Carton Council

The Carton Council is composed of four leading manufacturers of gable top (refrigerated)and aseptic (shelf-stable) cartons used to package food and beverages. Our members, Elopak, Novolex, SIG, and Tetra Pak, formed the Carton Council in 2009 todeliver long-term collaborative solutions to divert valuable food and beverage cartons from the landfill. Through a united effort, the Carton Council is committed to building a sustainable infrastructure for carton recycling nationwide and works toward its goals of increasing access to recycling, as well as recycling of, cartons throughout the U.S. As of February 2025, cartons have achieved 63% household access to recycling nationally.

Recommendations for Policymakers Developing Circular Policy & EPR for Packaging Policies:

1. Providing for as-needed updates to the statewide collection list. Statewide collection lists determine whether a covered material is collected for recyclingunder a state EPR program. Under EPR, the recycling system is continually evolving alongside recycling access, collection infrastructure, and processing capacity. For this reason, statute should establish a clear process by which stakeholders may submit updated information or new data reflecting operational realities. For materials that are not initially on the collection list, statute or regulation should provide an on-ramp process for adding the material to the collection list once certain targets are met. As an example, Washington’s SB 5284 (Section 70A.208.090, (2)) allows a PRO to propose a covered material for addition to or removal from the collection list through a program plan amendment. This approach ensures that the EPR program is continually responsive to recycling innovations that make it possible to improve and expand the system over time.

2. Crafting achievable performance targets based on needs assessment baseline, marketplace availability, and technical feasibility. Performance targets and goals of an EPR program should be informed by the statewide needs assessment and applied by material type. For example, Minnesota’s HF 3911 (Section 12 [115A.1451], Subd. 5) instructs the PRO to propose performance targets by covered material type, as well as the units by which to measure them, based on learnings from the statewide needs assessment. Evaluating needs assessment data, marketplace availability, and technical feasibility is especially important in the context of crafting post consumer recycled fiber content targets for food-contact packaging like cartons. Performance targets for covered packaging must be well researched to be reasonably achievable and safe for the products inside.

3. Keeping all cartons together both in collection and definition. Cartons are a valuable paper-based commodity widely collected for recycling. However, cartons make up a small part of the recycling stream, and all types must be collected together to ensure sufficient volumes in sorting and selling them to end markets.

• In an EPR system, where material categories are established in statute, aseptic (shelf-stable) and gable-top (refrigerated) cartons should be designated as a single, distinct packaging category. This is because, in practice, aseptic and gable top cartons are collected, sorted, marketed, and recycled together.

• Where DRS and EPR systems coexist, cartons are often best suited for curbside recovery through EPR. This is due to the fact that DRS programs often only include some cartons used to package beverages like coffee, tea, and water, while excluding others used to package juice, milk, soup, and other food products. Collecting all cartons through the same mechanism (curbside EPR) mitigates consumer confusion and preserves sufficient collection volumes at material recovery facilities.