Understanding PCR - Why it Matters, What it Means for Compliance

What It Is, Why It Matters, and What Companies Need to Know

Post-consumer recycled content (“PCR”) has become an increasingly important topic in packaging, sustainability planning, and regulatory compliance. While PCR is often discussed in the context of plastics, its relevance extends across many material types and policy frameworks. As states continue to adopt extended producer responsibility (“EPR”) laws and recycled content requirements, companies are expected to understand not only what PCR is, but also how it is defined, verified, and regulated.

This article provides a high-level overview of PCR, explains why it matters from both a regulatory and practical standpoint, and outlines key challenges companies face when incorporating PCR into packaging materials.

What Is PCR?

Post-consumer recycled content refers to material recovered from waste after a product has been used and discarded by a consumer. This differs from post-industrial recycled content, which comes from manufacturing scrap or other material generated before a product reaches consumers.

PCR can be incorporated into a wide range of materials, including plastics such as PET, HDPE, and LDPE, as well as paper and paperboard, glass, and metals. Although plastics receive significant attention due to recent legislation, PCR is not limited to plastics. Many state policies address recycled content more broadly, particularly where material recovery, end-market development, and waste reduction are core policy goals.

Why PCR Matters

Several states now require minimum percentages of PCR in specific packaging materials. California, for example, has established PCR mandates for certain plastic packaging and beverage containers, and other states are considering or implementing similar requirements, often phased in over time with associated reporting and verification obligations.

PCR also plays a growing role in EPR programs, where eco-modulated fees may vary based on packaging attributes such as recyclability, material type, and recycled content. Packaging that includes verified PCR may receive more favorable fee treatment as these programs develop.

California’s EPR law reflects a broader policy shift toward plastic source reduction, with PCR requirements operating alongside source-reduction targets to reduce reliance on newly produced, non-recycled plastic. As a result, PCR has become a practical consideration not only for regulatory compliance, but also for companies responding to retailer requirements, investor expectations, and public sustainability commitments. Aligning PCR claims with regulatory definitions and verification standards is therefore increasingly important.

Challenges in Using PCR

While interest in PCR is high, incorporating it into packaging is not always straightforward. Companies commonly face challenges related to cost, supply consistency, material performance, and verification.

PCR materials often cost more than newly produced, non-recycled materials, particularly when supply is limited or when applications require consistent material quality. Access to a steady, high-quality domestic PCR supply also remains limited as recycled content requirements expand across states. PCR is not a uniform input, and material quality can vary based on collection methods, sorting systems, and reprocessing controls, which can lead to variability during manufacturing or packaging even when specifications are in place.

Material performance may differ from non-recycled material, affecting properties such as strength, seal performance, or processability. These issues are often more noticeable for post-consumer recycled polyethylene films, which can be sensitive to contamination and variation in material characteristics. At the same time, verification and documentation requirements are becoming more complex as states add reporting, certification, and verification obligations, and practices that were acceptable in the past may no longer meet regulatory expectations.

Although many EPR laws are intended to address these challenges over time by supporting recycling infrastructure and improving recycled feedstock availability, companies must account for these constraints in the near term when planning packaging strategies.

The Growing Importance of Third-Party Certification

One of the most significant developments in PCR regulation is the increasing reliance on third-party certification to verify recycled content claims. Third-party certification typically involves independent verification of the source of recycled material, chain of custody throughout the supply chain, the percentage of PCR incorporated into a product, and compliance with applicable accounting rules.

California’s EPR program requires third-party certification for PCR claims, and other states with recycled content mandates or EPR programs have adopted or are considering similar requirements. These policies reflect growing concern about unsupported or inconsistent recycled content claims and are intended to improve transparency and credibility.

Colorado provides a clear example of how PCR accounting rules are tightening. The state has prohibited the use of mass-balance free allocation methods for PCR accounting in certain contexts. As a result, companies cannot assign recycled content to products without a direct, verifiable link to material inputs. Certification and documentation practices that were acceptable in the past may no longer satisfy state requirements.

For companies operating across multiple jurisdictions, understanding where third-party certification is required and how standards differ by state is becoming increasingly necessary.

What This Means for Companies

As PCR requirements continue to expand, companies should treat PCR as a broader packaging and materials issue rather than a narrow compliance task. This includes evaluating current and upcoming PCR requirements across states, understanding how PCR interacts with EPR fee structures, assessing supply chain readiness and documentation practices, and engaging suppliers early on verification expectations.

Proactive planning can help reduce compliance risk, avoid last-minute design changes, and support longer-term packaging decisions as recycled content mandates and EPR programs evolve.

Conclusion

PCR is no longer a narrow sustainability issue. It affects material selection, regulatory compliance, and long-term packaging decisions. As states adopt more detailed and enforceable PCR requirements, particularly around third-party certification, companies will need to rely on documented and verifiable practices rather than general sustainability claims.

Understanding how PCR is defined, regulated, and verified today is an important step in preparing for future packaging requirements.

References

1. California Department of Resources Recycling and Recovery (CalRecycle). Extended Producer Responsibility (EPR) for Packaging – SB 54 Implementation Materials.

2. California Department of Resources Recycling and Recovery (CalRecycle). Recycled Content Requirements for Plastic Packaging and Beverage Containers.

3. Colorado Department of Public Health and Environment (CDPHE). Producer Responsibility Program for Packaging: Rulemaking and Guidance on Recycled Content Accounting.

4. Association of Plastic Recyclers (APR). Design Guide for Plastics Recyclability.

5. U.S. Environmental Protection Agency (EPA). National Recycling Strategy.

6. Ellen MacArthur Foundation. Global Commitment and Guidance on Recycled Content and Circular Packaging.

7. EPR Group Consulting Inc. Internal Analysis of PCR Requirements, Eco-Modulation, and State Packaging Laws.