Perhaps more than other formats, flexible packaging has faced backlash amid a wave of US legislation aiming to decrease reliance on fossil fuels and reduce plastic waste.
Since its inception, flexible packaging has been touted as energy efficient, taking up less space and weighing less, to help reduce emissions from transportation. However, the format also has been characterized by the use of mixed materials – a polymer outer layer, a thin aluminum foil layer and another polymer layer – that make recycling a challenge.
As such, flexible packaging stakeholders including Charter Next Generation (CNG) and others including the Flexible Packaging Association (FPA) have seen customers seek monomaterial solutions, to help ensure recyclability. This shift has occurred despite brands scaling back plastics goals, a change in US policy priorities, and increased costs stemming from macroeconomic and geopolitical pressures.
Kristin Edie, CNG director of sustainability and regulatory, said the material sciences firm is seeing an increase in demand from customers concerned with source reduction requirements, especially in California.
The first step tends to be downgauging, or making film thinner, but this approach is feasible only to an extent, she said. “PCR is really a great approach for them to meet source reduction targets of 10%,” of which 8% can be PCR, she said. “Customers are definitely seeing PCR as an avenue to meet the source reduction goals without needing to further downgauge the packaging.”
CNG joined the US Flexible Film Initiative (USFFI) in March as an associate member, only the second packaging manufacturer after Emerald Packaging.
Coalition members provide funding for recyclers to launch initiatives for film and flexible packaging, starting with California. These subsidies are meant to bridge the gap between the cost to recycle plastics and the price at which companies can sell the recycled material at profit.
Designing for recyclability
Most states will assign lower fees for single-material packaging to help ensure recyclability and meet recycling rate targets, a practice known as eco-modulation, Edie said.
“But it still requires trials and testing because a lot of mixed material solutions have been used by companies for many years and they have a lot of confidence in that.” For example, the brand owner may be concerned that a monomaterial package will not be strong enough.
In an annual FPA survey, members have cited the qualities “recycle ready” and “all PP or PP/PE” as top priorities since the 2023 FPA report, with “PCR” not far behind, despite the concepts taking a backseat to economic pressures in 2025, CEO Dan Felton said in March at the Sustainability in Packaging conference.
The sustainability “trend may be a momentary setback, and sustainability will likely continue to be a major driver for brand owners in the mid- and long-term future,” both globally and regionally, Felton added.
Food applications
Food packaging is a major outlet for film and flexibles, Felton said during the March conference. Flexibles represent 20% of the US packaging market – second only to corrugated cardboard – and around half of that share is used for food applications, according to FPA’s upcoming 2025 State of the US Flexible Packaging Industry Report.
Edie said building public confidence about using PCR in food-grade applications requires more analysis, to provide science-based safety data. CNG is currently testing different batches of PCR to validate its performance, as well as to determine which grades are the most compliant from a regulatory perspective, she added.
And while incorporating PCR may involve added cost, bigger companies tend to accept the business case, Edie said. “They also are facing bigger estimates on their EPR fees, and big brands feel they are going to be the ones called out if they’re not compliant, more than small companies,” she said.
That higher profile position results in bigger brands employing rigorous processes to ensure product safety, which “doesn’t happen overnight,” she said. As an example, she visited a key PCR supplier’s factory to conduct food safety audits and check that the applicable US FDA Letter of New Objection (LNO, or NOL) meets full compliance standards, and to follow up with extensive lab testing on the PCR.
“Regulators are very well-intentioned and the NGOs have their point of view, which I completely understand,” but goals often collide with the practical realities when executed at the retail level, she said.
One example is California’s SB 343, known as the “truth in labeling” law, scheduled to take effect Oct. 4, but in mid-March an industry coalition filed suit, seeking to block enforcement.
FPA said in a March 17 statement that flexible packaging used in a wide range of consumer goods including food and household products helps to preserve and protect products and provide convenient packaging solutions. “SB 343 restricts our ability to provide important recycling information and relies on standards that do not always reflect real world recycling conditions,” the organization said in the statement.
Prior to the filing, Felton said at the March conference that FPA – which is part of the coalition – “generally opposes state-led compostability and recyclability labeling laws due to interstate commerce issues unique to packaging manufacturing and product distribution.” While FPA supports the PACK Act and other federal initiatives, it opposes “most” recycled content mandates proposed so far “because we don’t think they’re thoughtful or mindful of the unique challenges around flexible packaging.”
He noted that laws treat films and flexibles inconsistently – for example, Oregon supports collection depots and alternative methods while California’s approach is to ban these formats. Like many recycling stakeholders, FPA is seeking harmonization among the various state-level packaging laws.
Collaboration to balance sustainability, performance
With some stakeholders opting to pursue paper-based alternatives for flexible packaging, Edie said there’s room for collaboration, to ensure materials are both sustainable and practical.
“We don’t want to increase food waste as we try to reduce the packaging and wind up shortening the shelf life of a product,” she said. “That’s where industry could provide more data, like how this material extends shelf life by so many days. So I think as an industry, we may say those things, but we need the data to take to the regulators. We want to be science-based.
“Could paper packaging have a film lining for food safety reasons, so there’s some source reduction but still is meeting the needs of the product? Those are the kinds of things where meeting in the middle is actually some of the great opportunities that exist here,” she said.
“If the industries can come together, that’s probably where the greatest opportunity is.”
