SPC Materials Decision Matrix

What kind of negative environmental impacts can occur during the sourcing and manufacture of this packaging material?

Logging practices can contribute to environmental impacts in the communities from which trees are harvested. Improper harvesting can reduce biodiversity and habitat loss and can have negative impacts on soil and water quality. Because forests are carbon sinks, deforestation contributes to climate change. Land use changes can also displace local and indigenous communities or may impact their use of forests for other purposes. Logging practices may also contribute to global warming impacts.

Pulp manufacturing for packaging may require significant amounts of water which can have negative impacts in water sensitive areas. Pulp and papermaking processes also consume large amounts of energy, which may be derived from non-renewable sources.

Certification organizations such as FSC, SFI, and PEFC consider the US, Canada, and Western Europe as “low risk” for illegal logging or problematic sourcing.

To mitigate these concerns, it is important to source certified and/or verified wood fiber, use recycled fiber and seek out paper suppliers with lower greenhouse gas emissions.

Does this material typically include chemicals of concern? Has this packaging material negatively impacted human health?

Paper based packaging may use adhesives made with formaldehyde or other volatile organic compounds (VOCs), which can off-gas and impact air quality. Water-resistant or grease-proof coatings may include per- and polyfluoroalkyl substances (PFAS), which are persistent in the environment and linked to health issues like cancer and hormone disruption. Finally, some printing inks contain heavy metals or other toxic compounds.

The use of PFAS in fiber-packaging applications has decreased due to voluntary commitments to phasing out the chemical of concern

Companies have made voluntary commitments to phase out PFAS in packaging, and standard setting organizations such as BPI have set limits on the intentionally-added chemicals that may be present in certified compostable packaging, including packaging made with wood fibers. For this reason, products that are certified compostable are likely to have fewer chemicals.

Organizations should work with suppliers on due diligence of their supply chains to identify if fiber packaging is sourced from areas where chemicals of concern, such as PFAS, may still be used. For packaging sourced from the United States, use of these chemicals is less of a concern.

How readily is this material being recycled or composted?

The recoverability of wood fiber can be negatively impacted by coatings, residue, and in some cases, the form. For example, packaging with plastic coatings, wax layers, or aluminum laminations can be rejected during the recycling process because separating the materials is difficult. Grease, food, and product residues can also disrupt recycling processes. Three-dimensional fiber packaging may also be sorted incorrectly at a recycling facility and typically requires further testing and validation to make sure it is getting recycled.

Paper currently makes up the largest percentage of material that is sent to landfill (CalRecycle Public Records Portal).

Wood fiber-based packaging is generally widely collected for recycling, and recyclers can often find end markets for the packaging that is processed.

As a result, in the US, the recycling rate for paper and paperboard is approximately 65-69% (68% according to the EPA), and various fiber packaging is accepted at levels ranging from 5% to 84% of community recycling programs. It is important to acknowledge that even when paper is recycled, its quality degrades over time and thus will continue to require virgin fiber inputs. This in turn can help to create demand for sustainable forestry practices.

In composting programs that allow packaging, uncoated, PFAS-free fiber packaging is commonly accepted along with paper bags, coffee filters, napkins and other paper that has been in contact with food. In the US, recent research indicates that approximately 18% of people have access to collection programs (either through their city or through a private collection partner) that will accept compostable packaging.

While paper and paper-based packaging are currently recovered at a high rate, the amount of paper materials still going to landfill represent a large opportunity for the packaging industry to increase paper recovery.

Brands and package converters may also consider where paper packaging is best recovered based on its application. For some food-contaminated paper packaging, the best recovery option may be composting.

What opportunities and concerns arise when using recycled content for this material?

The collection, transportation, and processing of fiber consumes energy, while water consumption and pollution from mills working with recycled fiber also contribute to the overall environmental footprint. There may also be a need to add additional weight to the package based on the amount of recycled content and the required performance characteristics, possibly impacting the environmental impact of the package overall.

Recycled content can contain chemicals of concern due to contamination from previous uses, additives in the original materials, and chemicals introduced during processing. Some of these chemicals include heavy metals (e.g., lead, cadmium, mercury) from pigments and PFAS, used for grease and water resistance in food packaging. These chemicals in recycled materials can leach into food, beverages, and personal care products, increasing exposure risks. Even low-level exposure to harmful chemicals over time may contribute to endocrine disruption, neurological disorders, and certain cancers.

Early research suggests that consumers do not understand the difference between “recycled content” and “recyclable” claims, and often conflate the two.

Incorporating recycled materials remains a key strategy for reducing the impacts from wood fiber packaging. Using recycled fiber for packaging typically lowers environmental impacts compared to sourcing and manufacturing virgin fiber, since it reduces the need for virgin fiber, lowers energy consumption, and decreases greenhouse gas emissions. Recycling also diverts waste from landfills and reduces pollution.

Packaging made with recycled content can be recycled in the same way and at the same rate as packaging made with virgin materials. However, it is important to remember that most recycled content, including recycled fiber, will degrade in quality over time and will require the input of new virgin materials. It can also be labeled as recyclable, provided it meets the same recoverability criteria as virgin material packaging, including factors such as coatings, product residue, and sortation challenges related to size and shape.

Companies should use on-pack disposal instructions to educate consumers about what to do with the package at end-of-life, especially if they are making on-pack claims about the use of recycled content.

While using recycled content is a step toward sustainability, the packaging industry will need to seek and provide significantly more transparency and disclosure around the chemical makeup of packaging.

Can this product be labeled as recyclable?

Are consumers likely to understand how to dispose of this material correctly?

State laws may impact what formats can be labeled “recyclable”. For example, according to preliminary rulemaking, aseptic or gable top cartons would not be allowed to be labeled “recyclable” under California’s SB 54 Act.

Consumers generally have a high degree of association between fiber-based packaging and recyclability, with 66% believing recycling paper is worth their time. Whether a wood fiber-based package can receive a “widely recyclable” on-pack label such as How2Recycle will depend on various recoverability factors, particularly coatings, adhesives and food residue.

Whether an alternative wood-fiber package can receive a “widely recyclable” on-pack label such as How2Recycle will depend on various recoverability factors, particularly the package’s coatings and the value of the material for reprocessors.

Can this material meet performance requirements such as product protection and barrier properties?

Products that require barrier properties for odor, oxygen or moisture will depend on the package design, manufacturing techniques, and use of additional treatments, such as water-barrier coatings, grease resistance, laminations for oxygen and gas barriers, or plant-based polymers. As mentioned above, these treatments may have a negative effect on a package’s recoverability, and in the case of treatments such as PFAS, on the package’s health profile.

Wood fiber packaging can meet high performance requirements especially related to ultraviolet (UV) protection and strength (e.g. most e-commerce and secondary packaging relies on corrugated containers).

How is this material being treated as part of packaging bills being proposed and passed?

As mentioned above, due to growing concerns over fluorinated chemicals leaching from packaging into food, PFAS bans have passed in some US states, as well as across the EU.

For wood fiber packaging that is designed to be compostable, brands and package converters will need to remain aware of California law AB 1201, which states that a product cannot be labeled “compostable” or “home compostable,” “biodegradable,” “degradable,” or “decomposable” unless it is an allowable agricultural organic input under the requirements of U.S. Department of Agriculture National Organic Program. This requirement is set to be effective June 2027.

Some Extended Producer Responsibility laws are incentivizing paper based packaging through their fee structures, including eco-modulation frameworks within these laws. However, these laws are still in the early stages of being outlined and implemented. Additional package characteristics, such as the weight of paper packaging, may also impact associated fees.

State-level policy is also beginning to outline requirements for levels of recycled content in wood fiber-based packaging. Bans on certain materials (e.g. single use plastic bags or cups) can also increase use of paper based substitutes.

Does extraction or processing of this material place an unequal burden on some communities?

Large-scale forestry operations may degrade traditional lands or displace marginalized communities. Output from mill operations may also negatively impact local or marginalized communities.

Well-managed, sustainable forests can provide local jobs and help maintain cultural ties to forested lands.

Brands and organizations can work with suppliers to ensure fiber materials are sourced from sustainably-managed forests, using certifications like FSC or SFI as markers for sustainable forestry practices.

What kind of negative environmental impacts can occur during the sourcing and manufacture of this packaging material?

Alternative fibers often need to be harvested more frequently and require more fertilizers, herbicides and pesticides which in turn may affect soil and water quality. Alternative fibers may also have a negative impact on biodiversity, since the homogenous structure of alternative fiber crops tends to support a less diverse range of species compared to either natural or plantation based forests. Similarly, there is the risk of forest conversion, where forested ecosystems are converted over to the growth of an alternative fiber and negatively impact local biodiversity. Some, like bamboo and arundo, also have invasive tendencies that can threaten native ecosystems. Looking upstream, differences in the pulping process can result in different environmental impacts between traditional and alternative fibers during manufacturing.

Alternative fibers like bagasse and wheat straw are often assumed to be residues that would otherwise go to waste if not used for products like paper and packaging. By utilizing this “waste”, companies assume they are diverting resources and turning them into a valuable product. In some circumstances, this may be valid, however, it is important to note that agricultural residues are oftentimes not considered waste. Many of these materials have markets outside of paper and packaging into which they can be sold.

Alternative fibers such as bamboo have the potential to sequester more carbon and produce higher biomass yields than managed forests. In some circumstances, the use of alternative fibers may use residue that would otherwise go to waste.

Companies should perform adequate due diligence into their supply chains to mitigate environmental, social, and reputational risk. Suppliers should confirm that alternative fibers are sourced from renewable biomass with sustainability-managed production, that production of the fibers does not destroy critical ecosystems, or that fibers do not result in deforestation or conversion of natural forests.

Does this material typically include chemicals of concern?

Has this packaging material negatively impacted human health?

Fluorinated chemicals, such as PFAS, have historically been used to provide grease and moisture resistance to both wood fiber and alternative fiber food serviceware. These chemicals are persistent in the environment and linked to health issues like cancer and hormone disruption.

The use of PFAS in fiber-packaging applications has decreased due to voluntary commitments to phasing out the chemical of concern

US manufacturers have made voluntary commitments to phase out PFAS in packaging, and standard setting organizations such as BPI have set limits on the intentionally-added chemicals that may be present in certified compostable packaging, including packaging made with non-wood fibers. However, PFAS may still be present in packaging sourced from outside of the US.

How readily is this material being recycled or composted?

Alternative, non-wood fibers may have different recyclability profiles than wood fiber, and not all non-wood fiber packaging is recyclable. Packaging and paper made from non-wood fiber can vary in physical attributes that can impact recyclability, particularly the length of fibers. Shorter, weaker fibers produced during the repulping process may get lost in screening and result in a low fiber yield for the recycled package, ultimately rendering non-recyclable.

Since alternative non-wood fibers tend to externally resemble other (wood fiber) paper packaging, we do not have data on US recycling rates specific to this material. For example, molded fiber foodservice packaging is accepted for recycling in 4% of US community programs, and molded fiber non-food packaging is accepted in 80% of communities. Acceptance rates based on the package format may vary.

In the US, recent research indicates that approximately 18% of people have access to collection programs (either through their city or through a private collection partner) that will accept compostable packaging. Alternative fibers are also used in compostable packaging like food serviceware or paper plates. All of these fibers typically pass compostability testing.

Companies should be prepared to do additional testing to ensure non-wood fiber packaging passes recognized repulpability testing for recycling and additives or chemicals added to the package do not render it unacceptable for composting certification

What opportunities and concerns arise when using recycled content for this material?

Alternative fibers typically do not have recycled content available on the market.

Can this product be labeled as recyclable?

Are consumers likely to understand how to dispose of this material correctly?

The diversity of non-wood fiber physical properties means package formats created using these fibers may require additional additives for coatings, all of which can impact the recyclability profile of the product and, in turn, whether the product can be labeled as recyclable.

State laws may also impact what formats can be labeled “recyclable” – for example, California will not allow molded fiber packaging with plastic components to be considered recyclable. Without on-pack disposal instructions, consumers may interpret the “earthy” look of alternative materials such as molded fiber as an indicator of biodegradability or compostability, and incorrectly dispose of or even litter this type of packaging.

Consumers generally have a high degree of association between fiber-based packaging and recyclability, with 66% believing recycling paper is worth their time.

As with all types of packaging, whether an alternative fiber-based package can receive a “widely recyclable” on-pack label such as How2Recycle will depend on various recoverability factors, particularly the package’s coatings and the value of the material for reprocessors.

Can this material meet performance requirements such as product protection and barrier properties?

Popular alternative fibers like bamboo or bagasse can be shorter or weaker compared to the wood fibers they are intended to replace, and this may limit the applications of the alternative fibers. For example, alternative fibers may work well in a molded fiber product, but not have the strength needed for papermaking. Due to performance and availability reasons, alternative fibers are unlikely to be able to replace wood fiber at scale.

Alternative fibers can provide desirable properties based on their physical and chemical structures, and can also be a valuable supplement for other fiber feedstocks that have become less available or more costly to source.

In cases where sufficient supply of alternative fiber exist, companies should look to alternative fibers that allow for similar production techniques and maintain existing manufacturing equipment.

How is this material being treated as part of packaging bills being proposed and passed?

Fluorinated chemicals leaching from packaging into food, PFAS bans have passed in some US states, as well as across the EU.

For non-wood fiber packaging that is designed to be compostable, brands and package converters will need to remain aware of California law AB 1201, which states that a product cannot be labeled “compostable” or “home compostable,” “biodegradable,” “degradable,” or “decomposable” unless it is an allowable agricultural organic input under the requirements of U.S. Department of Agriculture National Organic Program. This requirement is set to be effective June 2027.

Some Extended Producer Responsibility laws are incentivizing paper based packaging through their fee structures and will likely not differentiate fiber types. However, these laws are still in the early stages of being outlined and implemented.

Does extraction or processing of this material place an unequal burden on some communities?

Large-scale production of alternative fiber sources may lead to land conversion or land degradation, with the potential to negatively impact local or indigenous communities.

A lack of certification programs for non-wood fibers may also make it difficult for organizations to ensure non-wood fibers are sourced from regions with labor and environmental protection programs in place.

Non-wood fibers, particularly those derived from production of other products or commodities (e.g., corn stover), may provide an additional income opportunity for small-scale farmers.

To the extent possible, organizations should look for certifications of sustainable non-wood fiber sourcing (e.g., FSC certification for bamboo). Where sustainable sourcing certifications are not available, organizations should work with suppliers to review supply chains to identify any areas where environmental justice risk may be present.

What kind of negative environmental impacts can occur during the sourcing and manufacture of this packaging material?

The sourcing and manufacturing of aluminum packaging can lead to negative environmental impacts stemming from bauxite mining, the energy-intensive refining process, and the potential for pollution. Bauxite is often found in tropical regions, leading to deforestation, loss of biodiversity, and habitat destruction as land is cleared for mining operations. Mining activities can contaminate water sources with sediment, heavy metals such as lead, cadmium, mercury, and other pollutants, harming aquatic life and impacting human health. Mining operations can also lead to increased erosion and soil degradation and release dust and other pollutants like sulfur dioxide and particulate matter into the air, affecting air quality and potentially contributing to respiratory problems.

The refining of bauxite into alumina produces large quantities of toxic red mud, a residue that can be highly alkaline and contain heavy metals, and this waste requires careful management to prevent environmental contamination. Storing red mud in large tailings ponds carries the risk of leaks or dam failures, leading to catastrophic environmental damage and potential harm to human populations.

Finally, aluminum production is a highly energy-intensive process, requiring significant amounts of electricity, often generated from fossil fuels, contributing to greenhouse gas emissions and climate change. It is also water-intensive, requiring large volumes of water for various stages of the process, potentially impacting water availability in certain regions.

The high level of aluminum recycling, along with the ability to use high amounts of recycled aluminum in packaging, can help to reduce the impact of virgin aluminum production through offset of virgin aluminum use.

Companies should perform adequate due diligence into their supply chains to mitigate environmental, social, and reputational risk.

Companies may look to the use of recycled aluminum to reduce the environmental impact of their packaging.

Does this material typically include chemicals of concern?

Has this packaging material negatively impacted human health?

Aluminum packaging can contain chemicals of concern, particularly Bisphenol A (BPA), phthalates, perfluoroalkyl and polyfluoroalkyl substances (PFAS), and other chemicals. Evidence suggests that these chemicals have negative impacts on human health, especially related to endocrine disruption. BPA has been used as a liner in aluminum cans, particularly for food and beverages, and has been linked to various health issues, including reproductive problems, developmental effects, and potential impacts on the cardiovascular and nervous systems. However, there is a growing trend for BPA-free alternative coatings and there are many brands that have transitioned fully away from BPA. Phthalates are sometimes found in the coatings or linings of aluminum packaging and are also known endocrine disruptors, potentially impacting hormone function and development. PFAS have also been detected in aluminum packaging and are also associated with various health concerns, including immune system disruption, liver damage, and cancer.

While chemicals of concern should be considered when looking at opportunities for using aluminum packaging, studies have shown that phthalates are not currently used in linings for food and beverage cans, or other can components. The aluminum packaging industry is also moving to minimize and eliminate the use of PFAs.

There may be ways to source and design aluminum packaging that does not include chemicals of concern. However, to do this, the packaging industry will need to provide significantly more transparency and disclosure around the chemical makeup of packaging.

How readily is this material being recycled or composted?

This material is not compostable and is not accepted for composting.

Recycling programs accepting non-can aluminum packaging, such as aluminum aerosols, are more limited compared to programs accepting aluminum cans.

In the US, the recycling rate for aluminum cans was approximately 43% in 2023, and the material is accepted in 91% of community recycling programs.

What opportunities and concerns arise when using recycled content for this material?

Recycled aluminum prices may fluctuate with market demand and scrap availability, but recycled aluminum supply is relatively stable due to efficient collection systems and the material’s high scrap value. Sourcing challenges due to supply constraints may exist.

Recycled aluminum is often not used for food contact packaging. Use of recycled content remains a gap and an area of opportunity for brand and converter collaboration.

Using recycled aluminum for packaging significantly lowers environmental impacts compared to sourcing and manufacturing new aluminum, since it reduces the need for virgin materials and decreases greenhouse gas emissions – in fact, recycled aluminum uses approximately 95% less energy than producing virgin aluminum from bauxite ore. For this reason, recycled aluminum is generally cheaper than virgin aluminum, although prices fluctuate with market demand and scrap availability. It is one of the most readily available recycled materials, and the supply is relatively stable due to efficient collection and high scrap value.

While there may be some technical limitations to the amount of recycled content that can be used in aluminium packaging, very high amounts of recycled content can be used. Limitations to the amount of recycled content will generally be determined by supply constraints.

Companies should use on-pack disposal instructions to educate consumers about what to do with the package at end-of-life, especially if they are making on-pack claims about the use of recycled content.

While using recycled content is a step toward sustainability, the packaging industry will need to seek and provide significantly more transparency and disclosure around the chemical makeup of packaging

Identifying areas where recycled content can be used, particularly for food contact aluminum packaging, remains an opportunity.

Can this product be labeled as recyclable?

Are consumers likely to understand how to dispose of this material correctly?

Consumers generally seem to understand that aluminum is recyclable, although whether aluminum packaging can receive a “widely recyclable” on-pack label such as How2Recycle will depend on various recoverability factors, including the presence of aerosol contents.

State laws are also beginning to weigh in on whether aluminum packaging will be considered “recyclable” in the future. In California, several kinds of containers made of “other metals”, including aluminum, with and without plastic components, will be allowed to be considered (and labeled) as recyclable.

Consumers generally seem to understand that aluminum is recyclable, with cans seeing a consumer recycling rate of 43%. State laws are also beginning to weigh in on whether aluminum packaging will be considered “recyclable” in the future. In California, several kinds of containers made of aluminum, with and without plastic components, will be allowed to be considered (and labeled) as recyclable.

Whether aluminum packaging can receive a “widely recyclable” on-pack label such as How2Recycle will depend on various recoverability factors such as the package’s coatings and product residue.

Can this material meet performance requirements such as product protection and barrier properties?

Aluminum provides important performance and barrier properties. While not applicable to some packaging applications, there are generally few cons from a performance standpoint for when using aluminum packaging.

Aluminum is impermeable to light, moisture, gases, and contaminants, making it ideal for protecting sensitive products such as food, pharmaceuticals, and electronics. It naturally forms an oxide layer that helps resist corrosion, extending the shelf life of packaged goods. Despite being lightweight, aluminum can be made strong enough to withstand mechanical stress, protecting products during storage and transportation, and it can be easily shaped into various forms (e.g., cans, foils, pouches) while maintaining its protective qualities. Aluminum also performs well under extreme temperatures, making it suitable for applications like heat-sealed packaging and high-temperature cooking.

How is this material being treated as part of packaging bills being proposed and passed?

Extended Producer Responsibility laws, including eco-modulation frameworks within these laws, are starting to incentivize- through lower fees – aluminum packaging that is recycled at high rates. However, these laws are still in the early stages of being outlined and implemented.

State-level policy is also beginning to outline requirements for levels of recycled content in aluminum packaging.

Does extraction or processing of this material place an unequal burden on some communities?

Bauxite mining, particularly in regions lacking strong labor and environmental protections, can be a cause of land degradation and negatively impact local or marginalized communities. Red mud waste may also contaminate local land and water, negatively impacting local or marginalized communities.

Aluminum’s high recyclability can help offset the environmental justice impacts of raw material extraction by lessening the need for virgin aluminum inputs. The high value of scrap aluminum may also provide an income stream for marginalized communities in areas where informal waste picking occurs.

Organizations and converters should look to use recycled content in aluminum packaging when possible to avoid environmental justice risks associated with material extraction. When virgin aluminum input is needed, organizations should review their material supply chains to identify areas where environmental justice risk may exist.

What kind of negative environmental impacts can occur during the sourcing and manufacture of this packaging material?

During sourcing and raw material extraction, the mining of iron ore causes habitat destruction, soil erosion, and landscape alteration. Coal mining for coke (used in steel production) leads to similar landscape impacts, and both mining operations can contaminate local water sources with heavy metals while also requiring significant water inputs for extraction processes.

During manufacturing, blast furnaces and other production processes consume high amounts of typically non-renewable energy, and release substantial carbon dioxide emissions – steel production accounts for 7-9% of global CO2 emissions. Manufacturing also releases air pollutants including particulate matter, sulfur dioxide, nitrogen oxides, slag and other solid waste byproducts, and water that is polluted from various cooling processes and chemical treatments.

During final processing, there may be additional wastewater containing heavy metals and treatment chemicals, as well as chemical exposure from metalworking fluids and VOC emissions from paints, coatings, and solvents.

The high level of aluminum recycling, along with the use of recycled steel in packaging to the extent possible, can help to reduce the impact of virgin steel production for packaging through offset of virgin steel use.

Companies should perform adequate due diligence into their supply chains to mitigate environmental, social, and reputational risk. Companies may look to the use of recycled steel to reduce the environmental impact of their packaging.

Chemicals and Health Does this material typically include chemicals of concern?

Has this packaging material negatively impacted human health?

Steel cans are produced from tin-coated steel, also called tinplate, or electrolytic chromium-coated steel. Though the toxicity of tin is relatively low, epoxy resins, lacquers, and other internal coatings used to prevent metal leaching are often used. These may contain BPA or similar alternative compounds, which have been linked to various health issues, including reproductive problems, developmental effects, and potential impacts on the cardiovascular and nervous systems. External coatings and printing inks may also contain heavy metals or other chemicals of concern.

While chemicals of concern should be considered when looking at opportunities for using steel packaging, studies have shown that phthalates are not currently used in linings for food and beverage cans, or other can components and the steel packaging industry is moving to minimize and eliminate the use of PFAs. BPA usage in steel cans is now close to being eliminated as well.

Organic can coatings reduce the interactions between the metal and the food. However, many chemicals present in these coatings have been found to migrate into food, for example, oligomers, lubricants, and crosslinkers.

Although tests indicate that 96% of cans are now BPA-free, information about the safety of the alternatives being used is still limited. To counter this, the packaging industry will need to provide significantly more transparency and disclosure around the chemical makeup of packaging.

How readily is this material being recycled or composted?

This material is not compostable and is not accepted for composting.

Recycling programs accepting non-can steel packaging, such as steel aerosols, are more limited compared to programs accepting steel cans.

Steel is highly recyclable. In the US, the recycling rate for steel cans was approximately 58% in 2021, and steel cans are accepted in 88% of community recycling programs. Steel aerosol containers, however, are accepted in only 39% of community recycling programs, likely because of the aerosol contents.

What opportunities and concerns arise when using recycled content for this material?

Recycled steel prices may fluctuate with market demand and scrap availability, but recycled steel supply is relatively stable due to efficient collection systems and the material’s high scrap value. Brands or converters may run into supply issues depending on the intended packaging application.

There are technical challenges that limit the amount of recycled content that can be used to make steel packaging. Recycled steel is often not used for food contact packaging. Use of recycled content remains a gap and an area of opportunity for brand and converter collaboration.

Using recycled steel for packaging typically lowers environmental impacts compared to sourcing and manufacturing virgin material. Recycled steel is generally cheaper than virgin steel because it requires significantly less energy to produce—about 60-74% less energy compared to making new steel from iron ore.

Can this product be labeled as recyclable?

Are consumers likely to understand how to dispose of this material correctly?

Consumers generally seem to understand that steel is recyclable, although whether steel packaging can receive a “widely recyclable” on-pack label such as How2Recycle will depend on various recoverability factors, including the presence of aerosol contents.

State laws are also beginning to weigh in on whether steel packaging will be considered “recyclable” in the future. In California, several kinds of containers made of “other metals”, including steel, with and without plastic components, will be allowed to be considered (and labeled) as recyclable.

Packaging made with recycled steel can be labeled as recyclable, provided it meets the same recoverability criteria as virgin material packaging, including factors such as coatings, product residue, and sortation challenges related to size and shape.

It is important to note that early research suggests that consumers do not understand the difference between “recycled content” and “recyclable” claims, and often conflate the two. Companies should use on-pack disposal instructions to educate consumers about what to do with the package at end-of-life, especially if they are making on-pack claims about the use of recycled content.

Can this material meet performance requirements such as product protection and barrier properties?

Steel packaging may be susceptible to corrosion if barriers are compromised, and as noted has the potential for metal-product interactions without proper linings.

Steel packaging provides excellent performance characteristics, particularly for product protection and barrier properties. It prevents UV degradation of sensitive products and allows for sterilization processes like retorting while significantly extending the shelf life of food products. Its high mechanical strength resists impacts, crushing, and punctures, maintains structural integrity during transportation and storage, and is resistant to temperature extremes without losing integrity.

How is this material being treated as part of packaging bills being proposed and passed?

Extended Producer Responsibility laws, including eco-modulation frameworks within these laws, are starting to incentivize- through lower fees – metal packaging, including steel, that is recycled at high rates. However, these laws are still in the early stages of being outlined and implemented.

State-level policy is also beginning to outline requirements for levels of recycled content in steel packaging.

Does extraction or processing of this material place an unequal burden on some communities?

Mining operations, particularly in regions lacking strong labor and environmental protections, can be a cause for land degradation and negatively impact local or marginalized communities. Steel production may also emit pollutants that may impact local communities.

Steel’s high recyclability can help offset the environmental justice impacts of raw material extraction by lessening the need for virgin steel inputs, although steel packaging is technically limited in the amount of recycled content that can be used.

The high value of scrap steel may also provide an income stream for marginalized communities in areas where informal waste picking occurs.

Organizations and converters should look to use recycled content in steel packaging when possible to avoid environmental justice risks associated with material extraction. When virgin steel input is needed, organizations should review their material supply chains to identify areas where environmental justice risk may exist.

What kind of negative environmental impacts can occur during the sourcing and manufacture of this packaging material?

The sourcing and manufacturing of glass packaging can lead to negative environmental impacts stemming from high energy consumption and raw materials extraction. Glass production requires extremely high temperatures (around 1,700°C) to melt raw materials like sand, soda ash, and limestone. This process is energy-intensive, often relying on fossil fuels like natural gas, which leads to significant greenhouse gas emissions (primarily carbon dioxide) contributing to climate change. The glass industry’s reliance on fossil fuels for heating furnaces and powering manufacturing processes contributes to air pollution and greenhouse gas emissions, impacting air quality and exacerbating climate change. Glass manufacturing also requires substantial amounts of water for cooling, processing, and cleaning, which can put a strain on water resources, particularly in water-scarce regions.

Sand, a key ingredient in glass, is extracted from natural sources like riverbeds and seabeds, and this extraction can lead to habitat destruction, erosion, and disruption of coastal ecosystems. The mining of silica, another crucial component of glass, can release dust containing crystalline silica, a hazardous substance that can cause silicosis, a serious lung disease. The extraction of other raw materials like limestone and soda ash also carries environmental risks, including habitat destruction, water pollution, and potential release of pollutants during mining and transportation.

The weight of glass (which is significantly heavier than paper or plastic) also requires more fuel for transportation, leading to a larger carbon footprint associated with moving glass packaging.

As glass does not lose performance quality through the recycling process, the use of recycled glass in packaging can reduce the impact of virgin glass production by offsetting the use of virgin glass.

Companies should perform adequate due diligence into their supply chains to mitigate environmental, social, and reputational risk.

Companies may look to the use of recycled glass to reduce the environmental impact of their packaging. Organizations may look at dark glass colors for packaging applications, which may allow for higher levels of recycled content to be used

Does this material typically include chemicals of concern?

Has this packaging material negatively impacted human health?

While glass itself is inert, there are rare instances where contamination can occur. For example, some older or low-quality glass products might contain lead or cadmium, which can leach into food or drinks. However, these instances are not common in modern food packaging. Some studies have found chemical contamination in food packaged in glass jars, but this is often due to the materials used to seal the metal lids, not the glass itself.

Glass packaging does not typically include chemicals of concern. Glass itself is an inert material, meaning it doesn’t react with the food or beverage it contains, preventing the migration of harmful substances into the product.

How readily is this material being recycled or composted?

There have been some swings in community acceptance of glass over the past several decades, and broken or damaged glass is generally not accepted in recycling programs.

End markets for glass collected via curbside, single-stream recycling programs may be limited due to the mix of glass product generated via MRF sorting operations and contamination from other materials.

This material is not compostable and is not accepted for composting.

In the US, the recycling rate for glass was 25% in 2018, and glass bottles and jars are accepted in 72% of community recycling programs.

While glass-to-glass end markets may be limited for MRF-bound glass, research has shown that glass generated from MRF sortation can be and is used as an alternate daily cover for landfills, offsetting the need to use other materials for this application.

What opportunities and concerns arise when using recycled content for this material?

Recycled glass can be heavy and expensive to transport. Contamination in recycled content from mixed colors or food residue can limit its use in high-quality applications, and in some areas, glass recycling infrastructure is less developed, making supply inconsistent.

It is more difficult to use recycled content in flint (clear) glass due to coloration issues recycled glass content can cause.

Using recycled glass (cullet) for packaging generally lowers environmental impacts compared to sourcing and manufacturing virgin materials. It reduces the need for virgin material extraction, lowers energy consumption, and decreases greenhouse gas emissions. Recycling also diverts waste from landfills and reduces pollution.

Brands and organizations may look to use darker glass colors that allow for easier incorporation of recycled glass content.

Companies should use on-pack disposal instructions to educate consumers about what to do with the package at end-of-life, especially if they are making on-pack claims about the use of recycled content.

While using recycled content is a step toward sustainability, the packaging industry will need to seek and provide significantly more transparency and disclosure around the chemical makeup of packaging.

Can this product be labeled as recyclable?

Are consumers likely to understand how to dispose of this material correctly?

State laws are also beginning to weigh in on whether glass packaging will be considered “recyclable” in the future. In California, some types of glass will not be considered recyclable.

Consumers generally seem to understand that glass packaging is recyclable, with 90% of consumers expecting to recycle glass according to 2020 research. Whether glass packaging can receive a “widely recyclable” on-pack label such as How2Recycle will depend on various recoverability factors, including any product residue and sortation due to its size and shape.

State laws are also beginning to weigh in on whether glass packaging will be considered “recyclable” in the future. In California, glass bottles and jars with and without plastic components and glass with two or more sides measuring less than 2 inches with and without plastic components, will be considered recyclable.

Whether glass packaging can receive a “widely recyclable” on-pack label such as How2Recycle will depend on various recoverability factors such as the package’s coatings and product residue.

Can this material meet performance requirements such as product protection and barrier properties?

The weight and fragility of glass can be drawbacks compared to alternative packaging materials like plastics or metals.

Glass meets packaging performance requirements, particularly where product purity and long shelf life are priorities. Since glass is chemically inert, it will prevent contamination and maintain product quality. It also provides a 100% barrier against gases (oxygen, carbon dioxide, etc.) and moisture, unlike plastics and some metals that may have permeability issues. It can also protect against UV light (especially amber-colored glass), which is crucial for sensitive products like pharmaceuticals, food, and beverages. Finally, because it can withstand extreme temperatures, glass is suitable for sterilization and pasteurization processes.

How is this material being treated as part of packaging bills being proposed and passed?

State-level Extended Producer Responsibility laws are still in the early stages of being outlined and implemented. State-level policy is also beginning to outline requirements for levels of recycled content in glass packaging.

Extended Producer Responsibility laws, including eco-modulation frameworks within these laws, are starting to incentivize- through lower fees – glass packaging that is recycled at high rates. In Oregon and Colorado, the proposed base fees for glass packaging are lower than for many other types of materials.

Does extraction or processing of this material place an unequal burden on some communities?

Sand mining operations, particularly in regions lacking strong labor and environmental protections, can be a cause for land degradation and negatively impact local or marginalized communities.

As glass performance does not degrade through the recycling process, robust glass recycling programs can help offset the environmental justice risks associated with sand mining by lessening the need for virgin class inputs.

Organizations and converters should look to use recycled content in glass packaging when possible to avoid environmental justice risks associated with material extraction. Using darker glass colors may allow for easier incorporation of recycled content.

When virgin glass input is needed, organizations should review their material supply chains to identify areas where environmental justice risk may exist.

What kind of negative environmental impacts can occur during the sourcing and manufacture of this packaging material?

Using virgin plastic for packaging contributes to environmental degradation through fossil fuel extraction, high energy consumption, greenhouse gas emissions, and pollution from chemical byproducts. Extracting and refining petroleum or natural gas for plastic production depletes non-renewable resources and disrupts ecosystems. The manufacturing process releases harmful air pollutants and wastewater contaminants, posing risks to human health and biodiversity.

Additionally, the carbon footprint of virgin plastic production accelerates climate change, further exacerbating environmental challenges. Studies have shown that continuing to extract virgin plastic under a “business as usual” scenario will lead to a substantial increase in mismanaged plastics and GHG emissions.

While there has been recent work on building new datasets, LCA may not be able to account for several important environmental and social externalities, such as the effects of packaging turning into litter or microplastics.

Virgin plastic often performs well on some environmental metrics based on available LCA data and due to attributes like its low weight. For example, LCA calculations can show flexible plastic, to have a lower carbon footprint than other materials because it is lightweight.

Highly streamlined production and distribution of plastic packaging can also result in lower environmental impacts associated with manufacturing compared to other materials. For example, the ability to have rolls of plastic shipped can significantly reduce the environmental footprint of moving packaging from the producer to the packager.

Companies should perform adequate due diligence into their supply chains to mitigate environmental, social, and reputational risk.

Companies may look to the use of recycled plastic to reduce the environmental impact of their packaging.

Does this material typically include chemicals of concern?

Has this packaging material negatively impacted human health?

Plastic as a material is known to be harmful to human health. The extraction and manufacturing phases create and release chemicals, additives, and pollutants, often in vulnerable, frontline communities. During the use phase, plastics can transfer harmful chemicals into food, water, and packaged products, and these chemicals can be readily absorbed into the human body (Journal of Exposure Science & Environmental Epidemiology, Plastic Health Map).

Recent research indicates that packaging can release microplastics into food and into the body. The long-term effects of this are still unknown. Preliminary human cell and animal studies indicate reproductive effects, inflammation, cell death, lung and liver effects, changes in the gut microbiome, and altered lipid and hormone metabolism.

Plastic is a relatively inert material, meaning the opportunity for the plastic to support something like microbial growth is relatively low.

More transparency around what chemicals are present in both virgin and recycled plastic is needed. There may be ways to use plastic more safely, and to choose certain families of polymers over others based on how they perform in terms of migration of chemicals or disintegration into microplastics. However, to do this, the packaging industry will need to provide significantly more transparency and disclosure around the chemical makeup of packaging.

How readily is this material being recycled or composted?

In the US, the recycling rate for plastics ranges from 9% in 2018, according to the EPA, to 13.3% in 2023, according to the U.S. Plastics Pact, although some plastic resins like PET and HDPE have recycling rates around 21%. The entire recycling value chain for plastic – including collection, sortation, reprocessing, and end-markets for recycled materials – is challenged by virgin plastic. Virgin resin is abundant, cheaper than recycled content, and suitable for a wide range of specifications and applications. This makes it difficult for recycled content, and recycling as an industry, to compete with virgin resin.

Flexible plastic packaging (used for consumer-facing packaging in particular) is not getting recycled at scale, through either mechanical or chemical recycling technologies. While sortation and reprocessing capabilities will continue to evolve over time and will be important for handling the plastic waste already in the market today, it is also important to acknowledge that even when plastic is mechanically recycled, its quality degrades over time and thus will continue to require significant virgin inputs. Even under theoretical, best-case assumptions, plastic recycling alone cannot be a fully closed-loop system.

Macroplastics and microplastics are now ubiquitous in the environment. Macroplastic litter is typically defined as plastic pieces that are larger than 5 millimeters, and can break down into microplastics over time. Packaging is a key contributor to these types of litter, although it is not the only source of microplastics in the environment, the other notable source being textiles and fibers. However, within the current recovery system it is inevitable that plastic packaging will escape into the environment and contribute to the microplastics problem. The lack of circularity of plastics, both in the industrialized United States as well as the global South (areas of Latin America, Asia, Africa, and Oceania that are considered less economically developed), often involves open burning, dumping, and the release of pollutants into the air and leachate into local waterways. These management strategies also contribute to the release of microplastics into the air, water, soil, and other living organisms.

Recycling of virgin plastic packaging can help divert plastic materials from landfill or leakage to the environment and reduce the environmental impacts associated with fossil fuel extraction.

Recycling rates for specific plastic formats, such as PET and HDPE bottles, remain high compared to other plastic types and formats due to effective recycling systems and strong end markets.

According to TRP state of recycling report – HDPE has a capture rate of 59% – 93% capture rate in MRFs.

High variability in the recycling rates for plastics based on resin type or format indicate a need for more robust collection programs and sortation for plastics to be recycled at a high rate. Organizations may look to industry collaborations working on plastics sortation to support development of these programs and technologies.

Systems like store drop-off programs for PE films remain a significant opportunity for additional recovery of flexibles, but will require consumer education to ensure programs are effective.

What opportunities and concerns arise when using recycled content for this material?

The plastic recycling process degrades quality over time, necessitating the addition of virgin material, and chemical recycling methods may involve hazardous substances and high energy use, potentially offsetting environmental benefits. Water consumption and pollution from washing and reprocessing recycled materials also contribute to the overall environmental footprint.

Recycled content can contain chemicals of concern due to contamination from previous uses, additives in the original materials, and chemicals introduced during processing. Some of these chemicals include phthalates, which are used as plasticizers in some plastics, bisphenols (e.g., BPA, BPS), which are found in certain plastics and coatings, heavy metals (e.g., lead, cadmium, mercury) from pigments, stabilizers, or contamination from older plastic sources, and PFAS, used for grease and water resistance in food packaging. These chemicals in recycled materials can leach into food, beverages, and personal care products, increasing exposure risks. Even low-level exposure to harmful chemicals over time may contribute to endocrine disruption, neurological disorders, and certain cancers.

Some recycled plastics may have reduced strength, clarity, or barrier properties due to degradation during the recycling process. To compensate, manufacturers may blend recycled content with virgin material, apply functional coatings, or use multi-layer packaging designs to enhance durability, moisture resistance, and oxygen barriers. These coatings or layers may negatively impact the package’s recyclability.

Recycled plastic is often more expensive than virgin plastic due to sorting, cleaning, and processing challenges. Prices fluctuate based on supply, demand, and oil prices. rPET (recycled PET, typically used in bottles) is 20-50% more expensive than virgin PET due to strong demand and limited supply. rHDPE (recycled high-density polyethylene, typically used in containers) is typically more expensive than virgin HDPE, but prices vary by region. rPP (recycled polypropylene) is often costly and less available due to lower recycling rates. Recycled plastic supply can be unreliable, especially for food-grade applications. Contamination, inconsistent collection, and the need for advanced processing limit the availability of high-quality PCR.

Using recycled content for packaging typically lowers environmental impacts compared to sourcing and manufacturing virgin fiber, since it reduces the need for virgin resin, lowers energy consumption, and decreases greenhouse gas emissions. Recycling companies can receive a “No Objection Letter”, which indicates that the FDA has reviewed their recycling process and determined that it currently has “no questions” regarding the suitability of the recycling process to sufficiently remove unwanted contaminants. However, this is not an “approval” or a guarantee of material health.

Recycled content can meet performance requirements such as product protection and barrier properties, but its effectiveness depends on the type of material, processing methods, and intended application. Advances in recycling technologies, including mechanical and chemical recycling, have improved the quality and consistency of recycled materials, allowing them to perform similarly to virgin materials in many cases.

Packaging made with recycled content can be labeled as recyclable, provided it meets the same recoverability criteria as virgin material packaging, including factors such as coatings, product residue, and sortation challenges related to size and shape.
Advances in technology are allowing for increased amounts of recycled content in plastics, including for food contact plastics.

Increased cost competitiveness of recycled plastic vs. virgin plastic can help justify its use, but issues of supply for particular resins may still be an issue. Development of more effective collection and recycling systems for plastic packaging can help to increase supply and potential support more cost effective recycled plastics.

Organizations may also look at chain of custody programs, such as the Recycled Material Standard, for assurances in their recycled plastic supply chains

While using recycled content is a step toward sustainability, the packaging industry will need to seek and provide significantly more transparency and disclosure around the chemical makeup of packaging.

Can this product be labeled as recyclable?

Are consumers likely to understand how to dispose of this material correctly?

State laws are changing what type of plastic packaging will be considered “recyclable” in the future. For example, California only allows PET, HDPE, and PP bottles, jugs, and other rigid plastics to be considered (and labeled) as recyclable. All other types of plastic will not be allowed to be labeled or marketed as recyclable. The European Union’s PPWR has similar implications for local markets. Without the possibility of being considered “recyclable”, this material is losing its social license to operate. In all cases, it is important to embrace transparency by adding on-pack disposal instructions that help consumers understand this fact and correctly dispose of it in the garbage, rather than the recycling. This is especially true for plastic packaging because of the confusion among consumers around what types of plastic resins and formats are recyclable.

Packaging made with recycled content can be labeled as recyclable, provided it meets the same recoverability criteria as virgin material packaging, including factors such as coatings, product residue, and sortation challenges related to size and shape.

Whether plastic packaging can receive a “widely recyclable” on-pack label such as How2Recycle will depend on various recoverability factors such as the package’s coatings and the value of the material for reprocessors.

It is important to note that early research suggests that consumers do not understand the difference between “recycled content” and “recyclable” claims, and often conflate the two. Companies should use on-pack disposal instructions to educate consumers about what to do with the package at end-of-life, especially if they are making on-pack claims about the use of recycled content.

Can this material meet performance requirements such as product protection and barrier properties?

The ability of plastic to be designed to meet required performance and barrier properties means there are few cons to plastic usage from a performance standpoint.

Virgin plastic has historically offered important barrier and performance properties and food waste-prevention applications, and these properties are not always available in recycled materials or bio-based alternatives.

While plastic packaging can be designed to meet the performance and barrier needs to various products, brands and organizations can work with suppliers to design plastic packaging that both meets product needs while allowing for easier recovery or lower environmental footprint. Strategies like lightweight or the use of mono-materials can improve the sustainability profile of plastic packaging.

How is this material being treated as part of packaging bills being proposed and passed?

Extended Producer Responsibility laws, including eco-modulation frameworks within these laws, are starting to disincentivize – through higher fees – virgin fossil-derived, non-recyclable plastics. In Colorado, the proposed base fees for plastic packaging are higher than for other types of materials, however, all of these laws are still in the early stages of being outlined and implemented. California’s extended producer responsibility legislation (SB 54) will prevent companies from selling plastic packaging that is not recycled at high rates.

Recycled content is a key focus in many packaging bills being proposed and passed at the state, national, and international level. These policies aim to increase the use of post-consumer recycled (PCR) content, reduce reliance on virgin materials, and improve recycling infrastructure. For example, recycled content mandates require minimum percentages of recycled content in specific packaging types, particularly for plastic beverage bottles, food containers, and other consumer packaging. These include California’s SB 270 and AB 793, which mandate increasing levels of recycled content in plastic beverage bottles, aiming for 50% by 2030, and Washington’s SB 5022, which requires post-consumer recycled content in certain plastic products, including bottles and trash bags.

Extended Producer Responsibility fees for plastic packaging will ultimately be highly variable for plastic packaging based on the specific polymer, the format, and the ease of recovery. The laws, including their eco-modulation frameworks, will start to incentivize – through lower fees – plastic packaging formats that are recycled at higher rates.

Working with producer responsibility organizations, such as the Circular Action Alliance in the United States, will help brands and organizations better understand the eco-modulation fees associated with various plastic packaging formats.

Does extraction or processing of this material place an unequal burden on some communities?

Research has shown that communities located near fossil fuel extraction sites, often made up of marginalized groups, often experience negative health outcomes.

Plastics collected for recycling that are not properly managed may find their way into marginalized communities, often located in the global south, where they can cause macro pollution issues, degrading local environments and impacting both the health and livelihoods of local communities.

In regions where informal waste picking occurs, plastics may provide an income stream for marginalized communities.

The use of recycled plastics can help to offset the environmental justice risks associated with fossil fuel extraction and mismanagement of plastics collected for recycling. Brands and organizations should work with their suppliers and collaborate to develop and support robust, local recycling programs for plastics, particularly formats that are not currently recycled at a high level or those that are more likely to be mismanaged.

What kind of negative environmental impacts can occur during the sourcing and manufacture of this packaging material?

Typically, one of the biggest impact categories for bioplastics is around water use and fertilizer requirements, since growing crops for bioplastics requires large amounts of water and may contribute to water scarcity in certain regions. These crops rely on synthetic fertilizers and pesticides, which can lead to soil degradation, water pollution, and eutrophication (excess nutrients in water bodies causing algal blooms and dead zones). There is also the risk of deforestation or loss of biodiversity if land is reallocated towards bioplastics production.

A common concern around bio-based bioplastics is whether the feedstocks are in competition with land used for feeding the global population, and whether using feedstocks like corn for bioplastics diverts nutrients away from people. However, global data indicates that bioplastics use 0.03% of total arable land, which indicates that there is no risk of competition between the use of biomass to produce bioplastics and its use for food and feed.

The use of bioplastics can offset the use of virgin plastic , which can reduce dependence on fossil fuels as a material feedstock

The term “bioplastic” includes any plastic that is bio-based, any plastic that is biodegradable, or any plastic that possesses both characteristics. Because of the wide range of materials included in this term, their impacts will vary depending on the specific feedstock sourced, and the end-of-life they are designed for.

Does this material typically include chemicals of concern?

Has this packaging material negatively impacted human health?

Bioplastics, like traditional plastics, typically contain additives to enhance their performance properties, such as flexibility, durability, and heat resistance. These additives may include phthalates, bisphenol A (BPA), and other chemicals, which have been linked to health issues like endocrine disruption, reproductive problems, and developmental effects. For this reason, bioplastics are likely to have the same toxicity profile as conventional plastics.

If bioplastics are littered, they can break down into microplastics in ways that are similar to traditional fossil-derived plastics. These microplastics can enter the environment and potentially contaminate food and water sources, while also leaching any additives that they contain into the environment.

There may be ways to choose certain families of polymers over others based on how they perform in terms of migration of chemicals. However, to do this, the packaging industry will need to provide significantly more transparency and disclosure around the chemical makeup of packaging.

How readily is this material being recycled or composted?

Biodegradable bioplastics can also be composted, though this depends on the availability of composting infrastructure. In the US, recent research indicates that approximately 18% of people have access to collection programs (either through their city or through a private collection partner) that will accept some form of compostable packaging.

While not all bioplastics are recyclable, some bioplastics can be recyclable – specifically, those known as “drop-in” bioplastics, which are the bio-based versions of the conventional, non-biodegradable plastics commonly used in the packaging industry, such as bio-based polyethylene terephthalate (bio-PET). These materials sort the same on optical scanners and behave the same way in float/sink tests and during the remelt process. Bio-PET is as recyclable as conventional PET, and is currently being used as recycled content in the rPET market. Because of their identical nature to their fossil-derived counterparts, there are no recycling rates specific to drop-in bioplastics.

What opportunities and concerns arise when using recycled content for this material?

Bioplastics typically do not have recycled content available on the market.

Can this product be labeled as recyclable?

Are consumers likely to understand how to dispose of this material correctly?

Packaging made from bioplastics needs to be carefully labeled so that consumers dispose of it correctly. Studies have shown that consumers find “bio” claims to be particularly confusing, and do not understand the difference between bio-based, biodegradable, and compostable. This means that there is an increased chance of contamination, with recyclable drop-in bioplastics ending up in composting bins if they contain too much messaging about biobased content, and compostable bioplastics ending up in the recycling if they are not clearly labeled as compostable.

Packaging made using drop-in bioplastics can pursue recyclability labeling, and whether it is considered “Widely Recyclable” will depend on various recoverability factors, such as product residue and the value of the material for reprocessors. State laws may also impact what formats can be labeled “recyclable” – for example, California will not allow plastics designed for composting to be considered recyclable.

For compostable bioplastics, laws in states like Washington and Colorado require packaging to have additional visual markings, such as green stripes, colors, bands, and certification marks, in order to reduce consumer confusion and clearly differentiate these items from their lookalike, non-compostable counterparts.

Can this material meet performance requirements such as product protection and barrier properties?

Bioplastics can meet various performance requirements, but their effectiveness will depend on the specific type of bioplastic and the intended application, since feedstocks vary in their ability to provide moisture, oxygen, and UV light barriers. For example, PLA offers moderate oxygen barrier properties but has relatively high permeability to moisture. PHA shows good barrier properties against oxygen and UV light but can be sensitive to moisture, and starch-based bioplastics generally have poor moisture barrier properties but can be blended with other materials to improve performance. These are general performance characteristics, and can be enhanced with specific technologies or innovations based on the requirements.

As mentioned, because bio-PE is chemically identical to PE, it has similar barrier properties to conventional polyethylene, making it suitable for the same types of packaging applications.

How is this material being treated as part of packaging bills being proposed and passed?

For bioplastic packaging that is designed to be compostable, brands and package converters will need to remain aware of California law AB 1201, which states that a product cannot be labeled “compostable” or “home compostable,” “biodegradable,” “degradable,” or “decomposable” unless it is an allowable agricultural organic input under the requirements of U.S. Department of Agriculture National Organic Program. This requirement is set to be effective June 2027

While Extended Producer Responsibility laws do not have specific language related to bioplastics, many states stipulate incentives for the use of renewable resources. In Oregon, a producer’s choice of material is a consideration that will lead to changes in eco-modulated fees. This means producers would not be incentivized, through lower fees, if they use bioplastics. The exception is around bioplastics that are used for certified compostable packaging. Proposed eco-modulation fees for compostable packaging (including compostable bioplastics) may be lower than for virgin fossil-derived plastic packaging, however, state laws are still in the early stages of being outlined and implemented.

Does extraction or processing of this material place an unequal burden on some communities?

Large-scale production of crops or other bioplastic feedstocks may lead to land conversion or land degradation, with the potential to negatively impact local or indigenous communities. Shifting the use of crops from food use to bioplastic use may also create food security risks for marginalized communities.

Bioplastic feedstocks may present a new market opportunity for small-scale farmers.

To the extent possible, organizations should look for sustainable sourcing certifications for bioplastic feedstocks, particularly in regions that lack strong labor or environmental protections.

Where sustainable sourcing certifications are not available, organizations should work with suppliers to review supply chains to identify any areas where environmental justice risk may be present.