Skip to Content


EPA’s National Framework for Recycling: Is it Enough?

March 24, 2020

In October 2019, NERC Advisory Member The Recycling Partnership (TRP) issued a new report entitled The Bridge to Circularity: Putting the New Plastics Economy into Practice in the U.S.  “The momentum around plastics waste should provide an entry point to address the broader question of how to build a circular economy for all consumer packaging in the U.S.,” the report states.

The following month, the US Environmental Protection Agency published The National Framework for Advancing the U.S. Recycling System. According to EPA, the 45 original signatories to the 2018 America Recycles Pledge (which includes the Northeast Recycling Council), working collaboratively through 2019, “pledged to work together to identify specific actions to take in addressing the challenges and opportunities facing the U.S. recycling system.”

EPA identified the four following critical action areas as priorities for the signatories:

  1. Promote Education and Outreach
  2. Enhance Materials Management Infrastructure
  3. Strengthen Secondary Material Markets
  4. Enhance Measurement

The first action area seeks to address contamination in the recycling stream by educating citizens about what properly belongs in recycling bins; an oft-repeated example of contamination is single-use plastic bags. Without even considering the wisdom of deploying a plastic bag just one time before disposing of it, the presence of single-use plastic bags in the recycling stream creates havoc with equipment in materials recovery facilities (MRFs).

In its Framework, EPA avoided taking a position on whether single-use plastic bags should in fact be removed from the economy altogether, despite a rapidly increasing number of bans on their use enacted by many localities and states.

In the second action area, “America’s existing recycling infrastructure has not kept pace with today’s changing recyclables stream”, EPA reports, referring to developments in packaging such as hybrid combinations of multiple components. Because of their hybrid nature, these products cannot be easily recycled. Yet EPA’s vision for improving the domestic materials management infrastructure avoids addressing the impact of these products on solid waste management, when most MRFs lack the capacity to process them; “A holistic, modern and adaptable national recycling infrastructure that embraces innovation and is resilient to changes in material streams, markets and consumer expectations” is the agency’s vision statement.

In a scathing editorial entitled The EPA’s new recycling plan is straight out of 1985, the Los Angeles Times identifies what it described as “strategies to hide the effects of an unsustainable consumer culture for a little bit longer while letting the industries that produce and employ single-use packaging off the hook.”

“The working group for the recycling plan was dominated by representatives from business and industry groups such as the American Chemistry Council, Dow Chemical Co. and ExxonMobil (plastic is a petroleum product),” the editorial continued. “It’s not in the best interest of plastic manufacturers to make less of their product or to have to cover the cleanup costs.”

In response to the LA Times, an email from EPA stated the following:

“Following the 2018 America Recycles Summit, workgroups were formed to address four critical action areas– Education and Outreach, Infrastructure, Secondary Materials Markets, and Measurement. Participation in the workgroups was voluntary and open to all America Recycles pledge signatories, including state, local, and tribal governments; government associations; funding organizations; trade associations; non-profits; product manufacturers; academia; and recyclers.

“In 2019, the workgroups identified priority projects for implementation, and a few participating organizations volunteered to lead the development of those projects, later referred to as Steering Committees (see list below). On November 15, 2019, EPA released the National Framework for Advancing the U.S. Recycling System, which summarizes the activities and accomplishments of the workgroup participants in 2019 and lays out the path forward for continued action in 2020. It also provides a foundation on which additional actions can be identified and taken.”

The steering committees, EPA asserts, were largely directed by nongovernmental organizations (NGOs) in the recycling field:

Education and Outreach – Keep America Beautiful, The Recycling Partnership, Sustainable Packaging Coalition

Infrastructure – Institute of Scrap Recycling Industries, Keep America Beautiful, U.S. Chamber of Commerce Foundation.

Markets – The Recycling Partnership, South Carolina Department of Commerce, Waste Management

Measurement – Environmental Research and Education Foundation, U.S. EPA.

NERC participated in the infrastructure and markets workgroups.

That the domestic recycling industry has a critical shortcoming in infrastructure was laid bare by the refusal of China and then additional export markets to continue accepting contaminated material from the United States. “Encouraging communication and collaboration across the different sectors of the U.S. economy, including private enterprise and government entities, will support innovation as well as the development, manufacture and reuse of high-quality recyclable materials,” EPA states.

As the L.A. Times editorial inferred, what is missing from EPA’s National Framework is the issue of money. Who is going to pay for upgrades to infrastructure and the development of markets? Here it is illustrative to return to TRP’s report on plastics and other single-use packaging. Noting that industry commitments to using post-consumer recycled content cannot be met at current levels of recycling, TRP’s Unlocking Supply initiative “calls for an initial investment of USD $250 million over five years…to begin bridging the gap in post-consumer supply by strengthening the existing recycling system for all materials.”

Also, TRP’s Recycling 2.0 vision calls for an additional $250 million investment in grants for a national recycling system; its Recycling 2.0 vision, TRP states, “necessitates all stakeholders to come to the table to agree on sustainable solutions that will deliver a uniquely American approach.”

One widely discussed solution for helping to fund the needed improvements in the domestic recycling system is Extended Producer Responsibility (EPR). Last year, after careful consideration and mediation among the priorities of different entities, NERC adopted a Post-Consumer Recycled Content Policy. “Despite improvements in the use of post-consumer recycled content in some products, significant opportunities remain to increase the use of this material; market driven incentives have generally proved insufficient to increase its use,” NERC’s policy states.

“NERC believes that beyond voluntary initiatives, mandatory actions based on science and economics are needed to drive an increased use of post-consumer recycled content.”

By Robert Kropp, NERC Office Manager


Comments (0)

Add a Comment

Allowed tags: <b><i><br>Add a new comment: