We have been given several regulatory opportunities this year to drive home our message on the importance of films and flexibles, including the protection of products and the reduction of carbon, as well as shaping the future of recycling in the United States to include this type of packaging. The U.S. Environmental Protection Agency (EPA) has two current strategies it is working on following its National Recycling Strategy that the Flexible Packaging Association (FPA) commented on this past year. The first, the “Draft National Strategy to Prevent Plastic Pollution,” focuses on actions to reduce, reuse, collect, and capture plastic waste. The second is its newly released “Recycling Infrastructure and Market Opportunities Map.” The objective of this strategy is to identify, develop, and aid in designing recycling programs by identifying gaps, expanding programs, and developing end-market circularity. The Federal Trade Commission (FTC) also has its “Green Guides,” which inform product manufacturers on labeling for consumer education, including recyclability.
While the intent of the plastic pollution prevention strategy was one FPA supported through the Save our Seas 2.0 Act in 2020, the EPA draft appears to go far beyond the original intent of supporting modern recycling infrastructure in the U.S. and circularity for plastics to a ban on new plastics in the U.S. In the draft, EPA is focusing on the elimination of plastics by capping plastic production, limiting innovative recycling technologies, and prescribing alternative materials. Not only is this out of scope with the objective of the underlying legislation, but these components of the strategy also risk working against our country’s climate objectives and moving plastic manufacturing jobs overseas. FPA has urged EPA to return to the focused objective of preventing plastic from contributing to the pollution of our land and waterways by investing in modern infrastructure to collect, sort, and reprocess plastic for future reuse.
FPA also asked EPA to add film and flexible packaging to its mapping tool. EPA must recognize that—as the second largest segment of the packaging industry and the largest plastic category—it is vitally important to develop recycling infrastructure and identify end markets. As flexibles are a contaminant to the current traditional recovery programs, the inclusion of flexible packaging in this tool will serve to aid programs in addressing this gap. Finally, FPA has requested that FTC update its Green Guides, particularly with respect to recyclability claims, so we have a harmonized approach to labeling as the emerging state-by-state approach is unworkable. FPA also stressed that for flexible packaging, advanced recycling technologies must be recognized as recycling for food packaging circularity, in particular. In the absence of federal action, we have seen too many divergent state laws in recent years. FPA must take all opportunities to weigh in at the national level to steer the conversation to infrastructure investment and a harmonized approach to circularity for flexibles.
Flexible Packaging Association