London designer and entrepreneur, Yair Neuman, transforms waste spectacle lenses into works of art. “The idea started as an emotional reaction to seeing the waste”, said the Neuman in an interview with Optometry Today.
The Ontario government recently issued a draft regulation for hazardous and special products that would require producers of hazardous and special products, such as paints, pesticides, solvents, oil filters, antifreeze and pressurized containers, to collect, manage or promote the recycling or proper disposal of these products at end-of-life.
The proposed regulations puts more responsibility of producers for the waste generated from their products and packaging. It also envisions waste as a resource that can be recovered, reused and reintegrated back into the economy.
The proposed regulation for hazardous and special products (HSP) would require producers to:
Under a producer responsibility model for waste diversion, costs would be shifted from municipalities and taxpayers to producers that can better control costs through influence over:
This model would encourage producers to find new and innovative ways to reduce costs and improve the environmentally responsible management of materials.
The proposed regulation is based on the following principles:
The current Municipal Hazardous or Special Waste (MHSW) Program is scheduled to end on June 30, 2021. Ideally for the Ontario Government, that regulation will be replaced by the proposed Hazardous and Special Products producer responsibility regulation under the Resource Recovery and Circular Economy Act, 2016 (RRCEA). The new regulation is expected to be fully in effect on July 1, 2021, subject to all necessary approvals being obtained.
The Resource Productivity and Recovery Authority (RPRA) would be responsible for:
The Ontario government is seeking input on the draft proposed Hazardous and Special Products regulation. The sections below summarize key elements of the draft proposed Hazardous and Special Products regulation. For full details, please review the draft proposed regulation which is attached under “Supporting materials”:
The proposed regulation sets out a methodology for identifying producers who would be subject to the requirements under the regulation. This ensures that the person with the closest connection to the designated products is made the responsible producer.
The draft regulation proposes the following hierarchy to determine producer responsibility:
This producer hierarchy would not apply to either fertilizers or mercury-containing devices, such as thermostats, thermometers and barometers, where the Ontario government is proposing to only obligate brand owners – and not importers or marketers – as brand owners would be in the best position to oversee the implementation of a P&E program for fertilizers or the management of mercury-containing devices.
To reduce burden, the Ontario government is proposing to exempt producers that supply a relatively small quantity (weight) of HSP into the Ontario market from all requirements under the regulation , except for recordkeeping requirements, if their supply of HSP is less than or equal to the product-specific minimum thresholds, as defined in the proposed regulation.
The proposed regulation would transition the products managed by the current Municipal Hazardous or Special Waste (MHSW) program, with the addition of mercury-containing devices (i.e. thermometers, barometers and thermostats). The proposed regulation sets out four (4) defined categories of HSP, where each category includes different HSP as well as different responsibilities that the producers of the HSP must undertake:
The Ontario government is proposing that producers of Category A Products and Category B Products would be subject to registration, reporting and auditing/data verification requirements. Producers of Category C Products (i.e. mercury-containing devices) and Category D Products (i.e. fertilizers) would be required to register and report annually.
At a future date, the ministry intends to consult on what additional products could be added in subsequent phases of the regulation.
The proposed regulation requires producers of Category A Products, including oil filters and non-refillable pressurized containers, to meet management targets. These targets set out a minimum amount of HSP that producers need to collect and recycle, calculated based on the weight of these HSP sold into the marketplace, multiplied by the management percentage stated in the proposed regulation.
Only HSP processed by registered processors that meet defined standards and is sent to an end market within the performance period would count towards meeting a producer of Category A Product’s management target.
The proposed regulation would prohibit a producer from satisfying the management target by adding the weight of HSP that is land disposed.
Producers of the other categories of HSP would not be subject to management targets. However, producers of Category B Products and Category C Products would still be required to properly manage (i.e., recycle or dispose) any HSP that they collect or receive.
The proposed regulation requires producers of Category A and Category B Products to implement promotion and education programs to:
Producers of Category C Products would be required to implement promotion and education programs to inform the public that mercury-containing devices can be returned to municipal depots, select non-retail collection sites and collection events.
The government is also proposing that producers of Category D Products (i.e. fertilizers) be required to implement promotion and education programs to:
To support transparency and protect consumers from potentially misleading or inaccurate information, the Ontario government is proposing that sellers who impose a separate charge in connection to the sale of HSP be required to communicate:
The proposed regulation would require producers of Category A Products and Category B Products to establish and operate a robust, convenient collection network, including both collection sites and events, for consumers to return their HSP at end of life, free of charge. The regulation would set consumer accessibility requirements based on municipal population size and/or number of retail locations to ensure there are collection locations throughout the province, including northern and rural areas as well as Indigenous communities, while also providing producers with flexibility on how they may establish their system.
The proposed regulation would allow for a variety of options that producers can use to satisfy their consumer accessibility requirements. The Ontario Ministry of Environment, Conservation and Parks (MECP) continues to consider how to design an approach that would support an equitable number and distribution of permanent collection locations (for example, return-to-retail and municipal depots) and collection events. Producers can reduce their required number of permanent sites by implementing alternative collection options, such as call-in “toxic taxi”, mail-in, curbside collection services, or additional collection events. In addition, the MECP is considering an option which would allow producers to offset their required number of collection sites or events in certain municipalities with collection sites or events implemented in other municipalities where collection sites exceed the minimum regulated requirements. This could allow for greater flexibility for producers to use existing sites to offset requirements for establishing new sites and reduce burden. The MECP is considering appropriate conditions to limit the application of offsets to ensure that Ontarians will still have convenient access to collection options. This proposed option is not reflected in the draft regulation which accompanies this posting.
The proposed regulation would include service standards for the various collection options (e.g. hours of operation, types and amounts of materials to be collected) to ensure a level playing field in the service provided.
Producers would have 18 months to establish their collection network and obtain MECP approvals where necessary, while they would be required to maintain the current number of collection sites and events in each municipality, and current service levels.
The MECP recognizes that environmental compliance approvals (ECAs) are required for collection sites in order to receive certain types of HSP (e.g. oil filters, antifreeze, oil containers, solvents and pesticides). Through a separate process, the ministry intends to consider ways to streamline approval requirements by proposing and consulting on amendments to Ontario Regulation 347 (General – Waste Management), made under the Environmental Protection Act, that would make it easier to implement collection sites for HSP that is destined to be sent to a recycling or proper disposal facility.
The proposed regulation would require producers of all categories of HSP, voluntary organizations, producer responsibility organizations and certain service providers (i.e. haulers, processors and waste disposal companies) to:
In order to reduce burden, the Ontario government is proposing that collection site operators (e.g. municipalities and retailers) do not need to register and report to the Authority, although they would still be required to keep records related to HSP at their site.
The proposed regulation would require producers to have an independent audit conducted annually by a certified accountant or verification via internal attestation to verify sales data.
The proposed regulation is posted on the Environmental Bill of Rights Electronic Registry for comment until March 28th, 2021. The MECP will also hold consultation sessions in the coming weeks to seek stakeholder feedback and input on the proposed regulation.
CHAR Technologies Ltd. (TSX Venture Exchange: YES) recently announced it has raised CDN$6,000,000 in a non-brokered placement.
CHAR Technologies is an Ontario-based cleantech development and services company, specializing in high temperature pyrolysis, converting woody materials and organic waste into renewable gases and biocarbon.
Andrew White, CEO, CHAR Technologies Ltd.
“We were very pleased with the overwhelming interest and exceptional investor support in the offering which had substantial demand beyond the placement size. We had significant institutional participation and interest,” said Andrew White, CEO. “The proceeds will not only strengthen our financial position but will also enable us to capitalize on the growing number of opportunities emerging in the Clean Tech sector for our products and technologies.”
CHAR intends to use the net proceeds of the Offering primarily for working capital needs with anticipated contracts, project development activities and investment in technology initiatives.
CHAR Technologies Ltd. is a cleantech development and services company, specializing in high temperature pyrolysis, converting woody materials and organic waste into renewable gases (renewable natural gas and green hydrogen) and biocarbon (activated charcoal “SulfaCHAR” and solid biofuel “CleanFyre”). Additional services include custom equipment for industrial water treatment, and providing services in environmental compliance, environmental management, site investigation and remediation, engineering and resource efficiency.
In partnership with McMaster University and the University of British Columbia, Vitacore Industries Inc. has launched Canada’s first single-use mask and respirator end-to-end recycling program aimed at reducing the environmental impact of single-use PPE. The pilot program officially launched across Metro Vancouver in February and provides PPE recycling bins at long term care and urgent care facilities at no cost including City Centre Urgent and Primary Care Centre in downtown Vancouver and North Vancouver Urgent and Primary Care Centre. This program provides front-line workers with the opportunity to recycle their single-use face masks and CAN95 respirators and will be expanded nationally to include bins across the country.
Once collected, the single-use masks and respirators are sterilized by Vitacore before being sent to McMaster University to be broken down and repelletized. Polypropylene, the plastic used in single-use masks and respirators, will be given a second life as construction materials to reinforce concrete or siding for buildings and reduce the amount of waste heading to landfills. Furthermore, to expand the possible uses for the repelletized materials, ongoing research is still being conducted by McMaster University.
According to Vitacore president Mikhail Moore, “Over 63,000 tons of Covid-19 related single-use masks and respirators will be used over the next year in Canada, significantly contributing to the pollution in our landfills and oceans. Vitacore is committed not only to providing the highest quality PPE to Canadians, but also to a sustainable future”.
“From product conception to point-of-use and disposal, we are developing a blueprint for maximizing sustainability in the life cycle of polyolefin-based PPE products.” Says Yang Fei, director, Research and Development at Vitacore.
“Environmental sustainability is one of the thematic pillars for research at McMaster’s Centre of Excellence in Protective Equipment and Materials (CEPEM). This project illustrates the innovative approaches the centre is taking, along with partners such as Vitacore, to advance long-term sustainable use of PPE by the public and healthcare workers,” says Ravi Selvaganapathy, CEPEM’s director and Canada Research Chair in Biomicrofluidics. This month, CEPEM received $1.2M in funding from the Government of Ontario to expand its testing infrastructure and partnerships with Canadian companies, such as Vitacore.
The Government of Canada recently announced it was providing $95,000 in financial support to the Aurora Research Institute, in association with Delta Enterprises, a Gwitch’in owned company, to study the potential of converting waste cardboard into pellets as biomass feedstock for heating homes and businesses throughout Inuvik.
Northern communities are looking at ways to reduce their reliance on diesel for heating and electricity by increasing the use of local renewable energy sources and improving energy efficiency. The goal of the project is to eventually build a facility that will take up to 60 per cent of the community’s cardboard bound for the landfill and instead, recycle it into heating pellets, thereby supplementing Inuvik’s biomass pellet supply and reducing reliance on fossil fuels used for heating.
Converting the cardboard to pellets and then burning the pellets to generate heat and electricity results in lower greenhouse gas emissions than disposing of the cardboard in landfill.
By supporting an emerging northern biomass industry, the Government wants to create local jobs, transition to clean energy and keep investments in the North by using local resources and building a regional economy. This will support healthier, more sustainable communities, across the North.
The funding for the study is through the Northern Responsible Energy Approach for Community Heat and Electricity program (Northern REACHE). This investment is part of Canada’s nearly $700 million commitment to help rural and remote communities get off diesel, through programs delivered by Natural Resources Canada and Infrastructure Canada.
The Government of Canada and the Federation of Canadian Municipalities (FCM) recently announced the investment of $9.1 million for a project the will reuse residual materials in the eco centres of the Regional Municipal County (RMC) of La Rivière-du-Nord. The funding is through the Green Municipal Fund (GMF) which supports more sustainable communities. The GMF is funded by the Government of Canada and delivered to municipalities by FCM.
Thanks to this funding, the RMC de La Rivière-du-Nord will be able to develop better management of residual materials, mainly by significantly reducing landfill sites and recycling residual materials on its territory. Currently, the RMC manages four eco centres that recover 900 tons of residual materials per year, and only materials that are in a condition to be resold are accepted. The funding will enable the RMC to build new infrastructure, including a reuse shop and a new energy-efficient eco centre in Saint-Jérôme, to optimize the Saint-Hippolyte and Prévost eco centres, and to treat construction, renovation and demolition residues as well as non-reusable materials.
“In collaboration with the Federation of Canadian Municipalities, the Government of Canada is helping communities reduce their carbon footprints and operate more efficiently”, said Stéphane Lauzon, Parliamentary Secretary to the Minister of Seniors and Member of Parliament for Argenteuil-La Petite-Nation. “These pilot projects will help municipalities become more eco-efficient, improve the quality of the environment, and offer citizens access to greener services, equipment and tools.”
The expected environmental benefits of the project include the diversion of 900 tonnes per year of waste from landfill, increased recovery rates for the RMC from 60 to 66%, the retention of rainwater to suspended materials in stormwater runoff by 43%, and energy savings in the operation of 25%.
The project is expected to result in an operating cost savings from $991/tonne in 2019 to $226/tonne in 2021. It will also provide a diversification of revenue sources with the contribution of the IC&I, contractor, and retail sectors.
Depending on the success of the project, there is potential for it to be replicated by municipalities in Quebec and across Canada.
“GMF is focused on local sustainable development projects that improve the quality of life of our citizens, and this project directly meets this goal,” stated Scott Pearce, FCM Third Vice-President and Mayor of the Township of Gore. “The new eco centres are an important step in adopting sustainable measures in the region. Reducing the amount of residual material going to landfill is not only good for the environment, but also helps people live healthier and build more sustainable communities.”
Bruno Laroche, Prefect of the RMC of La Rivière-du-Nord and Mayor of Saint-Hippolyte stated: “The success of reuse in the eco centres managed by the RMC of La Rivière-du-Nord is already known throughout the province. Optimization of the network will not only make it possible to maintain this momentum, but also to recycle construction materials, which account for nearly half of the generation of residual materials on the territory. This funding represents both a recognition of the efforts made and a boost to continue improving performance and achieving the objectives of the RMC’s residual materials management plan.”
The GMF is a $1-billion program funded by the Government of Canada and delivered by FCM. Since 2000, GMF has helped bring over 1,360 projects to life. GMF supports local innovation that can be replicated and scaled up across the country to tackle Canada’s climate challenges.
Written by Jonathan Cocker, Partner, BLG LLP
The push to overhaul the use of conventional plastics with bio-based and/or biodegradable alternatives is supported by many multi-national companies, particularly in the various consumer goods industries.
Therefore, international standardization of the bioplastic packaging or (single use) product content is seemingly foreseeable, if not inevitable. However, recent legal initiatives looking into this previously unregulated sector suggest bioplastics specifications will be based upon actual recovery in the communities in which they are waste-managed, turning a global development into a very local concern.
The European Commission (EC) has been actively investigating the value of bioplastics under various end-of-life processes in an effort to capture the actual movement of such materials within Europe. In December 2020, the EC issued Biodegradability of plastics in the open environment, containing recommendations by an independent scientific advisory group looking at the performance of BDPs where no dedicated processing (such as in-vessel composting) has been applied.
The recommendations constrain the promotion of BDP and require performance verification based upon the particular waste management environments in which they are processed. These recommendations include:
As the EC is aware from its ongoing assessment of compostable/biodegradable plastic packaging standard CEN 13432, processing of waste, even industrial composting activities, differs among E.U. members, making the “specific open environment” a domestic designation at best.
Similarly, Japan recently issued a Bioplastic Introduction Roadmap specifically tied to growth of “sustainable bioplastics” driven by a national plastic resource recycling strategy. The roadmap focuses on switching from fossil fuel to biomass-based polymers, specifically plant-derived inputs, reflecting the availability of local resources.
Manufacturers of products using plastics, such as containers and packaging, plastic shopping bags, electrical and electronic equipment, clothing, footwear, furniture and toys, are to introduce biomass content into their products, with the coincident growth of recycling infrastructure to match this material profile. Concerns over international compostability standards and certifications are secondary to Japanese resources and their recovery.
The country’s Zero Waste Plastic Initiative is funding an assessment of the performance of certain “compostable” bioplastics in both aerobic and anaerobic organic waste facilities, recognizing that plastic waste frequently contaminates organic waste streams, particularly residential source-separated “green bin” organics. In doing so, locally-demonstrated resource recovery is prioritized over international bioplastics standards:
While national and international certification standards exist, meeting those standards does not necessarily ensure that Compostables can be properly managed after reception of the source separated organics, including Compostables, at Ontario’s aerobic composting or anaerobic digestion facilities.
A similar study was funded last year by the EC and found the demonstrated value of compostable plastics in these processes to be “sparse and inconclusive”.
While there are significant growth projections for bioplastics and plans for further standards developments, such as under the EU Circular Economy Action Plan 2020, obtaining product certification under an international regime will not necessarily mean acceptance in any domestic market. Instead, demonstrable performance of the bioplastic within existing local waste management infrastructure will ultimately be needed.
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Jonathan Cocker, a Partner at BLG LLP, provides advice and representation to multinational companies on a variety of environmental and product compliance matters, including extended producer responsibilities, dangerous goods transportation, GHS, regulated wastes, consumer product and food safety, and contaminated lands matters. He assisted in the founding of one of North America’s first Circular Economy Producer Responsibility Organizations and provides advice and representation to a number of domestic and international industry groups in respect of resource recovery obligations.
The Manitoba government is launching a unique $1-million Green Impact Bond that will support projects that help divert organic waste from landfills, create green jobs and reduce greenhouse-gas (GHG) emissions.
The Green Impact Bond is a finance tool to fund impact-driven projects, enabling the government to rapidly innovate and implement new solutions for organic waste and GHG emissions while sharing risks with the private sector. This tool brings the public, private, non-profit and charitable sectors together to develop innovative solutions to complex problems that have not been solved by one sector alone. Through the Green Impact Bond, a service provider is to meet agreed-upon outcomes for organic waste diversion, job creation and GHG reduction. Investors will provide up-front funding to the service provider. A third-party evaluator will determine whether the outcomes have been met and the return on investment to be paid by the province.
Waste and landfills account for 3.3 per cent of Manitoba’s annual GHG emissions. Manitoba’s landfills are approaching capacity and by some estimates, approximately 40 per cent of their waste is organic material. Organic waste produces methane, a harmful GHG, so diverting organic waste from landfills will reduce emissions, contributing to the Made-in-Manitoba Climate and Green Plan and Carbon Savings Account.
Innovative NRG, a Manitoba waste-to-energy company, has been chosen as the Green Impact Bond service provider. The company will use its patented and proprietary innovative technology, branded as Rapid Organic Conversion (ROC), to process organic waste such as animal byproducts and waste-water sludge through a gasification process. The ROC technology is a made-in-Manitoba innovative, clean-tech solution that vaporizes carbon-based waste material. Thermal energy released in the process is captured and can heat buildings or water for industrial uses, thereby reducing the use of fossil fuels. Waste-to-energy can be appropriate for materials that do not have landfill diversion options such as recycling. Innovative NRG’s waste diversion units will be installed in the rural municipalities of Cartier and Rossburn, as well as in the town of Carman.
“We need to take steps to prolong the lifespan of our landfills and this Green Impact Bond provides a great opportunity to reduce organic waste while growing Manitoba’s green economy,” said Conservation and Climate Minister Sarah Guillemard. “By reducing organics in our landfills, we lower the production of methane and create new, clean-growth job opportunities.”
The concept of impact investment is growing globally. The Green Impact Bond creates a unique investment opportunity for those committed to driving environmental change. Organizations can now support transformational work while investing at competitive rates in Manitoba, Families Minister Rochelle Squires noted. The Manitoba Department of Families includes the Social Innovation Office.
“Our ROC innovation represents a leap forward in reducing GHG emissions and costs, disrupting the existing centralized waste landfill disposal system by locating ROC plants at commercial operations sites to recover their waste energy profitably,” said Del Dunford, CEO, Innovative NRG. “By eliminating the need to transport waste to landfills, we eliminate the cost and GHG emissions from transportation and landfilling, and take advantage of a renewable energy resource for economic development in remote and northern Manitoba communities.”
Investors with an interest in supporting leading-edge environmental projects are invited to learn more by emailing [email protected] and visiting www.manitoba.ca/sio.
Written by Calvin Lakhan, Ph.D., Faculty of Environmental Studies at York University
In a recent review of New York State’s proposed Extended Producer Responsibility (EPR) legislation, I was taken aback by the sheer number of materials that were included (more than 30 individual materials in all) – it included everything from the conventional (newsprint, magazines, corrugated cardboard, aluminum cans) to the obscure (Multi-layered and flexible packaging made out multi resin products like LLDPE, PCV and PS), and even things we know not to be recyclable (BPA, Compostable Plastics, Polycarbonate and Lexan).
While surprising, I can’t say that it was entirely unexpected. New York State is merely following the lead of jurisdictions such as Ontario, which have decided to adopt the “Kitchen Sink” model towards printed paper and packaging recycling, and attempt to recycle everything, everywhere, in order to make recycling simpler for households.
It’s an extremely easy story to sell to the public, more recycling is obviously good, and the companies who produce the packaging will need to figure out a way to recycle it effectively. While the latter comment touches on the topic of extended producer responsibility, which is not what this article is about. Rather, I want to remind readers that not all recycling is created equal, and the “Kitchen Sink” approach being proposed by New York State (and other jurisdictions), is not sustainable, and unequivocally does more harm than good – economically, environmentally and even socially.
The endogeneity hypothesis
Whenever I refer to the “endogeneity hypothesis”, I am often met with blank stares. In its simplest terms, endogeneity (in this specific context) refers to when variables within a system are interrelated – the existence of variable A, impacts variable B, which in turn, affects variable C. This is a gross oversimplification of a rather complex issue, but I do so to illustrate a broader point: What we decide to accept in our recycling bin will not only influence our ability to recovery these materials economically, but also affect the recycling performance of individual materials that make up the recycling program.
What policy makers and advocates of the “Kitchen Sink” approach fail to recognize is that waste management infrastructure (including the development of downstream processing and end use applications) was largely designed around “core materials” – These materials, which are characterized by high levels of recyclability, stable revenue, strong end market demand and are accepted in most municipal recycling programs: Newsprint, Other Paper (Magazines, Office Paper etc.), Corrugated Cardboard, Boxboard, Gable Top Cartons, PET bottles, HDPE bottles, Aluminum Cans, Steel Cans, and Glass* (glass cullet is generally not considered a core material due to poor end market demand). While the proliferation of light weight and composite packaging has spurred innovation in the waste management sector, it would be a gross overstatement to say that these materials are readily recyclable. Recycling of flexible plastic and composite plastic packaging in particular are still in its most nascent form – research for this article could only find a handful of pilot projects (across North America) where recyclers are accepting composite and flexible packaging to be tested for chemical recycling and waste to fuel.
But what does any of that have to do with the “endogeneity hypothesis”? For every additional “non-core” material added to the recycling program, not only do the costs of the entire program go up, the costs of managing individual materials within the program go up. Materials that are difficult to sort and/or recycle have an adverse impact on all other materials being managed within the same system – this is particularly true of single stream recycling systems. The more materials accepted by a program, the greater the number of types of materials inbound into a material recycling facility. If a MRF is not configured or cannot be readily retrofitted to efficiently sort materials that fall outside of the “core material” categories, it increases both the sort time and cost of managing *all* materials, irrespective of whether it is newsprint or a multi-laminate plastic.
In essence, the decision to attempt to recycle everything not only radically increases the costs of a recycling system that was never intended to capture these materials, but it poses an externality on the materials that were already being recycled. It makes the cost for all participants within the system more expensive, a somewhat perverse outcome given that we are trying to encourage producers who use readily recyclable packaging.
What are we trying to achieve again?
When writing these articles, this is a question that I often return to – largely because I don’t think a clear answer has emerged. Based on what I am seeing in the latest legislative developments in both Canada and the United States, it appears as though increasing recycling rates may be the end goal. It’s a “Do good, feel good” activity that people can readily get behind – I agree with half of that statement.
It certainly is a feel good activity, but whether it “does good” is highly questionable. I have repeated time and time again that not all recycling is created equal – decision makers are not oblivious to this, as there was a time when certain municipalities were considering *contracting*the list of accepted materials due to the issues that it posed within the recycling system.
So why the sudden 180 degree turn – in fairness, one part of that is consumer driven. Telling households not to recycle is walking back on years of environmental messaging, and can serve as a significant source of confusion/contradiction. The second part has to do with “who pays for the system”. Municipalities were very interested in booting materials out of the Blue Box when they paid for half of the cost. However, under a 100% EPR system, the same people who wanted me to find out how to get LDPE film and Polystyrene out of the program, are now calling for producers to pay their fair share for keeping materials out of landfill.
Not all recycling is created equal
While I obviously have very strong feelings about the appropriateness of EPR for PP&P, and the efficacy of recycling in general, I want to leave you with the following. One is a tool that I had developed several years ago that allowed users to enter in either a goal recycling rate, or a goal carbon abatement target, and the model would automatically find the lowest cost way to achieve it by prioritizing the recovery of specific materials. The data is a bit outdated (2018), but the overall finding remains unchanged – it isn’t how much we recycle that matters, it’s what we recycle. The “optimized” scenario actually found that maximum carbon abatement was achieved by recycling *less* (in absolute tonnes) than what we do today, and at a lower cost. There is a decoupling of recycling rate performance and environmental impacts – no longer is recycling directly correlated with carbon abatement.
Beyond this tool, I also want to provide a material evaluation matrix that looks at the characteristics of each material being considered in the New York State EPR program. Please note that I have grouped all the sub-categories (i.e. flexible PET, flexible PP, Flexible PS) into one container category (flexible packaging). As best I could, I tried to mirror the proposed list to the ones we use in Ontario – the reason for that is that I wanted to give actual data for what the quantities and costs of recycling are in a program that has already implemented EPR.
The criteria I used to evaluate materials are based on:
· recovery rate,
· revenue received (using Ontario price sheet)
· cost of recycling, (using the SO Pay in Model)
· Is the material accepted in most programs?
· Is there available recycling infrastructure?
· Is there end market demand?
· Carbon abated per tonne recycled (by material) (EcoInvent)
· Carbon impacts per tonne landfilled (by material) and (EcoInvent)
· Money spent on recycling to abate one tonne of carbon (by material).
I have always felt that the last metric is the most important – how much would you have to spend recycling something in order to abate one tonne of carbon? If you refer to the second worksheet (“Cost of Carbon”) it quickly becomes apparent that some materials make virtually no sense to recover given how much you have to spend to achieve a given environmental goal, i.e. $1856.14/TCO2e for plastic laminates.
It is critical that decision makers use data and evidence to guide their decisions, and not rely on emotionally or politically driven narratives. Jurisdictions are tripping over each other trying to push forward with EPR legislation for packaging waste, but it is of paramount importance that we proceed with caution and question the approach we are taking and explore potential alternatives. Producers also need to understand that EPR systems prioritizing recycling based outcomes is likely to have many adverse impacts that need to be better understood. Now more than ever, producers cannot resign themselves to playing a passive role in legislative discussions.
Recycling is a wonderful thing, but it is not the only tool in our tool box. In fact, it should be one of our last resorts when we cannot find ways to achieve waste reduction (i.e. package light weighting) or adopting systems that make reuse easier.
There will be many people that disagree, but I encourage you all to look at the data, and see what conclusions you reach.
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