Dive Brief:
- Circular Action Alliance has opened the public comment period on its draft certification standard for responsible end markets, a component of most extended producer responsibility laws for packaging in the U.S.
- The REM standard would require certain businesses in the recycling value chain to show that recycled materials are being handled in a way that minimizes environmental and public health risks. CAA’s draft lays out the process for verifying these “responsible” claims.
- Some packaging EPR states already have REM verification provisions, but the CAA draft standard is meant to uunify those requirements to ensure a consistent process across the country. The public comment period is open through July 7.
Dive Insight:
REM requirements are an important facet of packaging EPR because they’re meant to make recycling systems more transparent and trackable. The concept was born in part to fight dumping, especially after China imposed recycling import bans in 2017 and other countries followed suit, raising more public awareness of the role some U.S. recycling systems played in exporting waste to other countries.
REMs can help rebuild trust in the recycling system by providing a “clear and credible framework that supports regulatory requirements while giving interest holders confidence in how recycling outcomes are defined, evaluated and verified,” said Victoria Norman, executive director of SCS Standards and Assurance Systems, in a statement.
SCS, a standard development organization for sustainability certification programs, is working with CAA to develop the draft. A standard development committee made up of a range of trade groups, recyclers and state agencies, also offered input on the draft.
In the seven states that have passed an EPR for packaging law, all but Maine’s program include REM provisions. The specifics vary from state to state, but most players in the recycling value chain — starting downstream of MRFs and including brokers, processors and others — need to comply with rules that show that recycled materials are going to these REMs.
Oregon already has its own REM standard for its packaging EPR law, while Colorado and California's EPR program plans also have REM requirements.
CAA’s new draft REM certification aims to streamline requirements across the states, including future states that may decide to pass packaging EPR with REM requirements. CAA is the producer responsibility organization in California, Colorado, Minnesota, Oregon and Washington.
Once the national standard is adopted, end market entities would be able to undergo one audit process instead of multiple audits for each state where it operates, explained Shane Buckingham, CAA’s chief of staff, during a presentation at the Plastics Recycling Conference in March. CAA also plans to roll out a pilot audit to test the standard sometime after the draft public comment period, he said.
CAA’s draft certification standard includes specific documentation and recordkeeping requirements. It also calls for entities to show up-to-date operating licenses and prove applicable facilities are following labor and safety laws and meeting environmental compliance obligations.
The draft calls for entities to certify each of their facilities separately, and the certification would last three years.
The draft also specifies which entities must comply with these REM requirements. CAA’s definition of a “responsible end market” includes “supply chain actors” working downstream of a MRF or collection depot. That could include those that buy, trade, manage or process the materials covered under the packaging EPR law.
Eligible entities could also include secondary processors, transporters, brokers and “other locations where material disposition occurs,” such as landfills and incineration facilities, according to the draft.
CAA will host a webinar on May 12 to explain more details of the draft.
