Part 1 of RCC’s Series on Recycled Content
Recycled content regulations have emerged as an economic instrument to help drive demand for post-consumer resin (PCR), advance markets for recycled plastics and drive a circular economy. Moreover, the implementation of PCR minimum requirements can increase the value of recycled materials which can help improve the economics of recycling and drive investment and innovation.
Post-consumer resins (PCR)
Materials, such as plastics, that have been collected and recycled (often through curbside programs) so they can be utilized as post-consumer resin in new applications (e.g., packaging, products, etc.).
Do not contain recycled content and are commonly produced from petrochemical feedstock (e.g., natural gas, crude oil, etc.).
With this significant regulatory shift, it is critical that retailers begin preparing for these requirements with their supply chains as recycled content regulations are developed and implemented across North America. From California to Europe, recycled content minimum requirements are on the rise in an effort to increase the supply of quality PCR and drive a circular economy through:
- increased collection, processing, and recycling of plastic waste;
- the creation of incentives for investments in innovation and infrastructure; and
- improved product and packaging design for the environment.
Here in Canada, the federal government has set an ambitious goal to achieve zero plastic waste by 2030. Central to achieving this goal will be a requirement for plastic packaging to be at least 50% recycled content by 2030. In February 2022, Environment and Climate Change Canada conducted a consultation on a proposed regulation to establish minimum recycled content requirements for certain plastic items. The government’s intentions for the minimum requirements are to drive improvements in product/packaging design and recycling infrastructure while reducing greenhouse gas emissions.
As recycled content regulations emerge globally, many retailers and brands have already announced their corporate goals for increasing recycled content in their packaging. Unfortunately, as organizations look to meet their objectives, the supply of quality PCR remains sparse. With an expected increase in demand for recycled resins with recycled content minimum regulatory requirements in place, an adequate supply of quality feedstock will be critical to the success of any regulation or corporate goal.
Over the last year, RCC has been actively engaged with Environment and Climate Change Canada and are advocating for the following policy considerations:
In infrastructure to ensure the supply of high-quality recycled resins to meet the significant increase in demand that the regulation would bring. Last year, the federal government committed to a $100 million infrastructure and innovation fund dedicated for the reuse and recycling of plastics. The details of this fund have yet to be released.
In innovation that would explore opportunities to further improve the outputs of mechanical recycling while also further studying the feasibility of chemical recycling. Technologies like chemical recycling have not been proven at commercial scale. Moreover, further study is required to determine health and environmental impacts.
It will be critical to set high recycled resin quality standards to limit contamination to ensure product, packaging and consumer safety. The biggest quality challenges relating to PCR include:
- contamination from other plastics in the stream;
- additives and colourants used in recycled plastic production; and
- odour issues.
Moving forward, stakeholders should be consulted to develop a range of recycled content quality parameters and standards. This should include laboratory practices, composition specifications and testing measurements and methodologies. Quality issues are a prime deterrent for the uptake of recycled content given the variances between virgin and recycled resins which can impact structural integrity. There are, however, solutions to manage the differences between recycled and virgin plastics, including the use of performance additives such as UV absorbers, water-based heat sealants, anti-block agents, fillers and impact modifiers.
Given there are challenges, such as the risk of potential contaminants from the recycled content leaching onto food, consideration for food-contact applications should only be explored once high quality standards are developed.
Environmental and health factors relating to recycled content should be considered when assessing recycled content requirements and Environment and Climate Change Canada should be working closely with their counterparts at Health Canada accordingly. Analysis is needed to better understand items where recycled content poses a risk to health, safety and/or security.
Using a chain of custody approach to validate recycled content documentation will be key to creating a level playing field. This will also help ensure transparency and equity in the system while helping to eradicate “greenwashing.” Extensive third-party verification should be used in order to avoid administrative burdens and block chain technology may be considered as a means to document flow of materials and data.
Examples of emerging recycled content regulations and trends include:
|California, USA||Taking a product-based approach with standards based on PCR:|
– Plastic bottles: 15% as of January 1, 2022, 25% in 2025 and 50% in 2030 (penalties if requirements are not met)
– There are also standards for garbage bags and rigid packaging.
|Washington, USA||Taking a product-based approach with standards based on PCR:|
– Plastic bottles: 15% in 2023, 25% in 2026, 50% in 2031
– Dairy milk containers: 15% in 2028, 25% in 2031, 50% in 2036
– Household cleaning/personal care products in plastic containers: 15% in 2025, 25% in 2028, 50% in 2031
– Garbage bags: 10% in 2023, 15% in 2025, 20% in 2027
More info here.
|New Jersey, USA||On January 10, 2022, Bills S2515/A4676 were signed into law. These will establish PCR requirements for glass containers, rigid plastic containers, paper and plastic carryout bags, and plastic trash bags.|
– Rigid plastic containers: 10% in 2024 and increasing incrementally until 50% by 2036
– Plastic beverage containers: 15% in 2024 and increasing incrementally until 50% by 2045
– Glass containers: 35% in 2024
– Paper carryout bags: between 20-40%, depending on size, in 2024.
– And more…
|Australia||As part of the 2021 National Plastics Plan, Australia has a National Packaging Target of 50% average recycled content included in packaging by 2025 (20% for plastic packaging).|
|UK||As of April 2022, there is a Plastic Packaging Tax (PPT) for all packaging that has less than 30% recycled content (some exemptions apply).|
|EU Single-Use Plastic Directive||By 2025, PET bottles must contain at least 25% recycled plastic. Requirement will increase to 30% in 2030. More info here.|