There’s no doubt about it; Extended Producer Responsibility (EPR) is the hot topic in the packaging industry these days with new/updated legislation and policies coming through weekly. Post-Consumer Recycled Content (PCR) and EPR go hand in hand, working together to make a circular economy, with many states incorporating specific PCR requirements and incentives into their packaging compliance laws.

 

A Look at PCR's Effect on EPR Laws

 

• California: California’s SB 54 requires producers to reduce plastic packaging by 25% by 2032, measured against a 2023 baseline. Incorporating PCR content into packaging is one of only five approved source reduction methods. Separately, California also has legislation establishing specific PCR requirements for plastic beverage containers, including a goal of achieving 50% recycled plastic by 2030.

• Washington: While Washington’s Packaging EPR law does not establish minimum PCR content requirements, the state has enacted separate recycled content legislation covering certain plastic products, including household cleaning & personal care containers, trash bags, and select beverage containers. These laws work alongside Washington’s broader packaging EPR framework.

• Oregon & Colorado: Oregon’s and Colorado’s EPR laws do not set minimum PCR content requirements for packaging. Both states will implement an eco-modulation fee structure; producers pay fees based on the recyclability and recycled content of their packaging.

• New Jersey: New Jersey’s Recycled Content Law sets minimum PCR content requirements for certain packages with increasing targets over time, including rigid plastic containers, glass containers, paper & plastic carryout bags, and plastic beverage containers.

Engineering with PCR

With EPR and recycled content legislation continuing to pave the way for increased use of PCR content in packaging materials, we’ll review a few challenges and insights the Adept Group’s Engineering Team has come across that might help you develop your next package with PCR content.

The Challenges:

Incorporating post-consumer recycled (PCR) content into packaging materials presents a unique set of engineering challenges that go far beyond simply replacing virgin resin with recycled material. Across flexible films, thermoformed trays, shrink wrap, and paper packaging, engineers consistently report that PCR materials behave very differently in production environments and often require extensive testing, process adjustments, and collaboration across teams to achieve acceptable performance.

One of the most significant challenges is machinability and sealing performance in flexible packaging applications. For example, when transitioning from virgin film to a PCR-based film that also met store drop-off recyclability requirements, engineers were required to use polyethylene (PE), a material that is highly sensitive to heat. In stand-up pouch applications where seals must crush through a zipper, this created a difficult balancing act. Increasing heat and dwell time helped achieve proper zipper crush and seal strength but also increased the risk of burning through the film in other seal areas. Engineers found that achieving consistent seals required hours of machine adjustments and close collaboration with maintenance and equipment teams to dial in the optimal settings.  

Another common challenge with PCR materials is reduced and inconsistent material performance. Engineers working with thermoformed rPET trays observed increased brittleness, tray breakage, and chipping. In one case, small pieces of tray material embedded into food products, creating serious food safety and brand reputation concerns. To improve durability, teams experimented with plasticizers and increased material gauge to maintain stiffness and strength. However, these changes added both development complexity and cost to the project. Some companies have since started exploring paper-based alternatives to reduce plastic usage altogether.  

The unpredictability of PCR materials is another major obstacle. Compared to virgin materials, PCR materials often have wider tolerances and fluctuating material properties, which can impact sealing, shrink performance, and overall package consistency. Engineers described introducing PCR content as requiring a “full redialing” of equipment settings because standard process parameters no longer apply. Extensive trialing is often necessary to validate temperature settings, pressure, dwell times, and machine speeds.  

PCR materials can also affect packaging appearance and printability. Variations in recycled content can reduce color vibrancy and alter surface characteristics. Changes in the coefficient of friction may require converters and printers to adjust their own processing conditions to maintain print quality. Because of these aesthetic and functional impacts, engineers emphasized the importance of evaluating graphics and print performance early in development when incorporating PCR content.  

Food safety and regulatory compliance remain critical considerations as well. Engineers noted that direct food contact approved PCR materials can be difficult to source. Concerns around contamination, odor, flavor transfer, and material integrity require extensive material and organoleptic testing. Some companies have implemented zero-tolerance policies during trials, immediately scrapping materials if contamination risks were identified.  

Cost and supply chain pressures further complicate PCR adoption. PCR materials are often more expensive than virgin materials due to limited supply, growing demand, and increasing regulatory pressure. Engineers noted that while companies are committed to implementing sustainable packaging, they are also searching for opportunities to offset costs through downgauging, packaging reduction, or eliminating unnecessary packaging components. In many cases, incorporating even a small percentage of PCR content is viewed as a positive step forward when higher percentages are not yet technically or financially feasible.


Key Takeaways:

Despite the challenges, engineers continue to view PCR integration as an important part of the packaging industry’s sustainability journey. While PCR may not always provide immediate performance or cost advantages, many teams recognize it as a necessary step toward reducing virgin plastic usage and meeting future regulatory requirements. Success with PCR packaging ultimately depends on strong supplier partnerships, extensive testing, cross-functional collaboration, and a willingness to continuously adapt materials, processes, and packaging designs in pursuit of long-term sustainability goals.

 

About the Author:

Courtney Schutt is a Senior Packaging Engineer at Adept, with 8+ years in CPG and Food & Beverage, specializing in film optimization, cost reduction, commercialization, and package standardization. Courtney is a detail-oriented engineer skilled in leading projects to improve overall packaging performance.