The How2Recycle Guide to Future Recyclability

This isn’t to say that there are equal amounts of these types of packages in the marketplace—equal focus should not be placed on all categories. Recyclability-challenged packaging arguably does not deserve the majority of our attention and energies as a community. Of the nearly 100,000 How2Recycle labels in the marketplace, most are Widely Recyclable or Not Yet Recyclable:

Putting the concepts together of core and challenged on top of the prevalence of the labels in the marketplace, you can see there are different “sizes” of opportunities and challenges for the different categories of recyclability:

And how does this stack up against the overall recyclability categories (colors) that How2Recycle issues members for each overall package design on the How2Recycle Member Platform? These categories are designed to help our members track their progress against their recyclability goals, and inform members about when their package design needs improvement or is best-in-class.

Throughout this process, How2Recycle recommends these guiding principles are kept in mind:

• Science-based approach. Relying on scientific evidence and data enables informed decision-making. Relying on tradition, intuition, or other unsystematic methods may lead to solutions that are not well-designed or shorter-lasting.
• Mutual-gains approach. Understanding the interests and perspectives of all relevant entities increases the likelihood of creating value and arriving at consensus. Uncertainty can be reduced through communication and ensuring incentives and resources align with any commitments made.
• Systems thinking. Identifying and understanding patterns and connections in structures and behavior expands the choices available enables change for structures that aren’t serving purpose well and creates more effective long term solutions to systemic challenges.
• Collaboration. Broadening participation and conversation can expand collective understanding, uncover new perspectives and build trust.

Note that only after some level of scale starts to coalesce around all these elements of recyclability should a conversation on recyclability claims even begin.

While we are constantly investing in new data for the benefit of all How2Recycle members, and are excited and able to take on the task of answering many of those questions for common, core packages—How2Recycle cannot research every possible recyclability question for all challenged packaging types to determine whether those packages could be recyclable in the future. For this reason, the member may need to provide its own data to ‘support the case’ for recyclability. Here are some key concepts explored in this section:

• What does it mean to ‘prove’ recyclability?
• The overall quality of data How2Recycle expects
• How much data How2Recycle expects
• How data should be presented
• How data will be interpreted
• Roles & responsibilities for data
• Commonly encountered problems in data

What does it mean to have to ‘prove’ recyclability?
First and most importantly, something can only be ‘proven’ if it exists. Assuming reasonable facts exist to support the idea that a package is recyclable, ‘proving’ it essentially means building a case for recyclability based on scientifically credible data about how that package flows through the recycling system. The member will have to gather information in an organized fashion, analyze candidly what that information means, and either make an argument for why How2Recycle should agree with that interpretation based on the recycling system today or make investments to see the infrastructure changes required in order for the package to be called recyclable.

Overall, what quality and quantity of data are required? Specifically, FTC says:

“[C]ompetent and reliable scientific evidence… consists of tests, analyses, research, or studies that have been conducted and evaluated in an objective manner by qualified persons and are generally accepted in the profession to yield accurate and reliable results. Such evidence should be sufficient in quality and quantity based on standards generally accepted in the relevant scientific fields…” Federal Trade Commission’s Green Guides § 260.2 (Guides for the Use of Environmental Marketing Claims, pursuant to Code of Federal Regulations, Title 16 Part 260). Emphasis added.

Canadian guidance on substantiation and scientifically credible evidence is extremely similar.

The overall quality of data that How2Recycle expects
Above all, How2Recycle labels must be truthful, not misleading, and supported by a reasonable basis. FTC states that to substantiate environmental marketing claims in particular (like recyclability claims under How2Recycle), a reasonable basis requires scientifically credible evidence.

For the vast majority of packaging, the way data is gathered and interpreted for How2Recycle under FTC’s guidance is straightforward. However for certain packages, there may not be an established standard outlining the exact best way to get data to answer every question that may be in the grey for recyclability. In this situation, How2Recycle is not overly prescriptive about the way data is collected but will review the data generally against the following concepts from the Green Guides, broken down into these pieces:

• Relates to who gathers the data, and for what purpose:
  • Conducted and evaluated in an objective manner
  • Conducted and evaluated by qualified persons
• Relates to how the data is gathered, and what it suggests:
  • Tests, analyses, research or studies generally accepted to yield accurate results
  • Tests, analyses, research or studies generally accepted to yield reliable results
  • Tests, analyses, research or studies and/or results are relevant
• Relates to how much data is gathered, and how good the data appears:
  • Sufficient in quality
  • Sufficient in quantity 
  • …Relative to the standards generally accepted in the How2Recycle program and the recycling community.

How much data we expect

• There is no precise answer as to how much data How2Recycle needs. Some challenged packages have much more compelling cases than others and don’t require as much proof, based on context or common sense or other factors.
• When in doubt as to how much data is sufficient to prove a case, be inspired by the US legal system’s doctrine of “preponderance of the evidence” and “beyond a reasonable doubt”. As an impartial third party truthfully assessing recyclability based on the evidence presented to us, How2Recycle believes somewhere between these two standards of evidentiary proof is a sweet spot for confidently making recyclability claims. Preponderance of the evidence is the standard used in civil litigation and family law and is generally understood to mean the one party “wins” if there is greater than a 50% chance that, based on all the reasonable evidence shown, the claims are true—or in other words, “more likely true than not.” This is a lower standard than “beyond a reasonable doubt” which is used in criminal cases. The standard of “beyond a reasonable doubt” is met when the prosecutor uses facts to convince the judge or jury that there is no plausible reason to believe otherwise—that the crime didn’t occur. The standard isn’t met if after careful consideration of the facts, there’s real doubt as to whether the crime occurred. How2Recycle’s standard of evidence is informal, but falls somewhere between “more likely true than not” and “true beyond a reasonable doubt.”

How the data will be interpreted

• Package is challenged until proven it’s not. How2Recycle assumes that a challenged package is not recyclable (or Check Locally) until the member proves it’s more recyclable. How2Recycle doesn’t start this journey from the point of the member assuming a package is recyclable and it’s How2Recycle’s job to prove that wrong. Rather, How2Recycle assumes the challenged package isn’t recyclable, and the member presents a compelling case that it is.

Roles and responsibilities

• Burden of proof is on the member. This means that the member is responsible for acquiring and sharing the data to support that the package is recyclable if How2Recycle does not already have that data in-house.
• Burden of persuasion is on the member. This means that member is responsible for ‘making the case’ with that data and persuading that the package is recyclable. Why should How2Recycle look at the data a certain way? What does this data mean?
• No one else is qualified to tell you what How2Recycle label applies other than How2Recycle. No other organization is authorized to dictate what type of data is sufficient and compelling to get a label. Consultants and other organizations can help usher you along in this process and their opinion can be something How2Recycle potentially takes into account, but does not dictate the outcome.

How the data should be presented to How2Recycle

• Explain yourself. When findings are presented to How2Recycle, the key word is because. All too often How2Recycle receives conclusions from the member based on the data, but there is no reasoning that connects the data to the conclusion. Why do you think what you think? Because, because, because.
• Organize arguments into clear segmented supporting points. It’s more persuasive to say that a certain conclusion is true if it’s explained it’s for X number of reasons, and then those reasons are discussed one by one.
• Alternative arguments are acceptable. This means presenting more than one potential outcome for a package even if those different outcomes contradict each other. For example, “we believe that our packaging should qualify for the Check Locally label, but we also believe that our packaging should qualify for the Widely Recyclable label.” Providing an argument for each means that multiple options are available if the ideal or desired outcome isn’t possible. It’s OK to throw multiple things up on a wall and see what sticks. How2Recycle doesn’t judge a member for possibly appearing self-contradictory. This is an everyday occurrence in the field of law that helps tease out potential benefits and risks of different outcomes.
• Avoid incomplete sentences or bulleted lists without accompanying written explanation. Power Points are helpful if they are a cherry on top of all the other data you’ve sent us. The devil is in the details and How2Recycle wants the whole body of evidence, not just the highest level summaries.
• Approach this journey by attempting to make a compelling argument with solid supporting evidence. Recyclability assessments aren’t a negotiation—for members’ benefit and How2Recycle’s, How2Recycle is legally required to take things carefully step by step, and all members are held to the same standard of scientifically credible information. How2Recycle is unable to make special exceptions or deviate from the established process.

Commonly encountered data problems

• Redacted data or summaries only. While Power Points and freestyle conference calls may be the modus operandi of the business world, in order to substantiate a claim legally, How2Recycle needs full documentation. Summaries are important and helpful to include, but only sharing summaries is insufficient because they can be inaccurate or incomplete. How2Recycle will feel confidence when the entire body of evidence can be assessed as a whole.
• Nonrepresentative data. This means the data provided is not representative of the ‘average’ or the big picture of the concept being measured. For example, if a member wanted to show how a package flowed through a MRF but picked the most technologically advanced MRF in the country that is ahead of all its competitors in terms of sorting equipment, that is not representative data. It doesn’t mean it’s irrelevant, but it’s less compelling than a flow study at a MRF that is more or less average in terms of capabilities, throughput, etc. Sometimes the question of what is actually ‘representative’ is difficult and not straightforward. How2Recycle does not have answers for what representative means in all contexts. In these cases, How2Recycle urges members to ask themselves, what do YOU think is representative? What does the member’s legal team feel comfortable with? Start there, and we can respond to any proposals before the member invests in data acquisition that may not be representative of that thing the member is trying to measure.
• Lack of explanation of methodology (and reasoning behind why it was chosen). Sending How2Recycle a document with numbers and conclusions without context or detail as to how the member arrived at those conclusions only generates more questions than How2Recycle had to begin with. And why did the member choose to measure it in this way—what is the member’s reasoning for taking this strategy? Providing this information goes a long way to putting the data in context and helping How2Recycle build confidence in the methodology chosen. How2Recycle also needs to see the calculations behind quantitative conclusions.
• Missing data. For example, if a member said it tested under parts 1 and 2 of WMU’s SBS-E protocol, but part 2 is missing from what was sent to How2Recycle, How2Recycle will have to ask member to provide that. Do not omit data.
• Contradictory data (unless you acknowledge and interpret the contradiction). There are two types: data that contradicts itself (within the same study or data set) or data that contradicts other data (that How2Recycle may have on file or that member knows may exist otherwise). In this instance, How2Recycle expects the member to acknowledge and explain the contradiction—this not only builds credibility and trust, but also expedites the process. If that explanation is not persuasive, How2Recycle will likely require more data to overcome the discomfort from the contradiction. But data can also contradict itself. This means it either doesn’t make sense or can’t be explained, or is ambiguous in a way such that two opposing conclusions may be possible. This is more common than not, because the recycling system is complex and straightforward answers do not always exist. The presence of a contradiction is not a dealbreaker for your item—in fact How2Recycle expects at least a small amount of ambiguity or differing opinions in anything by the nature of recycling.
• Data that doesn’t answer the question that was asked. This could also be called nonresponsive data, or irrelevant data. For example, if How2Recycle asked whether hand pickers at a MRF are likely to pull this item off the conveyor because they are trained to consider it a contaminant, but in response member presents optical near infrared equipment sortation data showing it sorts correctly 75% of the time, that does not answer the question of whether humans will pick it out anyway (either before or after the optical sorter does its job).
• Only highlighting favorable data, or omitting or glazing over less favorable data. Build credibility through full disclosure. Put the data in context to suggest why it might be this way.
• Data that isn’t objective. For example, polling a company’s own employees about their personal opinion on a matter is not objective data.
• Not considering differences between qualitative and quantitative data and what might be more compelling in certain instances. Quantitative data is numbers—it relates to quantities or specific measures of things. For example, a specific additive in PET may increase yellowing for recyclers at X% when used at Y% concentration. Qualitative data is descriptive and not measurable in the same way. For example, a trade association representing PET reclaimers publishes that they consider a certain type of closure detrimental to their recycling process. Both types of data are relevant and important in interpreting recyclability; qualitative data can tell us about behavior and dynamic realities or illuminate realities that are very difficult to measure; quantitative data allows us to make statistical comparisons and inferences in a more predictable and fixed way. Both types of data may illuminate the other. This is just something to think about in the journey. Think like a scientist.

What members should keep in mind if they go down this road.

At How2Recycle, we say design your packaging to fit the existing recycling system, or change your packaging. It’s as simple as that. But, some companies don’t like that answer. Some want to keep their existing packaging but ask the system to change. That is a harder road. That is what some of this guidance is for. But understand that’s swimming upstream.

How2Recycle recommends a longer-term, holistic approach to packaging sustainability. Just because a company has challenged packaging doesn’t mean the company should try to achieve a recyclability claim in the short term (short term generally means immediately to 3 years from now—but it depends on package type). Many companies understand that their packaging is challenged within the existing recycling system and instead of pushing for ‘recyclable’ today, they are focusing their energies on other strategies. For example, by investing in chemical recycling infrastructure or doubling down on other important sustainability attributes of their packaging like maximizing use of recycled content (PCR) and selecting safer packaging materials.

How2Recycle observes that companies are most aggressive about challenged packaging when all or a substantial portion of their business relies on it, and the company wants to maintain the status quo of its business to the maximum extent practicable while not losing customers because of the weaker end-of-life story. Some believe the recycling system will or should adapt somewhat to their packaging and economic interests. More diversified businesses, or those taking a holistic, longer-term perspective on sustainable packaging are less likely to press to get their challenged packaging to be deemed recyclable, and understand that the economics need to benefit all parties.

That said, we are environmentalists, and of course would like to see more valuable items deemed recyclable, leading to more materials getting recycled. How2Recycle loves and embraces innovation (both in packaging and the recycling system), because without it, we cannot evolve and build resilience. For this reason, for certain packaging (those that face an easier road to recyclability than others), pursuit of recyclability claims can be a meaningful and worthy one if that effort is executed thoughtfully. But if a company decides to go down this road, expectations should be managed, and investments should be expected.

The first step towards recyclability should be submitting a label request to the How2Recycle team to confirm the label that it would receive today. This sets a foundation for where the package is today, so members can compare that to where they’d like to be. Along with the How2Recycle label, the program will provide specific recommendations for design improvements to make the packaging more recyclable. This is the starting point to understand generally what the issues are, but because challenged packaging is complicated and nuanced, the label does not always tell the whole story. This first step is critical so companies do not make incorrect assumptions about their packaging.

The second step is sharing your intent on your package’s future recyclability with How2Recycle. This is OPTIONAL—if a company has a challenged package, the member doesn’t need to let How2Recycle know, and if the member is not going to pursue future recyclability, How2Recycle doesn’t need to know that either. But if the member intends to try to create future recyclability, it’s advised to give How2Recycle a heads-up to help avoid any unforeseen road bumps in the details. For example, maybe How2Recycle just learned something that would impact the guidance the program gives a member on a package (note that significant learnings are proactively shared with all How2Recycle members). Accordingly, please send a note to how2recycle@greenblue.org. How2Recycle recommends your email communication follow one of these formats

• We have a challenged package (include label request URL from How2Recycle Member Platform) and we are going to take on the task of building a case for recyclability. OR
• We have a challenged package (include label request URL from How2Recycle Member Platform) and we would like to explore whether we should take on the task of building a case for recyclability.
• Helpful details to include:
  • Who the member has designated as the internal primary contact on this matter (How2Recycle has had companies unintentionally duplicate effects because multiple persons in a company reach out regarding the same thing, or certain important people may not be looped in, creating information gaps)
  • Whether or not you’d like How2Recycle to share your company’s name with other companies with the same challenged package—possibly we could give you each other’s contact information for potential collaboration? Are you an SPC member? The topic may be eligible for one of our Collaboratives.
  • Whether you intend to work with a specific organization or consultancy to help you navigate this process (not required).
  • What your general expectations or hopes are (time-wise, and what exact result are you hoping for?). This gives How2Recycle some additional context in case we can give you any important initial feedback.

We will confirm the receipt of your email and give any feedback we are able to at that time. Based on the novelty and complexity of the issue at hand, an additional conversation may or may not be appropriate. Of course you can change your course of direction from the above avenues at any time—just let us know.

The third step is coming up with a plan for achieving future recyclability based on the guidance in this Future Guide, and sharing that plan with How2Recycle. Do not take action on your plan yet—we don’t want you to think you need to do a certain thing, when in fact that may not be the appropriate thing. How2Recycle is happy to vet a member’s plans to save time and money before a member starts off on a journey.

How2Recycle will need to see plans in writing. Telling staff verbally what your plans are is insufficient because the program needs a paper trail for clarity, and due to the complexity in this space, How2Recycle needs time and opportunity to fully prepare our feedback.

What that plan to achieve future recyclability looks like depends on the member. The intent of this Future Guide is to provide as much constructive, specific guidance as possible to demystify the process and How2Recycle’s impartial perspective on it. That said, How2Recycle is not so bureaucratic as to prescribe a specific approach for every single challenged package of the future. That’s because most of the time, we may not know the answer, or a specific approach could be arbitrary. There are always grey areas and unknowns when a member is trying to push the frontier forward.

This is the point in the process where How2Recycle flip the burdens on the member, for you to ask yourselves what you think is a good journey to future recyclability (given our guidance outlined here). As much as How2Recycle would like to say we know all the answers, we don’t. We are open minded about how you build your case. We just need the case to be a good one.

The fourth step is to follow your plan. And to keep How2Recycle updated! Keeping How2Recycle updated helps ensure you are still on a confident plan for future recyclability. At this point How2Recycle only needs to know high level information; the program doesn’t need to be involved in the details of the process.

The final step is to request a new How2Recycle label at the end of your process. Because future recyclability strategies may vary wildly for different packaging types, How2Recycle doesn’t want to be too prescriptive here, but a point does come where the member needs to inform the program you are “ready” for us to consider your “case.” Depending on how the process has gone so far, How2Recycle may need the member to send information in writing, or may need some time to deliberate and follow up with further questions. At this point, patience is required. It can take time for How2Recycle to assess a case and manage any possible follow up research that may be needed (on our side or yours), especially if other members are ahead in the queue. But hopefully, at this stage, you’ll have a Check Locally or Widely Recyclable How2Recycle label because of all your hard work and investment to uncover truth and expand the recycling system’s capabilities.

Commonly encountered process problems

• Member has not read, understood, or challenged their consultant’s or supplier’s work or data before passing it off to How2Recycle. Member should read the work, ask questions, and require clarity for things that might be confusing, vague, or unclear. While you may not have the same subject matter expertise of that person who did the work, common sense and a healthy dose of skepticism is usually enough to provide an effective filter. Doing so helps the member have a stronger case and understand its package’s challenges on a meaningful level.
• Unclear explanation of packaging format. It is critical to clearly indicate the type of package for which the member wants a How2Recycle label; if the member gave one set of specifications, does the member want the conclusion we give to extend to other similar packages? If so, how are those packages different (e.g., different sizes, different labels adhered to them, or different thickness of coatings)? If you’re unsure what information to disclose, disclose it all.
• Unclear what is actually being requested. Is the member asking How2Recycle to say  whether it’s within the realm of possibility for the package to be considered recyclable within the next few years, or is the member wanting a Widely Recyclable label right now? Tell How2Recycle what you are requesting.

The How2Recycle program doesn’t have all the answers, but is committed to an impartial, honest assessment of the recyclability of packaging so that consumers are not deceived about an item being recyclable. How2Recycle would like to see more packaging get recycled to support a circular future. This is our humble attempt at bringing some structure and guidance to a sometimes murky frontier based on information available to us today.

What do you think? Is this helpful? What else should How2Recycle consider? Please let us know at how2recycle@greenblue.org. This is a living document and we want it to continuously improve and evolve.

How2Recycle is a part of 501(c)(3) environmental nonprofit GreenBlue in Charlottesville, Virginia.

GreenBlue is dedicated to the sustainable use of materials in society, and envisions a world where human activity is in balance with Earth’s carrying capacity. GreenBlue was originally founded by William McDonough and Michael Braungart who together co-authored Cradle to Cradle: Remaking the Way We Make Things, which is acknowledged as a seminal text of the sustainability movement.

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.