Plastic Waste Coalition of Action Releases New Guiding Principles on EPR for Liquid Packaging Cartons in LMICs

This new publication builds directly on CGF’s 2025 report on Extended Producer Responsibility (EPR) for Packaging: Design and Implementation in LMICs. While that earlier paper set out system-wide guidance for effective EPR design across all packaging materials, this latest report complements it by focusing in depth on recommendations tailored to one specific packaging format: liquid packaging cartons (LPCs).

These recommendations do not replace the CGF’s broader EPR guidance for LMICs. Rather, they translate those system-level principles into material-specific considerations for liquid packaging cartons.

Why focus on liquid packaging cartons?

Liquid packaging cartons (LPCs) deliver safe and shelf-stable food and beverage applications for dairy, plant based alternatives, juices and nectars — particularly important in low- and middle-income countries where cold-chain infrastructure can be limited.

Made of 75% paper on average, LPCs contain high-quality, long fibres that retain strong material value when effectively recycled. However, their multi-layer composition, combining paper, polymers and sometimes aluminium, creates specific recycling challenges, especially in markets where infrastructure is still developing. Mature systems have demonstrated that high recycling rates are achievable for LPCs, and well-designed and efficiently implemented EPR schemes are essential to make this a reality.

“Many governments in the global south have understandably started implementing EPR for plastics only, but to reach economies of scale, EPR should deliver for all packaging irrespective of material. This project recommends how to make an EPR more inclusive complementing the earlier CGF EPR guidance. Thank you to CGF, companies in the project steering and all stakeholders who shared their insights and feedback in the interviews and consultation during the project!” – said Kristiina Veitola, Director, Corporate Affairs Circular Economy and Packaging Policy, Tetra Pak

Three challenges identified in implementing EPR for liquid packaging cartons

Drawing on case studies from countries including South Africa, India, Vietnam, Chile and China, the paper highlights three recurring barriers to effective carton recycling within EPR systems:

1. Inadequately considered in policy
   Liquid packaging cartons are not consistently included in EPR schemes, or are grouped under inappropriate categories or with unrealistic targets.

2. Lack of a level playing field for recycling pathways
   In some systems, only part of the carton is recognised in recycling accounting, rather than the full packaging unit. Additionally, LPCs are not always accepted in recycling infrastructure.

3. Lack of adequate financing
   EPR fees often do not reflect the true net costs of collection, sorting and recycling, and are not always ring-fenced to support carton-specific value chains or infrastructure investment.
   
   

Recommended Guiding Principles

To address these challenges, beyond the general CGF guidance elements for effective EPR in LMICs, the paper outlines a set of sequenced Guiding Principles specific to LPCs to support policymakers and Producer Responsibility Organisations (PROs), including:

•       Establishing a dedicated LPC category (preferably within paper) or a clear roadmap to create one
•       Setting realistic, infrastructure-aligned collection and recycling targets
•       Ensuring LPCs are accepted in national collection and recycling systems
•       Allocating EPR fees to reflect the full carton structure through the range of recycling pathways
•       Setting EPR fees to reflect the  true net costs of LPC management and ring-fencing funds for LPC collection and recycling
•       Supporting long-term infrastructure development through multi-year contracts and end-market development
  
  

Supporting scalable, inclusive circular systems

As EPR continues to expand rapidly across LMICs, the Coalition underscores the importance of harmonised, practical implementation that reflects material-specific realities while remaining aligned with broader system design principles.

The CGF Plastic Waste Coalition of Action welcomes feedback and ongoing engagement from policymakers, industry stakeholders, and civil society to help strengthen effective and inclusive EPR systems worldwide.

Download the paper here.