Packaging EPR: From Packaging Supplier to Strategic Brand Partner

Global sustainability regulations are reshaping brands’ packaging strategies. Packaging has evolved from a simple product protector into a multi-faceted asset that delivers not only product protection and regulatory compliance but also brand communication and customer engagement.

With the expansion of Extended Producer Responsibility for Packaging (EPR) schemes across US states and the introduction of the EU Packaging and Packaging Waste Regulation (PPWR), packaging reusability and recyclability have become a key focus for brand owners.

Mike Barry, Commercial Director, Digital Printing, Domino, explains how label and packaging converters can support brands’ ‘Design for Recyclability’ initiatives and packaging EPR compliance.

Recycling Priority

While over 70 countries worldwide now operate Extended Producer Responsibility for Packaging (EPR) schemes, in the US, packaging recycling is handled at state level. Since 2021, seven states have established EPR schemes, including Maine, Oregon, Colorado, California, Minnesota, Maryland, and Washington. The scope of each scheme varies, but they all demand brands register as producers with the Circular Action Alliance (the only approved Producer Responsibility Organization [PRO] in the US at present), report packaging volumes, and pay EPR fees.

Some EPR frameworks put further demands on producers. California’s Plastic Pollution Prevention and Packaging Producer Responsibility Act, SB 54, for example, includes a mandate to reduce plastic packaging by 25%, recycle 65% of single-use plastics, and make 100% of packaging recyclable or compostable by 2032.

Escalating cost implications

EPR fee structures are typically based on the packaging weight or unit count and material, with calculation methods varying by state. Most states with active schemes have rolled out, or plan to implement, eco-modulated fee structures to reward more sustainable packaging design and material choices and discourage lightweighting using less environmentally friendly materials.

Eco-modulation is used to classify packaging waste based on recyclability, suitability for reuse, toxicity, and other factors. Criteria vary by state, with materials that are recycled statewide often benefiting from bonus payouts, while those that are more difficult to recycle may be penalized with higher charges or even be banned. Poor ink or material choices can also downgrade otherwise recyclable packaging, resulting in higher fees for brands.

By linking packaging design and material choices directly to costs, recyclability performance, and market competitiveness, it’s clear that EPR is more than just a tick-box exercise for brands.

Driving packaging recyclability and reducing fees

Converters play a key role in supporting brand owners’ responses to evolving regulatory demands while also enabling more sustainable, circular packaging solutions.

Beyond reporting, packaging EPR and initiatives such as the EU PPWR are prompting many brands to redesign packaging according to ‘Design for Recyclability’ principles. This includes switching to widely recyclable packaging materials, using smaller, easily removable labels, and considering the impact of inks on recycling processes.

For converters, there is a compelling opportunity to add value for customers by working closely with brands, packaging designers, and material suppliers throughout the process. A good understanding of state-level packaging EPR fee structures and demands, in combination with expertise in printing technology, inks, and substrates, offers a chance to differentiate. Converters can help brands create cost-efficient, compliant packaging and labels, while meeting marketing objectives with brand-compliant colors and excellent print quality.

In a world where packaging now receives the same level of scrutiny as the product itself, the ability to access high-quality information about material composition is becoming a key differentiator for brands when choosing a packaging supplier.

Seamless access to information, including material declarations on composition and weight, as well as compliance documentation for inks and adhesives, can transform brands’ EPR reporting. This information can provide evidence for market surveillance authorities and internal sustainability audits, and, when selling into EU markets, support the creation of declarations of conformity under PPWR.

Digital printing as an enabler

The focus on recyclability will continue to evolve, demanding new levels of flexibility and agility for both brands and converters. With sustainability and packaging regulations still in flux, and new initiatives such as digital product passports due for roll-out over the coming years, brands need to be able to quickly adapt packaging designs.

Digital printing technology is key to rapidly updating packaging in line with emerging regulations. Converters with access to digital presses can also efficiently produce shorter print runs of packaging variations, such as those requiring regional recycling symbols.

Digital also supports the addition of variable data elements, a key requirement for digital product passports. Brands will use printed, often serialized, QR codes powered by GS1 to share material, recyclability, and product and packaging compliance data via a website or app.

Preparing for the future 
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While there are no plans to standardize EPR at a federal level, at least ten other states are currently debating EPR legislation and are expected to introduce schemes in the coming years. The industry, including brands, manufacturers, and standards bodies such as GS1, is also driving greater consistency in data, reporting, and packaging design.

Packaging is becoming a regulated asset, data carrier, and cost driver for brands. As brands invest in packaging for the future, converters familiar with state-level packaging EPR regulations, advances in recyclable materials, and able to provide detailed documentation will have the edge.

ENDS