Why Must Commercial Recycling Be Excluded from EPR Programs?
Including commercial packaging recycling in extended producer responsibility (EPR) programs would require businesses to pay into a system they do not use and do not need. It effectively charges them twice for recycling that is already happening.
When lawmakers consider EPR programs, it is critical to understand:
- How paper and paper-based packaging are already recycled today
- Where the real gaps in the system exist
What is Commercial Recycling?
Commercial recycling, for our purposes, refers to materials such as paper-based packaging collected from businesses for recycling. Businesses can include grocery stores, big box stores and more.
Businesses typically pay for recycling services by contracting directly with private recycling companies. Materials are collected separately from curbside household collection and residential drop-off programs. That keeps commercial materials cleaner and more consistent in type and quality.
This dramatically reduces contamination and allows paper to be efficiently recycled into new products.
How “Commercial Recycling” Gets Defined in Practice
In many cases, EPR legislation does not clearly define “commercial recycling.” Key details are often left to regulators to decide after a law is passed.
That means the scope of “commercial packaging recycling” can change during implementation of the law.
For clarity, this blog uses a practical definition based on how the paper recycling system works today. We define commercial recycling as materials collected from businesses through private recycling services, separate from residential programs.
Does Commercial Recycling Use Public Systems and Funding?
No, commercial recycling operates separately from residential recycling systems.
It does not rely on:
- City or county collection programs
- Taxpayer funded recycling infrastructure
- Public recycling education or enforcement
Businesses already pay directly for recycling services. The system is already built, functioning well and delivering strong results.
EPR Programs Must Exclude Commercial Packaging Recycling
EPR programs are designed to address challenges in residential recycling for hard-to-recycle materials like plastics.
Applying EPR requirements to commercial packaging:
- Duplicates cost, with no additional benefit for businesses
- Adds unrelated compliance burdens
- Disrupts efficient, established markets
But it does not:
- Increase paper recycling rates
- Improve material quality
- Expand recycling access
Most paper-based packaging from businesses is already recycled at very high rates through existing systems. Including it in EPR would require businesses to pay into a program they do not use, effectively subsidizing residential recycling without receiving those services.
Including it in EPR ultimately raises costs without improving paper recycling outcomes. As a result, Americans will ultimately feel the impact when shopping at the grocery store and for everyday necessities.
What Policymakers Must Consider
Many EPR frameworks already recognize that materials outside the residential system should be excluded when they are already being recycled at high rates.
As lawmakers evaluate EPR proposals, 3 considerations are important:
Keep the focus on residential challenges
EPR programs are intended to address gaps in household recycling, particularly for hard-to-recycle materials, like plastic.
Avoid shifting costs onto businesses unnecessarily
Commercial recycling systems are already funded and functioning. Including them risks duplicating costs without improving paper recycling outcomes.
Ground decisions in a full understanding of the system
Conduct and complete a comprehensive recycling Needs Assessment to better understand the current recycling system’s performance and avoid unintended consequences.
Keeping commercial recycling out of EPR ensures that policy solutions remain targeted and aligned with how recycling actually works today.