A Circular Advantage: PET Thermoforms, Recycled Content, and the Path to EPR Readiness

Packaging’s circular future is rapidly coming into focus, and PET (polyethylene terephthalate, universally recognized by the #1 resin identification code) thermoforms play a pivotal role. PET thermoform packaging—things like clamshells, trays, tubs, lids, and boxes—often get overshadowed by the beverage bottle market, but did you know that in 2022 and 2023, the average level of recycled content for PET thermoforms manufactured in the US and Canada exceeded that of PET bottles?

Indeed, PET thermoforms (known as trays outside of North America) are the rising star of post-recycled content (PCR). In today’s packaging landscape, where the shift toward circularity is accelerating, this context is important. With extended producer responsibility (EPR) laws taking root across the United States, companies using PET thermoformed packaging are facing new obligations and opportunities. By acting now, thermoform stakeholders can turn regulatory pressure into a strategic advantage.

Introducing the EPR Legislation Toolkit from Plastic Ingenuity

That’s where Plastic Ingenuity’s new EPR Legislation Toolkit steps in—a resource designed to help packaging stakeholders understand, prepare, and thrive in the evolving policy environment. The toolkit offers a practical overview of how the seven states that have enacted packaging EPR laws so far have structured their EPR legislation, and what that means for producers, including registration requirements, reporting obligations, fee structures, and the risk of non-compliance.

The toolkit strongly emphasizes thermoforms as a key category for EPR strategy. Because legislation often broadly defines “covered packaging,” PET thermoforms are likely to fall under future mandates. Getting ahead by designing for recyclability, reducing virgin (new) plastic use, and boosting post-recycled content are wise moves.

What the EPR Toolkit Covers

Plastic Ingenuity frames the toolkit around three core tenets of packaging EPR:

1. Design for Recyclability – creating packaging that can be collected, sorted, and recycled effectively.
2. Source Reduction – reducing the amount of virgin/new material used in packaging.
3. Post-Consumer Recycled (PCR) Content – ensuring that packaging incorporates recycled material and closes the loop.

Crucially for PET thermoforms, the toolkit lays out specific pathways to compliance, including prioritizing PET as the most recycled (and recyclable) plastic in the world, collaborating with recyclers and reclaimers, and tracking PCR usage in packaging portfolios.

How the Toolkit Helps Thermoform Stakeholders

For those in the thermoform ecosystem—brands, converters, material suppliers, reclaimers—Plastic Ingenuity’s EPR Toolkit can help:

• Assess risk and readiness: The toolkit charts out the EPR landscape, including which states have laws, when they take effect, and what obligations apply, so you can identify your exposure and timeline.
• Design-for-recyclability playbook: Use the section on thermoforms to benchmark your packaging design and align with best practices.
• Source-reduction pathways: For thermoforms, this might mean lighter gauge materials or shifting from virgin to PCR resin. The toolkit gives strategies for documenting these efforts, which is essential under many EPR laws.
• PCR content strategy: With thermoform data showing higher average recycled content than bottles, the toolkit supports the case for investing in PCR PET. It also helps track and document PCR usage.
• Compliance planning: The toolkit prompts stakeholders to register where required, develop reporting systems, and understand fee-modulation mechanisms, aka eco-modulation, that can reward more sustainable packaging design and higher PCR content.

Why Now is the Time to Act

Waiting until the last minute is riskier than ever for thermoform stakeholders. A few reasons:

• States ramping up EPR: California, Colorado, Maine, Maryland, Minnesota, Oregon, and Washington have already enacted packaging EPR laws, and others are under consideration.
• PCR & design mandates are taking shape: For example, California will begin requiring 10% PCR content in packaging in 2027, increasing to 20% by 2030 and 25% by 2032. Canada’s 20% PCR mandate begins this year and will rise to 50% by 2030.
• Design for recyclability matters: As material streams evolve, packaging that is not designed for recyclability may face higher fees, restricted access to markets, or bans on sale in certain jurisdictions.
• Competitive advantage: Brands and converters that proactively align with circular economy metrics will be better positioned for sustainability reporting, corporate commitments, retailer requirements, and consumer expectations.

State-Specific EPR Resources

Looking for additional EPR resources? Each of the states with new or established EPR programs has produced a guide to help:

• California: https://calrecycle.ca.gov/epr/
• Colorado: https://cdphe.colorado.gov/hm/epr-program
• Maine: https://www.maine.gov/dep/waste/recycle/epr.html
• Maryland: https://mde.maryland.gov/programs/land/RMP/Pages/Extended-Producer-Responsibility-Program.aspx
• Minnesota: https://www.pca.state.mn.us/air-water-land-climate/extended-producer-responsibility-for-packaging
• Oregon: https://www.oregon.gov/deq/recycling/pages/modernizing-oregons-recycling-system.aspx
• Washington: https://ecology.wa.gov/waste-toxics/reducing-recycling-waste/our-recycling-programs/recycling-reform-act

We are also looking forward to APR’s upcoming design assessment tool.

With the release of these helpful resources, brands and converters now have an actionable framework to navigate the emerging regulatory landscape, optimize their packaging for circularity, and align with market and sustainability shifts.

A Data-Driven Boost: Thermoform PCR & Circularity

EPR is not just a regulation—it’s a leverage point to accelerate circular innovation in thermoform packaging. As additional recommended reading, our white paper, “Increasing PET Thermoform Recycling,” developed with the Circular PET Thermo-Forum, offers actionable recommendations for states to improve PET thermoform circularity through innovation, policy alignment, and industry commitments. We underscore how circularity in thermoforms depends on three pillars:

• Improving collection and sorting systems so thermoforms can be captured in dedicated streams or alongside other streams.
• Aligning policies (including EPR, recycled content mandates, and design for recyclability guidelines) to incentivize thermoform reuse and recycling.
• Ensuring industry players commit to realistic targets and collaborate across the value chain.

From Compliance to Collaboration: The Path Forward for PET Thermoforms

Circularity is a shared mission—and PET thermoforms are at its forefront. By combining policy readiness, design innovation, and collaboration across the value chain, the industry can make thermoform recycling a cornerstone of sustainable packaging. With resources like state guides, Plastic Ingenuity’s EPR Toolkit, and NAPCOR’s PET thermoform recycling white paper, stakeholders are better equipped than ever to build a future with PET packaging.