Most packaging is single-use, meaning it’s designed to be disposed of, but that doesn’t mean that it has to end up incinerated or in the landfill. And yet, that is the fate of the majority of packaging waste across all materials (plastic, paper, metal, glass, etc.). Most of these materials are technically recyclable, so where’s the disconnect? Some common reasons include limited access to curbside recycling programs, consumer confusion about what belongs in the recycling bin, material recovery facilities (MRFs) lacking the capability to process certain materials, and packaging designed with problematic additives, coatings, inks, or multi-material components. All of these challenges contribute to actual recycling rates being incredibly low across the board. There are plenty of solutions – like furthering consumer education, community recycling programs, and MRF infrastructure – but all of these require funding. That’s where legislation comes into play.
Extended Producer Responsibility (EPR) laws aim to hold producers accountable for the end-of-life management of the packaging that they produce. This approach is not new; many countries around the world have already implemented some form of EPR legislation. In the United States, EPR laws exist at the state level, with 8 states having already passed legislation and many others drafting their own regulations. While the specific details of each law differ, most of them are structured similarly: producers must annually report the types and weights of packaging they place on the market and pay fees based on those amounts. Generally, materials and packaging formats that are harder to recycle have higher fees, which incentivizes producers to design packaging that is easy to recycle.
California’s EPR Law, Senate Bill 54, requires that by 2032 all single-use packaging sold in the state must be recyclable or compostable and 65% of single-use plastic packaging must actually get recycled. Each year California’s Department of Resources, Recycling, and Recovery (CalRecycle) conducts statewide assessments of the collection and processing infrastructure and publishes a Covered Material Category (CMC) List that defines which materials and packaging formats are considered recyclable or compostable. By 2032 producers will only be allowed to sell packaging that falls into one of these eligible categories. For each category on the list, CalRecycle also calculates the total weight of the material sold into the state and then estimates the percentage that actually gets recycled. The Circular Action Alliance (CAA) then uses this information to set the EPR fees for each category, with the goal of incentivizing producers to sell packaging that is recyclable because they will pay lower fees.
There are some material categories that are recyclable in theory, but they are classified as not recyclable on the CMC list due to low real-world recycling rates. For example, most flexible and film plastic packaging can technically be melted and remolded into new products, but frequent problems with separation, sorting, and contamination mean they are not accepted in most curbside programs. As such, every flexible and film format within the plastic category on the CMC list has been deemed non-recyclable. So how can companies gauge the overall recyclability of their packaging portfolio?
To assess if packaging is compatible with existing sorting and processing capabilities, consider the primary material of the package and refer to the design guides published by the associated industry organizations. For example, in North America the APR Design Guide is considered the most robust set of criteria for designing recyclable plastic packaging. Similar guides also exist for aluminum, cartons, glass, paper, and steel. These resources provide recommendations to achieve optimal sorting, reprocessing, and recoverability, while also highlighting packaging attributes that are detrimental to recycling. The specific recommendations differ for each material; however, there are a few general rules that apply to most packaging:
- Mono-material: Use the same primary material type for the entire package.
- Separability: If your packaging requires multiple components, design each one so that it is easily separated from the main body.
- Additives, Inks, and Adhesives: Avoid using additives, barrier layers, inks, or adhesives that are not compatible with the target recycling stream.
- Color: Dark and opaque colored items are more difficult to recycle, so instead opt for transparent, natural, or light colors.
- Contamination: Design packaging that can easily be emptied or rinsed out to avoid it being contaminated by the product.
California Senate Bill 54 is just one state’s approach to improving the end-of-life outcomes of single-use packaging and offsetting the negative environmental impacts, but similar kinds of legislation exists in many other states and countries. Recyclability is quickly shifting from a sustainability goal to a legal requirement, and companies that proactively design packaging for real-world, at-scale recycling will be much better prepared once bans and performance mandates take effect.
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