Recycled Content in Flexible Packaging: What Packaging Teams Need to Know

PCR, PIR, mechanical recycling, chemical recycling, structure placement, food-contact sensitivity and claims logic

A technical deep-dive into PCR, PIR, mechanical recycling, chemical recycling, mass balance, food-contact sensitivity, structure placement, performance risk and claim substantiation

Recycled content is becoming one of the most important technical and strategic topics in flexible packaging.

For brand owners, converters, packaging development teams, R&D leaders, procurement departments and sustainability officers, the direction of travel is clear. Packaging must become more circular. Dependence on virgin plastic must be reduced where technically and legally possible. Material choices must support recyclability. Packaging claims must be documented. ESG reporting must be supported by credible data. And under the EU Packaging and Packaging Waste Regulation, commonly known as PPWR, recycled content is becoming more important within the wider framework of packaging sustainability and circularity.

The European Commission states that PPWR entered into force on 11 February 2025 and will generally apply from 12 August 2026. The regulation covers all packaging and packaging waste, regardless of material or origin, and sets requirements for manufacturing, composition, reusability, recoverability, waste management and prevention.

For flexible packaging, this creates both opportunity and risk.

The opportunity is clear. Recycled content can help reduce the use of virgin plastic, support circular packaging strategies, strengthen ESG reporting and help customers move toward packaging systems that are better aligned with future regulatory expectations.

The risk is equally clear. Flexible packaging is not a simple material. It is a technical structure. Adding recycled content without understanding material source, recycling route, layer placement, food-contact status, barrier performance, sealing behaviour, processing stability and claim documentation can create problems rather than progress.

That is why the stronger question is not:

“Can we add recycled content?”

The strategic question is:

“Can we integrate the right recycled content, from the right source, into the right layer of the structure, for the right application, while maintaining safety, performance, shelf life, recyclability direction and credible documentation?”

This article explains the technical logic behind recycled content in flexible packaging and why expert packaging teams need to treat it as a structure-design decision, not a marketing slogan.

Why there is a knowledge gap around recycled content in flexible packaging

Recycled content is widely discussed, but often not explained deeply enough for real packaging specification.

Many articles focus on broad sustainability benefits. Fewer explain what packaging engineers, R&D teams and technical buyers actually need to know before they can move from interest to implementation.

That gap matters because recycled content in flexible packaging raises several technical questions at once.

• What is the difference between PCR and PIR?
• How does mechanical recycling differ from chemical recycling?
• When is mass balance relevant?
• Where should recycled content be placed in a multilayer structure?
• What changes when the pack is food-contact sensitive?
• How does recycled content affect sealability, OTR, WVTR, odor, migration risk, stiffness, clarity and commercial line speed?
• Which sustainability claims can be supported with evidence?
• Does the final pack still support the intended recyclability pathway?

These are not secondary details.

They are the questions that determine whether recycled content becomes a credible packaging solution or a source of technical, regulatory and reputational risk.

Flexible packaging is already complex. It often combines thin layers that must work together to provide mechanical strength, sealing, barrier performance, printability, shelf-life protection and commercial reliability. A small material change can affect the whole structure.

That is why recycled content must be discussed in the same language as packaging performance.

What recycled content means in flexible packaging

Recycled content refers to plastic material that has been recovered, processed and reintroduced into a new material or packaging structure instead of being produced entirely from virgin raw materials.

In flexible packaging, recycled content may be considered for films, laminates, pouches, bags, wraps, rollstock, lidding films, secondary packaging, industrial packaging or selected layers within multilayer structures.

However, recycled content is not one category.

The two most important starting points are PCR and PIR.

PCR: post-consumer recycled content

PCR stands for post-consumer recycled content.

It comes from material that has already been used by consumers or businesses, collected after use, sorted, cleaned and reprocessed.

PCR is important because it creates demand for material recovered from real waste streams. From a circular economy perspective, this is highly relevant. If brands want packaging systems that keep materials in use and reduce dependence on virgin plastic, PCR can play an important role.

But PCR is also technically challenging.

Post-consumer material may have an uncertain or mixed history. It may include residues, labels, inks, adhesives, coatings, odor sources, additives, degradation products, or traces of non-food applications. It may vary in polymer purity, molecular weight, color, smell, mechanical behaviour and processing stability.

For flexible packaging, this variability matters.

Films are thin. Sealing windows can be narrow. Barrier requirements can be strict. Odor can be unacceptable. Food-contact requirements can be sensitive. Filling lines may run at high speed. Even small inconsistencies can become commercial problems.

PCR is therefore not simply “better” because it sounds more circular. It must be qualified for the application and the structure.

PIR: post-industrial recycled content

PIR stands for post-industrial recycled content.

It usually comes from production or converting waste generated before the product reaches the consumer. Examples include trim waste, start-up waste, offcuts, rejected rolls, clean film scrap, edge trim and process waste from manufacturing.

PIR can be more controlled than PCR because the source may be known. The polymer type may be clearer. The contamination risk may be lower. The material may have a more predictable processing history.

This can make PIR technically easier to use in selected flexible packaging applications.

However, PIR and PCR should not be confused.

PIR helps reduce industrial waste and improve material efficiency, but it does not address post-consumer packaging waste in the same way as PCR. For ESG reporting, customer communication and circular economy positioning, the distinction matters.

Packaging teams should be precise in their language.

A claim based on PIR is not the same as a claim based on PCR.

Why PCR versus PIR matters for claims

The difference between PCR and PIR is not only technical. It is also commercial and reputational.

When a brand claims recycled content, customers, retailers, regulators and sustainability teams may ask:

• Is the recycled content post-consumer or post-industrial?
• What percentage is used?
• Where is it used in the structure?
• Does it apply to the film, the laminate, the pouch or the full pack?
• Is the claim verified?
• Is chain-of-custody documentation available?
• Is food-contact suitability documented where relevant?

A vague claim such as “made with recycled content” may not be enough for expert buyers.

A stronger claim explains what type of recycled content is used, where it is used, how it is measured, and which documentation supports it.

This matters because sustainability claims are under increasing scrutiny. Recycled content can strengthen trust only when the claim is accurate and defensible.

Mechanical recycling: strengths and limitations

Mechanical recycling is the most established recycling route for many plastic materials.

The process typically involves collecting, sorting, washing, shredding, melting, filtering, regranulating and reprocessing plastic into new material.

When the input stream is clean, well-sorted and compatible, mechanical recycling can be an efficient way to keep plastic materials in use.

For flexible packaging, however, mechanical recycling has limitations.

Flexible packaging waste can be difficult to collect and sort. It is often printed, laminated, coated, metallised or contaminated with product residues. It may include mixed polymer families. It may contain adhesives, inks, barrier layers or incompatible materials. These factors can reduce recycling quality and limit the use of the recycled output in demanding applications.

Mechanically recycled material can also show variation in:

 • Color Odor
 • Gel content
• Molecular weight
• Melt flow behaviour
• Thermal stability
• Polymer purity
 •Mechanical properties
 •Sealability
• Film appearance

For some flexible packaging applications, this may be manageable.

For high-barrier food packaging, retort packaging, medical packaging or premium transparent packaging, it can be more difficult.

The key question is not whether mechanical recycling is useful. It is.

The key question is whether mechanically recycled material provides the quality, consistency and safety profile required for the specific packaging structure.

Chemical recycling: opportunities and questions

Chemical recycling, sometimes called advanced recycling, uses chemical processes to convert plastic waste into smaller molecules, intermediates or feedstocks that can be used to produce new plastics.

This route may help address some limitations of mechanical recycling, especially for mixed or difficult-to-recycle plastic streams. In certain cases, chemically recycled feedstock can be used to produce polymers closer to virgin-quality material.

For demanding flexible packaging applications, this can be attractive.

It may support higher-purity feedstock. It may be relevant for food-contact sensitive applications where the correct regulatory and certification framework is in place. It may help create recycled-content pathways for applications where mechanically recycled material cannot deliver the required performance.

But chemical recycling also raises important questions.

• What technology is being used?
• What feedstock is accepted?
• What is the yield?
• What is the energy demand?
• What certification system supports the claim?
• Is the recycled content physically present or mass-balance attributed?
• How is chain of custody documented?
• What claim language is allowed? Is the route commercially scalable?
• What is the cost position?

Chemical recycling should not be presented as a universal answer. It is one possible route within a wider recycled-content strategy.

The practical question is:

Which recycling route provides the right balance of material quality, safety evidence, traceability, scalability, cost, regulatory suitability and credible claim language for this application?

Mass balance and recycled-content accounting

Mass balance is increasingly relevant when chemically recycled feedstocks are used.

In simple terms, mass balance is a chain-of-custody accounting method. It tracks the input of recycled or circular feedstock into a production system and allocates an equivalent amount of recycled content to output materials according to defined rules.

This matters because polymer production often operates through complex industrial systems where recycled feedstock and virgin feedstock may be processed together.

Mass balance can help scale recycled-content claims in applications where physically segregated recycled material is difficult to use.

However, mass balance must be communicated clearly.

Packaging teams should ask:

• Which certification system is used?
• What chain-of-custody model applies?
• What percentage is claimed?
• Does the claim apply to resin, film, laminate, pouch or final pack?
• Is the claim clear to customers and retailers?
• Can documentation be provided?
• Is the claim consistent with legal and market requirements?

Mass balance can support credible recycled-content strategies when the documentation is strong and the claim language is responsible.

It can create confusion when communication is vague.

Food-contact sensitivity: why recycled content becomes more complex

Food-contact packaging must be safe before it can be sustainable.

This is especially important for recycled plastics.

Recycled plastic may contain substances from previous use, contamination from waste streams, degradation products, inks, adhesives, labels, residues or non-intentionally added substances.

For recycled plastic materials intended to come into contact with food in the EU, Regulation (EU) 2022/1616 establishes specific rules for recycled plastic materials and articles intended for food contact. EFSA explains that recycled plastic food-contact materials can pose risks because of possible contamination from previous use or from other waste, and EFSA assesses the safety of recycling processes for food-contact materials.

For packaging teams, this creates a simple rule:

Do not assume recycled content is suitable for food contact. Verify it.

That verification may include supplier documentation, regulatory review, migration testing, sensory assessment, process approval, functional barrier assessment and application-specific validation.

The question is not only whether the material is recycled.

The question is whether the recycled material is suitable for the intended food-contact application, in the intended layer, under the intended time, temperature and product conditions.

Structure placement: where recycled content is used matters

Flexible packaging is usually a layered system.

A typical structure may include:

• External print or protection layer
• Functional barrier layer
• Tie layer
• Adhesive layer
• Core layer
• Sealant layer

Recycled content may be suitable in one layer but not another.

This is why layer placement is central to recycled-content strategy.

External layer

The external layer may provide printability, scuff resistance, heat resistance, stiffness or protection. Recycled content in this layer may be technically possible in some applications, but packaging teams must consider appearance, odor, print quality, surface energy, lamination, COF and set-off risk.

Core layer

The core layer may be a more practical location for recycled content because it can contribute material volume without necessarily being the direct food-contact surface. However, the core layer still affects stiffness, puncture resistance, web handling, extrusion stability, odor and overall pack behaviour.

A core-layer approach still requires validation.

Functional barrier layer

A functional barrier may reduce migration from a recycled-content layer toward the food-contact side. This can be relevant in certain food-contact structures.

However, a functional barrier is not a generic promise. It must be technically appropriate for the substances of concern, food type, contact time, temperature and final pack conditions.

It must also survive conversion, filling, sealing, transport and storage.

Sealant layer

The sealant layer is critical because it often contacts the product and creates pack integrity.

Using recycled content in a sealant layer may be difficult, especially for food-contact applications. It can affect seal initiation temperature, hot tack, final seal strength, leakage risk, contamination resistance, migration, odor and organoleptic performance.

For retort pouches, wet pet food, sauces, soups, ready meals, liquids and high-speed packing lines, the sealant layer should be treated as a critical control point.

Performance risks that must be tested

Recycled content affects sustainability strategy, but it can also affect packaging performance.

Expert teams should evaluate the full pack structure, not only the recycled material.

Key performance areas include:

• Seal strength
• Hot tack
• Leak resistance
• OTR
• WVTR
• Aroma barrier
• Puncture resistance
• Tear resistance
• Tensile strength
• Stiffness
• Flex-crack resistance
• Lamination bond strength
• COF
• Blocking
• Clarity
• Haze
• Gloss Odor
• Migration risk
• Line speed
• Waste rate
• Shelf-life performance

For high-barrier flexible packaging, OTR and WVTR are especially important. A recycled-content layer may not be the barrier layer, but it can still influence total structure performance through stiffness, adhesion, flex behaviour, layer uniformity and process stability.

The only reliable answer is testing.

Recycled content and design for recyclability

Recycled content should not be evaluated separately from recyclability.

A pack can include recycled content and still be difficult to recycle after use.

The CEFLEX Designing for a Circular Economy guidelines provide practical design guidance for flexible packaging and are intended to help businesses make sustainable design choices for 2030 and beyond. CEFLEX also states that its updated D4ACE guidance is aligned with the direction of EU regulation, including PPWR and forthcoming design-for-recycling criteria.

For flexible packaging teams, this means recycled content should be considered alongside:

• Polymer family
• Mono-material direction
• Barrier layer selection
• Adhesives
• Coatings Inks
• Labels
• Metallisation
• Sorting compatibility
• Recycling stream quality
• Residual product contamination
• End-market requirements

The best recycled-content strategy supports both material circularity and the intended recyclability pathway.

It should not create a structure that is harder to sort, harder to recycle, or less valuable as secondary raw material.

Claims logic: credible sustainability needs evidence

Recycled-content claims can be powerful.

They can support ESG reporting, retailer discussions and customer trust.

But they must be specific, measurable and documented.

Packaging teams should avoid broad or unsupported claims such as:

“Green packaging”
“Eco-friendly packaging”
“Fully circular packaging”
“Food-safe recycled plastic”
“Recyclable because it contains recycled content”

Instead, claims should be built around evidence.

• What percentage of recycled content is used?
• Is it PCR or PIR?
• Is it mechanically recycled, chemically recycled or mass-balance attributed?
• Which layer or component contains it?
• Does the claim apply to the film, laminate, pouch or full pack?
• Is certification available?
• Is food-contact suitability documented where relevant?
• Does the final pack support recyclability direction?
• Can the claim be defended in ESG or retailer review?

The strongest sustainability claim is not the biggest claim.

It is the claim that can be proven.

Why recycled content must be commercially realistic

A recycled-content structure must work beyond the laboratory.

Commercial packaging needs consistent supply, stable quality, reliable conversion, predictable filling-line performance and clear documentation.

A recycled-content film that performs once in a trial but cannot be supplied consistently is not a scalable solution.

Packaging teams should evaluate:

• Feedstock availability
• Supplier reliability
• Batch consistency
• Processing window
• Waste rate
• Line speed
• Cost position
• Regulatory status
• Testing requirements
• Customer approval process
• Retailer acceptance
• Documentation package
• Long-term scalability

This is especially important for global brands and multinational supply chains. A recycled-content solution must often work across regions, product formats, filling lines and retailer requirements.

Sustainability must be scalable to become business value.

How packaging teams should start

The best starting point is not to ask for the highest possible recycled-content percentage.

The best starting point is to define the application.

• What product is being packed?
• What shelf life is required?
• What are the oxygen and moisture sensitivity levels?
• Is the product dry, wet, fatty, acidic, aromatic, powdered or heat-treated?
• Is it food-contact sensitive?
• Does it require retort, pasteurisation, hot fill, freezing or sterilisation?
• What are the line-speed requirements?
• What recyclability pathway is intended? What recycled-content claim is desired?
• What documentation will the customer or retailer require?

Once those questions are clear, the recycled-content strategy can be designed around the structure.

That may involve PCR, PIR, mechanically recycled material, chemically recycled feedstock, mass-balance attribution, non-contact layer placement, functional barrier design, mono-material structures, advanced barrier films or a phased transition strategy.

There is no universal recycled-content answer.

There is only application-specific structure development.

Where TOPPAN Films can support packaging teams

Recycled content is transforming flexible packaging, but it must be integrated with technical discipline.

TOPPAN Films can support packaging teams exploring recycled-content strategies, recyclable high-barrier flexible packaging, Mono-PP and Mono-PE structures, GL BARRIER film options, aluminum foil alternatives, OTR and WVTR targets, functional barrier discussions and PPWR-ready packaging development.

The goal is not simply to add recycled content.

The goal is to design packaging structures that protect the product, perform commercially, support recyclability direction and provide credible documentation for sustainability claims.

That requires collaboration between material experts, converters, brand owners, R&D teams, regulatory specialists, procurement and sustainability leaders.

TOPPAN Films can help teams ask the right questions early:

Which recycled-content route is realistic? Where can it sit in the structure? What barrier performance is required? What food-contact limits apply? What testing is needed? What claim can be supported? What structure can scale commercially?

This is where sustainability ambition becomes technical packaging development.

Recycled content is a structure decision, not a slogan

Recycled content will continue to shape the future of flexible packaging.

It can reduce dependence on virgin plastic, support circular packaging goals, strengthen ESG reporting and help packaging teams prepare for PPWR-aligned requirements.

But recycled content is not automatically suitable for every structure.

• It is not automatically food-contact approved.
• It is not automatically compatible with high-barrier packaging.
• It is not automatically recyclable after use.
• It is not automatically better if it weakens product protection.
• It is not automatically credible without documentation.

The most useful question is not:

“How much recycled content can we add?”

The most useful question is:

“How can recycled content be responsibly integrated into a flexible packaging structure that protects the product, performs commercially, supports recyclability direction, meets regulatory expectations and can be validated with data?”

That is the question packaging teams should be asking now. For technical sales, datasheets, samples or application-specific packaging discussions, contact TOPPAN Packaging Czech s.r.o.: toppancz@toppan.com