Rosemont, Illinois— Extended producer responsibility (EPR) for packaging has been a hot topic in the industry, but mandatory post-consumer recycled (PCR) content requirements are also drawing significant attention in brand compliance efforts.

Although many brands have publicly committed to increasing PCR content in their packaging, the actual demand indicators for PCR have not moved significantly, according to speakers at the Packaging Recycling Summit held June 15-17 in Rosemont.

While several states have passed mandatory PCR regulations, New Jersey's law is considered the most far-reaching, speakers said. Some states' mandates apply only to beverage containers, but New Jersey's regulationsalso cover a wide range of food containers, and many brands are designing their packaging according to its stricter standards.

Challenges of aggregate average compliance model

"Obviously, there's a huge focus on EPR. But on PCR, we're focused on meeting New Jersey's requirements," said Molly Campbell, packaging sustainability manager at Campbell Soup Co. "When we talk specifically about non-beverage categories, that makes people uneasy." She noted that Campbell's portfolio includes both foods like soups and Prego pasta sauce, as well as beverages like V8 juice.

Mike Roxas, manager of packaging engineering for private brands at Ahold Delhaize USA, agreed that New Jersey's PCR regulation "is the most complex." He said data is crucial in helping brands determine compliance priorities.

Ahold Delhaize looks at which products sell fastest and which categories use the most plastic packaging. "For New Jersey, compliance means an aggregate average across the entire brand," Roxas said.

Campbell's strategy has shifted toward cross-category collaboration to support compliance. "We're no longer having each category team look at packaging in silos; we have to shift our focus a bit, step back, and look at it strategically," Campbell said. "You could switch X, Y, Z products to 100% PCR packaging tomorrow, but that wouldn't get us to the aggregate average New Jersey requires."

Cooling enthusiasm and cost realities

Cost and capital factors have also surfaced, and these perceptions are increasingly influencing brands' PCR decisions, Campbell said.

"Five years ago, I found many CEOs were interested in PCR before truly understanding its costs and impacts; they thought it was an easy win," said Suzanne Shelton, senior partner at ERM Shelton. "We've seen that enthusiasm cool somewhat."

However, she said brands remain interested in exploring how to incorporate more PCR, but cautioned that "interest doesn't always equal action."

Roxas noted that when considering both cost and supply, PCR presents challenges in material sourcing, especially for food-grade materials. This significantly impacts companies like Ahold Delhaize (whose private brand portfolio is about 80% to 90% food) and Campbell's (whose entire portfolio is food).

Technical bottlenecks and material limitations

A key technical challenge for Campbell's comes from the retort process that hot-filled products undergo, which causes packaging degradation. Campbell called it "a very, very harsh high-stress process on both the package and the product." She specifically pointed to issues with microwavable soup cups.

Roxas also echoed the difficulty of microwave-safe materials, specifically mentioning ready-to-eat meals in polypropylene trays. Recently, when developing a new product, the grocery company's packaging supplier offered only two options: a clear PP tray without PCR or a black PP tray with 25% PCR—the latterpresents recycling challenges. The company ultimately chose the 25% PCR option but is discussing with suppliers whether alternatives like fiber could be offered in the future.

The resin type and how it is recycled—mechanically or chemically—are crucial when incorporating PCR, speakers noted.

Campbell explained that one reason brands and packaging companies have traditionally placed so much emphasis on adding PCR to PET beverage containers is that this resin performs better than polyolefins in balancing recycled content with quality control. "It's hard to find containers outside of PET that can pass all the tests," she said. "My sensory team won't be happy with any changes in color, odor, or flavor."

Roxas said PET is a more mature PCR market, making sourcing relatively easier. "When it comes to polyolefins, the contamination risk is enormous. I've worked with many PCR suppliers who really struggle to achieve food grade... to ensure no chemical taste is transferred to the product."

Shelton warned that if adding PCR causes any such negative change to packaging or products, "be wary" of strong consumer backlash. "I can see this spreading like wildfire on social media."

Consumer perception misconceptions

Another challenge Shelton often hears when conducting consumer research is that consumers expect products with recycled materials to be cheaper. This contradicts the current reality of pricing for many products containing PCR.

"In the consumer's mind, 'it was something before, you just chopped it up and made it into something else. That should be cheaper, not more expensive,'" Shelton said. "It's very difficult to get a price premium based on recycled material alone."

Education and messaging are crucial, Shelton said, noting that words starting with "re" confuse consumers. "We use recycle, recycled content, renew. These words are fuzzy in their minds." But when all parties in the value chain take time to educate the public about what recycled materials really are, consumers accept them.

"When communicating recycled content, you can't just say '75% recycled content' because consumers will think that means 75% of the product can be recycled. They don't necessarily understand what it means," Shelton said.

She suggested that the additional cost of PCR should be paired with other benefits, such as performance improvements, to make price increases more acceptable to consumers. Otherwise, PCR labels on consumer goods may only heighten public skepticism about the recycling system—which in turn further damages the PCR market.

"If consumers don't believe the recycling system works, they won't recycle. If they don't recycle, we can't get the recycled materials we need, and we can't have more PCR," Shelton said. "It's a vicious cycle we have to solve."