CMI

CMI is the trade association representing U.S. metal can manufacturers and their suppliers. CMI’s customers are consumer packaged goods companies that fund producer responsibility organizations. CMI supports a combined EPR and recycling refunds for beverage containers as the best way to significantly increase the recycling rates for can container beverages, food, and household products. CMI is a member of the Coalition for High Performance Recycling (CHPR), a group of brands, packaging manufacturers, environmental groups, recycling system operators, and policy experts.

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

1. CMI advocates increased recycling rates and consumer participation in recycling programs, which can be achieved through a combination of extended producer responsibility (EPR) and a consumer incentive refund for recycling their beverage containers.
‍This should be the focus of producer-financed recycling programs. Occasionally, advocates will include a ban on specific materials approved by domestic and international regulators for use in packaging manufacturing. CMI believes legislators should focus on legislation that finances access to recycling and infrastructure, while deferring to the U.S. Food and Drug Administration for its expertise and approval of materials used in consumer packaging.

2. Fees charged to producers should reflect the total cost to the system of each material type.
This approach ensures that each material pays its cost for collection and processing. This prevents the cross-subsidization of lower-valued materials by higher-valued ones and encourages producers to choose packaging that is readily recyclable and has strong existing end-market demand, in order to “close the loop.” Minnesota’s Producer Fees section of its EPR law [Chapter 115A , Section 115A.1454] is a short but clear example of how each material paying its own way can be written, for reference. Circular Matters, a consultancy, prepared a 2022 report for CMI that examined recycling refund programs and identified which programs share costs more equitably across material types. Oregon, Alberta, British Columbia, Norway, and Sweden are among the top tier of programs where each material type pays its own program costs. California is in the second tier. Its program requires beverage companies to pay material-specific “processing fees” that are calculated through program costs and scrap value revenue.

CMI also opposes preferential treatment of reusable packaging, specifically language requiring producers to pay only once, the first time a reusable package is put into the market. The unintended consequence is that producer fees for single-use packaging fund the infrastructure needed to collect and wash reusable packaging. EPR and recycling refund programs must clearly state that the producers utilizing reusable packaging pay for the infrastructure costs and that single-use packaging fees and taxpayer dollars are not used.

3. EPR+Recycling Refunds (also known as Deposit Return Systems).
As a member of the Coalition for High Performance Recycling (CHPR), we defer to its submission and comments on the benefits of combining EPR and recycling refunds for beverage containers. As previously stated above, CMI supports both EPR and recycling refunds for beverage containers policy.