PRINTING United Alliance Provides Comments on EPA’s Comprehensive Procurement Guideline (CPG) program

Due to the current problems with solid waste and need to increase recycling, EPA has asked for feedback on its Comprehensive Procurement Guideline (CPG) program. The CPG program is designed to promote the use of materials recovered from the municipal solid waste stream by designating products that are or can be made with recovered materials. Once a product is designated, procuring agencies are required to purchase it with the highest recovered material content level practicable. EPA publishes recommended recycled-content levels in a Recovered Materials Advisory Notice (RMAN).

EPA has designated 61 items in eight product categories in a Comprehensive Procurement Guideline (CPG) and has issued recycled-content recommendations and procurement specifications for these items in a series of Recovered Materials Advisory Notices (RMANs). EPA last updated the CPG/RMANs in 2007. This request for comment is the initial step in updating these documents.

The categories in the current CPGs are:
- Paper and Paper Products
- Vehicular Products
- Construction Products
- Transportation Products
- Park and Recreation Products
- Landscaping Products
- Non-paper Office Products
- Miscellaneous Products.

On April 7th, 2020, EPA published a request for comment on the Existing Comprehensive Procurement Guideline Designations (CPGs)and Recovered Materials Advisory Notice Recommendations (RMANs). In response to the request for comments, PRINTING United Alliance submitted comments that included recommended additions to the existing CPG categories.

PRINTING United Alliance recommended that Textiles, Electronics, and Packaging be included as categories in the CPG. Products in these categories, of which we specified examples, can widely be made from recycled content. However, the demand for recycled materials is still extremely low. Designating textiles, electronics, and packaging as products that can be made with recycled content and specifying a recommended amount of recycled content to use in the manufacturing process of these products will drive demand for the collection of waste materials that will be recycled and incorporated into these products.

Furthermore, expanding the market for recycled content will reduce the cost of incorporating recycled materials, which will further incentivize buyers to purchase products with recycled content over those made with all virgin materials. In turn, higher demand in the recycled content market will provide recycling facilities with the financial ability to invest in new technologies or processes to better turn the hard-to-recycle products back into viable materials.

The comment period closed on July 6th 2020. If you have any further questions, please contact PRINTING United Alliance’s Government Affairs team at