U.S. Plastics Pact’s Problematic and Unnecessary Materials List

The U.S. Plastics Pact works with its member Activators to take measures to eliminate 11 problematic and unnecessary resins, components, and formats by 2025, in order to accelerate progress toward a circular economy for plastic packaging in the United States.

Definition of “Problematic or Unnecessary Materials"

Plastic packaging items, components, or materials where consumption could be avoided through elimination, reuse or replacement and items that, post-consumption, commonly do not enter the recycling and/or composting systems, or where they do, are detrimental to the recycling or composting system due to their format, composition, or size.


The list was developed over the course of 16 months by U.S. Pact Activators, representing the expertise and experience of more than 100 organizations across the plastics packaging value chain. The materials on the list were evaluated in accordance with the criteria and definitions using the most comprehensive publicly available data from federal and state agencies, nonprofits, and trade associations. The list of sources is not exhaustive.

U.S. Pact’s adaptations to The Ellen MacArthur Foundation Global Commitment Criteria for identifying problematic or unnecessary plastic packaging components are provided in italics.

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The U.S. Pact’s Problematic and Unnecessary Materials List

U.S. Pact Activators will take measures to eliminate these items by end of 2025:

  • Cutlery*
  • Intentionally added¹ Per- and Polyfluoroalkyl Substances (PFAS)²
  • Non-Detectable Pigments such as Carbon Black
  • Opaque or Pigmented PET – Polyethylene Terephthalate bottles (any color other than transparent blue or green)
  • Oxo-Degradable Additives, including oxo-biodegradable additives
  • PETG – Polyethylene Terephthalate Glycol in rigid packaging
  • Problematic Label Constructions – This includes adhesives, inks, materials (e.g., PETG, PVC, PLA, paper). Avoid formats/materials/features that render a package detrimental or non-recyclable per the APR Design® Guide. Labels should meet APR Preferred Guidance for coverage and compatibility and be tested in any areas where this is unclear.
  • PS – Polystyrene, including EPS (Expanded Polystyrene)
  • PVC – Polyvinyl Chloride, including PVDC (Polyvinylidene Chloride)
  • Stirrers*
  • Straws*

*When non-reusable, non-recyclable, or non-compostable per U.S. Pact definitions and provided as an ancillary item to the primary container. For instance, a packet of plastic cutlery provided with a prepared salad or a straw/stirrer provided with an on-the-go beverage would be defined as problematic whereas cutlery, straws, or stirrers sold as a product would not.

¹ “Intentionally added” either in the package or in the manufacturing of that package.
² “PFAS” or perfluoroalkyl and polyfluoroalkyl substances are defined as the class of fluorinated organic chemicals containing at least one fully fluorinated carbon atom at or above 100 parts per million, as measured in total organic fluorine.

The 11 items listed are not currently reusable, recyclable, or compostable with existing U.S. infrastructure at scale and are not projected to be kept in a closed loop in practice and at scale by 2025.

Criterion 1:

The material is reusable, recyclable, or compostable by 2025.[1]

Reusable, recyclable, and compostable is assessed in accordance with the U.S. Pact Definitions

Data Sources

  • 2019 U.S. Post-Consumer Plastic Recycling Data Report
  • 2020 NAPCOR PET Recycling Report
  • Association of Plastic Recyclers APR Design® Guide for Plastics Recyclability
  • Biodegradable Products Institute (BPI)
  • Expert Opinion Within the U.S. Pact (APR, BPI, USCC, etc.)
  • United States Environmental Protection Agency (EPA) Sustainable Materials Management Report

[1] Changed Criterion 1 from the EMF Global Commitment criteria into the affirmative.

Criterion 2:

The material contains hazardous chemicals or creates hazardous conditions that pose a significant risk to human health or the environment (applying the precautionary principle) during its manufacturing, recycling (whether mechanical or chemical), or composting process.

Data Sources

  • Defer to the most stringent U.S. regulations, including:
    • Agency for Toxic Substances and Disease Registry (ATSDR)
    • California Proposition 65
    • Centers for Disease Control and Prevention (CDC)
    • Environmental Working Group
    • United States Food and Drug Administration (FDA)
    • International Agency for Research on Cancer (IARC)
    • Maine Department of Environmental Protection Toxics in Food Packaging Program Food Contact Chemicals of High Concern
    • Safer States
    • United States Department of Health and Human Services (HHS)
    • United States EPA: TSCA, RCRA, etc.
    • Vermont Department of Health Chemicals of High Concern to Children Washington State Department of Ecology Chemicals of High Concern to Children

Criterion 3*:

The material can be avoided (or replaced by a reuse model) while maintaining utility.

*Speaks to “unnecessary” designation.

Data Sources

  • Ellen MacArthur Foundation: Reuse – Rethinking Packaging
  • Expert Opinion Within the U.S. Pact

Criterion 4:

The material hinders or disrupts the recyclability or compostability of other items.

Data Sources

  • Refer to APR for design features that are detrimental to recycling or render a package non-recyclable.
  • Refer to BPI for design features that are detrimental to composting or render a package non compostable.

 Criterion 5:

The material has a high likelihood of being littered or ending up in the natural environment.

Data Sources

  • Keep America Beautiful National Litter Studies
  • National Oceanic and Atmospheric Administration (NOAA) Marine Debris Program
  • Ocean Conservancy Trash Information and Data for Education and Solutions (TIDES)
  • Pew Charitable Trusts Breaking the Plastic Wave
  • Quantis The Plastic Leak Project



The list applies exclusively to plastic packaging. Medical plastics used in clinical, hospital, and related laboratory and research settings are not included. Definitions used in the criteria derive from the Ellen MacArthur Foundation’s global Plastics Pact Network, which provides the framework for the U.S. Pact. The U.S. Pact Vision for 2025 focuses on where the U.S. Pact and its member Activators can make the greatest impact. The most prominent resins, components, and formats are at the heart of this focus.

Important Notes

  • During the next two years, the U.S. Pact will continue to investigate additional items for potential elimination.
  • Participation in the U.S. Pact is voluntary and does not necessarily signify an individual Activator’s endorsement of the list.

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