Update: Plastics industry critical of the EPA Draft National Strategy to Prevent Plastic Pollution

This past 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 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 (EJ) 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, according to the EPA .

The comment period on the draft strategy originally was scheduled to conclude June 16 but was extended to July 31.

The goal of the strategy is to eliminate the release of plastic waste from land-based sources into the environment by 2040 by reducing, reusing, composting, collecting and capturing plastic waste. The strategy does not include processes that convert these end-of-life materials into fuels or energy. It also addresses EJ and climate change considerations.

The strategy's objectives are reducing pollution during plastic production, improving postuse materials management and preventing trash and micro/nanoplastics from entering waterways and recovering escaped trash from the environment.

A number of industry groups have responded to the strategy, including the Consumer Brands Association, the Plastics Industry Association and the American Chemistry Council.

The comment submission from the Consumer Brands Association, Arlington, Virginia, compiled insight from across the consumer products industry, according to the association.

Vice President of Sustainability John Hewitt writes in the comment letter, “Consumer Brands commends the EPA for identifying and undertaking the actions presented in the Draft National Strategy to Prevent Plastic Pollution. We are eager for its implementation alongside the goals established by the National Recycling Strategy.”

He went on to say that the strategy will complement the existing recycling commitments made by “all of the 25 largest CPG [consumer packaged goods] companies in the United States,” of which, 80 percent “are working toward introducing fully recyclable packaging for all of their products by 2030 at the latest.”

Consumer Brands highlighted the major factors deemed critical by the consumer products industry for preventing plastic pollution:

1. harmonizing recycling standards nationwide;
2. reviewing the misunderstood “chasing arrows” symbol;
3. integrating advanced recycling, with the EPA encouraging and leading research, development and integration of new tools available for improved recycling technology.

“A significant percentage of this loss of valuable postconsumer recycled content into waste streams can be attributed to consumer confusion,” Hewitt writes in the comments.

The Plastics Industry Association, Washington, also submitted comments, with its President and CEO Matt Seaholm saying the group was “disappointed with the agency’s draft strategy.”

“The EPA was directed by Congress in an overwhelmingly bipartisan way to focus on postconsumer materials management and infrastructure, and instead the agency’s first stated objective in this strategy is to reduce the production of essential materials rather than address plastic waste,” he says.

“We don’t recycle enough, and we need to improve recycling rates in the U.S., period. Plastics remains eager to collaborate with the EPA, stakeholders and anyone who is willing to work towards our common goal of effective solutions to keep plastic waste out of the environment,” Seaholm adds.

According to Plastics, the EPA’s draft strategy should:

• recognize plastics serve a critical and sustainable role in modern life and have more than “some potential benefits;”
• acknowledge that innovations in product and material design have outpaced our infrastructure, negatively impacting our country’s ability to recycle at acceptable levels;
• revise a draft consistent with the bipartisan legislation that directed the EPA to develop a strategy to improve postconsumer materials management and infrastructure, not preproduction and product restrictions;
• foster circularity, not advocate production limits;
• hold all materials to the same standard and recognize that plastics often outperform other materials environmentally; and
• revise the draft strategy following appropriate, thorough stakeholder engagement in a transparent process to develop practicable and achievable goals.

In its comments to the EPA, the American Chemistry Council (ACC), Washington, outlines opportunities where greater collaboration could turn the draft strategy into a more comprehensive approach to eliminate plastic pollution. The association also calls out sections of the draft where unintended consequences could mean significant negative impacts for American consumers and the environment. 

The ACC calls on the EPA to recognize the promise of advanced recycling, which it says could enable the United States to recycle significantly more types of plastics, and the diversity of recycling technologies and programs that can provide circularity for plastics.

ACC says it is concerned that many parts of the Draft National Strategy to Prevent Plastic Pollution are inconsistent with the direction and intention of Congress, adding that aspects of it would stall the transition to a circular economy and increase carbon emissions in the U.S. “Our biggest concerns lie with the agency’s call for material substitution without considering the impacts of alternatives that may ultimately increase our environmental footprint, the ACC says. “Taking this proposed approach without science-based analysis could increase resource utilization, greenhouse gas emissions and waste sent to landfills.

As the National Strategy to Prevent Plastic Pollution is linked to the EPA’s National Recycling Strategy, emphasis should be put on fulfilling the objectives laid out in that strategy, the ACC says. 

The Institute of Scrap Recycling Industries (ISRI), Washington, also submitted comments to the EPA, with the association's President Robin Wiener noting their diversity and the complexity of the recycling system mean no single answer will address the challenges facing the management of these materials. She adds, "We applaud EPA for a proposed strategy that recognizes there are many solutions that, taken together, can make a significant difference in keeping plastic out of the environment and instead, circulate these valuable material resources into the manufacturing supply chain. We welcome the opportunity to further collaborate with the agency and others to advance this proposed strategy.”

 Among the recommendations ISRI provides in its comments are: 

 In its comments, ISRI provided key recommendations, including:

• improving markets for recycling plastics through policies that do not interfere with existing efficient markets and encourage maturation of developing markets through technological innovation, incentives and other efforts;
• encouraging policies that incentivize manufacturers to design their products for recycling after their useful lives, to use greater amounts of recycled content in manufacturing and to use recyclable and recycled content in packaging, provided there are no negative implications to the product’s recyclability;
• as an alternative to full ratification of the Basel Convention, continued leadership of the U.S. government at the Organization of Economic Cooperation and Development (OECD) on plastics-related issues to provide plastics recyclers with further legal clarity and access to global markets;
• exploring continued federal funding for U.S. government-led public-private partnerships focused on research and development of innovative technologies and implementation of Design for Recycling principles;
• exploring development of an accredited, voluntary third-party certification program, such as or similar to the Recycling Industry Operating Standard (RIOS), for plastics recyclers to increase the safe and effective management of plastics recyclables in the U.S. and strengthen the domestic manufacturing supply chain;
• excluding processes that convert materials to fuels, fuel ingredients or energy from being considered as a recycling practice; and
• prioritizing additional funding opportunities for recycling accessibility and infrastructure in under-resourced communities.

*This article was updated Aug. 2, 2023, to include comments from ISRI.