I spent most of last week buried in our packaging compliance audit — cross-referencing SKU-level material data against California's draft definitions under SB 54. Our sustainability lead forwarded me a NERC webinar summary with a note that read: "You need to understand what this means for our vendor list." She wasn't wrong.
For context: I manage packaging procurement and compliance for a mid-size CPG company. In the eight years I've tracked our packaging spend — roughly $1.2M annually across 10 suppliers — I've never seen a regulatory deadline reshape the conversation around a single material class as fast as what's happening with flexible film right now.
The numbers behind the urgency are stark. CalRecycle currently estimates the recycling rate for flexible and film packaging in California at less than 5%. SB 54 requires 65% of single-use plastic packaging to be recycled by 2032. That gap is not a gentle slope — it's a cliff. And the industry is staring at it with infrastructure that simply isn't ready.
Where the system breaks down
If you're not deep in the recycling supply chain, it's easy to assume flexible film recycling is just a matter of putting more bins out. The reality is far more layered — and far harder to solve.
Right now, most film collection relies on store drop-off programs. Despite 20-plus years of these programs, consumer confusion remains the norm. People don't know what qualifies, what doesn't, and where the material actually ends up. Kyla Fisher from the Flexible Film Recycling Alliance put it bluntly in that NERC discussion: if consumers still can't navigate drop-off after two decades, what does that mean for curbside ambitions?
The collection gap is only the first layer. When film does make it to a MRF, the economics get ugly. The material is lightweight, often contaminated, and prone to getting lost in the paper stream. Most of the film entering MRFs today arrives incidentally — wishcycled by well-meaning consumers — rather than through intentional collection channels. Maite Quinn-Richards from the US Flexible Film Initiative has been vocal about this: MRFs need operational subsidies to make film processing viable right now, because the market math simply doesn't work on its own.
I've seen this dynamic play out in our own supply chain conversations. One of our converters told me flatly that they've considered adding film recovery capability, but without guaranteed downstream offtake contracts, the capital investment doesn't pencil out. And reclaimers won't build capacity without assured supply. It's a chicken-and-egg problem that EPR deadlines are now forcing to a resolution.
The scale nobody's ready for
Here's the number that stuck with me from the webinar: Shannon Bouton from Delterra estimated that SB 54 implementation could trigger a "massive injection" of post-residential PE film into the system — somewhere between 400,000 and 800,000 tons. That's an order-of-magnitude increase over current volumes. The system as it stands doesn't have the converters, reclaimers, or end-market capacity to handle it.
To put that in procurement terms: imagine your annual packaging spend suddenly needed to allocate 30-50% of its material sourcing to recycled content that barely exists as a commercial-grade supply today. That's the kind of disruption we're looking at.
Some of this is already in motion. CalFFlex, the initiative led by The Recycling Partnership, is running pilot projects with MRFs and secondary sorting facilities in California. The approach is practical — test loads, technical assistance, capital support — and it's designed to have data ready before EPR compliance goes live in 2027. But "pilot" and "at scale" are very different things, and the timeline is short.
What's actually being done
Three parallel tracks are emerging, and I think they're all worth watching if you're on the procurement side of this equation.
First: collection pilots targeting mid-sized generators. FFRA is launching two pilots in California this summer focused on small and mid-sized enterprises — schools, small retail, facilities that generate consistent film volumes but lack recycling logistics. The goal is to test reverse logistics that don't rely on costly milk-run models. Results expected sometime in 2027.
Second: MRF subsidy models. USFFI is pushing for operational subsidies that make film processing economically viable for MRFs today, not five years from now. The logic is straightforward: if MRFs can't afford to sort it, none of the downstream solutions matter. Quinn-Richards has been pushing for more formalized downstream contracts to create the predictability MRFs need to invest.
Third: end-market development. Delterra's pilot, backed by Amcor and Kraft Heinz with technical support from Eunomia, is testing recycled flexible film resin in new product applications — things that currently don't use it at scale. The goal isn't just to prove it's technically possible, but to quantify what percentage of recycled content is workable and what financial support would be needed to scale it. Bouton described it as building the underlying business case. I think that's exactly the right framing.
What this means for packaging procurement
If you're managing packaging spend or supplier relationships, here's what I'd be tracking:
First, the material cost impact is coming. If SB 54 drives a surge in post-residential PE film into the supply chain, the cost of recycled content — and the infrastructure needed to process it — will eventually show up in pricing. It's not a question of if, but when.
Second, supplier qualification criteria are shifting. The converters and reclaimers that are investing in film recovery capability today will have a competitive advantage when compliance deadlines hit. I've already started asking our key suppliers about their film recycling investments. The ones who can't answer are the ones I'm watching most carefully.
Third, the data transparency push is real. Fisher made a point that stuck with me: if consumers can't trust that their film is actually being recycled into new products, the entire system loses credibility. That means better data-gathering, better traceability, and better communication about what's actually happening to the material. From a procurement perspective, that translates to new documentation requirements in supplier contracts.
I don't pretend to have a neat answer to any of this. The system is not set up to handle what's coming, and no single pilot or subsidy program will fix it overnight. But watching the pieces come together — the pilots, the funding commitments, the policy pressure — I'm more convinced than ever that the next 18 months will determine whether the U.S. film recycling market becomes a real industry or remains a well-intentioned experiment.
From where I sit, the smart move is to start asking the hard questions now, not when compliance deadlines leave no room for alternatives.
