Post-Consumer Recycled Content (PCR) Guide

August 2026

POST-CONSUMER RECYCLED CONTENT (PCR) GUIDE Understanding PCR requirements, material options, performance considerations, and the questions to ask before making a packaging decision

gamer@gamerpackaging.com

612.788.4444

www.gamerpackaging.com

1

TABLE OF CONTENTS INTRODUCTION

3

KEY TAKEAWAYS

4

WHAT IS PCR?

5

WHY DOES PCR MATTER TO CPG BRANDS?

6

PCR PLASTIC REGULATIONS

7

WHAT DOES THIS MEAN FOR NATIONAL CPG BRANDS?

8

UNDERSTANDING PCR MATERIALS

9

PCR & EPR

12

PCR PLANNING CHECKLIST

13

2

INTRODUCTION Post-consumer recycled resin, or PCR, is becoming an increasingly important consideration for CPG brands. As state requirements evolve and sustainability goals become more integrated into packaging decisions, brands are looking beyond virgin resin to understand how recycled content can fit into their packaging strategy.

But choosing PCR isn't as simple as selecting a recycled-content percentage.

The type of PCR, percentage used, color, sorting, processing method and availability can all influence the final package. These factors can affect appearance, consistency, performance and cost, making it important to evaluate PCR as part of the entire packaging solution.

This guide breaks down the fundamentals of PCR and the key considerations CPG brands should understand before specifying recycled content for their packaging.

3

KEY TAKEAWAYS PCR is more than a sustainability initiative. For CPG brands, recycled content can have implications for regulatory compliance, packaging performance, appearance, sourcing and cost.

PCR REQUIREMENTS ARE ALREADY IN EFFECT Five states currently mandate PCR percentage requirements for certain plastic packaging applications, and several have established phased increases in required recycled content.

NOT ALL PCR IS CREATED EQUAL Different types of recycled resin can vary in color, consistency, sorting and processing characteristics.

CLEAR AND GRAY PCR OFFER DIFFERENT BENEFITS AND TRADEOFFS Clear PCR is highly sorted and mostly transparent, making it well suited for applications where product visibility is important. Gray PCR can incorporate a broader mix of recycled plastics and may be a better fit for opaque applications.

THE BEST PCR STRATEGY STARTS EARLY Understanding your requirements before packaging specifications are finalized can help you evaluate material options, manage potential tradeoffs and plan for future requirements.

4

WHAT IS PCR? Post-consumer recycled resin (PCR) is made from plastic products and packaging that have already been used by consumers and recovered for recycling.

Rather than becoming waste after their initial use, these materials are collected, processed and converted into recycled resin that can be incorporated into new plastic products and packaging.

PCR can be made from materials such as PET, HDPE, and PP. Using recycled resin can help reduce reliance on virgin plastic while keeping recovered materials in use longer. PCR can also require less energy to produce than virgin plastic, which can contribute to a lower carbon footprint.

RECYCLED RESIN

NEW PACKAGING

CONSUMPTION

PCR LIFECYCLE

PROCESSING

COLLECTION

PCR VS. VIRGIN RESIN PCR and virgin resin each have characteristics that need to be considered based on the application. CPG brands should determine what combination of recycled and virgin material best meets their regulatory, performance, appearance, sustainability and cost requirements.

VIRGIN RESIN

PCR

Made from new raw materials

Made from recovered post-consumer material

Typically consistent in comparison

Can have greater material variation

Established processing characteristics

Requires consideration for variations in both performance and aesthetics

Does not contribute to recycled content percentage

Adds recycled content to the finished package

5

WHY DOES PCR MATTER TO CPG BRANDS? REGULATORY REQUIREMENTS

SUSTAINABILITY GOALS

PACKAGING STRATEGY

Some states have established minimum recycled-content requirements for certain plastic packaging applications. These requirements can increase over time, making it important for brands to understand both current and future obligations.

PCR helps keep recovered plastic materials in circulation and can reduce the need for virgin plastic. The use of recycled resin can also reduce energy consumption and emissions associated with producing new plastic materials.

PCR can also become part of a broader packaging strategy that considers material selection, sourcing, cost, supply availability and brand positioning.

6

PCR PLASTIC REGULATIONS If your products are sold across multiple states, PCR requirements may already be affecting your packaging strategy. Five states currently mandate PCR percentage requirements for certain plastic packaging applications. And those requirements aren’t static.

Several states have established phased increases in required recycled content.

STAT E

L EG I S L AT I O N

P R O D U C T CAT EG O RY

P C R R EQ U I R E M E N T T I M E L I N E

CA L I F O R N I A

(AB 793)

Glass & plastic beverage bottles

15% (2022) → 25% (2025) → 50% (2030)

Exemptions apply*

(SB 235)

Rigid plastic packaging containers

25% (1995)

(SB 690)

Trash bags

10% (1998)

(SB 5022)

Plastic beverage bottles

15% (2023) → 25% (2026) → 50% (2031)

(SB 5022)

Plastic wine containers (187 mL); Dairy milk containers

15% (2028) → 25% (2031) → 50% (2036)

(SB 5022)

Plastic household cleaning & personal care products

15% (2025) → 25% (2028) → 50% (2031)

(SB 5022)

Plastic trash bags

10% (2023) → 15% (2025) → 20% (2027)

(SB 5323)

Reusable carryout bags

40% (2022)

NEW JERSEY

(S2515)

Plastic beverage containers

15% (2024) → +5% every 3 years → 50% final target

Food containers exempt until 2027*

(S2515)

All other rigid plastic containers

10% (2024) → +10% every 3 years → 50% final target

(S2515)

Plastic carryout bags

20% (2024) → 40% (2027)

Varies by bag thickness*

(S2515)

Plastic trash bags

5-20% (2024) → 10-40% (2027)

MAINE

(LD 1467)

Plastic beverage containers

25% (2026) → 30% (2031)

CO N N EC T I C U T

(HB 6664)

Plastic beverage containers

Report required by end of 2023; 25% (2027) → 30% (2032)

WAS H I N GTO N

Disclaimer: This is not legal advice. PCR requirements can change and may vary based on packaging type, exemptions and other factors. Always verify current requirements before making compliance decisions or finalizing packaging specifications.

7

WHAT DOES THIS MEAN FOR NATIONAL CPG BRANDS? If your products are sold across multiple states, a requirement in one state can influence your broader packaging strategy.

Brands may need to evaluate whether it makes more sense to: Develop packaging specifications that meet the highest applicable requirement Create different packaging specifications for different markets Increase PCR content over time as requirements change Adjust packaging materials or formats Work with a packaging partner to source compliant material options These decisions can affect more than the package itself. They can also influence sourcing, inventory, production, warehousing and supply chain complexity.

That's why PCR planning should happen early in the packaging development process.

8

UNDERSTANDING PCR MATERIALS When discussing PCR, one of the first numbers brands typically consider is the recycled-content percentage. A package might contain 15%, 25%, 30% or 50% PCR, for example. But the percentage alone doesn't tell the whole story.

Two packages containing the same percentage of PCR can have different appearance and performance characteristics depending on the type and quality of the recycled material being used. The right PCR percentage is the one that meets the needs of the application while balancing regulatory, sustainability, performance and commercial requirements.

P C R E VA LUAT I O N CO N S I D E RAT IO N S

M AT E R I A L T Y P E The PCR needs to be compatible with your packaging material, such as PET or HDPE.

P C R Q UA L I T Y A N D S O R T I N G More highly sorted PCR can provide greater consistency and, in some applications, a clearer appearance.

R ECYC L E D - CO N T E N T P E R C E N TAG E Higher PCR percentages can help meet regulatory or sustainability goals but may also affect appearance and material characteristics.

CO LO R A N D A P P E A RA N C E PCR can influence color, transparency and visual consistency, making it important to match the material to your package design.

P R O C E SS I N G C H A RAC T E R I ST I C S Different PCR formats can behave differently during manufacturing.

P E R F O R M A N C E R EQ U I R E M E N TS PCR needs to meet the structural and functional requirements of the finished package, not just its recycled-content target.

9

CLEAR PCR

G RAY P C R

Clear PCR is made from highly sorted post-consumer plastics and is mostly transparent.

Gray PCR incorporates a larger mix of recycled plastics or a higher percentage of PCR without extensive color sorting.

It is particularly sought after for: Premium packaging Applications where product visibility is important Packaging where maintaining a clear appearance is a priority

As a result, it can have: A slightly gray or yellowed tone A more speckled finish Greater visible variation

Clear PCR is generally the most expensive form of PCR and is typically available in clear PET. It can also develop a slight gray or yellow tint at higher PCR content, particularly above approximately 35%.

BEST SUITED FOR Brands where transparency, product visibility, and premium appearance are priorities.

For opaque packaging, these characteristics may be less of a concern. In some cases, brands can even embrace the natural appearance of recycled material as part of their sustainability story.

Another option is to use PCR as a core layer within a multilayer package, with virgin material used on the exterior and interior layers. This can help minimize many of the appearance issues associated with recycled material.

BEST SUITED FOR Opaque applications or brands that are comfortable incorporating the natural visual characteristics of recycled material into the package.

10

P C R P E L L E TS PCR pellets are pure PCR resin made from 100% recycled material. They can be mixed with virgin resin to achieve different recycled-content percentages in the finished package.

POTENTIAL BENEFITS Allows flexibility in PCR percentage Enables high levels of recycled content Can be customized by blending with virgin resin CONSIDERATIONS May require machine tuning Can be less consistent than pre-mixed PCR May introduce greater material variation

P C R P R E M IX PCR premix is a pre-compounded resin in which the supplier has already blended PCR and virgin plastic at a specific ratio.

This can minimize some of the material variation and degradation associated with pure PCR. Premix can also run comparably to standard virgin resin and provide more consistent color and structural performance.

POTENTIAL BENEFITS More consistent material composition Easier integration into production More consistent color More consistent structural performance Can run similarly to standard virgin resin

11

PCR & EPR Extended Producer Responsibility, commonly referred to as EPR, adds a crucial element to the discussion around packaging costs. EPR is an environmental policy that holds manufacturers and brand owners financially and operationally accountable for managing their products and packaging at the end of their life cycle. By transferring waste management costs from local governments and taxpayers to producers, EPR aims to encourage environmentally friendly product designs and minimize overall waste.

KEY ASPECTS OF EPR PROGRAMS Some EPR initiatives implement eco-modulation, which means fees can fluctuate based on the packaging's characteristics and its environmental impact.

For brands affected by relevant EPR programs, it is essential to assess whether incorporating recycled content and other packaging features could affect the overall economics of their packaging choices.

However, it’s important to note that EPR programs can vary significantly by jurisdiction, and the treatment of PCR may differ as well.

THE TAKEAWAY Do not evaluate PCR solely based on the cost per pound of resin. Instead, consider the broader implications on your total packaging economics, which should include factors like material, processing, compliance, and relevant EPR considerations.

12

PCR PLANNING CHECKLIST Use this checklist to evaluate your brand’s current packaging strategy.

REGULATORY ☐ We know which states and PCR requirements apply to our products. ☐ We've identified upcoming recycled-content requirements. ☐ We've reviewed applicable exemptions. ☐ We've considered whether our current packaging specification will meet future requirements.

MATERIAL ☐ We've identified the appropriate plastic material. ☐ We've evaluated available PCR percentages. ☐ We've discussed available material grades with our packaging supplier.

APPEARANCE & PERFORMANCE ☐ We've established our acceptable appearance requirements. ☐ We've determined how important product visibility is. ☐ We've considered structural and processing requirements. ☐ We've trialed the selected PCR specification where appropriate.

SUPPLY CHAIN ☐ We've confirmed PCR material availability. ☐ We've evaluated supply consistency. ☐ We've considered our expected volume requirements. ☐ We've developed a plan for future increases in PCR requirements.

COST & COMPLIANCE ☐ We've compared PCR and virgin resin costs. ☐ We've evaluated applicable EPR considerations. ☐ We've considered the total cost of the packaging solution.

13

YOUR PACKAGING PARTNER At Gamer Packaging, we can help you evaluate supplier options, PCR percentages, packaging performance, and sourcing considerations to identify a solution that fits your product and business goals. With a deep understanding of industry trends and sustainability practices, our team is committed to guiding you through the complexities of packaging selection. Whether you are looking to enhance the eco-friendliness of your packaging or need advice on the latest innovations, we offer tailored recommendations that meet your specific requirements.

READY TO EVALUATE YOUR OPTIONS? Our expertise ensures that you not only achieve optimal performance but also remain competitive in the ever-evolving market. Let us partner with you to craft a packaging strategy that embodies your brand’s values and supports your growth objectives.

VALUE-ADDED SERVICES Gamer Packaging, Inc. is a full-service packaging distributor with over 39 years of experience. Our services range from initial packaging design and sourcing to delivery at manufacturing and co-packing facilities, covering all your supply chain needs.

Sourcing Design & Engineering

Decorating Services Warehousing & Logistics

Quality Assurance Financing

WO R K W I T H O U R PAC KAG I N G E X P E R TS gamer@gamerpackaging.com

612.788.4444

www.gamerpackaging.com

Disclaimer: The information in this Guide is provided for general informational purposes only and is based on information available as of the date of publication. Regulations, recycled-content requirements, industry standards, and other packaging requirements may change and vary by state, product, and application. This Guide is not a substitute for reviewing current applicable regulations or standards and should not be construed as legal, regulatory, or technical advice. Readers with specific questions should consult the applicable regulatory authorities or qualified professionals. Each brand is responsible for determining and complying with the requirements applicable to its products and packaging.

14