2025 Packaging Regulations Outlook
The calendar flip from 2024 to 2025 heralded several new packaging regulations, rulemaking updates, and bills with significant implications for consumer packaged goods in North America and Europe.
Recent packaging legislation is reshaping packaging requirements for waste reduction, recyclable materials, circularity, and sustainability. However, actions by the Trump Administration may defer regulatory action at the U.S. federal level and shift packaging-related policies.
EPR Packaging Laws
Five U.S. states—California, Colorado, Oregon, Maine, and Minnesota—have passed extended producer responsibility laws for packaging. While each state's requirements vary, they share common goals of reducing packaging waste, enhancing recycling efforts, and holding producers (e.g., brand owners) accountable for the life cycle of their products.
Since the start of the year, 10 states have introduced or re-introduced EPR packaging bills. They include Washington, Tennessee, Hawaii, New York, Connecticut, Nebraska, Illinois, Maryland, Massachusetts, and Rhode Island. In November 2024, New Jersey introduced the Packaging Product Stewardship Act.
Oregon
In November 2024, Oregon finalized rules for its Plastic Pollution and Recycling Modernization Act. The updated EPR packaging rules, effective July 1, 2025, added covered product exemptions and calculated the costs the producer responsibility organization (PRO) will pay to recyclers or municipalities.
By March 31, 2025, producers must pre-register with and report their 2024 supply data to the PRO. In July 2025, producers will start paying fees to the PRO, and the EPR program will begin rolling out a list of acceptable recyclable materials to help local governments and businesses determine what is and what's not suitable for recycling in the state.
Large producers (top 25) must conduct life-cycle assessments (LCA) every two years on at least 1% of the covered products (SKUs) they sell or distribute in the state. These producers must disclose LCAs for 1% of their SKUs by Dec. 31, 2026. Furthermore, any producer can voluntarily perform an LCA to receive an eco-modulation fee adjustment.
Maine
In December 2024, Maine finalized rules for the state's EPR packaging law, which will take effect in 2027. Producer payments will directly reimburse local governments for waste management costs. The amount each producer pays will correspond to the volume it generates and the recyclability or reusability of its packaging.
Producers must make 50% of their packaging "readily recyclable, reusable, or compostable" by 2030. This percentage increases to 75% by 2040 and 100% by 2050. In addition, producers must reduce the weight of their packaging by 40% by 2040 and 60% by 2050. Calculated by weight for applicable packaging materials, PCR content should be no less than 10% by 2030, no less than 20% by 2040, and no less than 30% by 2050.
Colorado
In Colorado, producers will begin reporting their packaging volume in August 2025, submitting data covering Q1–Q2 of 2025. Producer fees, based on the quantity and weight of covered materials, must be paid by Jan. 1, 2026.
California
On Dec. 31, 2024, California released two new reports—Updates to Covered Material Categories and Source Reduction Baseline Report—related to its EPR packaging law (SB 54 Plastic Pollution Prevention and Packaging Producer Responsibility Act ("SB 54")), which comes into force on or before Jan. 1, 2027.
The Updates to Covered Material Categories lists 94 categories of packaging materials and types (e.g., plastic, glass, metal, paper and fiber, ceramic, etc.), with 45 considered "recyclable" and 11 deemed "compostable."
SB 54 requires a 25% source reduction in single-use plastic packaging and food service ware by 2032. The Source Reduction Baseline Report estimated the amount (i.e., total plastic components and total weight of plastic) of single-use plastic packaging sold, offered for sale, or distributed in the state in 2023.
According to the report, more than 2.9 million tons of plastic went into producing single-use plastic packaging and plastic food service ware. Collectively, these items consisted of 171.4 billion plastic components. Using these baseline figures, the PRO must reduce single-use plastics by approximately 725,000 tons and 43 billion components by 2032.
To continue selling plastic foam food service ware in California, producers must prove that all expanded polystyrene packaging and food ware meets a 25% recycling rate as of Jan. 1, 2025.
In early March 2025, Governor Gavin Newsom directed CalRecycle (i.e., the state agency responsible for overseeing SB 54) to restart the regulations because of cost concerns for businesses and consumers. In response to Newsom's action, CalRecycle stated it will work with various stakeholders in the next 12 months to develop rules that balance the need to cut plastic pollution while minimizing costs to families and small businesses.
The 2032 deadline of reducing single-use plastic by 25%, recycling 65% of single-use plastics, and ensuring 100% of single-use packaging is recyclable or compostable remains in effect.
Minnesota
In February 2025, Minnesota selected the Circular Action Alliance (CAA) as its initial PRO to implement the state's EPR packaging law. CCA also acts the PRO for EPR packaging programs in California, Colorado, and Oregon. In Minnesota, producers must register with the PRO by July 1, 2025.
Quebec
Similar to the U.S., Canada does not have a national or federal EPR packaging law. However, EPR programs are firmly entrenched in Canada. Many Canadian provinces and territories either operate or are working on packaging-related EPR programs.
On Jan. 1, 2025, Quebec instituted new rules for package recycling, making them universal for the entire province. Under the new EPR recycling program, consumers can now dispose of various types of containers, packaging, and printed materials in the same recycling bin. Exceptions include pressurized metal containers, polystyrene protective packaging, and biodegradable or degradable plastics.
Producers are charged fees for the expanded recycling program, with lower payments for packaging that's easily recyclable, lighter in weight, constructed of mono-material, and not over-packaged.
State PCR Content Laws
Five U.S. states mandate minimum PCR content requirements in plastic packaging. They include California, Connecticut, Maine, New Jersey, and Washington. Here's a rundown of several PCR rules taking effect this year:
- On Jan. 1, 2025, the minimum amount of PCR content in beverage bottles in California increased from 15% to 25%.
- In New Jersey, manufacturers/brand owners of products covered under the legislation must submit first-year compliance reports by July 18, 2025, and annually thereafter.
- In 2025, plastic packaging for household cleaners and personal care products in New Jersey must contain a minimum PCR content of 15%. This percentage increases to 25% by 2028 and 50% by 2031.
Single-Use Plastics Rules
Several states have passed laws restricting small single-use plastic bottles for shampoos and personal care products at hotels. On Jan. 1, 2025, New York banned these mini bottles for hotels with 50 and over rooms. For hotels with fewer than 50 rooms, the ban will go into effect in 2026. California has a similar law that took effect in 2023 (larger hotels) and 2024 (smaller hotels).
On July 1, 2025, an Illinois law will ban hotels with 50 or more rooms from offering small single-use plastic personal care bottles. On Jan. 1, 2026, the law will extend to hotels with fewer than 50 rooms. Washington state has a similar law that will take effect in January 2027. In response to these regulations, several major hotel chains have voluntarily agreed to remove the mini bottles in favor of wall-mounted refillable containers.
The EU's Packaging and Packaging Waste Regulation (PPWR) came into force on Feb. 11, 2025, with a general application date of PPWR provisions on Aug. 12, 2026. The new regulation aims to prevent and reduce packaging waste (EU member states must achieve a 65% recycling rate of all packaging waste generated by Dec. 31, 2025), make all packaging in the EU market economically recyclable by 2030, increase the use of recycled content in plastic packaging, decrease the use of virgin materials, and put the packaging sector on track to climate neutrality by 2050.
The new rules include certain restrictions on single-use plastics, such as pre-packed fruits and vegetables weighing less than 1.5 kg and individual portions of condiments, sauces, and sugar in hotels, bars, and restaurants. By 2029, 90% of single-use plastic and metal beverage containers up to three liters will have to be collected via deposit-return systems or other solutions that meet the collection target. Single-use plastic beverage bottles must contain at least 30% PCR content by 2030 and 65% PCR content by 2040.
PPWR calls for packaging reduction targets of 5% by 2030, 10% by 2035, and 15% by 2040, compared to 2018 numbers. It also supports reuse models, with at least 10% reusable packaging by 2030, and 40% by 2040 in specific categories. Forty percent of transport packaging used within the EU, including e-commerce, must be reusable by 2030. This reuse requirement rises to 70% by 2040.
The EU regulation addresses EPR by strengthening producer obligations to ensure end-of-life management of packaging materials, shifting financial and operational responsibility to manufacturers and importers, and incentivizing sustainable packaging designs through eco-modulated fees.
The information contained in this article is intended for general information purposes only and is based on information available as of the initial date of publication. No representation is made that the information or references are complete or remain current. This article is not a substitute for review of current applicable government regulations, industry standards, or other standards specific to your business and/or activities and should not be construed as legal advice or opinion. Readers with specific questions should refer to the applicable standards or consult with an attorney. It is the customer’s responsibility to determine whether its filled product is subject to any applicable government regulations and to ensure compliance with such regulations.