The Association of Plastic Recyclers (APR) has suspended recyclability certification for plastic packaging containing fluorinated components, citing risks linked to per- and polyfluoroalkyl substances (PFAS). This decision significantly affects manufacturers, retailers, and recyclers seeking compliance with evolving chemical and labelling regulations.
On 1 October 2025, APR announced it would no longer accept or renew APR Design Recognition for packaging technologies with intentionally added fluorinated ingredients. This temporary suspension aims to align industry guidance with the increasingly complex regulatory environment, including California’s SB 343 law. Effective from October 2026, SB 343 tightens labelling criteria for recyclable materials based on real-world collection and sorting practices.
Fluorinated Packaging Under Regulatory and Legal Scrutiny
This shift puts pressure on producers such as Inhance Technologies, a major fluorinator of high-density polyethylene (HDPE) containers. Used to enhance resistance for products like pesticides, fuels, and industrial cleaners, these containers are manufactured using Inhance’s proprietary Enkase™ technology. In a 7 October 2025 customer statement, Inhance criticised APR’s decision, describing it as unilateral and unsupported by technical standards. The company asserts its containers are safe, sustainable, and compliant with U.S. recyclability protocols.
However, mounting evidence and litigation suggest otherwise. Investigations by the U.S. Environmental Protection Agency (EPA) and environmental organisations have revealed that Inhance’s fluorination process can create and release PFAS, including perfluorooctanoic acid (PFOA) and perfluorononanoic acid (PFNA). These persistent and toxic chemicals have been found leaching into container contents and entering waste and recycling streams.
In 2023, the EPA concluded that the process posed an “unreasonable risk” to human health and issued a stop order under the Toxic Substances Control Act (TSCA). The order was later blocked by a federal court, and the agency withdrew its enforcement action. In July 2024, two advocacy groups, PEER and the Center for Environmental Health, filed suit against the EPA for failing to act despite acknowledging that PFOA poses risks even at trace levels.
California SB 343 and Market Labelling Challenges
While Inhance maintains that its containers currently meet recyclability definitions under existing U.S. standards, it concedes that California’s upcoming SB 343 law may affect the ability to label its products as recyclable from October 2026 onwards. SB 343 will require packaging to be widely collected and processed in practice, not just technically recyclable. Fluorinated HDPE containers may fall short of these criteria if they are excluded from material recovery systems due to PFAS contamination risks.
Inhance states that its containers will retain RIC #2 classification, but the recyclability label in California depends on real-world infrastructure and processing, which are under pressure from the presence of fluorinated plastics.
PFAS in the Recycling Stream: Industry-Wide Implications
PFAS chemicals are under increasing global scrutiny due to their environmental persistence and links to adverse health effects. Recyclers fear that contamination from fluorinated packaging could jeopardise the integrity of recycling streams and raise liability concerns. This has prompted APR’s pre-emptive action to safeguard recyclability standards and align with anticipated state and federal policy shifts.
Stakeholders across the plastics value chain, including chemical suppliers, converters, brand owners, and retailers, must now re-evaluate the use of fluorinated technologies in packaging. The APR’s move signals a broader transition toward safer barrier solutions that do not compromise recyclability or regulatory compliance.
