CAA lays out responsible end markets strategy

Circular Action Alliance, which has emerged as the primary U.S. packaging producer responsibility organization, aims to increase PCR utilization with strategies including verification of responsible end markets, according to the organization’s technical advisor.

Within that broader goal, CAA has several desired outcomes, including increasing supply, meeting end-market quality specifications, ensuring market demand and collection volumes match and maintaining a reliable and efficient natural flow within the system, according to Pierre Benabides, technical advisor for CAA and general manager for Canada’s Circular Plastics Taskforce. 

Benabides spoke at the fall member meeting for the Association of Plastic Recyclers. APR owns Resource Recycling, Inc., which publishes Plastics Recycling Update. 

The definition of responsible end markets varies among extended producer responsibility schemes. For example, Oregon describes a responsible end market as “a materials market in which the recycling or recovery of materials or the disposal of contaminants is conducted in a way that benefits the environment and minimizes risks to public health and worker health and safety.” 

CAA views responsible end markets as a means to support best practices in managing environmental, health and safety concerns, rather than an instrument to penalize minor errors by making end-users non-compliant, he said.

The considerations guiding responsible end market verification include requirements that vary based on locality, and concerns around sharing proprietary data. Nevertheless, existing systems could support responsible end market verification, Benabides said, but would require collaboration throughout the value chain. 

Verifying vs developing end markets

In explaining CAA’s strategy, Benabides began by differentiating between verifying end markets and developing them. 

Verification consists of auditing end-market facilities against “responsible” standards, ensuring compliance with laws and regulations, and measuring social and environmental impacts. With the CAA approach, a third-party auditor conducts these activities, to ensure confidentiality and impartiality.

In addition, he said CAA seeks to minimize the administrative burden on companies, and to leverage existing programs, such as PCR certification from APR that can be used to document the chain of custody.

In contrast, end-market development consists of increasing recycling facilities’ capacities to process more recovered materials in both types and volumes. Although each state that is implementing EPR has requirements for supporting end market development, the role of the PRO varies. In Colorado, the PRO must invest in market development, while in Oregon, the PRO must carry out practicable actions to support sectors meeting the responsible end market requirements. And in California, the PRO must support the establishment, expansion and continued existence of responsible end markets. 

In the EPR schemes it manages, the CAA will perform these activities, in collaboration with key partners.

Three-step verification

CAA views the responsible end market verification process as consisting of three steps: initial screening, ongoing data review and auditing, Benabides said.

First, CAA and MRFs will collect self-attestation forms from end markets, and they will provide an initial verification. Then CAA or a contracted certification body will review data each quarter to ensure that materials are going to verified responsible end markets. 

And finally, a contracted third party will verify compliance with responsible end market criteria, with an on-site audit every five years and annual desktop verification.

CAA will apply responsible end market verification criteria based on state requirements and material type; harmonize with existing certification programs; request exemptions when appropriate – for example, resins used in packaging for children’s products; and prioritize verification for overseas markets, which hold higher risk of non-compliance.

“The mission is to deliver best-in-class compliance for producers, but that could not be done without the help of the different stakeholders involved in the value chain, including you as plastic designers,” Benabides told the audience. He added that because packaging EPR and responsible end markets are new concepts, CAA seeks to gain industry feedback, with plans for a future webinar.

Seeking public input

CAA is seeking industry feedback for four proposed responsible end market criteria surrounding compliance, transparency, environmental impact and yield. 

In California, the period has been extended to Nov. 4 for public feedback on SB 54. Oregon accepted feedback on CAA’s draft proposal through Oct. 28, and is expected to post public comments soon. Next the Oregon Department of Environmental Quality will submit its own suggestions to CAA for revisions to the EPR scheme. Colorado and Maine are also in the midst of program plan development.