Packaging EPR is here: What that means for label converters

Extended Producer Responsibility (EPR) laws for packaging have passed in seven US states, covering 63 million people – nearly 20% of the country’s population. In Canada, similar rules already reach 98% of residents.

For label converters, the shift expands the definition of label performance to include environmental impact and packaging recyclability. And this performance can impact brands’ bottom line now while becoming a market access issue in the near future.

UPM is actively tracking packaging EPR developments and shares what it learns with customers, so they can explain the requirements to their own customers in turn. “This is a dynamic situation. Rules and guidance are still under development, and producers, producer organizations, governments, and suppliers are all learning as we go,” says Jessica Rocha, UPM sustainability manager.

At the same time, there’s no need to panic – just prepare.

“Packaging EPR is grounded in pragmatic solutions we’ve long been preparing for,” says Rocha. “It’s moving recyclability from a nice-to-have to a requirement, and we have the materials ready to help customers make the right choice.”

Recyclability has been a UPM focus for years, Rocha adds. “We know how pressure sensitive labels fit into different packaging recycling streams. We were first to market with many solutions, and our UPM ProCycle portfolio is designed to make these choices easier.”

Why the label counts toward the recycling stream

Packaging EPR laws aim to fund recycling infrastructure improvements by charging packaging fees for “producers”– primarily brands. The fees are based on packaging type and quantity. They also incentivize packaging design choices through eco-modulation: fees that rise or fall based on how recyclable, reusable or reduced a package is.

States are also setting targets to meet packaging reduction and recycling goals. A California requirement that all covered packaging must be recyclable or compostable by 2032 has strong implications for converters.

While the primary focus of the laws is on the main package, a label’s material, adhesive, ink, and varnish all affect several aspects of recyclability. This includes how a sorting machine reads the package under the label, then moves it into the right material stream – think separating HDPE containers from PET and PP. These materials are then baled and sent to reclaimers who further process the material, which may mean separating the label and its embellishments from the package for better quality.

Label and design choices have a big impact on plastic recyclate quality. And because UPM wants higher quality to replace virgin plastics, these choices affect recyclability and potentially brands’ EPR fees – even if the label itself is a small percentage of the package weight.

That’s why different packaging types require different solutions. “You can’t talk about an ‘EPR compliant’ label without understanding what that label is going on,” Rocha says. “If there’s one question our converter customers need to ask their customers, it’s, ‘What material will the label will be applied to?’ That determines the recycling stream the package is sorted into. A label is a component, and the main packaging material determines recyclability.”

That question keeps conversations grounded in design choices, Rocha says. What’s important is making data-driven decisions, not assumptions.

UPM tests those assumptions directly by visiting material recovery facilities (MRFs) and recycling plants with customers to see how packaging performs once it leaves the shelf.

“We can no longer make assumptions about what is recyclable. We need data,” Rocha says, adding that determining recyclability requires looking at the bigger picture and considering:

• Is the package collected?
• Can it be sorted?
• Is it designed for recyclability/recycling compatibility?
• Is there a market for the recycled material?

“Once we have that data, then we can select the best label choice for EPR compliance,” Rocha says.

UPM ProCycle simplifies converter choice

UPM’s new ProCycle portfolio applies this mindset across packaging materials. Starting with rigid PET and HDPE packaging, two of the most commonly recycled plastic packaging materials. ProCycle pairs UPM’s adhesive technology with filmic label materials built for high-volume CPG packaging.

ProCycle products for HDPE and PET also meet APR Design for Recyclability criteria, which supports compliance with California’s EPR law and others. The portfolio includes wash-off adhesives that separate cleanly during the washing and grinding stages of mechanical plastic recycling. UPM will show the portfolio at the LOUPE Americas trade show in Chicago this September.

“The ProCycle portfolio makes it easy to select face and adhesive materials that are compatible with a given packaging recycling stream,” Rocha says. “Several solutions work across packaging types, so customers can simplify their SKUs and find efficiencies.”

The recycling numbers beat the narrative

In the end, packaging EPR laws are about much more than design choice. They aim to funnel the collected fees into building and scaling states’ recycling infrastructure. The US Environmental Protection Agency estimates the country needs $36.5 billion in infrastructure investment to reach a 61% packaging recycling rate.

That’s a lot, but we’re not starting from scratch, Rocha says.

“Americans are not hopeless when it comes to recycling, even though the narrative might suggest otherwise,” she explains. “We do recycle a lot of packaging, including plastic. California estimates that 19% of HDPE bottles, jugs and jars are recycled, and more than 60% of glass bottles, jars, and cardboard are recycled. In Colorado, a large state with big rural areas, an estimated 25% of all packaging is recycled, with cardboard at 45%, at least a third of glass and metal, and 14% of rigid plastics. We can do better for sure, but we aren’t starting from zero.”

This extends to label choice, as well.

“Almost all of our label products sold last year carried some kind of sustainability attribute,” Rocha says. “Our customers are already choosing materials that reduce packaging’s environmental impact while doing their job: protecting food and medicine, cutting the waste that comes with spoilage, and telling a brand’s story on the shelf.”

Actions label converters can take today

Rocha’s advice for converters on packaging EPR comes down to a few habits:

• Keep an eye on packaging EPR developments. Fees in Colorado and Oregon are already published, and California’s are coming soon.
• Ask early what material the label is going on. That answer decides the recycling stream, and the recyclability solution.
• Keep proof ready. Certifications such as APR Design recognition and lifecycle assessments will matter more as states ask producers to substantiate bonus claims.
• Watch release liner. It sits outside packaging EPR’s scope today, but UPM continues to work on end-of-life solutions for it.
• Understand your obligations on items like transport packaging. While most of the laws focus on consumer packaging where labels are a component, some states also include business-to-business packaging.
• Start the conversation before the deadline does. Review your portfolio for EPR-readiness and talk to your customers about their needs.

“Our customers can expect a true partner in circularity,” Rocha says. “We want to equip converters with the knowledge and the products to succeed with their own customers. A good first question to ask is simple: what is the main package’s base material, and if it’s plastic, what kind? Simple questions go a long way.”