When it comes to packaging claims and legislation, right now, we’re in “the messy middle” as GreenBlue Executive Paul Nowak calls it. No one knows exactly what their operations and fees will look like when EPR legislation kicks in across states. No one knows which states will pass Truth in Labeling laws or PCR mandates in 2025. But we do know that in order to get out of this messy middle and into a functional future, we’ll need data to be our guide.
At How2Recycle, we ground our definition in five pillars: applicable law (such as the U.S. Federal Trade Commission’s Green Guides and guidance from the Competition Bureau Canada), collection, sortation, reprocessing, and end market viability. Now, as U.S. states and Canada refine their legal definitions of recyclability, we adapt in accordance with our first pillar.
Where does data come in? Moving forward, laws will require formats to meet certain recyclability thresholds — and they’ll require data-backed evidence to prove it. And that’s where our How2Recycle R&D team comes in.
How2Recycle R&D Senior Project Manager Nyssa Thongthai and R&D Project Manager Marina Solis are at the center of How2Recycle’s data interpretation and standards. As the recycling landscape shifts gears to meet the new packaging policy paradigm, these two know that there’s a data revolution in recycling. Let’s explore the role that data will play on our path out of the messy middle.
What role does data play in recycling? What role has it played historically and how is that changing in the years ahead?
Marina Solis: Before there were regulations for environmental marketing claims, there was a sense of lawlessness. There were more unverified claims going into the marketplace without penalty. Now, not only are there regulations specific to on-pack labeling, but consumers are also more informed — they want to see the truth backing recyclability claims.
As we move further down this road, having data behind your claims on-pack is becoming more and more important, both for consumers and for compliance. The data is critical from a substantiation standpoint, which is what How2Recycle labels are all about.
Nyssa Thongthai: When I think about this question, I think about the data that sits within our recyclability pillars and how we define recyclability as a program. For us, data has always been at the core of what we do, it ensures we have everything we need to substantiate the accuracy of all of our on-pack labels.
What is changing in the future is that there’s more nuance to data. Decades ago, data wasn’t questioned as much, but now people are scrutinizing it more than ever. There’s a lot of debate on data interpretation, too, which makes it even more important to keep having conversations about how we align data with partners, members, and the public.
What kinds of data are you dealing with at How2Recycle?
Marina Solis: We’re backing our definition of recyclability with data organized by our five pillars, plus the underlying principles. In terms of how we get our data, that varies. Sometimes it’s hard numbers as in calculations or results from a standard test protocol; other times it’s more qualitative and based on a physical evaluation and common sense logic.
Nyssa Thongthai: On the team handling label requests, we deal a lot with test data that shows whether something is technically recyclable or reprocessable. We also look at sortation data to determine how packaging moves through the sorting system at a MRF. As our program evolves, especially with our alignment with The Recycling Partnership’s acceptance data, the definition of what “acceptance” means may evolve, too.
How do you keep up with changing data?
Marina Solis: Our partners and members play a big role in how we keep up with changing data and new data. Different partners have different specialties. The Recycling Partnership, for example, is more plugged into individual communities, and they’re the ones pulling the national acceptance data in the U.S. We also have the Association of Plastics Recyclers who helps us keep up with all things in the technical plastics world.
We’re a small team and validating recyclability for innovative formats takes time, so we’ll ask our members to provide data if they’ve requested a label for something new or unusual. Our members have also been great with being proactive and collaborating with others to build their case for a label designation change. We stay open to receiving new information and growing and improving with the changing times.
What are some of the biggest misconceptions around recycling data that you encounter in your work?
Marina Solis: I often see questions about what the recycling rate is or how a label has changed the capture rate. I think there’s a misconception that we track this, but while we would love to have this information, it’s beyond our scope. People think this data is easier to get than it actually is. Material recovery facilities and reclaimers are businesses, so they’re not necessarily open books where you can see the volume of everything collected or captured.
Nyssa Thongthai: One of the biggest misconceptions I see is the idea that a single piece of data automatically means that something is recyclable. People sometimes don’t realize that our recyclability assessments follow a specific definition (based on the FTC’s Green Guides and Competition Bureau of Canada Guidance). For our program, packaging has to meet the requirements of all five pillars of recyclability, not just one or two, to be considered recyclable.
How has better data directly improved recycling?
Nyssa Thongthai: Better data helps track and understand how things are progressing. If you can’t measure it, you have no way of knowing if you are making progress. Having reliable data helps us understand the current recycling landscape better, and how to improve it.
Marina Solis: We’re also able to use data to provide recommendations for members on how to make something more recyclable. There have been times where we determined something wasn’t recyclable or they needed to test it and it failed. Then the member came back using a similar but different material, tested again, and it passed for higher recyclability.
Talk to me about the term you used at the 2024 How2Recycle Summit “ASAD.” What does that mean for How2Recycle?
Marina Solis: ASAD means “as soon as the data.” At the 2024 How2Recycle Summit, someone asked about the timeline for a challenged format receiving a “Widely Recyclable.”
Practically, ASAD means that the data needs to be proven before we can assign a label. We are an on-pack labeling system. The label is a reflection of recycling as it stands today, so it can’t be used before we have data backing a recyclability claim. But I also said ASAD, because things can change as soon as we get the data to change them. Functionally, could we produce a label? Sure, but there’s not a timeline to when we would actually get the data from a member or trusted source. So just as soon as the data comes in in a scientifically valid way, that’s when we can actually issue a positive recyclability label. From there, our team’s pretty quick at assigning a label.
What emerging legislation or technologies will have the biggest impact on recycling data?
Nyssa Thongthai: Definitely EPR and SB343 for the U.S. That’s going to have a huge impact. For technology, improvements in AI sortation at MRFs. It’s able to capture a ton of data identifying brands, materials, sizes and colors, and whether the packaging is sorted correctly or incorrectly. All that data can really help to improve both packaging design and sortation, making the recycling process more efficient.
In a perfect world, how would recycling data be collected, shared, and used?
Marina Solis: One word I think of is “freely.” We want more out of our data — we want it to be better, transparent, and shared with our members and consumers too. We also want it to be auditable. We want the standard for data to be higher, with a more rigorous check in place.
Nyssa Thongthai: In my perfect world, we’d put sustainability first, prioritize it over marketing or competition to collaborate more, and talk about how we can all coordinate and share our data to improve this industry together.
Why are we in the middle of a data revolution in recycling?
Nyssa Thongthai: Because of all the sustainability regulations coming out. Several states are trying to develop their EPR programs, which require more data sharing to demonstrate compliance — more showing that you’re using the right materials to avoid fees. I think that’s why we’re in this revolution, because sustainability has come to the forefront more than ever.
Marina Solis: To back it up further, the data revolution is a result of the climate crisis we’re in right now. We have so many people working in sustainability fields because we need to take action, and we’re nerdy scientists who use data to get everything done.
What resources do you recommend for someone trying to find their footing in the world of recycling data?
Marina Solis: Come talk to us. We would love to explain the data behind our process. Anyone on our team could give a rundown on our assessment process or a thread to start pulling at. Being part of GreenBlue, we also have many resources available to the public through the Sustainable Packaging Coalition and other projects.
Another thing someone could do is start locally. If you live in an area without great information published about what you can recycle and what’s happening in your material recovery facility, or if you don’t have recycling, start poking around your community to figure out why.
Nyssa Thongthai: Check out our website. We have a lot of resources that explain our program, what we mean by recyclability, and how our process works. I’d also say, keep an open mind. If you’re new to recycling, it can be very overwhelming and confusing at first. There are many definitions of recyclability out there that can coexist and work together. While each program has its own definition, at the end of the day, we’re all working towards the same goal of sustainability, even if we have slightly different objectives or approaches.