Monday, December 12, 2011

EPA Sustainable Packaging Dialogue: Big Consumer Goods Companies Not All On Same Page

By Bill Sheehan, Executive Director, Product Policy Institute

From September 2010 through August 2011, the U.S. Environmental Protection Agency convened and facilitated a dialogue on how to finance recycling of consumer goods in the United States. The dialogue included four two-day meetings. Product Policy Institute was one of 30 invited organizations and businesses. Participants included representatives from ten consumer goods companies (such as Proctor & Gamble and Coca-Cola), two retailers (Wal-Mart and Target), seven state governments, five local governments, three environmental public interest organizations, and other non-governmental organizations [see report, Appendix B, p. 120]. The final report from the year-long dialogue was released on EPA’s website on December 9th and a public comment period has begun [see below].

The stakeholder dialogue showed a gaping divergence between public interest organizations and governments on the one hand, and the consumer packaged goods companies, on the other. Most of the former group entered the dialogue with the understanding that it would primarily focus on extended producer responsibility as the most promising solution to boost recycling of packaging materials in the U.S, the vast majority of which are wasted in landfills and incinerators. Governmental representatives made it clear that municipal recycling systems are maxed out, and that current taxpayer and ratepayer funding and decision-making is inadequate to achieve needed results. 

Instead of exploring EPR, industry representatives insisted that the focus should be on financing the status quo (see Strategies for Optimizing the Current System). The discussion on Financing Strategies was diluted by industry’s insistence that all conceivable options be considered, including those which have been shown to be inadequate (e.g., taxpayer-funded municipal recycling) and/or are politically or logistically not viable (e.g., federal funding for recycling infrastructure).

In spite of the fact that these same companies participate in take-back programs in Europe, Canada and other places around the world, most consumer goods companies balked at the notion of assuming responsibility for their packages after consumers are done with them. “We’re not in the garbage business,” was a frequently heard refrain.

However, these companies were not all on the same page. During the Dialogue, a consultant hired by Coca-Cola issued a report supporting EPR for packaging (although the report was never discussed in the meetings). An Estée Lauder company, Origins, has been operating a voluntary take-back program for its cosmetic packaging, and Estée Lauder publicly advocates for individual producer responsibility. It was also evident that retailers are evaluating the potential for increasing customer traffic and loyalty from take-back programs.

With other significant dialogues on EPR for packaging happening around the United States and the likelihood of state legislation forthcoming, the large product manufacturers and retailers are going to have to make a decision. Will they support EPR policies – which many of them comply with around the world – for the truly sustainable management of packaging? Or will they be on the wrong side of history and continue to fight for taxpayers to subsidize the massive amounts of packaging waste they create?


The report is: Final Report of the Dialogue on Sustainable Financing of Recycling of Packaging at the Municipal Level (PDF) (128 pp, 872K). EPA will accept comments on this report until February 9, 2012 . The docket for this rulemaking is EPA-HQ-RCRA-2011-0912 and can be accessed at

Below are highlights excerpted from the 125-page report:
-- an overview of the major “work products” of the dialogue, and
-- three major topics that “illustrated divergence among stakeholders.”

“Work Products” [page 7 >]

“Participating stakeholders identified, examined and evaluated a total of eleven strategic options for financing recycling of packaging and printed material, and also proposed the advancement of eight distinct projects to optimize the current system. Together, these two work streams considered opportunities for enhancing the funding available to the system while reducing the cost of the system’s operation.”

“Strategies for Financing Recycling"
The assessments were intended to provide a balanced summary of participating perspectives regarding the advantages and disadvantages of each strategy, providing a strong foundation for leaders in the public, private and civic sectors to determine how best to address the challenge of financing recycling. The strategies are categorized by general source of funding: producers, consumers, rate-payers, and taxpayers.

• Producer-funded strategies
• Consumer-funded strategies
• Rate-payer funded strategies
• Taxpayer-funded strategies”

“Strategies for Optimizing the Current System
Eight potential projects were identified as strategies for improving the effectiveness and efficiency of the existing recycling system, to meet the characteristics of success that the group discussed. The projects evolved out of the mapping exercise through which participants identified challenges or areas for improvement at each phase of the system. Participants jointly developed a set of project briefs…”

Major Topics [page 4 > & 19 >]
“The major topics that generated discussion and illustrated divergence among stakeholders included:”

“Extended Producer Responsibility
Many participants would have preferred to focus largely or exclusively on certain financing strategies they believed to be most promising, especially extended producer responsibility (EPR). At least some stakeholders believe the dialogue missed a critical opportunity for productive deliberation and cross-sector learning by not pursuing deeper analysis of EPR.”

“Some participants, however, including most brand owner representatives, expressed strong discomfort with any explicit emphasis on EPR. A handful of stakeholders expressed the view that EPR was in fact too broad a subject given the need for meaningful and near-term action, and that a somewhat narrower but still reasonably holistic focus on sustainable waste management – i.e., end-of-life management of key materials – would be most productive. The chapter below on Financing Strategies provides more detail on the group’s deliberations and stakeholder perspectives regarding EPR and other strategic options. [page 20:]”

Some participants believed that inclusion of printed paper in the scope of inquiry was inappropriate since relevant industry sectors (e.g., paper manufacturing, printing and publishing) were not represented at the table. Alternatively, a few participants preferred a focus on priority material types (e.g., aluminum, cardboard, steel) rather than all forms of packaging.”

“Dedicated focus on recycling
Some participating stakeholders – largely from industry – raised concerns about the focus on recycling and advocated for a more holistic assessment of end use options, hoping to explore how best to maximize the recovery of value (in financial and environmental terms) from the municipal solid waste stream. They preferred to be able to consider an integrated waste management approach including composting and waste-to-energy, determining the appropriate management strategy for each set of circumstances. Also, some participants from various sectors emphasized the need for source reduction and reuse to play a more significant role.”

“The purpose of the project was to solicit a range of stakeholder opinion and identify promising options rather than attempt to achieve agreement among participants. This report therefore does not represent consensus views but rather serves as a summary of deliberations, including findings and some jointly developed recommendations.” [bold in original]

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