Option 4 – Recyclability and Improved Actual Recycling

Why Important?

Improving the recyclability of packaging, whether single-use or reusable, improves the potential to increase the supply of recycled material available for new products and packaging.

We say ‘potential’, and added ‘enabling actual recycling,’ because, while design for recyclability is a critical first step, many factors influence the quantity and quality of material collected, sorted and reprocessed. These factors include:

• consumer awareness
• education and behaviour
• waste collection practices and initiatives (e.g., deposit-return systems)
• waste sorting capabilities (optical sortation, including digital water-marking)
• secondary materials market dynamics

Action in each of these areas is vital to ‘actual recycling’ success. Where possible we flag promising work in these areas, but our focus is on the recyclability of the plastic packaging itself.

Definitions

Defining recycling is straightforward – we rely on the definition of recycling as laid out in the Ellen MacArthur Foundation’s New Plastics Economy initiative. Full details here:
https://www.newplasticseconomy.org/assets/doc/Global-Commitment_Definitions_2020-1.pdf

Definition: Material Recycling

Below is an excerpt from this document which defines recycling as follows:

“Definition: Material Recycling

Reprocessing, by means of a manufacturing process, of a used packaging material into a product, a component incorporated into a product, or a secondary (recycled) raw material; excluding energy recovery and the use of the product as a fuel.

Source: ISO 18604:2013 – Packaging and the environment – Material recycling, modified (note to entry not applicable).”

Definition: Recyclable

It’s when one tries to define ‘recyclable’ that things become more complicated.

There is a difference between what is technically recyclable, and what is recyclable according different jurisdictions.  Most materials can be recycled, but for different reasons, the system conditions for recycling to actually occur may not exist. Three leading barriers to these system conditions are:

• Risk of Contamination: Although PVC is an effective plastic packaging material which can be recycled, tiny amounts of PVC can completely compromise other material recycling streams (e.g., PET, HDPE, etc.). Consequently, it makes sense – as recommended by the Golden Design Rules – to eliminate PVC from packaging.
• Scale of Supply: sufficient supply is required for a given material type to be economically viable for reprocessing. Harmonization of what is and is not accepted across large jurisdictions can impact economic viability of recycling. See https://resource-recycling.com/plastics/2016/11/15/first-steps-for-secondary-processors/ for further insights.

Ease of Recycling: Some packaging (e.g. clear PET bottles) are relatively easy to reprocess, whereas others are much harder (e.g. multi-material, multi-laminate structures) due to current state of waste material sorting and post-processing technologies.

How is recyclability determined in Canada or the US?

The recyclability of plastics is based on the following conditions being collectively present:

Is it an Accepted Waste Material?

Generally, most plastic packaging is accepted for recycling across Canadian jurisdictions, but there are exceptions.  Although virtually all plastics, as individual resins (e.g., PE, PET, PP, PS, PVC, etc) can technically be recycled, many of these plastics when used in separate packaging products may not be recycled for a number of reasons.

For example, Canada’s largest municipality (Toronto) notes the following exceptions, based on factors including colour, format, material type, and food contact:

• Any items that are black, including takeout containers, bags, plant trays and flowerpots
• Any items labelled or marketed as compostable or biodegradable, including bags, containers, cutlery
• Stand-up resealable pouch bags
• Liner bags (e.g., from cereal, cookies, crackers)
• Wrapping around pre-packaged foods like meat and cheese
• Food wrap (i.e., Cling wrap)

Is there a Sufficient Collection Capacity Across Multiple Jurisdictions?

Jurisdiction over recycling in Canada is provincial.  However, a common understanding of the term recyclable in Canada is based on Federal Competition Bureau documents, which state that for a package to be recyclable, a minimum of 50% of people in any given jurisdiction need access to recycling for the package type in question. If a product is sold in just one province, then the 50% would apply to just that province. If sold across Canada, then 50% of Canadian households must have access. If this threshold is not met, then a more specific qualified claim must be provided. An example of the range of access to recycling by packaging type is illustrated in the following figure (from 2017).

This understanding is now in flux, as the Government of Canada’s 2022 consultation paper committed to introduce labelling rules that prohibit the use of the common recycling logo (e.g., chasing-arrows symbol) on plastic products, unless 80% of Canada’s recycling facilities accept, and have reliable end markets for, these products. See the summary on Canada’s Labelling consultation for further information.

Is there Sufficient Market Demand for the Recycled Material?

Although materials can technically be recycled and sufficient capacity for collection can be established, the lack of demand for recycled material would prevent the conditions for recyclability to be met. The lack of market demand can be the result of a fundamental lack in applications which can use the recycled material, due in part to the barriers outlined above, notably the contamination risks or lack of stable and secure supply. In other instances, there may be no viable manufacturing processes able to use the recycled content due to the composition of the recycled material, significant reprocessing costs (e.g., energy, other materials costs, etc.) or other related manufacturing considerations.

Consequently, a key consideration in determining material recyclability is to assess both current and future market demands for the recycled materials in question.

Are there Supporting Activities to Mitigate Recycling Risks (EPR, others)?

Key supporting activities are critical to establish, sustain and enhance the system conditions which enable recyclability of various plastics packaging forms.  Of particular interest in assessing the state of recyclability are Extender Producer Responsibility (EPR) mandates, and labelling considerations given their impact on consumer behaviour.

Extended Producer Responsibility Mandates

Increased adoption, enforcement and harmonization of EPR programs will drive what is considered recyclable in the future, largely by increasing access to recycling services for various packaging types, increasing what municipalities accept, collect and sort, and increase labelling effectiveness. Consequently, EPR regimes not only influence what is recyclable now, but will direct impact what is recyclable in the future.

Notable recent implementation of major EPR changes in Canada include Ontario’s Blue Box Transition, and Quebec’s Modernization of Curbside Recycling.

Understanding and meeting these new regulations is the role of Producer Responsibility Organizations (PROs).

Labelling Considerations

Currently the only labelling system that addresses packaging sold into the Canadian marketplace is GreenBlue’s How2Recycle Program, which also operates in the US.  In Canada How2Recycle aims to adhere to Competition Bureau guidelines.  In the US, the key reference is the Federal Trade Commission (FTC) Green Guides, which say “a product or package should not be marketed as recyclable unless it can be collected, separated, or otherwise recovered from the waste stream through an established recycling program for reuse or use in manufacturing or assembling another item.”  In the US a ‘widely recycled’ label means that at least 60% of Americans can recycle a package at curbside recycling or drop-off recycling.

Consequently, answering “what is recyclable” remains a challenge in Canada due to the lack of organizations which can validate the recyclability of packaging across evolving Canadian jurisdictions lacking any substantive harmonization at this time.

Given the current lack of harmonized approach across large jurisdictions, adoption of Golden Design Rules is a practical, and important way to contribute to improved recycling systems in Canada, North America and globally. Designing for recyclability remains a key strategy in moving packaging in the right direction.

Supporting Resources

The following references are recommended for organizations considering or exploring enhanced recyclability and enabling actual recycling as a sustainable packaging option.

Golden Design Rules (GDRs): The Consumer Goods Forum Coalition of Action on Plastic Waste members, with a shared revenue of more than 1 trillion euros and representing more than 10 percent of the global plastic packaging market, have committed to adopting the GDRs wherever possible by 2025. Members have been asked to voluntarily commit to implement these design changes by 2025 and to report annually on progress, in a process aligned with the New Plastics Economy Global Commitment.

Association of Plastic Recyclers (APR) Design Guide for Plastics Recyclability: Widely recognized in North America, and elsewhere globally this guide helps package designers measure each aspect of a package design against industry-accepted criteria to ensure that it is truly recycling compatible.

World Packaging Organization (WPO) Design Guide: The WPO has prepared this resource as the first step to developing a consistent global notion of circular design thinking for materials and packaging, with the intent of encouraging all 53 WPO member countries to use the tool, and work with WPO to develop more localised versions that suit their countries and regions.  Canada is not currently a WPO member.

Food and Retail Industry Guidance: a number of food and retail vendors have developed guidance documents to assist their suppliers in migrating to more sustainable packaging alternatives. The following are recommended as key references in Canada:

• Loblaw Packaging Material Guidance for Vendors and Printers – Released in 2021, the 24pp guide incorporates key sustainability areas (reduction, reuse, recyclability and recycled content), cross-references current GDRs and uses a traffic light method to assess packaging (i.e., Preferred, Avoid When Possible, Avoid).
• Walmart Recycling Playbook: Updated in 2021, the 97pp guide is targeted to companies setting recyclable packaging and recycled content goals.
• Metro Better Packaging for Better Recycling Guide: Published in 2019, the guide provides Metro suppliers with guidelines on reducing the use of packaging, implementing optimal design, selecting ecoresponsible materials, and facilitating recovery and recycling.
• Costco Sustainable Packaging Guidelines: Updated in 2021, the Costco guide outlines Costco’s global packaging plan and related strategies to reduce the amount of packaging overall, increase the recycled content and certified fiber in packaging, increase the recyclability and compostability of packaging, and educate and learn from employees, suppliers and members the importance of sustainable packaging and recycling.

CPMA Packaging Guidance Documents: The CPMA has produced several industry guidance documents under the direction of the CPMA’s Plastics Packaging Working Group, each updated over time to reflect key market developments. Key documents include:

• (2022) CPMA Golden Design Rules for Produce Packaging
• (2020) CPMA Packaging Materials Selection Guide
• (2020) CPMA Preferred Plastics Guide
• (2019) CPMA Plastics Packaging Roadmap
• (2019) A Landscape Review of Plastics in the Canadian Fresh Produce Sector

Collaborative Initiatives: Several collaborative initiatives are underway in Canada and around the world to promote and enable increased recyclability and enable actual recycling, notable examples including:

• Circular Plastics Taskforce (Canada) – A cross value chain collaboration that includes digital water-mark testing, a powerful design technology which, among other benefits, improves sorting, and recycling yields. The Circular Plastics Taskforce’s activities link to the Alliance to End Plastic Waste’s Holy Grail 2.0 digital watermarking project and is a Canada Plastics Pact (CPP) Implementation Partner.