American Chemistry Council
ACC is a national trade association representing America’s Plastic Makers. We work across the plastics value chain to advance circularity, support recycling solutions, and help shape effective, durable Extended Producer Responsibility (EPR) policies.
Three Recommendations for Legislators Developing Circular Policy and EPR for Packaging Policies:
1. Keep policies technology neutral and grounded in real needs. EPR programs should be built to last decades. Legislators should avoid prescriptive language that locks in today’s systems and instead allow programs to evolve as new solutions emerge. States should also “look before they leap” by conducting a needs assessment to understand current infrastructure, material flows, and market realities before enacting mandates.
Why it matters: Without neutrality and a clear baseline, states risk discouraging investment, locking in outdated systems, and missing better solutions.
2. Strengthen trust and accountability through third-party certification.
Independent third-party certification systems play a critical role in verifying recycled content and supporting accurate environmental claims. Certification systems that are transparent and auditable provide the traceability needed for producers, policymakers, and consumers to trust the recycling data being reported. These systems offer deep technical expertise in how to account for recycled content, including the use of mass balance, and include inspections and audits that state agencies may not have the capacity to conduct. Recognizing established certification programs also prevents each state from creating different or duplicative approaches.
Why it matters: Third-party certification increases transparency, supports consistent reporting across states, and provides the certainty needed to drive investment and demonstrate verifiable progress toward recycling goals.
3. Promote consistency across states and empower the PRO to deliver results.
Packaging is designed, manufactured, and distributed across state lines. Fragmented or conflicting rules increase costs and complexity without improving outcomes. Legislators should strive for consistency in definitions, labeling, certification, and reporting. Producer Responsibility Organizations (PROs), such as the Circular Action Alliance, play a key role in harmonizing approaches across states while tailoring implementation to local needs. States should also avoid reinventing the wheel by leveraging existing third-party certification programs instead of creating new state-specific systems. Giving PROs flexibility to design, manage, and update plans ensures programs remain effective and efficient.
Why it matters: Consistency across states avoids a patchwork of rules, empowers PROs to focus on results, and enables scalable, nationwide progress toward circularity.
For more information, please consider these external resources available in the Public Facing Statements & Resources Section: