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Advocacy Agenda: Sustainability & The Environment

The U.S. scrap recycling industry’s significant contributions to environmental protection, resource conservation, and sustainability can be enhanced by government policies (e.g., incentives for technology, a recognition that scrap is not waste and recycling is not disposal, etc.) that understand, recognize, and promote these benefits and their growth.

With the industry recycling more than 130 million metric tons of commodity grade materials each year to transform outdated or obsolete products and materials into useful raw materials needed to produce new products, recyclers offer real sustainable solutions for balancing economic growth and environmental stewardship. ISRI uses its voice to help policymakers understand and develop legislation, regulation, and policies that:

  • Recognize Scrap is Not Waste/Recyclables are Not Waste. ISRI seeks enactment of language in federal and state laws that specifies “used or recyclable metals, electronics, paper, plastic, glass, rubber, and textiles that are destined for reuse or recycling as valuable commercial commodities are not, and shall not be, deemed to be solid waste under any provision of law” to combat impediments to recycling and trade through persistent attempts at misidentification of recyclable materials as solid waste (and even hazardous waste). We also seek clear, written guidance from the EPA Administrator to the Regions and state authorities stating that scrap commodities destined for recycling are outside of and excluded from, the RCRA Subtitle D definition of solid waste and call for the EPA to seek opportunities for improving metrics to measure municipal recycling.

     

  • End Uncertainty over the Use of Recycled Crumb Rubber in Artificial Turf. Use of recycled crumb rubber is being questioned by the public despite over 100 scientific studies concluding that recycled crumb rubber does not pose elevated health risks to athletes using such fields. ISRI monitors the occurrence of legislation at the state and local levels and coordinates member testimony and resources for presentation to policymakers in support of the use of synthetic turf made with crumb rubber.

     

  • Stop Materials Theft through Effective Legislation and Outreach Initiatives. ISRI aggressively pursues outreach with law enforcement, prosecutors and local communities to promote even enforcement of existing metals theft laws, including providing valuable tools to assist in the fight against metal theft, while taking measures to protect the confidential business and personal information collected, so that it is only used by law enforcement and then only for materials theft issues.

     

  • Oppose Extended Producer Responsibility (EPR) Systems that Interfere With and Disrupt Existing Viable Markets. As EPR proposals continue to pop up throughout the states, ISRI will advocate that such proposals recognize the existing recycling infrastructure and are limited to products for which markets have not yet matured. In fact, ISRI supports ending producer responsibility and government-imposed fees as soon as practicable once such markets mature and are economically sustainable.

     

  • Provide Support for Advanced Manufacturing. ISRI supports continued federal funding for U.S. government-led public-private partnerships focused on research and development of innovative technologies and implementation of ISRI’s Design for Recycling® principles. The Department of Energy’s Advanced Research Projects Agency-Energy (ARPA-E) supports a number of cutting-edge projects, including with ISRI members, to develop and commercialize advanced material-separation technologies unlocking value that would otherwise be unrealized.ISRI also continues its active role with the Institute for Reducing Embodied-energy and Decreasing Emissions (REMADE) in Materials Manufacturing, a five-year public-private partnership supported by federal matching funds to support industry-relevant projects that drive down the cost of technologies for reusing, recycling, and remanufacturing metals, fibers, polymers, and used electronics.

     

  • Exempt Recyclers from Liability under State Superfund Laws. ISRI continues to identify opportunities for enacting state superfund relief for recyclers (such as SREA) in as many states as possible to remove the threat of third-party liability.

     

  • Ensure the Quality of the Recycling Stream through Proper Collection Systems. ISRI strongly opposes any attempt through legislation to offer tax incentives for, or otherwise require consolidated “mixed-waste” collection, (i.e., “One Bin,”) by raising awareness of the hazards of collecting trash and recyclables together in one bin, and the fallacies of viewing the matter through the narrow lens of economic savings to municipal solid waste programs at the expense of available quality raw material feedstock to U.S. manufacturers.

     

  • Reduce TSCA Impacts on Recycling and Reuse. ISRI proactively engages the EPA and monitors the Toxic Substances Control Act (TSCA) regulatory activities for their potential or actual negative impacts on recycling and reuse, including burdensome information reporting and retention requirements, challenging threshold requirements for the presence of DECA flame retardants in used electronics and inadvertent illogical requirements on imported scrap metal that ISRI has been working to eliminate.

     

  • Reform Citizen Suits Provisions in the Clean Water Act to Prevent Abuse. ISRI seeks modifications to the Clean Water Act’s citizen suit provisions to prevent frivolous and unfounded lawsuits, many of which have been filed for enrichment rather than as the Act originally intended.

     

  • Protect Recyclers from Liability from new Chemicals of Concern. Classifying chemicals of concern (COCs) – such as per- and polyfluoro-alkyl substances (PFAS) – as hazardous could subject scrap yards to new and inapplicable permitting requirements, potential cleanups, restrictions on materials received and recycled daily, and potentially improperly regulate outgoing scrap commodities. There are numerous federal and state bills and amendments containing PFAS provisions, including in food-grade packaging or that arise from TSCA activities that ISRI must monitor for potential improper liability shifting to member companies.

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