Flexible packaging has a target on its back. Shortsighted elimination policies for flexible packaging—and all packaging in general—will not solve the problem and, in many cases, will result in more environmental harm. The Ellen MacArthur Foundation’s (EMF) report, “Flexible packaging: The urgent actions needed to deliver circular economy solutions,” has come to many of the same conclusions that the Flexible Packaging Association (FPA) has been touting for years. While some packaging—plastic or otherwise—can be eliminated or reduced, most packaging plays the vitally important role of protecting and preserving the efficacy of products and eliminating food waste. Thus, short-term solutions, such as bans, will not solve the problem. Only long-term investment in circular systems will. This means a commitment to circular design and a modern U.S. recycling and composting system.
In the EMF’s report, its first line of defense is directly eliminating single-use flexible packaging. However, it estimates that only 5% to 10% of flexible packaging’s portfolio can actually be considered unnecessary. And it states that “it is currently not possible to completely move away from single-use flexible packaging without negative unintended consequences.” FPA and its members know that this includes increased greenhouse gas (GHG) emissions from the manufacturing and transport of alternative packaging types, as well as increased food waste, and increased water and energy usage. It also increases waste of both the packaging and product through damage and loss. The Oregon Department of Environmental Quality reports that the average carbon footprint of food production alone is over 75% when compared with processing and packaging, which often has the smallest footprint. And if food waste was a country, it would be the third-largest contributor to GHG emissions after the U.S. and China.
Simply put, while other packaging types may be more readily accepted at recycling centers, they offer fewer protections for consumer products, especially food, while ultimately being more expensive and less sustainable to produce. For example, the recycling rate for a steel coffee can would need to increase from 71%—one of the highest packaging recycling rates—to 93%, and the plastic lid recycling rate needs to increase from 21% to 75% before the coffee packaging would have less landfilled material as a stand-up flexible coffee pouch. This is in addition to the increase in water usage to manufacture a steel can (16 times as much), fossil fuel usage (453%), and GHG emission increases (7 times as much). Simply eliminating flexible packaging in favor of other packaging formats not only doesn’t solve the packaging pollution problem, it actually creates others.
Flexible packaging creates “less waste in the first place®”, uses fewer virgin resources, and creates less GHG emissions. Even the EMF agrees that much of it can’t and shouldn’t be eliminated. So, what do we do with the rest? Again, FPA agrees with the EMF—the answer is unprecedented efforts to scale recycling systems. Recycling does work, but in the U.S., our system is decades old, and for far too long it relied solely on a failed policy of exports, particularly plastic exports, instead of investment in domestic infrastructure. FPA supports well-crafted extended producer responsibility (EPR), as does the EMF, to subsidize that investment and create sustainable funding for a dynamic recycling system that includes advanced recycling technologies for both mechanical and chemical. Let’s admit what the EMF report states for the U.S.: While we have low levels of mismanaged waste in comparison with other geographies, we also have a less advanced waste management system overall.
FPA members invested millions in transitioning to mono-material and other readily recyclable flexibles, as well as compostable structures. And, even where flexible plastic has been substituted with flexible paper, the EMF correctly points out that unprecedented efforts are still needed for paper recycling systems. Thus, mere substitution to paper or compostable structures is not the answer. The current U.S. recycling and composting systems today will not support flexibles, regardless of the makeup. We need to continue to move toward improvements in packaging design and better barrier protection to create more readily recyclable flexible packaging without increasing product loss and food waste. But we need to do so in tandem with collection and circularity systems, or these efforts will be stranded.
Oregon, one of the first states to pass an EPR bill in the U.S., is currently in the regulatory phase of implementation. One of the first things the state is attempting to do is bring some harmonization to the myriad of local recycling programs it has in the state. Oregon’s preliminary recommendations would be to include mono-material flexible plastic packaging on its statewide recycling list. This is a good start, as it will mandate that EPR funding goes toward establishing a robust collection system for all Oregon residents, processing, and viable end markets for a large segment of flexible packaging.
It is this type of policy that FPA and the EMF can agree will trigger the right approach to creating circularity for flexibles. If this is done in other states, it can create the market dynamic necessary to mitigate packaging pollution, spur investment in recycling and composting systems, and create the supply demand for post-consumer recycled material in this sector.
Other states offer clear examples of poor policy that will not advance either access to or add more packaging materials to circularity. That would include Maine, where the EPR program is simply a tax that will merely pay for the status quo, and California’s proposed ban on plastic e-commerce packaging, the majority of which is recyclable today. Instead, more packaging will continue to go to landfills and is more likely to leak into the environment. FPA may not always agree with the EMF, but in this case, let’s agree that where we can use more sustainable packaging types, we do so. But for the 90% of flexible packaging that cannot be eliminated without unintended consequences, investment in recycling and composting infrastructure is the key to eliminating packaging pollution.
Alison Keane, Esq., IOM, CAE, is FPA president and CEO.