Tag: how2recycle

How Will Policy Change Labeling? Updates on Refreshing the How2Recycle Label

How2Recycle labels against pink background.

How Will Policy Change Labeling? Updates on Refreshing the How2Recycle Label

Back in 2008, members of our sister project at the Sustainable Packaging Coalition (SPC) got together to solve a problem: How do we create a packaging label that consistently, clearly, and effectively communicates disposal instructions to consumers? 

Today, How2Recycle has flourished into its own labeling program with more than 525 brand and retailer members and more than 200 manufacturing members. Of course, a big part of the power of the label is its widespread adoption in the U.S. and Canada. More members means more on-pack labels—and, critically, more recognizable instructions for consumers. From packaging on Yoplait containers to REI products, every glance at a How2Recycle label can help reinforce the signal that: Hey, you’re looking at disposal instructions

And while the How2Recycle label has provided labels for hundreds of thousands of packages thus far, right now we’re at the middle of a crossroads. The recyclability landscape is changing. States are adopting EPR legislation across the country. And California’s SB 343 is redefining the laws around labeling. 

To meet the moment, the How2Recycle team is going back to our roots. We’re working with our partners at SPC’s Packaging Design Collaborative to solve a new problem: 

Can we refresh the How2Recycle label to not just meet new legislative requirements, but to also increase consumer understanding and advance innovation? 

The Shifting Label Landscape: How Will Policy Change Labeling? 

Historically, the How2Recycle team has used national data to assess recyclability. Whenever we complete a recyclability assessment, we’ve weighed the following factors:

  • Applicable law
  • Access to collection
  • Sortation
  • Technical reprocessability
  • End markets

Our label is one of the most stringent, data-backed labels on the market. We use national-level data to conduct our assessments and consistently update our guidance to ensure we are reflecting the current state of recyclability. We also consult with the U.S. Federal Trade Commission (FTC) to confirm that our labels responsibly communicate to consumers, and are closely following the changes led by Environment and Climate Change Canada (ECCC) to ensure our label continues to comply with guidance at the federal level.

States are raising the bar now and adopting legislation to advance recyclability beyond federal requirements. Several states, California, Colorado, Maine, and Oregon, have adopted EPR legislation, which assigns producers responsibility for products’ end-of-life management. 

California has also adopted SB 343, which restricts the use of the “chasing arrows” on packaging. SB 343 requires that products with the chasing arrows meet two key criteria: 

So, what does this all mean for brands? It means that we’ll need to understand a material’s recyclability in compliance with California’s state standards before applying the chasing arrows to packaging. We’ll need to make sure that labels comply with SB 343 and other state-specific labeling laws for brands with national footprints. 

And it means we’ll need to refresh the How2Recycle label. 

“How2Recycle has always been and needs to be a living program,” GreenBlue Executive Director Paul Nowak said. “We’ve adjusted the program before as new policy and data came forward. This is the next natural step and shows that the founders of How2Recycle built a flexible program that can take us into the future.”

So alongside the SPC Packaging Design Collaborative, we’re working to advance a label that is flexible enough to meet state-specific requirements, makes room for labeling innovation, and still accurately, clearly communicates instructions to consumers.

Refreshing the How2Recycle Label

If you’re not familiar with SPC’s Collaboratives, they’re issue-specific, action-oriented working groups covering everything from policy to compostable packaging. The Packaging Design Collaborative, which comprises experts in branding, on-pack ‘real estate,’ consumer education, and design, is the perfect partner for this project. 

Headed by SPC Packaging Design Collaborative Program Lead Brandi Parker, who brings more than 20 years of experience from the packaging and design industry, the Collaborative has embarked on two phases of research so far toward a refreshed, better label. 

In the first phase, they’ve identified the myriad catalysts for changing the label and developed initial direction and concepts to guide a new label. With experts on consumer packaging design involved, they broke down what catches a person’s eye, what people are likely to read, and, critically, what they’re likely to miss. 

Three UK recycling logos.

We surveyed recycling labels in other regions, like the UK. Photo: London Recycles

In the second phase, the Collaborative took the How2Recycle team’s feedback and consolidated concepts into themes to be researched and tested with consumers. In these and future phases, we’re looking at everything from compliance with California standards to consumer understanding of the slash-through chasing arrows. And we’re not just looking at our own label. We’re also drawing insights from labels across the globe that clearly communicate disposal instructions to consumers. 

Next up for the Collaborative is consumer research and testing. From there, we’ll continue iterating towards a refreshed design for the label that meets the moment. Members of How2Recycle can look out updates about this work in our July Guidelines for Use and at our How2Recycle summit, and expect an announcement in the fall about the new label design.

One of the concepts that the SPC Packaging Design Collaborative is exploring is How2Recycle’s first scannable label. We’re leveraging the consumer brand equity in the How2Recycle label and combining it with a dynamic, QR code label. From there, the QR code connects consumers to audited databases that give them more localized information for disposal. Our first pilot project on a dynamic label is currently running in parallel with the SPC Packaging Design Collaborative work and The Recycling Partnership’s Recycle Check program. 

Looking Ahead: How Can We Design a Recognizable, Future-Proof Label?

“Throughout this process, we’re asking ourselves: If we refresh the chasing arrows, will consumers recognize that our label is the place to look for disposal instructions?” said Karen Hagerman, How2Recycle Director.

“There’s an information hierarchy in design. Chasing arrows aren’t just arrows. They’re a cue to consumers saying: Look here for disposal instructions.” 

So far, our consumer research indicates that 87% of tested consumers found the How2Recycle label helpful. These results speak to the tremendous brand equity in the current How2Recycle label, used by brands from Costco to Estee Lauder. 

Beyond that brand equity though, this moment marks an excellent opportunity to create a label that’s not just recognizable, informative, and innovative—but to create a label that’s future-proof. A label that can meet future changing legislative requirements and consumer needs. Together with some of the best and brightest minds in the packaging and design industry, we’ll keep working toward a dynamic solution while never losing sight of our mission: to get more materials in the recycling bin by taking the guesswork out of recycling.

Learn more about How2Recycle, follow us for label design updates, or get involved with the SPC’s Packaging Design Collaborative.

 

By: MK Moore, Communications, Content & Design Manager, GreenBlue

Reflections on Earth Day: Recycling’s Gaps & Opportunities

A black and blue bin stand in front of trees.

Reflections on Earth Day: Recycling’s Gaps & Opportunities

April 22, 2024

Before the first Earth Day in 1970, the natural environment across the United States seemed to be in tatters. Oil splurged across the shores of Santa Barbara, smog blanketed skies in Los Angeles, and oil-coated rivers caught fire in Ohio. Dennis Hayes, an organizer of the first Earth Day, helped turn those tatters into action, “Earth Day gathered up those strands, and dozens more, and knitted them together in the public consciousness as ‘environmental’ issues.”

In the years that followed, the passage of legislation like the Clean Air and Clean Water acts and the formation of the Environmental Protection Agency marked seismic shifts in our country’s environmental response. Throughout that same decade though, a more mundane shift that would help curb pollution, save energy, and conserve water was underway.

Recycling was picking up steam.

Throughout the 1970s, communities across the country rolled out curbside recycling programs, they built the first MRFs, and importantly, they helped make recycling a mainstream concept.

Today we know the potential that recycling—and other solutions like sustainable design, reuse, and compostable packaging—have on our environment, energy, and water. In the decades since that first Earth Day, the recycling system has seen incredible innovations, from large-scale curbside recycling programs to robotic sorting machines. But we’ve also seen the recycling system struggle to keep pace with production.

I’m sure you’ve heard statistics like this: Only 9% of plastics are recycled, or maybe that plastic waste makes up 80% of marine pollution. These widely dispersed statistics are emblematic of the public conversation about recycling—a conversation that’s focused on the system’s shortcomings. Take the perspective of Wasteland author, Oliver Franklin-Wallis:

“Recycling has been called a myth and beyond fixing as we’ve learned that recyclables are being shipped overseas and dumped (true), are leaching toxic chemicals and microplastics (true) and are being used by Big Oil to mislead consumers about the problems with plastics.”

Franklin-Wallis has traveled the world to investigate and research the global waste system, meeting with waste pickers and MRF administrators alike. In his research, he found what rang true to the first Earth Day organizers: We have one Earth, it’s connected, and consequently, the waste we produce doesn’t exist in a vacuum, it has repercussions that ring around the world.

In his latest piece for The New York Times, Franklin-Wallis helps characterize the public sentiment around recycling, but, more vitally, he outlines the solutions toward fixing a system with incredible potential.

So this Earth Day, the How2Recycle team is breaking down Franklin-Wallis’ insights and following his lead. We’re looking clear-eyed at the gaps in the recycling system to inform concrete solutions. In doing so, we hope that by next Earth Day, recycling—at least our corner of the system—will reap better outcomes for our environment.

The Gaps in Recycling

In his opinion-editorial, Franklin-Wallis points out several prominent flaws in the recycling system.

For starters, one of the most often discussed flaws in the recycling system is that plastics are recycled much less frequently than the public assumes. Franklin-Wallis cites statistics showing that the PET recycling rate is about 30%. He points to other plastics that fare worse, with recycling rates below 10%. To consumers, the takeaway from these statistics could be that 70%-90% of the waste they recycle isn’t getting recycled. The reality is that these gaps exist largely because 79% of recyclable waste never even enters the system—which needs to be solved. And the effect is that trust in the system is eroded.

Franklin-Wallis also sheds light on the fact that, in the United States, landfilling is quite prominent compared to other major economies: “According to the E.P.A., America’s national recycling rate, just 32 percent, is lower than Britain’s 44 percent, Germany’s 48 percent and South Korea’s 58 percent.” Together, a low recycling rate and a high landfill rate create a sort of one-two punch, undermining trust in the system.

However, what might be most visible to the public is the pervasive downstream effects of low recycling rates paired with high landfill rates. In his book, Wasteland: The Secret World of Waste and the Urgent Search for a Cleaner Future, Franklin-Wallis points out that, with time, landfills pose greater environmental threats, “Over time, they erode, until inevitably they spill their contents.” The combination of low recycling rates, high landfill rates, and the addition of any polluted waste, paves the way for marine waste and microplastic pollution, both of which garner significant attention.

Taken together, Franklin-Wallis creates a clear narrative throughline: The recycling system is “broken,” the alternative (landfilling) is dangerous, and the consequences to our health and our environment are pervasive.

He identifies the gaps in the system but looks to the past to inspire improvement rather than abandoning recycling: “Yes, recycling is broken, but abandon it too soon, and we risk going back to the system of decades past, in which we dumped and burned our garbage without care…”

And so, we turn to the promise of an improved recycling system.

The Promise of an Improved Recycling System

Recycling has untapped—or perhaps less noted—potential. From an economic point of view, as Franklin-Wallis points out that more recycling means more jobs: Recycling creates as many as 50 jobs for every one created by sending waste to landfills.

Of course, from an environmental perspective, recycling has incredible benefits. When we recycle instead of landfill, we can reduce landfills’ methane emissions. Franklin-Wallis points to improved energy efficiency and water conservation as well, with steel recycling saving 72% of the energy and 40% of water it would take to produce new steel.

So, how can we meet that potential?

In his editorial, Franklin-Wallis proposes several solutions for improving the recycling system, including:

  • Government intervention
  • Responsible design from companies
  • Transparency around recycling rates
  • Clear labeling

Labeling is where we come in. Clear labeling leads to clear decisions. Our research shows that 87% of consumer participants found the How2Recycle label to be helpful for informing their disposal action.

Of course, we also hope that this clarity—understanding what you can and can’t recycle—does more than inform one person’s disposal decision. Clear labeling can increase consumers’ participation in the recycling system, and directly impact broader recycling rates. Plus, at a deeper level, we want consumers to feel empowered in their informed decision-making so that we can help to restore trust in the recycling system’s potential to improve environmental outcomes.

Our labels help to demystify the recycling process for consumers, but our work doesn’t start—or end—there. The team at How2Recycle helps members improve packaging design and the quality of recycled materials. We also conduct rigorous recyclability assessments and consumer research to ensure that our labeling is both accurate and actionable.

From the moment a piece of packaging crosses our desks for assessment to the time of disposal for a product, we’re working to make sure that we capitalize on the potential in the recycling system.

Still, our work isn’t over. We’re proud of the progress we’ve made so far as an organization, but we won’t ignore the problems still looming in the recycling system. That’s why, this Earth Day, we’re looking at the problems directly that expert Oliver Franklin-Wallis outlined, and we’re promising to continue working toward solutions—like improved packaging design, on-pack labels, and consumer education tools—alongside our members to address these problems and drive better environmental outcomes.

Learn more about our work to drive responsible recycling and design or become a member to help your organization reach your recyclability potential.

 

By MK Moore, Communications, Content & Design Manager

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 announces new criteria for assessing material health in recyclability

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.

REPORT: The Future of Store Drop-Off Recyclability

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.

Contents

  • What is Store Drop-Off?

  • The recyclability challenge for flexible packaging

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

  • Design and phases of the study

  • Key findings on the Store Drop-Off stream

  • Key findings on PE film innovations

  • What did How2Recycle learn about the test protocol design?

  • Key takeaways

  • Why did How2Recycle adopt the APR Critical Guidance protocol?

  • What does this mean for How2Recycle members?

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.

Why the “recycling numbers” don’t mean quite what you think they mean

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.

We’re talking about the numbers you sometimes, but not always, see on rigid plastic packaging. Incidentally, these numbers are not required on non-rigid plastic (such as bags, wraps or films), which can further add to confusion. As a side point, never put plastic bags or film in your curbside recycling bin, unless you live in one of the rare cities that accepts bags curbside. Take items with the Store Drop-off label to the store for drop-off instead.

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 How2Recycle Guide to Future Recyclability

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.

Contents of this Future Guide

  • ‘Core’ versus ‘recyclability-challenged’ packaging explained

  • Assessment criteria to achieve future recyclability

  • Considerations for far future recyclability

  • Considerations for substantiation data

  • Recommendations for strategizing future recyclability

  • Steps for How2Recycle members to achieve future recyclability

This Future Guide builds on the How2Recycle Guide to Recyclability, available here. If you haven’t read it yet, we suggest you start there first.

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

Some packages aren’t recyclable today (See the How2Recycle Guide to Recyclability for a definition of what recyclable means). Some may be recyclable today, but there is little or no data available to substantiate a recyclability claim for that item. To help guide conversation around these concepts, How2Recycle has developed terminology to help distinguish between the classic packaging types that are widely recyclable today from those packaging types that the recycling system is not currently designed to specifically capture or for which data does not yet exist to substantiate a claim: core packaging vs. recyclability-challenged packaging.

Core packages are well suited to recycling today because the existing recycling system was developed specifically to accommodate these traditional packages. They are not challenged in collection, sortation, reprocessing, or end markets. There is no doubt about whether these items are collected at scale, sorted correctly in a Material Recovery Facility (MRF)* into a high-value bale, and enjoy strong demand from recyclers to be manufactured into another item. A significant amount of data exists to easily substantiate Widely Recyclable claims for these items.

Examples of current core packaging:

    • Corrugated boxes (aka ‘cardboard’ boxes)
    • Uncoated or clay coated paperboard without direct food contact (like cereal boxes)
    • Steel cans (like soup cans)
    • Aluminum cans (like beverage cans)
    • Transparent clear, transparent blue or transparent green PET bottles (like beverage bottles)
    • HDPE bottles (like laundry detergent)

*A fair amount of core packages are collected and recycled through a source-separated system (like bottle deposit collection, source-separated drop-offs, and dual stream curbside collection), and so never see a MRF.

In contrast, recyclability-challenged (‘challenged’) packages are those that either face a more challenging journey to actually being recycled, or those that face a more challenging journey to receive a recyclability claim due to lack of sufficient substantiation data.

Examples of current recyclability-challenged packaging:

    • Tubes (toothpaste, lotion)
    • Hot paper cups (coffee)
    • Cold paper cups (fountain drink)
    • Ice cream paper packaging
    • Fiber foodservice packaging with direct food contact
    • Alternative fiber packaging (e.g. bagasse, bamboo)
    • Coated flexible papers
    • Certain polyethylene (PE) film innovations
    • Composite metal-bottom canisters
    • Expanded polyethylene (EPE) protective packaging
    • Multimaterial flexible packaging

There are two main types of recyclability-challenged packages: infrastructure-challenged packages, and data-challenged packages.

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 “++”:

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.

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

In the How2Recycle Guide to Recyclability, How2Recycle explains how scientifically credible data is required to support four assessment criteria in order to call something recyclable:

  • Collection
  • Sortation
  • Reprocessing
  • End markets

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

For some challenged packaging formats, recyclability at scale may be so far off into the future (5+ years) that the prior considerations are too specific. For those packages, like multimaterial flexible packaging, ‘far future recyclability’ should be considered very broadly.

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.

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.

Considerations for substantiation data

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.

Recommendations for strategizing future recyclability

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.

You may be thinking, “but don’t the recyclers want my packaging today?”  
Understand that recyclers probably don’t need a challenged package, or at least they don’t feel that way today—otherwise it’d already have a Widely Recyclable label. The package “not being worth it” to recyclers may be due to a combination of factors such as its very low volume in the stream, an undesirable yield loss, or a lack of data to convince recyclers of otherwise.

One specific package may constitute a very, very small amount of a recycler’s potential feedstock, and so the recycler may not perceive it as a priority worth dedicating time or effort towards. For example, a recycled paper mill might use 10% mixed paper (classic paper packaging like cereal boxes) and 90% corrugated boxes, so a company arguing that a special paper soap wrapper (with a new type of coating there is no reprocessing data about) should be considered recyclable because it is X tons of fiber per year is not always persuasive. That’s because at best it’s a fraction of a fraction of a single percent of what a recycler receives and so not as significant as it may seem to the company that produces the package.

The notion of ‘yield’ in recycling is very important—packages that aren’t designed for recyclability increase yield loss for recyclers, negatively impacting their bottom line. Yield loss comes from things that simply don’t belong in the recycling stream, like food waste or nonrecyclable materials, but also comes from packaging attributes like coatings, attachments, or fillers that do not provide any value, or even at times may proactively reduce the value of the recycled material. Recyclers pay to have the contamination come into the facility (so they can remove it from the saleable recycled material via reprocessing) and then pay again to have it landfilled. Recycled paper mills can spend millions to install a single piece of equipment to increase their yield or decrease their contamination by a mere 1%. The more feedstock that a recycler receives that does not give them a decent return on the investment of buying that material is better worth leaving out of the stream.

Some companies believe that even though their packaging design may create some positive yield for the recyclers but that same package is also known to create a certain level of contamination, it should still be considered recyclable because the rest of the stream would “dilute” it. While some level of contamination is an unavoidable reality that recyclers already deal with, How2Recycle does not find dilution arguments compelling. Many packaging formats have the potential to substantially increase in volume over time (sometimes in difficult-to-predict ways), especially if you observe changes over the last decade in what we refer to as ‘the evolving ton.’ So, even if it might be diluted now, that can’t be guaranteed into the future; what adverse impacts might that cause the recycling stream?

Approaching the recycling system as if a company has a gift for it (“size of the prize!”) is sometimes inaccurate (but not always) and could have the inadvertent effect of conveying to the recycling community that the company lacks an understanding of the economics of recycling. In order for something to be recyclable, someone needs to want to buy it… and so far no one has been biting. Or maybe they would bite, but there is a lack of persuasive data to make that case.

Whose job is this to figure it all out anyway?

Companies should be prepared to roll up their sleeves if they have a challenged package they want to be considered more recyclable. While How2Recycle works hard to continually expand and improve its understanding of recyclability, spending significant amounts of resources on building the case for certain challenged packages is outside the scope of our work. How2Recycle invests in data to understand the recyclability of certain packaging formats better, but the program has a select amount of these projects each year and How2Recycle does not prioritize challenged materials as a general matter. This means that while How2Recycle might study and acquire data on a challenged package someday, it is not appropriate for us to do so at this time. Note that if other organizations or consultants want to lead or do this work on a member’s behalf, they are not the authority of the standard or decision-making process for How2Recycle. How2Recycle appreciates being made aware of work being done and is happy to provide members feedback on a proposed plan for future recyclability but will not lead this work for members’ behalf and How2Recycle will never delegate its decision-making to another organization.

Managing expectations
The journey to future recyclability can be long and complicated. From How2Recycle’s experience, one should be prepared to:

  • Expect long timelines. Although some companies are focused on how far away from commercialization they are, or how far out their artwork deadline is, these considerations cannot play a role in the determination of recyclability at How2Recycle. How2Recycle understands that brands are used to moving quickly in the consumer packaged goods (CPG) space, but it takes time to change the recycling system, or to collect and interpret meaningful data. Even if a member has built a compelling case for something to be called recyclable, it still takes time for that case to be interpreted and discussed within the recycling community and/or the How2Recycle program, depending on the circumstances. If a company has challenged packaging, consider the journey to recyclability to be more likely years, not months or weeks.
  • Anticipate moving targets. As much as How2Recycle would like to say “this is the exact checklist” and not adjust it so that businesses can have that certainty, How2Recycle just legally isn’t able to provide that guarantee. How2Recycle does not want members relying on a snapshot of the recycling system in time when in reality it is highly dynamic and changing. Moreover, How2Recycle is constantly learning and improving its understanding of recyclability and thus becomes more sophisticated over time and may grow to expect more from members as our industry evolves. That said, How2Recycle knows that companies are investing significant time and resources into new packaging designs and infrastructure investments, and thus want to provide some idea of the journey.
  • Be prepared to invest. Companies may need to invest in (a) data, (b) infrastructure, or (c) both. This can be anywhere from a few hundred dollars for a simple screening lab test to millions of dollars to fund on-the-ground end market development in multiple geographic regions. There is no one-size-fits-all.
  • Companies will hear conflicting points of view about their package. Once members start investigating a package’s recyclability, without question there will be opposing opinions on it. If there was consensus about this package, it wouldn’t be considered challenged packaging. Recyclers don’t complain about steel soup cans—those are core items and are not under dispute. If a member comes to How2Recycle and says a MRF in a city told the member the package is recyclable, that’s great, but not surprising. The issue is proving it’s recyclable at scale across the country, in a majority of the instances. This is the task ahead.
  • You may not get the result you desire. There is risk that members will go down the road and uncover unflattering truths or difficult roadblocks, or the recycling system may change. This is an unavoidable risk in the journey to recyclability.

Tips to expedite the journey to recyclable

  • Consider banding together with your peers to build a stronger movement together. This can manifest in two ways: first, consider working directly with competitors, so companies aren’t doing duplicative work. How2Recycle has observed first hand how competition-obsession and secretive postures prevent progress because if the two competitors had been talking to each other, certain pitfalls or expenditures could have been avoided. Second, consider joining forces with companies using similar, but different, packaging formats. How2Recycle sees converters and brands of hot paper cups fight to get their cups called recyclable, but cold paper cups face a similar plight, as do fiber ice cream containers. They are all very similar—paper packages with different coatings and similar food contamination concerns. Wouldn’t it be easier if those three groups worked collaboratively? Sometimes there are political concerns—”oh, we don’t want them in this, they are food service, we are grocery”—but if a company goes solo because of this, How2Recycle cautions that waste could be created or potential limited.
  • Challenged packaging needs leaders. Within these loose collectives, or groups with a shared interest, it’s possible that nothing may get done if one or two companies or organizations don’t rise to be the leader(s). Consider leadership. See the later section about models.
  • Be strategic about who takes on this work inside your organization. Who works on this journey within a company can make a difference. While it’s by no means a requirement, because of their analytical skill set, attention to detail and “no until yes” temperament, How2Recycle recommends legal teams get involved with this project—it’ll possibly save some headaches. How2Recycle has observed that others in the company who work closely with specific packages may be so tied up in a specific outcome that they may lack the objectivity required to endure the journey to recyclability and may overlook critical obstacles or considerations. However, they may be the best individuals to navigate complex technical considerations like reprocessability and dense lab results.
  • You probably can’t buy your way out of this—unless you go really, really big. It all depends on the situation, but in many cases, throwing a few thousand dollars at the issue (like to get a lab test completed) may be insufficient. Millions or billions of dollars (in some but not all cases) could potentially be required to impact a package’s recyclability at scale in the US and/or Canada. In most cases, actual work needs to be done like installing new recycling equipment at scale, influencing attitudes or recycler behavior, building end markets city by city, or creating an entirely new bale specification (but these aren’t the only ways). Investment at scale is almost always required if companies want change.

Member expectations: commonly encountered challenges

  • Member is only focused on positive aspects of the recyclability story. Sometimes a member may only acknowledge the optimistic possibilities of a package getting recycled, and disregard or downplay how the package is challenged. This slows down the process because How2Recycle has to tease those challenges out over a longer period of time and play the role of rebutting or explaining to the member why their assessments are overly optimistic. In other words, confronting the realities of a package’s challenges will expedite potential success.
  • Misunderstanding the mission of How2Recycle. While How2Recycle understands that there are commercial interests in play in getting a positive recyclable claim for a package, How2Recycle’s interest is only the truth of whether something is recyclable. No individual member funds a substantial portion of the program, and How2Recycle’s low, flat annual fee structure and diverse membership base enables the program to remain independent. Ultimately, we are communicators, and How2Recycle’s goal is to provide the general public with accurate recyclability labeling. Note that members do not, have never, and will never choose their own How2Recycle label.
  • Member is not open to outcomes or strategies not previously considered. A member may be so dead set on getting a specific outcome or following a specific strategy that other opportunities or alternative plans for future recyclability along the way could be missed. Flexibility can help companies adapt to shifting realities and sometimes certain desired outcomes are not possible at this time.
  • Not all at your company on the same page. In some cases there is a lack of information sharing that causes confusion and duplicative actions within a company, and that has an impact on the success of your efforts. But How2Recycle has also witnessed profound disconnects on the recyclability of a package from different people in the same company. If a packaging converter company also owns paper mills, How2Recycle cannot only listen to the converter side of the business and disregard the concerns of the recycling side of the business. If one ice cream brand within a company isn’t talking to the other ice cream brands in the company, efforts can be duplicative and confusing. How2Recycle encourages everyone to get on the same page for the best possible outcomes.

Previous models for achieving recyclability
There are a variety of successful approaches How2Recycle has observed that result in making packaging more recyclable. A forthcoming report from ASTRX will explore this in greater detail to provide companies with inspiration from recent successful models.

Steps for members to achieve future recyclability

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.

About us

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.

 

 

The How2Recycle Guide to Recyclability

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.

Contents of this Guide

  • Why the How2Recycle program exists and how it works

  • What does ‘recyclable’ mean?

  • What the law says about recyclability claims

  • How does How2Recycle assess recyclability for each package under that definition?

  • Currently under study for How2Recycle

  • About us

Why the How2Recycle program exists and how it works

How2Recycle was created because the Sustainable Packaging Coalition (SPC), by way of its parent environmental 501(c)(3) nonprofit GreenBlue, identified the critical need for an accurate, consistent on-package labeling system. When SPC initially identified this need, recyclability labeling was too often absent—or when it was present, greenwashing was common. There was no impartial organization that synthesized and interpreted the divergent and diffuse data about recyclability across all materials. Additionally, there was no pragmatic recovery communication tool for the packaging industry to voluntarily leverage as a group.

When How2Recycle launched in 2012, many in the recycling and packaging industries were skeptical that brands would voluntarily label their packaging in a standardized way along with their competitors, including ‘giving up precious on-pack real estate’ and admitting when their packaging wasn’t recyclable.

Years later the How2Recycle movement proves those status quo adherents wrong. While labeling packaging for recyclability certainly won’t solve all our problems in how we use, value and manage materials in society, telling people how to actually recycle is frankly the least we can do. How2Recycle is thrilled that so many companies share this belief and together we can empower people to recycle more accurately.

How membership and the label request process works
The way membership works is brandowners—or in other words, consumer packaged goods companies, retailers or quick service restaurants—become members of How2Recycle for a modest annual flat fee. Then, they place the How2Recycle label on all, or a selection of their brands’ packaging—it’s up to them which packages they label. Every package that features a How2Recycle label undergoes an individualized recyclability assessment based on detailed packaging specifications that the company sends How2Recycle via its Member Platform. How2Recycle encourages its members to use How2Recycle labels on all their packaging or as many as possible, and to place the labels in the most prominent position and size on the packaging they are able.

There are over 330 brandowners and retailers representing over 2,600 brands in the How2Recycle program, and an additional 100 packaging producer (‘converter’) and material manufacturer members. Given this breadth of membership, the How2Recycle team has touchpoints with more than 4,000 packaging or sustainability professionals per month. How2Recycle is a movement of many people working together towards a common goal of helping drawing attention to and capturing the value of materials in our world. There is still plenty more hard work ahead for How2Recycle members, present and future, to get the How2Recycle label on the majority of all packaging in the marketplace, and to move towards all recyclable packaging.

How2Recycle enables unprecedented feedback to brands about packaging recyclability
How2Recycle is more than just a label. It can serve as a mirror, showing brands how recyclable their packaging really is. Sometimes it surprises them. Members can embrace the insights the label generates, and use the label as a conversation piece with R&D; teams, procurement teams, or suppliers—so they can explain to them where they are with the recyclability of their packaging, and where they want to go.

It is important for How2Recycle to provide brands effective feedback on the recyclability of their packaging so they can drive design improvements. For this reason, How2Recycle developed the first-of-its-kind platform so that our members can track, measure and improve the recyclability of their entire packaging portfolio: the How2Recycle Member Platform.

When each package receives a custom How2Recycle label on the Platform, the package is assigned one of three categories about the overall recyclability of the design (you can read more here). Additionally, specific practical recommendations for design improvement are issued. How2Recycle has issued over 150,000 specific recommendations for packaging design improvement to its members since late 2017. The Platform also allows brands to get feedback about new package designs to assess recyclability before they are launched. These recommendations have led to over 2,200 packaging designs specifically changing to become more recyclable as a direct result of How2Recycle.

How How2Recycle fits into the bigger picture
Recycling is complex. It’s a sometimes volatile system ultimately driven by global commodities markets, and is an interconnected but independent linkage of consumers, communities, material recovery facilities, reclaimers, and buyers of recycled materials. Recycling still has big problems that need solving, like increasing the quantity of valuable materials getting into the recycling cart, reducing contamination from nonrecyclable packaging that does not belong there, and the economic disparities between virgin and recycled material pricing.

For these reasons, what the recycling industry itself will look like in the long term will be hard to predict. We may see big changes to logistics, infrastructure and waste management in the Fourth Industrial Revolution; recycling could play a huge role in the resilience of society as we face greater material scarcity and climate volatility, but we need to invest in better technology and seriously address issues in market demand to face those challenges.

That said, How2Recycle’s contributions of transparent labeling and influencing package design are only a couple pieces of the pie to improve recycling. But they are critical pieces. How2Recycle’s Consumer Survey Report shows that 61% of people may be changing their recycling behavior as a direct result of How2Recycle.

Still, packaging being recyclable isn’t necessarily “enough.” Companies should also look to minimize environmental impacts at every point in the package’s life cycle, including sourcing packaging material sustainably, optimizing package design to use the least amount of materials to protect the product, and should build and invest in initiatives to grow and strengthen the recycling system.

We don’t want people to think that recycling alleviates all their consumption guilt. We should all consume less. Still, packaging protects products that have to be moved to be sold. In the future, it will be wonderful if we have robust reuse or novel delivery systems to rethink the entire product-packaging system. But we’re not there yet. So in the meantime, packaging is a reality of our daily lives—and How2Recycle is influencing companies to make their packaging more recyclable, and believes in the power of labeling for recyclability so people know what to do.

What does ‘recyclable’ mean?

The answer is often more complex than what meets the eye. Recyclability is not always black and white—important nuance and context makes this question surprisingly relative, depending on all the circumstances.

Packaging is recyclable if it can be collected, sorted, reprocessed, and ultimately reused in manufacturing or making another item.

What that means is that 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. 

What the law says about recyclability claims

Note that this is not legal advice.

In the United States, How2Recycle is designed to comply with the Federal Trade Commission’s Guides for the Use of Environmental Marketing Claims, aka ‘the Green Guides’ (Code of Federal Regulations, Title 16 Part 260) and Section 5 of the FTC Act, 15 U.S.C. 45. The FTC Green Guides state:

“A product or package should not be marketed as recyclable unless it can be collectedseparated, or otherwise recovered from the waste stream through an established recycling program for reuse or use in manufacturing or assembling another item.”

Federal Trade Commission’s Green Guides § 260.12 (Guides for the Use of Environmental Marketing Claims, pursuant to Code of Federal Regulations, Title 16 Part 260). Emphasis added.

Likewise, in Canada, How2Recycle is designed to comply with the Competition Bureau Canada’s Environmental Claims: A Guide for Industry and Advertisers, aka ‘Enforcement Guidelines’ and the Consumer Packaging and Labeling Act. The Enforcement Guidelines similarly state:

[Recyclable is a term that is] “characteristic of a product, packaging or associated component that can be diverted from the waste stream through available processes and programmes and can be collectedprocessed and returned to use in the form of raw materials or products. It is not enough to confirm that there are municipal or industry collection systems where the product is sold in order to make a claim of “recyclable” — there must also be facilities to process the collected materials and reuse them as an input to another product that can be marketed and used.” Id. at 10.7.1. Emphasis added.

There are additional rules around when qualifiers are needed for items that are less recyclable.

We interpret the American and Canadian definitions of recyclability to be essentially the same with the one exception that the American guidance asks for qualifiers on recyclability (which our Check Locally label is designed to address) if fewer than 60% of Americans can recycle it where they live through curbside or drop-off programs. This is in contrast to the Canadian guidance that asks for qualifiers if fewer than 50% of Canadians can recycle that item (sortation, reprocessing, and end markets considerations notwithstanding, for both countries).

How2Recycle’s view of recyclability is directly based on these definitions.

As always, we remind our members to read and know the legal guidance in their country in full.

In addition, there has to be data to substantiate recyclability claims. Specifically, FTC says:

“In the context of environmental marketing claims, a reasonable basis often requires competent and reliable scientific evidence. Such 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, when considered in light of the entire body of relevant and reliable scientific evidence, to substantiate that each of the marketing claims is true.” Id at 260.2.

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

More on data substantiation can be found in the How2Recycle Guide to Future Recyclability.

How does How2Recycle’s definition of recyclability compare to other definitions of recyclability?
We consider How2Recycle’s definition aligned with other organizations’ definitions, like APR and ISO, even if word choice differs—the meaning and spirit are the same. The Ellen MacArthur Foundation’s definition of recyclability under the New Plastics Economy does not conflict with the How2Recycle definition of recyclability at all, but it does add an additional requirement of recycling rate on top. In other words, the How2Recycle definition is in harmony with the EMF definition but the EMF definition goes a step further than How2Recycle by saying in addition the item being recyclable, it also has to be that a certain percentage of the material produced is ultimately recycled as a result of individuals’ ability or willingness to put in the recycling bin.

We believe the real space where the rubber hits the road is interpreting recyclability on a package by package basis at a national level. This is How2Recycle’s (and our friends at The On-Pack Recycling Label (OPRL)’s (UK) and the Australasian Recycling Label’s) specialty—and where the most interesting and difficult questions arise. Making sweeping, broad statements about what is recyclable packaging is easy. Assessing a specific package against those statements, with nuance and complexity after examining the actual packaging specifications and how it fits into the evolving, diverse recycling system in the area where those products are distributed? Much more difficult. But this is our bread and butter.

How does How2Recycle assess recyclability for each package?

In a perfect world, packaging design would be standardized across brands and product categories so that consumers could intuitively or easily know how to recycle everything based on a couple basic rules; unfortunately, this is not the case. Two packages that look the same to the average person can differ in terms of recyclability for a variety of reasons (such as moisture or oxygen barrier needs that differ by product, or aesthetic choices marketers make). Packaging design is extremely diverse and complex: there are over 3,200 unique How2Recycle labels in the program’s library. The How2Recycle label cuts through confusion of lookalike packages to help people know exactly what to recycle, and how.

How2Recycle follows this framework for defining and assessing recyclability for over 200 products’ packaging per day:

Based on these considerations, each main packaging component can be assigned one of our four recyclability categories:

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

How2Recycle continuously engages in new research to deepen its understanding of recyclability. These current research projects will continue to support How2Recycle decisionmaking:

  • Research on end markets for certain materials
  • 2D/3D sortation in MRFs per future sortation potential test protocol by APR

Complex issues in recyclability flagged by How2Recycle for future consideration

How2Recycle may consider these complex issues in the future:

  • How and to what extent robotics and AI in recycling impact successful sortation of specific package types (How2Recycle will seek to standardize analysis when these technologies approach scale in North America)
  • Whether the Check Locally thresholds should be adjusted for practical reasons related to market volatility
  • Whether there should be a specific threshold for yield loss to disqualify specific packages from receiving a positive recyclability claim
  • How and to what extent the dramatic, recent push for innovation in fiber packaging for product categories traditionally packaged in plastic will potentially impact or materially change the recycled paper stream. Specifically, as fiber packaging now seeks to accomplish from a performance or aesthetic perspective what plastic historically has been able to do, there will be an explosion of innovations. It’s important for industry to ensure that they are developed with an understanding of how to design for recycling from the start.
  • How to assess recyclability in regards to differing food contamination levels on paper packaging

 

For even more recyclability information, visit our companion resource: 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.

 

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.

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.

How consumers feel about and respond to recycling & How2Recycle: A consumer research summary

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.

How the How2Recycle program interprets inconclusive access to recycling data

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.

How2Recycle announces updated criteria for assessing end markets to determine whether a package is recyclable

A package cannot be considered recyclable if it does not have an end market. In other words, you can’t call something recyclable unless it’s actually getting recycled. How2Recycle has incorporated this concept into its definition of recyclability since the inception of the program in 2012, as directly inspired by Federal Trade Commission guidance:

A product or package should not be marketed as recyclable unless it can be collected, separated, or otherwise recovered from the waste stream through an established recycling program for reuse or use in manufacturing or assembling another itemFederal Trade Commission “Green Guides”, § 260.12 (2012). Emphasis added.

Despite some misconceptions and alternative interpretations of this legal guidance, the Green Guides were truly ahead of their time in 2012 by contemplating this issue of end markets. The How2Recycle program does not call items recyclable if they do not have an end market.

How2Recycle has already made consequential determinations on recyclability because of end markets concerns. For example, How2Recycle downgraded the recyclability of certain plastics in early 2020 based on end market ambiguity. Today, How2Recycle provides greater clarity in this area of recycling that is often misunderstood and rife with nuance and complexity.

For more information on how How2Recycle is designed to comply with Federal Trade Commission and Competition Bureau Canada criteria for recyclability claims, visit How2Recycle’s Guide to Recyclability. To see the prior criteria for end markets for How2Recycle that were in place before this new rule, see the note at the end of this document.

For a summary page of this updated rule, click here.

Assessment criteria to achieve recyclability
As outlined in the Guide to Recyclability, How2Recycle assesses a breadth of information and scientifically credible data related to issue the most appropriate recyclability claim for a specific package. All of the following elements are required to be positively demonstrated in order for How2Recycle to call it recyclable:

  • Collection
  • Sortation
  • Reprocessing
  • End markets

A package cannot be considered recyclable if it does not have an end market. While end markets are listed as the final element of recyclability in the above graphic, they can present challenges throughout the recycling process and are not necessarily sequentially ‘last.’ For How2Recycle’s purposes, end markets usually but not always refers to transactions between Material Recovery Facilities (MRFs) and reprocessors like recycled paper mills and plastic reclaimers. This is because How2Recycle finds those transactions usually the most consequential in determining whether something is actually getting recycled. Still, end market issues can manifest from reprocessor to final end user, or in between collection and the MRF, and so can be understood as an issue that is woven throughout all of recycling.

Accordingly, How2Recycle aims to keep the definition of end markets broad, to mean the stuff actually gets recycled and made into something new again. In practice, this refers to how the value of materials is managed throughout the recycling process, and how that value in turn dictates materials’ fates in recovery.

The How2Recycle program has developed new criteria to assess end markets within the definition of recyclability.

This new rule seeks to bring more meaning and precision to this concept of end markets in a way that (a) increases the accuracy of recyclability claims and (b) also provides feedback to the packaging industry to drive improvements in the recycling system. 

This article will explore why end markets have historically been difficult to measure, what How2Recycle’s new rule outlines, and why this rule was designed this way.

Why ‘end markets’ has been challenging to define historically

End markets is the least-developed and understood element of recyclability in the industry currently. Greater clarity and new definitions are needed to communicate recycled material value in a way that is meaningful, constructive and tangible.

The topic of end markets is essentially about value and scale—which makes some aspect of it always subjective and subject to change, especially given that recycling is a global commodities marketplace with little to no regulation. But all materials in society possess varying values and are traded at varying scales at different times for different reasons. The opportunity at hand is to illuminate how we might think about recycled material value in a way that ensures consumers are not deceived but also helps the packaging industry understand how their package is valued for recycling or not, and why.

The packaging and recycling industries (and to some extent the media and certain governmental bodies) often talk about end markets in a binary fashion: either a package “has an end market” or it “doesn’t have an end market.” But when one seeks to apply this yes/no framework to a complex marketplace with ambiguous and layered information, it can be difficult to make this concept meaningful and can sometimes even be misleading. In reality, end markets for recycled materials exist on a spectrum: some packages have very strong end markets, others have very weak ones, and other packages’ values fall somewhere in the middle or are unclear or unknown. The very strong and very weak end markets are known and unmysterious—it’s the grey area in the middle that could really benefit from some additional structure and clarity. What if a package’s value is declining, but still bought and sold at some scale to be recycled into something new again? What if a package is valuable to some recyclers but not all recyclers? What if a package should reasonably be considered valuable to recyclers but that value has not been demonstrated yet with data? These are complex and consequential questions that demand nuanced and contextual frameworks in order to illuminate the appropriate path forward.

Once we acknowledge that end markets exist on a spectrum and different materials possess different values for different reasons, the question then becomes whether—and how—a material of moderate value can be called recyclable. Differing strength end markets may be appropriate for different types of recyclability claims. For example, a qualified recyclability claim telling the consumer the item is not recycled in all communities need not demonstrate the highest level end markets achievable in the recycling industry.

Another important consideration in end markets is that an overly uniform approach across all materials will not work well. Each material is subject to its own unique market dynamics. These dynamics include many factors such as the customer makeup of a certain recycled material and the performance required for certain applications of it; the most widely adopted technologies for recycling certain materials and what level quality feedstock they can handle; and the way the value of one material relates to the value of other materials within the recycling system. Most dynamics play out within a broad material type such as recycled paper mills (but not always), so it may be difficult or inappropriate to compare recycled paper mills’ end markets to say, polypropylene reclaimers’.

Additionally, change and volatility are inherent in recycling. There will always be longer term changes in what gets recycled and how a material’s value influences that over time. But there are also shorter term changes as well—what gets sold in a specific region at a specific price can change regularly. How might we better manage these changes and market dynamics?

How2Recycle’s updated rule to bring greater clarity to the concept of end markets

How2Recycle has created three potential end market categories for assessing the end market of a specific package. This is important to move away from a binary yes/no framework to a more meaningful spectrum of value. 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. 

In other words, only packages with strong end markets can receive unqualified (Widely Recyclable, Store Drop-Off) recyclability claims.

The definitions of whether a package has strong, moderate, or negligible end markets will be explored in the next section.

How the end market categories are defined

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.

  • 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.
      • Explicitly accepted means specifically called out in text of established bale specifications such as ISRI and/or APR model bale specifications.
      • Bought by recyclers for recycling at scale means transactions for that bale are:
        • Not limited to a subset of eligible recyclers, and
        • Occur at relatively high volumes.
          • In other words, significant capacity for recycling this material exists, and those recyclers are buying the material at significant volumes.
      • For positive value means either the average national price is above $0 or otherwise adequately and intentionally managed by Material Recovery Facilities (MRFs) and/or governmental entities as part of the overall material mix.
      • Reasonable amount of time means at least 2 consecutive years, or
        • 1 year with supporting information demonstrating values very unlikely to decrease in forthcoming year
  • 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.
      • Implicitly accepted means reasonably expected to be included in text and/or intent of established bale specifications such as ISRI and/or APR model bale specifications and known to not cause any bale downgrades at scale if included
        • Known to not cause downgrade at scale if included means the majority of recyclers for that material will not meaningfully reduce the price of a bale or reject a bale if that package is included
      • Bought and sold at some scale means transactions for that bale:
        • May or may not be limited to a subset of eligible recyclers, and
        • Occur at moderate volumes.
          • In other words, at least moderate capacity for recycling this material exists, and those recyclers are buying the material at at least moderate volumes.
      • For positive value means either the average national price is above $0 or otherwise adequately and intentionally managed by Material Recovery Facilities (MRFs) and/or governmental entities as part of the overall material mix
      • Reasonable amount of time means at least 2 consecutive years, or
        • 1 year with supporting information demonstrating values very unlikely to decrease in forthcoming year
  • None or negligible end markets
    • Package is unclear or unknown if accepted, or is implicitly prohibited or explicitly prohibited in the existing relevant 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 but at 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.
      • Unclear or unknown if accepted means it’s unclear or unknown if a package description fits into the text and/or intent of current ISRI or APR model bale specifications or if it’s unclear if it causes bale downgrades at scale if included
      • Implicitly prohibited or explicitly prohibited means it is known to cause or likely to cause appreciable bale downgrades at scale if included
        • Known to cause downgrade at scale if included means the majority of recyclers for that material will reduce the price of a bale or reject a bale if that package is included
      • Not bought and sold at some scale means transactions for that bale may be limited to:
        • A small to very small subset of eligible recyclers, or
        • Low to no volumes.
          • In other words, low capacity for recycling this material exists, or recyclers are buying the material at low volumes, or not at all.
      • For negative value means either the average national price is below $0 and not otherwise adequately and intentionally managed by Material Recovery Facilities (MRFs) and/or governmental entities as part of the overall material mix
      • Reasonable amount of time means at least 2 consecutive years, or
        • 1 year with supporting information demonstrating values very low and/or unlikely to increase in forthcoming year

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).

 

Guiding interpretation principles for this rule

On temporary volatility

Recycling is a commodities marketplace, which means that some level of volatility in end markets is not only normal but expected. How2Recycle does not intend for rules to be construed so narrowly that temporary market disruptions need instill panic, nor any ‘restarting of the clock’ to positively demonstrate the ‘value’ or ‘time’ elements. Any disruptions will be assessed in a common sense way through each material’s esoteric lens of historical patterns, future trajectory indications, and level of severity.

On regional volatility

Similarly, regional disruptions are somewhat normal and expected and will be analyzed in a similar way. How2Recycle looks to the national level in all aspects of recyclability, including end markets. In all recycled commodities, it is not expected for reprocessing capacity to be co-located with collection in the same city, state or even region. Recycled commodities cross interstate and international borders regularly, and whether a region can find a market for a material depends on many context-heavy factors such as fuel costs, available nearby capacity, and business contracts. Placing too much importance on any one geographic region’s end markets could be misleading and not representative of the bigger picture of how recycling works. Some materials are reprocessed in many locations but other materials are reprocessed in more specific locations; some materials travel further than other materials to get recycled. Additionally, if How2Recycle were to render a material less recyclable or not recyclable because of the end market challenges of one region, recycling the item in the rest of the country would be unfairly limited and potentially detrimental to the environment. As a result, How2Recycle will zoom out to American and Canadian data in order to identify meaningful patterns in end markets.

On ‘volumes’

Some aspects of this rule are left intentionally open; for example, what constitutes “significant”, “moderate” or “low” volume could be interpreted differently for different materials in different contexts. How2Recycle does not intend for this to be construed as “significant [in the context of all recycled materials].” This is because a material could have a strong end market, but still only constitute a small portion (by weight or volume) of the overall mix of materials that move through MRFs. Nor should it mean “significant [compared to what it used to be][or significant in the eyes of an entity’s aspirations]” or “significant [compared to how much of that material is generated by society overall].”

While our society has profound issues it needs to aggressively face about how materials are valued and managed, How2Recycle refers to ‘recyclable’ as the ability to put something in the recycling bin and then it will get recycled, as opposed to “X% of this material that is made in society ends up going into the recycling system.” Collection, sortation and reprocessing systems still need to grow and improve to a monumental degree so that more valuable materials can be captured and used again. Since investment in those areas often requires good ‘end markets’ first, hopefully this rule provides industry with some constructive ideas for how they might go about achieving their recovery goals.

On ‘capacity’

If there are recyclers (such as PET reclaimers) who are willing and able to actually recycle a material, and even have the infrastructure to prove it (to prove “reprocessing capacity”)—that does not automatically mean that there is demand at scale. Sometimes there can be structural hurdles for a recycler to actually get the material. For example, maybe there is a bottleneck in collection because too few Americans have good access to recycling—so even though the recycler wants it, they aren’t getting a lot of it. Sortation capacity can limit what gets recycled at scale—if MRFs do not have the physical space or necessary equipment to sort, store and sell a certain material, then that can be an important limiting factor. The rule is intended to only ‘count’ what volumes of material are actually getting to the recycler and getting recycled.

On ‘bought… for recycling’

There may be instances where a recycler such as a recycled paper mill or a reclaimer buys a bale of material, but doesn’t actually intend to recycle all of the materials typically found in that bale. Perhaps the material is intentionally sorted out before being placed in the reprocessing equipment, or habitually removed from the rest of the material during the recycling process. The rule is intended to only ‘count’ the stuff that’s bought that actually gets recycled. Due to the complex dynamics of certain bale specifications and how they are bought and sold, and how that interplays with different recyclers’ processing technologies and market niche, whether a package within a bale will get recycled may be a context-specific assessment and additional information may be required to demonstrate end markets.

On ‘otherwise… managed’ value

This rule intentionally uses the word “value” instead of “price” because price is only one way to assess value. It’s typically the most prominent and important because recycling is a capitalistic marketplace, but there are other dynamics in the recycling system that enable a material to get recycled despite its challenged (and sometimes even negative) dollar value. For example, glass has been traded at a loss in many places for many years, and still gets recycled. Whether or not materials possess value is due to a variety of factors including its role in the overall mix of materials at a MRF and how the MRF manages its profitability relative to contracts with municipalities, tipping fees, sort costs, volumes, and other variables. Additionally, potential future Extended Producer Responsibility regimes or other governmental initiatives could directly influence whether a material is valued, and in turn, recycled.

On what exactly gets run through the formula

This end markets analysis will take place on a package by package basis. How2Recycle will not run a bale spec through the process, but rather a specific package format. For example, How2Recycle will not run the 3-7 bale through the formula, but rather, polypropylene tubs (which are sometimes, but not always, present in the 3-7 bale). More granular packaging specifications such as attachments, barriers or coatings will likely but not always be analyzed in the sortation and reprocessing elements of recyclability separately. There could be some overlap with end markets on these sorts of details and those will be assessed on a case by case basis as needed; focus will be placed on what level of granularity may be meaningful in recyclers’ transactions.

On uncertainty & common sense

In the presence of uncertainty as to how a package should be characterized in terms of end markets, How2Recycle will err on the side of conservative and not issue a claim or issue a qualified claim.

This rule is intended to be applied in a common sense way, where all the relevant and available information will be considered in context. The rule is subject to change and improvement, especially as How2Recycle will apply this rule to divergent and complex sets of facts into the future. Accordingly, exceptions or greater nuance could apply to certain package types under specific compelling or changing circumstances. For more detail on what quality data How2Recycle finds scientifically credible, visit the How2Recycle Guide to Future Recyclability.

Why How2Recycle designed the end market rule in this way

On consumer perception

First and foremost, How2Recycle seeks to prevent consumer deception and greenwashing in the realm of recyclability claims. Given the complexity in the area of end markets and the increased (and sometimes incorrect or misleading) attention given to it, it became critical to make this aspect of recyclability clearer. To that end, How2Recycle sought feedback from the Federal Trade Commission on this updated criteria, and the rule was adjusted as a direct result of that feedback. Additionally, the How2Recycle Advisory Committee provided feedback and their recommendations are reflected in the rule. Future consumer perception testing could influence how this rule is revised in the future.

Lack of recycler information is a barrier to better end markets measurement

One might be tempted to ask, “well can’t you just track exactly how much of each material is getting recycled annually, and make sure that’s equivalent to the exact amount that’s getting collected for recycling annually?” Well, in 2021, no. Recycling is not a super transparent supply chain. There are many barriers to better measurement: there is not a universally adopted and timely mechanism to measure collection and reprocessing on a national scale with a relatively high degree of granularity or accuracy. Recycler confidentiality is a huge part of this: recyclers’ business models make them unwilling and sometimes unable to disclose their customers, volumes traded, bale spec details, locations of sales, and amounts and makeup of residual. Decisionmaking on these factors can be decentralized or only available in inconsistent reporting formats. Some materials are traded through brokers, adding another layer of transactions. Additionally, recyclers are often in competition with one another, making anecdotal information sometimes unreliable; some recyclers have a financial interest in the recycling stream being a certain way, and so may be encouraged to deliver information in a certain way. If recyclers would be willing or able to share a little more information, measurement of end markets could be improved. But the general public and packaging industries would also be well-advised to understand the inherent characteristics and limitations of the recycling marketplace. It’s mostly a private business, even though many consider it, or want it to be, a public utility.

On limitations of how ‘demand’ is measured

Demand is hard to identify and measure because it can be so subjective, anecdotal or context-dependent. What is ‘enough’ demand? How much demand is needed for a new or innovative material before it snowballs and becomes a successfully recycled material? Does the demand need to be actual, or is speculative demand meaningful? ‘Who’ is the arbiter on whether demand exists? One can always find divergent responses to any of those questions. In the presence of imperfect and too little information on market demand, established bale specifications such as ISRI and/or APR model bale specifications appear to be the best available way to assess this today (so long as they are analyzed alongside other elements of end markets: scale, value and time). That said, they are only a partial snapshot of demand. Model bale specs are a signal of demand—a credible and representative group of recyclers has indicated a willingness to trade, and has outlined what that should look like. But, those model bale specs are still just an example of what a real bale spec could look like—recyclers may adjust the specs as needed for their own business. Some bale specs are more mature than others (and thus better understood and defined) and some bale specs are more popularly used by recyclers in real life than others. Observers should note that the development of new model bale specs or adjustment of existing ones can at times be a highly political process, subject to its own set of complex and competing forces and interests.

On limitations of how ‘value’ is measured

For average national pricing information, How2Recycle references recyclingmarkets.net. But like bale specifications, this does not provide a complete or perfectly representative picture of how material value is assessed and managed. Databases like these do not provide mechanisms to understand how certain prices or price changes impact buy/sell behavior, and in what ways. Still, this particular database is a credible independently-operated tool where prices are reported on a weekly basis by consumers of that recycled material (end users/processors) as well as MRFs and haulers. And as explored earlier, there are challenges in assessing value beyond mere pricing of a material in isolation; this is why the end markets rule contains an exception for ‘otherwise intentionally and adequately managed value’.

Why do 1-2 years constitute a reasonable amount of time?

Especially in light of dramatic export restrictions playing out in the last few years, How2Recycle has observed that market volatility does tend to shake out on the years’ timeframe; weekly, monthly or quarterly volatility does not provide a sufficiently zoomed out picture for purposes of recyclability labeling. Not only would it be confusing to consumers if recycling labels changed on a semi annual basis, it is also totally impractical from a brand perspective to adjust artwork on this small a timeframe. At the same time, if the timeframe is too long, there is a risk of potential consumer deception if a material is experiencing a downward trajectory, and more than two years may be an unreasonably long time to wait for an innovative or emergent material to achieve a recyclability claim if it is achieving success. How2Recycle was also inspired by the well-crafted two year language included in Maine House Bill 2104 (2020).

On the elephant in the room: virgin prices

One essential factor that contributes to the value of recycled material and its viability as a manufacturing feedstock into the future is the price of its virgin counterpart. This is hands down one of the most powerful influences on the end markets of recycled material (explored further in Sustainable Packaging Coalition’s Design for Recycled Content Guide) and presents a significant challenge to the circular economy—particularly for plastics. This is a complicated market issue that is beyond the scope of How2Recycle’s current ability to measure or manage in any meaningful way.

Another key factor that impacts material value is landfill tipping fees. In some localities, it is extremely inexpensive to landfill materials, so there is a much greater incentive to not recycle. In contrast, some areas with high tipping fees have much healthier end markets.
While not all of these factors are reflected in the text of the rule, they can provide helpful context to packaging producers who are interested in maintaining the recyclability of their material. Additionally, as the recycling industry evolves and more and better information becomes available, How2Recycle may be able to incorporate some of these elements into future iterations of the end markets rule.

A note of caution for packaging producers

Just because an item is characterized as having strong end markets in order to substantiate a recyclability claim, that does not mean it’s necessarily strong in other important ways. For example, it may not be as strong in the context of whether it will be recycled by society long term, or it may not be as strong as it arguably should or could be. How2Recycle looks at the recycling system of today to issue labels, but many companies’ goals are dependent on the recycling system of the future. Similar to how How2Recycle’s recyclability feedback to brands exceeds the information in the label, companies should not stop learning or improving based on the on-pack label their package receives. Individual companies and trade associations representing certain packaging types should very seriously assess the end markets for their materials and actively develop and fund initiatives to sustain and grow those end markets. Talk is insufficient; action is required. The push to support recycling of a material often must be continuous—if efforts cease, there is risk that the recyclability claim may only be valid for a temporary period of time. Some materials require timely, active support in order for recyclability to be maintained; others may require later intervention if certain conditions come into play. The degree of risk depends on many factors such as history, diversity of recyclers and end markets, or evolving supply. No one should ever assume that just because an item has an unqualified recyclability label that it is “safe” or more or less stable. Two items may both be characterized as having strong end markets, but one could just barely exceed the standard whereas the other may be the most valuable material in the entire recycling system with no real threat of diminished value in the foreseeable future. End markets are serious business (literally), and companies who are serious about recyclability goals should put building them at the front of their strategies.

How2Recycle strives for continuous improvement and learning. Any interested parties are encouraged to provide written feedback on this rule and how it can continue to evolve into the future to how2recycle@greenblue.org.

Companion resources:

How2Recycle Guide to Recyclability

How2Recycle Guide to Future Recyclability

For historical reference, this is How2Recycle’s prior criteria for assessing end markets:

There is no straightforward, easy way to assess end markets across all materials in a standardized way. As a result, How2Recycle currently looks at a variety of considerations based on the circumstances, including but not limited to:

—  Secondary material pricing at recyclingmarkets.net
—  Inclusion of package type in industry model bale specifications such as APR Model Bale SpecsISRI Scrap Specifications Circular
—  Aggregated expert or media reported information regarding landfilling or incineration post-collection
—  Aggregated expert or media reported information regarding buy/sell transactional behavior at the MRF or recycler levels
—  Feedback from individual recyclers or trade associations representing recyclers on value of specific pack types
—  Specific research available or published by consultancies or other organizations regarding end markets for certain materials. 

How2Recycle Recyclability Insights

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.

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.

How2Recycle labels can be applied to any packaging format or material (even non-recyclable packaging, since the program does tell consumers when an item should not go in the recycling bin), so How2Recycle holds data across all material types. Every How2Recycle label calls out the recyclability of each main packaging component, so consumers are empowered to know what to do with the full package. Plastic packaging constitutes a significant portion of the member packaging portfolio. Specifically, 47.9% of the packaging components that have been issued How2Recycle labels are for plastic, whereas 43% are for paper, 2.3% are for metal, and 1.5% are glass (with 5.3% other).

In terms of packaging format, about half of How2Recycle member packaging components are flexible (like bags, wraps, pouches, wrappers, etc):

Looking at only rigid plastic packaging, the types of plastics used by members include polyethylene terephthalate (PET), high-density polyethylene (HDPE), low-density polyethylene (LDPE), polyvinyl chloride (PVC), polypropylene (PP), rigid polystyrene (PS), and other (expanded polystyrene (EPS), multi-material plastics or other). Accordingly, this is the breakdown of types of plastics by number of packaging components (not by weight):

The data in this report only reflects a subset of the packaging portfolio of member companies. That’s because the How2Recycle program is voluntary, so the brands and retailers in the program choose what items feature the How2Recycle label. Many members place the How2Recycle label on all products and have public goals to do so, but not all do. Accordingly, this data is reflective of the packages for which companies have requested How2Recycle labels.

How2Recycle member companies collectively own over 2,600 brands. However, the program estimates that around only 15% of those brands that are licensed to use the How2Recycle label currently do. Typically, companies add the How2Recycle label to packaging whenever it’s “up for redesign,” so this organic growth is unsurprising. Still, this suggests that despite the vast number of packages the label is already on, there is significant room for labeling improvement (and thus packaging design insights) just in the current membership.

Additionally, this data does not take into account the volume of packages in the marketplace. How2Recycle does not hold members’ sales data.

The overall recyclability of the How2Recycle member packaging portfolio

Overall, How2Recycle members are making progress towards recyclability goals but still have a ways to go. As of April 2020, only 18% of the How2Recycle member packaging portfolio is optimally designed for recycling. Optimally designed means the package meets recyclers’ best-in-class criteria for packaging design.

An additional 26% of packaging is classified as recyclable, but needing design improvement. An example would be a clear polyethylene terephthalate (PET) bottle with a pressure sensitive label with detrimental label substrates, adhesives or inks. Together, these categories suggest that 44% of How2Recycle member packaging is currently recyclable.

The remaining 57% of the How2Recycle member packaging portfolio is partially recyclable, or not yet recyclable. These are packages where at least one main packaging component features the Check Locally or Not Yet Recyclable label. You can read a more detailed description of these color categories here.

However, since How2Recycle members voluntarily submit packaging information, and a certain subset of the membership shies away from requesting labels for packaging they believe will receive the Not Yet Recyclable label, the amount of nonrecyclable packaging in the overall How2Recycle member portfolio is likely higher.

How2Recycle’s impact on the recyclability of packaging in North America

How2Recycle has issued over 100,000 recommendations for how brands should make their packaging more recyclable. As a direct result of these recommendations, more than 2,000 packaging designs have changed to become more recyclable. This number is conservative: it comes from members voluntarily checking a box to indicate that a design has changed based on How2Recycle feedback during their process of requesting a new How2Recycle label.

Because of How2Recycle’s broader design guidance to members through other channels like the Guidelines for Use, the Guide to Recyclability, and How2Recycle-related programming through SPC events, and because this number only reflects design changes since 2017 (How2Recycle began in 2012)—How2Recycle’s influence on package design is likely much larger. Even still, with these figures, since 2017, How2Recycle has analyzed over 25,000 package designs, which suggests that How2Recycle is currently directly influencing at least 6% of packaging.

Interesting How2Recycle insight: Based on numbers in the How2Recycle Member Platform, companies seem to use the same package design for approximately 3 products, and approximately 7 package designs ultimately ‘share’ the same How2Recycle label.

Note that these numbers do not include packages that How2Recycle has analyzed that are currently in research & development for potential inclusion in the marketplace. Members submit these designs to How2Recycle to see what recyclability label would apply and if and how the design could become more recyclable. Those insights directly feed into brands’ decision making about whether to use that package design. How2Recycle has analyzed 1,470 of such packages to date.

Design recommendations for How2Recycle member packaging
The average number of design recommendations issued to How2Recycle members per package is 1.5. Many packages are issued more than one recommendation, and others are not issued any recommendations at all (those that receive the dark green optimally recyclable designation).

Looking at the over 100,000 recommendations for design improvement that have been issued to members, two-thirds apply to plastic packaging and most of the remainder applies to paper packaging or all packaging:

The most common recommendation that applies to all package types, regardless of material, is:

Move to all one material so that the consumer does not need to separate components for recycling.

This recommendation (above purple) has been issued around 12,000 times and is a core principle of designing packaging for recyclability, applied to 11% of all member packaging. It is better to use one material in a package design, even if there are multiple components, than using more than one material, because it requires consumers to separate components in order for the package to get recycled properly. Most often this applies to blister packaging, “bag in box” configurations, complex food packaging, toy packaging, and electronics packaging.

Plastic packaging on average receives 1.86 recommendations per package, whereas paper packaging on average receives 1.51 recommendations per package. This suggests that all packaging types have room for improvement when it comes to recyclability. It also could possibly suggest one or all of the following: plastic packaging design may be more complex than for other materials; that the plastic recycling process may be more complex or less forgiving than other materials’ recycling processes, and/or that plastic packaging has more sophisticated industry design guidance available to improve it.

This graph does not visualize the average number of recommendations for glass packaging (0.34) and metal packaging (0.99) because together, those constitute less than 1% of all recommendations issued.

Insights on design recommendations for plastic packaging

These are the most popular design improvement recommendations issued for plastics, in order:

  1. Change to film that qualifies for the Store Drop-Off label 
  2. Change to mono-material from multi-material
  3. (For PET, PE, or PP containers) Ensure label substrate, label adhesive, and label ink meet criteria for Preferred per the APR Design® Guide
  4. (For PET thermoforms) Change to label that meets criteria for Preferred per the APR Design® Guide
  5. Change to a Widely Recyclable material

The first recommendation—change to film that qualifies for the Store Drop-Off label—is the most popular design recommendation across all materials, all time. It is also no surprise: the marketplace is experiencing an unprecedented explosion in flexible packaging, most of which is not recyclable. Store Drop-Off is the only recycling option for flexible packaging at scale, and is only available to polyethylene packaging.

For context, here is a snapshot of the overall recyclability of members’ flexible packaging; while about 36% receives the Store Drop-Off label, the remaining 64% is Not Yet Recyclable:

However, the ability of the Store Drop-off stream to alleviate the packaging industry’s end-of-life challenges with flexible packaging will be likely 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 potential long term success 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 and How2Recycle’s report on Future of Store Drop-Off Recyclability for more insight.

Related to this, How2Recycle’s second most common recommendation for plastics—change to mono-material from multi-materials—is an important step in design for recyclability for flexible packaging, even aside from the state of the current Store Drop Off stream. That’s because any future recycling technologies like chemical recycling are likely to favor or require substrates made of one material. Industry work is needed to explore far future design for recyclability further. Note that this recommendation also applies to rigid plastics, where multiple materials are sometimes used to create certain performance characteristics.

Labels on plastic packaging are a big area of potential improvement as well—changing to less detrimental label substrates, adhesives and inks to make those packages overall more recyclable occupy both the third and fourth most frequent design recommendations. Especially for PET packaging, this is a critical step towards more recyclable packaging.

The fifth most popular recommendation is changing to a Widely Recyclable type of packaging, which means packages where more than 60% of Americans or 50% of Canadians have access to recycling programs where they live for that package, and the package is also successfully sorted, reprocessed, and sold to become a new item. (See the How2Recycle Guide to Recyclability for more detail about the definition of recyclability and what qualifies for Widely Recyclable.) This recommendation is issued to companies with packages that receive the Check Locally or Not Yet Recyclable label. Some companies are actively working towards increasing the collection and end markets of materials in those categories, and other companies are switching to different materials in the Widely Recyclable categories.

Given the insights from How2Recycle about its member packaging, these are the key takeaways for plastic packaging:

  1. Flexible packaging is far and away the biggest and most challenging recyclability challenge facing brands. This is almost half the entire challenge. 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 high performance barrier, require recycling system interventions. 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. Additionally, How2Recycle’s report on Future of Store Drop-Off Recyclability illuminates design considerations for flexible polyethylene packaging.
  2. Recyclers have already identified what design interventions are required to make more recyclable packaging, and most of those are already ‘easy’ to do. New industry research or work is not required to identify common design problems, their prevalence in the marketplace, and how solutions could be prioritized to reach change at scale. That information is included in this report, and is already provided to How2Recycle members on a package-by-package basis. That information is based on feedback and research from recyclers, including the pioneering and impactful guidance in the APR Design® Guide for Plastics Recyclability. While design innovation may help improve the recyclability of a select variety of package types, infrastructure interventions are likely more important—and required for some materials if companies wish to continue using them and consider them recyclable. See the How2Recycle Guide to Future Recyclability for more detail.
  3. Recommendations for rigid plastics design in particular are very straightforward, low-hanging fruit. Rigid plastic packaging has on average 2.1 design recommendations issued per package in the How2Recycle Member Platform. Commercialized, recyclable innovations already exist for the majority of design concerns for rigid plastics, and it’s just a matter of the brand making the change (like labels, closures). See the APR Champions for Change Program for lists of innovations by companies already rising to the challenge.
  4. PET thermoforms’ design challenges are (a) eliminating the need for consumer separation (e.g. blister packaging), and (b) using labels that meet criteria for Preferred per the APR Design Guide. PET thermoforms are used for a wide variety of packaging such as toy packaging, produce clamshells, and blister packaging. Design for recyclability solutions already exist: see the ‘labels’ tab in the list of recipients in the APR Champions for Change Program. Additionally, investment is required at scale to increase the end market demand and availability of recycling for these items.
  5. Less than 5% of the recommendations issued apply to PVC, and to lesser extent PS and EPS. Some industry conversations focus on the desire to eliminate challenged plastics such as PVC, PS and EPS. However, How2Recycle data suggests these materials do not constitute an appreciable portion of the member packaging portfolio.

How2Recycle recommendations for collective voluntary commitments aimed at increasing recyclability of plastic packaging

There are several collective voluntary commitments such as the New Plastics Economy Global Commitment that include an emphasis on making packaging more reusable, recyclable or compostable, with a special focus on plastics. How2Recycle recommends that projects like those in the United States and Canada may want to keep in mind that:

  1. Industry resources should be allocated in proportion to the size and complexity of design for recyclability issues. Not all recyclability challenges are as widespread or as difficult to overcome. In contrast, a strategy that places equal priority and focus on all plastics or all design issues could create a false sense of equivalency.
  2. Many design for recyclability issues are less about the type of plastic selected for the package and more about the product category or the overall design of the package. Thinking about “improving recyclability of HDPE packaging” in isolation is less effective than say, “overcoming detrimental characteristics of closures,” or “reducing the need for consumer separation to recycle properly” or“packaging liquids in recyclable packaging.” Stated differently, some plastics have the same or similar challenges so organizing by mere resin may be overly simplistic and overly complicated at the same time. It also mistakenly dictates material selection as the most appropriate first step in packaging design.
  3. Keep in mind the difference between ‘easy’ work (using better labels for PET—solutions already exist) and ‘harder’ work (improving future fate of multimaterial flexible packaging). Both types of work should be pursued concurrently.
  4. Note that design for recyclability overlaps with other sustainable packaging pursuits, such as eliminating problematic packaging, increasing recycled content and improving recycling, so a systems-based approach to workflows (as opposed to segmented or parallel) is more appropriate.
  5. Recognize there are potential unintended consequences when companies replace plastic with an alternative material. Plastic historically could ‘do more’ than other substrates, so as other materials seek to meet the performance attributes of plastic with new innovation, there is a bit of Wild West effect starting to occur. For example, the dramatic, recent push for innovation in fiber packaging will potentially impact or materially change the recycled paper stream. It’s important for industry to ensure that these packages are developed with an understanding of how to design for recycling from the start, and that other critical packaging sustainability issues like carbon footprint are still kept in mind. Given this trend, How2Recycle’s paper packaging recyclability recommendations are increasing. To illustrate the move away from plastics, the use of molded fiber packaging by How2Recycle members increased by 23% in February 2020 as compared to the month prior. Packages of all materials, not just plastics, should be designed with sustainable sourcing, optimization and design for recovery in mind.

Insights on design recommendations for paper packaging

These are the most popular design improvement recommendations issued for paper packaging:

  1. Ensure no additives, layers or coatings 
  2. Change to no attachment or a paper attachment
  3. Move from poly coating to no coating or clay coating

The first recommendation, ensure no additives, layers or coatings, is a broad brush recommendation that applies to the use of UV treatments, wet strength additives, any non-fiber fillers, and any coatings that are not clay coatings. While there is a need for a comprehensive industry design guide for paper packaging that explores these issues in depth, similar to APR’s for plastics, the Walmart Recycling Playbook is a dependable reference. Sustainable Packaging Coalition was a key partner in the development of that resource.

The second most popular recommendation for paper packaging is change to no attachment or a paper attachment. This is most frequently issued for blister packaging (like for toothbrushes, batteries), or plastic windows in paper boxes—common in toy packaging and certain dry goods. This recommendation can also apply to plastic handles or metal attachments of various sorts, such as magnets or RFIDs. Recycled paper mills are able to remove most non-fiber attachments during the pulping process, but they are still considered contamination and will be landfilled after removed from the fiber.

The third recommendation, move from poly coating to no coating or clay coating, possesses some overlap with the first recommendation but is a significant area for paper packaging design improvement on its own. Poly (plastic) coating is a common problem for recycled paper mills, though some mills have signaled a potential rethinking of that. While in some cases it’s used as a moisture barrier or sealant to create three-dimensionality, other times it is used only for aesthetic purposes to make a package appear glossier or more attractive to the consumer. Companies are innovating more recyclable coatings that aim to possess the performance characteristics of traditional poly coating but perform better in recycling—and some are commercialized today. Testing the reprocessability of coatings on paper packaging is critical in order to understand impacts to recyclability; see the Guide to Recyclability for more detail.

Given the insights from How2Recycle about its members’ packaging, these are the key takeaways for paper packaging:

  1. The lowest hanging fruit for paper packaging could create big wins in recyclability. Two key areas for improvement are eliminating plastic coatings where feasible, and removing plastic windows. Since these recommendations constitute roughly a quarter of all packaging recommendations in the How2Recycle program, overall packaging recyclability would increase notably if these design changes take place.
  2. The packaging industry should cautiously assess the recycling impacts from its increasing use of flexible paper structures. The increase in coatings, adhesives and other innovations in the move away from plastics could not only create significant design for recyclability challenges, but could also lead to “paper” packages essentially becoming multi-material packages. Today, flexible packaging only constitutes 2.7% of members’ paper packaging, but How2Recycle is extremely confident that will increase (potentially dramatically) in the short and long term.
  3. Similarly, the industry should consider the recycling impacts from the rise of non-wood fiber. The paper recycling stream and its technologies were fundamentally designed to accommodate wood fiber from trees—not necessarily other fibers like bagasse and bamboo. Repulpability and yield loss may differ for these emergent fiber packaging formats and so design for recyclability should be kept in mind.
  4. The rise of three-dimensional fiber packaging, such as bottles and protective packaging, should also be monitored. Since paper is designed to sort in a Material Recovery Facility (MRF) by virtue of being two-dimensional, industry should consider sortation of these items in the design process, and assess how recyclers are adapting to these emergent packaging formats. Note that How2Recycle is studying 2D/3D sortation in 2020.

About us

How2Recycle is a part of the Sustainable Packaging Coalition: a collaborative that is the leading voice on sustainable packaging. The SPC’s mission is to bring packaging sustainability stakeholders together to catalyze actionable improvements to packaging systems and lend an authoritative voice on issues related to packaging sustainability. The SPC’s work includes hosting packaging sustainability events, conducting research, issuing reports, and more.

The parent nonprofit of both How2Recycle and Sustainable Packaging Coalition is 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.


For more information on how How2Recycle defines and interprets recyclability, visit the How2Recycle Guide to Recyclability.

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.

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.

Published April 23, 2020. Last updated August 18, 2020.