Several U.S. states, along with federal and provincial governments in Canada are considering policies that would make appliance manufacturers responsible for ensuring that the packaging used to ship their products is recycled. The proposals so far have focused heavily on reducing the prevalence of single-use plastic material.
AHAM recognizes the importance of finding solutions on this important environmental issue. However, there are significant differences between consumer and commercial waste. For example, on commercial waste, business have an inherent incentive to reduce waste and reuse materials. Furthermore, the United States lacks the recycling infrastructure needed to properly recycle single-use plastic waste.
Plastics’ benefit to society is indisputable, but reducing its environmental footprint requires sound public policy. AHAM is interested in being part of the solution and will support reasonable policies on plastics and recycling that are consistent with these key industry policies:
• Source reduction requirements must be realistic and consider whether viable alternatives exist.
• Policies must recognize the difference between consumer and non-consumer facing packaging.
• Extended producer responsibility (EPR) policies, which are supposedly intended to make manufacturers responsible for the costs of recycling, must give manufacturers the ability to exercise proper oversight without being required to give preferential treatment to existing partners, collectors, or municipal recycling programs during the EPR program’s design and implementation.
• Recycling infrastructure, which is currently inadequate to meet even current needs, must be improved.
• Post-consumer content (percentage of packaging made from recycled material) requirements must be realistic.
• Federal, state and local recycling policies must be harmonized.
• “Pay as you throw,” or other consumer recycling incentives are effective and should be part of any policy
Multiple stakeholders, including state, local and federal governments, must come together and identify responsible policy solutions that address this important environmental matter and recognize the role that manufacturers, businesses and consumers play in the delivery and disposal of consumer goods.
Some proposals go beyond packaging and seek to make manufacturers responsible for the cost of recycling the appliances themselves. Such policies are unnecessary and could create significant challenges for product design.
Major appliances are already recycled at a very high rate, driven by the market value of the metals used in their manufacturing. Only a small amount of plastic ends up in shredder residue, which is disposed of in landfills, often beneficially, as daily landfill cover.
The plastics used in appliances are often rigid mixed plastic, material for which there are limited end markets after it is recycled. In addition, some of the plastic contains flame retardants, which are necessary to comply with widespread safety standards. Enhancing or investing in new technologies such as chemical recycling could help address mixed plastics. However, these technologies have yet to demonstrate commercial viability.
Plastic recycling infrastructure must be modernized and expanded so that various and more challenging plastics can be more effectively recycled. Achieving increased diversion rates requires investment in additional capacity and technology across all recovery options.