Navigating Packaging EPR Mandates: A Strategic Roadmap For Producers The U.S. packaging industry is undergoing a significant, mandatory transformation. With seven states—Maine, Oregon, California, Colorado, Minnesota, Maryland, and Washington—enacting Extended Producer Responsibility (EPR) for packaging laws, the regulatory landscape is rap- idly evolving. Producers cannot afford a reactive stance; compliance must be a core business strategy. EPR laws fundamentally shift the financial and oper- ational responsibility for packaging waste management from municipalities to producers. This structure, which incorporates eco-modulation, is designed to incentivize a circular economy by promoting recyclable designs, plastic material reduction, and greater use of post-consumer re- cycled (PCR) content. For packaging manufacturers and brand owners, navi- gating these complex, jurisdiction-specific rules requires a proactive strategic response. The Three Tenets Of EPR Compliance While implementation timelines and requirements vary, all U.S. EPR for packaging policies feature three key pillars. 1. Design For Recyclability: As EPR mandates expand, designing for recycling is no longer optional—it’s essen- tial. Recyclability must be embedded early in the product development process, not addressed as an afterthought. • Use the Association of Plastic Recyclers (APR) Design® Guide for new and redesigned packaging. The How- 2Recycle labeling program is also valuable. • Replace problematic plastics like polystyrene (PS) and polyvinyl chloride (PVC) with widely recycled materials such as PET (RIC 1), HDPE (RIC 2), and PP (RIC 5). • Transition away from carbon black to black colorants. • Ensure oxygen and moisture barriers that are critical for food safety and shelf life are compatible with existing recycling streams. 2. Source Reduction Using fewer materials in packaging is a highly effec- tive way to reduce environmental impact, minimize overall waste management, and cut production costs. Implement lightweighting by reducing material thickness and right-sizing packages to avoid unnecessary material use. • Eliminate extraneous secondary or tertiary packaging elements. • Thermoforming is inherently lighter and limits material inefficiencies compared to injection molding process- es, supporting immediate material reduction goals. • Align with stringent source reduction requirements to streamline processes and reduce the complexity of multi-state compliance. 3. PCR Content PCR requirements are ramping up alongside EPR poli- cies, aiming to drastically reduce reliance on virgin plastic. CONTINUED ON PAGE 18
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November 3, 2025
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