A couple weeks ago, I attended the Sustainability in Packaging Conference – an industry trade conference for packaging suppliers and sustainability personnel for large and small companies. Over the course of three days, I had numerous opportunities to dialogue with people throughout the packaging and waste management supply chains – from packaging designers to sustainability staff for brands, to packaging suppliers trying to win their business, to local government and waste management representatives.

Not surprisingly, flexible plastic packaging was a central topic of the conference and of the many networking discussions over drinks and dinner. Over the last five years, many consumer goods companies have switched their packaging from traditional recyclables (aluminum, glass, paperboard, rigid plastics) to flexible packaging (recyclable polyethylene (PE) film, compostable film and non-recyclable laminates). The former have value while the new flexible packaging currently does not – it costs far more to collect and sort than it is worth. This trend is expected to continue: the flexible plastic packaging market is estimated to be worth $351 billion within four years.

There are some environmental reasons to like flexible packaging. Foremost among them is that it has significantly lighter weight than some forms of traditional recyclable packaging, especially glass. Lighter weight means a smaller carbon footprint due to transporting more product and less packaging.

While PE film (such as chip bags, toilet paper plastic wrap, granola bags, disposable shopping bags) is technically recyclable, we saw several presentations which said it could not currently be separated at scale at materials recycling facilities (MRFs), due to the contamination issue and the value to collection costs ratio. PE film and other flexible packaging are a major problem for MRF operators as the materials literally “gum up the works” by getting stuck in machinery that has to be stopped and cleaned.

All of this a major headache for the recycling industry, which does not currently have the technology deployed to efficiently sort and recover this material at scale. In addition, the switch from traditional recyclables to flexible packaging completely confounds the business models of public and private MRF operators that built their facilities based on collecting and selling certain projected amounts of paper, aluminum and higher-value rigid #1 and #2 plastics. By collecting less higher-value materials and having to deal with low to no-value flexibles at MRFs, the recycling industry is suffering. The switch to flexible packaging by the consumer goods industry in the name of the first R (Reduce) has inadvertently created a crisis for the folks managing the third R (Recycle).  

What to do with flexible packaging?

First, let me say that UPSTREAM doesn’t advocate for recycling over source reduction, and certainly does not ignore greenhouse gas emissions any more than toxics issues. What we do advocate for is cradle-to-cradle cycling of all products and packaging, so that everything is designed for perpetual reuse as either a biological or technical nutrient, to use McDonough and Braungart’s terms. Products and packaging that are not designed for infinite cycling should be redesigned or removed from the market.

From a cradle-to-cradle standpoint, it’s important to look at the design and management problems with flexibles, and to treat the three categories – recyclable PE film, compostable film and non-recyclable laminates – separately.

* With recyclable PE film, some MRF operators have suggested that PE film be collected in curbside programs through a “bags in a bag” strategy. Residents put their film in a larger PE bag and put it out at the curb in their recycling bin or cart. While there are some technologies that can be deployed at MRFs to more efficiently recover PE film when it is collected this way, the value of the material often doesn’t justify the investment, plus non-compliance with the “bags in bags” strategy leads to fouled machinery.

The American Chemistry Council is currently working with the Sustainable Packaging Coalition on a “Recyclable: Return to Store” label to be printed on all PE film packaging. They are piloting an in-store takeback program in WI for post-consumer PE film, where the PE film is collected at grocery stores; then mixed with commercial PE shrinkwrap; and then backhauled through their distribution chain to a processor to be recycled.

In Maine, where I live, we have had a requirement since the 1990s – that all stores that dispense plastic bags must provide a collection receptacle in the store. It is often a sad little bin with little to no signage, and is emblematic of a failed program with estimated capture rates of less than 1%. Even aggressive in-store collection programs in California have failed to demonstrate significant collection rates. I have no reason to think that the American Chemistry Council initiative will be any better than what has proceeded it. The labeling may end up confusing customers, especially if there is no “in-store” collection infrastructure or if local recycling programs have decided to collect the material in curbside bins.

All of this begs the question: Is PE film really a “recyclable” package if less than 1% of the material actually gets recycled?

* With compostable film made from natural materials like corn starch and cellulose, there are different issues raised. UPSTREAM works with a lot of organizations to prevent plastic pollution, predominantly from plastic packaging and carry-out (to-go) containers and cutlery. Many of us are excited to see efforts to make to-go packaging and cutlery out of compostable material.

The problem is that most “compostable” material is only compostable in industrial-scale composting facilities, which can generate the kinds of conditions to effectively biodegrade the “bio-polymers.” There has not been enough research to determine what happens to compostable polymers in the environment, and I’m not qualified to make any judgments here.

However, if compostable film companies are able to develop products which can be harmlessly biodegraded in composting bins, and even better – in seawater – then we may have products which make sense for use in some applications. A lot of thought needs to be given to the types of applications where compostable packaging makes sense, and producers need to develop plans that can be scaled up across the country for ensuring their packaging makes it into a composting facility rather than the garbage.

* With non-recyclable laminates, product designers have created packaging that is literally “designed for the dump” and completely violates the Sustainable Packaging Coalition’s definition of a sustainable package. As my friend Dick Lilly, Waste Management and Product Stewardship Manager for Seattle, says, “It’s not sustainable if it’s garbage.” We believe that this type of packaging needs to be phased out in favor of reusable, recyclable or compostable packaging. At the Sustainability in Packaging Conference, I spoke with several sustainability reps, who all said they were pressuring their suppliers to develop flexible laminated packaging that reduced the amount of different materials to one polymer so that the package would be recyclable.

There are technical obstacles to this, as each layer in the laminate performs different functions (e.g. one prevents oxygen from getting inside; the other – water, etc). We would bet that the company that develops this technology first will see a significant boost in business.

Where do we go from here?

OK, so now what? Not surprisingly, we see this as another signpost that we need extended producer responsibility (EPR), which makes manufacturers responsible for green design and reducing, reusing and recycling their packaging. The companies that put packaging into the marketplace need to have a plan for where that packaging is going once consumers are finished with it.

The plan should follow the cradle-to-cradle model of designing packaging to become either biological nutrients (biodegradable, compostable, etc.) or technical nutrients (metals/petroleum-based polymers, etc.) at end-of-life. The plan must include how packaging will be collected and processed into either bio-nutrients to grow plants, food and farms; or tech-nutrients to grow products and industry. Finally and most importantly, the plan has to include how companies will finance the deployment of collection, processing and outreach strategies and technologies – at scale nationwide – to ensure that 90%+ of the packaging is utilized.

At the Sustainability in Packaging Conference, Dick Lilly said, “Without EPR, it won’t be possible to fund full recovery of less valuable plastics… Sustainability in packaging requires that we invest to improve our MRFs to a) capture packaging that now goes into the garbage because we can’t process it, b) develop systems to recover new kinds of packaging – usually plastic – so it can be recycled as feedstock for new products, and c) reduce processing yield loss.” He asked, “Can EPR make this possible?”

We believe that it can. We also believe that without EPR, we will continue to plunge headfirst toward the alternative being proposed by many consumer goods and waste management companies, which is to sift flexible packaging out of the garbage and pelletize it into fuel that can be used in any industrial boiler in the United States – without proper emissions controls to protect public health from the toxic chemicals caused by burning plastic.

Guess who is also complicit in this scheme? According to Global Alliance for Incinerator Alternatives: “The U.S. EPA recently created a toxic and deceptive loophole around Clean Air Act health protections, allowing the deregulation of waste burning in literally hundreds of thousands of industrial facilities across the country. If these facilities burn waste under this loophole, they will not be required to meet federal emission control standards and permitting processes for incinerators – creating a disastrous back door way to get around regulations designed to protect public health.”

For obvious reasons, we prefer the development of a unified packaging system that holds companies responsible for the design choices they make, and ensures that they create cradle-to-cradle systems for producing, using and managing packaging. Properly designed EPR initiatives can help us achieve packaging systems that generate a wide variety of economic, social and ecological value.

We will continue to explore what an EPR packaging system could look like that meets these values in our blog over the next few months. Stay tuned! For a look at NGO principles on packaging-EPR, check out the CRADLE2 Coalition’s Packaging Platform