Waste Industry Remarks on EPA's National Recycling Strategy Draft

Two leading solid waste and recycling organizations, National Waste & Recycling Association (NWRA) and the Solid Waste Association of North America (SWANA), submitted their observations of the EPA's proposed National Recycling Strategy on behalf of the industry. 

Details of the draft were announced in October, with public remarks accepted through December 4. The EPA plans to release the final iteration of the National Recycling Strategy in early 2021.

During the third annual America Recycles Summit in October, EPA Administrator Andrew Wheeler announced the agency's target of boosting the nation's recycling rate to 50% by 2030, saying "As a nation, we are blessed with abundant resources. And we all want to protect the value of those resources, so future generations can enjoy and benefit from them. We know that recycling is one of the most widely available ways to have a positive impact on the environment, from children in schools to families in the suburbs." 

The national recycling rate has hovered near 30% for two decades. Efforts to progress it upward should involve "all levels of government and across the value chain," Wheeler indicated. 

While the draft strategy has "identified the right objectives to support making recycling resilient and strong," penned NWRA President and CEO Darrell K. Smith, "consistent messaging" to address contamination, research and a focus on the demand versus supply of recyclable items is needed to progress the agenda.

SWANA's Jesse Maxwell, SWANA's Advocacy & Safety Senior Manager echoed Wheeler's sentiments, saying"EPA’s efforts can be amplified by ensuring coordination of the National Recycling Strategy across federal agencies. While EPA plays a leading role on this issue, other parts of the federal government can have a major impact on all three of the proposed objectives. This year’s America Recycles: Summit speakers from the Department of Energy and the Department of Commerce demonstrated well how other agencies can further our nation’s recycling goals."

Both organizations provided a detailed breakdown of the EPA's three objectives and what can be achieved going forward should recommendations be implemented.

1. Reducing Contamination in the Recycling Stream

NWRA:  With limited resources, the nation's focus should be on "increasing recycling participation and promoting the value of recycling," Smith said.

"In order to reduce contamination, education needs to reduce confusion about the types of materials and form factors that can be recycled. In addition, education is necessary about what cannot be recycled in curbside programs, or what must be taken to drop-off. Last, the public needs to know how to recycle, such as “caps on,” dry, and loose.

We urge EPA to take on the task of establishing these messages:
1. What can be recycled 
2. What cannot be recycled
3. What needs to be recycled at a drop-off
4. What can be recycled in some areas, “check locally”
5. Where to find information about local programs
6. How to prepare recyclables"

SWANA: When it comes to contamination, Maxwell likewise indicated that consistent messaging should be a primary consideration and is crucial to progressing the EPA's agenda:

"EPA should focus on the development of a common recycling message that will help unify recycling programs across the US. There is currently too much confusion regarding what basic items can or cannot be recycled. A uniform message that focuses on types of materials and not resin codes would be preferable and would allow similar education and outreach throughout the US. The states of Massachusetts and Connecticut offer examples of unified recycling messaging that EPA can refer to. This would also assist communities that have limited budgets to devote to recycling education and outreach. By having ready-made messaging and materials they can use, this can help to close the recycling gap between communities with different levels of resources.

Education and outreach to the public would also be greatly improved by addressing confusion around the labeling of packaging and products as recyclable. The objective to reduce contamination in the recycling stream must address this issue. Contamination is not just a result of public confusion, but also mixed or poor messaging by the producers. A role for producers in this objective should be explicitly developed. There is far too much confusion when the public is expected to interpret labeling for recycling directions.

For instance, most consumers assume that any product that has the “chasing arrows” symbol on it can go into their recycling bin. This leads to contamination in places where that material is not accepted, and in the case of items like lithium-ion batteries, often leads to dangerous fires.

A specific area of confusion is the chasing arrows symbol with the resin identification code (RIC) used on plastics. The RIC was not created to inform consumers about the recyclability of the material but has come to serve that role in the public’s eye."

2. Increasing Processing Efficiency 

NWRA: A "dramatic" shift in the mix of materials has occurred in the past decade, directly correlated to the decline of newspapers, along with a rise in cardboard from e-commerce, light-weighting of cans and plastic bottles and the move toward flexible plastic pouches, Smith wrote.

"The change in material mix means that the MRF is handling a mix of materials significantly different than was it was originally designed to handle. Some equipment may be able to be repurposed to handle different materials than originally anticipated. However, not all of it can be, leading to a less efficient processing system. Such rapid change in material composition can place significant financial burden, or risk, on long-term investments. A new MRF will face some of the same problems. While designed to handle today’s mix of materials, it may not be able to efficiently handle the mix of materials that will be delivered to it ten years from now. EPA can help MRFs to anticipate these changes by projecting the material changes that can are expected over the next decade.

As EPA develops these projections, it may become apparent that some of the fastest-growing packaging is not recyclable. Yet this non-recyclable packaging might be environmentally better than recyclable packaging. Therefore, we recommend that EPA conduct science-based life-cycle analysis of various packaging forms considering end-of-life management as well as other environmental attributes such as energy usage, climate change impacts and water impacts in order to promote the best environmental outcomes."

SWANA: "It is imperative that packaging and products are designed with current recycling systems in mind in order to increase processing efficiency," wrote Maxwell.

"That having been said, more focus needs to be turned to recycling infrastructure. Many recycling facilities have not been able to upgrade their processes or invest in innovative new technologies, particularly because the markets for recyclable materials have been depressed. Small operations often don’t have the financial resources or stability to invest in needed upgrades. There needs to be more funding and incentives offered at the federal, state, and local levels. This should include both public and private entities.

EPA can play an important role by increasing awareness of available public and private funding and incentives and effective strategies to access the funding. This is directly within the capability and authority of the agency. This will also help with the objective to reduce contamination in the recycling stream, as upgraded infrastructure will allow recyclers to remove more contaminants and offer higher quality feedstock. This higher quality feedstock will also have more value and provide further financial security to the recycling facilities. EPA can also be particularly helpful in improving understanding of available recycling infrastructure and needs. 

Finally, EPA should continue its efforts to develop and implement national recycling system definitions, measures, targets, and performance indicators. The work being done by the America Recycles stakeholder group, as well as the recent announcement of a national recycling goal with associated measures, is an excellent step in that direction."

3. Strengthening Markets for Recycled Materials 

NWRA: In order to improve markets, the use of recycled content must be amplified, Smith said.

"Reverse logistics associated with collecting increasingly lighter materials in an ever-expanding number of forms from individual homes and then separating them into single product bales will always be an expensive process. It will generally be less expensive to obtain virgin raw materials, especially virgin resins. Given that, improved markets require commitments to utilize recycled content even when the price exceeds the cost of virgin materials through a variety of policy incentives. Achieving EPA’s recycling goal means that supply, which is already inelastic, will continue to increase. Demand needs to be increased in order to balance out the supply. Continuing to focus on supply without increasing demand will cripple the future of recycling in the U.S."

SWANA: The increased use of recycled content is "perhaps the single most important factor in ensuring that recycling remains sustainable in communities across the United States," Maxwell confirmed, mentioning the U.S. government's purchasing power as a means to increasing demand.

"SWANA encourages EPA to conduct market development workshops and dialogues as proposed by the strategy. Further analysis of end markets and making data available about the materials that manufacturers need are also valuable actions that EPA can take and that are within its capability and authority. This will be particularly useful for smaller recycling operations that tend to struggle to find nearby markets. To have access to regional information to match sellers and buyers would be beneficial.

EPA should also analyze existing barriers to using recycled content in products. For a material such as glass that has been problematic for many programs, it is important to look at alternative uses, such as engineering applications. Examples include use of recycled materials in roadway construction and beneficial reuse as alternative daily cover at landfills. Some of these applications are already proven but are held up by artificial barriers due to outdated laws or engineering standards. Understanding why certain recycled materials are not in demand may help to open new avenues for their use.

Additionally, EPA should analyze technological limits to recycled content. For instance, paper fibers are generally too short after being recycled seven times to be usable. Similar data on production losses for aluminum cans, glass bottles, plastic bottles and containers is necessary to set appropriate recycled content standards."

Read each organization's complete comments:

NWRA's Letter to the EPA
SWANA's Letter to the EPA