Sustainable Packaging
and EPR Support

EPR is a regulatory approach where producers are responsible for the end of life of their packaging, covering collection, recycling, and disposal costs. This policy approach shifts financial and operational responsibility for the end – of – life management of a product from local governments and taxpayers to the producer.

EPR programs for packaging are active and passed, in 7 states so far (2/20/26): California, Colorado, Oregon, Maine, Maryland, Minnesota, and Washington. This accounts for about 20% of US consumer demand.

Labels are considered non-detachable components for EPR in states like Oregon, Colorado, and California, meaning labels are part of the main package for EPR reporting and fee purposes. To ensure correct reporting, you must know the weight and material type of your label, as these details impact your EPR calculations.

California assigns packaging into categories based on whether they contain plastic components. For example, a glass jar with a plastic label is categorized as “with plastic component,” regardless of the base package material.

However, if a label is perforated and includes clear instructions for the consumer to remove it before disposing of the packaging, it will be considered a separate component for EPR reporting and fee calculation.

For more details and the latest guidance, refer to the Circular Action Alliance website and California’s specific EPR regulations.

All primary packaging—such as jars, bottles, flexible packaging, and their labels—are included if supplied into covered EPR states. In some states, secondary packaging (like boxes or wrap) may also be included, particularly if it ends up in the consumer’s hands after purchase. Additionally, certain states’ EPR programs may regulate some business-to-business (B2B) packaging, depending on local definitions of “covered products.”

Each state maintains its own list of covered packaging and products. For the most current and detailed information, visit the Circular Action Alliance (CAA) website. CAA is the Producer Responsibility Organization (PRO) administering EPR compliance for paper and packaging in most active EPR states, including California, Colorado, Oregon, Maryland and Minnesota.

Yes. Our team has an internal calculator with the most up-to-date EPR fee information, available through our customer portal.

Yes, we can review your current formats and advise on transitioning to recycle-ready solutions.

Our framework includes eliminating unnecessary packaging, lightweighting or right-sizing, moving to recycle-ready materials and designs, and increasing PCR (post-consumer recycled) content.

We can analyze your packaging, propose ways to reduce fees, review recyclability, and assist with packaging data for Reporting processes.

Ecomodulation is an approach within EPR systems where fees charged to producers are adjusted (“modulated”) based on the environmental impacts or design features of their packaging. Packaging that is easier to recycle, uses more recycled content, or is otherwise more sustainable may be subject to lower EPR fees, while less sustainable packaging may incur higher fees. The goal is to incentivize producers to design packaging that is recyclable and has a lower environmental footprint.

APR generally evaluates and recognizes packaging designs (Design® for Recyclability Recognition), not “certifying” every label by default. Whether your specific label construction meets APR guidance depends on the full label system (facestock/film, adhesive, inks/coatings, varnishes/laminates, and the package resin—PET/HDPE/PP, etc.).

If you share your current label spec (or we pull it from your job history), we can provide:

• A construction-level recyclability assessment against the relevant APR Design® Guidance, and
• Recommended changes (if needed) to align with APR’s PET/HDPE/PP guidance.
  If formal APR recognition is required, we can help you identify the right path and supporting documentation.

We can absolutely quote a switch, but cost varies based on what you’re switching from and the performance requirements (wet strength, refrigeration/condensation, scuff resistance, chemical exposure, application speed, etc.). The typical cost drivers are:

• Facestock/film change (e.g., PETG → OPS / BOPP / PE / specialty wash-off constructions)
• Adhesive change (standard permanent → wash-off / alkaline removable / recycling-compatible systems)
• Ink/coating change (ink system, pigment selection, white coverage, varnish/overlam, metallics)
• Qualification costs (press trials, line trials, bottle tests, performance validation)

Typically, timeline to switch to a preferred design is around 4 months.

Yes—Fortis actively supports recycling-aligned label constructions and can propose options designed to reduce contamination risk (adhesive cleanability, ink bleed/discoloration control, and film density/float behavior where relevant). We’ll recommend the best option based on your package resin, recycling stream, and real-world performance needs.

Yes—in many cases, floatable label constructions can be specified, but “float” depends on the film density and any layers/coatings (including heavy ink coverage) that can change overall density. We’ll evaluate:

• Package resin (PET vs HDPE/PP)
• Label film type and gauge
• Ink coverage and coatings
• Adhesive behavior in wash systems

If your goal is PET bottle recyclability, we’ll propose constructions intended to improve separation and reduce contamination, then validate the recommendation against your application and recycling objectives.

It depends on the construction you’re using today. We can specify wash-off / recycling-aligned adhesives where required, but we need to confirm your current adhesive and the PET recycling process assumptions (typical caustic wash conditions vary).

Ink behavior depends on pigments, cure system, coatings, and total coverage, and the recycling process conditions.

We can provide this at the SKU / item number level. For many programs, the exact supplier chemistry is proprietary, but we can share the ink technology type and adhesive category, for example:

• Inks: UV flexo, water-based flexo, solvent-based flexo, EB (if applicable)
• Adhesives: acrylic emulsion permanent, hot-melt rubber-based, acrylic wash-off/removable (as specified), etc.

If you need supplier-specific details for compliance, we can coordinate an NDA-supported disclosure through the material supplier.

Yes/No can only be confirmed for a specific label construction. Float behavior is a function of the film density + total construction (inks/coatings/laminates). Provide the item numbers, and we will respond with a construction-specific yes/no and recommended alternatives if needed.

Yes—we can provide label weight per SKU/size in a spreadsheet. We typically report:

• Facestock basis weight / film gauge
• Adhesive coat weight (if available)
• Release liner weight (if requested)
• Finished label weight (mass per label) and labels per roll / roll weight (if helpful)

What we need to generate it quickly:

• Item numbers (or list of sizes), material constructions, and whether you want label-only weight or label + liner weight.

Yes, shrink sleeves are considered part of the primary packaging under EPR laws and must be included in producer reporting and fee calculations.

Shrink sleeves made from recyclable, floatable, or APR-compatible films may be eligible for lower EPR fees under ecomodulation principles, while less compatible materials may result in higher fees.

Yes, inks and adhesives must be chosen carefully, as they can impact the recyclability of the package and may affect your EPR reporting and compliance.

Absolutely! We provide material recommendations, design support, and documentation to help you select shrink sleeves that will enhance recyclability and potentially reduce your EPR fees.

Yes, all flexible packaging supplied into covered states must be included in EPR reporting and fees

Flexible packaging is classified based on its materials (e.g., mono-material, multi-layer, paper laminated) for the purposes of EPR registration and fee assignment.

Rightsizing, using recyclable structures (like mono-material films), reducing non-recyclable components, and increasing recycled content are all strategies that can help minimize EPR fees through ecomodulation.

Yes, we offer guidance on transitioning to mono-material and recycle-ready films and will help you select the best structure to meet your compliance goals.

Yes, folding cartons (such as paperboard boxes) are included in EPR obligations if supplied into states with active programs.

Yes. Non-paper components (like plastic windows or laminates) must be considered for accurate categorization and may result in higher fees. Cartons made from recyclable paperboard may qualify for lower EPR fees.

We advise on eliminating unnecessary coatings or laminates, and selecting paperboard grades with high recycled content.

Absolutely! We support reporting and can provide specifications and support for compliance with state EPR programs.