Why Waste and Recycled Content Claims Are Material
Across the globe, in a wide range of industries, manufacturers are working to minimize waste and reuse materials.
For many years we have heard about closed-loop systems, in which waste from one process is the raw material for another. But across the global community of environmentalists, government, manufacturers, academia and other groups, the reward system has been inconsistently interpreted and applied.
There are few people who would argue that the minimization of waste is evil, but there is no common strategy to minimize waste among the community of stakeholders.
One of the main services UL Environment, where I used to work, provides is independent, third-party substantiation of environmental claims. One of the issues we faced, and this issue is exponential on a global scale for many others as well, is defining and substantiating claims for the use of recycled content in products. This is particularly true for the use of what is called pre-consumer (also known as post-industrial) recycled content, which is material that is recycled prior to reaching its intended end user.
While this may sound trivial, this accounts for billions of dollars worth of materials every year. It also is important for companies making environmental claims that are enforced by the Federal Trade Commission in the United States, as I have talked about in a previous article.
The difficulty with pre-consumer recycled content is in interpreting and applying the many definitions that exist.
The most commonly used definition can be found in the ISO 14021 standard; however the key challenge in interpreting this definition is with the sentence:
Excluded is reutilization of materials such as rework, regrind or scrap generated in a process and capable of being reclaimed within the same process that generated it.
My understanding of the intent of this sentence was that it was meant to exclude material that can easily be thrown back into a hopper at the beginning of a manufacturing process. So if material falls on the floor or emerges from a separate but related process, this definition would exclude those manufacturers that collect and add this material back into the same process.
But what about manufacturers who perform a significant amount of reprocessing on a material in order to reuse it in the same or a different process? Or manufacturers that come up with a new product formulation that can use the reprocessed material and find a market to sell it in? Are these considered to be recycled content?
As mentioned at the beginning, the common goal is to prevent waste materials from going to landfills or incinerators. So when a material destined for a landfill is instead used as a raw material in a new product, this new product should be considered to contain recycled content. Regardless of whether the material is a waste from an identical or similar product, the reprocessing of a material in order for it to be used in a closed loop helps us all achieve our common goal of reducing waste.
There are many people who will argue that this would allow manufacturers to claim credit and be rewarded for recycled content products when they are simply implementing good business practices to reduce cost. But this is irrelevant -- in fact manufacturers have a right to be rewarded monetarily for benefiting the environment, there is no better incentive I am aware of.
The question that should be asked is: Are manufacturers going out of their way and exuding effort to reuse materials that cannot be used for their original purpose? This question gets to the heart of our common goal of reducing waste.
Today UL Environment published a paper on interpreting pre-consumer recycled content claims. For those of you with an interest in this area or those that are implementing manufacturing processes to reduce waste, I invite you to read it and post your comments to Greenbiz.com under this article.
If we can all agree on our common goal, then the reward system we use to get there is secondary so long as it doesn't negatively impact the world around us.