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Rebuttal to NYT's "Devilish Packaging, Tamed"

Posted by Chandler Slavin on Oct 16, 2012 5:43:00 PM

Stephanie Clifford’s “Devilish Packaging, Tamed,” appeared in the June 2nd addition of the New York Times' Energy and Environment section. What follows is a critical analysis thereof from the perspective of a Sustainability Coordinator at a family owned and operated clamshell manufacturing company.

Clifford makes the following assumptions in “Devilish Packaging, Tamed:”

Retailers are instigating the shift from clamshell to trapped blister packs because (1) increased plastic packaging prices; (2) the desire to reduce packaging material use (re: Wal-Mart’s goal of 5% packaging reduction by 2013); (3) trapped blister packs are more “green” than clamshells; and, (4) trapped blister packs are easier to open than clamshells.

In discussing these assumptions, it will become clear that not only are the claims made in this piece incorrect, but the perception about “green packaging” created therefrom a disservice to the always-progressing dialogue about sustainability and packaging.

Assumption 1:

Retailers are instigating the shift from clamshell to trapped blister packs like MWV’s Natralock because of increase plastic packaging prices.

Trapped blister packs are not new to the packaging market; hence, the assumption that the recently unstable resin market motivates the transition from clamshell to trapped blister packs is incorrect. Since Natralock’s introduction years ago, it has been marketed as the “sustainable alternative to clamshell packaging.” Consequently, referencing the unstable resin market as reason for why clamshell packaging is being replaced with trapped blister packs is an after-the-fact justification that meets MWV’s PR story more that the realities of supply and demand.

Due to the contemporary “death of print” phenomenon—a repercussion of our digital age—the fiber market has been cutting prices to allow for market gains in areas formally controlled by other mediums. This, in conjuncture with other global economics (like the unsuccessful cotton crop in Asia resulting in increased international demand for RPET driving up prices for RPET for packaging converters, like clamshell manufacturers), paints a more accurate picture of the intricacies of the resin vs. paper market than assumed by Clifford. Seeing as how industry publications such as PlasticsNews devote entire sections to explaining and contextualizing the fluctuating resin market (see Material Insights), it is silly to assume that something so complicated as the international production and consumption of commodities be so simply reduced as Clifford would have it.

Assumption 2:

Retailers are instigating the shift from clamshell to trapped blister packs Like MWV's Natralock becasue the desire to reduce packaging material use.

It is misinformed to assume that packaging material reductions are achieved by switching from clamshell to trapped blister packs, which this article postulates. In fact, as per the Wal-Mart Packaging Success Stories presented during the Wal-Mart Packaging Sustainable Value Network meetings, most packaging reductions are achieved by attaining lower product to package ratio via package redesign and/or moving into a lighter packaging medium i.e. PP shrink wrap vs. corrugate boxes. The reason-by-association tactic employed by Clifford assumes that the retailer’s desire to reduce packaging is achieved by transitioning into trapped blister packs; this is overly reductionist and negates the role of the packaging engineer in understanding how each packaging medium allows for different savings depending on the application of the package. In short, packaging material reductions are the result of extensive R&D within a specific distribution context and are made with consideration of the unique market demands inherent in any consumer product.

Assumption 3:

Retailers are instigating the shift from clamshell to trapped blister packs like MWV’s Natralock because it is more “green” than clamshells.

What is “green?”

How does Clifford understand “green?” At the last SPC meeting attorney general of the FTC discussed their recent efforts to understand the consumer’s perception of ambiguous marketing claims like “green,” “sustainable,” “environmentally friendly,” etc. After conducting a survey, it was found that consumers didn’t really understand these terms, which lead the FTC to conclude that such ambiguous environmental marketing terms should be avoided in order to alleviate consumer deception. Consequently, if a marketer is going to make a claim of sustainability/environmentally friendliness, he/she must qualify it with further information like: “Made with 30% post consumer recycled content;” or, “complies with ASTM D6400 Standard for Industrial Compostability.” Hence, the postulation that ALL paper packaging is more sustainable than ALL plastic packaging and, via reason-by-association, that ALL trapped blister packs are more sustainable than ALL clamshells is not only manipulative insofar as no qualifying language is provided, but again, overly reductionist; as such, lacks the legitimacy seemingly assumed in a news article worthy of publication in the NYT.

Environmental marketing claims aside, I would like to take the moment to clear the air re: the sustainability of clamshell packaging.

Sustainability of clamshells vs. trapped blister packs, like MWV’s Natralock:

I am no expert in sustainability. However, I have learned that when discussing the “sustainability” of any product, package or service, it is helpful to take a life-cycle based approach; this looks to quantify the environmental requirements of production, conversion, distribution and end of life management. Only when a full life cycle analysis is conducted can the “sustainability” of any product be understood.

In regard to the first life cycle phase in the context of packaging material production, issues such as feedstock procurement (what is consumed and emitted during the process of raw material extraction?) and feedstock conversion (what is consumed and emitted during the process of raw material conversion?), are important to consider when discussing the “sustainability” of any packaging material.

In the context of pulp and paper production for conversion into trapped blister packs, trees are needed as feedstock, and extensive amounts of water and electricity are required to convert the material into useable fiber-based packaging materials. Consider this excerpt from TreeHugger.com, which attempts to answer to age-old paper vs. plastic conundrum by discussing the production of paper bags:

Paper comes from trees -- lots and lots of trees. The logging industry…is huge, and the process to get that paper bag to the grocery store is long, sordid and exacts a heavy toll on the planet. First, the trees are found, marked and felled in a process that all too often involves clear-cutting, resulting in massive habitat destruction and long-term ecological damage.

Mega-machinery comes in to remove the logs from what used to be forest, either by logging trucks or even helicopters in more remote areas. This machinery requires fossil fuel to operate and roads to drive on, and, when done unsustainably, logging even a small area has a large impact on the entire ecological chain in surrounding areas.

Once the trees are collected, they must dry at least three years before they can be used. More machinery is used to strip the bark, which is then chipped into one-inch squares and cooked under tremendous heat and pressure. This wood stew is then "digested," with a chemical mixture of limestone and acid, and after several hours of cooking, what was once wood becomes pulp. It takes approximately three tons of wood chips to make one ton of pulp.

The pulp is then washed and bleached; both stages require thousands of gallons of clean water. Coloring is added to more water, and is then combined in a ratio of 1 part pulp to 400 parts water, to make paper. The pulp/water mixture is dumped into a web of bronze wires, and the water showers through, leaving the pulp, which, in turn, is rolled into paper.

Whew! And that's just to MAKE the paper; don't forget about the energy inputs -- chemical, electrical, and fossil fuel-based -- used to transport the raw material, turn the paper into a bag and then transport the finished paper bag all over the world.


Please note that this account of pulp and paper production is too simplistic; for a full discussion of the life cycle attributes of pulp and paper production, consult the SPC’s Fiber-Based Packaging Material Briefs, available here for download.

To be fair and get both sides of the story, below is TreeHuger.com’s description of converting fossil fuel bi-products into plastic packaging:

Unlike paper bags, plastic bags are typically made from oil, a non-renewable resource. Plastics are a by-product of the oil-refining process, accounting for about 4% of oil production around the globe. The biggest energy input is from the plastic bag creation process is electricity, which, in this country, comes from coal-burning power plants at least half of the time; the process requires enough juice to heat the oil up to 750 degrees Fahrenheit, where it can be separated into its various components and molded into polymers. Plastic bags most often come from one of the five types of polymers -- polyethylene -- in its low-density form (LDPE), which is also known as #4 plastic.Again, this account of plastic packaging production from a bi-product of the oil-refining process is too simplistic, failing to take into account the different processes/materials required for the production of PET vs. PVC vs. PP; each resin has its own production profile and it’s important to understand how each informs the overall “sustainability” of said resin.

For the full discussion of the paper vs. plastic bag debate re: TreeHuger.com, click here.

When trying to understand the sustainability of clamshells vs. trapped blister packs, it is also important to distinguish between fiber-based packaging IN GENERAL and Natralock, which is a specific type of clamshell alternative produced and marketed by a specific company. Unlike the majority of fiber-based packaging on the market, Natralock incorporates a special type of adhesive/laminate that allows these packages to be deemed “tear-proof.” After a quick search of the US patent database, the following description about BlisterGuard—a trapped blister pack similar to or the same as Natralock (I couldn’t find any patents for Natralock but believe that Colbert Packaging licenses the tear-proof technology to MWV)—is provided:

A packaging laminate is formed by a paperboard substrate with a plastic blister layer sealed to the substrate. The packaging laminate comprises a paperboard substrate for providing a base layer, a tear-resistant polymer layer applied to said substrate, and a heat seal polymer layer applied to said tear-resistant polymer…

The tear-resistant polymer layer 14 may be polyamides, such as nylon 6, nylon (6,6), nylon (6,12) or other polyamides, polyester, polyurethane, block copolymer, unsaturated block copolymers such as styrene-butadiene-styrene, styrene-isoprene-styrene and the like; saturated block copolymers such as styrene-ethylene/butylene-styrene, styrene-ethylene/propylene-styrene, and the like) or other material possessing high tear-resistant properties. The polymer used to make the tear-resistant layer may be blended with another polymer selected from the group including ethylene copolymers such as ionomers, vinyl acetate, methylacrylic or acrylic acid copolymers.
For a full description of the patents from which the above excerpts were taken, click here and here.

The motivation for referencing the tear-proof laminate found on Blisterguard and perhaps Natralock is to demonstrate that these fiber-based alternatives to clamshells are not just a paper version of a clamshell; they are multi-material/chemical compositions that are only marketable as “tear proof” due to the addition of a variety of chemicals during the process of production. Without implying that the chemicals used in the Natralock adhesive/laminate are toxic/pose a hazard to human health as I am not privy to such information, it is important to acknowledge the following statistic about the inks/adhesives/laminates used in fiber-based packaging from the USA EPA’s Toxics Release Inventory Report :

Coated and laminated paper products are associated with significant reporting of releases and other waste management of toxics chemicals…Pollutants associated with various coating materials and processes have included emissions of volatile organic compounds and discharges of wastewater containing solvents, colorants, and other contaminants (EPA, TRI Data for Pulp and Paper, Ch. 5).

It would be great to conduct an LCA of a trapped blister pack like MWV’s Natralock vs. a, let’s say, RPET clamshell via the SPC’s comparative packaging assessment software COMPASS. Unfortunately, LCA tools like COMPASS don’t contain metrics for toxicity resulting from the inks, laminates and adhesives used in fiber-based packaging because: lack of life cycle data availability, lack of risk data beyond MSDS information, and that hazard is not easily correlated to toxicity based on mass of material. A respected LCA practitioner did explain to me that this need for risk data re: inks, laminates and adhesives used in fiber-based packaging like trapped blister packs IS being investigated via GreenBlue’s CleanGredients. He writes, “The fact that possibly the most toxic part of a package is not being assessed [by LCA tools like COMPASS] has not been missed by the LCA community.”

While we can’t conduct a holistic LCA of a trapped blister pack vs. a plastic clamshell because of the realities outlined above, we can conduct one comparing a PET clamshell to a corrugate box of similar dimensions via COMPASS; this is what I did to facilitate entry to GreenerPackage.com’s Database for Sustainable Packaging Suppliers--click here to see the third-party reviewed entry. Please note that I was only able to claim that the submitted RPET clamshell package “releases less GHG equivalents throughout life cycle than fiber-based packages of similar dimensions” because I provided this COMPASS LCA. As the data illustrates, the corrugate box releases more GHG and consumers more water, biotic, and mineral resources and results in higher concentrations of water toxicity and eutrophication than the plastic clamshell counterpart. Eutrophication is what contributes to the Gulf Dead Zone, which is where the absence of oxygen in the water has resulted in female fish growing testes as described in this National Geographic article.

Please understand that LCA tools like COMPASS are a constantly evolving tool; more LCI data is needed to paint a more accurate picture of the “sustainability” of any product. As such, this tool is appropriately deemed “COMPASS;” it helps illuminate where you are going but doesn’t always tell you where you are. In addition, though implied, I do not have information on how much paper and pulp production contributes to dramatic cases of eutrophication like the Gulf Dead Zone; it’s inclusion in this discussion was to demonstrate the complexities of “sustainability” as it pertains to different packaging materials and modes of production.

Next one should focus on the end of life management of trapped blister packs vs. clamshell packaging. As per the FTC Green Guide’s definition, in order to claim a package is recyclable, 60% or more American communities must have access to the infrastructure/facilities capable of sorting and reprocessing this material for remanufacture into new products and/or packaging. Unfortunately, as per this MSW report from the US EPA, clamshell packages AND trapped blister packs are not classified as recyclable insofar as there is no data on these packaging/material combinations (see table 21). As you can see , the high rates for paper recovery is attributed to newspaper and corrugate and those for plastic are attributed primarily to HDPE jugs and PET bottles. Those packaging categories listed “Neg.” like “other paper packaging/other paperboard packaging” means that not enough data is collected; this implies that all fiber-based packaging materials that fall outside of the categories listed are not recycled, contrary to popular belief.

The recyclability of materials used in combination to create the package depends entirely on the ability of someone (the end user or MRF) to separate the material constituents. After performing extensive research in the area of post consumer materials management, I have a hard time understanding how trapped blister packs, like MWV’s Natralock, are recycled due to the multi-material/chemical composition inherent in the package design…

Assumption 4:

Retailers are instigating the shift from clamshell to trapped blister packs like MWV’s Natralock because it is easier to open.

Consider the following excerpt taken directly from the NYT’s article:

“As a guy in packaging, I get all the questions — there’s nothing worse than going to a cocktail party where someone’s asking why they can’t get into their stuff,” said Ronald Sasine, the senior director for packaging procurement at Wal-Mart. “I’ve heard over the years, ‘How come I need a knife to get into my knife?’ ‘How come I need a pair of scissors to get into my kid’s birthday present?’”

That’s all fine and good—I am aware that consumers get frustrated trying to open their product packaging. The reason for the hard-to-open nature of the clamshell packaging is, as this article explains, to deter shop-lifters; it was Sam Walton himself who explained that products over a certain price point had to be packaged in clamshells to reduce shrinkage. However, clamshell manufacturers do not design their packaging to be frustrating to the consumer—in fact, most domestic manufacturers offer easy-open features and design the packaging to snap together, eliminating the need for secondary RF sealing. However, by the time the fulfilled package makes its way to a retail shelf, it has been RF sealed due to the requirements of the RETAILER, not the manufacturer. Don’t hate the players hate the game.

Now, consider this factoid taken directly from MWV’s webpage explaining Natralock: “The polymer-reinforced paperboard, along with our unique sealing process, makes the package virtually impossible to tear open by hand" (http://www.natralock.com/WhatIsNatralock/SecurityDurability/SecurityLossPrevention/index.htm).

Call me crazy, but doesn’t this imply that the package requires scissors, or another tool, to get into? If you can’t open it by hand, what can you open it with? Sooo how are trapped blister packs easier to open than clamshells?

Taken together, it is clear that this NYT’s article presents an overly simplified account of the requirements and realities of retail product packaging in the context of “sustainability.” As a representative of the plastics industry and a third-generation plastic clamshell manufacturer, I believe it is crucial that we combat these biased and scientifically unfounded perceptions about the “evils” of clamshell packaging; if we do not, clamshell packaging will continue to be targeted by self-serving actors looking to capitalize on the anxiety produced from notions of environmental destruction via our consumption habits.

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And the investigation begins!

Posted by Chandler Slavin on Oct 16, 2012 4:41:00 PM

Hello and happy September!

I hope everyone had a labor less Labor Day! I was able to get away to the beautiful dessert oasis of Arizona! For those of you who have never been, Arizona is beautiful! The vegetation is so bizarre and sparse and the horizon looks like it travels forever. And the stars! Don’t even get me started on the stars; all I know is that I was able to see more stars than I knew currently existed living in downtown Chicago for the last 5 years! All in all, good times.

Before I forget, I found the BEST Mexican restaurant in downtown Scottsdale! Called Los Olivos, this no-fuss authentic Mexican restaurant has been family owned and operated since 1919 and serves tortias bigger than my head, which you rip up to create your own tantalizing tacos, fajitas, burritos, what have you. Awesome!

AND, I went here!

http://www.rockstargallery.net/

If you like rock n’ roll, then you may as well have died and gone to heaven!

I have some super exciting Dordan news. While waiting for my flight from St. Louis to Chicago last week (I was traveling on business), I was contacted by someone from a National TV show who is investigating doing a series in 2011 about sustainability and business. Somehow, this show’s research team found Dordan and requested an interview about our sustainability efforts. After speaking with the assistant producer, I was asked for another interview, this time with Dordan CEO and President Daniel Slavin, to determine if Dordan’s Story to Sustainability would be a good fit for their series! Our interview is scheduled for today at 3:00. Wish me luck! Maybe I will get discovered as the actress I always knew I could be! Ha!

So that’s neato!

And now let’s talk packaging and sustainability.

As some of you know, several weeks ago one of Dordan’s customers inquired into this new “biodegradable” additive that when added to traditional polymers, render the plastic biodegradable in any disposal environment; be it by the side of the road, in our waterways, in a landfill, etc.

The company that distributes this product just had their first ad in the September issue of Pack World. Check out their ad in the digital addition?here, located on the right hand side of page 55.

http://digitaledition.qwinc.com/publication/?i=43523

Anyway, I set up a conference call with a rep from this company to learn about this additive’s various properties and afterwards, was more confused than before! I quickly put in a call to Robert Carlson of CalRecycle; Robert and I met last year at the SPC members-only meeting in Atlanta and he quickly became my go-to-guy for all things sustainable packaging. For some of my more diligent blog followers, you will note that Robert helped me with the inception and execution of my clamshell recycling initiative; he is a doll!

After providing a quick summary of our conversation, Robert mentioned that these “biodegradable additives” sounded a lot like the school of products known as “oxo-biodegradables,” which he explained as follows:

Oxo-biodegradation, or those products considered “oxo-biodegradable,” require/s oxygen and sunlight to initiate the breakdown process. Oxo-biodegradables have been used in Europe for some time now, though much concern has been voiced over issues pertaining to the complete biodegradation of the polymer (total consumption via microorganisms present in intended disposal environment); and, ambiguities surrounding biodegradation testing standards. Further concern has been raised about these additives’ impact on existing recycling technologies insofar as they may jeopardize the value of the post-consumer material by rendering it partially—or entirely—“biodegradable.”

After chit-chatting for close to an hour about biodegradable plastics and everything under the sun, Robert concluded that he would check out the company’s website and get back to me with more insight.

In the meantime, I conducted some preliminary research on the term “oxo-biodegradable” as I knew so little about the concept or the science behind it.

I reached out to my contact from a working-industry group that Dordan is a member company of, inquiring about his opinion on “oxo-biodegradation.” He subsequently sent me a plethora of documents on the issue. While I was waiting to retrieve these documents from the printer for my analysis, I received an email from Robert:

Chandler,

I've passed this on but from what I read, it doesn't seem like it IS oxy-degradable. It seems like it's something different...however I'm not sure what to make of it so I'm checking in with a few of my co-workers...

Hmmmmmmmm…

I then sent the company rep with whom I spoke about these biodegradable an email requesting a synopsis of his products’ attributes. This is what he sent me:

Quick facts:
    • Biodegrades plastics to humus (soil), CO2 & methane (converts to energy);
    • 100% organic – non-starch based;
    • ASTM tested and validated with data available;
    • Recyclable;
    • FDA compliant;
    • Does not change the manufacturing process;
    • Added to current resins at approximately 1%;
    • Does not affect shelf-life;
    • Does not change tensile or physical properties;
WOW, I thought to myself as I skimmed over the “facts” about this product…what do these claims actually mean?

Let’s start with a biggie—certification. I put in a call to the company rep, asking what certification they had received for their marketed “biodegradable additive.” He referenced ASTM 5511, which he explained as certification for plastic biodegradation in a landfill.

I rallied this information to Robert. What follows is his feedback:

Hey Chandler,

I asked a few people in my office about that ASTM testing standard as well as the potential for these plastics to degrade in the landfill.

This is what I received from our degradable plastics expert:

The intent of ASTM 5511 is not to establish the requirements for labeling of materials and products as biodegradable in landfills. ASTM 5511 is a standard test method, not a standard specification. As such, ASTM 5511 provides the testing procedure to measure the degree and rate of biodegradation of high solids in anaerobic digestive systems. This procedure is not intended to simulate the environment of any particular high-solids anaerobic-digestion system. However, it is expected to resemble the environment of a high-solids anaerobic-digestion process operated under optimum conditions. This test method may also resemble, not simulate, some conditions in biologically active landfills.

Weird bears; how convoluted can we get? A certification for a testing standard, not a certification of complying to said standard? Huh?

I googled “ASTM 5511” and found that I had to buy the Standard to have access to its qualifications. Dang.

Then I sent the company rep another email, inquiring into some of the other claims made:

Hey,

This is Chandler Slavin with Dordan, we spoke several days ago about your biodegradable plastic additive.

First, thanks for the information about your product! I am in the process of looking through the literature and performing some research.

What follows are some questions about your product:

One of the claims about your product is 100% recyclability, which implies that if added to a traditional RPET beverage bottle, it would not result in the breakdown of the resin when reprocessed and remanufacured into, let’s say, green industrial strapping. Can you expand on how a biodegradable additive does not render the recyclate "weak" when compared with recyclate without a presence of this biodegradable additive?

Does this additive allow for the biodegradation of plastic in other disposal environments besides a landfill, such as on the side of the road (as litter), in our marine and freshwater environments, etc.?Are you familiar with the concept "bioaccumulation," which results from the accumulation of small plastic particulates being ingested throughout the food chain? If you product allows for the biodegradation of plastic, does it ensure the complete breakdown of the polymer i.e. total consumption of material by microorganisms in disposal environment???Thanks for your time; I look forward to hearing from you soon!

Chandler

The next day, I received the following “answers:”

Chandler,

In regard to your first inquiry:

Our product is a nutrient that attracts microbes when they are present. PET or RPET going through distribution will not come in contact with active microbes and therefore no biodegradation will occur. There would therefore be no reduction in physical properties until the plastic is placed in a landfill or compost. We have experience in this area and I can tell you that the material is not weakened.

In regard to your second inquiry:

Yes, we believe so. We have run ASTM D 5988 (litter test) and have seen very nice results. We have some indications for ASTM D7081 (marine, salt or brackish) testing that we will have good biodegradation. However, I don’t have data here that I can share. Regarding the freshwater, we believe we will have good biodegradation; we are looking at testing in this area and have not done any to date.

In regard to your third inquiry:

This really is applicable to oxodegradable additives. Our product does not fall into this category. Our product attracts the microbes that then take the long chain carbons in synthetic polymers and break them down to CO2 and CH4. We don’t leave plastic particulate behind.

Thanks!

And around we go!

Tune in tomorrow to learn about the validity of these claims; reference will be made to many different position papers published by the Society of Plastics Industry Bioplastics Council, European Bioplastics, Biodegradable Products Institute, and more!

It’s great to be back!

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I heart Dordan!

Posted by Chandler Slavin on Oct 16, 2012 4:29:00 PM

Hello world! Again, I apologize for my lack of blogging this week. I just thought I would let the recycling report marinate for a bit…

Anyway, guess what happened yesterday: the Metra train that I take from Chicago to the office everyday HIT and TOTALED a car at the Des Plains stop. It was totally crazy!

Read the press release here:

http://www.nbcchicago.com/news/local-beat/Car-Bursts-into-Flames-Driver-Killed-After-Train-Collision-99950479.html.

Ironically, and not to get all metaphysical or anything, but as one soul left this world, another came in. Check out this article about how a pregnant woman gave birth in the traffic caused by the Metra accident:

http://www.nbcchicago.com/news/local-beat/baby-delivery-firefighters-birth-train-accident-metra-100021949.html.

Weird bears. And, totally unrelated but worth mentioning, they are filming Transformers literally a block from my house—I got to see the transformer trucks and everything!

Okay, enough personal embellishments for the day.

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RPET vs. PET & Inks, laminates and adhesives

Posted by Chandler Slavin on Oct 16, 2012 2:45:00 PM

Good afternoon world! Thought I would catch you all before the late-afternoon slump, which is when I am accustomed to blogging. Second cup of Joe, here I come!

Today’s post takes a slight detour from the world of recycling: I wish to briefly discuss how one quantifies the environmental benefits of sourcing packaging material from recycled resin versus virgin; and, the associated environmental burdens of using inks, laminates and adhesives on fiber-based packaging.

First, the environmental benefits associated with making packaging out of recycled resin versus virgin is kinda a no brainer…one would assume that sourcing post-consumer material yields environmental benefits when compared with sourcing virgin. Luckily, the Franklin Associated recently determined that recycling plastic significantly reduces energy use and greenhouse gas emissions. According to their work, the generation of cleaned recycled resin required 71 trillion Btu less than the amount of energy that would be required to produce the equivalent tonnage of virgin PET and HDPE resin (Killinger, ACC). In other words, the amount of energy saved by recycling PET and HDPE containers including bottles in 2008 was the equivalent to the annual energy use of 750,000 U.S. homes. The corresponding savings in greenhouse gas emissions was 2.1 million tons of C02 equivalents, an amount comparable to taking 360,000 cars off the road (Killinger, ACC). You can download the full report here: Final Recycled Resin HDPE PET Life Cycle Inventory Report.

So this is great because it finally provides justification for moving into PET and RPET packaging as that is the most readily recycled and recyclable. However, how do we show how this data actually impacts the LCA of a package? In other words, if I wanted to measure the environmental benefits associated with sourcing my packaging from RPET as opposed to PET, how would I?

And enter COMPASS, which is the SPC’s packaging environmental life cycle modeling software, which allows you to compare the “footprint” of different packaging materials and types in the design phase. Now that Franklin has provided LCI data about RPET used in packaging, COMPASS should be able to integrate the data into its software, thereby allowing users to compare packaging made from recycled PET versus virgin.

Here’s the email I sent to the creator of COMPASS:

Hey,

I hope this email finds you well.

I had sent you an email asking when COMPASS was going to be updated with the LCI RPET data released by the ACC/APR/NAPCOR, etc. This email is to follow up on that inquiry. As thermoformers of RPET, it is very important for us to be able to quantify the environmental benefits of sourcing an RPET clamshell versus a PET clamshell.

In addition, is COMPASS intending on including metrics for inks, laminates, and adhesives i.e. clay coated SBS board? A lot of research I am finding is that these chemicals greatly impact the environmental profile of a package; when will COMPASS be able to quantify these components?

Thanks for your time.

Chandler

And his response:

Hi,

See below.

Hey,

I hope this email finds you well. Thanks doing well indeed. And you?

I had sent you an email asking when COMPASS was going to be updated with the LCI RPET data released by the ACC/APR/NAPCOR, etc. This email is to follow up on that inquiry. As thermoformers of RPET, it is very important for us to be able to quantify the environmental benefits of sourcing an RPET clamshell versus a PET clamshell. As you may know, we do not add data until they are third party verified. There has been a lot of activity on the data front of late and the data verification is coordinated by the EPA, and rPET and rHDPE are among them. Once we get the go ahead, we will begin work to model the data for COMPASS. This is anticipated to start towards the end of Q3 2010.

In addition, is COMPASS intending on including metrics for inks, laminates, and adhesives i.e. clay coated SBS board? A lot of research I am finding is that these chemicals greatly impact the environmental profile of a package; when will COMPASS be able to quantify these components? The secondary materials you mention may indeed be of concern and they are on our radar, however, since GreenBlue does not collect primary LCI data, we cannot add information until they become available and are verified. There is a lot of talk in the industries about the need for such data, and the best way to convey the information. We may have spoken on this before, but coatings, inks, glues etc are generally used in a very small quantity relative to the primary materials, and the existing display mechanism may need to change to record the results for the secondary materials. Also, since LCA is not a very good mechanism for conveying toxicity, the entire secondary materials module may require some detailed thought prior to implementation. I do not have a timeline for these materials as yet since much of the work in preliminary talk stage only.

Groovy…

I then sent a similar inquiry to another contact who knows a thing or two about sustainable packaging metrics and modeling software:

Hello,

This is Chandler Slavin with Dordan Manufacturing. I hope this email finds you well.

At the meeting, a participant asked if you intended on including any metrics for the inks, laminates and adhesives used in many fiber-based packaging materials. You replied that unless you had scientific evidence that illustrated that such a metric had an impact on the overall environmental profile of a given package, you did not intend on including said metrics in the Scorecard.

I found the following statement in the U.S. E.P.A.’s TRI (Toxics Release Inventory) report, 1996:

…Coated and laminated paper products are also associated with significant reporting of releases and other waste management of TRI chemicals…Pollutants associated with various coating materials and processes have included emissions of volatile organic compounds (VOCs) and discharges of wastewater containing solvents, colorants, and other contaminants.

Download the report at: http://www.epa.gov/tri/tridata/tri96/pdr/chapt5_ry96.pdf

That being said, what are your thoughts on the inclusion of some type of metric that would attempt to quantify the environmental burdens associated with the utilization of inks, laminates, and adhesives on packaging?

Thank you for your time.

Chandler Slavin

And her response:

We aren't opposed to including but we need to have details on what to include and how much they impact the total Life Cycle of the package.? In studies that I have seen on packaging the impact by these materials to the total package LCA are small in comparison than other parts like production of raw materials and transportation.? Prior to us adding to the scorecard we would need the data proving they are a big portion of the LCA and publicly available LCI to add to the scorecard.

Thanks for reaching out sharing some of your questions and concerns.

Hmmmmmm…

I replied the following:

During the meeting, you and your team discussed the ambiguities surrounding the “sustainable material” metric and participants articulated the desire for a “material health/toxicity” metric, in addition to, or as a component of, the “sustainable material” metric. Have you and your team given any thought to the inclusion of such a metric that does not rely on an LCA-based approach, but another “mechanism for conveying toxicity?”

I look forward to your response; thanks again for your time!

And her response:

Yes, we are analyzing the GPP metrics?through the Pilot process as discussed at the meeting.?

She then provided me with a link to their website and other pertinent information; what a doll!

The GPP is the Global Packaging Project and it is super awesome! It looks to provide global metrics for quantifying the environmental profile of a material, packaging type, conversion process, etc. Tons and tons of CPGs and retailers and manufactures and packaging converters are members of this organization. I believe they are currently in a pilot phase, which is attempting to collect LCI data from primary processes.

I reached out to a representative from the GPP and she was really nice. She told me about their work and provided me with access to said work—I feel like I hit a gold mine! Unlike the Scorecard, the GPP will cover a multitude of different metrics, toxicity being among them. SOOOO I guess I am definitely not the only one interested in this and eventually, we will have much more thorough tools to measure the environmental repercussions of our packaging purchasing decisions.

Consequently, it’s only a matter of time until the greenwashers get phased out. I feel like we are in the Wild Wild West of packaging and sustainability and that eventually, some governance will come to maintain order—hopefully the GPP.

AND GUESS WHAT: The GPP is having a conference in October in PARIS. That’s right, Paris, the most romantic city in the whole wide world. I would kill to be able to go; hopefully I can make a good enough case for my Superior to consider it…

The last email that I sent along this theme was to the wonderful Robert Carlson of CalRecycle.

I wrote,

Hello there!

Question: why is an LCA-based approach not appropriate for trying to quantify the environmental ramifications of secondary materials i.e. inks, laminates and adhesives? In addition, what “other mechanisms” exist for quantifying these ramifications? How do you foresee the inclusion of this information in environmental modeling tools going forward?

Do chemical manufactures have to report their releases to the US EPA? If so, where/how can I access this information?

AND, I was reading the back of one of our competitors’ packages and the following verbiage was displayed: “This product contains a chemical known to the state of California to cause cancer and birth defects and other reproductive harm.” WHAT THE WHAT? What is this, where can I find out more?

Thanks buddy!

And his response:

Ok…let me try to take this piece by piece and see what I can help you with:

As far as the competitors’ package goes, there are LOTS of chemicals that require that warning, it’s all part of prop 65 (see the attached PDF for the complete list and their website http://oehha.ca.gov/prop65.html ).? There is very likely a Material Safety Data Sheet available for that product…you might check on their website.

As far as manufacturers reporting their emissions to US EPA…I’m not really sure but I don’t think they do generally.? There are very likely specific situations that are regulated and are required to report emissions to EPA…but I’m not familiar enough with them to tell you which ones are required to be reported on.

Now…on to the meat of your question…the inks, laminates and adhesives…? I’m not sure what you meant with the comment that LCA is not a good mechanism for conveying toxicity…? Perhaps it has to do with the fact that usually LCA don’t get into exposure…? If a product emits 1.2 grams of a toxic substance, that’s all that is reported…it doesn’t really get into whether it’s emitted close to people, if people have long contact time with it or short, if sensitive sub-populations are exposed or not, if the toxin is persistent or not, if workers are exposed or consumers, etc…? That may be what was meant… ?It could be that a combination of an LCA (to determine the releases at various points in the process) and a toxicological assessment of some kind (to determine exposure and risk assessment) would be a better way to approach LCA for these kinds of materials.

?There are always data gaps…there always will be.? To some extent, you can’t measure what you don’t know...? BUT somebody has to collect that data!? Eventually!? So somebody is going to have to step up and foot the bill…the problem of course comes in the sense that nobody trusts industry and government is broke…

How’d I do?? Make any sense???

You did wonderful, Robert, thanks!

That’s all for now. Tune in tomorrow to learn more about packaging and sustainability and the feasibility of recycling PET thermoforms in North America.

Tootles!

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GO BLACK HAWKSSSSSS

Posted by Chandler Slavin on Oct 16, 2012 2:41:00 PM

Happy Monday Funday!!!

I have returned from my travels. GO BLACK HAWKSSSSSS!!!!!!!!!

While I will fill you in on what I learned in tomorrow’s post (busy day!), I thought I would include a response to my greenerpackage.com post. Check it out (notice the “anonymous”…)

June 9, 2010, Anonymous (not verified) wrote:

Chandler - One point that can't be argued. Packaging from trees is a sustainable option. Packaging from oil (like plastic films) is not - once its pumped out and converted into film products, there will be no more. It would be ideal to compare apples to apples and determine which causes less harm to the planet, however, the opportunity to replant trees and convert paper back into usable pulp is an obvious advantage. And the article makes a solid point that regardless of what might be possible for recycling films, consumers or municipalities rarely have the facilities for taking advantages of the possiblities of recycled film products.

June 11, 2010, Chandler Slavin wrote:

Thank you for your comments and I understand your perspective; however, I am a little confused by this statement: “Packaging from oil (like plastic films) is not [sustainable] - once it’s pumped out and converted into film products, there will be no more.” Are you simply making the argument that paper is sustainable because it comes from a renewable resource while plastic is not because it comes from fossil fuel, which is ever depleting, as dramatically illustrated by the tragic Gluf Coast Spill? If so, that argument is acceptable, but very one dimensional, in my opinion. The reason I feel that this argument is sub par is because it only highlights the different feedstocks used in the production of fiber-based packaging materials or fossil-fuel ones; what about the energy required to convert this feestock into its end-product, that is, paper or plastic? What about the resources consumed in this converstion process; the GHG equivalents emitted therefrom, the inks, laminates, or chemicals added, etc.? I guess the whole point of my post was that to view “sustainability” from one metric, be it renewable versus unrenewable feedstock, is unacceptable in trying to quantify the overall burden a specific packaging material has on the environment.

As an aside, the point about the complexities of recycling plastic packaging is appropriate; with the exception of PET bottles, the rates of recycling plastic packaging in the States is very low. However, Japan, the UK, Belguim, Germany, and many others have very high diversion rates for plastic packaging post-consumer, usually with the aid of waste-to-energy technologies. Because we live in a global market, I am sure that the products of a large CPG company, like Kodak, end up on many international shelves; therefore, the probability that the packaging will or will not end up in a landfill is constituent on the region in which it is distributed. Consequentially, it is difficult to speculate on how much packaging material a company diverts from the landfill by switching from one material to another without specifying what geographical region said packaging material resides in.

In addition, there is a lot of interest in diverting PET thermoforms from the waste stream, as there is an every growing demand for this recyclate. Many companies are now investing in the sorting and cleaning technologies necessary to reprocess these packages with PET bottles to remanufacture into new packages or products. Hence, it is only a matter of time until plastic packaging begings to be recovered post-consumer because of the inherent value of the recyclate.

Thank you for your comments; it is always good to move the dialogue forward!

Mahahahahahahhahaha. See you tomorrow!

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Anti-plastic claims analyzed

Posted by Chandler Slavin on Oct 16, 2012 11:04:00 AM

Hey!

So in yesterday's post I talked about an article I read on greenerpackage.com that dissapointed me due to its unfounded anti-plastic stance. I? included a letter that I had intended on sending to the disseminator of said anti-plastic stance because I didnt want to call him out in the public forum that is greenerpackage.com; however, our CEO wanted me to post a rebuttal to his comments on greenerpackage.com, so this reductionistic stance on plastic can begin to be confronted.

Here we go:

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Holly Toledo!

Posted by Chandler Slavin on Oct 16, 2012 10:59:00 AM

Happy Friday!

So I have been working on a presentation on everything sustainability for one of Dordan's customers. Sustainability and Packaging 101, per se.

Anywoo, it took me two days and 190 slides to finish, but I am FINALLY DONE!

It's jam packed with good stuff--basically a summary of all my work to date--so check it out!

Sustainability and Packaging Presentation, Blog

Enjoy the heat-wave this weekend, my fellow Chicagoians!

Also, please do not reproduce or distribute without my written consent. Thanks!

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Recap # 2: Walmart Expo

Posted by Chandler Slavin on Oct 16, 2012 10:45:00 AM

Greetings world! I feel like a million bucks—finally cleaned my office and organized all the information I gathered the last several weeks traveling. I will now resume my diligent blogging!

Soooo, where did I leave off? That’s right, I still need to fill you all in on the Walmart Expo in Arkansas.

Well, first of all, Arkansas is really nice! The drive from the airport to Bentonville was beautiful—very lush and it smelled so good! It appears as though the entire town of Rogers-Bentonville has been created to sustain the Walmart community, which is crazy! All the main buyers and movers and shakers for and to Walmart live around the headquarters, which must make company outings easy and enjoyable! Everyone we met was super duper nice and the whole “dry county” thing didn’t really apply because every restaurant we went to suggested you “sign in” thereby giving the establishment the status of a “club” and consequentially allowing them to serve us booze!

The Expo itself was really exciting! It being my first time “working the booth” I was thrilled to get in front of the packaging community and talk about Dordan and all our exciting new happenings! All the passerbyers were, again, super awesome and polite and all in all it was a good show! I got to see some old packaging buddies from the SPC and meet more people within the industry. Because I have only been to one or two other conferences, I was surprised to run into people that I had met previously—I didn’t realize what a small community the sustainable packaging realm was!

Check out our beaut of a booth:



AND all the Walmarters are really, really nice. Some of the top guys came by our booth and asked how the show went and thanked us for coming. We couldn’t believe the hospitality of the entire event and look forward to participating next year! If any of you Walmarters are reading, thanks again, we had a blast!

It was really cool too because our engineers had JUST finished running our samples that we designed for the Expo literally hours before we flew out of Chicago, which gave us the ammo we needed to initiate conversations with anyone. They looked great and showcased our thermoforming capabilities; and, demonstrated the different materials we were now offering! Basically it is a fancy business card holder with cool engravings and what not and the tray is made out of a bio-based, certified compostable resin and the lid is made from supplier-certified 100% PCR PET, which derives its feedstock entirely out of bottles post-consumer. We found that having something tangible to give to passerbyers really helped initiate discussion and we got a lot of attention because of the clarity of the PCR PET. For those of you not familiar, high concentrations of post-consumer content in PET often times give the resin a sort of orangy-brown tint; our source for 100% PCR PET, however, ensures a level of clarity that we have not been able to find elsewhere. In a nut shell: Good times all around.

This is a sort of poopy picture of our sample offer; but you get the idea:



During the Expo there were education sessions, too. I found the content of these sessions very interesting and compiled my notes to debrief our sales and marketing departments upon my return. I have included these notes below, FYI.

Walmart Expo Summary:
    • Scorecard seminar, misc.

        • ECRM created the software for the Walmart Scorecard

            • “Efficient collaborative retail marketing”

        • Direct suppliers are REQUIRED to enter packages into scorecard

            • Via “retail link” i.e. per vendor number and item number

            • Allows you to compare with packages in same product category i.e. dairy. ECRM is working to narrow the categories down so you are only compared with direct competitors.

        • Indirect suppliers do not have access to retail link.

        • Focus of Score: Material type, material weight, material distance, packaging efficiency

            • Distance: the point the package travels from point of conversion to point of fulfillment.

        • Completion rate of Scores:

            • 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. In other words, suppliers that have more than 85% of their Scores completed receive an “A” in the Walmart world; suppliers that have 55% complete receive a “B;” everything below comes up as a “red flag” in Walmart-internal.?

        • Package modeling software: Different than the Score card but formatted the same way; this is what we subscribe to.

            • Intended for indirect suppliers to utilize the modeling software in such a way that they can approach their customers (direct suppliers to Walmart) and explain how by doing X you can improve your score and here is the proof.

            • “Reversed engineering;” encouraged doing this on competitor’s packages, too.
    • Paperboard Packaging Council seminar, misc:

        • Fiber-based packaging is a by-product of the lumber industry? I need to look into this…

        • I asked why the recovery rates for corrugated were higher than paperboard…

            • Answer: Difference is attributed to post-industrial collection (corrugate) vs. post-consumer (paperboard). I need to examine this further.

        • Fibers can be recycled 6-8 times before the fibers become too small to reprocess

        • China currently buys most of our post-consumer mixed paper and reprocesses it; we need to find a domestic source for recycled fibers.

        • All corrugated has 46% post-industrial content in the U.S.

        • SBS is almost ALWAYS virgin fiber, with the omission of MWV’s Natralock.

        • I asked what the difference in energy demands are for virgin vs. recycled paper; I received a very ambiguous answer?apparently a controversial topic.
    • Plastic fundamentals seminar:

        • Discussed the benefits of plastic such as:

            • Keeps food fresher for longer;

            • Lightweight;

            • Didn’t address fossil fuel consumption;

            • Didn’t discuss MSW rates;

            • Did say that recycling for non bottle-PET has grown from 7.5% to 11% in the last year;
        • ACC supports re-writing the Toxics Control Act, which we referenced in our first Newsletter.

        • The ACC released LCI data on RPET and recycled HDPE. HURRAY!
    • SVN meeting:

        • There are a ton of different organizations that Walmart has its involvement in; I will try to explain the various relationships as follows:

            • ISTA—transit assessment; I don’t know what this is.

            • Global Packaging Project: Walmart funds this but is not the only CPG company on the board; this looks for a GLOBAL metric for assessing the sustainability of packages and product; this is bigger than the Scorecard, as the Scorecard will be a component of these metrics; the metrics used will be country-specific. This grew out of the CONSUMER GOODS FORUM, which was originally called the GLOBAL CEO FORUM. The GPP metrics look to take into account the Scorecard metrics, COMPASS, and other existing and legitimate metrics. If one wants the inclusion of another metric, it must be reviewed for application prior to being incorporated into the GPP metrics.

            • ISO project for Sustainable Packaging: I don’t know.

            • Scorecard: For packaging only; scores based on ITEM level.

            • Supplier Sustainability Assessment: Consists of 15 questions, which are asked of all product suppliers to Walmart; “scores” based on CORPORATE level.

            • Sustainability Index: the Assessment is part of the Sustainability Index, which is a project of the Sustainability Consortium. Again, Walmart funds this organization but is not the only CPGs company that participates.
    • Points of discussion:

        • “Sustainable material” metric: What does this mean? What are the limitations?

            • Should everyone get the same “score” until clarified?

            • Should we remove the metric?

            • Is Recovery taken into consideration?

            • Is it a LCA approach?

            • Does it consider conversion or primary production?

            • What about toxics?

            • Sourcing certificates?
        • Determined that it would be helpful to have a health and safety metric AND a sustainable sourcing metric.
  • Should inks/adhesives be included in GPP and Scorecard?
    • Not until proof that it has an impact?I have proof and will see that it gets into the right person’s hands.
Sorry if the format of my notes are a little confusing. Please let me know if you would like me to expand on any of these points or provide clarification.

AND I met a gentleman that gave me a PLETHORA of information about non-bottle plastic recycling and I am forever indebted to him. Seriously, good stuff and AMAZING feedback in regard to the various approaches I was considering for our clamshell recycling initiative. Once I get through recapping my recent travels, I will resume my clamshell recycling narrative. I think we are getting somewhere

Stay tuned!

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Day 12: Oct. 26, 2009

Posted by Chandler Slavin on Oct 16, 2012 9:49:00 AM

Happy Monday Funday!

I hope everyone enjoyed the Superbowl. What was your favorite commercial?

I swear, my job as the Sustainability Coordinator at a plastic company is making me crazyyyyyy! I interpret any reference to the environment and plastics in the context of popular culture as a case to be studied; as an academic text to be analyzed.

Such crazyiness manifests itself in my life outside work, when, for instance, I am watching the Super Bowl with friends, drinking beer and eating pizza.

And roll Audi commercial about the Eco-police:

Opening scene: Would you like paper or plastic?

My ears perk up; my senses ready.

Plastic, the man at the check-out counter says.

Enter: Eco Police. They arrest the man at the counter, thereby implying that because he opted for plastic, he is transgressing against our ecosystem. Ug!

And the funny thing is, Obama suggested that American-produced cars utilize more plastic in their construction than previously manufactured cars because it makes them lighter; therefore, less energy consumptive.??

AND the new Audi has plastic components for this very reason. It’s cool though—I understand what the marketers of this car were going for; after all, this Audi runs on diesel, which releases less green house gases than the burning of fossil fuel. So that’s neat. I just wish they wouldn’t continue to propagate the notion that plastic is bad for the environment when, because of its lightweight and versatile properties, it actually facilitates innovation in the field of sustainability.

You can check out this commercial at: http://www.youtube.com/watch?v=O_MuqoSsuTQ&feature=player_embedded.

Anyway where am I? Oh that’s right; awaiting an email from the educational tour guide from Recycle America…

Until I speak with this contact about the contents of this email and receive her approval to include it in this blog, I am unable to continue the narrative at this point. Sorry for the inconvenience.

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Day 10: Oct. 21, 2009.

Posted by Chandler Slavin on Oct 16, 2012 9:47:00 AM

The next day I received the following email from the educational tour guide at Recycle America:

Chandler,

I just received this and will gladly answer as best I can but it will not be until tomorrow as I have tours.I appreciate your patience.

Lisa

Okay…what else can I do in the meantime to move this initiative forward?

I thought back to the lectures at the SPC’s members-only meeting in Atlanta. The president of Environmental Packaging International (hereafter, EPI) gave a very honest presentation about environmental marketing. Basically he explained what kinds of environmental claims on packaging are misleading or manipulative and what kinds are acceptable. Because the FTC is being restructured, he explained, they have not been able to investigate the environmental claims on packaging; however, that will change, and those making unsubstantiated or vague claims will be sought out by the FTC. Therefore, he explained, it is in all of our interest to only make claims that can be validated via scientific analysis.??

Hurray, I remember thinking. Finally, marketers will be held accountable for manipulating consumer’s desires to do well by the environment.

To be honest, I probably would not have a job at Dordan as the Sustainability Coordinator if people in our industry were not greenwashing. In other words, it was because my father, the CEO of Dordan, didn’t know how to interpret the claims being made by our competitors that he hired me to investigate them. And what I found, more often than not, was because the FTC didn’t have the man power to investigate environmental claims our industry was in sort of a Wild West limbo where marketers could get away with saying almost anything. This Wild West limbo was catalyzed by the recent consumer research that showed how most consumers would buy the product with the better environmental profile if at a comparable cost and performance to other, less environmentally friendly products. I am sure we are all familiar with this…

Anyway, I remember the President of the EPI discussing the Mobius Loop symbol and how that can be a form of greenwashing in and of itself insofar as it implies recyclability or recycled content. All of our packages have this symbol, which houses the SPI resin identification number; both the symbol and ID number were mandated by SPI (Society of Plastics Industry) decades ago.

I sent the President the following email, hoping to get some clarification about the applicability of this symbol to our packages:

Hello,

This is Chandler Slavin with Dordan Manufacturing—we spoke briefly following your presentation in Atlanta entitled, “Are the Labeling and Green Claims on Your Packaging Meeting FTC and Retailer Requirements?” First, I wanted to take this opportunity to express my gratitude for your presentation: it was the most honest, direct, and educationally insightful discussion I had yet experienced at the forum. At the same time, however, there are some questions still lingering.

For instance, you said that the mobius loop i.e. chasing arrows symbol, which houses the SPI resin identification number, implies to the consumer that the package is either: (1) made out of 100% recycled material or, (2) is 100% recyclable. After telling this to the president of our company, we were confused because we thought that this symbol was mandated by the SPI. Are you and the FTC suggesting we remove this symbol from our packages? Is there someone at the FTC we could talk with for clarification? Is there someone at SPI that would be of assistance?

Sorry for the quick-fired questions: this is all new to us and we are trying to be honest with our labeling in order to inform our customers about the sustainability of our packages. Additionally, I would really like the opportunity to talk to you about industry-led EPR initiatives in the U.S. When would be a good time to reach you?

Best,

Chandler Slavin

The same day, I received the following email from the President of the EPI:

Chandler,

The SPI code as required by 39 State Laws are allowed if used as prescribed by those laws. If you placed it in an inconspicuous location on the container (e.g., embedded in the bottom of the container) it would not constitute a claim of recyclability or recycled content and is allowed.

If you have a questions let me know, Hope this helps.

Phew…I thought to myself; we only place the chasing arrows symbol on the bottom of our packages. We are FTC clear, at least for now.

Tune in tomorrow for more recycling in America tantalizing tid bits.

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