Revisions/Clarifications to SPC Labeling for Recovery Project Post!!!

April 13, 2011

Hey guys!

I’m back! The Walmart SVN/Expo was great! I will give you the skinny ASAP. In the meantime, however, I wanted to revise/clarify some of the claims made in my April 7th post, titled “Feedback from SPC’s Labeling for Recovery Project.” The lovely Anne Bedarf, project manager of the SPC, who works extensively on this Project, sent me the following email:

Hi there Chandler—great to see you in Arkansas, hope you make it home fine.

Thanks for blogging on the Labeling for Recovery Project! There were, however, a number of errors/clarifications needed that I’d like to bring to your attention. I’ve put them in below in bold. Feel free to quote me on them. Let me know if you have any questions, and thanks.

Kind regards–AnneB

As per her request, check out the revised post below!

Helllooooo my packaging and sustainability friends!

Today I am going to begin discussing the insights of the SPC meeting I attended in San Diego last week. As alluded to in yesterday’s post, these meetings are conducted under the “chatham house rule,” which means that “participants are free to use the information received, but neither the identity nor the affiliation of the speaker(s), nor that of any other participant, may be revealed.”

I flew into San Diego on Monday to catch part of the pre-conference workshops—specifically—the “SPC Labeling for Recovery Update” as I spend a lot of time researching end of life management of packaging materials. One of the arguments I make in my Recycling Report is that the SPI ID code on the bottom of plastic packaging is an inefficient means of segregating plastic by resin type for its end of life reprocessing in manual sortation systems. Do note, however, that sortation by resin type post-consumer was never the SPI’s intention with these codes—it was more constructed as a form of intra-industry communication. ANYWAY, the SPC’s Labeling for Recovery Pilot looks to model itself a bit off the UK’s Labeling for Recovery scheme insofar as it is intended to communicate to CONSUMERS what packaging materials are recycled, what may be recycled, and what currently are not recycled. For those of you unfamiliar with the UK’s labeling scheme, it began as a project by WRAP, which was subsequently re-identified as OPRL Ltd. (On Pack Recovery Label). It actually became a subsidiary company created by WRAP and the British Retail Consortium. WRAP is still WRAP. OPRL is now used on more than 90% of grocery packaging in the UK and has reportedly resulted in increased understanding by consumers of what is recyclable and what is not, thereby elevating recovery rates of packaging waste post consumer. The catch, for lack of better words, is that companies wishing to use this labeling scheme on their packaging must pay the “distributors” of this scheme an agreed upon annual fee. Like most “certifications,” I believe, –be it SFI, USDA Organic, Green Dot, etc.– money must be generated by those wishing to use said label/certification in order to ensure the proper distribution and implementation there of. I just read this article, which explains how SFI is in some hot water as many Fortune 500 companies that previously used said certification are removing it from new product packaging due to the unethical implications of this entire certification system. Therefore, it is very, very important when using/issuing a labeling scheme/certification that due diligence is taken throughout the supply chain to ensure that the label conveys to consumers what it is intended to convey, without falling into the deep, dark waters of GREENWASHING, dun dun dunn. Sorry I am getting way off track. Totally agree—BUT—this label is NOT a certification. It’s more like the nutrition label for recyclability. Also there will be no fees charged during the pilot—we are looking at fees for long-term implementation mainly to ensure that it is properly used and that we have proper data collection.

So, the SPC’s Labeling for Recovery Project attempts to present a legitimate, uniform labeling scheme that educates consumers on what types of packaging can and cannot be recycled currently in America. The workshop got in somewhat of a debate, however, over what percentage of recovery/REACH data per packaging material is considered “recyclable,” vs. “check locally,” vs. “not currently recycled.” Obviously, most participants in the workshop represented some type of packaging material, and no one wants to have a “not currently recycled” label on their packaging, regardless of if that is the reality of the situation. At first it was articulated that the FTC’s recently revised Green Guides would be used to determine what is considered “recyclable” (60% or more American communities have access to facilities that can recycle packaging X post-consumer) vs. “check locally” (20%-60% “…”) vs. “not currently recycled” (less than 20% “…”). This type of data collection, that is, what percentage of Americans/American communities have access to recycling facilities that can reprocess packaging material X, is called “REACH” data, though I myself am a little confused about the difference between having access to recycling facilities vs. actually recycling packaging…This is a legitimate concern. Our first filter is Reach data—per FTC, related to collection. Our secondary filter is actual recyclability and a number of “prohibitives” will be on an “exceptions” list. For example, PET bottles are widely recycled; however, with a PVC shrink under our system they will not be labeled as such but as not yet recycled.

ANYWAY, the workshop spent a considerable amount of time discussing:

Holes in existing data sets, be it REACH data or recycling/recovery data (American data sets don’t consider incineration with energy recovery as a form of “recovery,” which is part of the reason that the “recovery” rates of packaging waste in the EU far exceeds that of America);

How incineration with energy-recovery would be incorporated into the labeling scheme, though little post-consumer waste is incinerated in America due to its sour reputation from the early 1990s; There is actually no way this could be included because we can’t determine final end use from reach data, MRF info, or prohibitives in recycling.

AND how private/closed loop recycling schemes, like those implemented by RecycleBank and TerraCycle, would be included into the construction of this labeling scheme as these non-national facts and figures are not currently incorporated into the US EPA/ACC data sets on packaging waste recycling/recovery. This isn’t totally true. You’d have to ask EPA, but remember EPA only looks at Rates, not Reach. Recycle bank helps get curbside recycling started, and those communities that have curbside are included in reach data analysis. I think that part of the discussion was more about drop-offs that weren’t part of a municipal program. TerraCycle isn’t included because we don’t really think mail-back is currently an effective recovery strategy—and after all—how would one measure “reach” for mail-in?

As you can see, something so simple as trying to educate consumers about what is recycled and what is not recycled is not NEARLY as easy as it seems—you have to deal with lack of uniform/accurate data sets, conceptual discrepancies between using data set A (REACH data) vs. data set B (recycling data), plus how to incorporate compostability data, incineration with energy recovery data, private/closed loop recovery scheme data, and much much more! Fun stuff, eh!??!

Thanks Anne!!!

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