APR Comments on U.S. Senate EPW Circular Economy Hearing

The Hon. Tom Carper
Chair
Senate Environment and Public Works Committee
2410 Dirksen Senate Office Building
Washington, DC 20510

Dear Chair Carper:

The Association of Plastic Recyclers (APR), the international trade organization that serves as the Voice of Plastics Recycling®, appreciates the opportunity to provide comments to supplement the record of the September 22, 2021, Senate Environment and Public Works Committee hearing, "The Circular Economy as a Concept for Creating a More Sustainable Future." APR is committed to working in cooperation with the Committee to ensure that any legislation and policy achieves the goals of increasing the supply of quality material, enhancing our recycling infrastructure, and expanding markets for recycled material to promote the circular economy.

APR is the only organization that is focused exclusively on growing and sustaining the plastics recycling industry. We are the sole provider of technical and engineering solutions to ensure that plastic packaging is sustainable, recyclable, and can play a role in the circular economy.

APR's membership includes independent recycling companies of all sizes that are processing numerous resins, as well as consumer product companies, equipment manufacturers, testing laboratories, organizations, and others committed to the success of plastics recycling. APR works to enhance quality and increase supply through technical resources, testing programs, design solutions, corporate training, regulatory leadership, and education programs. The APR Design® Guide for Plastics Recyclability is recognized across the globe as the solution to the design challenges facing plastics packaging.

APR members are the recycling industry.APR is intimately familiar with every aspect of this business as our members exist at every link along the chain of recycling. Consumers start the chain by putting their recyclable products in the bin, and companies at the end of the chain buy and use that recycled material for new products. It is that end-of-chain demand that drives the entire system. Recycling breaks down when there is no waiting destination for the paper, plastic, glass, and metal that consumers want to recycle.

The following key points outline how every link of the recycling chain could be strengthened in order to tangibly support and grow recycling in this country.

1. Improve consumer education and participation in recycling programs by better defining and labeling recyclable materials. In recognition of the business realities of recycling, any definition of "recyclable" must contain a market demand component. The APR definition is comprehensive and is provided below as a reference for the Committee as it discusses synchronization of what it means for an item to be "recyclable." APR's definition is also referenced as part of the Global Plastics Commitment of the Ellen MacArthur Foundation.

An item is "recyclable per APR definition" when the following three conditions are met

1) At least 60% of consumers or communities have access to a collection system that accepts the item.

2)The item is most likely sorted correctly into a market-ready bale of a particular plastic meeting industry standard specifications through commonly used material recovery systems, including single-stream and dual-stream MRFs, PRF's, systems that handle deposit system containers, grocery store rigid plastic and film collection systems.

3)The item can be further processed cost effectively through a typical recycling process into a postconsumer plastic feedstock suitable for use in identifiable new products.

APR is eager to work with the Committee to develop a labeling system for products deemed to be recyclable. A better labeling system can provide a needed level of consistency for recycling programs across the country. The current overwhelming differentiation in how packaging is labeled - and what packaging materials are accepted - is a major contributor to the system's lack of collection and proper sortation.

2. Enhance infrastructure to grow collection and improve sortation. Specific goals for recycling rates should be matched with adequate collection and sortation infrastructure development. Otherwise, we are setting ourselves up to fail.

3. Increase demand for recycled content by creating content minimums and other strategies.

• The issue of recycled content supply, and the alleged lack thereof, is a primary narrative used by some consumer brands to justify their inability to incorporate more recycled content in their packages. However, in many instances, there is an ample supply of material available. APR's membership includes the nation's recyclers. As a result, we know what recycled material we have available to market. The fact is that some consumer brands balk at paying the market price for this material. The lack of supply is an incomplete argument; the reality appears to be there is not enough supply at the price that consumer brands are willing to pay.
• Consumer product companies must design their packaging so that it is easier to recycle in today's mechanical systems and recognize that they are their own raw material suppliers in a circular economy. It is difficult for recyclers to manufacture a clean supply of recycled resin if the stream of material they receive is contaminated with non-recyclable packaging.

• Recycled content requirements can increase – and, just as important, stabilize – the market for recycled material. Expanded and stable markets will also have a positive impact on the pricing of recycled material.

• Plastic bags with recycled content should be permitted under requirements similar to California SB 270, which essentially has become a national standard for the bag industry.

Again, APR appreciates the opportunity to provide clarity on the recycling of plastic packaging and its role in achieving a circular economy. We look forward to continuing to work with the Senate Environment and Public Works Committee.Please contact me if you have any questions.

Sincerely,

Steve Alexander
APR President & CEO