The Plastic Pollution and Recycling Modernization Act requires the Oregon Environmental Quality Commission to establish by rule the methodology, procedures, and requirements to be used by producers of covered products when conducting evaluations of life cycle environmental impacts. These rules are located at
OAR 340-090-0900-0940.
Pursuant to ORS 459A.944(2), life cycle evaluations conducted by producers of packaging, printing and writing paper, and food serviceware in accordance with the rules will be used by the top 25 largest producers in the state to fulfill an obligation to evaluate and disclose impacts of 1% of their products on a biennial basis. Pursuant to OAR 340-090-0910(3), the evaluations can also be used by all producers in requesting ecomodulated fee discounts – a smaller bonus for simple evaluation and disclosure, and larger bonuses for a more complex evaluation that proves that substantial impact reduction has been achieved through a producer action like a design change or switch from single-use to reusable packaging.
Large producer disclosure obligation
The preliminary list in alphabetical order of top 25 producers required to evaluate and disclose the life cycle impacts of 1% of their products biennially, with a first disclosure deadline of Dec. 31, 2026, is as follows:
- 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 list was compiled by Producer Responsibility Organization, Circular Action Alliance and reported to DEQ on Aug. 1, 2025. It represents the top 25 producers with respect to the weight of covered product supplied into the state in 2024 by each producer in aggregate across material categories.
The list will be finalized on or before March 31, 2026, and is subject to change resulting from CAA validation of producer reporting and producers submitting corrections to their supply reporting to CAA.
Ecomodulation fee discounts for evaluation and disclosure
Producers interested in pursuit of ecomodulation fee discounts from the PRO for evaluation and disclosure of the life cycle impacts of their products should consult approved PRO Circular Action Alliance and review:
- Circular Action Alliance's approved program plan section regarding ecomodulation of fees through Bonuses A and B, pg 210-221.
- Circular Action Alliance's
plan amendment regarding the addition of Bonus C to the program, pg 216-222.
- Circular Action Alliance
guidance and template materials regarding Bonuses A, B, and C (guidance for Bonus A has posted, guidance for the other bonuses is forthcoming).
Bonus A for simple evaluation and disclosure will first roll out for the 2026 fee year, with producer evaluations due to CAA on Aug. 15, 2025.
For the 2027 fee year, CAA intends to both continue offering Bonus A and additionally offer Bonuses B and C for substantial impact reduction, with producer evaluations due to CAA on May 31, 2026.
Posting of disclosures
Pursuant to ORS 459A.944(2)(c) and OAR 340-090-0910(3)(a)(A) and (b)(B), public report submissions from large producers fulfilling their disclosure mandate and from producers seeking LCE ecomodulation bonuses must be posted to the PRO's website.
The first batch of ecomodulation LCE submissions for Bonus A is expected to post to Circular Action Alliance's website in December 2025.