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.
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.
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 rule | What it means |
|---|---|
| Design in one polymer family | Mono-material is rewarded. Mixed and multilayer constructions are penalized. |
| Prefer clear or light PET | Clear 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 resins | PVC 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 separable | Closures, pumps, labels, sleeves, and liners are recyclability-determining, not accessories. Metal springs and full-body sleeves are flagged. |
| Clear the small-format test | Parts 2 inches or under in two dimensions must pass APR's size-sortation protocol or they fall through MRF screens. |
| Keep inks and coatings compatible | Heavy inks, dark pigments, and wash-resistant coatings can contaminate the recycled stream and interfere with optical sorting. |
| Put real recycling instructions on-pack | How2Recycle 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
| Feature | U.S. recyclability | Fee consequence | Status |
|---|---|---|---|
| PVC / PVDC | Non-recyclable | No recyclability credit; elimination-list material | confirmed |
| Carbon black / NIR-undetectable dark | Non-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 values | signaled |
| PETG (rigid and full-body sleeves) | Contaminates the PET stream | Degrades the host container's recyclable determination | confirmed |
| PS / EPS | Very low recyclability | No recyclability credit; targeted by state bans | confirmed |
| Full-body non-perforated shrink | Detrimental; hides the host resin | Design-based malus risk in Colorado | signaled |
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.
| Layer | Question it answers | Set by |
|---|---|---|
| Design | Is it built so it can be recycled? | APR Design Guide (RecyClass in the EU) |
| Access to recovery | Is it collected, sorted, reprocessed, and sold into an end market? | How2Recycle / SPC four-criteria definition |
| Legal determination | May 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 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 label | What it signals |
|---|---|
| Widely Recyclable | Curbside access for most of the population (PET bottles, HDPE bottles, aluminum cans). The outcome to design toward. |
| Check Locally | Collection is inconsistent and depends on the community (PP tubs, aseptic cartons). |
| Store Drop-Off | Not curbside; returned to retail collection (PE film, bags, air pillows). |
| Not Yet Recyclable | No 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 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 rule | What 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 color | All 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 glass | The container-glass chemistry that North American curbside streams collect. Borosilicate, opal, and aluminosilicate glasses contaminate the cullet. |
| Treat metallization as chemistry | Metallic 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 formats | Containers 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.
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 rule | What it means |
|---|---|
| Keep it uncoated and clean | Uncoated paperboard is recyclable in California at about 30%; OCC corrugated at about 68%, the strongest recyclable secondary pack. |
| Avoid plastic coatings and lamination | California 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 board | Solid metal foil and heavy metallized decoration move fiber toward non-recyclable, the same coverage logic as plastics (see Decoration below). |
| Cartons are a separate stream | Aseptic 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 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 rule | What it means |
|---|---|
| Keep it mono-metal | Only metallic aluminum counts as recyclable value. Laminates are defensible (the plastic burns off in reprocessing) but true mono-aluminum maximizes recovered weight. |
| Eliminate | PFAS 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 barrier | State-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 access | The 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 can break recyclability, the rules differ by material, and metallization is governed by amount and type.
| On | Rule | Status |
|---|---|---|
| Plastic | Solid 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 |
| Glass | Judged 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 |
| Metal | Vapor-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.
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.
| Format | CA recyclable? | Recycling rate | Read |
|---|---|---|---|
| Clear PET bottle | Yes | 16% | Among the highest California plastic rates, and still low |
| Colored or pigmented PET | Yes | 5% | Pigment cuts the real rate to a third of clear |
| HDPE bottle | Yes | 19% | Among the highest California plastic rates |
| PP jar | Yes | 2% | 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 pouch | No | ~5% | Not on the recyclable list; store drop-off is the likely main route, not curbside |
| Multi-material laminate | No | under 2% | Redesign or take-back |
| PS / EPS | No | under 1% (EPS); under 2% (solid PS) | Eliminate |
| PVC / PVDC | No | insufficient data | Contaminant |
| Paperboard poly-coated on both sides | No | under 6% | Do not claim recyclable on board poly-coated on both sides |
| Uncoated paperboard | Yes | 30% | The defensible recyclable carton |
| Corrugated | Yes | 68% | Strongest recyclable secondary pack |
| Glass bottle or jar | Yes | 65% | Opaque coatings can cause rejection at the optical sorter (glass study) |
| Aluminum, non-aerosol | Yes | under 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).