ISRI Submits Comments to EPA Regarding Draft National Strategy to Prevent Plastic Pollution

Aug 2, 2023, 17:02 PM
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Vicki Morgan
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On July 31, 2023, ISRI submitted comments in response to the U.S. Environmental Protection Agency (EPA) request for public comment on its Draft National Strategy to Prevent Plastic Pollution. ISRI’s comments applauded policies that prevent plastics pollution and promote a circular economy, as well as provided key recommendations.

“Plastics are an extremely diverse, resourceful group of materials used in our daily lives,” said ISRI President Robin Wiener. “Given the complexity of the recycling system and plastics in particular, there simply is no one single answer to the challenges facing plastics materials management in the United States. We applaud EPA for a proposed strategy that recognizes there are many solutions that, taken together, can make a significant difference in keeping plastic out of the environment and instead, circulate these valuable material resources into the manufacturing supply chain. We welcome the opportunity to further collaborate with the Agency and others to advance this proposed strategy.”

In its comments, ISRI provided key recommendations including:

  • Improve markets for recycling plastics through policies that do not interfere with existing efficient markets and encourage maturation of developing markets through technological innovation, incentives, and other efforts.
  • Encourage policies that incentivize manufacturers to design their products for recycling after their useful lives, to use greater amounts of recycled content in manufacturing, and to use recyclable and recycled content in packaging, provided there are no negative implications to the product’s recyclability.
  • As an alternative to full ratification of the Basel Convention, continued leadership of the U.S. government at the Organization of Economic Cooperation and
  • Development (OECD) on plastics-related issues in order to provide plastics recyclers with further legal clarity and access to global markets.
  • Explore continued federal funding for U.S. government-led public-private partnerships focused on research and development of innovative technologies and implementation of Design for Recycling® principles.
  • Explore development of an accredited, voluntary third-party certification program, such as or similar to the Recycling Industry Operating Standard (RIOS™), for plastics recyclers to increase the safe and effective management of plastics recyclables in the U.S. and strengthen the domestic manufacturing supply chain.
  • Exclude processes that convert materials to fuels, fuel ingredients, or energy from being considered as a recycling practice.
    Prioritize additional funding opportunities for recycling accessibility and infrastructure in under-resourced communities.

Excerpts from ISRI’s comments are below and full text of comments can be found here.

  • “ISRI represents the infrastructure through which the vast majority of recycled materials in the U.S. flow for processing into high-quality materials for manufacture into the everyday items and essential infrastructure that people depend upon. This infrastructure includes companies that process, broker and industrially consume metals, paper, plastics, glass, textiles, rubber, and electronics, whether sourced from commercial, residential, or industrial operations. It also includes those companies that manufacture and distribute optical and infrared scanners, balers, shredders, conveyors and other sorting, separation, and size-reduction machinery and transportation equipment that are used in all parts of the chain.”
  • “ISRI applauds EPA for proposing a strategy to improve post-consumer materials management, foster circularity, reduce pollution, and prevent the movement of plastics and other postconsumer materials onto the land and into our waterways and oceans.”
  • “ISRI believes that – once finalized, incorporating the input from ISRI and others – the proposed Plastics Strategy can help achieve the goals identified in the National Recycling Strategy and provide the guide for achieving circularity for plastics while reducing the pollution resulting from its mismanagement, over production, failure to consider recyclability at the point of design, and underinvestment in recycling infrastructure.”
On July 31, 2023, ISRI submitted comments in response to the U.S. Environmental Protection Agency...
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