substance Assessment, which identifies any intentionally-added hazardous substances that are at or above practical quantification limits, as well as any contaminant hazardous substances at concentrations above 100 parts per million, in addition to a description of any known releases of hazardous substances to a consumer or to the environment.
Producer reports must also include a Human Health Impact Statement, which discloses any non-compliance of the covered product with customer health and safety regulations or voluntary codes in any jurisdiction in the past five years. Additionally, if the producer judges any health impacts associated with the covered product to be non-material, then they must provide a written justification.
Critical Review
The Oregon DEQ requires that producer LCA reports undergo critical review and verification by an independent third party. The reviewer should be proficient in LCA methodology, practice, and standards, and must not be an employee of the commissioner or practitioner of the LCA. The review should be conducted in accordance with ISO 14071.
Conclusion
Navigating Oregon’s LCA requirements may seem daunting at first, but breaking them into the six core categories and ensuring all reporting elements are addressed allows producers to not only meet regulatory obligations, but also identify meaningful opportunities for environmental impact reduction. As Oregon continues to lead the way in the incorporation of LCA in EPR programs, understanding and implementing these requirements positions your organization for both regulatory compliance and environmental stewardship.
To learn more about how Trayak can support your EPR reporting, eco-modulation strategy, or Top 25 Producer disclosures, contact us or reach out to your Trayak representative.
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