Sustainability and Packaging Chandler Slavin Sustainability Coordinator Dordan

Sustainability and Packaging Chandler Slavin, Sustainability Coordinator, Dordan Mfg.

What is Sustainable Packaging?

In a perfect world… l According to the SPC, Sustainable Packaging: – – – – Is beneficial, safe & healthy for individuals and communities throughout its life cycle; Meets market criteria for both performance and cost; Is sourced, manufactured, transported, and recycled using renewable energy; Is manufactured using clean production technologies and best practices; Is made from materials healthy in all probable end of life scenarios; Is physically designed to optimize materials and energy; Is effectively recovered and utilized in biological and/or industrial closed loop cycles.

In reality… l l In my opinion, today there is no such thing as a truly sustainable package; all commodities consume energy and emit GHG equivalents during production. While paper comes from trees and plastic fossil fuel, both utilize natural resources as their feedstock; both consume energy during their procurement and conversion; and, both emit chemicals into the atmosphere throughout their lifecycle.

So what’s all this jazz about “Sustainability? ” l According to the WWF’s Living Planet Report, which is a biannual analysis of the carrying capacity of the globe compared with resource consumption, our current approaches to production and consumption are not sustainable: – Population x Consumption > Planet

Yikes! l l We estimate that current demand for the Earth’s resources is 1. 25 times what scientists believe our planet can sustain. And by the way, that’s with 6 billion people, not the 9 billion world population predicted by mid-century. Put another way, according to the findings in our Living Planet Index, on September 25 of this year our resource use surpassed what is sustainable. What this would mean as a financial issue is that we are living off our principle; as a farmer it means we are eating our seed.

We need to use less and produce more from less…

What does this mean for packaging? l l Because of the contemporary anxiety over our depleting resources, single-use, disposable packaging has been targeted as a manifestation of our over-consumptive society. Think bag bans, bottle bills, PS bans and the like…

The “Green” Consumer l l l Market research shows that consumers will buy a product/package with a “green” presence over a product/package that is perceived to have a negative impact on the social and ecological environments. While most surveys indicate consumers are willing to pay more for “green” products, this is often not the case. Therefore, it has been concluded that if at a comparable cost and performance, consumers will buy the “green” product/package over the product/package not identifying with “green” values.

What’s important for you l l Because of these cultural shifts and the changing landscape of the packaging industry, it is important for you as packaging professionals to understand the various dimensions of “sustainability” as it pertains to packaging. By understanding these issues, you will be able to make more informed packaging choices, which will resonate with your customer and end consumer.

Presentation Overview, Part I l How to measure “Sustainability: ” – – – LCA and LCI Sustainability Metrics COMPASS l – Go Phone package redesign Walmart Scorecard l l Direct and Indirect suppliers Scorecard metrics Scorecard completion SVN Scorecard discussion

How to measure sustainability, continued l l l Walmart Supplier Assessment P&G Scorecard Global Packaging Project Consumer Goods Forum Sustainability Index

Presentation Overview, Part II l Traditional packaging materials sustainability profiles: – – – Energy consumption GHG emissions Water and biotic consumption Global warming Deforestation

Presentation Overview, Part III l Waste management of traditional packaging materials – – – MSW, US EPA 2007 Generation and recovery rates, US EPA 2008 Recycling initiative

Presentation Overview, Part IV l Environmental labeling guidelines for packaging: – – – FTC, EPI Greenwashing, Walmart Expo, greenerpackage. com Dos and don’ts of green claims Recyclability claims Bio/oxo/photo degradability claims Comparative claims

Presentation Overview, Part V l Extended producer responsibility/product stewardship – – – EPR and packaging Who does it affect? What you should do about it How to avoid high EPR fees What you should require from your suppliers The advantage of the domestic supplier

Presentation Overview, Part VI l Bio-based polymers sustainability considerations – – Sustainable sourcing Complete biodegradation End-of-life management Energy requirements/GHG emissions of production vs. traditional resins

Ready?

Part I: How to measure “Sustainability” l l LCA stands for life cycle analysis, which is a popular approach to understanding the environmental profiles of products and services. LCA considers the entire life cycle of a product or service, from its procurement to conversion, manufacture, distribution, and end of life.

LCA and LCI l l If one wanted to perform a LCA of a product or service, one would need at least three different LCI data sets, which stands for life cycle inventory data. These data sets would be averaged to determine the metrics used for the product or service LCA. LCI data is primary data that is collected for a specific product or service.

LCI, example l l If Dordan wanted to measure the environmental requirements of its manufacturing facility in order to contribute to the metrics used in LCAs for material converters, Dordan would have to collect data about its operating processes, such as the energy requirements of manufacturing and distributing its products. This data would be consider LCI data, and would be used in the development of metrics for performing LCA of thermoforming operations.

Sustainable Metrics l l l The LCI data collected for the performance of LCAs of a product or service are based on sustainability metrics. Metrics are the various environmental indicators considered in LCAs that help measure sustainability. These include, but are not limited to, greenhouse gas emissions, fossil fuel consumption, water consumption, biotic consumption, aquatic toxicity, eutrophication, etc.

COMPASS, overview l l COMPASS is a life-cycle based, environmental modeling software that allows you to compare the environmental performances of different packages, based on material selection and packaging weight. COMPASS contains life cycle inventory data from raw material sourcing, primary packaging material manufacture, conversion, and end-of-life. Transportation and purchased electricity within these phases is also included. In addition, COMPASS includes end-of-life probabilities for waste scenarios such as recycling, waste-to-energy incineration, landfill, composting, and litter.

COMPASS and LCAs l l This tool uses LCI data in order to create the metrics used to perform LCAs. If no LCI data has been collected about a certain material or service i. e. RPET, then one can not perform an LCA of said material or service.

COMPASS example, introduction l l Dordan uses COMPASS to run environmental comparisons between different packaging materials and designs. One instance in which Dordan used COMPASS to illustrate the environmental improvements of a package redesign is the Go Phone package comparison.

Old Go Phone package

Redesign approach l l l Redesign package to achieve a smaller product-to-package ratio; Reduce the gauge of the clamshell from 0. 030" to 0. 025" and the inner tray from 0. 045" to 0. 035; " Change the clamshell from convex to flat, thereby eliminating the snap-on lid.

New Go Phone package

Go Phone package redesign savings l l l 29% cost savings compared to previous package; For the same amount of product sold, reduced the total packaging weight by 25%; Reduced C 02 emissions by 25%; Reduced total usage of packaging, saving transportation costs and energy use; The slimmer design allows for more products per pallet and an increased number of units per foot of retail space.

See the difference?

The proof is in the pudding… COMPASS packaging comparison results: l http: //www. dordan. com/Go_Phone_COMPA SS. xps

COMPASS Summary l In short, COMPASS can be utilized in the following ways: – – Allows packaging engineers to compare the environmental impacts of their package designs using a life cycle approach. Helps engineers make more informed material selections and design decisions early in the development process. Allows Marketing teams to articulate packaging improvements, which should resonate with customers and the end consumer. Allows Sales teams to “reverse-engineer” competitors packages in order to show package can be improved to yield a better environmental profile.

Questions about COMPASS as a tool for measuring sustainability?

Retailers and measuring sustainability, overview l l Many retailers are investigating the different tools available for measuring sustainability, for both products and packages. Examples include: – – – Walmart Scorecard and Supplier Sustainability Assessment Global Packaging Project Consumer Goods Forum P&G Scorecard Sustainability Index

Walmart Scorecard, introduction l l Like COMPASS, the Walmart Scorecard uses available LCI data sets to perform LCAs of different packages, based on material and packaging weight. ECRM created the software for the Walmart Scorecard, which stands for “Efficient collaborative retail marketing. ” Based on the environmental profile of one’s package, suppliers receive Scores, which conveys a packages assumed “sustainability. ” Scores for packaging only; based on ITEM level.

Scorecard and suppliers l l Direct suppliers to Walmart are required to enter their packaging information into the Scorecard software via “retail link, ” which is per vendor number and item number. Indirect suppliers are encouraged to subscribe to the Walmart Packaging Modeling Software, which uses the metrics of the Scorecard to perform LCAs of different packages.

Scorecard metrics l Metrics considered: – – l Material type material weight material distance packaging efficiency. Material distance considers the point the package travels from point of conversion to point of fulfillment.

Scorecard completion l l The Walmart Scorecard is a constantly evolving tool. Each item sold in Walmart has its own number. Suppliers are required to fill out a Score for each item number. Currently, completion of Scores is the easiest way to influence purchasing decisions. Scores are based on comparisons with others in your product category i. e. dairy. As more companies submit their Scores, your Score is likely to change, depending on your competitor's performance.

SVN meeting, Scorecard discussion “Sustainable Material metric? ” l – – – – What does a “sustainable material” mean? Until clarified, should everyone get the same Score? Should we remove the metric? Is Recovery taken into consideration? Is it a LCA based approach? Does it consider conversion or primary production? What about toxics? Sourcing certificates?

SVN meeting, Scorecard discussion, continued l SVN determined that it would be helpful to have a health and safety metric AND a sustainable sourcing metric, which together would be blanketed under the metric “sustainable material. ”

SVN Questions l Add an ink/laminate metric? – l Only if proof is provided that argues that such a metric is necessary. International manufacturing vs. domestic metric? – – Had considered a point of origin because overseas manufacturing has different environmental profiles than domestic manufacturing i. e. labor laws, environmental regulations, etc. ; however, unable to quantify at this time. It maybe considered in the future.

Walmart Scorecard questions?

Walmart, Supplier Sustainability Assessment l l Consists of 15 questions, which are asked of all product suppliers to Walmart. “Scores” based on CORPORATE level.

Global Packaging Project l l l Walmart funds this but is not the only CPG company on the board; GPP looks for a GLOBAL metric for assessing the sustainability of packages and products; This is bigger than the Scorecard, as the Scorecard will be one component utilized in the metrics.

GPP, continued l l The GPP metrics look to take into account the Scorecard metrics, COMPASS, the SPC’s Sustainable Packaging Metrics, and other existing and legitimate metrics. If one wants the inclusion of another metric i. e. sustainable sourcing, it must be reviewed for application prior to being incorporated into the GPP metrics.

Consumer Good Forum l l The GPP grew out of the CGF, which was originally called the Global CEO Forum. The relationship between the CGF and GPP has yet to be determined.

P&G Scorecard l l l Release in May 2010; This tool is designed to help suppliers meet sustainability targets, for both packaging and products. It utilizes existing data sets to determine the “sustainability” of a product, package, or service.

Sustainability Index l l The assessment is part of the Sustainability Index, which is a project of the Sustainability Consortium. Walmart funds this organization but is not the only CPGs company that participates. Ambiguous organization and role; Assumed to provide metrics to GPP.

Retailers, organizations, tools and sustainability l l It has yet to be determined what the governance will be over the different tools to measure sustainability i. e. Walmart Scorecard vs. P&G Scorecard vs. COMPASS, etc. It has yet to be determined what the governance will be over the different organizations i. e. GPP vs. CGF vs. Sustainability Index.

Questions on how to measure sustainability?

Part II: Packaging Materials Sustainability Profiles, introduction l l Different packaging materials have different environmental requirements, based on their feedstock and procurement. It is important to acknowledge that no packaging material is “the” sustainable packaging material; each has its advantages and disadvantages in the context of environmental considerations.

Packaging materials and energy consumption l l Each packaging material type consumes energy during its procurement and conversion. Packaging materials of focus: paper and plastic.

Graph analysis l l This graph represents the energy (million Btus) consumed per 1, 000 lbs of plastic produced. The average energy consumed for the production of 1, 000 lbs of plastic is: 9. 94 million Btus.

Graph analysis l l This graph represents the energy (million Btus) consumed per 1, 000 lbs of material produced. The total energy consumed in the production of 1, 000 lbs of fiber-based packaging is 8. 96 million Btus.

Energy requirements comparison, paper and plastic l l These graphs illustrates that while plastic is made from fossil fuel and paper is made from trees, the energy required to produce the two packaging materials is comparable. This is because the energy-intensive threestep process pulp undergoes in its conversion to paper.

Embedded energy of plastics l l If plastic and paper have similar energy consumption requirements for production, why is plastic targeted as a waste of our fossil fuel and paper seen as the environmentally friendly alternative? Because most of the energy consumed in resin production (around 88%) is embedded in the material itself, available for recovery post-consumer via waste -to-energy (hereafter, WTE).

Graph analysis l This graph illustrates the energy (million Btus) embedded per 1, 000 lbs of plastic material, which is available for recovery via waste-to-energy.

Plastics and incineration, misc. l l According to the journal of Resources, Conservation and Recycling, “Polyolefins commonly used in [plastic] packaging can generate twice as much energy as coal and almost as much energy as fuel oil. When plastics are processed in modern WTE facilities, they can help other waste combust more completely, leaving less ash for disposal. ” Moreover, because there are 114 WTE facilities operating in the U. S. today, generating enough energy to meet the power needs of 1. 2 million homes plastic packaging should not be viewed as a wasteful consumption of fossil fuel but as a viable form of energy available for latter recovery.

Plastic and energy, misc. l l in a recent Franklin Associates Ltd. study that analyzed the carrying capacity ratios of different packaging materials, it was determined that plastic has a value of 34 and paper 6. 9. This means that 34 ounces of juice could be carried in 1 ounce of plastic and 6. 9 ounces could be carried in 1 ounce of paper. The study also found that by using plastic packaging, product manufactures save enough energy each year to power a city of 1 million homes for roughly 3. 5 years.

Plastics and energy, summary l l The energy required to produce plastic is comparable with that of paper production. Most of the energy consumed in its production of plastic is embedded in the resin itself, available for later recovery. The density of plastic allows for lighter and therefore less shipments, thereby saving energy in production, conversion and transportation. The carrying capacity of plastic allows for less material consumed for the same packaging application, therefore reducing the volume of packaging waste and the overall energy consumption.

Questions on packaging materials and energy?

Packaging materials and GHG emissions, introduction and data limitations l l As with energy consumption of production, different packaging materials release different amounts of GHG equivalents. Due to proprietary data sets, I am unable to perform an “apples-to-apples” comparison between paper and plastic in regard to GHG generated per 1, 000 lbs of material produced.

Graph analysis l This graph represents how many thousand GHG equivalents are generated per 1, 000 lbs of material produced.

Fiber-based packaging production, overview l The production of fiber-based packaging materials is broken down into three processes: – – – The pulping process, achieved through chemical or kraft pulping; the bleaching process; and, the paper making process.

Processes emissions l l Overall, the pulping processes are the sector’s primary source of air emissions and water discharges of pollutants. The bleaching process, however, generates chlorinated byproducts—chloroform, dioxins, furans—that pose particular environmental concern for their persistence, bioaccumulatability, and toxicity.

Paper Laminates and VOCs l It is also important to note that coated and laminated paper products, like those found in many packaging applications, are associated with significant reporting of releases and other waste management TRI chemicals; including emissions of volatile organic compounds (hereafter, VOCs) and discharges of wastewater containing solvents, colorants and other contaminants.

Blue: Air emissions Red: Water discharges

Graph analysis l l This graph represents the total air and water emissions generated during pulp and paper production in the United States in 1996. This report is the most recent Toxics Release Inventory Report released by the US EPA.

Graph analysis l This graph illustrates the total production related waste generated in pulp and paper production in 1996 in the US.

Fiber-based packaging production related-waste l Taken together, the U. S. pulp and paper industry (SIC Code 26) generated 1, 599, 797, 509 lbs of production-related waste in 1996 i. e. air emissions, water discharges, etc.

GHG emissions and Global Warming l l According to the 2009 report released by the U. S. Global Change Research Program, the largest factor contributing to global warming is increased greenhouse gas emissions such as carbon dioxide, methane, nitrous oxide, water vapor, halocarbons, soot, etc. ; deforestation, agricultural practices and irrigation also have greatly contributed. Climate change will most dramatically stress water resources, and crop and livestock production will be increasingly challenged.

Fiber-based packaging production and water consumption l l As the USGCRP report indicates, water scarcity will become an increasingly challenging problem with the elevation of the global climate. According to the EPA’s “Toxics Release Inventory Data for the Pulp and Paper Industries, ” the pulp and paper sector is the country’s largest industrial process water user. Therefore, because the production of paper from wood requires large amounts of water and steam, marketing paper as more environmentally “friendly” than plastic is without ecological merit when considered in the context of global warming because of the value of water for economic and human sustainment and the extensive water requirements for pulp and paper production.

Fiber-based packaging, deforestation and global warming l As the USGCRP report explains, deforestation is a leading contributor to the increased emission of greenhouse gases; as such, the emphasis on paper as the sustainable packaging material needs to take into account the greenhouse gases emitted during deforestation and the extensive consumption of our natural resources.

Fiber-based packaging production and deforestation l l The US Forest Service estimates that the sustainable production of timber on all the land under its jurisdiction is about 550 pounds per acre per annum. Packaging grade paper requires about 1. 1 to 1. 2 pounds of wood per pound of paper or about 500 pounds of paper acre. To produce the required 82 billion pounds of paper needed to replace all plastic packaging would therefore need an additional 162 million acres of forestland developed to paper production. To put this in perspective, this is the area of six US states the size of Tennessee.

Paper production, emissions and consumption summary l l l Paper packaging production requires deforestation, which contributes to greenhouse gas emissions and consumes high concentrations of biotic and mineral resources. The pulp and paper sector consumes more water than any other industry. This is a problem as water becomes increasingly scarce with the elevating global temperature. Paper production releases large amounts of greenhouse gases into the atmosphere. Paper production releases high concentrations of VOCs into our water and land, contributing to aquatic toxicity and eutrophication. Replacing all packaging applications with fiber-based packaging materials would require the appropriation of more land for deforestation than we currently have access too, therefore increasing the burden of packaging on the environment as articulated above.

Questions on packaging materials and GHG emissions, global warming, and deforestation?

Part III: Waste management of packaging materials, introduction l There are different avenues a packaging material may take post-consumer. Some materials get landfilled, others are recycled, and others still are incinerated with waste-toenergy.

Municipal Solid Waste, material type

Graph analysis l l This graph illustrates the amount of packaging material that ended up in a landfill in the U. S. in 2007. Paper is the largest contributor to the landfill, comprising 52% of our MSW.

MSW: Generation and recovery Blue: Generation Red: Recovery

Graph analysis l l l This graph illustrates the amount (millions of tons) of packaging material generated in the US in 2008 AND the amount recovered postconsumer. While paper has the highest generation of the packaging material types, it also has the highest recovery. However, this recovery is attributed mostly to newspapers and corrugated boxes.

“Paper” packaging recovery rates, expanded l l http: //www. epa. gov/epawaste/nonhaz/munici pal/pubs/msw 2008 data. pdf Paperboard packaging/other paper packaging recovery= Neg. ?

Recyclable vs. recycled? l l Anything is theoretically recyclable if the collecting, sorting, and processing technology exist and if there is an end market for this material. However, few material/packaging types are actually recycled in America due to the economics governing recycling.

Example of recyclable vs. recycled: Dordan’s clamshell recycling initiative l l l Currently, thermoform packaging is not recycled in American, although theoretically it can be recycled. A material/package is considered “recycled” if >60% of American communities have access to recycling facilities that process said material/package. We have been trying to find a way to recycle our clamshell packages for several months now. I have a blog, which narrates our day-to-day attempts to integrate thermoforms into the existing recycling infrastructure.

Recycling initiative l l www. recyclablepackaging. org I am the co-lead of the PET subcommittee of Walmart-Canada’s Material Optimization Committee. Hopefully I can help them reach their goal of zero waste for PET packaging post-consumer, both bottle-grade and thermo -grade. If Canada can do it, so can we!

Approach to recycling initiative, # 1 l Integrate our RPET thermoforms into the existing PET bottle recycling infrastructure: – – Sent 50 of our RPET clamshells to the MRF to run through their optical sorting technology to see if our clams are “read” like PET bottles. If so, then the issue of integrating RPET clams into the bottle recycling infrastructure has nothing to do with sorting technology. Test found that their was no optical difference between our RPET clams and PET bottles.

Recycling initiative, # 1, continued – – – What this means is that If our RPET clams were accepted for recycling with PET bottles, when they would move down the line they would be sorted with PET bottles and baled together for purchase. However, according to WM, even if our RPET clams made it into the PET bottle bales, when the bale is bought by a reprocessor, they throw away RPET clams. Therefore, it is not WM who determines what materials are recycled but those who buy said material post consumer for reprocessing.

What’s the deal? l Buyers of balled PET bottles do not want RPET clams in the mix, even if the same material, for the following reasons: – – “Look-a-like” syndrome, fear of PVC contamination; different IV’s; different melting points; “fly” and “bale” differently due to different shapes and sizes.

Problem with initiative l Like anything, recycling is a business, which requires: – – l Supply Demand Technology Investment While RPET thermoforms can be recycled, they are not because limited supply, limited demand, lack of technology, and no investment.

Recycling initiative, # 1, pilot l l l Dordan is investigating a pilot program whereby they would designate a bale at a local WM that would accept both PET bottles and RPET clamshells. This mixed bale would be purchased by our material supplier of RPET, who would grind and extrude the mixed bale into thermoformable sheets. We would buy this material and test it on our machines to see its performance.

Approach to recycling initiative, # 2 l l Create a new stream of low-grade, mixed rigid plastic packaging, which would either be incinerated for energy or recycled into timber applications for parks and decks. This market exists on the East and West coasts where international markets purchase our plastic scrap post-consumer for incineration or reprocessing.

Questions on the waste management of packaging materials?

Part III: Green Claims, overview l The FTC is starting to persecute those making unsubstantiated environmental claims on packaging.

Example of “greenwashing” l l According to an FTC statement issued last month, the commission issued letters to 78 U. S. retailers and manufacturers warning that they may be breaking the law by selling textile products that are labeled and advertised as “bamboo, ” but that actually contained manufactured rayon. The statement also said the companies have been warned against making eco-friendly claims about bamboo fibers— which are produced using harsh chemicals that release air pollutants, the statement said.

Bamboo greenwashing claims, continued l l Failure to properly label and advertise these products violates the FTC Act and the commission’s Textile Rule, the FTC said. Making unsubstantiated green claims has real costs.

Example of real cost, California Law l l Any company that advertises its product using broad claims of environmental friendliness such as “ecologically sound, ” “environmentally safe, ” “green, ” or any similar term must provide written documentation supporting such claim to any member of the public upon request. Failure to do so results in a misdemeanor punishable by jail and/or a fine up to $2, 500.

Retailers and greenwashing l Retailers such as Walmart are taking an aggressive role at tackling products and packages that make unsubstantiated green claims.

5 th Annual Walmart Stores, Inc. Sustainable Packaging Exposition example l l EPI audited the environmental claims at the Walmart Expo for all packaging vendors. EPI audited both the Packaging Success Story and the 7 Rs handout. 70% were rejected in the first review. All were eventually approved; however, most had to dramatically change their marketing language.

Walmart Expo, green claims l According to the EPI, the biggest issues were: – – Claims of recyclability; no proof; biodegradable/degradable claims; ambiguous comparative claims.

Anti-greenwashing efforts l l l The greenerpackage. com database for packaging suppliers requires documentation supporting any environmental claim. The database is linked to Walmart’s Sustainable Packaging Scorecard Modeling tool. http: //www. greenerpackage. com/database.

EPI’s Six Sins of Greenwashing l l l Sin of hidden tradeoff Sin of no proof Sin of vagueness Sin of irrelevance Sin of fibbing Sin of the lesser of two evils

EPI research l Study of 1, 018 consumer products that make environmental claims found that “all but one made claims that are demonstrably false or that risk misleading intended audiences. ”

EPI’s Six Virtues of Green Labeling l l l Tell the truth; use specific claims—do not make broad environmental claims i. e. “green” or “sustainable; ” don’t overstate a product’s attributes; use clear and prominent qualifications; have reliable data to back up your claims; make sure a consumer can clearly understand the meaning behind the claim.

Recyclable claims l A basis for the claim i. e. study or survey results of municipal recycling facilities, must be stated when making ‘recyclable’ claims on packaging that is not traditionally accepted for recycling. – – You must consider both the material and packaging type i. e. PET bottle versus PET clamshell; You must review what is collected by communities and what is accepted at recycling facilities; Must be available to a substantial majority of consumers or communities (60%) Closed recycling systems are OK if well qualified i. e. in-store plastic bag collection programs.

Availability of facilities for recycling l Recyclable in the US: – – – – – Glass bottles and jars (clear, green and brown) PET bottles with necks (clear, light green and very light blue) HDPE bottles with necks (all colors, accept black) Aluminum cans Steel cans Newspaper Corrugate (non-waxed) Paperboard without “bling” (although EPA data ambiguous) Paper without “bling”

Availability of facilities for recycling l Not presently recyclable: – – – – – Glass (other than clear, light green and very light blue) PET bottles (other than clear, light green, and very light blue) All other PET i. e. clamshells, blisters, trays, etc. HDPE (black and non-bottle HDPE) All plastic film and bags Paperboard with “bling” Paper with “bling” Waxed corrugate Packaging with food contamination Laminates

Other claims… l l l Recycled content claims: specify post-consumer and post-industrial; include % values; Degradable/biodegradable/photo/oxo: Qualify claim with intended disposal environment; include rate and extent of degradation. Comparative claims: Claims should be sufficiently qualified and clear as to what is being compared. Use of green dot: Use of green dot is only allowed with valid trademark license. Claims based on Walmart Scorecard: Specify what change altered score and how.

Questions on making green claims?

Extended producer responsibility, introduction l l EPR stands for extended producer responsibility, which is a strategy to place a shared responsibility for end-of-life product management on the producers, and all entities involved in the supply chain, instead of the general public; while encouraging product design changes that minimize a negative impact on human health and the environment at every stage of the product’s life cycle. First implemented with the management of electronic waste and vehicles, EPR now extends to packaging: Today, over 30 countries mandate EPR legislation for packaging.

EPR geographical scope l While EPR legislation has historically been confined to member states of the EU due to the implementation of the 1994 EU Directive on Packaging and Packaging Waste, it is now expanding into the American and Canadian markets. Accordingly, it is in all producers’ interests to familiar themselves with EPR requirements in order to avoid the costs associated with failing to comply with said requirements.

EPR legislation, overview l EPR legislation is composed of three basic elements: – – – waste management financing; product design; and, informational requirements.

EPR and waste management financing – Waste management financing refers to the funding of the recovery of electronic and packaging waste; producers can therefore choose to comply individually or collectively. If chosen to comply individually, producers must set up their own system for the recovery of electronic and packaging waste; if chosen to comply collectively, producers must join an organization that assumes responsibility for recovering their packaging and electronic waste, as in the case with the Fost Plus system in Belgium.

EPR and product design l l l Product design requirements refer to material restrictions and design for recycling/reuse. These design requirements often extend to electronics, batteries and packaging. An example of a material restriction mandate is the EU Ro. HS Directive, which requires that the materials used in packaging/consumer goods/electronics do not contain any heavy metals. An example of a design for recycling/reuse mandate is the EU WEEE Directive, which requires member states to meet targets for recycling and/or reuse, thereby granting authority to the state to mandate certain design for end of life requirements from producers.

EPR and labeling requirements l l EPR legislation often includes a requirement to label the product, user manual, and/or packaging to inform the consumer that s/he should not place the product in the trash but rather drop off the product at a designated collection location for separate disposal. This extends to packaging, as illustrated through the development of various labeling schemes for packaging to inform the consumer what to do after use.

EPR and packaging l According to Victor Bell, the President of Environmental Packaging International, “The centerpiece of the environmental movement in Europe is a set of new packaging standards being developed; they are called the “Essential Requirements” and all packages must meet them before they can be sold in Europe. ”

Essential requirements, # 1 l Requirements for packaging recoverable through recycling: – – This standard will require that the person responsible for placing the packaging on the market ensure that the design of the packaging includes consideration for the recycling of the materials from which it is produced and that the selection of raw materials used ensure that recycling processes are not negatively affected i. e. PVC labels on PET containers. Additionally, this standard will require that the design of the packaging is compatible with the available recycling technology and that the environmental impact cause by recycling is taken into account.

Essential requirements, # 2 l Requirements for packaging recoverable through composting and biodegradation B Test scheme and evaluation criteria for final acceptance of packaging: – – This Standard requires that constituents known to be harmful to the environment during biological treatment not deliberately introduced into packaging or packaging materials. The Standard establishes tests and guidelines for packaging and packaging materials to be designated as organically recoverable.

Essential requirements, # 3 l Requirements for packaging recoverable in the form of energy, including specification of minimum calorific value: – This Standard defines and specifies the requirements for packaging to allow the overall optimization of energy recovery.

Essential requirements, # 4 l Reduction of waste (prevention by source reduction): – This Standard require that the person responsible for placing the packaging on the market demonstrate that the minimum adequate amount of packaging has been used, taking into account the critical functions of the packaging (protection, safety, storage, application and marketing).

Essential requirements, # 5 l Reuse: – This Standard outlines the requirements for packaging to be deemed to be recoverable.

Essential requirements, # 6 l Requirements for measuring and verifying heavy metals present in packaging (CEN report): – This report addresses the environmental impact from heavy metals in packaging after incineration or land filling. The report confirms the heavy metals limits outlined in the Packaging Directive i. e. packaging must contain less than 100 ppm of the sum of the concentration levels of lead, cadmium, mercury, and hexavalent.

Do I have to meet all 6 Standards? l l l As presently structured, all packaging will be required to meet the standard for heavy metals and other hazardous substances requirements (CEN report). If you claim that your packaging is reusable, than you will be required to meet the reuse standard. Finally, you will be required to meet at least one of the recovery standards (Material, Energy and/or Organic).

What to take away from this… l Taken together, it is important for packagers to take the Essential Requirements into consideration in the design phase and establish a paper trail documenting how each standard was incorporated into their packaging design protocol.

Who does EPR laws effect? l EPR laws affect producers: – – – Producers would be defined as either the direct manufacturer of a product that sells or distributes in the [member state] under its own name or a brand name; or, an entity that is not a manufacturer but is the owner or licensee of a trademark or brand name of a product sold or distributed in the [member state] under their own brand; or, an entity that imports the product into [the member state] for sale or distribution.

“Producers? ” l l “Producers” are not considered “manufactures” because the term “manufacturer” is too narrow. For example, many manufacturers are located overseas and work under contract to the brand owner. It is the brand owner who makes design and marketing decisions; therefore, it is the brand owner who is responsible for funding the recovery of their products’ post-consumer packaging waste.

“Producers? ” l l Also, many retailers are producers because they sell products under their own brand. Generally, the producer will be the brand owner.

What should you do about EPR laws? l In order to comply with EPR requirements, electronic products and consumer goods’ packages must be viewed at the component level to ensure that he entire product and package complies with the various requirements: – – Material Considerations: In order to comply with material restrictions (EU Ro. HS), producers will have to ensure that component specifications are written so as to forbid regulated materials and to obtain certification from the supply chain. If the legislation requires producers to design products/packages that meet recycling/reuse targets, product/package designers will need to consider how to improve recyclability.

What should you do about EPR laws, continued? l l Often times, EPR legislation requires companies to submit reports on waste generation and product material contents [e. g. packaging weight by component]. In order to ensure compliance and therefore pay minimal fees for managing electronic and packaging waste, consumer goods/electronic producers should collect and maintain a bill of materials database.

What you should do about EPR laws, continued? l l l Producers should require that their suppliers submit third-party certification documenting compliance with the relevant standards. Examples include a letter of certification from material suppliers documenting compliance with the EU Ro. HS Directive. It is also helpful to establish a due diligence protocol to ensure that all procedures established to enable compliance are, in fact, being respected

How to avoid high EPR fees l Understand the requirements: – – – Producers of electronics and those who are responsible for putting consumer products’ packages on the market must understand the requirements in the markets in which their products and packages are sold. To do otherwise may result in bad press, fines, and the possibility of getting their products and packages banned from the market. By understanding the waste fees associated with products and packages, producers could design product—and require their packaging suppliers to design packages—that incur lower fees, thereby creating a marketing advantage over those who do not.

How to avoid high EPR fees l Incorporating waste fees into the cost of the product: – – There are many fees that producers are now required to pay to fund their products’ and packages’ disposal/recycling at end of life. Waste fees are associated with EPR legislation are real costs.

How to avoid high EPR fees l Maintain necessary data points: – – EPR mandates place new data demands on the producer of electronic goods/those responsible for bringing packaging to the market. In order to be able to generate reports for electronics, battery and packaging waste fee payments and maintain documentation on material composition, producers must maintain data on, for example, weight, detailed material composition, and component type. As is seen in Europe, it is recommended that producers develop a compliance software tool that aids in complying with these requirements. An example of this is the Pack. NET software system developed by Foresite Systems, which calculates waste fees and generates compliance reports for all worldwide electronics, battery and packaging regulations.

How to avoid high EPR fees l l l EPR fees are often based on product/package type or the weight of the product/package. Therefore, electronic producers and product packagers should design products and packages that do not have any heavy metals or hazardous constituents. Additionally, because fees are dependent on the weight of both the product and package, it is important to design electronics and packages with lightweight and safe materials.

How to avoid high EPR fees l If the material is classified as laminated you pay larger fees.

EPR example, Canada’s Waste Diversion Act, 2002 l l This law says that industry has to pay for 50% of the net cost for municipalities to run their Blue Box program. Stewardship Ontario was set up specifically to collect that money from industry and give it to the municipalities.

Blue Box Program l l l The Blue Box Program is similar to our curbside recycling in the States. Unlike the States, however, Canadians are encouraged to recycle a lot more material. The “designated” material types accepted for recycling via the Blue Box Program are listed here: http: //www. stewardshipontario. ca/bluebox/pdf /materialcategories. pdf.

Material type and fees l l There are different fees for different materials, depending on the ease of recovering said material post-consumer. In other words, the harder a package is to recycle or recover, the higher the associated fee will be. The fees change every year; here’s the latest: http: //www. stewardshipontario. ca/bluebox/fees_ rates. htm.

Fee analysis l l For example, if you sold a polystyrene container into the Canadian market, you would be required to pay 24. 65 cents per kg. However, there all sorts of restrictions/exemptions/etc. so it gets very complicated.

What you should require from your suppliers, overview l l l In order to ensure compliance, suppliers must understand their obligations and the requirements that affect their products and packages; they must certify that their products and packages will meet these requirements; and, they must provide key third-party data on their products and packages.

What you should require from your suppliers l Consumer goods companies/ electronic producers should obtain the following data from their suppliers to ensure compliance: – For the consumer product/electronic good: l l l Sales by country and month, declared weight and/or volume of the product, and the product-to-package ratio.

What you should require from your suppliers, continued l For the package: – Data by packaging component: l l In most cases, manufactures must be prepared to provide data on each specific component of the package, not just the package as a whole. Additionally, packagers need to establish a program to obtain certification from suppliers to assure that their products comply with the EPR requirements.

What you should require from your suppliers, continued l For the package, continued: – – – Primary package material and weight; Secondary package material and weight; Transport package, material and weight;

What you should require from your suppliers, continued l Material type of primary, secondary and transport packages needs to be classified into the following: – – – Plastic by resin type Paper Glass Aluminum Composite

What you should require from your suppliers, continued l l Data must be collected in regard to the number of uses for the primary, secondary, and transport packages: Reusable or refillable? Data must be collected in regard to the percentage of recycled content in the primary, secondary, and transport packages. – Distinctions must be made between pre- and postconsumer material.

The advantage of domestic suppliers l l l Despite the increasing trend toward international manufacturers, brand-owners remain legally responsible for compliance with EPR legislation. Therefore, while it may be cheaper to source product and packaging overseas, it is more difficult to ensure compliance with EPR requirements because of data gathering obstacles and the absence of a due diligence protocol throughout the supply chain. By sourcing domestically, consumer goods companies/electronic producers can have harmonized reporting, which will improve compliance, reduce compliance costs, reduce paperwork, improve data accuracy, and send a clear message to producers on how to improve their packaging and products.

The advantage of sourcing direct from the manufacturer l l l Because consumer goods companies are held liable for EPR compliance, it is in their interests to source packaging direct from the manufacturer in order to ensure that the mandates are met and the necessary certifications are received. By sourcing direct, it is easier to attain and maintain the data points necessary for EPR compliance i. e. materials and weight of package and its components. Moreover, sourcing direct allows for better supply chain management via the implementation of a due diligence protocol and data reporting.

Questions on EPR and packaging?

What is “Biodegradability? ” l Biodegradability is an end of life option that allows one to harness the power of microorganisms present in a selected disposal environment to completely remove plastic products designed for biodegradability from the environmental compartment via the microbial food chain in a timely, safe, and efficacious manner.

How “Biodegradation” works: l Microorganisms utilize carbon product to extract chemical energy for their life processes. They do so by: – – – Breaking the material (carbohydrates, carbon product) into small molecules by secreting enzymes or the environment does it. Transporting the small molecules inside the microorganisms cell. Oxidizing the small molecules (again inside the cell) to CO 2 and water, and releasing energy that is utilized by the microorganism for its life processes in a complex biochemical process involving participation of three metabolically interrelated processes.

Part IV: Bio-based polymers, introduction l Designing plastics that can be completely consumed by microorganisms present in the disposal environment in a short time frame can be a safe and environmentally responsible approach for the end-of-life management of single use, disposable packaging.

However… l When considering any bio-based resin, there are some environmental considerations one must take into account. These include: – – end-of-life management, complete biodegradation; its agricultural-based feedstock; and, the energy required and the greenhouse gasses emitted during production.

End-of-life management considerations l Because biodegradation is an end of life option that harnesses microorganisms present in the selected disposal environment, one must clearly identify the ‘disposal environment’ when discussing the biodegradability of a bio-based resin. Examples include: – – biodegradability under composting conditions; under soil conditions; under anaerobic conditions (anaerobic digestors, landfills); or, marine conditions

Bio-based resins intended disposal environment l l Most bio-based resins used in packaging applications are designed to biodegrade in an industrial composting facility and one should require some type of certification or standard from material suppliers, ensuring compostability. Available certifications include BPI certification or ASTM D 6400 certification.

Problems with intended disposal environment l l Unfortunately, little research has been done on how many industrial composting facilities exist in the United States and how bio-based plastic packaging impacts the integrity of the compost. However, the Sustainable Packaging Coalition did perform a survey of 40 composting facilities in the U. S. , which provides some insight.

SPC’s Composting Survey l l According to their research, 36 of the 40 facilities surveyed accept compostable packaging. These facilities reported no negative impact of including bio-based plastic packaging in the compost. Of the 4 facilities that do not accept compostable packaging, 3 are taking certain packaging on a pilot basis and are considering accepting compostable packaging in the future. Of the facilities surveyed, 67. 5% require some kind of certification of compostability.

Industrial Composting Facilities, their preference l l Because value for composters is found in organic waste, I assume most facilities would not accept biobased plastic packaging for non-food applications because the lack of associated food waste and therefore value. As Susan Thoman of Cedar Grove Composting articulated in her presentation at the spring SPC meeting, composters only want compostable food packaging because the associated food waste adds value to the compost whereas the compostable packaging has no value, positive or negative, to the integrity of the compost product.

Likelihood of composting l l Because there are so few industrial composting facilities available, the likelihood that your bio-based plastic packaging will find its way to its intended end of life management environment is rare. While the idea of biodegradation and compostability for plastic packaging may resonate with consumers, the industrial composting infrastructure is in its infancy and requires a considerable amount of investment in order to develop to the point where it would be an effective and economical option to manage plastic packaging waste post consumer.

Questions on the end-of-life consideration of bio-based plastic packaging?

Complete biodegradation consideration l l l A number of polymers in the market are designed to degradable i. e. they fragment into smaller pieces and may degrade to residues invisible to the naked eye. While it is assumed that the breakdown products will eventually biodegrade there is no data to document complete biodegradability within a reasonably short time period (e. g. a single growing season/one year). Hence hydrophobic, high surface area plastic residues may migrate into water and other compartments of the ecosystem.

Plastic fragments and the environment l In a recent Science article Thompson et al. (2004) reported that plastic debris around the globe can erode (degrade) away and end up as microscopic granular or fiber-like fragments, and these fragments have been steadily accumulating in the oceans. Their experiments show that marine animals consume microscopic bits of plastic, as seen in the digestive tract of an amphipod.

Plastic fragments and toxicity l l The Algalita Marine Research Foundation report that degraded plastic residues can attract and hold hydrophobic elements like PCB and DDT up to one million times background levels. The PCB’s and DDT’s are at background levels in soil and diluted our so as to not pose significant risk. However, degradable plastic residues with these high surface areas concentrate these chemicals, resulting in a toxic legacy in a form that may pose risks to the environment.

Complete biodegradability, summary l Designing degradable plastics without ensuring that the degraded fragments are completely assimilated by the microbial populations in the disposal infrastructure in a short time period has the potential to harm the environment more that if it was not made to degrade.

Questions on the complete biodegradation of bio-based plastic packaging?

Agricultural feedstock considerations l l l Most commercially available bio-based resins are produced from sugar or starch derived from food crops such as corn and sugarcane. Over the past few years, the use of food crops to produce biofuels has become highly controversial; the same may happen with bio-based resins. However, this is only if the scale of bio-based polymer production grows. According to Telles VP Findlen, “If the bioplastics industry grows to be 10% of the traditional plastics industry, then around 100 billion pounds of starch will be necessary, and there is no question that will have an effect on agricultural commodities. ”

Feedstock procurement considerations l Because sugar is the most productive food crop, it makes an ideal feedstock for biobased resin production; however, if all Bio-PE and Bio-PET came from sugarcane, we would need 2. 5 times as much land in sugarcane. Unfortunately, this can not be done sustainably. .

Agricultural-based feedstock considerations, summary l l When considering bio-based resins, one should take into consideration the feedstock from which it is derived and the various environmental requirements that go into procuring said feedstock. While the current production of bio-based resins is not to scale to compete with sugarcane production for food, it is important to understand the environmental and social ramifications of sourcing materials from agriculturally based products.

Questions on feedstock procurement?

Energy requirements and fossil fuel consumption of bio-based polymer production, introduction l l Obviously sourcing plastics from bio-based resources as opposed to fossil fuel is an intriguing option for those looking to reduce the burden of packaging on the environment. However, if the energy required to produce bio-based plastics exceeds the energy consumed in the production of traditional resins, then the sustainability profile of biobased plastics can be compromised.

In the old days… l When bio-based plastics first became commercially available, the processing technologies were not developed to the point where producing plastics from bio-based sources consumed less energy than producing traditional, fossil-fuel based plastics.

Today, things have changed! l l The bio-plastics industry has dramatically evolved and is now able to produce certain bio-based resins with less energy when compared with traditional resins. Natureworks Ingeo PLA (2005), for instance, is processed in such a way that it actually consumes less energy and emits fewer greenhouse gas equivalents during production when compared with traditional, fossil-fuel based resins.

LCA study, introduction l l The Institute for Energy and Environmental Research (IFEU), Heidelberg, Germany, conducted the head-to -head lifecycle comparison on more than 40 different combinations of clamshell packaging made from Ingeo PLA, PET and r. PET. Both PLA and r. PET clamshells outperformed PET packaging in terms of lower overall greenhouse gas emissions and lower overall energy consumed and PLA exceeded r. PET in its environmental performance.

LCA study, results l l l According to the study, clamshell packaging consisting of 100 percent r. PET emitted 62. 7 kilograms of C 02 equivalents per 1, 000 clamshells over its complete life cycle. PLA clamshells emitted even less, with 61. 7 kilograms C 02 equivalents per 1, 000 clamshells. Energy consumed over the lifecycle for 100 percent r. PET clamshells was 0. 88 GJ. This compared to o. 72 GJ for the Ingeo 2005 resin, which is an 18% reduction in energy consumed.

Bio-based plastics considerations, summary l l l Taken together, one would assume that the 2005 Ingeo PLA is a more sustainable option than traditional plastics, as manifest through this study. However, it is important to take into account the other dimensions discussed above, such as end of life management, complete biodegradation, and sustainable sourcing. By understanding the advantages and disadvantages of biobased resins from an environmental perspective, packaging professionals can make informed material selections and truly comprehend the ecological ramifications of their packaging selections and designs.

Questions on bio-based plastic packaging?

In conclusion… l l “Sustainability” as it pertains to packaging refers to a multitude of broad and complicated issues. It is difficult to understand the various ramifications of the “green” movement on the packaging industry; however, if we do our due diligence and research, we will be ahead of the curve.

Thanks for listening! For existing questions, email me at: Cslavin@dordan. com