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THE REMA FIBER RECYCLING

READINESS TOOL

The ReMA Fiber Recycling Readiness Tool focuses specifically on recycling
post-consumer fiber-based packaging that will be marketed in the United States.

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THE REMA FIBER RECYCLING READINESS TOOL

The ReMA Fiber Recycling Readiness Tool (Tool) focuses specifically on recycling
post-consumer fiber-based packaging that will be marketed in the United
States.   The Tool is a research-based approach for users to assess the extent
to which fiber-based packaging is compatible with the current US residential
recycling system and does not pose known challenges for that system. The
methodology for the Tool is based on the ReMA Board of Directors-approved
definition of recyclable materials, which is “a previously used material that
can be processed into specification-grade commodity for which a market exists.”

The Tool is an online resource that automatically scores each criterion based on
the methodology research conducted for development of this tool. The results
will determine whether the packaging meets the criteria of the Tool, has
challenges that require modifications, or does not meet the criteria.
Paper and paperboard are some of the most widely recycled materials in the
world. Paper recycling recovers fiber that can be used to manufacture other
paper products while producing jobs and protecting the environment.

The Fiber Recycling Readiness Tool is a living document that will be reviewed
and updated to reflect current technologies and market conditions within the
recycling process on a regular basis. The scoring methodology was developed
based on results of several empirical studies including the 2021 ReMA Paper
Recyclability MRF (Materials Recovery Facility) Survey conducted by Moore &
Associates on behalf of ReMA.

Purpose
The purpose of this Tool is to help reduce confusion on the part of packaging
and product manufacturers and designers, regarding the ease that fiber-based
packaging that can or cannot flow through the current recycling infrastructure,
given pressure points in the current recycling system.
The following principles guided the development of this Tool:
 * The primary audiences for the Tool are fiber-based packaging manufacturers
   and brand owners of consumer products that use fiber packaging in categories
   such as food and beverage, personal care, and electronics.
 * The decision criteria for the Tool are transparent so that users know the
   specific criteria that need to be addressed.
 * The Tool incorporates all stages in the recycling process from packaging
   design to end-use markets. Users will receive the results in writing
   including additional information and/or recommendations if any.

Scope & Eligibility

This first edition of the Tool is for fiber-based packaging that are currently
bought and sold, or will be launched in the United States. Biodegradability and
compostability are not addressed by the Tool. 
 
The focus of the Tool is to determine whether the packaging can be effectively
flow through the current residential recycling infrastructure and does not
assess recycled content. For packaging to be recycled in the U.S., the following
criteria need to be met:   

 * The packaging meets the U.S. Federal Trade Commission (FTC) requirements for
   recyclable claims.  
 * The packaging is likely to be successfully sorted into a market-ready bale of
   like material at a MRF.  
 * The material can be cost effectively processed at a paper mill into suitable
   feedstock for production of new products.  

The Tool assesses the packaging, unfilled and separated from the product, after
use by consumers. The determination of the Tool is based on the whole packaging
in its typical condition after use. Whole includes all packaging components such
as staples, labels, seals, lids and closures, handles, and any other integrated
components that would typically be found on the packaging. The packaging is then
collected from residential curbside recycling collection, subscription services,
and drop-off locations. 
 
The following types of fiber-based packaging are included in the Tool, but this
list is intended to be illustrative only, not exhaustive. Refer to the grade
definitions  in the ReMA Specifications:  Paper Stock – Specs22 (isrispecs.org)
 
Most commonly used fiber-based packaging:  

 * Corrugated
   boxes                                                                      

 * Paperboard folding cartons – URB, CRB  
 * Paperboard folding cartons – SBS  
 * Paperboard folding cartons – CUK  
 * Molded fiber packaging  
 * Kraft paper bags 

 * Cartons – aseptic and gable-top multilayer containers  
 * Fiber-based multi-layer containers with metal/poly  
 * Fiber-based flexible packaging with poly barrier (pouches)  
 * Paper cups and foodservice packaging; pizza boxes  
 * Paper mailing envelopes  

How Packaging is Evaluated

The following characteristics are scored in the packaging evaluation:  

 * Physical size of the packaging  
 * Distribution volume of the product (local, regional, national)  
 * Percentage of recycling programs that accept the packaging type  

 * Likelihood that packaging will be successfully sorted at the MRF  
 * The packaging is explicitly included in ISRI’s current paper grades  
 * The extent that non-paper elements added to the packaging would generate
   unacceptably high contamination and/or low yields when recycled by the
   end-market mill  

The scoring system is qualitative. Packaging is scored on each of the
characteristics listed above using points-based rating scales. Each point in the
scale reflects a continuum from less to more able to pass through the recycling
system. The final result indicates when packaging does not pose consistent
challenges in the residential recycling stream. The higher the score, the more
likely the packaging will pass through the recycling system. 
  
Different scales have been selected for different characteristics so that scales
reflect the relative importance of the various characteristics to the recycling
system in general. The scoring is done on a pass/fail basis. 

A final result of “Green” means the package meets the Tool criteria and will
pass through the average MRF in the U.S. A final result of “Yellow” means the
package did not meet the criteria but could pass through the average MRF with
some modifications, or that it would pass through the recycling infrastructure
in some local/regional systems, but not others. A result of “Red” means that the
package did not meet the criteria, and there are significant compatibility
issues with the package and the current recycling system in the US.  

FAQs

What is the Fiber Recycling Readiness Tool (Tool) and why is it important?
The Tool is a science-based online resource for brands, packaging companies, and
other industry users to assess the extent to which fiber-based packaging is
likely to pass through the current U.S. residential recycling system and whether
it poses known challenges for that system.

The Tool assists manufacturers in designing for recycling. If the packaging
flows easily through the current recycling system,  a “green” score is given and
the applicant receives a confirmation email. If not, then ways the packaging can
be altered to achieve a “green” designation are provided. The applicant can
redesign the packaging so that it receives a “green” designation.

The Tool focuses specifically on post-residential consumer fiber-based packaging
that will be marketed in the United States.

 

Who should use the Tool?
The primary audiences for the Tool are fiber-based packaging manufacturers and
brand owners of consumer products that use fiber packaging. Some common end-use
markets are food and beverage, personal care, and electronics.

 

What is the history behind the Tool and why now?
Brands have expressed their desire to convert current packaging materials into
fiber-based packaging. One important feature of the packaging is for it to flow
through the current recycling infrastructure. This impacts the complete
lifecycle of packaging—including design, collection, processing, and being used
into new products. Because of the magnitude of change to fiber-based packaging,
ReMA created the Tool to meet this industry need.

 

Do I need to be an ReMA member to use the tool?
No. The Tool is accessible to members and nonmembers alike for the betterment of
the fiber recycling industry.

 

Do I need an ReMA account to access the tool?
No, there is no login is required.

 

What should I have ready before I start the Tool?
To complete the Tool, you will need to have the specifications of your packaging
handy, so that you can accurately answer questions about the packaging’s
material composition, size, and shape. Progress on the Tool cannot be saved, so
you will need to have this information prepared in advance.

 

Is the Tool easy to use?
Yes. The Tool is a simple online resource that asks a series of questions that
will identify the packaging characteristics that are most impactful to its going
through the current recycling infrastructure and provides a straightforward end
result of Green (Meets Criteria), Red (Does Not Meet Criteria) or Yellow (Could
Meet Criteria With Modifications). If the result is Yellow or Red, the tool also
provides customized feedback on how the packaging can more readily go through
the current recycling infrastructure. The Tool’s design provides clarity to
brands and packaging companies on packaging and its attributes that flow through
the current U.S. recycling infrastructure. It was designed to be straightforward
and effective.

 

How does the Tool benefit ReMA members?
ReMA members can point stakeholders to the Tool when they have questions about
whether their package will be recycled. It allows the industry to assess
fiber-based packaging compatibility with the recycling system based the
packaging’s design, and on the overall MRF and mill infrastructure in the US,
instead of testing at just one or two facilities.

 

Who was involved in the creation of the Tool?
Like the ReMA Specifications, this Tool was designed using ReMA member expertise
across all aspects of the entire recycling infrastructure cycle, in addition to
relying on the MRF research conducted by Bill Moore & Associates. Non-ReMA
member advisors were consulted throughout the process. To achieve the important
goal of transparency, ReMA has met, and will continue to meet, with any
stakeholders that wish to know more about the Tool. Using nonmember advisors
also helped achieve this important goal.

 

How does the Tool relate to Design for Recycling®?
The design of the packaging is the first step of the Tool’s purpose which is to
help reduce confusion on the part of packaging and product manufacturers, and
consumers, regarding the types of fiber-based packaging that can or cannot be
recycled, given pressure points in the current recycling system. Using the
principles of ReMA’s Design for Recycling® will increase the likelihood for
fiber-based packaging to flow through the current recycling infrastructure.

 

Does the Tool assess recycled content or compostability?
The Tool does not assess recycled content, nor compostability. For packaging to
be recycled in the U.S., the following criteria need to be met:

 * The packaging meets the U.S. Federal Trade Commission (FTC) requirements for
   recyclable claims.
 * The packaging is likely to be successfully sorted into a market-ready bale of
   like material at a materials recovery facility (MRF).
 * The material can be cost effectively processed at a paper mill into suitable
   feedstock for production of new products.

The Tool assesses packaging, unfilled and separated from the product, after-use
by consumers. If the packaging is not likely to flow through the current U.S.
recycling infrastructure and be made into a new product, written feedback on how
the packaging could be improved is provided to the applicant. This feedback will
help in the future design of that packaging.

 

How often will the Tool be updated?
The ReMA working group continues to monitor the current U.S. recycling
infrastructure and will provide updates accordingly.

 

What if I want to assess the recycling readiness of packaging that is not
fiber-based?
The Recycling Partnership offers the Circular Packaging Assessment Tool which
provides guidance on other packaging materials. If the material is plastic, one
can also consult t The Association of Plastic Recyclers | APR Design® Guide
(plasticsrecycling.org). How2Recycle, Home Page – How2Recycle, is another
resource that assesses recycling readiness of other packaging materials.

 

What is the relationship between this Tool and The Recycling Partnership’s
Circular Packaging Assessment?
ReMA and The Recycling Partnership (TRP) are actively collaborating to ensure
that brands, packaging manufacturers, and other users are receiving clear and
consistent guidance on fiber packaging recycling through their two complementary
tools: the ReMA Fiber Recycling Readiness Tool and TRP’s Circular Packaging
Assessment Tool.

TRP’s assessment tool provides an overview of all material packaging, includes
digitized design guides from industry associations, and leverages the
Partnership’s recycling access database to provide localized information on
packaging acceptance in recycling programs. High level feedback is provided for
a material’s inclusion in the ISRI Specifications and the material’s performance
within eight criteria of end markets.

ReMA’s readiness tool provides more detailed review and feedback on fiber-based
packaging specifically. In particular, ReMA’s tool assesses end market
contaminants and their cumulative impact on the ability of the package to pass
through the current U.S. recycling infrastructure. It can also be used by
designers and engineers considering or testing innovative packaging formats
given the level of granularity provided on individual design elements.

 

What else?
The Tool is based on United States recycling infrastructure. The results will
not apply to how packaging would pass through the recycling system in other
global markets. The Tool is based on self-reported information and is only as
accurate as the information that a user inputs about the packaging’s
characteristics. Users should prepare themselves with all relevant and
up-to-date specifications on their packaging before getting started, to ensure
an accurate result.

Legal Terms of Use

Ownership. ReMA is the sole owner of the Tool, and any creative derivative works
thereof. By reviewing and submitting comments in response to this public notice,
all commentators agree not to modify or duplicate the Tool in any way. All
rights are reserved.   
  
Warranties. ReMA’s Recyclability Tool is a tool and should be used as a tool.
The Tool should not be relied on as the sole determinate of recyclability, and
it does not exempt users from any additional applicable federal or state
requirements. Because of ongoing technological advancements and the inherent
limitations of the current recycling system, this Tool cannot anticipate how
these advancements might impact fiber-based packaging. ReMA offers the
information stated in the Tool in good faith, but without warranty of any kind,
either expressed or implied, including WARRANTIES OF MERCHANTABILITY OR FITNESS
FOR A PARTICULAR PURPOSE, which ReMA expressly disclaims. ReMA intends to
regularly update the Tool to reflect new advancements and best practices in
fiber-based packaging.  
  


Miscellaneous. ReMA will consider all relevant matters presented during any
public comment periods and will respond in some form to all comments received.
ReMA reserves the right to modify comment periods and to choose which comments
are incorporated into the final version of this Tool, if any.

The identities of all commentators and their respective comments, and the
identities of all users of the Tool and their individual data will be kept
confidential by ReMA, to the extent permitted by law. ReMA may use data
generated by the tool that has been anonymized and aggregated.

The Fiber Recycling Readiness Tool, the information in the Tool, and any
feedback provided to the user of the Tool, does not constitute legal advice.

For general questions about the terms, please contact
hlyons@recycledmaterials.org

Appendix
 1. REFERENCES

ReMA “Learning from the MRF Survey”, February 2020 

ReMA Design for Recycling® 


AF&PA Mill Survey “Design Guidance for Recyclability – Paper-Based Packaging”,
2021

SPC (Sustainable Packaging Coalition) “2020-2021 Centralized Study on
Availability of Recycling”


Walmart – Recycling Playbook, October 2019


WRAP Design Tips for Recycling, Fall 2019


CEPI Paper-Based Packaging Recyclability Guidelines, November 2019

 

 1. FEDERAL TRADE COMMISSION GREEN GUIDES

The FTC’s guidelines for environmental marketing claims are as follows: 

260.6 Certifications and Seals of Approval 

(a)   It is deceptive to misrepresent, directly or by implication, that a
product, packaging, or service has been endorsed or certified by an independent
third party. 

(b)   A marketer’s use of the name, logo, or seal of approval of a third-party
certifier or organization may be an endorsement, which should meet the criteria
for endorsements provided in the FTC’s Endorsement Guides, 16 CFR part 255,
including Definitions (§ 255.0), General Considerations (§ 255.1), Expert
Endorsements (§ 255.3), Endorsements by Organizations (§ 255.4), and Disclosure
of Material Connections (§ 255.5). 

(c)  Third-party certification does not eliminate a marketer’s obligation to
ensure that it has substantiation for all claims reasonably communicated by the
certification. 

(d)   A marketer’s use of an environmental certification or seal of approval
likely conveys that the product offers a general environmental benefit (see §
260.4) if the certification or seal does not convey the basis for the
certification or seal, either through the name or some other means. Because it
is highly unlikely that marketers can substantiate general environmental benefit
claims, marketers should not use environmental certifications or seals that do
not convey the basis for the certification. 

(e)   Marketers can qualify general environmental benefit claims conveyed by
environmental certifications and seals of approval to prevent deception about
the nature of the environmental benefit being asserted. To avoid deception,
marketers should use clear and prominent qualifying language that clearly
conveys that the certification or seal refers only to specific and limited
benefits. 

Examples can be found at the following link: 

https://www.govregs.com/regulations/expand/title16_chapterI_part260_section260.6#regulation_5 

260.12 Recyclable Claims 

(a)    It is deceptive to misrepresent, directly or by implication, that a
product or package is recyclable. A product or package should not be marketed as
recyclable unless it can be collected, separated, or otherwise recovered from
the waste stream through an established recycling program for reuse or use in
manufacturing or assembling another item.  

(b)   Marketers should clearly and prominently qualify recyclable claims to the
extent necessary to avoid deception about the availability of recycling programs
and collection sites to consumers.  

(1)   When recycling facilities are available to a substantial majority of
consumers or communities where the item is sold, marketers can make unqualified
recyclable claims. The term “substantial majority,” as used in this context,
means at least 60 percent.  

(2)   When recycling facilities are available to less than a substantial
majority of consumers or communities where the item is sold, marketers should
qualify all recyclable claims.  

 * Marketers may always qualify recyclable claims by stating the percentage of
   consumers or communities that have access to facilities that recycle the
   item.  
 * Alternatively, marketers may use qualifications that vary in strength
   depending on facility availability. The lower the level of access to an
   appropriate facility is, the more strongly the marketer should emphasize the
   limited availability of recycling for the product. For example, if recycling
   facilities are available to slightly less than a substantial majority of
   consumers or communities where the item is sold, a marketer may qualify a
   recyclable claim by stating: “This product [package] may not be recyclable in
   your area,” or “Recycling facilities for this product [package] may not exist
   in your area.”  
 * If recycling facilities are available only to a few consumers, marketers
   should use stronger clarifications. For example, a marketer in this situation
   may qualify its recyclable claim by stating: “This product [package] is
   recyclable only in the few communities that have appropriate recycling
   facilities.”  

(c)   Marketers can make unqualified recyclable claims for a product or package
if the entire product or package, excluding minor incidental components, is
recyclable. For items that are partially made of recyclable components,
marketers should clearly and prominently qualify the recyclable claim to avoid
deception about which portions are recyclable.  

(d)   If any component significantly limits the ability to recycle the item, any
recyclable claim would be deceptive. An item that is made from recyclable
material, but, because of its shape, size, or some other attribute, is not
accepted in recycling programs, should not be marketed as recyclable. 

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