Advancing Recycled Content and Recyclability

Postconsumer recycled content that can be used in new food and beverage packaging still faces obstacles to widespread use. Companies like Nova Chemicals and Atlantic Packaging are trying to leverage B2B closed loops to increase supply.

Some states have also passed laws mandating minimum levels of recycled content in certain types of packaging.  

There’s also some evidence that the shift to more PCR use could win brands favor with customers. In a recent Nova Chemicals consumer insight survey, three-quarters of respondents agreed that companies ought to increase their use of packaging made from recycled materials.

But there are barriers to achieving this ubiquity, and industry participants lament imbalances in the recycled plastics economy.

“One of the issues that I see is a real disconnect between supply and demand,” said Crystal Bayliss, who leads the PCR workstream at the U.S. Plastics Pact. She said that procurement teams need to think about the long term, working with converters to establish a supply of the PCR grades they need. 

It’s a pressing issue: A recent study by Closed Loop Partners highlights an increasing demand for food-grade polypropylene, citing infrastructure challenges as a key barrier to increasing supply. 

Today, food-grade PCR is most often found in the form of recycled PET in soda and water bottles. Many companies include recycled content targets among their voluntary packaging sustainability goals, though progress toward those goals has varied. 

A March 2025 report from Smithers noted that 1.2 million metric tons of food-grade PCR was used for packaging in 2024. That’s up 9% from 2019 and “driven by strong demand in end-use sectors such as food and drinks, as well as greater emphasis on the use of recycled material in the manufacture of plastics packaging,” the report said.

And a 2023 McKinsey & Co. report said that “if brands with public recycled-content commitments follow through on their plans, the U.S. demand for recycled polyethylene terephthalate (rPET) in 2030 would outpace supply by about three times.”

PCR logistics

While some companies have since adjusted their plastics goals, major increases in recycled content use remain on many of their road maps.

Some of the hangup comes from issues with initial packaging design. Stabilizing PCR streams starts with boosting the amount of material that can be successfully recycled. For example, opaque colored bottles are harder to recycle. Avoiding potential contaminants also is important when the goal is to recycle packaging into a new product.

“We need to make sure that we’re not unintentionally contaminating the waste stream by doing things like putting a paper label onto a plastic film,” said Stewart Whitmire, senior manager at Atlantic Packaging.

Sources say that collection remains one of the major barriers to increasing the quality and quantity of food-grade PCR. They also say more investment and control in the recycling value chain is needed, as well as changes to consumer habits and recycling availability.

“Even though collection is going up, it’s not going up enough,” said Srinivasan Prabhushankar, technical director at the National Association for PET Container Resources. “What we really need is the velocity and scale.”

For now, PCR is typically more costly than virgin plastic. As of January 2025, Platts data showed price spreads between recycled and virgin materials are close to their highest recorded values since 2022. For procurement teams that are used to buying virgin materials, it’s a learning exercise.

“When you’re talking about virgin materials, you can get the same thing every time, for the agreed upon price, for the stated term,” said Emily Tipaldo, program manager at the Association of Plastic Recyclers.

Reiterating a longstanding industry concern, Tipaldo said there’s a chicken-and-egg problem: low availability of PCR feedstock can drive up prices, but recyclers and reclaimers ultimately need long-term assurance of demand. “Without that … they really can’t make those investments and likely won’t be able to deliver exactly what the client or customer wants,” Tipaldo said.

PCR can differ from virgin materials in terms of texture and color, potentially posing concerns for brands who want complete consistency in the aesthetics of their packaging.

Longer-term contracts can help ensure more consistency over time. But, Tipaldo pointed out, they are often not watertight. And when companies walk away from PCR contracts due to importing resins from abroad or opting for virgin materials at lower prices, that can stifle reclaimers’ progress.

Tipaldo said some companies may not continue business due to the size of the contracts that were abandoned. She noted that when North American reclaimers cite "economic conditions" as a reason for cutting capacity, not moving forward with upgrades, or pulling out of certain markets it often has to do with losing contracts. This can happen, she said, “because of prices compared to virgin or ‘off-spec’ resins, or due to recycled plastic imports undercutting [North American] PCR."

Bayliss echoed the need for long-term contracts, “so that reclaimers can install the equipment that is needed to produce those higher quality grades of PCR.”

Looking ahead

The U.S. Food and Drug Administration released new guidance in 2021 on the use of recycled plastics in food packaging, but more momentum is happening at the state level due to certain laws requiring PCR.

For example, Washington state will require that most types of plastic beverage containers have no less than 25% postconsumer recycled plastic content by weight by 2026. And in California, requirements to use PCR are ramping up over time: Between 2025 and 2029, many plastic beverage containers will have to contain at least 25% PCR, on average; by 2030, the requirement will be 50%.

But using more PCR is just one lever that brands can pull in their mission to use less virgin plastic. Another, Whitmire pointed out, is lightweighting and downgauging. For some brands, this might be a more viable option.

“All PCR is not created equal at the moment,” he said. “[It] has to be of a quality that you’re not sacrificing performance of the structure.”

If the PCR doesn’t meet specific performance criteria, then this could potentially lead to using more plastic. The goal, Whitmire said, is to find instances where virgin plastic can be replaced with PCR one-for-one.

Closed loops and B2B sourcing are seen as one way to generate more high-quality PCR. Nova Circular Solutions, a business unit formed in 2023, started up a new Indiana facility in January that will focus on processing films collected from retail and distribution centers into pellets.

“What’s key is the traceability, and the security of supply of the feedstock,” said Vice President Greg DeKunder. 

Once at full scale in 2026, the facility is expected to offer more than 110 million pounds of recycled polyethylene to the market annually, with two of the four lines designed for food-grade PCR.

This follows Nova Chemicals announcing in June that it received a letter of no objection from the FDA for its Syndigo product, confirming the capability of the recycling process to produce linear, low-density polyethylene suitable for broad food-contact applications. Helping customers to design the packaging and shoring up supply is a key focus, said DeKunder, adding that “it’s not going to be here today, gone tomorrow.”

In the push for incorporating more PCR and preparing for state regulation, Bayliss suggested that companies need to make sure their cross-functional teams are all on the same page.

“Oftentimes, these things run through the sustainability department, possibly the packaging department. But it also needs to run through the procurement department,” she said. Companies need to understand requirements “and then [put] their procurement managers to work to build that industry capacity.”

The effort to add more recycled content to packaging has been a long road for brands, converters and recyclers alike. Speakers at the Plastics Recycling Conference celebrated industry progress while highlighting the best next steps for improvement. 

The conference, held March 24-26, 2025, in National Harbor, Maryland, highlighted ongoing supply and demand challenges, the role of brand commitments and the ups and downs of tackling harder-to-recycle packaging formats. Here are some takeaways from the event: 

Balancing ambitious goals with business realities

Numerous brands have publicly committed to recycled content goals, and speakers highlighted the balancing act of striving toward ambitious targets while also being realistic — and transparent — when companies fall short of those goals. 

Some brands that had 2025 deadlines as part of global commitment programs led by the U.S. Plastics Pact and the Ellen MacArthur Foundation either missed those targets or updated their timelines to 2030. USPP has also updated its strategic plan with new 2030 goal targets. A 2024 progress report from EMF noted that PCR now accounts for 14% of brand and retail signatories’ plastic packaging, which is up from 5% in the baseline year of 2018 but below the 2025 target of 26%.  

Consumers ultimately need to understand the value of recycled content so they’re motivated to recycle, but they also need to understand the forces at work that make adding PCR difficult, such as market dynamics and supply challenges, said Jonathan Quinn, CEO of the U.S. Plastics Pact, during a panel on recycled content goals.

“As an industry, we've done a tremendous job of telling each other how great of an impact we're having, but we've done a horrible job of communicating the challenges and the hurdles of the progress we've made to consumers,” he said.

Mark Watts, associate director of packaging sustainability at Church & Dwight, noted during the panel that brand owners are grappling with the costs of adding PCR to their products, either because the PCR version of a resin is more expensive or because of added costs associated with certifying such PCR resins.

“It’s getting more and more expensive, as well as technically demanding, in terms of how we put this material back into products,” he said. 

Watts says some companies face a “vicious spiral” where they scramble to meet higher recycled content rates by certain dates, “but the infrastructure is not keeping up with it, and we're now having to pay more for what little material is available that fits the portfolio.”

Brands must acknowledge the realities that make recycled content integration a challenge, but should continue making as many changes as they can — even if they miss a goal in the short term, Quinn said. 

“We can’t back down now,” he said. “These goals are meant to be aspirational. If they’re not, they're not going to drive progress.” 

Matching recycling policy with market demands

Upcoming extended producer responsibility laws for packaging could help smooth out many packaging companies’ supply and infrastructure problems, speakers said. However, EPR isn’t a magic wand — and EPR won’t have an immediate impact on markets or companies’ ability to integrate more recycled content. 

“The beauty with EPR is that we can now go out to recyclers, municipalities and really invest in these [recycling] systems, knowing brands have your back” and will commit to buying recycled content in the long term, said Anja Brandon, director of plastics policy for the Ocean Conservancy. “In theory, that should be helping you, not tomorrow, but in three to five years, to get to those PCR goals, get to those targets.”

But policy — either EPR or other legislation — should also include PCR requirements that drive demand, she added. Without PCR mandates, recyclers don’t have assurances that customers will buy recycled content and could lag on investing in the infrastructure needed to do so.

Domestic sourcing is another key element to effective recycling legislation, Quinn added. “You’re getting access to all the material in the domestic market in which you operate. … That is critical to just making this financially viable,” he said. 

Though most of these conversations are playing out at the state level, federal policy could also drive recycling and recycled content policy in coming years. 

A newer perspective on recycling-related legislation is the idea that recycling supports the U.S. economy, a view that has become more popular under the Trump administration, said Kate Bailey, chief policy officer at the Association of Plastic Recyclers, during a panel on recycling policy. “It’s a more important time than ever to talk about the domestic manufacturing benefits of recycling,” she said. 

In Congress, recycling has typically been seen as a bipartisan issue, even after the Trump administration took office again earlier this year, she said. 

Investing in recycled content innovations

State and federal policies will continue to have an important influence over the future of recycled content in packaging, speakers said. Yet businesses also continue working on innovations meant to ease recycled content challenges. 

Films and flexible packaging are formats that have endured such well-known challenges.

“In the big push to increase plastic recycling, the last one to be resolved will be film because it’s the hardest to do,” said Scott Coleman, CEO of Revolution Sustainable Solutions. The material is fragile, gets contaminated easily and often comes with a host of layers and additives that are expensive to eliminate, “but this still needs to be done — 18 billion pounds of film are manufactured or used in North America each year,” he said.

Part of getting brands on board with recycled content for these formats is acknowledging both the costs and the benefits, said Anna Rajkovic, market and innovation manager of mechanical recycling for Nova Chemicals.

“In our conversations with our converters, brand owners and retailers, everyone is interested in having the ability to put recycled content back in their products. And that means focusing on the high-quality products,” she said. “They are willing to pay for that quality, and that is a positive sign for our investments. That means we can drive innovation.”

Plastic film recycling is growing, although the sector still largely relies on recycled content from postindustrial sources and has limited curbside recycling inputs, speakers said.

“It’s in a place I never thought possible 10 years ago,” said Sunil Bagaria, chairman of film recycler GDB International. He noted that the company has grown its film recycling partnerships over the years, including with companies like General Mills. 

Panelists noted that there’s also plenty of room for innovation in the food-grade plastics space, both for flexible packaging and for rigid polypropylene. 

During a discussion on food-grade PP challenges, Neil Darin, senior director of resiliency and holistic packaging for TMS, noted that the resin offers packaging companies “great performance with great density advantage,” but uneven recycling markets mean finding reliable PCR sources can be a struggle.

Robert Flores, senior vice president of sustainability for Berry Global, noted that increased recycling rates for PP benefit both recyclers and packaging companies like his. That’s because a higher volume of PP allows customers to request specific grades and formats to fit their processes, he said.

Recycling equipment innovations are swiftly bridging the gap between sorting challenges and demand for PP that can easily be remade into food-grade resins, Darin said. “AI is something that we weren't even talking about a few years ago. Now, it’s being used to sort food grade from non-food grade.”

Sponsored content

By Avery Dennison

The global shift towards sustainability is no longer a distant future; it is a present reality reshaping the consumer packaged goods (CPG) industry. As highlighted in the Avery Dennison Making Packaging Circular white paper, brands increasingly recognize sustainability as a key performance criterion and value driver. A critical component of this transformation is the focus on recycled content and recyclability in packaging, driven by consumer demand, regulatory pressures and a growing understanding of environmental responsibility.

Consumers are demanding sustainable packaging and are willing to pay more for eco-friendly options, pushing brands to reduce waste and promote circularity. Global regulations, such as the EU's Packaging and Packaging Waste Regulation (PPWR) and North America's EPR policies, are further driving sustainable practices by mandating recyclable and reusable packaging. While nearly all major CPG brands aim for 100% recyclable, reusable or compostable packaging by 2030, over 80% are falling short of their goals, underscoring the challenges in achieving sustainability. Despite this, sustainable packaging remains a key focus for progress.

Recyclability: A cornerstone of sustainable packaging

Recyclability remains a central theme in advancing sustainable packaging. Brands are increasingly committed to ensuring that every component of their packaging — from the main body to caps and label decorations — supports effective recycling. By designing with recyclability in mind, companies contribute to a circular economy and reduce dependence on virgin materials. Every detail matters; even small design oversights can disrupt the recycling process.

The evolution of pressure-sensitive labels (PSLs)

Pressure-sensitive labels (PSLs) play a significant role in packaging and must be designed with recyclability in mind. Historically, PSLs were sometimes misperceived as having a negative impact on recycling processes. However, recent advancements in pressure-sensitive adhesive technology have transformed them into a circular packaging enabler. Innovative "clean release" PSL adhesive solutions, like CleanFlake™ Technology, have gained recognition from leading organizations such as the Association of Plastic Recyclers (APR) and RecyClass. These technologies are officially deemed compatible with standard rigid plastic recycling streams, including HDPE and PET, marking a significant step toward more sustainable recycling practices.

In PET mechanical recycling, for example, PSLs designed with CleanFlake™ adhesive technology cleanly detach from the PET packaging during the washing process. This ensures that PET flakes are free of residue or contamination, maintaining the quality of the recycled material. Similarly, in HDPE recycling, new PSL adhesive solutions that use mono-material facestocks are recognized as compatible, enabling HDPE rigid plastic recycling.

The environmental impact of recycled materials

Incorporating recycled content into packaging significantly reduces environmental impact, as highlighted in the Making Packaging Circular whitepaper. According to the report, recycled PET and HDPE generate over 70% fewer emissions compared to their virgin plastic counterparts. For instance, recycling one kilogram of PET packaging saves 1.4 kilograms of carbon emissions, while recycling one kilogram of HDPE saves 1.9 kilograms. The whitepaper also emphasizes that even small improvements in recycling rates can have a substantial impact. For example, a beverage company producing 10 billion bottles could reduce plastic waste by 2,000 tons annually, with just a 1% increase in recycling rates.

To achieve sustainability goals, brands are setting ambitious targets for incorporating recycled content into their packaging, ranging from 5% to 50%, depending on the materials used. However, the growing demand for recycled materials often outpaces supply. Avery Dennison is bridging this gap through initiatives like AD Circular, which strengthens the circular economy by providing liner collection sites to improve recycling rates. The company also offers label materials with 30% to 100% recycled content, including liners and facestocks, enabling brands to minimize their environmental impact effectively.

A collaborative path towards packaging circularity

The push for circularity is reshaping the packaging industry. Consumers demand sustainable solutions, and brands face growing pressure to meet these expectations while fulfilling their environmental commitments. By adopting innovative technologies like advanced PSL adhesives, increasing the use of recycled content and fostering collaboration throughout the value chain, brands have the opportunity to reduce waste, lower emissions and drive meaningful progress toward sustainability.

The journey to packaging circularity is complex, but attainable. Recycled content and recyclability are the cornerstones of a more sustainable packaging ecosystem. By combining innovation, collaboration and a commitment to environmental responsibility, the packaging industry can deliver solutions that meet consumer needs and environmental goals, paving the way for a greener, more sustainable future.

When Amcor first committed to make all of its packaging recyclable or reusable by 2025, “there was a lot of doubt, both internally and externally,” said Chief Sustainability Officer David Clark.

At the time in 2018, Amcor wasn’t sure how it would develop packaging to achieve those goals and meet customer expectations. But once its innovation teams started working with suppliers and customers, “it turned out to be a lot more possible than people may have thought at the beginning,” Clark said.

The company says that by the end of 2024, 100% of its specialty carton packaging and 95% of its rigid packaging was recyclable. Separately, 94% of its flexible packaging had a “recycle-ready” solution available, up from 56% in 2018, indicating the packaging is at least designed to be recycled by existing technologies — though, in practice, infrastructure may not yet be widely available, meaning it doesn’t actually get recycled.

Now comes the toughest work for Amcor along with other packaging producers and their customers: transforming the remainder of the packaging portfolio, sometimes referred to as the “final 5%.”

It’s a bit of a euphemism, seeing as producer, brand and retail signatories to the Ellen MacArthur Foundation’s Global Commitment have collectively made 70% of their plastic packaging reusable, recyclable or compostable. As part of the commitment, Amcor and others agreed to transform 100% of their portfolios by 2025.

The most challenging part of the portfolio typically includes flexible plastics and multilaminates, both of which are difficult to recycle. That’s prompting producers, brands and retailers to innovate with new materials that are recyclable, reusable or compostable. But they’re also recognizing the trade-offs with redesigning packaging for certain products, as well as limitations with collection and sorting systems to ensure recyclable packaging actually gets recycled. At times, this has led companies to reconsider their lofty sustainability goals. 

“We're at this plateau,” said Brandi Parker, the founder and brand-level sustainability consultant of Parker Brands. “Now we've hit the very complicated problems to solve.”

To swap or not to swap materials

For decades, packaging manufacturers have developed multilaminates and flexible plastics with a focus on performance, whether that’s shelf stability, moisture barriers or anti-contamination properties, Parker said. While functionality remains critical, today’s heightened attention to end-of-life management means packaging manufacturers and brands have to “undo incredibly complicated pieces of engineering,” Parker said. 

Transforming packaging for circularity requires some trips back to the drawing board. One approach is to shift from multimaterial to monomaterial design. 

Parker has seen this type of R&D in pet food. Dry kibble, which can get stale quickly, uses multilaminate packaging to preserve the product, but large CPGs are looking at monomaterials — namely polyethylene, because “it does well on its own with all of those barrier requirements,” Parker said.

CPGs have also tested the waters with monomaterial packaging and other alternatives. In 2023, Ferrara switched 13 SKUs from multimaterial plastic film packaging to a monomaterial alternative. Nestlé started packaging some of its chocolate candies in paper in 2021, removing 250 million plastic packs sold globally each year.

When it comes to sustainability innovations, producers are “seeing promise in the natural world,” said Andrew Hargest, CEO of food packaging supplier SupplyClub. Manufacturers are developing packaging materials derived from seaweed, corn and more.

Even as alternative materials improve, “One of the things that plastic unfortunately has done is proven how well it performs as packaging,” Parker said. “These are incredibly difficult materials to get out of.”

Is the price tag worth it? 

Amcor pointed to the influence that customers and recyclers have in closing the gap on the 100% target. Clark suggested it’s on these customers to move the needle.

“It's hard for us to make the investment in R&D to develop a new product if our customer's not ready to switch yet,” he said. 

Cost is often cited as the biggest factor when companies are considering how to lower the environmental impact of their packaging, especially without a regulation mandating change. Newer technologies aren’t yet produced at scale or economically, Hargest said. If large brands buy into newer technologies and biobased materials, demand for those options will increase and costs will come down. But the industry isn’t there yet, according to Parker.

“Plastic is cheap; that is why it is the packaging material of choice,” Hargest said. However, as companies have coalesced around goals to make entire packaging portfolios recyclable, reusable or compostable, plastic substrates could become less profitable, Hargest noted.

Another key consideration is how a new material would affect customers’ operations. If the new packaging is filled or sealed differently, manufacturers might have to re-engineer their production lines, which would add cost and time, Clark noted.

Given the functionality and cost trade-offs with packaging changes, many companies, including giants like Walmart and Coca-Cola, are questioning whether they can meet the ambitious sustainability goals they set for themselves. Others are abandoning or resetting goals altogether, Parker said.

Kraft-Heinz is among the latest CPGs to recognize this challenge, noting in a recent sustainability report that 13% of its packaging isn’t expected to be recyclable, reusable or compostable within existing infrastructure. The company noted that much of this packaging is multimaterial flexibles and films that offer other benefits.

Hargest said it’s noble for companies to set ambitious goals, but “it takes away from the impact if the goal continually gets pushed a few years out.” His preference: A realistic approach that showcases what they did to achieve positive results so that other firms can learn from them. 

While there’s attention to the target percentages, companies also zoom out and acknowledge the factors inhibiting packaging from completing a circular cycle. The cost and functionality trade-offs to replace some packaging aren’t worth it in certain cases, Clark said. 

Packaging companies and their customers don’t necessarily want to get rid of multilaminates altogether, which shifts the focus to recycling infrastructure.

Unilever has pointed to a gap between its technical and actual recyclability rates, noting that “assumptions made on the development of new technologies and infrastructure have simply not materialized.”

Amcor has pursued chemical recycling as a set of technologies that could help manage flexible packaging, though such systems remain in the early stages of investment and efficiency. But in the end, “even if we do develop packages that meet the recyclability targets that we've set,” Clark said, “the rest of the system has to adapt.”

Consumer product companies are adapting, albeit with some challenges, as multiple states look to ramp up recycled plastic requirements for beverage containers and other packaging.

Washington state has begun enforcing a 2021 law that mandated various levels of recycled content in certain packaging types starting in 2023. This comes as a handful of other states have also enacted their own laws, each with their own product focuses, thresholds and timelines.

“It's important that Washington in particular is doing enforcement, because we want a level playing field,” said Kate Bailey, chief policy officer at the Association of Plastic Recyclers. “Everyone should be held to the same standard.”

At baseline, Washington’s monitoring relies on producers’ own reporting — the law does not contain a third-party certification requirement to confirm data accuracy, the Washington State Department of Ecology noted.

Environmental regulators there recently doled out more than $400,000 in fines across 35 companies — a list that included notable names like Clorox, Ocean Spray and Albertsons — for not incorporating enough recycled plastic in products.

While those few-dozen companies were fined, the other side of the coin is that many more registered producers successfully complied, Bailey noted.

And some brands have exceeded expectations. In California, for instance, in 2023 Niagara Bottling was the leading user of PCR plastic in the state at nearly 37.3 million pounds — which already put it at about 26% of recycled content across its overall reported plastic use, according to data published by CalRecycle. AB 793 required a postconsumer plastic recycled content standard of 15% starting in 2022 and 25% and 50% come 2025 and 2030, respectively, for plastic beverage containers subject to the California Refund Value.

Bailey called it “an important step forward” that Washington has the resources to ensure its law is enforced, and that in general it seems like brands are registering and complying without many waivers.

Still, there are shortcomings. Washington’s Department of Ecology described non-registration as its “greatest challenge with compliance” and estimates there are between 200 and 300 obligated producers that have not yet registered.

“This is particularly difficult when producers are not easily identifiable by a brand on the shelves, but may in fact be registered by a manufacturer with little to no brand recognition to the general public,” said Dave Bennett, the Department of Ecology’s communications manager for the solid waste management program, in an email.

While states are writing their laws differently, in Washington’s view enforcement can be one area for collaboration. “We plan to work with other states implementing recycled content laws and compare their registrants with ours,” Bennett wrote.

New Jersey, Connecticut and Maine are also states with recycled plastic requirements for certain types of beverage containers, although the latter two don't initially come into force until 2026.

Multiple brands in recent years have named limited access to recycled material as a key obstacle when reporting on voluntary recycled content or virgin plastic reduction goals in sustainability reports. At the same time, companies selling recycled plastic have repeatedly said there need to be stronger, longer-term and more reliable commitments from buyers to sustain the market.

From APR’s vantage point, supply seems to be largely available to meet laws’ current thresholds.

“I think some of the supply conversation is really also looking more into the future projections,” Bailey said. As with other state policies, Washington’s recycled content thresholds will ramp up by product type in the coming years. For instance, plastic beverage containers had to contain 15% recycled content in 2023, but requirements will increase to 25% come 2026 and 50% come 2031.

However, the Consumer Brands Association reiterates that “demand is far outpacing supply,” according to John Hewitt, senior vice president of packaging and sustainability and head of state affairs.

Many of the registrants that did not meet Washington’s minimum PCR requirements were juice producers, Bennett noted. “We have received some feedback to suggest that there is difficulty sourcing recycled content hot-fill polypropylene used in many of the beverage containers sold by these types of companies,” he said.

Additionally, the lack of uniformity of rates and dates across state laws is a challenge for packaging designers, Consumer Brands observed.

As companies redesign product packaging to comply in Washington, “they have to keep in mind that because they may meet the 2023 or 2026 mandate, doesn't mean that they're going to be ready or in a spot to meet the New Jersey mandate that may be happening within the next 12 months,” said Hewitt. “That contemplation, that constant churn in the packaging types, makes it very difficult to ensure that the packaging serves its ultimate purpose, which is to protect the product and protect the consumer.”

Hewitt said that as CPGs work to meet internal targets, “they oftentimes have to either pause or redirect those efforts” to meet various state requirements “because those dates don't necessarily all line up.”

And the nature of supply chains make it hard to design for a specific market, Hewitt said. But Bailey also called that out as an important driver of change. “It speaks to the power of individual states taking action. It can drive an entire market in some cases,” she said.

Industry groups anticipate states will continue to legislate on these issues. Early experiences with scale-up of these laws inform what they’d like to see in policy design going forward.

For the Consumer Brands Association, it’s important that legislation has “on-ramps” that take into account nuance by packaging type, as well as different requirements from agencies like the U.S. EPA and FDA, Hewitt said. Consumer Brands also advocates for being able to average recycled content levels across a portfolio; “that helps us take into account supply chain issues.”

For APR’s part, Bailey said that while numerous state policies have largely focused on beverage containers, APR would like to see more recycled content in durable good applications like pallets or trash bags.

Looking ahead, Washington’s Department of Ecology is interested in feedback on best practices from brands that have been successful in meeting or exceeding recycled content thresholds. That’s currently a knowledge gap because “Washington’s law does not allow for eco-modulation to reward producers who go above and beyond with recycled content use, and thus, we do not ask for additional narrative information in our reporting platform to understand producers’ individual processes or supply chains,” Bennett wrote.

Forgoing labels on packaging can help with processing used plastic, aluminum and glass containers for recycling. But there are barriers to this becoming ubiquitous across all material types, and for all brands.

Marika Knorr, head of sustainability and communication at CCL Label, pointed to branding issues that result from removing labels.

“The label usually sells the bottle,” she said via email. “If all bottles shifted to label-less bottles it would be hard to tell the products and brands apart.”

From January to March this year, Coca-Cola trialed 500ml rPET Sprite bottles without labels. In this pilot, labels were temporarily removed from bottles of Sprite and Sprite Zero sold in select U.K. stores. In place of the usual label, an embossed logo appeared on one side of the bottle, with laser-engraved product and nutritional information on the reverse side. The two varieties of the soft drink could be told apart based on bottle cap color.

Coca-Cola has run label-less pilots before, but this was the first combining these technologies for single-unit bottles sold in-store.

Bottles without labels are easier to recycle, thanks to cutting out one removal step from the typical recycling process. Plus, label-less bottles use less packaging material overall. According to Coca-Cola, removing the recyclable plastic labels would equate to a saving 2.8 kilograms of CO2 equivalent for every 1,000 label-less bottles produced.

“Although the design change may sound simple, this is a big shift from a marketing perspective,” Javier Meza, vice president of marketing with Coca-Cola Europe, said in the January announcement. “This trial could contribute to longer-term changes to the way brands communicate with their consumers.”

Aside from the laser-engraved Sprite bottle, there are other shifts toward label-less plastic bottles.

TotalEnergies Corbion, produces PLA with 20% and 30% allocated recycled content, is working with Korean bottled water producer Sansu to develop an embossed water bottle made of Luminy PLA bioplastics to help speed up the adoption of recycled PLA as feedstock.

“The recycling process typically starts with collection, followed by sorting and cleaning to ensure only PLA material enters the recycling stream,” said ChowPin Tan, vice president, sales and business development APAC & India at TotalEnergies Corbion, via email. “Labels, often made from different materials containing substances like inks and glue, must be removed during recycling.”

With label-less bottles, the company hopes to streamline the recycling process. Launching embossed bottles requires TotalEnergies Corbion to design molds that meet both aesthetic and technical specifications.

“Once the mold design is finalized, manufacturing steps are relatively unchanged, except for the reduction in labeling steps,” Tan said.

While the company intends to release its embossed bottles in Korea first, it also plans to explore introducing them to additional clients in other markets in the future.

There are other paths to more easily recycle PET which don’t involve forgoing labels altogether. CCL is among the label manufacturers working to solve for ease of recyclability by offering stretch sleeves that easily separate from PET bottles during the sink/float process at recycling facilities.

“Clean separation means higher-quality PET flakes for closed loop bottle-to-bottle recycling,” Knorr said.

She added that a label often contains important information that is required by law. “Engraving [instead] makes that information very unreadable — especially for older people or consumers with impaired eyesight.”

As more brands look to the possibilities of going label-less, Knorr believes that the visual impact of a product will continue to be important. And in the past, it has been the label that sells a bottle. 

“Brand colors and designs… have become iconic and make the product recognizable for the consumers at the point of sale,” she said.

Beyond embossed plastic bottles, other alternatives to conventional labels exist in the beverage industry, including some with striking visual results. 

For glass bottles, Saverglass offers direct-to-object printing, working with premium wine and spirits brands that are looking for advanced customization. The company helps clients to increase their shelf appeal with visually impactful packaging that eschews conventional labels. Instead it uses direct decoration, by printing right onto the bottle.

For now, some of these options remain out of the reach of some brands, due to a higher price point compared with conventional labels. However, Stephane Stanton-Brand, sales director with Saverglass for the East Coast regions of the U.S. and Canada, pointed out that inks can be cheaper for premium brands’ high-end decoration than for a high-end label.

Traditional printing uses enamel and heavy metals, but Saverglass has found what it describes as more environmentally sound solutions. The team now tries to use organic ink as often as they can.

“It’s better for the workforce because they’re not exposed to heavy metals,” said Stanton-Brand.

Plus, the organic inks use less energy.

“A bottle that is printed using enamel inks will need to be cured at a much higher level of temperature than a bottle that is printed [with] organic inks,” said Stanton-Brand, adding that there’s also an energy differential.

Meanwhile, the beer industry has seen an influx in shrink sleeves over the years.

Canworks is collaborating with the Earth to Beer project, which challenges craft brewers to create a packaged beer that is better for the planet. Formed in 2021, Canworks uses digital printing to print directly onto aluminum cans for beverages including beer, soda and energy drinks. This eliminates the need for the plastic shrink sleeves that hinder can recycling.

Canworks co-founder Marshall Thompson said that since aluminum can be recycled repeatedly without degradation, it’s an ideal candidate to be diverted from disposal. 

He said that the cost of digital printing on cans is comparable with the pricing for shrink sleeves. He added that digital printing is flexible enough to make fast changes: a big benefit for brands working to satisfy regulations that are in a state of flux, such as in the cannabis space.

“They just have to email us a new PDF,” he said. “We work a lot with the THC and hemp space. That regulatory environment is changing weekly.”

Plastic squeeze tubes have been an omnipresent packaging form in U.S. households for decades, but their incompatibility with single-stream recycling systems causes headaches for recyclers who receive them and brands with sustainability goals. That’s changing rapidly thanks to efforts from players along the squeeze tube value chain, but there are still major hurdles to overcome, they say, including a lawsuit over one big-name brand’s tube recyclability claims.

While squeeze tubes historically incorporated multiple strata of different materials, such as various resin exteriors with aluminum barrier layers, manufacturers are moving away from these designs, which hinder the recycling process, and toward monomaterial options. Most tubes on the market today are made from polyethylene, specifically HDPE, according to recycling research firm Stina. Currently, more than 75% of all HDPE squeeze tubes, and 90% of toothpaste tubes, on the U.S. market have designs that are compatible with recycling, according to data Stina recently released. 

Reaching that 75% milestone “reduces the potential for contamination and increases reclaimer confidence in accepting plastic squeeze tubes,” said Stacey Luddy, chief operating officer at Stina. “The majority of any packaging format on the market needs to be designed for recycling to provide quality feedstock.”

Stina credits its Tube Recycling Project, which launched in 2015, with advancing recyclability for this packaging type, which has been around since the 1950s. Participants and observers have noticed the change and how quickly the impacts occurred.

“I don’t want to underemphasize how big of a change in packaging format this is,” said Scott Trenor, technical director at the Association of Plastic Recyclers. “We've essentially, in five years, transformed a 60-year-old packaging format to one that's compatible with the current recycling stream. And that's a tremendous amount of work for everyone in the supply chain.”

Tube turmoil

On the tumultuous path toward making squeeze tubes recyclable, toothpaste tubes have become a lightning rod.

One setback is a class action lawsuit filed last year against Colgate-Palmolive over the CPG company’s “breakthrough” recyclable HDPE tube, released in 2022. Plaintiffs say the company’s on-product claims that some Colgate and Tom’s of Maine monomaterial tubes are recyclable is misleading because the tube typically is not locally recyclable in practice. They said a “miniscule” number of people in the U.S. can actually recycle these tubes curbside because few MRFs accept them, despite Colgate’s claims that they can be recycled with other No. 2 HDPE containers such as milk or detergent jugs.

Colgate sought to dismiss the case, but a judge ruled in February that the company must face the lawsuit. Various deadlines to advance the case will occur this year, and a hearing has been tentatively scheduled for July 11, 2025.

Colgate now uses recyclable tubes for about 90% of its North American toothpaste SKUs, according to its recently released 2023 sustainability and social impact report. It expects to reach 95% by the end of this year and hopes for 100% by next year.

Despite the legal challenge, Colgate remains a leader in advancing tube recyclability and helping to achieve the 90% recyclability level, Trenor said. The brand also went through APR’s critical guidance protocol during the design phase.

“They were the first ones to have a recycling-compatible tube,” he said. “Since then, they kind of did an open innovation type thing — where they offered that technology to others — because they knew that they couldn't be the only one in the space in order to grow the market and also make this a large enough volume that reclaimers would would want the material.”

Many domestic MRFs are equipped to sort monomaterial plastic squeeze tubes, but in practice, few publicly advertise that they’ll accept the products. One reason is that consumers don’t easily know the difference between the recyclable versions and the multimaterial lookalike tubes, which results in nonrecyclable products ending up at MRFs and potentially causing contamination.

During a session at the Packaging Recycling Summit in November, speakers broke down which items are and aren’t recyclable at most domestic MRFs. Joy Rifkin, sustainability manager at Illinois-based recycler LRS, noted the challenges with recyclable toothpaste tubes. She explained that the optical sorters at the company’s Chicago MRF can differentiate between the monomaterial and multimaterial tubes, but the company doesn’t advertise that to prevent a potential influx of lookalikes at the facility. 

“There are nonrecyclable tubes on the market. Obviously, even if you have 90% of the market, there's still 10% that are not,” Trenor said. “It's really now taking that next step on better educating the MRFs and the municipalities that these materials are recyclable.” 

‘Interconnected system’

While Colgate is a leader in this arena, more plastic squeeze tubes broadly are sporting recyclability messaging and recycling instructions.

Butth e fact that they’re labeled recyclable doesn’t mean tubes are getting recycled. Now that the Tube Recycling Project has determined that plastic squeeze tubes technically are recyclable in modern systems, its efforts move toward focusing on proper collection, sortation and processing — and at a large enough scale to make it attractive to recyclers.

While the tubes represent a “valuable feedstock” for recyclers and manufacturers to use in making new tubes or other products containing PCR, Trenor said, the order of tasks in achieving more tube recycling is important. “Starting with MRFs first and saying, ‘You're going to take these tubes that may or may not be designed properly,’ is going to work even worse than our current system,” he said. But “the complexity with the U.S. recycling system is that it's all held and controlled locally,” which adds time and difficulty to achieving unity. 

Collaboration across the value chain is critical to working through barriers to achieve higher levels of squeeze tube recycling, sources said. They noted the need to engage everyone, including brands, packaging engineers and consumers. For example, MRFs need to know that if they collect the tubes, a market exists for selling that material.

People need to understand that “recycling is an interconnected system that relies on the economic balance of supply and demand like any industry,” Luddy said. As such, “more recycled content needs to be used in products, and more of those products need to be purchased. Consumers also can play a big role in demand by buying products with recycled content.”

Boosting the amount of squeeze tubes that get recycled will take time. Even if all the tubes on the market were immediately recyclable, and every MRF suddenly accepted them, it would still take time for the products to work their way through the supply chain and use cycles to end up in the recycling stream. But Trenor is encouraged by the “huge change in the last five years” with plastic squeeze tubes and the potential for similar movement in upping the product’s recycling.