In its September 2019 comment, SGIA listed several key concerns with the proposed framework. One concerning the definition offered on “readily recyclable” that lists specific materials. By listing only specific materials, we feel that the state has already shut the door to any new materials that are developed that could also be recycled by either current technologies or emerging recycling technologies, such as chemical recycling. While the definition does state “...not limited to...”, the question remains how will state determine if other materials are readily recyclable? Will this involve a regulatory process? Is there any interest on the part of the state to explore compostable packaging? And, if so, how would this fit into the current program development?
SGIA continued that these questions do bleed over into the discussion points related to costs and funding. If materials are developed that can be recycled by means that are not currently employed by municipalities, will the program then ask the municipalities to invest in future recycling technologies that would accept these new materials? We ask this question as we believe one fundamental outcome of these programs is the development of new materials that can be recycled, possibly by different recycling technologies. An example is the increased emphasis on the use of compostable packaging.
SGIA concluded by stating that we believe that in order for this program to truly succeed it needs to have the ability to change and adapt as the recycling landscape changes.
For more information on this topic, please contact SGIA’s Government Affairs Department at email@example.com.