The critical role of life cycle assessment in the effectiveness of EPR programs is increasingly prominent

As states across the U.S. advance packaging extended producer responsibility (EPR) programs, how to charge producers has become a key issue. Currently, Oregon is the only state using life cycle assessment (LCA), a common but controversial tool, to set fee standards.

According to a draft implementation plan released by the Oregon Department of Environmental Quality (DEQ), LCA protocols will be used to evaluate the environmental impacts of products from "cradle to grave" and may determine the EPR fees owed by the state's 25 largest producers. At the same time, LCA will also serve as the basis for all brands to apply for fee discounts through "eco-modulation" mechanisms.

Oregon's DEQ believes this approach helps go beyond simply passing recycling costs on to brands and encourages the use of packaging with relatively lower environmental impacts. However, some argue that LCAs are often reports released by companies or industry groups only when results align with their interests. In Oregon, submitting an LCA is sometimes mandatory, and the DEQ has established clear protocols for the companies involved.

Experts point out that the ultimate effectiveness of LCA depends on its influence in decision-making and whether it covers all truly important factors. Shelie Miller, a sustainability scientist at the University of Michigan, said: "I think it's completely reasonable to think deeply about and critique LCA. LCA has flaws, but it's the best tool we have right now."

The Role of LCA in EPR

EPR systems have been applied to various products in the U.S. for decades, but their use in packaging is relatively new. Policy advisors note that governments can shape broader management outcomes, such as reducing total material production, by designing EPR programs. Five states have already passed EPR legislation specifically targeting packaging, requiring producer responsibility organizations (PROs) to charge manufacturers based on material design, type, and disposal method.

Oregon's EPR program aims to incentivize manufacturers to reduce the environmental harm of their packaging, and LCA is a key part of achieving this goal. LCA was first developed for Coca-Cola products in the late 1960s, and its methods and intentions have evolved over the years. LCA studies aim to examine the environmental impacts of a product from raw material extraction to its final destination—landfill, compost pile, or deep ocean—requiring data collection and quantification of water consumption, ozone depletion, pollution, and other harms.

When Oregon's system begins affecting recycling in July 2025, LCA will play a role in multiple ways, encouraging companies to make specific decisions. The EPR fees companies must pay depend on the types of packaging materials they use and the tonnage used in the state. The largest 25 producers must create LCAs for 1% of their products sold or distributed in the state every two years, while smaller companies may voluntarily submit LCAs to seek fee reductions. Both types of companies can receive discounts if they further use LCA to demonstrate that they have reduced their products' environmental impact.

Offering lower fees for more environmentally friendly products is often called "eco-modulation." Oregon's DEQ provided PROs with five factors that must be considered when determining fee adjustments, including LCA considerations. While these tools are intended to be informative, they are not mandated to actually participate in setting final fees. Nicole Portley, program planning lead for Oregon's DEQ, said: "We believe that among the five factors in the regulations, LCA is the most closely related to actual environmental impact adjustments."

These rules were adopted in late November. In early December, Oregon's PRO—the Circular Action Alliance (CAA)—submitted its third proposed implementation plan. Oregon's DEQ has not yet approved the plan, and the public comment period runs through January 17.

Oregon does not require companies to prove they meet specific environmental benchmarks through LCA. But the DEQ believes that completing an LCA and making it public yields environmental benefits, based on findings from a study the agency commissioned about a decade ago. Portley said: "The simple act of producers conducting assessments and disclosing them is associated with actions that reduce impacts."

Other researchers also see value in the assessment process itself. Reid Lifset, a research scholar at the Yale School of the Environment, said: "In my research circles, it's often said that the real value of LCA lies in the process of conducting the LCA."

While exact data on the overall number of LCAs or who funds the research is not available, it is common for industry groups and packaging companies to conduct LCAs. Supporters say that requiring organizations to systematically collect more information about how their products are made can prompt companies to consider the consequences of their sourcing, manufacturing, and waste. If the goal of an EPR program is to reduce the environmental harm caused by packaging, then LCA may better serve that mission than programs that judge choices based on whether they lead to disposal.

Meanwhile, Lifset said he is skeptical about whether LCA results—i.e., numerical scores—should serve as the basis for any EPR program. Requiring every relevant detail to be included in the assessment is too demanding. Lifset said details such as the social consequences of manufacturing certain packaging types might be better suited for a separate assessment. "I'm not sure we want one big tool to solve everything," he said.

The Plastics Factor

In recent years, LCA has also sparked controversy in other areas, especially when analyzing plastics. Anja Brandon, director of plastics policy at the Ocean Conservancy, believes LCA omits key factors about the benefits or consequences of specific packaging types. For plastics, LCA typically does not address health impacts on communities near refineries and production plants, or the broader effects of further rationalizing fossil fuel extraction. Microplastic dispersion, PFAS contamination, "or any other factors we struggle to include because we struggle to measure them in the first place," Brandon said.

Brandon added that LCA results focused on emissions could become a factor in deciding which packaging to promote, especially in the plastics industry. A 2024 analysis of more than 130 LCAs—some commissioned by companies or groups—showed that findings often favored plastic options. The analysis, conducted by Anibal Bell and Rafael Auras of Michigan State University's School of Packaging, found that 92% of LCAs reported emissions for different packaging options, and plastic bottles and cartons had lower greenhouse gas values than glass bottles or cans.

Oregon's protocol for producers to earn fee reductions by demonstrating improved performance stipulates that in LCA scoring, climate impacts carry more weight than mineral and metal use, plastic harm to wildlife, or material contributions to water eutrophication. Brands must also report toxicity scores for human and environmental health, but these results are separate from LCA values.

Oregon's DEQ is aware of other concerning impacts—and the scarcity of data describing their environmental effects. Part of its LCA protocol references modules from organizations that continuously update best assessment methods to respond to evolving science. MariLCA (Marine Impacts LCA) is one of these modules. Founded by academic, nonprofit, and industry groups, MariLCA—funded by the Life Cycle Initiative and Plastics Europe—is building a more robust method to enable LCA to incorporate the harms of plastic waste to organisms, ecosystems, and human health. For aquatic life, for example, some considerations include plastic entanglement or ingestion.

Anne-Marie Boulay, a chemical engineer at Polytechnique Montréal and co-chair of MariLCA, said she first organized a similar initiative for water use, which is now a common life cycle impact factor but was often excluded from analyses in the past. The dispersion of plastics in the environment is another missing piece that could lead LCA practitioners to draw misleading conclusions. "If emissions of plastic waste to the environment are not included in the methodology, then most questions about packaging cannot be properly answered," Boulay said. "When we don't have the full picture, how do we know if this is actually worsening another problem or shifting the problem elsewhere?"

Some MariLCA collaborators study how different plastic types, shapes, and fragment sizes behave in freshwater, seawater, or soil. Others like Boulay use existing research to build characterization factors—the part of LCA that translates scientific understanding into measurable environmental impacts. MariLCA offers several conversion methods. One approach translates science into the percentage of species a specific plastic might affect annually. Currently, MariLCA only provides guidance for calculating impacts in marine systems. As more data emerges, MariLCA will revise its tools. Boulay and colleagues are already drafting a second update, expected to be released later in 2025.

Even as LCA becomes more comprehensive and includes concerns like wildlife harm, Brandon still hopes states will adopt approaches different from Oregon's. She prefers EPR programs to work backward from the recycling systems they envision, rather than setting fees or incentives based on LCA results. If the goal is to maximize reuse, have easy-to-operate recycling systems, and reduce plastic packaging—goals the Ocean Conservancy hopes to see in EPR programs—then policies can be crafted to support these changes.

Other states are taking this approach. For example, California's EPR law requires that by 2032, the amount of single-use plastic packaging and food service ware sold in the state be reduced by at least 25%. In the same year, all such items must be recyclable, and 65% must actually be processed through recycling systems. The draft implementation plan requires the PRO to determine fees based on the quantity and weight of plastic materials producers place in the state. The PRO is also expected to give discounts to producers using "renewable" plastics—materials "derived entirely from natural resources that are not mineral or fossil fuel sources and do not cause net depletion of any resource."

California's program does not require producers to submit life cycle assessments. According to CalRecycle, it is up to them whether to do so. "The law does incentivize producers to consider the life cycle of their products by ensuring they pay costs associated with end-of-life management. Products that are difficult to reuse and recycle will bear higher costs under the EPR program," information officer Patrick Coyne wrote in an email. "Producers need to consider the product life cycle, including design for easy recyclability, compostability, or reuse, as well as the product's recycling rate."

Sean Buckingham, EPR program planning lead at the Circular Action Alliance (CAA), the PRO for both Oregon's and California's programs, wrote in an email: "CAA currently does not plan to introduce LCA in states where EPR legislation or regulations do not mandate its use."

Future Questions

If many producers choose—or in Oregon's case, are required—to submit LCAs due to regulations, comparing assessments across companies could become tricky. Miller of the University of Michigan said: "The real problem arises when we try to use LCA for legislation and lawmaking. How do we ensure that all LCA practitioners handle things the same way, consistently?"

Oregon's EPR program prescribes some LCA protocols for manufacturers. The entire process is based on guidelines issued by the standards organization ISO, a choice followed by many—but not all—LCA practitioners. Oregon's DEQ added additional specifications to ensure brands use the same inputs as much as possible. But Miller said every group of LCAs comparing similar products faces the same dilemma: either everyone uses the same baseline data (industry averages or data from a single study) and agrees that the data is not perfectly suited to their own operations, or they use site-specific information for more accurate LCAs but make results harder to compare.

A trade-off example frequently arises in Miller's work and conversations with other LCA practitioners. LCAs targeting U.S. manufacturing include energy use data, particularly the amount of carbon dioxide emitted per kilowatt-hour of electricity. A national average is available, but factories in states like California or Vermont, which are below typical levels, might object. "If my factory is in a region below the U.S. average, that means you're penalizing the results of studies about my factory," Miller said. There is no single right decision about these trade-offs, but they are unavoidable, she added.

Oregon's DEQ wants information in brand LCAs to reflect as specifically as possible the manufacturing processes companies currently use for products that end up in the hands of Oregon consumers. "Producers must represent their specific products and supply chains as much as possible and prioritize primary data," said Peter Canepa, LCA specialist at Oregon's DEQ. Even if these requirements make comparing results across companies more difficult, site-specific information serves another DEQ goal: providing more information about manufacturing practices. Except for some proprietary details, LCAs and their components must be made public, Canepa added. The first mandatory reports will be released in 2026.

Lifset of Yale said more information about how packaging is made and where it ends up could be useful for government staff, policy researchers, and advocacy groups. Over the years, all the information generated by Oregon's LCAs could demonstrate multiple ways to change production protocols to reduce emissions, improve recyclability, or reduce material use. The LCAs generated for Oregon's EPR program will join what Miller calls a long list of existing assessments already sufficient for their own analysis. Enough LCAs have examined similar products and systems to step back and see which conclusions align or diverge. Although the pros and cons of specific packaging always vary depending on where and how it's made, Miller said one reliable approach remains constant: "The only way to guarantee no trade-offs is to reduce consumption."