California’s extended producer responsibility (EPR) law for packaging might be forcing a consequential overhaul of the U.S. recycling system.
Known formally as SB 54, the law requires that by 2032 all packaging sold in the state be recyclable or compostable and that 65% of all packaging materials be recycled. Producers (brand owners and CPGs) will bear the cost and responsibility for meeting those targets. Materials that fail to meet performance thresholds may eventually face restrictions or penalties under CalRecycle rulemaking.
For brands and CPGs who package products in flexibles, the potential of losing footing in the California market seems existential. Films and pouches have long been prized for efficiency and source reduction, but lag in ease of recyclability. The structures are lightweight, often multilayered, and are hard to capture in municipal collection systems or material recovery facilities (MRFs). Flexible films can wrap around rotating screens, augers, and shafts in MRFs, gumming up the works. Or worse, they're prone to contaminate paper streams at MRFs that don't employ a burdensome secondary sortation (most currently don't), since flexibles often present as flat and two-dimensional, like paper rather than three-dimensional containers. California’s deadlines have put film recycling front and center, turning what was once a technical challenge (and in the case of multi-material substrates, a reprocessing impracticality), into an economic and regulatory necessity.
At today's FPA Flex Forward 2025 panel discussion on the future of flexible packaging recycling in California, leaders from across the value chain agreed that the industry’s response will depend on a systemic overhaul. The conversation, moderated by Kyla Fisher of the Flexible Packaging Association (FPA), included voices from producer responsibility, system design, and recycling operations perspectives: Neil Menezes of the Circular Action Alliance (CAA), Danielle Easdale of The Recycling Partnership (TRP), Anne Johnson of the newly introduced U.S. Flexible Film Initiative (USFFI-- and also Resource Recycling Systems, or RRS as her "day job"), and Susan Robinson, formerly of WM, now consulting. Their collective message is that flexible packaging recycling will rise or fall on end-market demand, design of both systems and packages, and collaboration through the circular value chain.
(from left) Kyla Fisher of the Flexible Packaging Association (FPA), Neil Menezes of the Circular Action Alliance (CAA), Danielle Easdale of The Recycling Partnership (TRP), Anne Johnson of the newly introduced U.S. Flexible Film Initiative (USFFI-- and also Resource Recycling Systems, or RRS as her "day job"), and Susan Robinson, formerly of WM, now consulting.FPA
Circularity and the role of 'downcycling'
Everyone agrees that the ultimate goal is circularity, or turning film back into film, bottles back into bottles, etc. But panelists emphasized that durable applications will be critical interim markets.
Products without the need for food-grade purity or appealing transparency, like decking, roofing membranes, and railroad ties, can absorb mixed or contaminated film that mechanical recycling cannot yet handle. These applications, while sometimes dismissed as “downcycling,” are building the bridge to circular systems.
“The highest and best use should always be the goal,” said Danielle Easdale of The Recycling Partnership. “But there’s a place for these durables too—products that can take material that either has higher contamination or mixed structures.”
The only problem is that durable markets aren’t limitless. Plastic's own longevity, usually a perk, is its enemy in this case.
“There are only so many benches and decks you can make,” said Menezes “At some point you saturate the market, and you have to look to the next demand to keep that cycle going.”
But PET bottles were recycled into textiles for decades before bottle-to-bottle systems matured, Robinson said.
“And if we hadn’t had those lower-cost markets, we might not be recycling some of the plastics we are today,” she said. So durable outlets create the early demand signals that allow higher-value systems to develop, she argued.
Anne Johnson of RRS pointed to roofing membranes as an example of a large, consistent, and under-appreciated opportunity. These construction products, she said, “can pull material through the system continuously,” providing long-term, high-volume demand. Large commercial markets such as roofing, decking, and asphalt modification also help build the processing capacity that packaging-to-packaging recycling will need later.
Advanced recycling is a promising but still controversial technology that has a ways to go, both in infrastructure and in standing. The 25 states that deem it a manufacturing process will be fine using it in a waiting food-contact packaging market. But some states consider it a waste management process, and material classified as waste is conceptually ill-suited for food-contact packaging. Johnson noted that non-mechanical/chemical recycling will likely play a role as EPR ramps up. It can handle complex, multilayered films that mechanical recyclers cannot, though the economics and environmental accounting remain under debate. “We’ll need all of it,” she said, “because the system isn’t monolithic, and neither are the materials.”
Most flexible film never makes it to recycling. As Kyla Fisher noted in opening the discussion, curbside programs collect only a fraction of film packaging compared to store take-back and commercial recovery. The chart shows that 11 times more film is recycled via retail drop-off than curbside, and over three-and-a-half times more commercial film is recovered than post-consumer film. Fisher used this data to underscore the system’s starting point: film collection remains largely outside municipal infrastructure.FPA
Many flexibles, not one flexible
Few materials present as much diversity, or as much confusion, as flexible films. They were designed that way; multilayer or multi-material substrates are often honed into a tight spec for a specific packaging application. Polyethylene, polypropylene, PET laminations, metallized structures, and barrier-coated films each behave differently at end of life on their own. Complicating that, they are often co-extruded or laminated together with other materials like aluminum, EVOH, or tie layers, plus inks and adhesives. That diversity complicates everything from consumer labeling to EPR fee structures.
“There’s this balance we need to provide,” Menezes said. “Producers understand the differences between PE, PP, and PET laminations. Consumers and legislators don’t. To them, it’s just plastic.”
He argued for dual communication tracks: one technical, for producers designing packaging; and one simplified, for consumers and policymakers making decisions about what’s “recyclable.”
Meanwhile, recyclers, reprocessors, and end markets face a quality challenge.
“Clean, dry, homogeneous. Those three words define recyclability,” Robinson said. “Residential film is none of those things.”
Food residue, moisture, and mixed resins drive up processing costs and lower bale value. “If we’re solving for the lowest common denominator, we need every tool we’ve got,” she said.
Anne Johnson urged regulators to keep all recovery pathways (like non-mechanical recycling) open. “You can’t take tools out of the toolbox,” she said.
The U.S. market is already losing mechanical film recycling capacity because virgin resin remains cheaper and cleaner.
“We’re seeing facilities close weekly in Europe because recycled material can’t compete with virgin pricing,” she said. “In that context, the U.S. needs mechanical, composite, and chemical recovery options operating side by side.”
At the same time, USFFI is trying to bring structure to the problem. The group, launched under a contract awarded to Johnson’s RRS, is brand-led but increasingly includes converters. It's mapping California’s collection and processing infrastructure to match materials with feasible end markets. Johnson called it “an experiment in practical circularity” and said early pilot projects are helping define what’s actually achievable under EPR timelines.
End markets as the linchpin
Without stable buyers, collection becomes an expensive exercise in logistics, and maybe, financial futility. “Without end-market demand, you don’t have recycling—you have collection,” Easdale said.
The economics remain daunting. Robinson estimated that processing curbside film costs two to three times more than purchasing virgin resin.
“Most manufacturers won’t bear that additional cost unless we bridge the gap with economic levers like EPR fees or incentives,” she said. Commodity volatility worsens the problem: when virgin prices drop, demand for recycled film evaporates.
Menezes described CAA’s approach as market-first. The PRO’s mandate under EPR is not just to build collection systems but to make sure they’re economically viable.
Menezes warned that collecting film before end markets exist risks landfill outcomes and public backlash under EPR. He imagined the media scrutiny if an RFID-tagged pouch were tracked through the system only to end up in landfill as “an absolute disaster,” as he put it.
To avoid that scenario, the U.S. Flexible Film Initiative is coordinating or funding pilot projects to cover the extra costs of sorting and reclamation. Johnson called the approach “recovery-agnostic.” Whether film is mechanically recycled, chemically converted, or compounded into durable goods, the goal is to “prove end-to-end viability at scale.”
Easdale added that TRP’s role is to map those value chains—identifying where collection, sortation, and end markets align or fail.
“We’re working to show the flow of material through the system,” she said, “and where intervention delivers the biggest impact.”
Panelists agreed that demand creation ultimately rests with brand owners. Procurement commitments for post-consumer recycled content will determine whether new markets take hold. As Robinson put it, “Stable markets build stable recycling systems. Without them, nothing sticks.”
Design for recyclability
Redesigning for recyclability means simplifying structures, reducing inks, and shifting toward mono-material formats, particularly polyethylene. Easdale called it “the starting point for everything.” When companies consolidate material types, she said, “sortation improves, bale quality improves, and markets start to see predictable feedstock.”
Innovation can and should come from suppliers. “Brands sell products, not plastic,” Menezes said. “They’ll look to converters and material suppliers for solutions that align with EPR goals and recycled-content requirements.” He added that California’s 60% recycling target by 2032 will push design faster than most realize: “Even Europe, after 30 years of EPR, is at about 25% for plastics. Getting to 60% in less than a decade is going to take fundamental redesign.”
Robinson noted that simplification consistently outperforms technological fixes.
“I’ve been watching new ‘miracle’ recycling technologies for 15 years,” she said. “Every time, the definition of ‘mixed material’ they can handle gets narrower. The less complex the packaging, the more likely it has real value.”
Inks and coatings can indeed be as disruptive as multi-material laminations.
“Polyolefin structures are preferred, but heavily printed packaging remains a problem,” Johnson said. “The ink layer is just as hard to remove as an incompatible polymer.” Advances in deinking and digital print could help, but she urged brand owners not to wait for technology to solve what design can fix today.
Fisher added that design changes will ripple across the system. Simplified structures make MRF operations more efficient and create better feedstock for end markets. “The knock-on effects are real,” Easdale said. “Design drives everything downstream.”
California as catalyst
California’s EPR rollout is being watched nationwide. With producer responsibility now law in several states—including Colorado, Oregon, and Minnesota—the lessons learned in California will shape national strategy. Menezes said CAA views the state as “a laboratory for learning.” Early data on material recovery, consumer behavior, and market response will inform how programs scale elsewhere.
Johnson agreed, noting that the sheer diversity of California communities—urban, suburban, and rural—will test every model of collection and processing.
“What works in Los Angeles won’t necessarily work in Redding,” she said. “We have to design systems that can flex.”
Fisher closed the discussion with a reminder that collaboration itself may be the biggest breakthrough.
“All of us are talking to one another—CAA, FPA, TRP, RRS—to see how we scale,” she said. “None of us can solve this alone.”
What brand owners can do now
- Simplify structures. Favor mono-material designs and limit inks to improve sortability and yields.
- Create demand signals. Commit to using recycled content where feasible to stabilize pricing and drive investment.
- Value bridge markets. Durable applications keep material flowing and fund infrastructure while film-to-film systems mature.
- Support system-wide collaboration. Engage with initiatives like USFFI and TRP to align design and investment decisions.
Plan for California, learn for the nation. The state’s implementation will set precedents for EPR design and compliance across the U.S.
California’s EPR law may be forcing the issue, but it’s also unearthing a roadmap. Progress will depend on packaging designed for the system that exists now, or at least a system that can realistically emerge without massive new investment. But more importantly, a sentiment heard across multiple panels today, it depends on markets strong enough to sustain it.
