Glass Packaging Institute

GPI represents the North American glass container manufacturing industry and supply chain. GPI advocates for policies that strengthen circularity, improve material quality, and promote domestic glass recycling end markets. As a durable, infinitely uniquely recyclable, and inert material, glass packaging plays a critical role in a truly circular economy.

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

1. Fees Should Not be Based on the Weight of the Packaging
EPR for packaging and paper products is largely driven to address plastic issues and basing producer fees on weight misses the mark from the start as it incentives more plastic use. There are other measures such as volume of product sold or units or other combinations within product categories that are better used to base producer fees upon. Incentives should be designed around rewarding and improving circularity and there should be limits to switching into plastic merely to reduce weight-based fees. The core issue facing the system isn’t the weight of packaging — it is a lack of infrastructure investment, contamination from commingled streams, and poor-quality material sorting that reduces yield and limit end-markets. Producers should be incentivized to use domestic product with recycled content and domestic market circularity must also be built into policy. California and Colorado have taken good first steps in this area, but more needs to be done.

2. Improve the System - Do not Merely Shift Costs 
Overprotection of the existing infrastructure and existing service providers merely locks in a system that has largely failed to improve recycling. We understand why large producers want to reduce administrative overhead and that in the beginning of the program, it is easier for one entity to gather up producers for registration. However, locking in all packaging to a single PRO model risks creating monopolies that favor dominant material sectors—particularly plastics—while marginalizing others like glass and aluminum. Legislators should allow alternative PRO options, independent collection systems and alternative compliance plans for materials at risk of marginalization due to over-reliance on commingled single-stream. Design the law to be accommodating of alternatives that diversify collections, like beverage deposit systems or evolving into some cleaner, separate material collections that improve program efficiency long-term.

3. Policy Design Should Incentivize Fairness, Circularity, and Material Balance
EPR policies must ensure that all materials are treated equitably and that system incentives reflect environmental performance. The use of flawed and limited , so-called “Life Cycle Assessments” only serves to incentivize lighter-weight plastic. Eco-modulation needs to be available from the start — rewarding recyclability, reuse, and domestic sourcing and penalizing use of toxic chemicals and complex mixed material packaging that is hard to recycle —is critical to prevent inert, endlessly recyclable materials like glass from being unfairly penalized. Policymakers should also link circularity incentives to domestic production, encouraging brands to source from U.S. recyclers and manufacturers.