Casella

Casella provides recycling services to homes and businesses throughout the Northeast and Mid-Atlantic states. We help producers nationwide meet their zero waste and sustainability goals.

Recommendations for Policymakers Developing Circular Policy & EPR for Packaging Policies:

1. EPR has been proven successful for managing hard-to-recycle and hazardous materials. Successful EPR programs aim to address materials such as textiles, mattresses, carpets, paint, tires, solar panels, wind turbines, batteries, and appliances, which cannot be managed within existing recycling facilities. Most proposed EPR programs for paper and packaging contemplate covering materials that are already effectively and safely processed at recycling facilities. Recycling outcomes for these materials would improve with targeted consumer education efforts and minimum recycled content standards, rather than the full intervention of EPR. Packaging types that would be considered hard-to-recycle – and potentially appropriate targets for EPR – include film plastics, flexible packaging, disposable serve ware, take-out containers, and Styrofoam coffee cups and lids.

EPR programs must find ways to target the recovery of hard-to-recycle materials without harming

established and effective recycling programs.

2. Minimum recycled content standards are essential to driving the use of recycled materials. The best driver for sustainable recycling outcomes is strong producer demand for recycled commodities. When demand is strong and reliable, service providers and communities have a market-based incentive to invest in new recycling services and infrastructure. Policy makers can support this demand by requiring producers to incorporate recycled content into their new products through “minimum content standards.” By appropriately phasing these requirements, policy makers can make recycled content more competitive with raw materials and drive a shift toward a more circular economy. For hard-to-recycle materials, EPR programs should include minimum recycled content standards. For materials that are already readily recycled, standalone minimum content standards will be more efficient and effective than EPR.

3. EPR should be used as a funding mechanism to support and strengthen existing recycling infrastructure. In areas with existing recycling infrastructure and service offerings, EPR policy must be designed to protect and strengthen municipal, county, and authority-based recycling and reuse programs. It should protect and promote investments in existing recycling facilities. EPR decisions should be based upon a comprehensive initial needs assessment of the current state of recycling and advised by the concerns and recommendations of all relevant stakeholders, including producers, municipalities, residents, retailers, private haulers, and recyclers. If deposit return (bottle bill) programs are considered as part of a state’s circular packaging policy, care must be taken to fairly integrate these programs with other recycling services such as single stream recycling. Service providers such as haulers and recyclers have decades of experience servicing their communities and they should have a strong voice in EPR programs. Producer organizations should not be given authority to upend existing recycling programs, infrastructure, and businesses.

Thank you for your focus on advancing recycling and circularity in your state. Through waste reduction, reuse, and recycling, we help to keep our communities clean, create local and regional employment, and advance an essential climate solution. We look forward to working with you on proposed legislation in the states we serve.