US EPA releases draft of strategy to prevent plastic pollution

During Earth Week, the U.S. Environmental Protection Agency (EPA) released the draft “National Strategy to Prevent Plastic Pollution” for public comment. The draft strategy was released alongside a new White House Interagency Policy Committee (IPC) on Plastic Pollution and a Circular Economy. The IPC will coordinate federal efforts on plastic pollution, prioritizing public health, economic development, environmental justice and equity to ensure the benefits of acting on plastic pollution—including jobs, minimized exposure to harmful chemicals and clean communities—are available to all, the EPA says.

In response to growing concerns about plastic pollution and marine debris, Congress passed the bipartisan Save Our Seas 2.0 Act in late 2020. Title 3, “Improving Domestic Infrastructure to Prevent Marine Debris, Section 301 Strategy for Improving Post-Consumer Materials Management and Water Management,” charges EPA with developing a strategy to improve postconsumer materials management and infrastructure to reduce plastic waste and other postconsumer materials in waterways and oceans. Congress also asked EPA to “distribute the strategy to states and to make it publicly available, including for use by for-profit private entities involved in postconsumer materials management and other nongovernmental entities.” Together with the “National Recycling Strategy,” the “National Strategy to Prevent Plastic Pollution” fulfills this mandate, the EPA says. 

Among the organizations that plan to comment on the “National Strategy to Prevent Plastic Pollution” are the American Chemistry Association (ACC) and the Plastics Industry Association (Plastics), both based in Washington.

“Some components of EPA’s draft strategy align with the federal policy proposal from America’s plastic makers, detailed in our 5 Actions for Sustainable Change, such as expanding recycling capacity and public education on recycling,” the American Chemistry Council’s Vice President of Plastics Joshua Baca says in response to the strategy.

“However, other components of the strategy risk sending plastic manufacturing and jobs overseas where plastic is often made with less stringent environmental standards and more greenhouse gas (GHG) emissions. We caution the administration that prescribing alternative materials, capping plastic production or limiting innovative recycling technologies could work against its climate objectives as plastic almost always has a lower lifecycle GHG footprint compared to paper and metal.”

Camille Gallo, director of communications at Plastics, says, “The Plastics Industry Association is dedicated to keeping waste out of the environment and in the economy. Plastics looks forward to the opportunity to submit comments to the EPA and work together towards our common environmental and sustainability goals.”

According to a news release from the EPA, the draft strategy includes actions designed to eliminate the release of plastic and other waste from land-based sources into the environment by 2040. 

“Plastic pollution negatively impacts our environment and public health with underserved and overburdened communities hit hardest,” EPA Administrator Michael S. Regan says. “As a global leader in the efforts to address these challenges and pave the way for the future, we must combat plastic pollution from every angle and prevent it at every step of the plastic lifecycle. As we take comment on EPA’s draft national strategy, the agency will continue this work to protect people and the planet, ensuring the benefits reach our most vulnerable communities.”

In the last 20 years, global annual production of plastics and plastic waste has more than doubled, the EPA says. As a result, communities face pollution not only from the manufacture and transportation of plastic and associated chemicals but also from the millions of tons of plastic products that end up in waste streams and “leak” into parks, neighborhoods, waterways and oceans.

In its work with industry leaders and additional stakeholders, the EPA says it identified three key objectives for the strategy: 

• reducing pollution during plastic production;
• improving postuse materials management; and
• preventing trash and micro/nanoplastics from entering waterways and removing escaped trash from the environment.  

The EPA says adopting a circular approach to plastics management in the U.S. involves a number of actions:

• understanding the effectiveness of programs and policies and preventing plastic pollution through reducing, reusing, collecting and capturing plastics from land-based sources;
• improving the U.S. capacity to reuse and refill products;
• increasing data availability and conducting life cycle assessments to understand the environmental, economic, social and health impacts attributed to plastics;
• addressing and improving consumer outreach and understanding of the proper management of plastic and other waste; and
• improving the wastewater/stormwater management and capture systems.

The draft “National Strategy to Prevent Plastic Pollution” and the EPA’s “National Recycling Strategy” identify how the agency can work with U.S. organizations to prevent plastic pollution and reduce, reuse, recycle and capture plastic and other waste from land-based sources, the EPA says. These actions support a circular approach to the management of plastics that is regenerative by design, enables resources to maintain their highest value for as long as possible and aims for the elimination of waste.

The draft strategy calls for improving the design of plastic products to provide more reuse and refill opportunities, increasing solid waste collection and ensuring that solid waste management does not adversely impact communities; producing fewer single-use, unrecyclable and frequently littered plastic products and reducing pollution from plastic production facilities; and increasing public awareness of ways to reduce plastic and other trash in waterways. 

ACC’s Baca adds, “The EPA and America’s plastic makers share the same goal: preventing plastic pollution. These words are backed by the billions of dollars plastic makers have invested to scale up a circular economy to help keep plastics from entering the environment, conserve natural resources by recycling valuable plastic materials and shrink the environmental footprint of manufacturing.”

The Plastic Pollution Coalition, Washington, welcomed the Biden-Harris administration’s recognition that plastic pollution is an environmental and social justice issue that disproportionately affects Black, Brown and Indigenous (BIPOC) and rural and low-income communities, saying the details of the plans as well as the timeline for implementation, are key areas of interest.

The EPA has included specific questions in the draft report for the public and other organizations to comment on and expects to finalize the strategy by the end of the year:

• Which actions are the most important and would have the greatest positive impact at the local, regional, national and global levels? 
• What are the most important roles and/or actions for federal agencies to lead?
• Is your organization willing to lead an action or collaborate with others to implement the actions?
• What are potential unintended consequences of the proposed actions that could impact communities considered overburdened or vulnerable, such as shifts in production or management methods?
• What key metrics and indicators should EPA use to measure progress in reducing plastic and other waste in waterways and oceans?
• What criteria should processes meet to be considered “recycling activities” (e.g., “plastics-to-plastics outputs are "recycling" if these processes reduce the life cycle environmental impacts in comparison to traditional mechanical recycling)?
• Are there other actions that should be included in the Strategy, such as expanding the scope of the strategy to include sea-based sources or targeting specific types of plastic products for reduction or reuse ?

Additionally, EPA says it is posting public comments on the Federal Trade Commission’s request for comment on potential updates to its “Green Guides” for the use of environmental marketing claims. The EPA says it supports strengthening requirements for environmental marketing claims and combating greenwashing, including requiring higher thresholds for plastic products and packaging to be marketed as recyclable.