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Key Issues

Extended Producer Responsibility

In 2010, 87% of Americans had access to curbside and/or drop-off paper recycling, resulting in a record 66.8% (or over 52.7 million tons of the paper) of paper recovered for recycling in 2011. Most surprising is that this success was achieved by an inexpensive volunteer effort driven by industry leadership groups. Even so, environmental groups are now proposing to increase recycling rates even further by implementing complex and expensive product stewardship programs, such as Extended Producer Responsibility (EPR), a system that obligates manufacturers to assume the costs of managing their own product and/or packaging waste.

Simply put, EPR legislation aims to shift the responsibility for “end-of-life” products and/or packaging from a municipality to those who create and use the packaging. While at first blush this might sound like a good idea, EPR programs are complicated, impractical, and expensive to implement, especially for inherently sustainable packaging substrates such as paperboard.

Even more concerning is the confusion that will result when only some states have an EPR law in place. For instance, in a common scenario, a converter in one state could produce a box that a brand owner in another state uses to package cereal that is sold by a retailer in a third state to someone who lives and/or consumes it in a fourth. How is it to be fairly determined who, exactly, is financially responsible for a product or packaging’s collection and how is the box producer or the cereal manufacturer to recover it?

Additionally, the EPR fees that will be imposed on brand owners will inevitably be passed along to consumers through higher product costs. Increased costs generally serve to decrease sales; if sales drop significantly, brand owners may be forced to lay off staff in order to remain profitable, thus adding to the high unemployment rates currently plaguing our country.

While some may feel EPR would help increase paper recovery from its current high level of almost 67%, when analyzed closely, imposing strict mandates, penalties, and fees only threaten to dismantle our current effective voluntary collection and recycling of paper and paper-based packaging. Our existing voluntary program is not only a success but is also improving every year: the volume of paper making its way to landfills has declined by more than 50% since 1990 and we are poised to far exceed our goal of 70% paper recovery by 2020.

In comparison, the recovery rate of other substrates is dismal: 27% for glass, 20% for aluminum, and a mere 8% for plastic. Given the disparity in recycling between paper and paper-based packaging and other substrates, how could EPR’s one-size-fits-all approach produce equitable results? Simply put, when it comes to paper, EPR is a solution looking for a problem.

The paper and paper-based packaging industry is not opposed to exploring new and creative ways to increase recycling and reduce waste. But with our existing market-based system yielding unparalleled results, the bar is set high for any option to exceed current rates. Although a well-intentioned idea, to think that arbitrary decisions made by state or federal government agencies will significantly improve paper recycling rates without adding burdensome costs to the management and implementation of such a program, defies credulity.

What Can I Do?

Submit letters to the editor or op-ed pieces to local newspapers and trade journals to remind your community leaders and state legislators about the sustainable nature of paper and paperboard. Remind them that 87% of the U.S. population has access to curbside or drop-off paper-based recycling programs and that the Federal Trade Commission has authorized packaging companies to use a recyclable logo on most paperboard packaging as a way to encourage consumers to recycle their used packaging. For more info on PPC’s recyclable logo for paper-based packaging, visit paperbox.org/recyclable.

Finally, reiterate the paper industry’s environmental success story—that in 2011, a record 66.8% (over 52.7 million tons) of paper was recovered for recycling, which is in stark contrast to the recovery rate of other substrates: 27% for glass, 20% for aluminum, and a mere 8% for plastic.

If EPR legislation is introduced in your state or community, contact your legislators to point out that any EPR legislation that includes paper and paper-based packaging has the potential to be economically damaging to your business. Then describe your belief that market forces should determine where recycled materials should go and suggest that further support be provided to our existing voluntary community recycling programs.

Finally, if an EPR program appears to have gained enough traction to actually become a law in your state, respectfully request that paper and paper-based packaging be exempt from the legislation.


Pioneer Packaging's EPR Statement (pdf)

AMERIPEN's 2013 Packaging Recovery Report recommends not EPR but a combination of other existing programs