With residential materials, the answer to the industry’s toughest question depends on whom you ask, as well as about what, where, and when you’re asking. Scrap examines how this issue got so confusing—and why it matters.
By Katie Pyzyk
It’s a cliché to start a feature article with a dictionary definition, but let’s do it anyway. Merriam-Webster’s online dictionary defines recycle as “to pass again through a series of changes or treatments” with its first subset “to process [something] in order to regain material for human use.” If it were only that easy. “It’s a very confusing subject, and everyone has different definitions, for sure,” says Bill Moore, president of Moore & Associates (Atlanta), a paper recycling consulting firm. When you’re talking about residential products and packaging, recyclable can mean different things according to how you interact with an item during its life cycle—as a manufacturer, user, collector, policymaker, processor, advocacy group, association, or consumer of recycled commodities. The definition varies within each of those stakeholder groups and subgroups as well.
For recyclers, the idea of a single, official U.S. government definition of what is and is not recyclable is a non-starter given the realities of constantly changing consumer products, packaging materials, prices, and markets. Some industry participants are putting forward their perspectives on how best to define recyclable for their parts of the residential material stream. Understanding how and why this issue got so complicated, and why it’s of critical concern today, is one step toward assessing the wide array of solutions being proposed to help clear up the confusion.
Don’t call it a definition
When looking for U.S. government guidance on what is and is not recyclable, many people point to the U.S. Federal Trade Commission’s Green Guides. The document provides guidelines for product manufacturers to remain compliant with federal regulations that dictate what product marketing claims they can and cannot make. It aims to prevent manufacturers from “greenwashing,” making deceptive or outright untrue claims about products’ environmental friendliness.
A well-known part of the Green Guides is commonly called the 60-percent access rule, which indicates that marketers can make unqualified claims about an item’s recyclability only “when recycling facilities are available to a substantial majority of consumers or communities where the item is sold.” The FTC considers 60 percent a substantial majority. “That’s sort of a functional definition,” says Susan Cornish, sustainability associate at Moore & Associates. It requires that “enough municipalities—60 percent—will take [the material], which means they must have [materials recovery facilities] that will take it and buyers for it,” she says.
Is this a definition of recyclable? The Green Guides “don’t define anything,” says Julia Ensor, an attorney with the FTC’s Division of Enforcement. They “provide guidance to marketers on how they can make truthful environmental marketing claims for their products that comply with Section 5 of the FTC Act,” which protects consumers from untruthful advertising.
The guidelines highlight the regional nature of some recycling markets. “We have to be careful because virtually all of our products are technically recyclable, but whether or not they’re recyclable for a [specific] person really depends on what infrastructure is available where they live,” says Michael Westerfield, corporate director of recycling programs at Dart Container Corp. (Mason, Mich.), which makes food service packaging out of plastic, paper, and other materials. Dart heavily considers the Green Guides when designing and marketing products, Westerfield says, but the company finds it “very challenging in terms of promoting the recyclability of a product because the public, by and large, doesn’t care about the FTC’s Green Guides.” Consumers just want to know if they can recycle a product or its packaging. As a manufacturer, that question is often difficult to answer because recycling programs vary greatly across the country, he says. As a result, a manufacturer might feel safer saying nothing rather than risk being accused of a false claim.
Scott Saunders, general manager of KW Plastics’ Recycling Division (Troy, Ala.), points out another drawback of the 60-percent access rule: “If you look at [it] strictly, then no new product innovation is ever recyclable because it hasn’t reached 60 percent of the population yet,” he says. To encourage innovation, he believes there should be one rule for the recyclability of established commodities and another for new products. The Green Guides do undergo revisions every 10 years.
Collection is not enough
“ISRI has long held that for a product to be recyclable, it must be both technologically and economically feasible to recycle,” ISRI President Robin Wiener says. That position dates back to ISRI’s work with auto manufacturers through the Vehicle Recycling Partnership in the 1990s, she notes, and the association has applied it across all commodity sectors.
The Association of Plastic Recyclers (Washington, D.C.) and Plastics Recyclers Europe (Brussels) took that same perspective last year, when they released a global definition of plastics recyclability as a benchmark to alleviate confusion. “At the end of the day, recyclability goes beyond just being technically recyclable,” APR President and CEO Steve Alexander says in a statement announcing the definition. “There must be consumer access to a recycling program, a recycler must be able to process the material, and there must be an end market.”
The definition spells out four conditions a plastic product must meet to be considered recyclable: (1) The product must be made with a plastic that is collected for recycling, has market value, and/or is supported by a legislatively mandated program; (2) the product must be sorted and aggregated into defined streams for recycling processes; (3) the product can be processed and reclaimed/recycled with commercial recycling processes; and (4) the recycled plastic becomes a raw material that is used in the production of new products. “Innovative materials must demonstrate that they can be collected and sorted in sufficient quantities, must be compatible with existing industrial recycling processes or will have to be available in sufficient quantities to justify operating new recycling processes,” the groups said in the announcement.
Traditionally, the existence of end markets is how processors have determined an item’s recyclability. “Recycling is driven by demand,” Wiener says. “It doesn’t matter how much scrap is collected and processed—if there is no end market, the recyclables will not move, and recycling has not occurred.” Products and packaging that might meet the Green Guides’ criteria don’t always satisfactorily pass the market test, and vice versa. Take thermoformed plastic containers. Some communities accept them in their municipal recycling, but PET thermoforms are “challenging from a market perspective now that China no longer wants our mixed plastic bales, and domestic markets are still in the emerging phase,” says Nina Butler, CEO of More Recycling (Sonoma, Calif.). Conversely, “polypropylene bottles, tubs, and cups are unfortunately being dropped from collection programs,” even though “rigid PP has active domestic buyers,” she says.
Ron Gonen, CEO of Closed Loop Partners, goes one step further. “There’s a really critical definition” for recyclable, he says: The material “needs to have a market that is willing to pay over $70 a ton for it” because that’s roughly what MRF processing costs are. Sometimes a product collected in recycling programs can be separated and processed into a salable commodity, “but the market for it is zero or $22 or $55. That’s a killer for the recycling industry,” Gonen says. Closed Loop invests in “sustainable consumer goods, advanced recycling technologies, and the development of the circular economy.”
Recycling was not always so confusing. In its earliest forms, commercial recycling existed for economic reasons—a person or company could make money by processing end-of-life material into a salable commodity. More than 80 years ago, scrap recyclers began creating industry specifications for scrap, guidelines that promote consistency and quality in the global trade of hundreds of scrap commodities, Wiener says. Those efforts, published as the ISRI Scrap Specifications Circular, are what some governments now use to determine what materials they’ll allow as scrap imports, versus those they’ll ban as wastes, “effectively making the specifications a standard for recyclability,” she says.
As recycling’s environmental benefits have gained increased attention over the years, the public’s view of recycling now primarily relates to the environmental value of keeping certain residential products and packaging out of the environment and out of the landfill. This has led to a disconnect, recyclers say, when governments create mandates or goals for keeping certain material out of the landfill—diversion—with no consideration for what the region’s recyclers can process and sell. “We’re really good at collecting, but collecting isn’t the same as recycling,” says Kristan Mitchell, executive director of the Oregon Refuse and Recycling Association (Salem, Ore.). “We want to make sure we can take [material] to a market that is actually going to turn it into something new.”
Recyclers say they would like municipalities to focus less on raw diversion numbers and more on the entire recycling value chain. “We pushed for so many years [for] higher diversion rates, but recycling is just like any other manufacturing business. It’s all about supply and demand,” says Brent Bell, president of Waste Management Recycle America (Houston). “If we don’t have those end markets [growing] at the same rate of speed or faster, the pricing for these materials is either flat or in a downward position, like it was at the beginning of 2019.”
The current confusion
Recycling in the 1980s and 1990s was easier because municipal programs accepted far fewer material types, and many curbside programs required source separation. Single-stream recycling came along in the early 2000s, with all collected materials going into the same bin, increasing the total volume collected but also resulting in higher contamination rates.
From 2001 to 2017, as China became the dominant market for most exported scrap commodities, demand grew for long stretches of time even as prices remained volatile. This corresponded with communities’ interest in expanding their recycling programs to collect greater volumes and more types of materials. And products and packaging continue to evolve, with plastic replacing glass and metal, newspaper and magazine circulation declining sharply, and flexible plastics replacing rigid ones. Recyclers adapted, in part, by incorporating better sorting, washing, and processing equipment, which allows a greater variety of products and more contaminated products to enter material streams, Moore says. The market dynamism means “what is recyclable technically has changed over time,” Cornish says, but product and packaging innovation has far outpaced the ability of MRFs and other recyclers to handle it.
Domestic recyclers’ relationship with China in recent decades could be considered symbiotic, but the United States “didn’t backfill and prepare for when that market was going to go away,” Butler says. That’s what happened in mid-2017, when China announced bans on imports of some scrap materials, vastly tighter contamination standards on others, and its intention to stop importing nearly all forms of scrap by 2020.
Contamination doesn’t simply refer to food or waste residues in scrap commodities. It’s also nonrecyclable items in the bin or bale. The increasing complexity of municipal recycling, especially curbside, has led to greater consumer confusion. People resort to “wishcycling,” putting incorrect materials in the bin because they think or hope they’re recyclable. Some MRFs have displays of the strangest items they’ve received through curbside collection, such as bowling balls, ice chests, small appliances, and electronic devices. (Dirty diapers are another common contaminant in the residential stream.)
Packaging and product design innovations play a role in contamination, too. Materials that are recyclable in some forms are not recyclable in other forms, or if they’re merged with other materials into a single product. Padded mailers with plastic or paper exteriors and bubble wrap interiors are one such troublesome item. “[If] you put those two [materials] together, there’s not a single program that can recycle those. Yet they carry the [chasing arrows] symbol,” Moore says. Others point to coffee pods made of multiple materials and flexible plastic bags with integrated zip seals made of a different resin.
Assuming collection equals recycling, many Americans incorrectly believe all the items they put into curbside bins get processed and returned to beneficial use. In reality, China’s demand masked the growth of contamination in residential recyclables, which in some communities exceeded 25 percent. “China provided the demand needed to move materials, and because there was little feedback about quality, we had the luxury of focusing on quantity over quality,” Butler says. Contaminated material at a MRF goes to a landfill or gets incinerated. Thus, even before China’s policy changes, “a lot of areas fooled themselves into thinking they were recycling when they were really not,” Saunders says.
Now, domestic recyclers find themselves in the midst of “that perfect storm” in which scrap plastic struggles to compete with virgin resin, which is priced much lower now than it was in 2013, when China first tightened its scrap import policies in Operation Green Fence, Butler says. At the same time, other countries have felt the ripple effects. “China’s policies forced some of its own recyclers to relocate to neighboring countries,” Wiener says, but in many cases those new operations “failed to heed local enviornmental laws, which caused those governments to restrict scrap plastic imports.” This sudden policy shift has caused short-term disruption in the global market, “including some materials being landfilled, but it also has resulted in recyclers retooling their operations to meet greater demand for high-quality materials,” she points out. Those changes take some time to implement, however.
The way forward
Recyclers and other stakeholders say they’re starting to work together better across the product and packaging life cycle to address the discrepancies among views of what’s recyclable. “There’s a lot of collaboration, which is great, as long as everyone works toward the same goal,” says Lynn Dyer, president of the Foodservice Packaging Institute (Falls Church, Va.). FPI is helping increase the food-service-packaging supply chain’s understanding of recyclability and create cross-industry collaboration, she says. “There is great interest in being able to call something recyclable, but we all need to be on the same level playing field and following the same rules,” she says.
ISRI and other organizations push manufacturers for thoughtful product design that takes into account end-of-life considerations—whether the materials used and how they’re combined affect a product’s recyclability. ISRI launched its Design for Recycling® initiative in 1986 to address the problem of consumer products that were not recyclable, either because they contained hazardous constituents—such as cadmium, lead, or PCBs—or they contained a mix of polymers that could not be separated for recycling. The program encourages manufacturers to redesign challenging products to make them—or their individual components—widely and easily recyclable.
ISRI also has partnered with APR on the development of protocols for testing whether currently available MRF technology can successfully sort and capture a clean stream of specific types of new plastic packaging. The protocols would give manufacturers the ability to replicate such tests on new products and packaging they’re developing. To date the project has created protocols for testing near-infrared separation, the impact of compression in a collection vehicle, and whether small items will get sorted properly. Additional tests on products that have both plastic and metal elements and “2D” plastic products that mimic paper or OCC in their size or shape when they enter the MRF are under development. The ability to capture a clean stream of a particular material is only one part of what’s required to ensure a product is recyclable, APR notes, pointing packaging and product designers to its APR Design Guide for Plastics Recyclability. (For more about ISRI’s work on this issue, see “ISRI’s Efforts to Advance Recyclability Issues,” page 144.)
Others work to eliminate confusion with clearer product labeling. Recycle Across America advocates widespread adoption of standardized labels on recycling bins so consumers immediately understand which items are recyclable and allowed in each bin. Founder and Executive Director Mitch Hedlund suggests recycling education should work like driver’s education: Once we learn the rules of the road, “for the rest of our lives, we can hop in a car and drive anywhere in the U.S. and know what to do, because even if the rules are different, the way the rules are presented are part of a standardized format.”
The Sustainable Packaging Coalition (Charlottesville, Va.) has its own product and packaging label simplification initiative, How2Recycle, which more than 20,000 products use, it says. It developed the labeling system with FTC guidance and references the 60 percent access rule. The label’s contents vary according how each product can or cannot be recycled. For example, a plastic bottle might feature the triangular chasing arrows recycling symbol along with the instructions “empty and replace cap.” SPC collaborates with The Recycling Partnership (Falls Church, Va.) on other initiatives to reduce consumer confusion. “Of course [consumers] are confused. They get a lot of different signals from a lot of different spaces,” says Dylan de Thomas, vice president of industry collaboration.
“Retailers and brand owners are looking for a reputable organization to say ‘OK’ to the recyclability of specific products or packaging, but, unfortunately, there is not one universal labeling system that currently works effectively for all stakeholders,” Wiener says.
Few of those interviewed for this article believe a federal definition of what’s recyclable will solve the problem. “Rules and regulations written by government agencies do a wonderful job for a static situation. But in our business … you’re operating with rules set up for things that never change and trying to apply that to an industry that rapidly changes,” Saunders says.
Although governments might have good intentions, “we don’t want unintended consequences, like [we have] with the resin identification codes,” de Thomas says. The plastics industry developed the codes—the numbers inside the triangle of chasing arrows on plastic consumer products—in 1988 to create consistency in plastics manufacturing and reprocessing. They indicate from which resin the product was manufactured, not whether the product is recyclable. But when residential recycling programs started using those codes to communicate to the public about what consumer packaging they do and don’t accept, the result was widespread confusion about what the codes mean. In the past few years, industry groups have urged recycling programs to stop using the codes and instead use commonly understood words like plastic bottles and containers or tubs and lids.
If any policy or regulatory changes are needed, they should come at the local or state level because of the industry’s regional nature, these industry participants say. For example, local leaders could redesign recycling programs so they still divert material from landfills but don’t accept items that lack established local end markets, Closed Loop Partners’ Gonen says, making the existence of viable markets part of the conversation about what the community deems recyclable. In addition, he thinks governments should get the “messaging out to major brands that if you want to use the terminology recyclable, it needs to be marketable at over $70 a ton.”
Waste Management’s Bell also suggests communities rethink what they collect—or mandate gets collected—in part based on demand. “We know every program in North America accepts paper, cardboard, bottles, and cans. … Let’s simplify and get those right,” Bell says. “We know those have great end markets. It will more than make up for the smaller, more confusing things.”
Quality control is part of this conversation as well. Recyclers who “produce high-quality bales, even in this difficult market, are moving their bales,” Gonen says. If collected material is not finding a market due to contamination, collectors and processors can work to reduce that contamination. Making the formula work means intense focus on “education, community outreach, using the right type of technology, and operational excellence to produce high-quality bales,” he says. Butler cautions that “we need to be mindful of ease for the consumer and how, within reason, our processing has to weed out some of that bad stuff.”
Federal, state, and local governments can play a role in expanding recycling education and creating incentives or otherwise investing in market development, many say. More demand for recycled commodities could spur collection and processing, especially for materials now being collected that don’t have sufficiently strong markets. Gonen suggests tax incentives for “those brands that are adding value into the system” by using recycled content because they can drive demand. Current U.S. policies don’t take into account products’ full environmental impact, Butler points out. “We need to have a better accounting of materials,” such as a system to verify the use of recycled materials, she suggests, “and reward those who use materials with the lowest environmental impact.”
Ultimately, the determination of whether something is recyclable needs to consider both the environmental and the economic aspects of processing it and returning it to the market, de Thomas says. Those two concepts “need to be married to one another, and increasingly they are. … That’s what we’re all trying to do.”
Katie Pyzyk is a contributing writer for Scrap.
ISRI’s Efforts to Advance Recyclability Issues
ISRI has long worked to promote product and packaging recyclability through such programs as its Design for Recycling® Award. In the past two years, it has stepped up its efforts to work with partners throughout the value chain to address recyclability with manufacturers, recyclers, and the public.
• In February 2017, the ISRI board added Guidelines for Inbound Curbside Recyclables for Material Recovery Facilities to the ISRI Scrap Specifications Circular. The guidelines list the baseline paper, cardboard, plastic, metal, and glass products and packaging ISRI recommends that MRFs accept in residential recyclables; other items MRFs can deem unacceptable or not preferred; and a third list of prohibitives—items that should never be accepted in curbside recycling streams, such as explosives and medical waste. Another section of the guidelines presents the pros and cons of accepting materials that can pose collection, separation, or marketing challenges in some communities.
• Last August, ISRI collaborated with the Solid Waste Association of North America (Silver Spring, Md.) to organize a MRF Summit in Nashville, Tenn. The event brought together several hundred recyclers, municipalities, and brand owners to address issues including packaging design for recyclability, MRF operations, and public policy. Additional sessions addressed the need for material specifications and a standard set of metrics for measuring recycling performance. ISRI’s Paper Stock Industries Chapter, Paper and Plastics divisions, and MRF Council were instrumental in organizing the summit.
Building on that work, ISRI is convening a Residential Recycling Summit at ISRI2019 in Los Angeles April 10-11. The summit will explore a range of potential solutions to problems of recyclability, from cart-tagging programs and social-media-based education campaigns to innovative packaging design. Visit isri2019.org/residentialrecycling.
• In 2018, ISRI convened the leaders of more than a dozen recycling-related industry groups to collaborate on issues facing the industry, with initial discussions focusing on increasing the quality of and demand for recycled materials. At this group’s most recent meeting, held Feb. 26 in Boston, the participants formed a task force to work on consistent messaging about recycling to educate the public and counteract negative messaging related to recent difficult market conditions. A second task force will consider what additional efforts might be needed to further drive demand for recycled commodities.
• As the accompanying article notes, ISRI is supporting and providing input into the Association of Plastic Recyclers’ (Washington, D.C.) program to develop recyclability testing protocols for packaging manufacturers. The manufacturers can use these protocols to assess how their products would behave in typical MRF technologies and processes—whether the MRFs can sort and capture them for sale.
• ISRI also supports APR’s “Demand Champions” program to encourage brand owners to increase the recycled content in their products or in “works in process” items they use to manufacture and transport their products. ISRI recently reached out to its consumer members to encourage them to join the Demand Champions program, as have major manufacturers including Procter & Gamble, Keurig Green Mountain, Nestle, and Coca-Cola.
• ISRI’s Plastics Division is developing additional education and training for plastics recyclers on plastics identification, plastics markets, proper sortation techniques, and similar topics to further the recycling and successful marketing of this commodity. The division also plans to develop best practices for MRF contract negotiation and a study of MRF technologies.
Contact Jonathan Levy, ISRI’s MRF Council liaison and director of member services, at email@example.com or 202/662-8530.