Life Cycle Evaluation

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, when voluntarily undertaken, 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 final list in alphabetical order of top 25 producers required to evaluate and disclose the life cycle impacts of 1% of their products is as follows:

1. Albertsons Companies, Inc.
2. Amazon.com Services, LLC 
3. Conagra Brands, Inc.
4. Conopco Inc.
5. Costco Wholesale Corporation
6. Dole Food Company, Inc.⁺
7. E&J Gallo Winery 
8. General Mills, Inc.
9. Kraft Heinz Foods Company⁺
10. McDonald's USA, LLC
11. NESTLÉ USA, INC.  
12. North Pacific Paper Company LLC
13. Novolex Holdings, LLC⁺
14. PepsiCo, Inc.
15. Staples, Inc. 
16. Swire Pacific Holdings, Inc. ⁺
17. Sylvamo North America, LLC⁺
18. Target Corporation
19. The Campbell's Company
20. The Procter & Gamble Company
21. Trader Joe's Company
22. US Foods, Inc.
23. Walmart Inc.
24. WestRock Company 
25. WinCo Foods, LLC 

The list was compiled by Producer Responsibility Organization Circular Action Alliance and reported to DEQ on Mar. 31, 2026. It represents the top 25 producers with respect to weight of covered product supplied into the state in 2024 by each producer in aggregate across material categories, and replaces the preliminary list that was reported to DEQ by CAA on Aug. 1, 2025.

Producers that appeared on both lists must submit their project reports to DEQ on or before Dec. 31, 2026. Producers who appeared only on the final but not on the preliminary list, denoted above with a “+" symbol at the end of the company name, have an extra six months to fulfill their disclosure obligation (their reports must be submitted to DEQ on or before June 30, 2027.

Templates and Guidance for Large Producer Disclosure

• Life Cycle Evaluations for Top 25 Large Producers: Guidance 
  This guidance outlines how the 25 obligated large producers shall evaluate and disclose Life Cycle Assessments of the top 1% of covered products. 
• Life Cycle Evaluations for Top 25 Large Producers: Project Report Template
  This is the project report template to be used by large producers when fulfilling their reporting obligation for each SKU or SKU batch.
• Life Cycle Evaluations for Top 25 Large Producers: Impact Assessment Template
  This is the impact assessment template to be used for summarizing results of a life cycle evaluation. It should be submitted together with a project report for each SKU or SKU batch.
  
• Life Cycle Evaluations for Top 25 Large Producers: FAQ
  This FAQ will be updated periodically to reflect questions posed to the department by producers seeking technical assistance.
  

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, B, pg 211-227.
• Circular Action Alliance guidance and template materials regarding Bonuses A, B, and C.
• DEQ guidance for CAA member pursuing bonus C for transition from single-use to refill.
  

Bonus A for simple evaluation and disclosure first was rolled out by CAA for the 2026 fee year, with producer evaluations due to CAA on Aug. 15, 2025.

For the 2027 fee year, CAA is continuing to offer Bonus A and additionally offering 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 was posted to CAA's RecycleOn website in fall 2025.