Extended producer responsibility implementation, end market challenges, and the need for supply chain dominated the discussion during the opening plenary at the Plastics Recycling Conference in San Diego this week. The session featured a fireside chat between Steve Alexander, president and CEO of the Association of Plastic Recyclers, and Jeffrey Fielkow, CEO of Circular Action Alliance, offering attendees an inside look at how EPR programs are taking shape in the U.S. and what challenges remain.
Alexander underscored the interdependence between recyclers and producer responsibility organizations (PROs) early in the discussion. “Plastic recycling cannot be successful unless CAA is successful on implementation and vice versa,” he said, adding that without material and customers, recyclers cannot remain in business.
From legislation to implementation
Fielkow explained that CAA’s role begins after laws are passed, translating policy requirements into operational programs that producers can follow. “We’re like Bob the Builder,” he said. “Once the law is passed, once the statutes are finalized, and the regulations or the rules are starting to be written, our job is to interpret what the law says must be accomplished. And then we build a program plan ultimately to keep producers compliant with the law.”
CAA currently serves as the PRO in six of the seven U.S. states with EPR legislation, with Maine as the lone exception. Each program differs because infrastructure, participation rates, and regulatory requirements vary by state, he noted.
The definition of “producer” itself can also vary. Producers are often brand owners, but not always, and part of CAA’s role is helping companies determine whether they qualify as obligated entities in each jurisdiction.
Alexander raised concerns about perceptions that CAA primarily represents brand interests because producers fund the system. Fielkow responded that while producers pay fees, the organization’s purpose is broader. “We’re conveners,” he said. “We are not the ones that have all the answers. Our role is to ensure that we’re getting all the people that do have the answers on how to actually make a better recycling system.
End markets in a fragile state
Both leaders agreed that end markets represent one of the most significant challenges facing plastics recycling today. Alexander pointed out that recyclers can solve technical barriers but cannot create demand on their own.
Fielkow described the condition of end markets as critical to the success of both EPR programs and recycling infrastructure more broadly. “There is no possible way that the EPR programs or even the recycling infrastructure can survive without the end markets,” he said.
CAA is working to develop responsible end-market standards to improve transparency and trust, ensuring materials collected for recycling are processed responsibly and reach legitimate downstream uses. Improving material quality by reducing contamination and enhancing sorting performance is another priority that could strengthen system economics.
The discussion also touched on the impact of imported resin pricing on domestic recyclers. While specific incentives tied to domestic sourcing remain uncertain, Fielkow emphasized that programs must ensure collected materials ultimately move into functioning markets to maintain circularity.
Incentives and design as system drivers
While not all state programs include recycled content mandates, Fielkow said EPR programs have tools to influence behavior, including eco modulation incentives tied to packaging performance. In Colorado, for example, producers using post-consumer resin may receive fee reductions. “That’s designed to drive that behavior, to show that it makes sense to use PCR content,” he said.
California’s law places significant emphasis on design, requiring producers to achieve 25% source reduction by weight and components in aggregate, along with recyclability targets tied to collection and sorting performance. Those requirements are expected to push companies toward material simplification and improved compatibility with recycling systems. “It’s not just about collecting,” Fielkow said. “It’s about design for the recycling system.”
Alexander emphasized APR’s long-standing role in solving recyclability challenges such as labels, adhesives, and material compatibility, while reiterating that the industry must address market demand to achieve sustainable outcomes.
Harmonization and participation
Another major theme was the need for harmonization across state programs. Fielkow described a CAA harmonization playbook that outlines best practices for legislation, including consistent producer definitions, covered material categories, and comprehensive needs assessments conducted before program launch.
Needs assessments evaluate infrastructure, participation rates, and market capacity to guide investment decisions and program design, while collaboration with recyclers, haulers, municipalities, and producers helps ensure programs reflect real world conditions.
Full producer participation is also essential, Fielkow said. Higher participation spreads costs across more companies, lowering fees and increasing resources available for system improvements. Early engagement from producers in states such as Oregon and Colorado has been encouraging, he added.
Defining success
Looking ahead, Fielkow said success for CAA will be measured by outcomes rather than financial flows. “We’re an outcomes-based organization,” he said. “We are pulling more materials in, better recycling rates, lower contamination rates. So we are building a better recycling system.”
Alexander offered a recycler perspective, saying APR would like to see all plastic packaging contain at least 5% recycled content within five years.
The session concluded with discussion of emerging technologies, including mass balance approaches. Fielkow said mechanical recycling should remain a priority but that multiple technologies will likely be needed to achieve broader circularity if they meet responsible end market standards. He also clarified that conversion to fuel would not count as recycling within CAA programs. PW
