Tag: consumers

Are we expecting too much from consumers to prep a package for recycling?

Special instructions (above, “Remove From Sleeve”) are added to the tab above a How2Recycle label tile to tell the consumer any special action that is required before recycling.


This article shares the How2Recycle program’s approach to determining what consumer preparation of packaging for recycling is reasonable, and provides guidance for what good packaging design looks like on this front.


What are special instructions?
Special instructions are used in the upper tab of some How2Recycle labels to communicate to the consumer how the item should be prepared for recycling. There are over 200 variations of special instructions used on How2Recycle labels. Special instructions may be included in the How2Recycle label for a variety of reasons, such as

  • To reinforce recycling best practices
  • To improve the overall clarity of the How2Recycle label for a specific package
  • To increase or ensure the likelihood of the item getting correctly recycled
  • To decrease or eliminate any associated contamination in recycling from that item.


What is How2Recycle’s approach for determining whether special instructions are appropriate for a specific package?
How2Recycle takes a balanced and common sense approach to determining whether a special instruction is appropriate. The program seeks to support packaging innovation and is not overly averse to the use of special instructions where needed, but also recognizes the importance of convenience and ease for the consumer to recycle correctly. With that in mind, How2Recycle engages in a case by case analysis of the packaging to assess whether a special instruction is appropriate per the following:

How2Recycle will not provide a special instruction to the consumer if it would be unreasonable to ask the consumer to take the special action. Unreasonable may include, but is not limited to:

  • The use of tools, such as scissors
  • Actions that require special dexterity
  • Actions that require notable use of force
  • Actions that require special patience or length of time
  • Actions that require any consumer ingenuity (such as finding another package to nest the package inside)
  • Actions that may put the safety of the consumer at risk

If How2Recycle cannot provide a special instruction because the action required would be unreasonable per the above criteria, the entire package will be deemed Not Yet Recyclable.

Exceptions may be made for special actions that are well-known and generally accepted by the general public to prepare the item for recycling (for example, flattening corrugate boxes).

Specifically, effective July 31, 2021 How2Recycle will not provide a special instruction to the consumer to recycle the package, and the package will receive Not Yet Recyclable, for:

  • Removal of full body shrink sleeve labels on plastic containers that do not have full-length perforation
  • Removal of high coverage pressure-sensitive or other types of labels on plastic containers that are not very easy to remove
  • Removal of pressure-sensitive non-PE labels on PE film that are not very easy to remove

Note that not all labels on packaging require removal in order for an item to be recyclable. How2Recycle assesses in-depth packaging information to determine whether labels impact recyclability in each instance based on a variety of considerations. Some companies have innovated labels (including full body shrink sleeve labels) that are preferred by recyclers and do not require any separation at all—use of these labels is strongly recommended. Labels that do not require consumer removal at all are much better than labels that are perforated but still require removal. For more detail, visit the APR’s Design® Recognition Program.

Note that paper packaging is more sensitive to product contamination in recycling than all other materials, so special instructions may be more stringent or altogether unavailable. Further research is required to determine what is sufficiently “clean & dry” for certain product applications for paper packaging. How2Recycle will update members when further guidance is available.

How2Recycle may not be able to provide a special instruction even if it’s reasonable if end markets cannot be positively demonstrated for that item. Recyclers may be intolerant of the package type or its associated contamination levels regardless of whether a special action is taken or not. In other words, special instructions cannot be used as a lever to overcome certain end market challenges.

The type of special instruction provided (meaning, the way the special instruction is worded or treated in the label design) will depend on a variety of factors including but not limited to:

  • Ensuring avoiding consumer deception regarding what it takes in order for the item to get recycled. This may mean in the presence of uncertainty as to the appropriate strength of the instruction, How2Recycle will err on the side of conservative and provide a more strongly worded instruction or render the package Not Yet Recyclable.
  • Consistency with other labels previously issued for similar packages
  • The level and type of concern from recyclers if special action is not taken
  • Common sense and empathy for the consumer

Note that in the interest of standardization, How2Recycle cannot provide custom or different consumer preparation instructions to a member by request. Special instructions may be adjusted or eliminated altogether if member presents compelling and unambiguous data demonstrating another instruction is superior for recycling or if the instruction is unnecessary for recyclers to recycle the item properly (for more insight on what is compelling data, see the How2Recycle Guide to Future Recyclability). Special instructions will not be softened or adjusted to convey an appearance that the special action is less burdensome.

How2Recycle may undertake further research or analysis to provide greater specificity to this rule in the future.

Given all this, what does good packaging design look like in terms of consumer preparation for it to get recycled correctly?


Good packaging design means no separation is required at all. Separation is required where packaging components are made of different materials that flow through different streams in the recycling system and so need to be placed in the recycling bin separately, or where some part of the package would constitute contamination to a degree that requires it be removed and discarded. The packages that are best designed for recyclability are those that are made of one material only. 

If separation is absolutely required, How2Recycle recommends that:

  • The separation occurs as a normal part of use of the product and is not something that only happens at the point of disposal
  • The separated pieces each remain wholly intact and maintain their physical integrity
  • The special action is quick, requires negligible force, and is able to be easily understood and accomplished by all members of society regardless of age or ability.

For more insights on packaging recyclability, visit the How2Recycle Insights report.

How2Recycle piloting shared label with Recycling Partnership

Paul Nowak & Olga Kachook at SPC Advance 2022

“The idea is that we could have a combined label that’s dynamic,” said Tom Pollock, GreenBlue’s director of strategic partnerships, noting the potential to also translate what they learn from how consumers are using the searchable tool into broader changes. “So if we have more data about what’s happening in recycling, in the recycling infrastructure, we can use that and share that with our partners so that we can make improvements.”

The How2Recycle Label Does So Much Right. Why are Recycling Rates So Low?

“It’s really challenging because as we see that occur, (we’re) operating at a national scale, so figuring out how to adapt to the different states while still communicating to a national market is complex.” – Karen Hagerman, Director, How2Recycle

“One really hot topic with the How2Recycle label, our membership and just recyclability in general is all the movement on policy to regulate recyclability messaging,” she said, referring to California’s S.B. 343 truth in labeling law coming into effect in 2024.

Perspectives from Early Adopters of the Recycled Material Standard

early adopters of RMS at SPC Impact - Austin

The Recycled Material Standard (RMS) has seen a rapid increase in certified participants and activity over the last few months. At the recent SPC Impact conference in Austin, TX, the RMS team highlighted new certification resources and RMS participants shared the stage to discuss their successes in leveraging different RMS tools.

Perspectives from Early Adopters

An overflowing room of attendees listened as Cherish Changala of Revolution Plastics, Richa Desai of Graham Packaging, and Martha Issa of Veritiv shared insights into their companies’ experiences with RMS. A panel discussion explored the three companies’ experiences as early adopters of strategic avenues to utilize the standard, including traditional recycled content claims supported by chain of custody, mass balance allocation, and Attributes of Recycled Content (ARC) trading.

Revolution was among the first companies to achieve RMS certification, and has used average content claims for certified post-consumer and post-industrial materials. While Revolution has been certified to other standards in the past, Changala said the company wanted to be an early adopter of the RMS because “it was so comprehensive. It’s a new way of looking at [certification].”  She noted that certification is important to Revolution because it helps their customers feel confident in their products.

Graham Packaging is now working with newly-accredited certification body DNV Business Assurance USA to pursue certification for two facilities in York, Pennsylvania. Desai noted a few features of the RMS that have helped the process go smoothly. Graham was able to use the new RMS toolkit to ease the burden of preparing for certification, unlike other certification processes that required the assistance of a consultant. Compared to other standards, the opportunity for multi-site certification via RMS has also helped reduce the audit burden, so the company doesn’t have to audit every site every year.

Like Revolution, Graham sees the value in certifying both post-consumer and post-industrial materials. Desai noted that post-industrial materials can help customers with goals to reduce virgin plastic use, while maintaining quality and performance of packaging.

Graham is the first RMS participant to pursue the use of mass balance allocation.  According to Desai, there are a few key advantages. First, mass balance gives Graham the flexibility to use materials processed through mechanical recycling and advanced recycling. Second, the company hopes to leverage non-food-grade PCR into food grade applications. Given the lack of supply of food grade PCR, especially for polyolefins, this flexibility will help Graham’s customers meet their recycled material use targets. Mass balance will also give Graham the flexibility to match its specific investments in use of recycled materials with its customers’ variable goals.

Desai pointed out that PCR cannot be incorporated into packaging overnight – it takes investment, infrastructure, testing, and more to incorporate PCR, especially in food grade applications. Graham’s customers have different goals and different willingness to pay for recycled materials, especially as new regulatory requirements are being put in place, so mass balance will enable Graham to meet those requirements while efficiently managing its inventory and capital investments.  Desai sees mass balance as key to advancing the use of recycled materials: “We now have EPR as an instrument to drive investment in recycling [collection and sortation]  infrastructure. I truly believe that we need mass balance to increase the amount of PCR in products.”

Meanwhile, as a distributor of packaging, Veritiv was excited about the ability to create a pipeline for recycled content without becoming certified directly through the RMS. When Issa first heard about ARCs, the new environmental commodity created by the RMS to support investments in recycling, she thought the idea was brilliant. “For me it was very easy to buy into the concept, because I had in mind that the end goal is to invest in infrastructure for more recycled content.”  The bigger challenge was to explain the new concept to stakeholders within her company.  Two of the main concerns they expressed were: how can you be sure that investments in ARCs are truly investments in recycling infrastructure, and how can you be sure that claims based on ARCs aren’t greenwashing? For Issa and her colleagues, the RMS was able to provide that assurance. Since every ARC is tied to materials reprocessed by a specific audited project that must meet additional criteria, Veritiv was assured that their investment was credible.

The RMS also gives guidelines on marketing claims so that ARC purchasers like Veritiv can avoid greenwashing. Ultimately, the holy grail is to have more post-consumer recycled plastic, and Issa sees investment in ARCs as a step on the path to get there: “This is not about offsetting or buying our way out. We need recycled content, there is not enough. This is a step forward to doing that.”

Learn how ARC’s are being utilized in practice and how they are creating additional value for companies across the packaging and recycling supply chain. 

These companies’ experiences highlight the importance of the flexibility and adaptability of the RMS, even as it provides robust assurance of the validity of claims. By offering different pathways, RMS can assure validity of both post-consumer and post-industrial content claims, give companies the flexibility to meet their goals through mass balance accounting, and facilitate scalable investments in new recycling infrastructure through ARC trading. With the new resources that are now available to participants, these opportunities will become accessible to even more companies that are working to advance the use of recycled materials.

New Resources for Companies Considering Certification

Dr. Laura Thompson kicked off the first RMS session by introducing the RMS participant toolkit developed with the support of McDonald’s. The session helped companies considering certification think through the process, answering questions like:

  • What key internal stakeholders need to be involved in the certification process?
  • How might a company align their certification approach with their strategy?
  • How should a company define the intended scope of their certificate, including covered sites, products, and types of claims?
  • How can the scope of a certificate evolve and grow over time as companies and their supply chain partners make progress on their recycled material goals?

Thompson’s session also touched on some less obvious certification opportunities such as the ability to certify post-industrial scrap (and potentially track any post-consumer content that may be present) and use mass balance for all types of recycling – not just chemical – offering flexibility and simpler inventory management.

Beyond the toolkit, the RMS team has other resources for current and prospective participants, including one-page brochures suitable for sales trading and educating customers on the RMS and a brief video on the often-confusing topic of mass balance allocation.