AMBR comments on EPA Draft National Recycling Strategy

In December 2020, AMBR submitted comments on the U.S. Environmental Protection Agency on their draft National Recycling Strategy.

While AMBR is excited to see renewed focus by the EPA toward improving recycling and composting nationwide, we are disappointed to see many of the same ideas from decades ago re-emerging in this strategy. What we have learned in the past few decades, and especially in the past three years, is that voluntary initiatives and residential education programs are not enough to transform recycling into a financially sustainable, accessible system that drives toward a circular economy and a zero waste future. The EPA strategy needs to evolve to the new realities of the U.S. recycling system.

AMBR urges the EPA to adopt the following priority recommendations into our National Recycling Strategy, as outlined in our comments to the Agency:

Funding for and greater integration of recycling with national climate, environmental justice and healthy community initiatives, and for organizations working in those communities most detrimentally impacted by our current production facilities and waste infrastructure. Integrate principles of environmental justice into all aspects of decision making. This was noticeably absent in the strategy.
Leverage government procurement as a primary tool to drive end market demand for recycled materials, and prioritize locally and regionally owned infrastructure and end markets to maximize local economic benefits.
Focus on better product labeling and design guidelines as the primary strategy to reduce contamination in the recycling stream. The EPA’s strategy was focused on residential education, which is a useful tool, but we argued that people would be a lot less confused if there were more consistent product labels and if companies adhered to the recycling design guidelines published by groups like the Association of Plastic Recyclers.
Hold producers responsible for funding investments in recycling infrastructure through extended producer responsibility policies, rather than continuing to rely upon government funds to support recycling.
No federal funds for plastics to fuel or waste-to-energy projects.
Prioritize reuse, refill and waste reduction. The EPA specifically stated this was not part of this plan and was covered elsewhere, but we pushed that it needs to be a higher priority and that reduce, reuse and recycle should be integrated into one plan, rather than treated as separate strategies.
Focus educational resources on underserved communities and using tools created by people within underserved communities.