As pressure grows to improve packaging circularity and reduce waste, governments are increasingly adopting policies that place greater responsibility for end-of-life packaging management on producers. Extended Producer Responsibility (EPR) laws are one of the primary policy tools used to shift the financial and operational burden of packaging waste management onto producers while creating incentives for more recyclable and resource-efficient packaging designs. For companies with in-scope packaging, these laws can create significant new compliance obligations and costs. As packaging EPR requirements continue to develop, life cycle assessments (LCAs) can help producers evaluate packaging trade-offs, support redesign decisions, and, in some EPR programs such as Oregon’s, reduce EPR fees by demonstrating improved environmental performance.
Why EPR is changing packaging decisions
Although extended producer responsibility is not a new concept, the growing number of packaging-specific EPR laws being introduced has brought the issue to the forefront for many companies bringing packaged products to market. Packaging EPR laws require producers to help fund and support systems that manage packaging at the end of its useful life through producer responsibility organizations and fee structures tied to the types, weights, and amounts of packaging introduced to the market. Adding complexity to the matter is that it is up to each state to develop EPR legislation applicable to producers within its scope. The legislation is still being developed and finalized in many states that have enacted EPR laws. Tracking the different compliance requirements and staggered deadlines can add an additional layer of stress for organizations operating across multiple EPR states.
The first producer fee invoices have begun being issued in Oregon and Colorado, and the public fee schedules show that costs can vary significantly depending on the types of packaging a company has supplied in each state. While specific fee schedules and circularity incentives vary by state, in general, states reward packaging choices that support recyclability, recycled content, and reuse systems.
Additionally, packaging may be subject to eco-modulation factors that affect the fees that in-scope organizations are responsible for. Eco-modulation works by increasing or decreasing producer fees based on packaging characteristics the state wants to discourage or reward. This can mean lower fees for packaging that better supports recyclability, recycled content, or reuse systems, and higher fees for materials that are harder to recover or recycle.
Specific to Oregon, producers may also request eco-modulated fee discounts by conducting voluntary life-cycle assessments (LCAs). Oregon awards larger eco-modulation bonuses for analyses that show that a packaging change has achieved a substantial reduction in environmental impacts. Outside Oregon, LCAs can still provide strategic value by helping producers test redesign options, document environmental trade-offs, and generate evidence that may support alignment with eco-modulation frameworks in other states, although there is not the same direct financial benefit seen in Oregon’s program.
Why an LCA is a useful business tool under EPR
While Oregon’s EPR legislation directly links eco-modulation adjustments to the life-cycle impacts of in-scope packaging, LCAs offer strategic value in other EPR states by helping producers compare packaging alternatives and prioritize redesigns that align with eco-modulation criteria. Many EPR programs reward packaging choices, such as using more recycled content, improving recyclability or compostability, and encouraging reuse.
An LCA helps producers avoid packaging changes that improve one performance characteristic while creating unintended consequences in another. Comparative LCAs can help organizations determine which materials or packaging formats best meet their needs, rather than focusing on a single factor. For example, conducting an LCA may reveal that switching packaging to a certain mono-material format improves recyclability but also increases GHG emissions because the replacement material is more energy-intensive to produce. Similarly, an analysis could find that reducing packaging weight may lower material usage but could also reduce product protection, leading to higher rates of damage, spoilage, or loss. By showing how a packaging system performs across multiple life-cycle stages and impact categories, LCAs provide organizations with a better understanding of redesign and purchasing decisions.
LCAs can also support EPR-related analysis and documentation by providing consistent, comparable data on a package’s environmental impacts across raw material extraction, manufacturing, transportation, and end-of-life management. This can help organizations identify impact hotspots in the supply chain, understand where meaningful improvements are possible, and focus efforts on changes that align with EPR compliance priorities.
In some states, these incentives are already taking shape. In Colorado, producers can submit voluntary data to qualify for certain incentives. LCAs can help pinpoint which packaging changes may be most valuable to track or invest in. Minnesota’s law strongly encourages packaging formats that are reusable, recyclable, compostable, or refillable. California requires in-scope producers to reduce plastic-covered material by 25% by 2032, adding another reason to compare packaging redesign options. LCAs can be a useful tool for producers to evaluate trade-offs and identify which redesigns are best aligned with EPR program priorities.
What an LCA evaluates and how it is performed
Organizations using LCA for EPR compliance generally conduct the assessment in accordance with ISO 14040 and ISO 14044 standards. These widely recognized standards provide a consistent framework for conducting and comparing life cycle assessments. Under these standards, an LCA is defined as a structured method for evaluating the potential environmental impacts of a product system across its life cycle.
Source: ISO Online Browsing Platform
For packaging, this typically means assessing impacts across key life-cycle stages, including raw material extraction, material pre-processing, product manufacturing, transportation and storage, and end-of-life management. The analysis may also consider performance-related factors such as product protection, spoilage, or product loss, as these outcomes can significantly affect the total life-cycle impact.
Under ISO 14040 and 14044, an LCA is generally conducted in four phases: goal and scope definition, life cycle inventory analysis, life cycle impact assessment, and interpretation. In practice, this defines which packaging systems are being compared and what functions they are meant to serve, gathers data on material and energy inputs, evaluates environmental impacts across selected categories, and interprets the results to understand trade-offs, hotspots, and opportunities for improvement.
Key Limitations and Cautions
While LCAs can be powerful tools for evaluating packaging alternatives, their results are heavily dependent on how the LCA is conducted. Choices such as end-of-life assumptions and data sources can materially affect the assessment outcomes, making results only as meaningful as the methodology behind them.
Packaging LCA results are most reliable when informed by the company or by other experts with product- and packaging-specific knowledge. Identifying realistic alternatives requires input on technical constraints that may not be reflected in publicly available LCA datasets. In practice, the company or its packaging provider helps identify realistic alternatives and provides the technical information needed to compare them. The LCA process then evaluates the environmental trade-offs among those packaging options. An LCA should be treated as a collaborative evaluation process, rather than a stand-alone exercise done without input from those responsible for packaging design and performance.
LCAs also do not automatically translate into lower EPR fees. A package may perform well in a life-cycle study but still fall short of an EPR program’s specific fee criteria related to recyclability, reuse, or recycled content. Additionally, conducting an LCA can require significant time, data collection, and technical review. LCAs are most useful when they are treated as structured decision-support tools that complement state-specific EPR compliance analysis.
Conclusion
As packaging EPR programs continue to take shape, producers are under increasing pressure to understand how packaging choices affect environmental performance and fee exposure. LCAs can provide a structured way to compare alternatives, identify tradeoffs, and support packaging decisions aligned with emerging EPR requirements. Although an LCA is not a substitute for state-specific compliance analysis, it can serve as a valuable decision-support tool for organizations seeking to better understand the potential environmental implications of packaging redesign options.
GSI can support comparative LCA analyses that evaluate packaging alternatives across their life cycles. This can help organizations compare options, identify unintended trade-offs, and make more informed decisions about source reduction, packaging changes, and potential EPR fee implications.
