Category: How2Recycle

Effective July 31, 2021, the How2Recycle® label program is establishing new criteria for when material health considerations will impact recyclability claims. This is not entirely new for the How2Recycle program to touch on material health issues; in January 2020, How2Recycle announced that any packaging that contains intentionally added per- and polyfluoroalkyl substances, or PFAS, will be labeled Not Yet Recyclable. Now for broader purposes, How2Recycle would like to provide objective, clearly articulated criteria to share with members and the general public when it might render a package Not Yet Recyclable in the future due to the presence of a harmful or potentially harmful material.

New material health rule for How2Recycle
How2Recycle may render a package Not Yet Recyclable if it contains intentionally added substances that are harmful or potentially harmful to the environment and/or human or nonhuman animal health.

Reasoning for the rule—why does it exist?
Material health is typically perceived as a distinct concept within the sustainable packaging life cycle, separate from whether a package is designed for recovery. However, How2Recycle believes it’s important to include it as a relevant consideration for issuing recyclability claims for the following reasons:

• Harmful or potentially harmful substances will or could substantially limit the successful circularity of a material long term.
• Precautionary principle: the principle that the introduction of a new product or process whose ultimate effects are disputed or unknown should be resisted. GreenBlue supports this concept.
• Trust of the How2Recycle label and its members in the eyes of the general public.
• Trust of recycled materials in the eyes of the general public.

How will the rule work?
From time to time, How2Recycle may examine a material more closely in order to determine whether packages containing that material should be rendered Not Yet Recyclable because of material health concerns.

These materials are at this point considered under review.

How2Recycle may place materials under review in the presence of one or more of the following conditions:

• How2Recycle becomes aware from credible scientific sources that a material used in packaging that is currently labeled as recyclable could potentially cause harm to the environment or human health
• How2Recycle has reason to believe that a material used in packaging that is currently labeled as recyclable may be substantially similar to another material known to cause harm to the environment or human health

These materials of concern may be present or potentially present in packaging in the following ways:

• Additive
• Process aids
• Materials
• Material precursors
• Coatings
• Fillers

Priority & sequence of under review
How2Recycle may be monitoring multiple materials at any given time to assess whether they should be put under review. It is likely that How2Recycle will take a phased approach to putting materials under review in order to manage operational complexity—meaning, even if there are several candidates to potentially place under review, the program may end up only choosing one or two at a time to tackle. How2Recycle may prioritize placing certain materials under review for a variety of reasons at its sole discretion, including:

• level of risk of harm to environment or health characterized in scientific literature,
• prevalence of use in packaging,
• understanding of and availability of safer alternatives, and
• relevant legislative or regulatory action.

The review process
When a material is under review in How2Recycle, the program will conduct its own investigation or research in order to determine whether packages containing the material should be rendered Not Yet Recyclable due to material health concerns. This process may include reaching out to the manufacturers of these materials and converters who work with these materials to better understand their chemistry, reviewing scientific literature in detail, and contacting other environmental nonprofits, governmental entities or scientists for relevant information. At the conclusion of the review period, which can differ in length based on the circumstances, How2Recycle will announce any changes to recyclability to its members and the general public.

In 2020, How2Recycle placed PFAS for PE films (primarily used in process aids) under review. The conclusion of that review is included at the end of this article.

There are several potentially determining factors for How2Recycle to consider in assessing whether an item should be deemed Not Yet Recyclable due to material health concerns. There are other factors that could provide additional context to the assessment process but will not be considered determining or authoritative criteria.

The following considerations are potentially determining factors for How2Recycle to prohibit recyclability claims due to material health concerns:

• Potential harm to human or nonhuman animal health or the environment. This includes the material at issue potentially disrupting biological processes or causing potential harm to a species’s ability to thrive. For example, whether the material causes or may cause cancer, birth defects, reproductive harm, harm to body systems such as endocrine systems, or genetic damage. Potential harm may derive from skin contact, ingestion or inhalation of the material.  Also considered is potential harm to the environment, such as negative impacts to water quality, biodiversity, plants, soil or air quality. Potential harm to humans or nonhuman animals, other organisms and/or the environment may occur during manufacture, use, or recovery of the material.
• Persistence of the material. This refers to the material’s persistence in human or nonhuman animal bodies or other organisms, or the environment, and/or the length of exposure to bodies or the environment.
• Stability of the material. This refers to potential changes in composition in the product due to chemical or biochemical reactions that may occur, such as oxidation, polymerization, depolymerization, enzymatic degradation, hydrolysis, thermolysis and photolysis. The more stable a material is, the slower it may be to break down in the environment.
• Mobility of the material. This refers to the material’s ability and likelihood to migrate from packaging to the surrounding environment, or to human or nonhuman animal bodies or other organisms.
• Bioavailability of the material. This refers to the material’s ability to enter into circulation when introduced into the human or nonhuman animal body or other organisms and so is able to have an active effect.
• Bioaccumulation of the material. This refers to the gradual accumulation of substances in the environment or in human or nonhuman animal bodies or other organisms.
• Solubility profile of the material. This refers to whether and to what extent the material is soluble in water, fats, oils or other substances.
• Potential impacts of the material’s degradation products. Whether or not the degradation of the material makes it safer or not depends on the chemical in question. For example, some materials of concern break down into harmless products, others break down into hazardous products, and others do not break down at all and are considered “forever chemicals.” Some degradation products may possess different harm, persistence, stability, mobility, bioavailability, bioaccumulation or solubility characteristics than the material in question.
• Tradeoffs of the material’s use in packaging. There may be environmental benefits to the material such as it enabling lower energy use or less material use. These considerations should be considered and weighed against potential health risks.
• Whether or not safer alternatives exist for the material. Regrettable substitutions should be avoided. Alternatives should be closely scrutinized to ensure they do not pose the same or substantially similar material health risks as the material at issue. Additionally, the relevant tradeoffs for the alternative should be considered.
• Legislative or regulatory action. This refers to whether governmental bodies are seeking or potentially seeking to create laws or regulations around a specific material because of material health concerns.

The following considerations are potentially relevant context but are not determining (not authoritative; not controlling) factors for How2Recycle to prohibit recyclability claims due to material health concerns:

• The overall value to the industry or the general public of the material under review in packaging; usually is associated with performance, packaging functionality or cost
• The level of difficulty, complexity, inconvenience or cost for industry to pivot to a safer alternative
• Whether governmental bodies or various organizations, in North America or abroad, have characterized the materials as either safe or hazardous or potentially hazardous.
• The level of media attention given to the safety of the material and the quality of that reporting.

What helps How2Recycle make the assessment
Material health issues are complex and are often difficult to research and analyze, so complete understanding of an issue may be elusive. That said, How2Recycle endeavors to explore the following factors where feasible:

• Understanding breadth and drivers for the material’s use
• Understanding varieties of the material that may exist and why certain varieties are used in different contexts
• Understanding how the material is made and how it’s used in the packaging manufacturing process
• Understanding the chemistry of the material itself as well as its chemistry when applied to packaging
• Understanding the potentially relevant biology considerations in relation to the material’s potential impact on human or nonhuman animals and other organisms
• Understanding potential impacts to the environment and/or human health of the material during its life cycle, including production, consumption and recovery (including, as relevant: reuse, mechanical recycling, chemical recycling, composting, waste to energy, landfill). This could involve how the chemistry may or may not evolve through these stages.
• Understanding potential impacts to health across relevant groups such as manufacturing workers, retail workers, end users, and local communities or ecosystems.
• Understanding whether alternatives exist, and whether those alternatives are:
  • Commercially available
  • Likely to be used
  • Studied and well-understood to be safer from a material health perspective
• Available scientific literature on any and all of these concepts
• Trustworthy and scientifically credible literature on these topics from governmental entities, companies or other organizations such as NGOs

Overarching principles

• How2Recycle wants to make the scope of a ruling on a material narrow enough as to not be overbroad, unreasonable or overly burdensome, but also not overly specific to unintentionally create loopholes for similarly hazardous materials to slip through.
• How2Recycle follows an objectivity, science-based and systems-thinking approach.
• How2Recycle will do its best to appropriately define and characterize the material at issue since confusion, synonyms, and competing definitions are rife in this space.
• The rule should align and not conflict with existing standards of material health but will likely operate at a shallower level. This is because other schemes provide a more comprehensive risk assessment of a material, or are designed to achieve ideal or even aspirational material health outcomes.
• The How2Recycle program does not endeavor to become a comprehensive material health assessment body, but rather wants to ensure that by calling certain items recyclable, the program is not perpetuating or enabling wide-reaching and/or known toxicity in the circular economy. How2Recycle acknowledges both the limits and possibilities of its reach and influence in the sustainable packaging space, and seeks to navigate this space in a deeply pragmatic yet principled way. In the future, How2Recycle may consider more explicit alignment with any of the following potentially relevant standards, methodologies or tools:
  • Cradle2Cradle
  • Bluesign
  • ZDHC
  • Detox Campaign
  • HIGG Material Sustainability Tool (MSI)
  • CHEM-IQ
  • GreenScreen for Safer Chemicals
  • The Sustainability Consortium
  • OEKO-TEX Standard 100
  • Safer Choice Master Criteria
  • SciveraLENS
  • ChemFORWARD
  • Others
• Depending on the material at issue and availability of analytic techniques, How2Recycle may or may not allow third party lab testing to demonstrate an intentionally added material is present at a certain loading.

Update on How2Recycle’s position on PFAS in polyethylene film

In January 2020, How2Recycle announced that any packaging that contains intentionally added per- and polyfluoroalkyl substances, or PFAS, will be labeled Not Yet Recyclable. While this rule was initially targeted at fiber packaging, How2Recycle came to realize the breadth of use of fluoropolymers used in processing aids in polyethylene (PE) film. Over the last year, How2Recycle paused issuing Store Drop-off labels for these items and placed PFAS in PE films under review. The program took time to investigate the material to understand whether these fluoropolymers should render PE film Not Yet Recyclable due to material health concerns.

How2Recycle examined best available evidence to assess the potential harm to the environment and human and nonhuman animal health of these materials, their prevalence and use in films, and the availability of safe alternatives. During the review process, How2Recycle conducted a scientific literature review, studied NGOs’ and other scientific bodies’ stance on PFAS, reviewed proposed and enacted legislation and regulation in North America and globally, and contacted fluoropolymer manufacturers, film manufacturers, film converters and other experts. This process informed the development of How2Recycle’s new material health rule detailed above.

Based on the conclusions of this review, PE films containing fluoropolymers used in processing aids, mold release agents, or other additives are eligible for a Store Drop-off How2Recycle label at this time. However, PFAS use should be minimized and ultimately phased out in favor of safer alternatives to avoid the intentional contribution of environmentally persistent hazardous chemicals to the recycling stream. How2Recycle will continue to monitor the use of PFAS in packaging and the development of safer alternatives. This rule may change in the future.

Material health is complex and it can be difficult to understand an issue entirely. While these fluoropolymers are similar to PFAS of concern because they are environmentally persistent, ultimately How2Recycle concluded that there are sufficient differences to not render their use Not Yet Recyclable at this time. Specifically, it appears the higher chemical and biochemical stability, higher molecular weight and lower mobility of these fluoropolymers limits their environmental and health hazards compared to other PFAS. Additionally, using fluoropolymers during film manufacturing reduces energy requirements and has resulted in thinner films and films using more recycled content. While these attributes are well documented, the fate of these fluoropolymers during the manufacturing, use and end of life of PE films is less understood and further research is needed. How2Recycle challenges its members to work towards a greater understanding of: 

• The stability of these fluoropolymers during film conversion processes such as cross-linking, ink-curing and surface treatments
• The hazards associated with mechanical and chemical recycling of PE films containing these fluoropolymers

If you have any feedback on this material health rule, please submit comments to how2recycle@greenblue.org in the interest of continuous program improvement.

How2Recycle upgrades recyclability of certain rigid polypropylene (PP) formats

Effective July 29, 2022, the How2Recycle® labeling program is upgrading the eligibility of rigid polypropylene (PP) tubs, bottles, jugs, and jars from Check Locally to Widely Recyclable in the United States. Thanks to data provided by, and the continued work of, The Recycling Partnership’s Polypropylene Recycling Coalition and other industry investments, How2Recycle is confident this progression in eligibility continues to be aligned  with the Federal Trade Commission’s Green Guides.

“The efforts of the Polypropylene Recycling Coalition are a great example of the impact that can be made with collaborative action focused on supporting the full recycling system and we are honored to have been in an advisory role since its inception,” said Caroline Cox, Director of How2Recycle. “As rigid polypropylene access, sortation, and end markets are on an upward trend across the U.S., we are excited to upgrade this packaging format from Check Locally to Widely Recyclable eligibility. Thanks to the strength and efficacy of the national data provided, How2Recycle is confident that this change in eligibility continues to be in line with federal law. While this win should be recognized, it is important to note that this is not the end of the road; the entire value chain should continue to invest in improving the recyclability of all materials and packaging formats.”

Launched in July of 2020, the Polypropylene Recycling Coalition’s mission is to bring stakeholders across the PP value chain together—from resin suppliers and manufacturers to consumer packaged goods, and recycling processors—to improve PP recovery and recycling in the U.S. and to further develop end markets.

“Achieving success for challenged materials is not a narrative often heard in our industry.  It was a mere two years ago when we acknowledged the challenges polypropylene recycling was facing and its uncertain future.  In forming the Polypropylene Recycling Coalition, we committed to leaning in and taking action in support of the material, to push ourselves and the industry to a more circular future,” said Keefe Harrison, CEO of The Recycling Partnership.  “The power of collaboration across the value chain can be seen through this substantial system wide shift for polypropylene.  The precedent we are setting for materials, coalitions, and innovations is exciting and hopeful.  We encourage companies to join us as we continue to lean in and push polypropylene recycling to new heights.”

Other rigid PP packaging formats, including PP beverage cups, remain eligible for Check Locally How2Recycle labels at this time. How2Recycle is pursuing additional data regarding the access to recycling and end markets of PP beverage cups in order to determine whether these packages should be upgraded from Check Locally to Widely Recyclable in the future.

How2Recycle is continually researching and analyzing issues in packaging recyclability and updates its program rules accordingly. This is done by assessing the recyclability of each package that features a How2Recycle label based on multiple criteria, which include how many people have access to recycle that package through curbside or drop-off programs, if the package is likely to  sort and reprocess correctly, the technical reprocessability of the package, and if reliable end markets exist for the material. Each How2Recycle label is backed by scientifically credible data so that the general public can rely on a consistent, standardized recycling labeling system run by a 501(c)(3) environmental nonprofit to help them recycle more accurately.

About How2Recycle
The How2Recycle® label is a U.S. and Canada-based standardized labeling system that clearly communicates recycling instructions to the public. Nearly 500 brand owners and retailers are members of How2Recycle, and tens of thousands of products carry the How2Recycle label in the marketplace. How2Recycle is a project of the Sustainable Packaging Coalition®, a membership-based group that brings together business, educational institutions, and government agencies to collectively broaden the understanding of packaging sustainability and develop meaningful improvements for packaging solutions. How2Recycle and Sustainable Packaging Coalition are a part of GreenBlue, a 501(c)(3) nonprofit based in Charlottesville, Virginia, United States. For more information, go to our website at www.How2Recycle.info. Companies interested in joining How2Recycle can visit https://greenblue.org/projects/how2recycle/how2recycle-membership/ for more information or contact how2recycle@greenblue.org.

Every day, brands and packaging producers submit detailed packaging specifications to How2Recycle®, and the program assesses the recyclability of each packaging type and issues specific recommendations for design improvement. On average, the How2Recycle program issues recyclability labels to brands and retailers for over 225 products every day. Of those, about 10% include the Store Drop-Off label. 

How2Recycle has completed an in-depth study on Store Drop-Off recyclability, and is pleased to share the results for the benefit of the general public in this report.

What is Store Drop-Off?

The Store Drop-Off label applies to certain flexible polyethylene (PE) film packaging, such as bags, wraps and pouches. Through Store Drop-Off recycling, consumers can take items featuring this label—like the wrap around paper towels, produce bags or certain stand up pouches—to their local participating retail location to recycle along with any plastic shopping bags.

Store Drop-Off collection bin at a Target.

The Store Drop-Off program is available to the majority of the population in the United States. It is not owned or operated by any central or unified entity. Rather, individual retailers set up their own collection systems, sometimes in collaboration with specific PE film recyclers or programs like American Chemistry Council’s WRAP.

The material collected through Store Drop-Off is recycled into a variety of end applications, the most dominant being composite lumber and plastic shopping bags. According to the most recent data available, over 225 million lbs of material were recycled through Store Drop-Off in 2017.

The recyclability challenge for flexible packaging

About half of How2Recycle member packaging components are flexible, such as bags, wraps, pouches, and wrappers.

Store Drop-Off is the only recycling option for flexible packaging at scale, and is only available to polyethylene flexible packaging.

While about 36% of members’ flexible packaging receives the Store Drop-Off label, the remaining 64% is Not Yet Recyclable:

Accordingly, flexible packaging is far and away the biggest and most challenging recyclability challenge facing brands. The marketplace is experiencing an unprecedented explosion in flexible packaging, most of which is not recyclable. This is almost half the entire challenge for companies to hit recyclability goals (see the Recyclability Insights report for more detail). While some product categories can be very easily changed to Store Drop-Off packaging today, others, such as those containing wet and sticky products or those requiring a very high performance barrier, require recycling system interventions. These interventions may include new or different collection mechanisms for reprocessing technologies like chemical recycling. See the “Considerations for far future recyclability” section of the How2Recycle Guide to Future Recyclability for more detail.

However, the ability of the Store Drop-off stream to alleviate the packaging industry’s end-of-life challenges with flexible packaging is limited long term. Like all recycling streams, market volatility in the global commodities context is a challenge. But for Store Drop-off in particular, the demand for the material, its current recycling rates, and the challenges inherent in Store Drop-off collection (consumer convenience, reliance on retailer participation), along with the enormous volumes of flexible packaging that are being produced, suggest that its long term potential for all or most flexible packaging is insufficient to meet recovery needs. Accordingly, How2Recycle recommends that brands, packaging producers and resin manufacturers critically analyze what wide-reaching collection, sortation, reprocessing and market mechanisms and investments are required to scale recyclability of flexible packaging for the far future. See the How2Recycle Guide to Future Recyclability for more insight.

Still, many packages that are Not Yet Recyclable today could be moved to Store Drop-Off recyclable material, and much of that is low hanging fruit from an implementation perspective.

PE film provides excellent moisture barrier, is transparent, and carries a lower carbon footprint than most rigid packaging. For this reason, it is potentially suitable for many packaging applications. Too many companies are still using nonrecyclable plastic films (made of materials like polypropylene (PP), polyethylene terephthalate (PET) or a combination of resins) to package products, when Store Drop-Off recyclable PE could be used instead. The most frequent example of this is products that require no moisture barrier but are packaged in PP film—the high clarity, crinkly bags. For example, you may see PP bags for certain apparel bought via e-commerce, or bags holding individually wrapped candy. Chances are, the package design could be changed to PE so that it can be recycled via Store Drop-Off.

For other product applications that may require a certain oxygen barrier or greater strength than traditional PE film, innovation is happening at a rapid pace in the packaging industry. For example, technology in PE film packaging has enabled products like granola that previously would not have been sufficiently protected by PE pouches to become Store Drop-Off recyclable. In order to ensure that these increasingly sophisticated and fast-proliferating innovations can be labeled as Store Drop-Off recyclable, especially as flexible packaging is the fast growing segment in packaging, How2Recycle needed to learn more—and so began this study.

This How2Recycle Store Drop-Off Film Study illuminates design considerations for flexible polyethylene packaging in the present and into the future for How2Recycle member companies seeking to make more recyclable packaging.

What is the How2Recycle Store Drop-Off Recyclability Film Study?

How2Recycle launched an in-depth Store Drop-Off film study in 2018 in order to:

1. Better understand the Store Drop-Off stream.
2. Better understand how certain PE film innovations may impact the Store Drop-Off stream.
3. Identify the most appropriate test standard for Store Drop-Off recyclability.
4. Be in an informed position to provide R&D; guidance to members for PE film.

Multiple phases of this study included on-site PE film recycler visits and extensive testing of current Store Drop-Off material and specific PE film innovations together with How2Recycle’s third party lab partner for this project, Plastics Forming Enterprises. Over 4100 pieces of quantitative data were generated and closely analyzed.

Design of the study

The study design focused on two key areas: first, understanding the Store Drop-Off stream, and second, understanding the potential Store Drop-Off recyclability of certain PE film innovations. For the first part of the study, to understand the current recycling stream, How2Recycle sought to answer these questions: What material is in the stream, exactly? How does that material behave as a whole? How do specific materials in the stream behave?

And for the latter question, How2Recycle asked, how do different PE film innovations behave from a material perspective? How do those materials compare to the Store Drop-Off stream? How do those materials compare to one another?

As a result of these two focus areas, How2Recycle’s goal was to identify the best way to assess PE film innovations against the stream in order to set a standard for Store Drop-Off recyclability.

Phases of the study

The need for a clearer standard and test protocol for assessing Store Drop-Off recyclability was first identified in 2017. The study began in early 2018 and ran through 2020. The current Store Drop-Off stream and specific PE film innovations were studied concurrently, and complemented by on-site visits with three PE film recyclers. Throughout this process, the scope of work was expanded to accommodate additional innovations of interest, as well as acquire greater levels of detail in lab testing than what was initially envisioned. The data gathered was continuously analyzed so that the trajectory of the study could be adjusted to new learnings.

Plastics Forming Enterprises (PFE) is an independent third party lab with significant testing expertise in plastics recyclability globally. How2Recycle worked with PFE as a partner on this project, relying on their technical knowledge and skills to not only shape the study design, but also analyze the data coming out of it with their decades of experience and science-based approach. Additionally, PFE joined How2Recycle at the reclaimer facilities for the opportunity to learn and add project value. PFE is a candidate test lab for Association of Plastic Recyclers (APR) that has worked with APR to develop several of its testing protocols for plastic packaging.

Real-life bales of Store Drop-Off material were broken up and analyzed in three locations from different retailers across the country; the types of packaging formats and contamination in the bales were assessed. In two cases, that sorted material was recombined (reflecting real world Store Drop-Off material as a whole) and turned into recycled pellet. In a third case, that material was kept separated into three different categories based on format, and the material from each format was then turned into recycled pellet. In total, over 2000 lbs of material were sorted by hand in these bale sorts.

Similarly, an array of specific PE film innovations along with resin controls were sent to PFE for analysis. The innovations to study were selected by How2Recycle, but specific formulations of those innovations (ones earmarked for potential commercialization) were selected by a handful of specific How2Recycle members with an interest in learning more about PE film recyclability. Members provided the material and covered some of the costs of testing—How2Recycle funded the rest. These materials were pelletized and analyzed.

In accordance with the forthcoming APR Critical Guidance PE film test protocol, the material properties of all the pellets were assessed through many parameters, including: extrusion pressure (psi), delta pressure, delta from first to last 5 minute pressure, melt flow rate (190 degrees C, g/10 min, 2.16 kg), density (g/cc), primary peak melt temperature, secondary peak melt temperature, peak 1 enthalpy, peak 2 enthalpy, delta enthalpy, average ash %, % volatiles (160 degrees C), color (l*, a* and b* values), bulk density (kg/m3), pellet surface appearance, impurity content, and extrusion process irregularity.

The recycled pellets were then turned into molded parts. The mechanical properties of the parts were assessed through parameters according to the APR PE film benchmark test protocol (as the APR Critical Guidance test for PE film was not completed at the time of study), including: flexural modulus (psi), delta flexural modulus, tensile strength at yield (psi), delta tensile strength, elongation at yield (%), delta elongation, notched izod impact (ft-lb/in), delta notch izod impact, and melt flow rate (190 degrees C, g/10 min, 2.16 kg).

The pellets were also then blown into films. The processing properties of the film were assessed through parameters according to the forthcoming APR Critical Guidance PE film test protocol at 50% concentration, including: tensile strength (psi), delta tensile strength, elongation at yield, delta elongation at yield, tear strength (gf), delta tear strength, tear strength with thickness calculation, delta tear strength to 1 mil, impact failure weight (Wf), delta impact failure weight, impact failure weight to 1 mil, delta impact failure weight to 1 mil, process stability (y/n), film thickness, and a film appearance rating that assessed texture, gels, carbon particles/specks/unmelts, fisheyes, holes, and breaks.

The material was turned into pellet, parts and film because those reflect different ‘end applications’ for the material. How a material performs in different applications influences who will buy the material, and for what reasons. Additionally, different end applications highlight different qualities of a material, painting a full picture of its character.

In total, 9 samples of real-world Store Drop-Off bales were assessed, as well as 10 films representing 5 innovation types across multiple concentrations. The data points from all these lab tests were closely analyzed so that innovations and Store Drop-Off bales could be compared to each other. This analysis was supplemented by qualitative data gathered at the three on-site PE film recycler visits about buy/sell behavior, contamination, recycling processes and end markets insights.

While the study is formally complete, it is not over: learning will continue indefinitely into the future as the How2Recycle program, PE film recyclers and the packaging industry learn and adapt to evolving needs, markets and information.

Concurrently with this study, the Association of Plastic Recyclers developed its Critical Guidance test protocol for PE film recyclability. The work was informed by APR member company research in similar areas and used a consensus process to validate important features of the test protocol. APR was involved in several aspects of How2Recycle’s film study, including the film sorting and review of preliminary results. Input from the How2Recycle team was considered where appropriate in development of the test protocol.

How2Recycle is pleased that this work culminated in the announcement of the program’s adoption of APR’s Critical Guidance protocol for PE films (see detail in later section).

Key findings on the Store Drop-Off stream
The Store Drop-Off stream is very diverse. There are many different packaging formats in it. The main materials seen in Store Drop-Off bales (often referred to as “mixed retail” bales) are:

• “Back of house” (predominantly LDPE stretch wrap from pallets in retail or distribution center operations), and
• “Front of house” (material from the consumer collection point at the retailer. This is where PE film labeled Store Drop-Off ends up; grouped with predominantly HDPE carryout bags, which usually constitute at least half of the front of house material).

PE film packaging from the “front of house” can take many forms, such as shrink film, case wrap, air pillows, ecommerce mailers, and pouches that may be HDPE, LDPE, LLDPE, ULDPE, or MDPE—either in monolayer or multilayer. This leads to a big variety of PE densities in the stream. Additionally, retailer and/or retailers’ employees’ behavior can contribute to variability in the material bale to bale within a location or across different retail locations.

How2Recycle’s lab analysis confirms the big variety in PE densities: some of the highest and lowest values on the exact same testing parameter came from categories within current Store Drop Off material. For example, on melt flow rate in part testing, the lowest value of all materials studied was the carryout bags from the real Store Drop-Off bale, and the highest value of all materials studied was the stretch from the real Store Drop-Off bale.

PE film recyclers each manage this diversity in their own way: they may adjust their purchase behavior, and/or have different quality control processes in place, and/or may leverage certain equipment to achieve the desired density mix. How PE film recyclers manage the incoming material depends on the needs of their end application/s, such as density, cost, and various other material or processing attributes.

Most of the contamination in the Store Drop-Off stream is from items that don’t belong there, such as PET bottles and trash placed in the front-of-house retail collection bins. This is likely due to bin location (whether other recycling and trash bins nearby), or clarity/size of signage. In all three bale audits, there were no How2Recycle Not Yet Recyclable labels on flexible plastics in the Store Drop-Off bins. This suggests that on-pack labeling is likely effective in encouraging correct Store Drop-Off recycling behavior and in discouraging contamination.

In the back-of-house, the most contamination comes from non-film items such as hangers, pallet strapping and rigid plastics from deli operations. This is likely due to insufficient or inconsistent training of employees at the retail location, as well as possibly PE film recyclers not enforcing or struggling to enforce their own bale specifications.

While the samples studied are not exemplary of all or every Store Drop-Off bale, some common characteristics in the Store Drop-Off materials were observed. All samples showed a large percentage increase in extrusion pressure when creating pellet from the material. Carryout bags, in addition to having the “highest” performance of physical properties (this is based on recycler feedback that strength is desirable), it also carried the highest ash content. This is due to widespread presence of mineral fillers in shopping bags. In regard to melt temperature, there were observed secondary peaks for all materials. This suggests that material other than PE is in the Store Drop-Off bales because those materials have a higher melt temperature than PE. No stable runs (“process stability”) for film production at a thin gauge (30 minutes) were achieved for any of the variables in a lab setting, although film can successfully be made with this material at a thicker gauge. The existing Store Drop-Off stream contains various visual impurities.

Top: carryout plastic bags from Store Drop-Off in the form of ground flake; below: stretch wrap from retail back-of-house in the form of ground flake

Top: carryout plastic bags from Store Drop-Off in the form of pellet; below: stretch wrap from retail back-of-house in the form of pellet

Top: carryout plastic bags from Store Drop-Off in the form of molded part; below: stretch wrap from retail back-of-house in the form of molded part

Top: carryout plastic bags from Store Drop-Off in the form of film; below: stretch wrap from retail back-of-house in the form of film

Key findings on PE film innovations

Several PE film innovations were supplied, prepared, produced and studied at PFE: EVOH at different concentrations with and without compatibilizer, vacuum-deposited metallized PE, PE/PP resin blend, spunbonded PE (Tyvek), nylon, and nylon/EVOH blend. Each innovation film was blended with its control at 10%, 25%, and 50% concentrations to make into pellet and molded part, and blended with the same control at 50% and made into film.

While the ideal result of this study would have been to develop the ability to plot a variety of innovations on a spectrum of recyclability or provide confident guidance on maximum allowable percentages of innovations in PE films, How2Recycle is unable to draw sweeping conclusions about a broad innovation category (like EVOH) at this time. There are several reasons why.

Some innovations are better performing in recycling than others, but no innovation category studied as a whole is “definitely OK” for Store Drop-Off. Conversely, no innovation category studied as a whole is “definitely NOT OK” for Store Drop-Off.

Some innovations decrease the material properties as compared to their controls, but at varying degrees. Some innovations increase the material properties as compared to their controls, but at varying degrees. None of the innovations decrease properties on all parameters. None of the innovations increase properties on all parameters.

Some films studied showed better material properties as compared to the Store Drop-Off stream. Some films studied showed decreased material properties as compared to the Store Drop-Off stream.

When you increase the concentration of an innovation, it doesn’t necessarily mean that the impact from that innovation will be proportionate to the increase. In some cases the impact may not increase at all.

There can be notable variability of recyclability within an innovation category—for example some EVOH films performed better than others, when it was not immediately clear why. How2Recycle could not isolate the recyclability performance to the innovation for all parameters in all instances.

Importantly, How2Recycle learned that innovations cannot be analyzed in a vacuum: the film structure as a whole (including components like tie resins) impacts test results. It was not anticipated that tie resins would make a noticeable difference in the recyclability of the films, but they do appear to play a role.

When two innovations are utilized in a single film, the results can dramatically change (for worse, or possibly better in other scenarios). In other words, mixing innovations together creates a whole different beast. This is an opportunity for further study and innovation.

That said, in some instances observed changes may be attributable to the base resin selected for the film, not necessarily the innovation (see later section on test method).

It’s unclear to what extent the controls selected truly affected the end results, especially since the innovations were tested against different controls.

Because of these ambiguities, How2Recycle is recommending testing for innovations in PE film (see later section).

Looking at each innovation, mixed results were observed. Note that as only one or a handful of film structures representing each innovation were tested, these results do not speak to the overall recyclability of these innovations as a whole, but rather, the individual film structures studied. Accordingly, readers should not conclude that since a film studied possessed certain characteristics in testing that other films with that same innovation would perform the same, because this data set is limited.

For the PE films containing EVOH, secondary peaks were observed with a range of 165 to 182 °C. It was visually noticeable that the film production benefited from the presence of a compatibilizer. Still, none of the PE films with EVOH studied met all the test requirements at the film stage—but the melt temperature of the control, the type and quantity of tie resins, and the quantity and mol% of the EVOH appear to contribute to these results. Compared to the current Store Drop-Off stream, most but not all of these films showed decreased tear strength for the thickness correlation values and impact failure weight, with some slight negative film appearance effects, but these results varied for each EVOH innovation film.

For the metallized PE film, the pressure delta (in pellet testing) and tensile strength (in film testing) did not meet specification per the APR Critical Guidance PE film test protocol. When made into film, this innovation did not experience process instability. Compared to the current Store Drop-Off stream, this film showed decreased tear strength and impact failure weight, with some moderately negative film appearance effects.

For the PE/PP film (resin blend, not multilayer), a secondary peak was observed in melt temperature, indicating the PP melt temperature (compared to the primary peak of the PE melt temperature). Consistent film production stability was not achieved throughout the run time, and did present holes. When the bubble was able to be held, decreased tensile strength and elongation at yield were observed. Based on insights from APR’s study of similar structures, the concentration of PP in the PE film likely impacts film properties. Compared to the current Store Drop-Off stream, this film showed decreased tear strength and some moderately negative film appearance effects.

For the PE film containing a portion of spunbonded film (Tyvek), the pellet met all APR requirements. The film met all the requirements except for dart drop and elongation at yield. Compared to the current Store Drop-Off stream, this film showed decreased tear strength and impact failure weight, with some slight negative film appearance effects.

For the nylon films, the pellet met all APR requirements except for an extremely high and concerning secondary peak (compared to all other innovations studied and the Store Drop Off stream itself) in the range of 212 and 232 °C. These films had significant issues in blowing the film properly, leading to How2Recycle being unable to assess its characteristics.

The innovations studied did not meet the APR Critical Guidance test specifications.

Interestingly, all innovations increased tensile strength and elongation at yield in film production compared to the Store Drop-Off stream. All innovations decreased tear strength and impact failure weight compared to the Store Drop-Off stream.

As indicated, various concentrations of each innovation were studied, and this did provide different insights. The concentration of the innovation does change the results most of the time—but not always. That said, when you compare 25% innovation values to 50% innovation values, the value does not necessarily double. Sometimes the difference in performance between 25% and 50% is only extremely slight. Some innovations fail on a parameter across all concentrations. Other innovations only fail at 25% and 50% or at 50% concentration.

The nylon films did perform visibly ‘worse’ than the other innovations, but the rest were ‘near meeting specification’—with one EVOH film clearly ‘in the lead.’ They all nearly were in specification, in different ways.

The films studied are not vastly different from one another in the big picture. However, they do present marked differences when studied closely in comparison. While no one innovation in isolation would be catastrophic, these innovations are cumulative and need to be evaluated with that in mind. How2Recycle feels enough concern from these noted ambiguities that there is insufficient confidence to justify widespread R&D; guidance. Nothing How2Recycle studied is clearly “definitely OK”, and nothing is clearly “definitely not OK.”

If companies optimize the use of innovations relative to performance and recyclability in the R&D; process, all films studied stand a chance at Store Drop-Off recyclability.

What did How2Recycle learn about the test protocol design?

The selection of a control can certainly influence test results, because many parameters depend on the change between the control and the innovation (delta variation) not being too great. For example, if an innovation is known to increase tensile strength but a control is chosen that has relatively weak tensile strength, then the innovation will “look bad” because of a bigger delta between it and the control. In other cases, a ‘higher performance’ control resin can obscure the characteristics of the innovation, making it difficult to draw conclusions.

That said, not all negative or positive results are attributable to the selection of the control. How2Recycle was able to review the control chosen to understand some of the results observed (via density). Results were also compared to the data gathered on the existing stream to draw additional observations.

How2Recycle cannot compare every aspect of an innovation to the Store Drop Off stream cleanly, however. This is because many test parameters require the use of a control. The Store Drop Off stream does not have one single control. Recyclers also have their own novel purchase behaviors and quality control processes in place to segment feedstock by density depending on end application or other factors, and often mix Store Drop-Off material with “back of house” post commercial stretch, so judging innovations against the averaged qualities of the existing Store Drop-Off stream may not be appropriate in all instances.

Different recyclers may have different opinions on the relative importance of different parameters and how much change in a certain parameter (delta) from the control is desirable. Still, a delta is a good sense of how much an innovation changes the PE resin; therefore, How2Recycle feels this is the best available approach today.

Key takeaways
The quality and quantity of data gathered about certain PE film innovations is insufficient to create cutoffs or prescriptive R&D; guidance on specific film attributes. For certain PE film innovations, testing will be required.
Due to the insights uncovered by this study, as well as anecdotal or other evidence gathered in this process, How2Recycle has identified that greater understanding of these packaging attributes and their potential impacts to PE film recycling is desired:

• Cross-linked
• BOPE
• Tie layers
• Adhesives
• Sealants
• Ink systems

More data about these attributes will clarify the true cruxes of PE film recyclability and enable the development of more industry R&D; guidance. Companies are strongly encouraged to share test results of PE film structures with any of these attributes with APR to facilitate the expansion of the APR Design® Guide for PE film, as well as with How2Recycle to enable better guidance for future Store Drop-Off recyclability.

Moving forward: How2Recycle will adopt the APR Critical Guidance PE film test protocol

How2Recycle is pleased to announce that learnings from this work now enable the program to adopt a transparent, data-driven test protocol for Store Drop-Off recyclability: the Association of Plastic Recyclers’ (APR’s) soon-to-be-released Critical Guidance Protocol for Polyethylene Films.
In order to be eligible for a Store Drop-off label, testing will be required for PE film packaging with certain attributes (detail in later section).

Over time, the How2Recycle program will grow in its confidence (from increased amounts of data) over what constitutes an ‘innovation’ for purposes of requiring testing. The goal is to increase understanding over what variables are the true influencers of recyclability so that over time, less testing is required.

Why did How2Recycle select this test protocol in particular?

How2Recycle acknowledges that the APR Critical Guidance test is a high standard to assess Store Drop-Off recyclability. Still, the program has concluded it is the most appropriate test standard for a variety of reasons.

Most innovations “show their true colors” at the film stage. In other words, materials often (but not always) look similar to each other in the pellet or part stage but look fairly different at the film stage (when How2Recycle dramatically increased its understanding of how these materials behave). This was very apparent during the many months of testing at PFE, for both How2Recycle and APR. It is also more challenging to make film from a processing perspective than it is to make molded parts. This helps tease out the true potential issues of a material.

This is a young stream that the packaging industry needs to better understand. The APR Critical Guidance test gathers a lot of information that increases collective understanding. It looks at around 45 parameters across a control and various concentrations of the innovation. This allows packaging companies and recyclers to understand a thorough picture of an innovation with this many data points.

The test was developed in a transparent and collaborative way and the protocol is publicly available. Additionally, the test design is modeled after other extremely well-established plastic recyclability tests such as the APR Critical Guidance test for Clear PET Bottles, HDPE Containers and Bottles, and PP Containers.

Increased amounts of information that industry will be able to gather about how films perform under this protocol will help develop the APR Design® Guide for PE films over time with scientifically credible data, which will benefit the packaging industry as a whole.

The APR Critical Guidance test was developed and validated by a committee with PE film recyclers and material scientists at North America’s largest and most sophisticated trade association for plastic recyclers.

How2Recycle’s film study and APR’s validation work have demonstrated that the test design fundamentally makes sense, and it has been adjusted over time to take new learnings into consideration. For example, an increase in certain properties beyond 25% delta is no longer considered a fail of that parameter based on APR studies.

Store Drop-Off material currently goes into a variety of end applications, so a test protocol must contemplate those applications. Composite lumber and plastic bags are the current predominant end applications. Publicly available figures differ about the relative volumes of material going to those different applications so How2Recycle must consider both in determining a test standard. These applications require different material qualities. In many but not all parameters, a bag application is more demanding than a composite lumber application. For this reason, if How2Recycle ‘set the standard’ at the ‘lower’ quality level, then the material may struggle to meet the needs of the ‘higher’ quality level required by film applications. How2Recycle has no evidence suggesting a material could meet the APR Critical Guidance test specifications but fail simpler melt temperature and melt flow rate requirements for a composite lumber application.

Due to the increase of corporate carbon reduction and recyclability goals, more consumer packaged goods are moving into PE flexible packaging. Given that the Store Drop-Off stream is the only recycling option for PE flexible packaging at scale in the United States, this means that more product categories will move to PE film, which requires new packaging innovations. It is important that these innovations do not negatively impact the quality of the Store Drop-Off stream as the stream grows. Because the volume of Store Drop-Off material will increase over time, and the performance characteristics of the packaging will also increase to meet the needs of new product categories, it does not make sense to use a ‘lowest common denominator’ standard for the recyclability of PE film.

There is a need for stronger end markets for this material, as well as more diverse users of this material, and this test will support that goal. Shifting export conditions and other factors make this stream more fragile than other more mature recycling streams, so a cautious approach is warranted. Recycling streams are healthier when more recyclers are competing for the material and developing innovations for different end applications. If the material in the Store Drop-Off stream is sufficient quality to enable that material going back into film applications, this will help build end markets for Store Drop-Off. How2Recycle does not want to give a potential future PE film recycler or a buyer of recycled PE resin a reason to disqualify Store Drop-Off material because it is not of sufficient quality. How2Recycle encourages more recyclers to enter the space to maintain the viability of the stream long term.

What does this mean for How2Recycle members?
In order to be eligible for a Store Drop-off label, testing will be required for PE film packaging with these attributes:

• Forms of PE/Conversion methods
  • Spunbonded
• Functional layers
  • Metallized
  • Nylon
  • Nylon with compatibilizer
  • EVOH
  • EVOH with compatibilizer*
  • PP
  • AlOx
  • SiOx
  • A combination of more than one functional layer
• Attachments
  • Rigid PP attachments (zippers, etc)

*Some structures containing Dow’s Retain technology are prequalified for Store Drop-Off.

At this time, testing must occur at a third-party APR candidate lab. How2Recycle will begin accepting test passes as soon as the protocol is released on APR’s website under “Test Methods” in the APR Design® Guide. And as included in the table above, metallized PE films will be required to undergo an additional test: Evaluation of Sorting Potential for Plastic Articles Utilizing Metal, Metalized, or Metallic Printed Components.

Important: as a result of learnings from this study, additional PE film structures may require testing in the future. Greater understanding of these packaging attributes and their potential impacts to PE film recycling are desired:

• Cross-linked
• BOPE
• Tie layers
• Adhesives
• Sealants
• Ink systems

PE films containing the following are acceptable for Store Drop-Off:

• Various PE densities including:
  • ULDPE
  • LLDPE
  • LDPE
  • MDPE
  • HDPE
• Workhorse additives per the APR Design® Guide including:

• • UV stabilizers
  • Nucleating agents
  • Antistatic agents
  • Lubricants
  • Pigments
  • Impact modifiers
  • Chemical blowing agents
• Mineral fillers (CaCO3, TiO2), assuming the filler does not cause the PE film to sink in water because of altered density.

PE films containing the following are Not Yet Recyclable:

• Biodegradability additives
• RFID tags
• Black PE (pigmented)
• PVC and PVDC
• Foil
• Certain applications:
  • Food, beverage, personal care, or home care products that are wet, moist, sticky, gooey, oily
  • Any products that are hazardous or potentially hazardous, or dirt or dirt-like
  • Or any other similar product where it would be difficult or unreasonable for the consumer to prepare as “Clean & Dry” before recycling via Store Drop-Off (e.g. would require scissors to cut off fitment to rinse the inside).

How2Recycle provides recyclability assessments for every package featuring a label, so members do not have to conduct this analysis themselves. The way it works is members send the program detailed packaging specifications, and a custom How2Recycle label is issued. If testing is required in order to receive a Store Drop-Off label, the member will be notified by How2Recycle. If you would like to learn more about the recyclability of your packaging and transparently label it for end-of-life, consider How2Recycle membership. Contact how2recycle@greenblue.org for more detail.

How2Recycle would like to sincerely thank the following organizations for their support in this study: the Association of Plastic Recyclers, Plastics Forming Enterprises, Nova Chemicals, Procter & Gamble, Dow, General Mills, The Recycling Partnership, PAC Worldwide, Avangard Innovative, Novolex, Plastics Industry Association, Trex, Sealed Air, Amcor, and Printpack.

Questions, feedback? Please reach out to how2recycle@greenblue.org.

If you like this resource, you may like:

Design for Recycled Content Guide
Recyclability Insights
The How2Recycle Guide to Future Recyclability

This report, the information contained herein, and the images are authored and owned by GreenBlue, the parent nonprofit of How2Recycle. Any copies, derivatives, references or uses of this work must be attributed to How2Recycle with a URL link to this page.

You know on plastic packaging, sometimes you’ll see a number on the bottom? And how most people think it means that the package is recyclable? Or they may think that in order to be able to recycle something in their town, it must have the number on it? Well, not so fast. It’s a little more complicated than that. We’re here to help explain.

These numbers were developed in the 1980s by people behind-the-scenes of recycling for people behind-the-scenes of recycling. They stand for six specific types of plastic, and the seventh number stands for all other types of plastic. These numbers helped manufacturers develop consistency in the materials they use for their packaging, and it gave specific information to recycling facilities or reprocessors to help them confirm which specific type of plastic they suspected a certain packaging was made out of. In turn, that helped them weed out the ‘garbage.

The numbers were not created to tell the general public whether something is recyclable.

These numbers are actually called RICs (In the recycling and plastics industry, pronounced “Ricks” for short) — which stands for Resin Identification Codes. These numbers only apply to plastics, so you’ll never see them on paper, glass or anything else.

If a package is made of one of those types of plastics, then it might have the number stamped onto it, but not always. We could go through each number for you, and tell you what type of plastic it stands for and what type of packaging is usually made with each type of plastic, but we don’t think you’ll find that very helpful. Here’s why.

In some places, communities specify what “number” plastics that residents can recycle.  But not all communities do this. In fact, the culture and language of recycling can be very different town to town.

Here are some examples of how American cities and towns talk about plastic differently, and how the numbers are sometimes intertwined with that, and sometimes not.

Here is an example of an American city that does not talk about the recycling numbers at all, on their website explaining what recyclables they accept. This is Portland, Oregon.

The City of Chicago uses mostly pictures to tell residents what they recycle, but only specifically mentions number 6 (as something they don’t want).

Here is an example of a city that tells people what shapes of plastic packaging they can recycle, but also provides numbers. This is Hampton, Virginia.

These numbers have been confusing people so much that there was a recent rule put out by ASTM International (the organization that maintains the numbers system)–to switch the chasing arrows around the numbers to a solid triangle.

In 2013, the rules were revised so the number should be inside a triangle instead of moving arrows, to try to not confuse the type of plastic with its recyclability.

Even on top of all this, the plastic industry’s guidelines for using RICs state that manufacturers must put them in an unnoticeable place on a package and not use them for saying something is recyclable! This is why they’re often small and hard to find. Additionally, they’re required on certain plastic packaging in 39 states in the United States, but not all.

There’s actually a movement away from communities using these numbers when talking to their residents about recycling.

So how do you know what to recycle?

Here’s where How2Recycle comes in. It’s a label designed for all Americans. Here’s a few reasons why it was important to develop a national system:

• It would be logistically impossible for a company with a national distribution of products to make a special recycling label for each and every American town, based on how that town talks to their residents about plastic recycling. Our label is designed to work in all states. So we’re practical.
• We work with companies to evaluate how their packaging should be recycled, and we find the most up-to-date, accurate recycling data to base our decisions on. We consult with experts and take care to correctly evaluate the recyclability of every package. So that means that almost every time, all the information you’ll need is on the How2Recycle label. You don’t need to go hunting for those numbers anymore!

Here are the How2Recycle labels:

Our label system breaks things down into easier categories for you. We base our labels on what the recycling industry needs and accepts, so we do all the hard work for you.

We also emphasize best practices for recycling with our label, such as instructing to Empty & Replace Cap on plastic bottles. Not all communities may currently follow this instruction, but recyclers and communities nationwide generally recognize it as the best thing to do with caps. What that means is that some cities and towns haven’t changed what they’ve done with recycling for many years, even if the industry has shifted in a certain direction. They also may have a good specific reason, local to their area, for why they tell residents to do or not do something, when it comes to recycling. So just know that your local recycling program may or may not be relying on assumptions, from a certain time or from a certain perspective.

How2Recycle is not against the recycling numbers, and we’re not trying to replace them, either. Instead, How2Recycle is going beyond them. We’re trying to make it so you don’t have to memorize which numbers are recyclable in your town or worry about finding that number, which is small and often tucked away on packaging (on purpose!). Even more, many towns are moving away from communicating recyclability to residents in terms of these numbers (because of all the confusion we’ve explained), so our label system is also designed to endure the passage of time.

How2Recycle is making recycling easier. We’re taking recycling labels to the next level. We’re the only national recycling labeling system. Join us!

The purpose of this Future Guide is to transparently provide How2Recycle member companies with guidance about how to build a future case for their packaging to be considered recyclable, and also may give members of the general public insight into the complexity of packaging recyclability and the recycling system today.

What is this Future Guide and what is it for?

The purpose of this How2Recycle Guide to Future Recyclability (‘Future Guide’) is to transparently provide How2Recycle member companies with guidance about how to build a future case for their packaging to be considered recyclable, especially as it relates to receiving certain How2Recycle labels. Additionally, labeling changes may be challenging for members, so this Future Guide will help companies understand why materials are experiencing change in the recycling system. It also may give members of the general public insight into the complexity of packaging recyclability and the recycling system today.

This Future Guide will describe how we conceptualize the future of recyclability-challenged packaging, what to keep in mind and expect if you are a How2Recycle member that wants your challenged packaging to be recyclable, and what specific data or changes may be required for your challenged packaging to be considered recyclable under the How2Recycle program.

 

‘Core’ versus ‘recyclability-challenged’ packaging explained

Infrastructure-challenged packages are those where the recycling system was not specifically designed to capture them (yet) and are known to face substantial challenges in collection, sortation, reprocessing, and/or end markets. Some infrastructure-challenged packages may not feasibly become recyclable in the foreseeable future, for reasons like viability: they are too expensive to reprocess. Other infrastructure-challenged items could become more recyclable, relatively easily, if the appropriate investments are made in infrastructure.

Data-challenged items may be those where the system wasn’t specifically designed with them in mind, but they may still get recycled if a consumer places the item in their bin—but no company or organization has yet demonstrated with data that a recyclability claim can be made. Accordingly, How2Recycle cannot give a member the label that may be desired.

Some packages may be challenged in both infrastructure and data to substantiate a recyclability claim. But what all recyclability-challenged packages have in common is they sit on the other side of the spectrum of packaging recyclability from core packages—“on the fringe” of the recycling system.

Note that some recyclability-challenged packages may have strong sustainability attributes in other respects, like sustainable sourcing, design optimization, or material health. Remember that end-of-life considerations are only one aspect of sustainable packaging.

Here is another way of looking at the differences between core and challenged packaging:

Not all recyclability-challenged packaging is equal.
Most challenged packages are currently designated Not Yet Recyclable in the How2Recycle program, but some packaging might be somewhat recyclable today (“Check Locally”) with the goal of achieving a Widely Recyclable designation. This is all to say: not all challenged packaging is created equal.

Here are a few guiding principles to put challenged packaging in context:

• Different journeys. Because of the complexity of the recycling system, some challenged packages may have different solutions to becoming recyclable compared to other challenged packages.
• Different timetables. Some packaging may have the same or a similar route as another challenged package but has a longer way to go than the other one to be considered recyclable.

Types of challenged packaging
Based on these considerations, packages may be roughly placed in one of these categories of challenged packaging:

• Data-challenged. 
  • Likely recyclable today but more data needed. Current recycling systems likely support the recycling of this item at scale, but more substantiation data is required to support a recyclability claim. More data may be needed in one, some, or all of the following elements to support a more positive recyclability claim:
    • Collection
    • Sortation
    • Reprocessing
    • End markets
  • Not recyclable because no to very little data exists. It may be unclear which above category a package might fit into because little to no data exists to help plot its current and potential future position in the recycling system.
  • Unsure whether recyclable today; more information needed. Current recycling systems may or may not support the recycling of this item at scale. If so, more substantiation data is required to support a recyclability claim. More data is needed in one, some, or all of the following elements to support a more positive recyclability claim:
    • Collection
    • Sortation
    • Reprocessing
    • End markets
      • Note that if the data is gathered but cannot ultimately support a recyclability claim, the package would fall into the infrastructure-challenged category outlined below.

• Infrastructure-challenged. 
  • (More) recyclable, likely recyclable or possibly recyclable in future if infrastructure investment occurs. Because of a developed body of data, we know confidently or somewhat confidently that the current recycling system cannot support the recycling of this item today, but investments in the recycling system will or could possibly change that (likelihood of future success varies). Additionally, changes in packaging design may also be necessary under the circumstances (see next bullet point). Investments may be required in:
    • Collection. For example by increasing the amount of communities that accept that item, or increasing the clarity of community instructions to demonstrate the item is accepted.
    • Sortation. For example by installing more commercialized sortation equipment, updating existing sortation equipment (either via software updates or retrofits) to enable better sortation, adjusting MRF processes like pick line worker training, or inventing novel ways to sort materials at MRFs at scale.
    • Reprocessing. For example by installing more commercialized reprocessing technologies at recyclers, or inventing novel ways to reprocess materials at scale.
      • Note that chemical recycling (a reprocessing technology) reaching scale could be a game changer for certain challenged plastic packages.
    • End markets. For example by creating a new bale specification to encourage more MRFs to bale these items, or going city-by-city to connect sellers with new buyers of the material, or inventing new applications for the material that would support demand at scale.
  • (More) recyclable, likely recyclable or possibly recyclable in future if packaging design changes. The best way for packaging to become more recyclable is simply for its design to change to fit the existing recycling system. Because of a developed body of data, we know confidently that the current recycling system cannot support or is not optimized to support the recycling of this package today, but changes in packaging design will or could possibly change that (likelihood of future potential success varies). Additionally, investments in infrastructure (see prior bullet point) may also be warranted under the circumstances. Packaging designs may be required to better enable:
    • Sortation. For example, by changing the label on a plastic container to enable it to be better sorted by near infrared (NIR) sorting equipment.
    • Reprocessing. For example, by switching to pressure sensitive labels where the label substrate, adhesive and ink meet criteria for Preferred in the APR Design Guide.
    • End markets. For example, by adjusting resin color to one with stronger market demand.
    • Note that on the How2Recycle Member Platform, members already receive specific recommendations for packaging design improvement to make their packaging more recyclable.
  • Not likely recyclable in the foreseeable future. We know confidently that the current recycling system cannot support the recycling of this item today, and potential for investments or changes in the recycling system are unknown or unlikely. Or, the package is fundamentally not designed for recyclability (for example, poor yield ratio), or is an active disruptor in the current recycling system, or exists in such a small concentration and is novel enough that it doesn’t fit into other existing package types that gathering momentum around its recyclability is unlikely. See later section about ‘far future recyclability’ for more insight.

Note that ‘core’ versus ‘challenged’ is a binary (and thus limited), informal concept to help tease out issues as to how and why not all materials flow through the recycling system similarly. There are some items that are debatable as to whether they would more likely be classified as core or challenged. There is a spectrum of the recyclability of packaging, and clear categorizations may not exist for all materials. Some may fall between core and challenged. Those may be items with:

• Shifting recyclability – on the rise. Either the markets or the infrastructure (or both) for these items are stronger than they were in the recent past, and may currently feature Widely Recyclable or Check Locally. These items may or may not be data-challenged.
• Shifting recyclability – on the decline. Either the markets or the infrastructure (or both) for these items may not be as strong as they once were. These items may or may not be data-challenged.
• Static recyclability. The infrastructure for these items, or their markets, may be static and holding at a moderate level. Any recyclability changes over time (within the last few years) may be negligible. The recyclability of these items is more stable than challenged items but not as stable as core items.  These items may or may not be data-challenged.

The informal concept of ‘core’ and ‘challenged’ does not directly correlate to the 4 recyclability categories for How2Recycle. That’s because the How2Recycle label on-package only conveys a specific piece of information: whether, from a legal perspective, one can currently claim it’s recyclable to the consumer. How a package has historically fared, is faring and will fare in the recycling system, and how the package design could be improved for recyclers (recyclability claims aside)—these are more nuanced considerations.

Not all packages with the Widely Recyclable label enjoy the same stability and viability as other packages with the Widely Recyclable label. One might categorize some Check Locally packages as challenged, but other Check Locally packages may be in the shifting or static categories. And Store Drop-Off is an interesting case because some might consider PE film core and some might not, but within PE films, there are challenged designs. This is how we tend to think about the overlap of these concepts:

Widely Recyclable items could be core or shifting; Check Locally items could be shifting, static, or challenged; and Not Yet Recyclable items are always challenged.

To provide further subclassification about how some packages may be better positioned within their broader recyclability category, consider this concept of recyclability “+” or “++”:

For all How2Recycle member packaging, the graphic shows that 17.8% are designated optimally recyclable, 26.5% are recyclable but need improvement, and 56.6% are partially or not yet recyclable. The ‘green’ categories may be either packages where all main components are Widely Recyclable or Store Drop-Off, and the yellow category is where at least one main packaging component is Check Locally or Not Yet Recyclable.

These infographics demonstrate that there are many different ways How2Recycle seeks to empower its members to assess the success of packaging in recycling.

 

Assessment criteria to achieve future recyclability

The below table reflects important assessment criteria under each element of recyclability but adds how it may specifically relate to future recyclability. But first, some important caveats to the below criteria:

• Not comprehensive. This guidance is not all encompassing. In other words, do not rely on the guidance here as complete for a package. Guidance may contain nuances depending on your packaging type and new data may illuminate the need for more details. Some packages have questions not listed here (too complex to include all and too many changes over time). This is intended as general guidance to cover most packages.
• Subject to change. Our guidance and standards are subject to change at any time, and a How2Recycle label may be rescinded at any time based on new data or standards. This is because the recycling system continuously evolves, and How2Recycle’s data about recyclability updates continuously. That said, broad changes to recyclability (for example, if all HDPE tubes were to qualify for the Check Locally label) will be communicated to all How2Recycle members simultaneously via updates to the Guidelines for Use on either January 31 or July 31 of each year via email newsletter, as well as posted to how2recycle.info for the general public (starting January 2020).
• Not one-size-fits-all. Not all criteria listed under each element apply to all packages. It depends on the specific package and all the circumstances at play. While we will issue How2Recycle members a custom label based on all the criteria under the circumstances for that package today (see the How2Recycle Guide to Recyclability), we are unable to give members a mathematical formula or affirmative promises on a specific checklist for you to legally be able to rely on for future recyclability. However, the below table is designed to present the important questions to empower you to understand and dig into these issues yourself, and why we are unable to give a formula.
• Embrace the grey. This Future Guide contains intentionally open-ended questions that seek to tease out ambiguous, unclear or complicated issues, so a yes or no answer, or a clear one, or a quantifiable one may not be possible (at least not right now). The recycling system is evolving, and our community’s knowledge and set of tools around recyclability become more sophisticated over time. All these considerations mean we are carving out new territory, where black and white does not exist. As we broaden participation in recycling and the How2Recycle community, establish new and improved feedback loops, and continue to foster complex adaptive systems thinking, the interconnected picture of recycling will become bigger, and clearer, and will likely shift. There may be journeys to recyclability that are not even contemplated in this Future Guide. Critical thinking and creativity go a long ways here. There are no perfect or single answers or solutions, and there is no silver bullet.

Note that this table is also in the How2Recycle Guide to Recyclability, but includes additional detail about the grey areas under each element of recyclability that may be especially relevant to building a future case for recyclability.

 

Element	Assessment criteria
Collection (Access to recycling)	For the standards for access to support a Widely Recyclable or Check Locally claim, see the How2Recycle Guide to Recyclability. Those standards still apply here. However, in this Future Guide, since we are focusing on less-recyclable packaging, or packaging where it’s unclear if it’s recyclable today, here are some additional layers of consideration for access analysis: _________For packages where the SPC Centralized Availability of Recycling Study may not give a precise answerSee this article. ________ For data that a member has collected Requests to override existing data compiled by SPC must be extremely compelling. If a member has commissioned its own study to supplement or update the SPC Centralized Availability of Recycling Study, some considerations may include: Is the data nationally representative? If so, how? Why was this sample size chosen? Is the methodology the same, or similar to the SPC Centralized Availability of Recycling Study, or better? If not similar, the member must present compelling reasons why this is sufficient or comparable in credibility, accuracy and completeness. Is this data timely—in particular, does it take into account changes in the recycling system due to current export conditions? Was the data collected by an objective, qualified third party to yield accurate, reliable results? See later sections in this Future Guide for more detail on substantiating data and what the data needs to look like. ______ For a more detailed discussion of what ‘explicit’ or ‘implicit’ access means, and what we find a compelling methodology to be, see the 2021 SPC Centralized Availability of Recycling Study.
Sortation	For the criteria for sortation to support a Widely Recyclable or Check Locally claim, see the How2Recycle Guide to Recyclability. Those criteria still apply here. However, in this Future Guide, since we are focusing on less-recyclable packaging, or packaging where it’s unclear if it’s recyclable today, here are some additional layers of consideration for assessing sortation: ______ For packages where it’s unclear if it will be sorted correctly in MRFs Is there evidence that the item will get correctly sorted at MRFs even though MRF operations were not designed specifically for the item? Was a MRF not designed to specifically sort it, but scientifically credible data indicates that the item will be sorted successfully by the relevant sorting technologies, including screens, 2D/3D, NIR, eddy current, magnets or robotics, in the form in which it would arrive at the MRF (somewhat compressed)? Note that not all sortation technologies are relevant for all packages. Is there a possibility that hand pickers at a MRF would pull this item out of the stream? Are they trained to? Is there a possibility that the presence or absence of certain equipment, or certain equipment settings may impact the success of sorting? How might you account for sortation of this item by AI and robotics? Will it be visually recognized? Is it an item of priority for robotics sorting at the majority of MRFs using robotics? In this sense, will it be positively sorted or would it be pulled out by robotics as a contaminant? This is not yet a criterion for How2Recycle, but will be. For emergent materials, AI and robotics may present either a challenge or an opportunity, depending on the package type. Its place in the bale If it’s not obvious, one must identify the intended bale destination—for example, colored HDPE bottles. Do you think it should go to the bale or you have proof it will go there at scale? Do model or industry bale specifications (such as ISRI’s or APR’s) explicitly allow or prohibit this item? Or are they silent, ambiguous or unclear? Will the presence of the package in a bale potentially cause that bale to be downgraded, per industry specs? Its relationship with other materials in the mix Would this item contaminate other items during transport (i.e. from food contamination)? Would this item contaminate other streams by being sorted to the wrong material bale? If so, does that substantially differ from the success rate of similar classic items of that same material or format? Relationship between consumer behavior and successful sorting Is certain consumer behavior required in order for the package to sort correctly, or to substantially increase the likelihood of it sorting correctly, or allow it to be sorted at an optimal level? What data exists to support that such behavior is reasonable to ask for, and will ‘work’? Substantiating data There is not an established industry testing protocol to answer every question that may be in the grey. In this situation, How2Recycle is not overly prescriptive about the way data is collected (subject to conditions on substantiation data later in this Future Guide). Generally, there are two types of approaches to this sort of data: lab testing, or field testing. There are arguments about the pros and cons of those two approaches. We ask members who are interested in collecting their own data because a sortation test protocol may not exist or may not answer the specific concern (see the How2Recycle Guide to Recyclability for detail) to propose a methodology for testing that they believe would be scientifically credible. More on that later in this Future Guide. Note that How2Recycle is currently studying 2D/3D sortation for certain plastic and paper items. Assessment is taking place on a case-by-case basis for items in the grey.
Reprocessing	For the criteria for reprocessing to support a Widely Recyclable or Check Locally claim, see the How2Recycle Guide to Recyclability. Those criteria still apply here. However, in this Future Guide, since we are focusing on less-recyclable packaging, or packaging where it’s unclear if it’s recyclable today, here are some additional layers of consideration for reprocessing analysis: Potentially relevant questions for plastic packaging design Would this item be classified as Preferred per the APR Design Guide in all or some  parameters of design? Would this item be classified as Detrimental per the APR Design Guide in all or some parameters of design? Is this item considered Non-recyclable per the APR Design Guide? Is the APR Design Guide silent, ambiguous or unclear about the recyclability design of this item? If so, why? Does any industry data exist on this issue that may not be reflected in the APR Design Guide? Potentially relevant questions for plastic packaging where lab testing may be necessary Has the item been tested for technical recyclability? If so, by an APR-qualified lab? Or, by an individual recycler in its on-site lab (may or may not be an appropriate entity to test with, depending on the package type)? Has the item been tested against every parameter of an established industry testing protocol? If an established industry testing protocol does not yet exist, or if How2Recycle has not yet officially adopted an existing protocol for that type of item, what testing protocol was followed, and why? What does the written report from the lab tests say? Does the item pass under all, some or none of the parameters? Is there additional contextual information that may help explain the results that are not in the report? If the results appear ambiguous or unclear in some way, what do you believe that suggests, and why? What is known and unknown? Potentially relevant questions for fiber packaging where lab testing may be necessary Has the item been tested for technical recyclability? If so, by a How2Recycle pre-qualified lab? Or, by an individual recycler in its on-site lab (may or may not be an appropriate entity to test with, depending on the package type)? If an established industry testing protocol does not yet exist (see the How2Recycle Guide to Recyclability for more detail), or if How2Recycle has not yet officially adopted an existing protocol for that package (for example for flexible coated paper packaging), what testing protocol was followed, and why? What does the written report from the lab tests say? Does the item pass under all, some or none of the parameters? Is there additional context information that may help explain the results that are not in the report? If some of the results appear ambiguous or unclear, what do you believe they may suggest, and why? What remains unknown? For all packages Even if the package doesn’t seem to necessarily ‘contaminate’ the stream (and may in some instances even ‘pass’ tests), does this package nonetheless experience a significant yield loss that would make it potentially deceptive to the consumer to label as recyclable? Note that for polyethylene (PE) film, How2Recycle recently studied the impacts of specific innovations on the Store Drop-Off stream. Read more here.
End Markets	A package cannot be considered recyclable if it does not have an end market. How2Recycle has three potential end market categories for assessing the end market of a specific package. A package will be characterized as fitting one of the following three categories: — Strong end markets — Moderate strength end markets — None or negligible end markets.And then based on which end market category applies to a specific package, that package will be eligible for certain recyclability designations: — Widely Recyclable items must have strong end markets. — Check Locally items must have at least moderate strength end markets. — Items that have none or negligible end markets must be deemed Not Yet Recyclable.Each definition of end markets focuses on several key elements: — Demand. Whether the recycling industry has signaled meaningful demand for the material; and — Scale. Whether the material is getting recycled at meaningful volumes; and — Value. Whether the material carries meaningful value; and — Time. Whether value for the material has been sustained over a reasonable time period. In order to meet the standard for having an end market, a package must possess all these characteristics: demand at scale and value across a period of time. In short, positive end markets consist of: Demand + Scale + ( Value Δ Time ) Taking that basic formula into consideration, How2Recycle has developed the following 3 strengths of end market categories based on the nature of the demand, scale, and value of a material across time. Strong end markets — Package is explicitly accepted in an existing bale specification, and that bale is bought by recyclers for recycling at scale, for positive value, for a reasonable amount of time. Moderate strength end markets — Package is explicitly or implicitly accepted in an existing bale specification, and that bale is bought by recyclers for recycling at some scale, for positive value, for a reasonable amount of time. None or negligible end markets — Package is unclear or unknown if accepted, or is implicitly prohibited or explicitly prohibited in an existing bale specification, or package is explicitly or implicitly accepted in an existing bale specification but that bale is not bought and sold at some scale, or bale is bought and sold for negative value for a reasonable amount of time without the material otherwise being intentionally and adequately managed by MRFs and/or governmental entities as a part of the overall material mix. For further definitions of some of these concepts, visit the full rule here. IMPORTANT: In addition to these end markets categories: if materials are being collected for recycling but are sent to landfill, incineration, or waste to energy to any appreciable degree, those items are not eligible for unqualified (Widely Recyclable or Store Drop-Off) recyclability claims. If this is happening to an extensive degree, an item is not eligible for any recyclability claim at all (will receive the Not Yet Recyclable label). How2Recycle may not have any data, or compelling data, for end markets on challenged packaging. In that case, it is the member’s responsibility to assemble data from some or all of the previously mentioned sources, or sources not mentioned here. How2Recycle asks members who are interested in doing this to propose a methodology that they believe would be scientifically credible to provide evidence of strong end markets for their specific item. More on that later in this Future Guide.

This table is complementary to the Navigating the Recycling System resources by ASTRX.

Potential mitigating factors
There are additional factors about the member’s current or future intent that may be relevant, or can provide more context in the decision-making process—but do not necessarily impact the label issued. If these factors are present for challenged packages, it may soften certain concerns in other areas, but it depends on all the circumstances.

• Whether or not the member is investing in, or already executing, education efforts that may be needed to improve recyclability
  • For example, if a certain package type has a high likelihood of being manually pulled out of the stream at a MRF, even if it’s desirable by reclaimers and would flow to the correct bale if not manually pulled out, what is the company doing to educate MRFs about the recyclability of this item?
• Whether or not the member is investing in, or already executing, continued end markets efforts.
  • For example, if the value of a package is only known by a limited subset of potential buyers, what efforts are being taken to expand awareness of the package’s value, in a way that materially impacts the end markets for that material?
• Whether or not the member is willing to label Not Yet Recyclable on lookalike packages in its portfolio
  • For example, if only one flavor of one brand the company owns is going to move to the more recyclable packaging format, and the rest of the flavors and brands with that same package format will be clearly labeled as not recyclable to the consumer, this is a positive step to help consumers know the difference between lookalike packaging.
• Whether or not the member is going to shift the design of all lookalike packages in their portfolio to the more recyclable version
  • For example, if only one flavor of one brand the company owns is going to move to the more recyclable packaging format, and the rest of the flavors or brands of that member with that same package format have no intention of moving to the more recyclable format, this is less compelling than if the company promises to move all its eligible packages to the more recyclable version. Public, formal promises are better than private, informal ones.
• Whether or not the member’s peers will follow the design choices, gradually shifting the recyclability of the product category
  • What is difficult in a standardized labeling system is empowering some level of innovation in packaging to push the entire industry towards more recyclable packaging, without rewarding a high level of design inconsistency within a product category that could confuse consumers longer term. If an entire product category needs to move to a recyclable structure in order for any of them to be deemed recyclable, that removes incentives for the innovative structures to gather steam in the marketplace. It is a chicken and egg problem where brands are (unfortunately) less likely to move to the more recyclable structure unless they can claim recyclability to the consumer, but if only one brand or one product is likely to move to that structure (for whatever reason), it’s potentially more confusing to the general public because it creates more inconsistency of package design in a product category.
• Whether or not the member uses recycled content in the package
  • Whether or not a package is made of recycled material does not impact whether it can be recycled in the future. How2Recycle’s hope is that all recyclable packaging is someday made with recycled material, but the package being made of material that’s already been through the recycling system doesn’t impact whether we tell the public it can go through the recycling system in the future. However, it is critical that companies making recyclable packaging support the end markets for their own packaging material. Sustainable packaging is not just about what happens to packaging at the end of its life, but also what materials are selected for the package, and how it’s designed to minimize the use of materials. Accordingly, if a brand wants to ‘push’ its recyclable packaging into the marketplace without providing any sort of ‘pull’ for demand of the material, putting that responsibility on other players in the system, that is less compelling than a brand that is committed to supporting the markets for its own packaging material.
• Whether the member has made public commitments to continue to monitor and support the future success of the recyclability of the material even after it receives the desired recyclability claim.
  • How2Recycle would like to avoid a situation where a member or group of members works hard on the ground to expand the recyclability of a certain package type, but stops those efforts once collection reaches a certain level. This creates risk it may be downgraded in the future if only the arguable minimum steps are taken to achieve recyclability. Recyclability is not a static thing, and history has demonstrated that relying on markets to automatically sustain viability of certain materials is a risky strategy.

Considerations for far future recyclability

Element	Potential future assessment considerations
Future law	Consider (currently unknown) future FTC guidance on recyclability claims (The Green Guides are up for revision in 2022). Might there be new law and policy in the future that may impact the recyclability of your package type or the recycling system, such as Extended Producer Responsibility (EPR)?
Future collection	Depending on sortation considerations, reprocessing considerations, and end market considerations, what will the collection mechanism for the package be? In other words, how will these packages be accepted for recycling? Will packages be collected via traditional curbside and drop-off recycling programs? Or through traditional collection with a twist (like a special bag within the curbside recycling cart)? Or through Store Drop-Off? Or through a new special take-back program? Or through a collection mechanism we don’t yet anticipate? What will be required to communicate acceptance of this item to the general public in community-facing recycling programs at scale?
Future sortation	Depending on the collection mechanism, and reprocessing considerations, and end market considerations, how will packages be sorted (if applicable)? What sortation technologies will be leveraged to get the package to the right place? Current infrastructure technologies like robotics or near infrared, or technologies not yet contemplated? And/or will packaging technologies such as digital watermarks be leveraged? What will be considered ‘like’ packages for purposes of sortation? In other words, what is the scope of the packaging type for purposes of how it will get sorted, and thus recycled? Will packages be sorted with reprocessing in mind? For example, will they be sorted by different package designs? Will packages be sorted with end markets in mind? For example, will the material be sorted into different grades of value? If applicable, how can it be ensured that the sortation of this packaging type does not lead to contamination of the recycling stream for other packaging types?
Future reprocessing	Depending on the collection mechanism, and sortation considerations, and end market considerations, how will packages be reprocessed? What technologies will be leveraged? Current technologies used at scale like those already at recycled paper mills, or future technologies like chemical recycling? If chemical recycling, which chemical recycling technologies may be relevant for this package type? Does the geographic location and capacity of the reprocessing facilities support the economic collection and sortation of the package? What will be considered ‘like’ packages for purposes of reprocessing? In other words, what is the scope of the packaging type for purposes of reprocessing? Will these packages be reprocessed with other materials already getting recycled, or on their own in a new stream? Will industry develop design-for-recyclability principles for this packaging type with reprocessing in mind? Has industry agreed upon a standard packaging design to ensure sufficiently similar packaging attributes to enable reprocessing of this package at scale? For example, does the package need to be more or less a single material to make recycling it economically viable, and which material is that? How will packages be reprocessed with end markets in mind? For example, will the material be sent to one or a variety of end applications? What are the requisite specifications for those end applications (dictating requisite quality of the material)?
Future end markets	Depending on future law, collection, sortation, and reprocessing considerations, are end markets for this material or its building blocks feasible and viable? What is the marketable recycled material? Is it a building block for one or many materials or products or a ‘drop in’ material for manufacturing today? Are there one or many potential end markets? Do those potentially differing end markets impact how we might conceive of collection, sortation and reprocessing? What’s the economic relationship between this recycled material and its virgin counterpart? Does demand currently exist or will it exist? What drivers may impact future demand? How does potential return on investment impact the future viability of this recycled material? What is the funding mechanism for the recycling of this material (if applicable), and who will fund it?

 

How the elements of far future recyclability are related to each other
As these questions above illustrate, all elements of far future recyclability are interconnected. As a result, these elements should not necessarily be considered sequentially, or separate from one another. A conclusion or insight in one element of recyclability could impact the conclusions or insights in other elements of recyclability for that package.

It’s unclear “where” this work should “start”, and whether work under each element of recyclability should occur concurrently or consecutively with the other elements. Some may argue that one element should strategically “lead” the other elements. In that case, there may not be consensus over which element should be the lead. Some may argue that work within one element should or should not overlap the work within other elements. For example, some would suggest that consensus around design for recyclability is the best starting point for specific package types, in order to scope potential end markets, and may believe that collection can be figured out later. Others may disagree, suggesting that other considerations like which relevant reprocessing technologies for that package achieve scale “first” should be the starting point. This is all to say that there is not yet industry consensus around how future recyclability strategies should be developed, and strategies may differ depending on the packaging type.

How work might proceed under each element of far future recyclability
Under each element of recyclability, there may be different levels of existing research and data for a certain packaging type. Research should be the first step of achieving far future recyclability in order to set a baseline of foundational knowledge of “where we are” in order to assess “where we want to (or can) go.” For example, what is the current state of the infrastructure and potential future infrastructure, what are the specific opportunities and challenges? Once that information has been gathered, a critical analysis should be conducted—what may still be unknown, what are variables that could impact the future, what considerations should be given priority? From that point, there should be industry consensus around what is needed to achieve scale in infrastructure investments and/or packaging design. After consensus is reached, investment in infrastructure and/or design changes is appropriate (although it may also be appropriate before consensus is achieved, depending on the specific context).

Because these considerations are interconnected and complex, efforts to develop the different elements of recyclability should be coordinated with ample feedback loops. This enables the future recyclability strategy to be refined, reassessed, and adjusted as needed over time.

The purpose of the How2Recycle Guide for Recyclability is to transparently provide the general public and How2Recycle member companies with guidance about what recyclability means, and insight about how the How2Recycle program assesses recyclability on a package-by-package basis.

Why the How2Recycle program exists and how it works

In addition to each main packaging component getting one of the prior recyclability categories assigned, special instructions to the consumer to prepare the material correctly for recycling may or may not be added to the How2Recycle label.

Interestingly, the majority of packaging components that are issued How2Recycle labels are either classified as Widely Recyclable or Not Yet Recyclable. A smaller amount are Check Locally or Store Drop-Off.

How2Recycle is an evolving program. As the use of materials in society evolves, and companies and consumption patterns evolve, How2Recycle will change along with those things to continually maximize impact. And recyclability changes: in the history of How2Recycle since the launch in 2012, some packages have become more recyclable, and other packages have become less recyclable over time. For example, due to updated data on acceptance in collection programs and information on markets for rigid polypropylene (PP) containers and polyethylene terephthalate (PET) thermoforms in January 2020, How2Recycle downgraded the recyclability claims for those items.

How2Recycle owns the majority of the substantiation data (like in the case of the SPC Centralized Availability of Recycling study, or written records the program has on file from external experts in certain specialty areas, or lab testing results), but sometimes members come to How2Recycle with data. How2Recycle uses best practices and its best judgment to assess the meaning of that data (what is the data suggesting or not suggesting? Is it relevant?) and whether the data collection methods and conclusions are scientifically credible (who, how, where, when?). In the instance How2Recycle does not have data to definitively answer that specific question, but the member presents relevant data to provide an answer, the members’ data can potentially be used to support the How2Recycle label issued (see the How2Recycle Future Guide to Recyclability for more detail on what data is compelling).

In the absence of compelling data demonstrating its recyclability, depending on all the circumstances, How2Recycle must issue a conservative claim to a package (either the Check Locally label or the Not Yet Recyclable label). For more insight, visit the How2Recycle Guide to Future Recyclability.

Assessment criteria to achieve recyclability
How2Recycle assesses a breadth of information and scientifically credible data related to all of the following elements of recycling in order to issue the most appropriate claim:

• Collection
• Sortation
• Reprocessing
• End markets

The below table reflects important assessment criteria under each element of recyclability. But first, some important caveats to the below criteria:

• Not comprehensive. This guidance is not all encompassing. In other words, do not rely on the guidance here as complete for a package. Guidance may contain nuances depending on the packaging type and new data may illuminate the need for more details. Some packages have questions not listed here—it would be too complex to include all, and there are changes over time. This is intended as general guidance to cover most packages.
• Subject to change. Our guidance and criteria are subject to change at any time, and a How2Recycle label may be rescinded at any time based on new data or criteria. This is because the recycling system continuously evolves, and our data about recyclability updates continuously. That said, broad changes to recyclability (when the recyclability designation changes for an overarching category of packaging) will be communicated to all How2Recycle members simultaneously via updates to the Guidelines for Use on either January 31 or July 31 of each year via email newsletter, as well as posted to how2recycle.info for the general public (starting January 2020).
• Not one-size-fits-all. Not all criteria listed under each element apply to all packages. There is no perfect equation for which criteria apply to which packages and when it is OK to “check that box.” It depends on the specific package and all the circumstances at play. While How2Recycle will issue its members a custom label based on all the criteria and existing data at play for that package today, How2Recycle is unable to give members a mathematical formula or affirmative promises on a specific checklist to legally be able to rely on for future recyclability (see the How2Recycle Guide to Future Recyclability for insights as to why).

Element	Assessment criteria
Collection (Access/ availability to recycling)	Does this item have explicit or implicit access to recycle this item for over 60% of the population in the US, or over 50% in Canada? (This is the starting point to potentially receive a Widely Recyclable label.) Does this item have explicit or implicit access to recycle this item for less than 60% of the population in the US or 50% in Canada but over 20% the population? (This is the starting point to potentially receive a Check Locally label. Below 20% access means that item automatically is deemed Not Yet Recyclable) If a package has less than 60% access, it is not eligible for a Widely Recyclable label, and if less than 20% access, it is not eligible for a Check Locally label. Data: For the US, the Centralized Availability of Recycling Study, last updated 2021. For Canada, CPIA Access to Residential Recycling of [Plastic] Packaging and Packaging Materials in Canada, PPEC Access to Residential Recycling of Paper Packaging and Packaging Materials in Canada, and for SPC by CM Consulting, Access to Residential Recycling of [All Other] Packaging in Canada. See this article for in-depth understanding of how How2Recycle interprets inconclusive access to recycling data, as well as the checks and balances that the program has in place for conclusive access to recycling data that may not tell the full story. See the How2Recycle Guide to Future Recyclability for more detail on how How2Recycle approaches substantiating data for collection for challenged packaging.
Sortation	Generally: How2Recycle looks to size, shape, and other attributes of packaging to ensure that the package successfully gets to where it needs to go at a Material Recovery Facility (MRF).Specifically: Size Is the item the right size to make it successfully through a Material Recovery Facility (MRF)? Shape (For plastics) Is the item too flat (2D) to sort with plastic containers at a MRF? (For paper) Is the item too deep (3D) to sort with paper packaging at a MRF? Other attributes (For plastics) Does the plastic container contain metal or metallized features that would cause it to not get recycled successfully at a MRF via magnets or metal detection? (For plastics) Will the item be successfully identified by near infrared sortation (NIR)? For example does the label (shrink sleeve, pressure sensitive, in-mold or other) made of a different material than the container cause the container to be incorrectly sorted via NIR because more than 75% of the bottle surface area, not including bottom or closure, is covered? Does the dark color make it likely to be incorrectly sorted via NIR? List of sortation potential protocols that may be applicable for certain packages: APR A Practice for Compressing Plastic Articles for Laboratory Evaluation, to be used in tandem with any of the following test protocols (relevance of these tests depend on pack type. How2Recycle prescribes specific tests to members on How2Recycle Member Platform as needed on a package-by-package basis) APR Evaluation of the Near Infrared (NIR) Sorting Potential of a Whole Plastic Article APR Evaluation of Size Sorting Potential for Articles with at least 2 Dimensions Less than 2 Inches APR Evaluation of Sorting Potential for Plastic Articles Utilizing Metal, Metalized, or Metallic Printed Components Coming in 2020: APR 2D/3D sortation potential protocol Only a few select packages require special testing. Of those, members commission their own tests per the above protocols and submit results to How2Recycle for review. See the How2Recycle Guide to Future Recyclability for more detail on how How2Recycle approaches substantiating data for sortation for challenged packaging. Note that How2Recycle is currently studying 2D/3D sortation for certain plastic and paper items.
Reprocessing	Generally: Is there an aspect of the package design that would cause issues in reprocessing? Does the packaging contain or come into contact with hazardous or potentially hazardous materials? Does the product leave residue on the packaging? If so, will the recycling process be expected to reasonably manage any residue not removed by the consumer, and/or, can special instructions be provided to the consumer to correctly prepare the package for recycling? Specifically: Technical reprocessability analysis can be simple or complex depending on the packaging type. For plastics, How2Recycle looks to the APR Design® Guide for Plastics Recyclability to assess potential impacts of: —  Barrier layers, coatings, additives —  Color —  Closures —  Labels —  Attachments For paper packaging, How2Recycle has historically consulted with Recycled Paperboard Technical Association to assess potential impacts of: —  Alternative fibers —  Coatings —  Attachments How2Recycle also has consulted with experts at Glass Packaging Institute, The Aluminum Association, Steel Recycling Institute, and Carton Council regarding specific packaging design issues as they relate to successful reprocessing. List of test protocols that may be applicable for certain packages (relevance of these tests depend on pack type. How2Recycle prescribes specific tests to members on How2Recycle Member Platform as needed on a package-by-package basis): For plastics: an array of APR test methods are available for different considerations For paper packaging: —  For unbleached rigid paper packaging with single sided poly coating or poly alternative coating: OCC equivalency testing by Western Michigan University, University of Wisconsin Stevens Point, or Innofibre Laboratory, both repulpability (Part 1) and recyclability (Part 2) —  For bleached rigid paper packaging with single sided poly coating or poly alternative coating: SBS equivalency testing by Western Michigan University, both repulpability (Part 1) and recyclability (Part 2). Only a few select packages require special testing. Of those, members commission their own tests per the above protocols and submit results to How2Recycle for review. See the How2Recycle Guide to Future Recyclability for more detail on how How2Recycle approaches substantiating data for sortation for challenged packaging. Note that for polyethylene (PE) film, How2Recycle is studied the impacts of specific innovations on the Store Drop-Off stream.
End Markets	A package cannot be considered recyclable if it does not have an end market. How2Recycle has three potential end market categories for assessing the end market of a specific package. A package will be characterized as fitting one of the following three categories: —  Strong end markets —  Moderate strength end markets —  None or negligible end markets. And then based on which end market category applies to a specific package, that package will be eligible for certain recyclability designations: —  Widely Recyclable items must have strong end markets. —  Check Locally items must have at least moderate strength end markets. —  Items that have none or negligible end markets must be deemed Not Yet Recyclable. Each definition of end markets focuses on several key elements: —  Demand. Whether the recycling industry has signaled meaningful demand for the material; and —  Scale. Whether the material is getting recycled at meaningful volumes; and —  Value. Whether the material carries meaningful value; and —  Time. Whether value for the material has been sustained over a reasonable time period. In order to meet the standard for having an end market, a package must possess all these characteristics: demand at scale and value across a period of time. In short, positive end markets consist of: Demand  +  Scale  +  (  Value  Δ Time ) Taking that basic formula into consideration, How2Recycle has developed the following 3 strengths of end market categories based on the nature of the demand, scale, and value of a material across time. Strong end markets —  Package is explicitly accepted in an existing bale specification, and that bale is bought by recyclers for recycling at scale, for positive value, for a reasonable amount of time. Moderate strength end markets —  Package is explicitly or implicitly accepted in an existing bale specification, and that bale is bought by recyclers for recycling at some scale, for positive value, for a reasonable amount of time. None or negligible end markets —  Package is unclear or unknown if accepted, or is implicitly prohibited or explicitly prohibited in an existing bale specification, or package is explicitly or implicitly accepted in an existing bale specification but that bale is not bought and sold at some scale, or bale is bought and sold for negative value for a reasonable amount of time without the material otherwise being intentionally and adequately managed by MRFs and/or governmental entities as a part of the overall material mix. For further definitions of some of these concepts, visit the full rule here. IMPORTANT: In addition to these end markets categories: if materials are being collected for recycling but are sent to landfill, incineration, or waste to energy to any appreciable degree, those items are not eligible for unqualified (Widely Recyclable or Store Drop-Off) recyclability claims. If this is happening to an extensive degree, an item is not eligible for any recyclability claim at all (will receive the Not Yet Recyclable label).

Additionally, How2Recycle considers material health. How2Recycle may render a package Not Yet Recyclable if it contains intentionally added substances that are harmful or potentially harmful to the environment and/or human or nonhuman animal health. For a full explanation of How2Recycle’s material health rule, visit this article.

Additionally, How2Recycle considers whether consumer action to prepare the item for recycling is reasonable. For a full explanation of How2Recycle’s rule on consumer separation, visit this article.

NOTE: Assessing recyclability for Store Drop-off is different than assessing for other recycling streams. Because the Store Drop-off label only applies to polyethylene (PE) film collected in stores (available to the majority of the US population), and does not go through a MRF (in the United States), analysis differs. For example, sortation is relevant only if sort equipment at the PE film recycler (or a MRF in Canada) suggests there may be an issue.

Currently under study for How2Recycle

 

If you are a member of the public and you do not see the How2Recycle label on your favorite brands, reach out to them and ask them to join this movement of transparent and standardized recycling labeling.

If you are a brand or retailer and interested in joining the How2Recycle program, reach out to how2recycle@greenblue.org today.

If you have any feedback for how the How2Recycle program and this criteria may be improved, please submit feedback to how2recycle@greenblue.org.

Originally published April 2020. Last updated July 2021.

Overview & Background

In late 2021, the How2Recycle® program contracted a consumer research firm to conduct research into consumer perceptions of the How2Recycle labels. The primary purpose of this research was to assess the alignment of the intended label meanings with the perceived label messages. Information about consumer recycling behavior was also included as a secondary research objective.

In this consumer research, after completing a short questionnaire about their background, respondents were asked to rate their agreement with multiple definitions of recyclable. Then, they were asked to rate agreement with possible definitions of the four How2Recycle label categories: Widely Recyclable, Check Locally, Store Drop-off, and Not Yet Recyclable. Finally, respondents were asked to “dispose” of products with each of the How2Recycle label types to assess the labels in a usage simulation.

Definition Alignment

The first definition that was assessed was consumer’s perceptions of what it means for something to be recyclable. The Federal Trade Commission (FTC) has provided guidance on recyclability claims in the Green Guides, and that guidance is the foundation of the How2Recycle operating definition of recyclable. However, having an operational definition that is aligned with the Green Guides does not guarantee consumers themselves would agree with our operational definition. Thus, this study was conducted to assure consumers would not feel misled by recyclability messages due to misalignment with their conceptualization of the terminology.

The list of possible definitions respondents rated included a spectrum of how much recycling in practice is required for something to be considered recyclable. The spectrum of possible interpretations of recyclable  included broadest in scope concept of “theoretic recyclability” to narrowest in scope concept of “always recycled in practice”. Additionally, some of the definitions were of common incorrect misconceptions (i.e. “recyclable means a product is biodegradable” or “recyclable means a product is made from recycled content”).

Figure 1. Spectrum of possible interpretations of recyclable, organized from broadest in scope to narrowest in scope.

Results for the assessment of alignment with “recyclability” indicate approximately 30%  of respondents agreed with the operating conceptual framework that recyclable items have to be commonly recycled in practice, not just in theory. The second most agreed-upon (approximately 20% of respondents) was the concept of theoretic recyclability. Theoretic recyclability  is broader in scope than How2Recycle’s operational definition; thus, consumers would not be misled as theoretical recyclability as the minimum standard for “recyclable”  would also include items that are recycled in practice.

Figure 2. Agreement with possible definitions of recyclability

Overall, consumers were also aligned with the intended messages of the Widely Recyclable, Not Yet Recyclable, and Check Locally labels. When forced to choose between access based messages (“recyclable in most communities” or “recycle in some communities” and recycling rate based messages (“recycled most of the time but not always” or “recycled most of the time by participating programs”), more respondents agreed with recycling access based interpretations of the Widely Recyclable and Check Locally labels. However, it is important to note that the How2Recycle requirements for use of these labels includes both access to recycling programs that collect the packaging format and proof of recycling in practice. There is less consensus in agreement of the intended message of the Store Drop-off label. This indication of consumer confusion about Store Drop-off recycling has necessitated plans to dedicate further research efforts to consumer understanding of and participation in  this recycling stream.

Label Usefulness

In the assessment of label use, the majority of participants correctly sorted the simulated packages into the correct disposal option according to the How2Recycle label. Participants were most accurate when disposing of a package with the “Widely Recyclable” label, and they were the least accurate when disposing of a package with the “Store Drop-off” label. These results indicate that the majority of consumers are receiving the intended message of the labels, but that there is room for improvement in consumer education about the variety of Store Drop-off recycling programs available beyond curbside recycling.

Figure 3. Illustration of the waste disposal option that was considered for each label option.

Figure 4. Results of the sortation task for single tiles. Correct sortation is illustrated above in figure 3.

In addition to assessing the accuracy of disposal for simpler packages with a single label tile, a multi-component package with multiple label tiles was also assessed. While the intended disposal option was the most selected, respondents were approximately 10% less likely to correctly identify the intended disposal option. This finding supports the How2Recycle recommendation of single material packaging where possible to increase the likelihood of material recovery.

Figure 5. Results of the sortation task for a package with multiple labels. Correct sortation is illustrated above in figure 3.

Participant Background

This study was conducted with a representative sample of the United States in terms of racial and ethnic background, and included people from all regions of the continental United States. The sample was recruited to have approximately 80% of the sample being made up of people who report recycling and approximately 20% who do not participate in recycling due to the estimated proportion of recyclers to non-recyclers in the United States.

Figure 6. Reasons non-recyclers gave for not participating in recycling.

The results of the survey about consumer recycling behavior indicated that access is the leading reason non-recyclers are not recycling. Additionally, this portion of the survey revealed that the least participated in (23% of respondents) recycling program is Store Drop-off recycling. This low level of participation is likely a driver of confusion about the intended message of the Store Drop-off label. Curbside Recycling was the most participated in recycling program with a participation rate of 72%.

Figure 7. Recyclers participation rates for varied recycling programs.

Finally, consumers were asked about their familiarity and perception of the helpfulness of the How2Recycle label. Overall, 60% of respondents were familiar with the How2Recycle label, with 45% being “very familiar” and 15% being “somewhat familiar.” Likewise, the perceived helpfulness of the How2Recycle label was also highly rated. Overall, 53% of the respondents rated the How2Recycle label as “very helpful”, and 34% rated the How2Recycle label as “somewhat helpful” which indicates an overall helpfulness rating of 87%.

Figure 8. Perceived helpfulness of the How2Recycle labels.

Figure 9. Familiarity with the How2Recycle labels.

Limitations

The primary limitation of the label use portion of the study is the external validity of an online survey methodology. To limit the biasing of participants’ responses, the “disposal scenario” was limited in detail, possibly leading to some confusion that could have been alleviated with more descriptive instructions. Additionally, while participants also were shown images of the products they were asked to dispose of to account for differences in packaging terminology, the presentation of a package as an image with the How2Recycle label oriented to the viewer is inherently different from how people interact with real, three dimensional packages in their daily lives. Additionally, it was assumed that participants would consider the package to be clean and dry when selecting a disposal option.

Future Research

While this study provided some more detailed information about the How2Recycle label’s communication with consumers, it also inspired questions to pursue with future research. For example, what level of empty is considered “empty” by a consumer when they are trying to recycle a package? Likewise, what level of clean is considered “clean and dry” by a consumer instructed to “Recycle if clean & dry” by a label? Additionally, more insight is needed into exactly what challenges  or confusing elements are preventing increased uptake in store drop off recycling.

If you have a question about how the How2Recycle label is functioning as a communication tool, please reach out to how2recycle@greenblue.org.

Recently, SPC released its 2020-21 Availability of Recycling Study that explores how many Americans have access to recycling programs for certain packaging types. This study will help inform recyclability designations for the How2Recycle program.

 

In this article, How2Recycle explores how inconclusive access to recycling findings are interpreted by the program, and shares How2Recycle’s perspective on limitations in access to recycling data.

 

First, this article will explore why inconclusive findings occur and how How2Recycle will interpret the recyclability of packaging types with inconclusive access study findings. Then, How2Recycle will discuss the inherent limitations of access to recycling data, how the program addresses those limitations, and what further research is needed in this space.

Putting ‘access to recycling’ in context
Recyclability is more complex than what meets the eye. Packaging is recyclable if it can be collected, sorted, reprocessed, and ultimately reused in manufacturing or making another item.

Just because some local recycling programs accept a material, that doesn’t automatically make that package recyclable. Just because a package could be sorted or separated from other packages to potentially be recycled, that doesn’t make that package recyclable. Just because a material could technically be reprocessed in order to make something new, that doesn’t necessarily mean that package is recyclable. Just because you could sell the material to become something new, doesn’t mean it’s recyclable. A package is recyclable only if there is a substantial likelihood that it can do all of those things in the majority of communities where an item is sold.

 

For more detail, please visit the How2Recycle Guide to Recyclability.

This article focuses on the collection element of recyclability. Another way of thinking about collection is thinking about people’s access to recycling, or the availability of recycling in their community for certain packaging types.

How2Recycle uses the SPC Centralized Availability of Recycling Study as its substantiation data for the collection element of recyclability in the United States. To learn more about the methodology of the study and the insights it’s yielded about American recycling collection of specific packaging types, visit the full report.

For the How2Recycle program, most of How2Recycle’s interpretation of the Availability Study is extremely straightforward. For example, the study found that 88% of Americans have access to recycling programs that collect PET bottles. Since the Widely Recyclable label for How2Recycle is available for package types that have over 60% access (so long as there are no other issues with sortation, reprocessing, or end markets for that specific PET bottle), this means the study demonstrates the Widely Recyclable label is still the appropriate recyclability for this packaging type.

When access to recycling data doesn’t easily answer all our questions: inconclusive results and why they occur.

Sometimes a closer look at the availability study’s findings is required in order for How2Recycle to apply it to nuanced packaging examples. Specifically, inconclusive access to recycling findings require a closer look.

According to the SPC Centralized Availability of Recycling Study, inconclusive access to recycling findings refer to packaging formats that have less than 10% explicit acceptance for recycling. For these items, there is insufficient certainty around whether the material is definitely intended to be entered into the recycling system. Inconclusive findings are somewhat common for specific packaging formats.

There are a variety of reasons why access to recycling data may be inconclusive, but two reasons will be discussed here in greater detail:

• When communities have good reasons for not communicating the recyclability of all packaging types
• When communities’ recycling instructions to residents do not always reflect packaging realities

To help frame these two issues, How2Recycle will introduce the concept of false constructs, and how these make interpreting access to recycling data more difficult. There are two types of false constructs: the type the packaging industry invokes when it attempts to measure access to recycling, and the type recycling programs invoke when they attempt to communicate recyclability to residents.

Communities have good reasons for not communicating the recyclability of all packaging types
Packaging design is extremely complicated. Packaging producers contribute to design complexity in an effort to create market differentiation, and brands and retailers often source unique packaging to market their products as distinct from peers’. Moreover, packaging touches the sale of all products, and products come in many shapes and sizes with differing protection needs. As a result, How2Recycle creates on average at least 50 new labels per week to accommodate the vast diversity of packaging in the marketplace, adding up to nearly 7000 unique How2Recycle labels total and counting.

Because of these complexities, it is somewhat unrealistic and unreasonable to expect communities would be able or willing to message packaging recyclability beyond the broadest and most common packaging formats that its residents will potentially recycle. When communities message recyclability to their residents, their goals are typically to (a) maximize the recycling of the most valuable materials, and (b) limit the amount of contamination. One of the most popular tactics to achieve both of these goals is to provide as simple and as clear instructions as possible. The more details and nuances community-facing instructions contain, the more potential opportunities there may be for resident confusion or loss of attention span to review the entire list. In other words, communities have a lot of good data-driven reasons to keep it simple. The result of this is that community-facing instructions may not provide all the answers to what is accepted for recycling in those places.

Packaging producers may be looking for definitive evidence in community messaging that their very specific packaging type is accepted for recycling, but that may not actually be the way that communities think about it. In other words, we may be looking for something that doesn’t exist, or maybe shouldn’t exist—it’s a false construct. For example, it may never occur to communities to tell residents that molded fiber protective packaging used to package electronics is recyclable because in their eyes, “it’s just paper.” False constructs about the way recyclability is messaged at the community level can make the way we measure access to recycling more difficult. 

Sometimes to try to demonstrate definite acceptance for recycling of a certain package type, we’re looking for something in community-facing instructions that just doesn’t exist. In other words, false constructs about the way community-facing recycling instructions should look can make measuring access to recycling more difficult.

Communities’ recycling instructions to residents do not always reflect packaging realities
One of the key challenges (but also opportunities!) in recycling is packaging innovation. Packaging research and development inside brand and packaging companies is active and ongoing, and it can take a relatively short period of time for a new package design to reach the marketplace after it’s conceived. Some packaging design changes are invisible to the eye; some are only visible to packaging experts; and some are more obvious. Sometimes new materials or new packaging technologies are developed, or packaging takes new shapes and formats that are actually better for recycling. Sometimes the inverse is the case: packaging innovations may make packaging become less recyclable than what communities think.

Unfortunately, there’s a disconnect between the evolution of packaging and what gets communicated to residents in community-facing recycling programs. As companies continually develop new packaging, sometimes the recycling system adapts to accommodate new packaging types, but often it does not, and those items cannot be deemed recyclable (see the Future Guide to Recyclability for more detail). Or, sometimes entire product categories can now be moved to more recyclable packaging because innovation has changed the package design to fit the existing recycling system. Because of these changes, recycling communities may be relying on overgeneralized or dated technical information about packaging some of the time. It can take years for those more recyclable packages to achieve saturation in the marketplace to the point where communities would have good reason to message them in any specific way even if they are aware of the innovation. Some communities may wait for entire packaging categories to switch over to “the more recyclable version” before investing in different messaging to residents in an all-or-nothing approach.

The way that recyclability gets communicated at the community level can be a result of some or all of these factors and others, and different communities make different decisions on how to manage packaging change in the way they best see fit. It just means that sometimes, community-facing instructions may too be relying on a different type of false constructs, or assumptions about what a certain packaging type is usually made of that may have been accurate at one time but may be no longer, or at least in part. For example, ‘frozen food boxes’ may be a false construct to some extent because these package types used to have wax coatings, which are very problematic for paper recycling. Over time, packaging producers have shifted away from wax to a variety of plastic coatings, or an absence of coatings, that may or may not be recyclable depending on the specific package. In other words, there are many types of frozen food boxes with differing levels of recyclability, and the category of frozen food boxes is no longer what it once was (mostly wax coated). False constructs about what packaging usually is or historically has been can make the way we measure access to recycling more difficult. 

Sometimes when communities message packaging recyclability in a certain way, they’re making assumptions about packaging design that are only somewhat true, or only sometimes true, or no longer true. In other words, recycling programs’ false constructs about packaging design can make measuring access to recycling more difficult.

How2Recycle is a key bridge that can rectify disconnects between packaging complexity and innovation and recycling programs

Considering both packaging complexity and packaging innovation, and the disconnects between that and recycling programs, the How2Recycle label can be a bridge via its in-depth recyclability assessments. Since the How2Recycle program assesses the detailed packaging specifications for each item featuring the label (and where needed, requires lab testing to demonstrate compatibility with the recycling stream), in this grey area, the How2Recycle label can create a link between the packaging world and the recycling world to show what can be recycled and not recycled based on all the other contextual evidence.

False constructs about the way recyclability is messaged at the community level—and assuming positive proof must or should exist for every imaginable pack type—can make the way we measure access to recycling more difficult, especially since packaging is so complex.  Additionally, false constructs in community-facing recycling instructions about what packaging usually is or historically has been, that may no longer be true or only partially true, can make the way we measure access to recycling more difficult. Because How2Recycle analyzes recyclability for thousands of diverse packaging designs, the label can provide a key bridge between the packaging world and the recycling world.

How inconclusive access to recycling findings will be analyzed by How2Recycle

While there are some identifiable patterns behind why inconclusive findings may exist, not all inconclusive findings should be thought about or treated the same. Just because access to recycling data is inconclusive, that doesn’t mean that false constructs are necessarily at play. Some communities may be silent on acceptance of certain packaging types due to real concerns about the recyclability of that package, while other package types may be inconclusive for innocuous and unconcerning reasons. Some How2Recycle in-house knowledge can provide clarity and context for certain package types, but for other package types, further study may be required.

For inconclusive access to recycling results, where it makes sense, How2Recycle may issue a recyclability claim considering all other available evidence on the item’s recyclability. How2Recycle will do this by first characterizing the nature of the inconclusive results for that specific package per the previously discussed themes. Then, if best available evidence suggests that false constructs are likely at play, How2Recycle will consider whether proxy indicators exist in order to confidently call that item recyclable.

The word “proxy indicator” refers to an “indirect sign or measure that can approximate or can be representative of a phenomenon without the presence of a direct sign or measure.” The recycling industry does not or will not currently provide direct measures or data to answer all possible questions related to recyclability. Moreover, for reasons explored earlier, it may not even be reasonable or appropriate to expect that direct measurement to exist in the foreseeable future to satisfy the collection element of recyclability. In the presence of imperfect or incomplete or not immediately knowable information about a specific package’s recycling collection, proxy indicators—or indirect measurements related to other aspects of a package’s recyclability—make sense to approximate collection information in a confident way.

How2Recycle will assess whether proxy indicators for access exist via a package’s sortation, reprocessing, and end markets. In other words, if there is inconclusive access to recycling data, and a false construct appears to be the reason for that, How2Recycle will look for solid evidence of the package’s recyclability in all other elements of the recycling system including sortation, reprocessing and end markets.

There should be no ambiguity that the item is sortable due to its shape, size and other physical attributes in a MRF, reprocessable in the recycling process in which it will be included (based on how it sorts), and there are strong or moderate end markets for that item (depending on which, a Widely Recyclable or Check Locally label may be appropriate). Depending on the specific circumstances, as well as whether a package is considered being upgraded to Check Locally or Widely Recyclable, these proxy indicators may require a higher standard of proof than How2Recycle typically requires (for packages with conclusive access to recycling data). If proxy indicators are present, How2Recycle may refer to the access data point for the closest related packaging format if it comports with common sense.

How2Recycle may also decline to issue a recyclability claim until and unless there are conclusive access to recycling results or more compelling proxy indicators. In the presence of doubt, How2Recycle will err on the side of conservative and issue a qualified recyclability claim or no recyclability claim.

In sum, availability study results may be inconclusive for a variety of reasons. Access may be positively demonstrated through the use of proxy indicators where it makes sense.

When conclusive access to recycling data doesn’t tell the whole story

Even when access to recycling data is conclusive, it still may not tell the whole story. Further discussion is included in the SPC Centralized Availability to Recycling Study in the section “How to use the study findings.” The following paragraphs will explore why conclusive access results may have limited applicability for How2Recycle, and how the program already addresses those limitations. Then, the concept of known MRF acceptance will be discussed, as well as what further research in that space is needed.

Conclusive access data may not tell the whole story because first, sometimes communities use intentionally imperfect messaging; second, market dynamics can complicate how recyclability is communicated at the community level; and third, disconnects can exist between the community and the recycler.

Communities sometimes intentionally use imperfect messaging
One way that community instructions may not tell the whole story is when they intentionally say stuff is recyclable that just isn’t, for specific reasons. Simplified messaging may be easier for residents to understand even if it doesn’t cover all exceptions. For example, many municipalities say that rigid plastics are accepted for recycling. However, plastics 3 (PVC) and 7 (catch all category) are not recyclable at scale in North America. They say this because it’s easier to message to residents “all plastics” are accepted for recycling than to say “all plastics except 3,7…” and so on. How2Recycle has many rules and criteria to ensure that these items will not be labeled as recyclable.

It’s OK when communities use intentionally imperfect messaging, because the How2Recycle label assesses recyclability for every package and will issue a Not Yet Recyclable label if appropriate even if the majority of communities say the item is accepted for recycling.

Market dynamics can complicate how community-facing recycling information is managed
The second way access to recycling data may not tell the whole story is because communities may not have direct or accurate knowledge of what’s actually recycled in their area because of complex market dynamics. Additionally, sometimes community-facing instructions intentionally do not reflect market dynamics because it may be impractical. Communities may not want to change recyclability messaging frequently in order to perfectly reflect evolving market conditions.

It may not be immediately clear to the community if recyclers demand and will recycle certain items… but that’s OK. MRFs physically sort materials into what are called bales; those bales are then sold to the actual recyclers for reprocessing. For example, a MRF will sort some of its paper packaging into what’s called a Residential Mixed Paper (RMP) bale. That bale is then sold to a recycled paper mill. There are complicated rules between MRFs and recyclers for what is accepted or prohibited in bales. Just because a specific package type is not explicitly mentioned in a bale specification does not automatically mean it is not getting recycled if it ends up in the bale. And just because a package type is accepted in a bale does not mean it will get recycled. What is accepted in bales is also subject to change over time, and communication across all players in the recycling system about certain nuances may be imperfect or delayed. For a variety of market-driven reasons, recyclers tend to be confidential about what materials they buy and sell at any given time. How2Recycle has ways to deal with all this.

Another complicating factor is that different people working at a single MRF may provide recycling programs with different answers or judgments on whether a specific package is recyclable for a variety of reasons. The same can be said for people representing recycling programs—sometimes different people’s interpretations of the same information can impact the way recyclability gets communicated.

This is all to say that end market complexity can have a direct impact on how recycling collection, or acceptance, is messaged. Thankfully, How2Recycle has specific rules for assessing end markets so that only packages that have end markets can be called recyclable.

(If shifting market dynamics mean that items are landfilled or incinerated after they’re collected for recycling, How2Recycle will change the recyclability claim of the challenged item depending on the severity of the problem. See the How2Recycle end markets rule for more detail.)

It’s OK that market dynamics mean that community-facing recycling instructions sometimes  don’t tell the whole story, because the How2Recycle label separately assesses end markets for every package so that only those with markets can be called recyclable.

Disconnects between the community and the recycler may exist due to MRFshed inconsistencies
The concept of MRFshed inconsistency can explain why in some instances, communities may not have direct or accurate knowledge of whether their recyclers serving their communities accept the material for recycling. A MRFshed refers to the sum of nearby communities that feed into a single Material Recovery Facility (MRF). Disconnects in what is accepted for recycling within a MRFshed are not uncommon.

Communities set up recycling programs in different ways, and based on those setups, ambiguity or contradictory information can ensue in some cases. Usually in establishing a recycling program, a local governmental entity (often referred to as a municipality) will contract with haulers (the companies that send trucks to collect recyclables) and/or MRFs (where the recyclables are sorted by material type) to establish what material is acceptable for recycling. There are many dynamics between these interconnected entities, and as a result there can be disconnects between the intent of contracts and what really happens on the ground. Some haulers may have different ‘rules’ for what packaging should be collected than what the MRF they are delivering the recyclables to does. It is not uncommon for communities in nearby areas all sending their recyclables to the same facility to actually have different instructions for what’s accepted for recycling. As a result of these nuances, community-facing instructions may not be perfectly accurate or reflective of what the MRF in that area actually recycles.

More work is needed to create greater consistency within MRFsheds so that the general public has more accurate and consistent information about what is recyclable in a particular area or region. MRFshed inconsistency provides helpful context in interpreting access to recycling data and provides industry with direction in understanding where work needs to be done in the future to improve recycling collection.

It’s OK that communities sometimes may have intentionally imperfect messaging, or if communications do not perfectly line up with complex market dynamics. That’s because How2Recycle has other ways of addressing and rectifying those issues.  MRFshed inconsistency provides helpful context in interpreting access to recycling data and provides industry with direction in understanding where work needs to be done in the future to improve recycling collection.

Given some of these inherent challenges in the relationships between communities and recyclers, one concept worth further exploration is whether known MRF acceptance should play a role in improving access to recycling data.

Known MRF acceptance may be an area for future access to recycling research

Known MRF acceptance refers to the presence of credible information that shows MRFs serving specific communities definitively accept a specific item for recycling even if the communities feeding into that MRF are silent on the item. An open question is whether known MRF acceptance should “count” as access to recycling, and if so, how it fits into existing interpretive frameworks. Known MRF acceptance was not studied in the SPC Centralized Availability of Recycling Study, and there is more to learn about this issue.

In some sense known MRF acceptance is a high quality data point because ‘you’re going straight to the source’ for information on acceptance. But in another sense, there may be more to the issue than meets the eye, or there may be consequences to consider before this data point is embraced fully.

For example, we generally understand most of the reasons why there may be known MRF acceptance in a place but silence in those communities’ recycling instructions. Some of those reasons include, they simply haven’t gotten around to changing their website but intend to (potentially in the package’s favor); or it could be that they have no intention of ever messaging acceptance of that item because they have a rule of not messaging more than 10 items to residents (neutral towards the package); or it could be that the MRF acceptance is more begrudging than enthusiastic, so silence is a strategic way to control quantities of incoming feedstocks (potentially against the package’s favor). It’s less understood how often these different reasons impact community messaging, and whether some of these reasons are more ‘valid’ than others and should be able to count towards acceptance or not.

A related consideration is that some industry groups representing certain package types actively invest and work to improve community-facing instructions to create clarity for consumers in places with known MRF acceptance, whereas other groups representing other package types may not.

If known MRF acceptance should be officially included as access to recycling, there’s an additional question of whether limits should be placed on the amount or type of known MRF acceptance that can “count” towards a recyclability claim, in order to avoid unintended consequences such as pauses on investments to improve recycling program messaging.

In summary, there are a variety of reasons for inconclusive access to recycling findings. Inconclusive findings may be overcome by demonstrating proxy indicators for certain packages where it makes sense. How2Recycle can be an important bridge between packaging innovation and recycling programs.  The How2Recycle program already has checks and balances to address certain inherent limitations in conclusive access to recycling data. The concept of known MRF acceptance and whether it should be included as access to recycling for purposes of recyclability claims warrants further research; potential limits may be established.  In all these analyses, How2Recycle will use common sense and critical thinking. As always, scientifically credible data is key. When in doubt, How2Recycle will err on the side of conservative in recyclability assessment.

For more detail on how How2Recycle analyzes recyclability, visit the Guide to Recyclability.

As always, How2Recycle welcomes any and all feedback and insights about these issues in order to support continuous program improvement. Please submit any comment to how2recycle@greenblue.org.

No other nonprofit organization in North America has as much comprehensive data on the recyclability of packaging in the consumer packaged goods (CPG) space than the How2Recycle program. This How2Recycle Recyclability Insights report provides a macro view of the recyclability of packaging today for the benefit of How2Recycle member companies and the general public. Additionally, this report explores the nature of the How2Recycle program’s influence on packaging design, and includes high-level recommendations to the packaging industry about which interventions on packaging design might be the most impactful.

The insights from the How2Recycle member packaging portfolio paint a fascinating story about the present and future of packaging recyclability in the United States and Canada, as well as the impact of the How2Recycle program on packaging design.

Recyclability is only one aspect of sustainable packaging, but an important one. Many companies have public goals to increase the recyclability of their packaging: in the SPC Goals Database, over 56% of companies have goals to make their packaging more recyclable, compostable, and reusable.

Every day, brands and packaging producers submit detailed packaging specifications to How2Recycle, and the program assesses the recyclability of each packaging type and issues specific recommendations for design improvement.

Key findings show that 44% of the packaging that How2Recycle member companies have submitted for the program’s review is currently recyclable. The vast majority of recommendations that How2Recycle provides to its members to make their packaging more recyclable are relatively low-hanging fruit—easy to implement. Two-thirds of recommendations relate to plastic packaging, and the vast majority of the remaining recommendations are issued for paper packaging. How2Recycle has directly influenced at least 6% of its members’ packaging to become more recyclable through recommendations for packaging design changes.

The scale and complexity of the How2Recycle member packaging portfolio

The How2Recycle program counts over 225 brandowners and retailers as members. To date, How2Recycle has issued labels to over 75,000 products in the Member Platform, reflecting around 25,000 different packaging designs. For those different packaging designs, How2Recycle has issued over 3,500 custom How2Recycle labels—which represents not only the massive diversity of packaging design in the marketplace but also the complexity of certain package designs. On average, How2Recycle issues labels for 225 products every day.

As of mid-2019, How2Recycle member companies represent 34% of the CPG industry, as measured by North American annual sales revenue of $680 billion. To avoid any potential ‘double counting’, this figure does not include retailer member companies. Accordingly, the insights in this report reflect a snapshot of the landscape of packaging recyclability in North America, and will increase in accuracy over time. As the How2Recycle program grows (the number of brandowner and retailer members grew by 74% in 2019), the figures in this report will become more and more representative of the packaging marketplace at large.

Not only will the figures become more representative over time, but it’s also possible the overall recyclability of the packaging assessed by the program will shift as more diverse products are assigned How2Recycle labels. Some product categories generally have more or less recyclable packaging than others; take electronics packaging as an example—much of that paper packaging has plastic coatings, rendering it less recyclable, so when more of those companies join the program, that could shift the overall recyclability of member packaging. Additionally, the rise in popularity of retailers in the How2Recycle program (35% growth over 2019) will also influence the recyclability of the member packaging portfolio, since private label products tend to fall more heavily in grocery product categories, favoring certain packaging formats.

The current breakdown of product categories represented in How2Recycle membership show a higher proportion of brands with higher volume, faster moving product categories like food, beverage, health and personal care. This is no surprise, as companies in these categories were the earliest adopters of the How2Recycle label by virtue of their participation in the Sustainable Packaging Coalition, and also face the most scrutiny from consumers about packaging recyclability.