All About Post-consumer Recyclables (PCR)

Plastic PCR is produced by sorting and shredding plastic recycling into small granules. Image Courtesy: Envato Elements

Post-Consumer Recycling (PCR) material is recycled materials that have been used in the market by consumers and can be used again to create new products. PCR packaging is made by collecting, sorting, cleaning, and processing post-consumer waste, such as plastic bottles, paperboard, glass containers, aluminum cans, etc., into a form suitable for reuse in manufacturing new items. PCR packaging has many benefits regarding environmental sustainability; it reduces the amount of virgin raw materials being sourced from limited natural resources and also helps reduce greenhouse gas emissions due to the reduced use of energy needed for producing new items compared with traditional production processes. Also, post-consumer recycling helps divert waste from landfills, where it may take years or even centuries to break down naturally. When it comes specifically to plastic, resins are the physical components of plastic recycling used to manufacture PCR plastic.

How is PCR Manufactured?

Paper PCR

Paper PCR is manufactured by sorting and shredding paper recycling into small pieces. Water and chemicals, such as hydrogen peroxide, are added to create a slushy pulp and to remove any inks. The pulp is then extruded into sheets and dried and sold as PCR paper.

Paper can typically be recycled up to seven times.

Plastic PCR

Plastic PCR is produced by sorting and shredding plastic recycling into small granules. The granules are liquified or gasified and extruded into pellets. The pellets are sold to manufactures and can be used to make PCR items as diverse as clothing, toys, rugs, yoga mats, kitchen tools, kitchen counter tops, trash bags, traffic cones and many others!

Plastic can typically be recycled up to three times.

Metal PCR

Aluminum PCR, like Plastic PCR, is produced by sorting and shredding aluminum into small pieces. Steel PCR is produced by treating with a chemical solution that separates the steel back into its original components. Both aluminum and steel are liquified into molten metal that can be extruded into new products.

Metal can be recycled FOREVER.

Glass PCR

Glass PCR is produced by crushing recycled glass and blending it with sand and other components. Like Metal PCR, Glass PCR is melted and extruded into new glass items.

Like metal, glass can be recycled infinitely.

Post-industrial Manufacturing and industrial recycling (PIR) may require treatment to remove toxins or chemicals. Image: Portco Packaging

How sustainable is PCR, really?

Greenhouse Gas Emissions

PCR generates fewer greenhouse gases than manufacturing virgin materials. PCR uses less water and energy, too!

Landfills

PCR reduces the amount of waste in landfills and oceans. PCR reduces the amount of chemicals that can potentially leach into the soils of landfills after a rainfall – these chemicals can poison both surface waters and groundwater. There is no such thing as a safe landfill.

Cost

PCR is one of the more cost-effective materials in sustainable packaging right now due to the efficient reuse of raw materials. A potential downside of PCR is that, unlike metal and glass, paper and plastic cannot be recycled infinitely. The recycling process degrades these materials with each generation, and they don’t last forever. There are additional food safety considerations with plastic recycling that we will also explore.

ISCC PLUS Certification

ISCC PLUS stands for International Sustainability and Carbon Certification. The ISCC PLUS is a global sustainability certification system. ISCC PLUS certification covers the entire supply chain involved in producing a certified item. This is critical when it comes to traceability and compliance. Follow this link to learn more about ISCC PLUS certification.

PCR: Food Contact and Food Safety

Glass and Metal

The FDA considers glass and metal PCR to be generally low-risk and impervious to contaminants. They are exposed to high enough temperatures during recycling to be sanitized for food safety.

Paper

Pulp from reclaimed paper may be manufactured into PCR for food contact. Still, it must meet Title 21 of the US Code of Federal Regulations (CFR), which limits the amounts and types of chemicals that can be used during the pulping process.

PCR Plastic: Food Contact and Food Safety
FDA Requirements: Primary and Secondary Recycling

Manufacturers of Food-Grade Plastic PCR must certify that the PCR is of suitable purity for its intended use and meets the same food safety requirements as virgin materials (Title 21 of the CFR: Parts 174 through 179). Additionally, because of the potential for contamination during the recycling process, extra care must be taken during the manufacture and testing of Food-Grade Plastic PCR for contaminants based on the source feedstock (in this case, food-based plastic recycling feedstock vs. plastic recycling feedstock from cleaning products, shampoos, motor oils, etc.). This means that manufacturers of Food-Grade Plastic PCR must: 1) provide a comprehensive description of the recycling process; 2) ensure that the Food-Grade PCR feedstock is completely isolated throughout the recycling process OR prove that the recycling process itself eliminates or reduces contamination to a safe migration level of .5 parts per billion; and 3) provide a thorough description of the intended use of the finished product.

Supplemental FDA guidance identifies Pre-Consumer Scrap (including PIR feedstock of a single substrate, such as untreated food-grade PE scrap) as safe feedstock for food-grade PCR, provided that Good Manufacturing Practices are followed. Pre-Consumer Scrap is considered Primary Recycling, and typically little more than sorting and sanitizing is required.

The FDA guidance also identifies the physical reprocessing of feedstock (such as the liquefaction of plastic recycling into pellets) to be safe, provided that the feedstock is sanitized to remove contaminants. This is considered Secondary Recycling. In all cases, the feedstock must meet Title 21 of the CFR: 174-179 and remain suitably pure for its intended use. In the case of Secondary Recycling, the FDA guidance permits the introduction of virgin materials into reprocessing to ensure the final PCR product meets the suitable purity requirements for food contact and food safety.

As with Secondary Recycling, Advanced Recycling feedstocks may be blended with virgin materials during the recycling process to meet the purity for intended use requirement. The introduction of chemicals throughout this process requires extra oversight to ensure there are no impacts to food contact and food safety. Image: Envato Elements

What is Advanced Recycling PCR?

Advanced Recycling, also known as Tertiary Recycling, allows plastics that are typically not recyclable to be converted into PCR. Advanced Recycling uses industrial processes to chemically transform difficult-to-recycle materials. These technologies allow more complex materials, such as laminations, to be converted into PCR. While Advanced Recycling is less sustainable than regular PCR, it still uses fewer resources and generates fewer greenhouse gases than the production of virgin materials. Recyclers must pay special attention to food-grade PCR to minimize risks to food safety.

PCR Plastic: Food Contact and Food Safety
FDA Guidance: Advanced Recycling

As with Secondary Recycling, Advanced Recycling feedstocks may be blended with virgin materials during the recycling process to meet the purity for intended use requirement. The introduction of chemicals throughout this process requires extra oversight to ensure there are no impacts on food contact and food safety.

FDA guidance recommends additional voluntary testing throughout the manufacturing process to guard against contamination during manufacture as well as contamination by a consumer after purchase, including the testing of PCR contact with household items such as pesticides or cleaning solvents. In some cases, the FDA may recommend burying a layer of PCR inside high-barrier virgin materials to minimize the food safety risk to the consumer.

Just as we do, the FDA treats food packaging as a food ingredient when assessing safety: https://www.fda.gov/regulatory-information/search-fda-guidance-documents/guidance-industry-use-recycled-plastics-food-packaging-chemistry-considerations.

We have been working for years to establish supply chains of FDA-approved manufacturers of Food-Grade Plastic PCR substrates, and we can offer the same variety of Food-Grade PCR options as non-PCR options.

Extended Producer Responsibility (EPR)

In the United States, EPR legislation is happening at the state level. California’s EPA legislation is the most dramatic and impactful, so let’s start there:

Applies to almost all single-use plastics, including flexible packaging like roll stock and pouches. It also applies to single-use serving utensils.
Requires covered materials to be at least 30% recycled, reused, or composted by 2028, 40% by 2030, and 65% by 2032.
Calls for the creation of a Producer Responsibility Organization (PRO). Manufacturers and brand owners/licensees must join a PRO by January 1, 2024, or be prohibited from selling in California. All costs associated with regulation and enforcement will be paid by PRO members.
Requires a 25% packaging reduction by weight and covered plastic component for the same size product by January 1, 2032.
Covered materials must be recycle-ready to meet the recycling deadlines. Recycle ready is not the same as PCR; however, products can be both.
Local jurisdictions and recycling service providers must institute collection and recycling programs for covered plastic materials.

EPR Legislation in the US

Maine – LD 1541

Similar to CA legislation in that it covers packaging sold within the state and will be 100% producer-funded. Fees will be set by volume and will be used to reimburse municipalities for recycling and waste management costs. Maine’s EPR law defines a producer exclusively as a brand owner.

There is less stakeholder engagement: Maine’s Department of Environmental Protection will award a 10-year contract to a single PRO (although Maine calls it a Stewardship Organization or SO) after a bidding process. The SO is not obligated to solicit advisement or feedback from other producers.

While this legislation was signed into law in 2021 and will take effect in 2026, recycling targets and other requirements still need to be determined. Rules and technical requirements are expected to be released in the summer of 2024.

Oregon – SB 582

Oregon’s law defines a producer as the brand owner, the licensee of a brand or trademark, or the first importer into the country. Oregon allows for multiple PROs as long as they are registered with the Department of Environmental Quality (DEQ).

Producers are required to belong to a PRO by July 2025. They will fund approximately 30% of the costs to create an expanded recycling system in the state and other targeted programs that promote recycling, sustainability, and environmental justice. The PRO will set fees. Producers can assign their representation to another producer in the supply chain via voluntary agreement.

This legislation was signed into law in 2021. Regardless of PRO membership status, producers will be part of a 17-member advisory council to the DEQ and PRO, and a majority vote is required to adopt any recommendations.

Colorado – HB 22-1355

HB 22-1355 was signed into law in June 2022 and defined a producer as the brand owner or the company named on the packaging.

The Colorado Department of Public Health and the Environment will designate a single PRO to set up and manage the program. Covered products are all retail packaging, regardless of the material's recyclability, and printed paper. Beginning on July 1, 2025, producers must participate in the program or discontinue selling in Colorado.

The PRO will develop three cost implementation scenarios for review and final approval by a legislative committee. The PRO will ultimately execute the law and will be responsible for assigning contracts to service providers, setting recycling requirements, and educating the public.

California - SB - 54

SB 54 creates an EPR program for printed paper and packaging. The bill includes requirements for reducing and eliminating single-use plastic packaging, the promotion of reuse and refill, eco-modulated fees, and social considerations. The state will require all plastic packaging to reach a 30% recycling rate by 2028 and 65% by 2032. There are plastic pollution efforts in the form of a mitigation fund. The PRO is charged $500 million a year over 10 years to the fund, and 60% will go to funding projects in disadvantaged, low-income, and rural communities. The bill passed on June 30, 2022.

Covered products include single-use packaging routinely recycled, disposed of, or discarded after its contents have been used or unpackaged and typically not refilled or otherwise reused by the producer. Packaging means any separable and distinct material component used for the containment, protection, handling, delivery, or presentation of goods by the producer for the user or consumer, ranging from raw materials to processed goods. This definition also includes plastic single-use food service ware, including, but not limited to, plastic-coated paper or plastic-coated paperboard, paper or paperboard with plastic intentionally added during the manufacturing process, and flexible multilayer material. Examples are trays, plates, bowls, clamshells, lids, cups, utensils, stirrers, hinged or lidded containers, straws, wraps or wrappers, and bags sold to food service establishments.

Brands
The producer is the person who manufactures a product that uses covered material and who owns the brand or trademark under which the product is used in a commercial enterprise, sold, offered for sale, or distributed in California.

Licensees
If there is no brand owner, the producer of the covered material is the owner or the exclusive licensee of a brand or trademark under which the covered product using the covered material is used in a commercial enterprise, sold, offered for sale, or distributed in California.

Importers/Distributors
If there is no person in the state who is the brand owner or licensee, the producer of the covered material is the person who sells, offers for sale, or distributes the product that uses the covered material in or into California.