21 September 2026
Bay Cities’ Sara Lowe on EPR, packaging complexity and why brands need to look beyond the material itself when making sustainability decisions
As extended producer responsibility (EPR) schemes bring packaging materials, recyclability and end-of-life costs into sharper focus, brands are having to look beyond simple material choices. In this exclusive interview, Sara Lowe, Senior Executive Administrator at Bay Cities, discusses why switching from plastic to paper is not automatically a sustainability win, how packaging complexity can affect both reporting and fees, and why designing for real-world recovery is becoming increasingly important.
There’s a common assumption that moving from plastic to paper automatically makes packaging more sustainable. From your perspective, where does that thinking fall short, and what should brands be considering instead?
It treats substrate as the whole answer when substrate is only one input. What determines the environmental outcome is whether that particular construction actually gets recovered at end of life, and that depends on the coatings, liners, and adhesives on it, and on the collection system where the package is sold, in addition to whether the base material is fiber or resin.
Paper does have a real advantage. The recovery infrastructure is mature, and the end markets exist. But a fiber package with a barrier coating can perform worse than a well-chosen plastic one. Brands are better served asking whether a specific package has a recovery path than asking which material family is better in the abstract. That’s a package-level question, and the industry keeps answering it at the category level.
When brands are choosing packaging materials, how can they balance sustainability goals with the realities of recyclability, infrastructure and EPR fees?
For most decisions, there’s less tension than people expect. These programs price material against whether the infrastructure to recover it actually exists, which is close to what a sustainability team is optimizing for anyway. Fiber, PET and HDPE do well on both counts.
One place where it pulls apart is compostables. A molded fiber tray reads as the sustainable option, and it may well be, but California recycles molded fiber at about 7 percent against 68 percent for cardboard. Compostability is tracked as a separate attribute from recyclability, and access to organics collection is thinner than access to recycling. So a brand can make a defensible environmental choice and still land in a worse fee position.
My advice is to be honest about which goal you’re optimizing. If the answer is recovery, follow the infrastructure. If it’s something else, whether that is material reduction, compostability, or a specific end-of-life story, go in knowing the fee will reflect the recovery system, not the intent.
Not all plastics have the same environmental profile or recycling prospects. How should brands think differently about established materials such as PET and HDPE compared with PVC, laminates and harder-to-recycle plastics?
Treating plastic as one thing is where this can go wrong. These programs price by whether a material has a functioning market behind it, not by resin type in the abstract. PET and HDPE are collected, sorted and reprocessed at scale, so they sit in the lower fee tiers and are designated recyclable.
PVC is the opposite case. It’s the material flagged for a penalty in California’s proposed eco-modulation, because it contaminates the streams around it. Multi-material laminates and flexible film sit in between — technically recoverable, but without sorting infrastructure at scale, so they price near the top. For a sustainability team, that’s a more useful frame than plastic-bad and paper-good. What matters is whether a functioning market exists for the material once it’s discarded.
You’ve highlighted packaging complexity as an important issue. From a sustainability perspective, how much could brands gain by simplifying packaging and reducing the number of components they use?
Complexity carries an administrative cost people consistently underestimate. Every material and every detachable component is classified and reported separately, so a package built from five materials generates five sets of data to source, verify, and maintain. And specifications change, so it isn’t a one-time exercise.
The compounding problem is that most of that data lives with suppliers rather than with the brand. Each additional component is another supplier conversation standing between a brand and its filing. Companies that standardize across a product line and cut component count reduce the reporting load and the fee exposure at the same time, and they make the whole system far easier to keep current.
How is EPR changing the meaning of “sustainable packaging”? Are we moving away from broad claims about materials towards a more measurable, data-driven definition of sustainability?
It’s making the definition external. “Recyclable” used to describe a best-case scenario that could differ widely in reality from region to region. In California, it’s now a designation on a published list. A package maps to a covered material category, and that category is either designated recyclable, or it isn’t. Now the questions are which category, what weight, how much recycled content, and whether it contains a plastic component. Those have documented answers a brand either has or doesn’t.
It’s also starting to reflect jurisdictional reality. The same package can be designated recyclable in one state and not in another, because those determinations are made against local collection and sorting reality. Brands have historically wanted one sustainability story for the whole country. That’s getting harder to maintain.
Mixed-material packaging can create both recycling and EPR challenges. What should packaging designers be thinking about at the design stage to avoid creating sustainability problems further down the line?
Classification runs on dominant material by weight, with a surcharge if there’s plastic in the construction. A paperboard carton with a laminated film window stays in the fiber family, but it moves into the “with a plastic component” category, which can be several times the plain fiber rate, and it loses compostable status. If the window is designed so a consumer can remove it easily, it is classified on its own, with the carton assessed as plain fiber.
Are there situations where switching from plastic to paper could actually result in a worse sustainability outcome once factors such as material use, weight, transport, recyclability and end-of-life are considered?
Fiber is usually heavier and bulkier than the plastic it replaces. Weight is the straightforward part — fees are assessed per pound, so a low rate on a package weighing two or three times as much may not be a savings, and every one of those pounds burns fuel across the full distribution network.
Additionally, getting the same protection out of fiber generally takes more thickness, so the same product ships in a larger case. That means fewer cases per pallet, fewer pallets per trailer, and more trailers to move the same volume of product. Most consumer goods freight cubes out before it weighs out, so volume tends to be the binding constraint, and that penalty repeats on every lane for as long as the package exists.
EPR is doing something valuable: it makes end-of-life cost visible and puts it on the brand that created it. The fee schedule was never designed to be a full sustainability assessment. It’s an accountability lever, not the totality of a brand’s sustainability story. So run the freight numbers alongside the fee math and let the two inform each other instead of letting either one decide on its own.
How much influence do you think EPR fees will ultimately have on packaging design? Could they become a meaningful financial incentive for brands to eliminate unnecessary materials and design for circularity?
Fiber is usually heavier and bulkier than the plastic it replaces. Weight is the straightforward part — fees are assessed per pound, so a low rate on a package weighing two or three times as much may not be a savings, and every one of those pounds burns fuel across the full distribution network.
Additionally, getting the same protection out of fiber generally takes more thickness, so the same product ships in a larger case. That means fewer cases per pallet, fewer pallets per trailer, and more trailers to move the same volume of product. Most consumer goods freight cubes out before it weighs out, so volume tends to be the binding constraint, and that penalty repeats on every lane for as long as the package exists.
EPR is doing something valuable: it makes end-of-life cost visible and puts it on the brand that created it. The fee schedule was never designed to be a full sustainability assessment. It’s an accountability lever, not the totality of a brand’s sustainability story. So run the freight numbers alongside the fee math and let the two inform each other instead of letting either one decide on its own.
From the brands you work with at Bay Cities, what are the biggest gaps you currently see between companies’ sustainability ambitions and the practical reality of their packaging choices?
The biggest gap is organizational. The people setting sustainability goals usually aren’t the people making packaging decisions. They can influence the outcome, but the final call belongs to procurement, or operations, or whoever owns the cost line. So you get companies with genuine commitments and packaging that doesn’t reflect them, and nobody in the building is acting in bad faith.
That’s what I’m hopeful EPR changes. It attaches a number to the packaging decision, and a number travels through an organization in a way a sustainability argument doesn’t. When the lower-impact package is also the lower-fee package, the sustainability team stops having to win on principle every time. The incentive lines up across the decision matrix, and the choice gets made on cost grounds that happen to point in the same direction.
If a brand were redesigning its packaging today with the next five to ten years in mind, what principles would you recommend it follow to create packaging that is both genuinely more sustainable and resilient to evolving EPR requirements?
Build the data foundation first. Every program asks for the same underlying facts about each SKU so that work holds its value regardless of which states move next.
Then design for recovery rather than for material story: fewer components, materials with real end markets, and construction that comes apart cleanly. And don’t wait for the rules to settle before acting. The companies handling this well aren’t the ones who guessed the regulation correctly. They’re the ones who knew what was in their packaging before they had to.
Read the full article: Beyond Paper vs Plastic: Designing Packaging for Real-World Recovery – Sustainable Packaging News
