In a letter submitted March 8, ISRI provided feedback on measurement strategies for the U.S. Environmental Protection Agency’s proposed national recycling goal to attain a 50% recycling rate by 2030. Overall, ISRI supports the goal and believes it “may be attainable” with strong support and leadership from the EPA and from other recycling stakeholders. The comments note some of the nuances and complications involved in measuring the recycling rate and lay out recommendations for successful measurement of the goal’s achievement and successful methods of achieving the goal.
In consideration of the scope, ISRI recommends the EPA expand its scope of recyclable material to include all sources, including materials from curbside, commercial, and industrial sources. It also asks the EPA to include products that are recyclable “but may not be accurately measured in existing data collection,” including electronics and small appliances, while continuing to study where gaps in the data exist. In addition, ISRI asks the EPA to include reuse, repair, refurbishment, and remanufacturing as part of the recycling process it measures. It also asks for exports of recyclable materials to be included.
In contrast, ISRI notes that it does not consider collection and processing of food, organics, and yard waste for composting to be part of the recycling system.
In its measurement of the recycling rate, ISRI asks the EPA to note how the increasing trend of “light-weighting” of packaging for the purposes of cost and energy savings complicates recycling rate measurement. “A weight-based overall recycling rate across all commodities may not provide a true picture of recycling, for instance, implying a lower recycling rate even when the number of units entering and processed in recycling units has increased,” it says. To avoid this challenge when possible, ISRI suggests the EPA use opportunities to measure the recycling rate by units rather than weight.
ISRI notes that the EPA’s national recycling goal draft identifies five potential metrics that could be used to measure recycling: recycling rate, recycling access rate, participation rate, capture rate, and recyclables landfilled. The most important of these is the recycling rate, ISRI says, defined in the draft as “the percentage of the total amount of collected used materials that are utilized as feedstock for the manufacture of new products.” Measuring materials that are collected, processed, and consumed is the “most effective” way of understanding the recycling system’s resiliency, ISRI argues. “Collection without end-market use is not recycling,” it states.
As a measure of contamination, ISRI recommends the EPA examine in-bound contamination at materials recovery facilities (MRFs), “especially as materials come from a variety of sources (not just residences) and the recycling capability (e.g., recycling infrastructure) will always vary on output.” ISRI also suggests the EPA measure “processing yield” (defined by ISRI in an earlier comment submission as “the amount of materials recovered by a MRF or secondary processing facility through sorting and processing compared to the volume of materials entering the MRF or secondary processing facility”). Doing so will help illuminate gains in efficiency that have been achieved, ISRI says.
Finally, ISRI notes a few ways it can work with the EPA to improve recycling, such as promoting its Design for Recycling program, through which recyclers partner with manufacturers to design products with recyclability in mind. ISRI is also willing to engage in workshops that bring a wide variety of stakeholders together for collaborative dialogue, it says.
ISRI’s comments on March 8 build on a longer set of comments the organization submitted Dec. 2 on the EPA’s draft strategy. The EPA announced its intention to increase the U.S. recycling rate to 50% by 2030 at the America Recycles Summit, held Nov. 17, 2020. It has held two comment periods to help inform the development of its recycling strategy.
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