The U.S. scrap recycling industry’s significant contributions to environmental protection, resource conservation, and sustainability are dependent upon government policies that understand and recognize these benefits and that promote their growth. With the industry recycling more than 130 million metric tons of commodity grade materials each year, transforming outdated or obsolete products and materials into useful raw materials needed to produce new products, recyclers offer real sustainable solutions for balancing economic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 throughout the U.S. and state governments understand and develop legislation, regulation, and policies that:
- Recognize Scrap is Not Waste/Recyclables are Not Waste. Persistent misidentification of recyclable materials as solid waste, and even hazardous waste, impedes recycling at the federal, state, and local levels. Thus, preserving the gains made by the industry that scrap is not waste under Subtitle C of Resource Conservation and Recovery Act (RCRA) is critical for the industry, and we are continually looking for opportunities on the federal level and in the states to build on this success. Last year’s resolution issued by the National Lieutenant Governors Association expressing the importance of distinguishing recyclable materials from the waste stream when it comes to policy and regulations provides an additional path forward for ISRI.
- Provide Support for Advanced Manufacturing. Opportunities exist to increase recycling through U.S. government-led public-private partnerships focused on research and development of innovative technologies and implementation of ISRI’s Design for Recycling® principles. ISRI fully supports federal efforts in these areas, and their continued funding remains an absolute ISRI priority.
- ARPA-E: The Department of Energy’s Advanced Research Projects Agency-Energy (ARPA-E) supports a number of cutting-edge projects, including some involving ISRI member companies, on advanced material-separation technologies that otherwise might not be developed (or might be developed in other countries). Development and commercialization of these and other recycling technologies will enable more and newer types of materials to be recycled in the United States and unlock value that would otherwise be unrealized.
- REMADE: ISRI is excited to be part of the team working on the Department of Energy’s new Clean Energy Manufacturing Innovation Institute for Reducing Embodied-energy And Decreasing Emissions (REMADE) in Materials Manufacturing. REMADE is a public-private partnership supported by funding from the Department of Energy’s National Network of Manufacturing Institute (NNMI) program. REMADE exists to drive down the cost of technologies needed to reuse, recycle, and remanufacture materials such as metals, fibers, polymers, and used electronics. The REMADE Institute will help increase recycling activity for many materials at lower cost and create value throughout the economy.
- Exempt Recyclers from Liability under State Superfund Laws. Building upon recent successes in Florida and Tennessee, ISRI continue to identify opportunities for creating state SREAs (Superfund Recycling Equity Act) in as many states as possible to remove the threat of third-party liability for recyclers.
- 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 waste collection, i.e., “One Bin.” Specifically, ISRI actively pursues strategies to assist the industry in its efforts to increase attention to the importance of product quality in the recycling stream and to the detrimental impacts on manufacturing when quality is not taken into consideration. ISRI continues to raise awareness of this issue with policymakers at all levels of government, highlighting 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 (thus ignoring the loss of quality raw material feedstock to paper mills and other industrial consumers of secondary commodities and the economic harm that causes).
- Reform Citizen Suits Provisions in the Clean Water Act to Prevent Abuse. ISRI seeks modifications to the citizen suit provisions of the Clean Water Act to prevent frivolous and unfounded lawsuits. Over the years, we have witnessed increased abuse of Clean Water Act citizen lawsuits filed for enrichment rather than as the Act original intended. Many organizations have used publicly available databases to obtain information about regulated facilities and threaten to sue them under the Clean Water Act simply to extract sizable financial “donations” and “voluntary” actions from facilities not otherwise required by law to do so. These facilities settle simply to avoid the costs of litigation, while the organizations then use settlement donations to repeat the process on other facilities in a vicious cycle that was not intended by Congress. Only modification of the Clean Water Act can curb such abuse of citizen suits.
- Support Continuation of a National Mercury Switch Program with Incentives. With the National Vehicle Mercury Switch Recovery Program (NVMSRP) slated to end this year, ISRI encourages consideration of reinstating switch payments and the exploration of available avenues to keep the program operational into 2018 and beyond. The program’s viability is dependent on a number of factors, including EPA’s continued participation and whether continuation of the program would carry the same indemnifications that vehicle dismantlers, scrap processors, and others receive for participating in the current program.
- Protect Recyclers’ Right to Reuse and Repair. ISRI continues to quickly respond to all efforts to block recyclers’ ability to return products and goods back into the marketplace for legitimate reuse, including the right to market used products without warranty, provided all applicable legal requirements are followed by the recycler. This applies to many recycling sectors, including rubber, automotive, and electronics.