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AMBR comments on recycled content standards developed by GreenBlue

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In January 2021, AMBR submitted comments to GreenBlue on the proposed Recycled Material Standard (RMS) which aims to help brands track, validate and communicate recycled material claims with a certified chain of custody.

AMBR sees value in the detailed and thorough verification and certification and Chain of Custody process developed by the RMS to build more accountability and transparency into the use of recycled content. Several of our comments speak to further ways in which the process can further support and expand the recycling industry. In addition, our comments are also rooted in a strong belief that there needs to not only be increased and more effective recycling, but also a reduction in the production of plastics overall. Recycling alone will not address the impacts of plastic production to both climate and human and environmental health. 

AMBR urges GreenBlue to incorporate the following recommendations into the RMS, as outlined in our full comment letter:

  • Require a cap on plastic production in the certificate trading scheme to drive reduction in plastic production. In order for the certificate trading system to be effective, it needs to be designed towards reducing the production of plastics overall, not just increasing recycled content when that means more plastics production. Reducing the cap over time will drive up the price of certificates which will, in turn, encourage manufacturers to use more recycled content rather than relying upon certificates.
  • Prioritize post-consumer recycled content. One of the primary goals of promoting the use of more recycled content is to drive investment and improvements in recycling collection and processing. However, post-industrial recycled (PIR) content does not support the expansion of curbside recycling programs or MRFs. Because there is such a significant need for increased demand and value of post-consumer content, AMBR strongly feels that this and any labeling standard or certificate trading scheme standard needs to prioritize PCR content over PIR content.
  • Require products to be compatible with recycling systems. Products using recycled content should also support the recycling system by following design standards, such as the APR Design Guides for plastics, to ensure the product itself can then be effectively recycled. AMBR would further support moving toward requirements that earning a recycled content label is contingent upon both the product and packaging actually being recyclable, which will further encourage producers to design for recyclability. 
  • Address social and environmental standards. Not all recycling is created equal, and the labeling standard and the certificate trading scheme should include specific social and environmental standards that an entity is audited to, particularly around safe working conditions, effluent and residual management, and toxicity.
  • Support for excluding waste-to-fuel projects. We strongly support the RMS in not allowing labeling and credit for any fuel products produced by recycled content.