It’s time to start preparing your packaging for the CA SB54 EPR deadline for extended producer responsibility regulations.

Claire Sand

February 27, 2024

3 Min Read
A. Ventrella

At a Glance

  • Prioritize food-waste prevention for lower EPR fees
  • Consider preservation changes to reduce EPR fees responsibly
  • Eliminate chemicals of concern for a circular economy

"The time is always right to do what is right." –Martin Luther King, Jr.

Extended producer responsibility (EPR)-forward food packaging can only decrease the environmental impact of our food system if we continue to “do what is right” and are guided by food waste prevention, preservation options, and chemicals that are of concern. 

For the next eight years, before the CA SB54 EPR 2032 launch, brands will have the opportunity to reduce EPR fees by cost-effectively balancing operational and value chain changes. EPR has been covered frequently at Packaging Digest.

Let’s explore the rationale for these three guidelines.

1. Keep food-waste prevention centerstage: Preventing food waste may decrease EPR fees.  We can waste less food and less packaging by preventing food waste.  By reducing food waste within packaged food, EPR fees can be significantly lowered because less packaged food will need to be trashed.  For example, if fresh packaged spinach wastage were reduced from the current 59%, fewer packages would need to be paid for with the EPR scheme. Technologies such as modified atmosphere packaging may increase per-package EPR fees but result in lower overall EPR fees and overall environmental impact.  This is especially true in areas with high food waste, such as produce.  Further, more sustainable packaging has a role, but perspective is essential — packaging generates about 80% less greenhouse gases than food waste.

2. Include food preservation in solutions: A change in preservation methods can lower EPR fees but alter the environmental impact of packaged food.  Freezing food for preservation has a high environmental impact, and frozen foods often require less packaging barrier properties; thus, a package reduction can occur in the conversion from shelf stable to frozen food even though the environmental impact of the food from farm to farm will increase.  Alternatively, if food packaging is restricted to the point that lower-impact processing and product solutions are not viable, an increase in environmental impact may occur.

3. Address chemicals of concern: Critically, packaging will not be considered recyclable if it contains certain chemicals above threshold levels, such as per- and polyfluoroalkyl substances aka PFAS. A partnership with suppliers is essential in eliminating chlorine-based chemistry, bisphenols, benzophenone, toluene, and the many chemicals of concern. The packaging industry is making great strides in this effort (Sand, 2024).

Eliminating chemicals of concern from packaging will fuel a more circular economy since packaging can be safely recycled and used in more applications. Importantly, in the food industry, the U.S. Food and Drug Administration (FDA) governs the use of recycled content in direct food contact by condition of use and food types. Recycled plastics approved for direct contact with food are easily determined through the FDA database. We can recycle more and use more recycled content by addressing chemicals of concern and building tighter chains of custody.

Keeping these three guidelines in mind will ensure our progress on major packaging material science, design, and value chain innovation will achieve a more sustainable food system. 

About the Author(s)

Claire Sand

Packaging Technology and Research

Claire Sand, PhD, has 30+ years of experience in industry and academia. She is owner of Packaging Technology and Research and Gazelle Mobile Packaging and an Adjunct Professor, CalPoly, Michigan State University, and the University of Minnesota. You can reach her at or using the email below.

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