Design for Recyclability Under U.S. Packaging EPR

Under U.S. packaging EPR, "recyclable" is a legal determination, and it can raise or lower the fee you pay. This page maps how design decisions translate into recyclability determinations and fees across the materials you ship, and it describes the rules without prescribing a redesign. To see the fee impact of a design choice, use the Unit EPR Fee Calculator. The Design for Recyclability Rater, now in beta, scores a specific package against these rules.

confirmed stated in a statute, an adopted rule, an approved program plan, or a published schedule or agency list signaled official but not final: a draft, a filed program plan, or an agency statement speculative projection
Designed for recycling and recyclable are separate tests.
Meeting the design rules on this page makes a package "designed for recycling." What you can legally put on-pack, and the fee you pay, depend on collection access and the state, not on design alone. See Claims (SB 343) below.

The materials this page covers

U.S. EPR covers, and eco-modulation prices, every major packaging material, not just plastics. Each material is recycled through a different system, so each has a different governing design rule: plastics are sorted optically by resin and color, glass is sorted by light transmission, fiber is judged by coating and contamination, and metal is judged by how much stays mono-metal. Because the rule that decides "recyclable" is different for each, this page treats them separately. Plastics carry the most design levers and the most fee sensitivity, so that section runs deepest, but glass, fiber, and metal each have a distinct rule.

Plastics

The APR Design Guide is a U.S. technical standard for plastics recyclability, but it is not the only input. How2Recycle and the SPC Guide to Recyclability define what counts as recyclable and add the collection-access test. RecyClass is APR's European counterpart, and the two have aligned their guidance. The U.S. Plastics Pact operationalizes APR into a national design handbook and a problematic-materials list that member brands commit to eliminating. APR sets the technical standard, while the Pact is voluntary and its influence is commercial, because its brand commitments flow down to suppliers. APR covers plastics only, and glass, fiber, and metal have their own authorities, below. Meeting this design core is necessary but not sufficient. Whether you can call the result "recyclable" is a separate question, covered in Claims below.

Design ruleWhat it means
Design in one polymer familyMono-material is rewarded. Mixed and multilayer constructions are penalized.
Prefer clear or light PETClear unpigmented PET, or transparent light blue or light green only. Carbon black and NIR-undetectable dark colorants render PET non-recyclable because most NIR sorters cannot see them.
Eliminate the problem resinsPVC and PVDC, PS and EPS, and rigid PETG are flagged by APR and targeted for elimination by the U.S. Plastics Pact.
Keep components compatible and separableClosures, pumps, labels, sleeves, and liners are recyclability-determining, not accessories. Metal springs and full-body sleeves are flagged.
Clear the small-format testParts 2 inches or under in two dimensions must pass APR's size-sortation protocol or they fall through MRF screens.
Keep inks and coatings compatibleHeavy inks, dark pigments, and wash-resistant coatings can contaminate the recycled stream and interfere with optical sorting.
Put real recycling instructions on-packHow2Recycle is the standard North American on-pack label, and APR Preferred designs are more likely to qualify as widely recyclable.

Features that push a plastic package into higher fees

FeatureU.S. recyclabilityFee consequenceStatus
PVC / PVDCNon-recyclableNo recyclability credit; elimination-list materialconfirmed
Carbon black / NIR-undetectable darkNon-recyclable (most NIR sorters cannot detect it)Can fall under the California malus on detrimental packaging features CAA proposes from 2029, which names undetectable carbon black among its examples; CAA lists the features each year and has set no valuessignaled
PETG (rigid and full-body sleeves)Contaminates the PET streamDegrades the host container's recyclable determinationconfirmed
PS / EPSVery low recyclabilityNo recyclability credit; targeted by state bansconfirmed
Full-body non-perforated shrinkDetrimental; hides the host resinDesign-based malus risk in Coloradosignaled

Who decides what a package can claim

APR and the U.S. Plastics Pact do not determine recyclability. They set design criteria: whether a package is built so it can be recycled. Whether it is recyclable in practice, and whether you may label it "recyclable," depends on the recovery system rather than the design, meaning whether the format is collected, sorted, reprocessed, and sold into an end market. The SPC Guide to Recyclability, which How2Recycle uses, defines recyclability through those four criteria, and California SB 343 turns a version of that test, collection reaching at least 60% of residents plus real sorting and processing, into law for on-pack claims.

LayerQuestion it answersSet by
DesignIs it built so it can be recycled?APR Design Guide (RecyClass in the EU)
Access to recoveryIs it collected, sorted, reprocessed, and sold into an end market?How2Recycle / SPC four-criteria definition
Legal determinationMay you label it recyclable, and what fee applies?California SB 343 (60% collection and sortation tests); SB 54 CMC list and state EPR eco-modulation

Under SB 343, a product or package may be labeled "recyclable" under the main test only if its material type and form is collected by programs serving at least 60% of Californians and is sorted for recycling by facilities serving at least 60% of the state's programs, and it meets the design limits in PRC 42355.51(d)(3). A material can alternatively qualify with a demonstrated recycling rate of at least 75%. The 60% test is about access, not the recycling rate. There is no simple weight cutoff, but a detractor that pushes an item out of a recyclable type and form, such as a full-body sleeve or carbon black, can disqualify it. A mono-material PE film pouch shows the gap: it is designed for recycling, but it is store-drop-off only and below the 60% collection threshold, so it cannot be called "recyclable" in California unless it qualifies under one of the alternative routes, such as the noncurbside collection provision in PRC 42355.51(d)(5).

How2Recycle: the on-pack label that reflects access

How2Recycle is a North American on-pack recycling label, used in the United States and Canada and run by the Sustainable Packaging Coalition (GreenBlue). It covers all materials, plastic, glass, fiber, and metal, and it is the layer that tells a consumer what to do with a package. It is built on the same access-to-recovery logic as SB 343: to assign a label, How2Recycle applies the SPC Guide to Recyclability's four criteria, so the format must be collected from a meaningful share of households, sortable at a MRF, reprocessable, and sold into an end market. APR-Preferred design helps a package qualify, but real-world collection access is what sets the tier.

On-pack labelWhat it signals
Widely RecyclableCurbside access for most of the population (PET bottles, HDPE bottles, aluminum cans). The outcome to design toward.
Check LocallyCollection is inconsistent and depends on the community (PP tubs, aseptic cartons).
Store Drop-OffNot curbside; returned to retail collection (PE film, bags, air pillows).
Not Yet RecyclableNo broad recovery pathway exists today (multi-material laminates, foamed PS).

How2Recycle is voluntary; SB 343 is mandatory and California-specific. They usually point the same way, but they are assessed separately: SB 343 keys to the collection and sortation tests in PRC 42355.51(d)(2), measured against CalRecycle's SB 343 Final Findings Report, and to the design limits in PRC 42355.51(d)(3), while How2Recycle assigns a communication tier. Use How2Recycle to label the package, and confirm the SB 343 determination before selling in California.

Glass

Glass is optically sorted, and the sorter reads each piece as glass or as a ceramic/stone/porcelain contaminant based on how much light passes through it. For decorated cosmetic glass, opacity, not color, is what usually causes rejection. The governing rule is a light-transmission spec. These rules come from the Glass Packaging Institute and a 2024 Estee Lauder/SMI cosmetic-glass study.

Glass design ruleWhat it means
Target light transmission at or above 5%Below roughly 2%, a package is rejected as a ceramic/stone/porcelain contaminant. 3% is the observed minimum that passes; 5% is the design threshold. This one number covers lacquering, silk-screen, and dark or feeder color.
Opacity blocks sortation, not colorAll colors can sort as glass; opacity is what makes the sorter read a piece as a contaminant. But color still affects whether it is recycled, see the note below.
Use soda-lime glassThe container-glass chemistry that North American curbside streams collect. Borosilicate, opal, and aluminosilicate glasses contaminate the cullet.
Treat metallization as chemistryMetallic coatings contaminate the cullet at parts-per-million and must be blended down even when they sort. Use as an accent or remove.
Watch small formatsContainers and closures at or under about 2.5 inches (sample and perfume vials) can drop out of recovery, although CalRecycle's January 2026 CMC list rates small glass (two or more sides 2 inches or less) as recyclable in California.

Sorting as glass is not the same as being recycled into new glass. Mixed and tinted cullet often becomes landfill cover (ADC) or aggregate. Labels and sleeves separate during crushing and do not impede recovery; ceramic swing-top closures are a contaminant.

Paper and fiber

Clean fiber is among the most recyclable packaging in the U.S., and plastic coatings, lamination, and heavy metallization are what make it non-recyclable.

Fiber design ruleWhat it means
Keep it uncoated and cleanUncoated paperboard is recyclable in California at about 30%; OCC corrugated at about 68%, the strongest recyclable secondary pack.
Avoid plastic coatings and laminationCalifornia keeps paperboard poly-coated on one side in the recyclable paperboard category (recycled at about 30%), and reclassifies board coated on both sides as a multi-material laminate that is not on the recyclable list (recycled at under 6%), which raises the fee under CAA’s 2027 California fee schedule.
Limit metallization and foil on boardSolid metal foil and heavy metallized decoration move fiber toward non-recyclable, the same coverage logic as plastics (see Decoration below).
Cartons are a separate streamAseptic and gable-top cartons are collected in some programs (for example, Oregon's statewide list) but are not on California's recyclable CMC list; check by state. CalRecycle raised carton sortation coverage to 62% of surveyed counties in 2026, which feeds the CMC list update due by January 1, 2027, but it does not change the determination today.

Metal (aluminum and steel)

Metal is the forgiving material. A mono-aluminum or mono-steel can, bottle, tube, or closure recycles at close to its full weight, and standard decoration (lacquers, inks, most coatings) is separable in reprocessing rather than disqualifying. In the U.S., collection access is the gating question for aerosols.

Metal design ruleWhat it means
Keep it mono-metalOnly metallic aluminum counts as recyclable value. Laminates are defensible (the plastic burns off in reprocessing) but true mono-aluminum maximizes recovered weight.
EliminatePFAS coatings (targeted by state packaging bans) and vapor-deposited metallized layers, which count as loss rather than recyclable content. Carbon black is a plastics sorting problem, not a barrier to metal recycling.
Small size is not a barrierState-of-the-art sorters recover even very small metal items; any minimum-metal-content sorting rule is economic, not a recyclability determinant.
Solve aerosol collection accessThe U.S. issue is MRF acceptance. Cans must be empty. The CMI/HCPA Aerosol Recycling Initiative targets 85%+ recycling access by 2030. Non-aerosol aluminum is CMC-recyclable at under 39% in California.

The per-format design detail is European (Metal Packaging Europe, Sept 2025); the physics translate to the U.S., where the recyclability determination comes from the CalRecycle CMC list and aerosol collection access from CMI/HCPA.

Decoration and metallization

Decoration can break recyclability, the rules differ by material, and metallization is governed by amount and type.

OnRuleStatus
PlasticSolid metal foil decoration generally renders a package non-recyclable. For metal sorting, APR rates metallic ink, metallized transfer, and metallized film as Preferred from 0 to 12 mm spherical equivalent on HDPE and PP and from 0 to 8 mm on PET; on PET, 8.1 to 15.9 mm is Detrimental to Recycling, and 16 mm or more (12 mm or more on HDPE and PP) renders the package non-recyclable. APR treats label or sleeve coverage up to 75% of the side wall and shoulder (55% for containers of 550 ml or less) as Preferred for PET, HDPE, and PP containers; above that the package requires testing, because coverage can affect NIR and color sorting, unless on PET the label is a perforated crystallizable PET sleeve of 50 microns or less, which APR also treats as Preferred.confirmed
GlassJudged by resulting opacity. Any decoration that drops light transmission below roughly 2% rejects as a contaminant, and 5% is the design threshold. Metallic coatings also contaminate the cullet chemically.confirmed
MetalVapor-deposited metallized layers are counted as loss, not recyclable content; lacquers and printed inks are separable and acceptable in moderation.signaled

The limits are from APR’s Metal Decoration Resource, RES-SORT-03b (Version 3, August 30, 2024), Tables 1 and 2.

California recyclability determinations and recycling rates

CalRecycle's January 2026 Covered Material Category (CMC) list is the authoritative California reference under SB 54. For the first time it publishes an estimated recycling rate for each category alongside the recyclable determination. A format can be deemed recyclable and still be recycled at a single-digit rate. This is a working subset. View or download the full CMC list (January 2026) for all 95 categories.

FormatCA recyclable?Recycling rateRead
Clear PET bottleYes16%Among the highest California plastic rates, and still low
Colored or pigmented PETYes5%Pigment cuts the real rate to a third of clear
HDPE bottleYes19%Among the highest California plastic rates
PP jarYes2%Recyclable, but recycled at 2 percent; a PP cap measuring 2 inches or less on two or more sides falls in the small-plastic category, which is not on the recyclable list
PE film or pouchNo~5%Not on the recyclable list; store drop-off is the likely main route, not curbside
Multi-material laminateNounder 2%Redesign or take-back
PS / EPSNounder 1% (EPS); under 2% (solid PS)Eliminate
PVC / PVDCNoinsufficient dataContaminant
Paperboard poly-coated on both sidesNounder 6%Do not claim recyclable on board poly-coated on both sides
Uncoated paperboardYes30%The defensible recyclable carton
CorrugatedYes68%Strongest recyclable secondary pack
Glass bottle or jarYes65%Opaque coatings can cause rejection at the optical sorter (glass study)
Aluminum, non-aerosolYesunder 39%Strong mono-material option

The CMC determination is category-level and does not clear an on-pack "recyclable" claim; California SB 343's population-coverage test applies on top of it for packaging manufactured after October 4, 2026, although Attorney General enforcement of SB 343 has been preliminarily enjoined since July 14, 2026 (California League of Food Producers v. Bonta, S.D. Cal., ECF 24).

Sources: APR Design Guide pages for rigid PET, HDPE, and PP (label coverage); APR RES-SORT-03b, Metal Decoration Resource, v3, August 30, 2024 (metallization); How2Recycle and the SPC Guide to Recyclability, and RecyClass; U.S. Plastics Pact Recyclable Packaging Design Handbook (3rd Ed., July 2026); CalRecycle SB 54 CMC list (Jan 2026) and California SB 343; Oregon DEQ statewide collection list (Aug 2025); glass thresholds from the ELC/SMI cosmetic-glass study (2024) and GPI; aluminum from the Metal Packaging Europe DfR guideline (Sept 2025) and CMI/HCPA Aerosol Recycling Initiative. Figures current as of July 2026 and subject to change.