Washington State PCR Mandate Gets Many Questions

HOUSTON (CIHI) – Passed in May, Washington state’s plastics sustainability law continues to spark questions from affected industry participants. Many details regarding the implementation and enforcement of post-consumer recycled content (PCR) requirements remain to be determined.

Late last month, Alli Kingfisher, statewide recycling coordinator at the Washington Department of Ecology, sought to review SB 5022 and answer questions from packaging producers, recyclers and of consumers. The inquiries covered several themes, such as PCR content calculations, the scope of packaging products included in the mandate, and supply chain concerns.

As Washington, California and Connecticut develop PCR warrant programs, preliminary conversations like these will be crucial in shaping future PCR legislation nationwide.

Kingfisher agreed that this level of industry involvement is exactly what his organization needs. As regulations continue to evolve, the collaborative relationship between lawmakers and the recycling or packaging industries must be strengthened, she said.

The bill covers several topics, including the minimum PCR content in plastic packaging, the removal of expandable polystyrene (EPS) in certain applications, and the removal of the arrow hunting mandate from recycling labeling.

Lawmakers set the general framework of the PCR mandate to apply to plastic beverage bottles, garbage bags, and plastic personal care / housekeeping products. It will go into effect on January 1, 2023, with several increases in the minimum percentage from 10% to 50% of PCR content over the next ten years. The remaining details are to be determined within the next year, Kingfisher said.

Below is a list of questions from the session that illustrate the many complexities of packaging and the global scale of packaging and product producers.

  • How is the minimum PCR content percentage calculated?
    • Is it the percentage of the entire package, or is it the percentage required in each individual component (i.e. cap vs bottle)? Is it by individual packaging or by average of total products manufactured / sold (i.e. if some packaging is 100% PCR and others 0%, but the average equals the minimum percentage)?
  • What is the scope of the packaging concerned?
    • Does the law apply to all beverage or personal care / household cleaning packaging that uses plastic to some extent or only to predominantly plastic packaging?
    • Is there an exclusion for plastic packaging made from organic or renewable raw materials?
    • Does tertiary packaging apply (i.e. packaging or films)?
    • Should certain end-user markets (i.e. medical packaging) be excluded?
  • Does the PCR material meet the objective of the circular economy?
    • Can PCR resin come from both mechanical recycling and chemical recycling production process?
    • How is post-consumer recycling defined?
    • Should post-industrial equipment also be included?
  • Will there be certification processes required to confirm PCR content?
  • Should the PCR content requirements be the same for all resins? Has the current supply of PCR resin been factored into the increase in PCR content?

ICIS is currently preparing a prototyping of a US report on recycled polyethylene terephthalate (R-PET), covering premium and curbside bales by region, mechanically recycled R-PET flakes and R-PET pellets. . To learn more about the new report or to receive a copy of the prototype, please contact Emily Friedman at [email protected]

About Thomas Hereford

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