Small format items’ recyclability is not determined by the resin alone but by the capabilities of the MRF that receives them.
Recycling high volume post-consumer products, even those that are easily identified and captured, is challenging under the best of circumstances. Material Recovery Facilities (MRFs) vary widely in what they accept in curbside bins based on their technology and economics. That variability influences how packaging is labeled and understood.
Many MRFs simplify communication by asking residents to recycle bottles and cans rather than referring to specific Resin Identification Code numbers or metal types. Recycling challenges go beyond the inevitable “ick” factor, which is simply part of the territory. Items have to get in the bin to get recycled, so initiatives need to focus on how to sort and recycle as much as possible.
Beyond Bottles and Jugs
Once you go beyond high-volume materials like PET bottles, HDPE containers, corrugated cardboard, and other well-established commodities – all essential to recycling performance – the next meaningful gains will come from the less ubiquitous packaging formats that do not fit neatly into existing recovery systems. This is the frontier where Extended Producer Responsibility (EPR) policies are pushing brands. Packaging types include multi-layer pouches, flexibles, paper cups with polymer linings, shrink-sleeved containers, and other more complex structures. These formats challenge current collection, sorting, and reprocessing infrastructure and require more creativity, more coordination, and more patience to manage effectively.
The good news is that the value chain is actively responding. Industry groups, pilot programs, and collaborative coalitions are testing new technologies, refining design guidelines, and developing end markets capable of handling these more challenging materials. Green Group Consulting and others in the space are helping producers turn policy into something that actually works in the real world, blending solid design know-how with creative, practical problem-solving that fits both the rules and the spirit behind them.
Small Formats
EPR is here and steadily growing. Oregon has led the way with Colorado close on its heels. California and Minnesota are next in line with an odd assortment of other states like Maine, Washington and Tennessee joining the queue. As states continue building the rollout roadmap alongside Circular Action Alliance (CAA), there are lots of “what ifs” and potential roadblocks for certain packaging items. Some of this is intended by the state legislatures.
EPR, by design, is intended to influence consumer product companies to transition to more sustainable packaging choices. This simple concept is anything but that when it comes to implementation. Does one value ease-of-recyclability or carbon footprint more? How much does shelf life play into decision making? What about ease of transportation? The list of variables weighed when selecting packaging is enormous and this is nothing new to industry veterans. This is by no means unique to the packaging or recycling industry. A primary packaging type that falls in the gray zone of EPR laws is “small format”.
In California, under SB 343, an item must be of a “material type and form collected for recycling by recycling programs for jurisdictions that collectively encompass at least 60% of the population of the state”. Under the Covered Material Categories (CMCs) released by CalRecycle for its upcoming EPR plan under SB54, all plastic items that have two or more sides measuring 2 inches or less fall under the same category.
Small format items play a more complicated role in today’s recycling system than many people realize. Their recyclability is not determined by the resin alone but by the capabilities of the MRF that receives them. In facilities with modern optical sorters, updated capture systems, and improved line configurations, small items can be successfully identified and recovered. In older or less-equipped facilities, these same items often fall through screens or are lost in the process, making recycling impossible regardless of material type.
Sorting Challenges
The Association of Plastic Recyclers (APR) has identified size as an important factor in sortation. Smaller pieces are more difficult for near infrared systems to detect and are more likely to end up in the fines stream or mixed into the wrong bale. This means that for small items, design choices matter even more than they do for larger packages. Dark colors, heavy printing, metallic inks, and label structures that interfere with detection can easily push a small item below the threshold needed for successful sorting.
New technologies offer promising improvements. Digital watermarks, upgraded algorithms, and two-pass sorting systems are showing that even very small formats can be detected more reliably. These advances, paired with better design practices, give brands more pathways to make small items work in a circular system.
The recyclability of small formats varies widely across the country because MRF capabilities vary. Some facilities are already capturing these items effectively, while others cannot handle them at all. This uneven landscape highlights why infrastructure modernization is so frequently cited as a national priority and why design for recycling must consider the realities of the system that exists today. Small items are as recyclable as any larger item as long as they get sorted into the right bale.
In practical terms, small format items now require the same level of format-specific testing and documentation as any other package. Tools such as the APR Sorting Potential Test Method provide objective data on sortation performance. This type of evidence bolsters recyclability claims.
No matter how strong the technology is, recycling only works if there is a buyer at the other end. Collection and sortation are important steps, but they do not mean much if the recovered material has no market value. When virgin resin is cheaper than producing recycled resin, buyers tend to default to the lower-cost option, leaving the recycled stream without a home.
Policies such as EPR and minimum recycled content requirements in states like Washington and New Jersey aim to shift that economic reality, but it is still too early to know whether they will change the math in a meaningful way. If the cost of using recycled content is higher than the penalties for avoiding it, many companies will simply choose to pay the fines. On the other hand, if the penalties are set so high that they become punitive, they may trigger long court battles that stall progress without delivering any real environmental benefit.
The challenge is finding the balance point that moves the system forward. The most effective path is the one that encourages real investment in recycled materials, supports stable end markets, and steadily builds a more sustainable and resilient recycling system.
David Nix, president of Green Group Consulting, brings over three decades of experience in the plastics industry with a focus on polypropylene and recycling. The firm works across the entire plastics recycling value chain, translating technical complexity into actionable, practical strategies.
Sources: APR sorting potential test protocols. Association of Plastic Recyclers (APR). (2024, September 17); California, S. of. (n.d.). SB 343: Accurate Recycling Labels; California, S. of. (n.d.-a). SB 54 Covered Material Categories List. Covered Material Categories.
