The Recycling Partnership: Policy pressure mounts for PET thermoforms as US states enact EPR 

As more US states pass EPR legislation, PET thermoforming faces policy challenges, with some states labeling them “unrecyclable” due to a lack of end markets where the recycled materials can be turned into new products. 

However, with targeted investment, PET thermoforms have the potential to be added back to recycling lists as more US states roll out EPR, improving the material’s acceptance across the country, according to Katherine Huded, The Recycling Partnership’s executive director of Material Systems.

Packaging Insights sits down with Huded to explore the current recycling environment for PET thermoforms in California and the strategies that could drive end market solutions.

What are PET thermoforms? 
Huded: PET thermoforms are created by molding a heated plastic sheet into its desired form. They are used for packaging like berry and salad containers, cold cups, cosmetic and toy packaging, and clamshell to-go containers. The packaging is popular because it is lightweight and offers good product protection, especially in food-grade applications. 

What are the primary barriers to recycling PET thermoforms in the US? 
Huded: PET thermoforms and PET bottles don’t share the same recycling outcomes — only 14% of the nearly 1.5 billion pounds of PET thermoforms generated each year make it through the system. This low rate is the result of challenges across the recycling system, but those challenges point to real, system-wide opportunities for meaningful improvement. 

Producers are encouraged to disclose information about grocery packaging design and the use of recycled content.One challenge is that reclaimers — facilities that clean and break down plastic to be made into new items — have limited capabilities and capacity in North America to process thermoforms. According to our estimates, only about 30% of PET reclaimers are set up to effectively process thermoforms. This results in material loss during the process due to differing material properties, methods of reprocessing that are optimized for bottles. The loss equates to losing millions in economic value each year. 

This material loss challenge, coupled with softening demand for domestic thermoform-derived recycled content and gaps in access and participation in residential recycling programs, is an urgent opportunity to address the fact that seven US states have passed EPR legislation. State programs take a wide variety of factors and supply chain data into account when determining their statewide “accepted for recycling” lists. Failure to comply can mean higher fees for companies at a minimum, or potentially packaging bans. 

For example, Oregon, which is rolling out its program in 2025, did not include thermoforms on its statewide acceptance list. This policy compliance threat is significant, as other states begin to work toward implementing their own programs. 

How is The Recycling Partnership’s PET Recycling Coalition addressing the end markets’ inadequacy for recycled PET thermoforms?
Huded: The partnership launched the PET Recycling Coalition in 2022, building upon years of expertise and interventions to improve the recyclability of PET. While The Partnership’s book of work will continue to include efforts to increase recycling for PET bottles, the Coalition is laser-focused on actions now to ensure the success of PET thermoforms in recycling in this new policy landscape. We are tackling this through a three-part strategy that includes:Increasing thermoform acceptance across the recycling system can be paired with clear community communication to ensure residents know exactly what can be recycled.

• Granting strategic reclaimers in North America to provide equipment that helps better processing of bottles and thermoforms together, or would allow for bottles and thermoforms to be processed separately
• Building an industry network to drive collective action through producer commitments around designing thermoforms for recycling and demanding domestic postconsumer recycled content made from thermoforms (which could be supported through fee incentives in the future)
• Increasing community acceptance where MRFs accept PET thermoforms, supported by educational practices to improve recycling behavior

One example of our work in action can be seen at Ice River Sustainable Solutions (IRSS), a bottling supplier in Ontario, Canada. IRSS is tackling a key issue for PET reclaimers: processing mixed loads of PET bottles and thermoforms. Supported by The Partnership’s PET Recycling Coalition, IRSS has optimized its operations to utilize as much PET thermoform material as possible, helping to create a new end market for a material that doesn’t often make it into recycled products. 

Why is optimizing reclaimer capacity essential for improving PET thermoform recycling? 
Huded: Reclaimers’ operations are often designed to handle PET bottles but not optimized for thermoforms — which have different properties — and therefore can pulverize the material after processing, resulting in yield loss. With the increasing volume of thermoforms in commingled PET bottle bales, investment in PET reclaimers can deliver the necessary expansion and technology needed to better process this material without losing so much of it. 

Paired with additional commitments from companies to incorporate thermoform-derived recycled content into products, these strategic efforts can help support a thriving network of end markets for thermoform material. This is critical to achieving long-term stability for PET thermoform recycling across the country and for companies to achieve compliance in policy states. 

What role does community engagement and education play in increasing PET thermoform recycling? 
Huded: Community engagement and education also play a crucial role in capturing more PET thermoforms — and any other recyclable materials — to pull through more material that can be made into new products. It’s why The Partnership has spent the better part of the last decade providing communities with education and outreach best practices, backed by behavioral research and data, to help people clearly understand what and how to recycle. Whether processing capability already exists or is newly available, it’s important to ensure this acceptance information is clearly communicated from the facility to community programs, and that those programs have the resources to properly educate their residents. 

What is the future outlook for PET in California, and how can it impact other states within the country? 
Huded: SB 54, California’s EPR law, has established rapid timelines and requirements for the largest US state in terms of population and packaging market share. While California’s regulatory process is still active and we await more details on implementation, we’ve seen through Oregon that there could be a potential risk for thermoforms when it comes to policy compliance. 

The PET Coalition’s new focused efforts to support PET end markets may include reclaimers in California and across North America. So far, we’ve seen strong progress in the state, with several reclaimers optimized to handle thermoforms, the establishment of a marketplace for thermoform-only bales, and a strong system that incentivizes thermoform recycling.