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.