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An open letter to CPG companies on recycling

Changing the legal definition of "recyclable" would go a long way to reducing waste.



As we wake up to the hard realities of the plastic pollution crisis, we are all eager to find sustainable solutions that will allow us to deliver products to our customers without creating waste in the process.

As a sustainable packaging designer, I have focused on this challenge for over a decade. Over the years, I have had the opportunity to study our materials and material management systems from a system-level perspective and I have found a simple way to fix our recycling system and get us on track to build a true circular economy.

The solution lies in changing the definition for "recyclable" in the Federal Trade Commission’s (FTC’s) Green Guide. The current definition of recyclable is interpreted such that a material can be labeled as recyclable only if over 60 percent of households have access to collection of the material. The current definition does not mention the need for an end market for these materials, and this is in fact where the recycling system is breaking down.

It turns out that material recovery facilities (MRFs) around the country have been working day in and day out to collect our single-use packaging materials, sort and bail these materials and try to sell them on the recycled material market. Unfortunately, many of these materials (mainly plastics) do not have strong end markets, which means no one wants to buy these materials from the MRFs. So, they end up shipping these materials overseas or sending these materials to landfill.

Quick fix: Update the definition of 'recyclable'

If we want to create a true circular economy, we must put only those materials into the system (the materials that make up our products and packaging) that have strong end markets on the secondary recycled material market.

A simple, yet effective way to drive this change would be to update the definition of recyclable in the FTC Green Guides to state: A material can be labeled as recyclable only if an end market exists for over 60 percent of the material entering the system.

The FTC could further define end markets as real companies and individuals that buy the recycled material and use this material to make new products (not including combustion for energy).

This would mean that plastics could not be labeled as recyclable unless they had strong end markets (high value on the recycled material market). The result would be that the plastic industry would be incentivized to invest heavily in developing real end markets for recycled materials, and they would be disincentivized to produce a growing volume of virgin plastic resin.

It also would create a dynamic where MRFs could become profitable and financially stable (as many depend on subsidies and are on the verge of closing their doors). As this would be a big change, I would suggest that we phase into this definition over the course of a three- to five-year period.

Anything is possible when we work together

I wanted to share this idea with you all to inspire new ways of thinking and open up conversations around the definition of recyclable in the FTC Green Guides. The global plastic crisis calls us, the CPG industry, to come together and take real action.

We are a brilliant and capable community and together we can update our policies and systems to build a better world for our future generations. I hope you will join me in this work.

I encourage you to add your voice, and your thoughts, here.

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