What did we learn from the feedback we received?
As a mission-driven organization focused on both system change and partnership, there isn’t much we enjoy more than a good bit of stakeholder feedback. So, when we launched the 30-day public comment period for the Pathway to Circularity’s Recyclability Framework, we were eager for a significant response that would help us refine the Framework and ensure it works for the industry as a whole.
Between August 19 and September 17, 2021, The Recycling Partnership hosted two webinars and received online submissions with more than 750 individual comments* from more than 70 organizations across the recycling value chain. A first of its kind opportunity to shape the future of recyclability, the process was designed with the intention of attracting input from all corners of the industry. With solid representation from brands, retailers, industry associations, MRFs, government representatives and NGOs among others, we were very encouraged by the engagement throughout this period, which supplemented the work done to date in partnership with the Circularity Council.
After reviewing all comments, we grouped the feedback into “themes” that asked similar questions, raised comparable challenges, and/or offered equivalent suggestions. In total, 65 themes were identified, covering both general and specific comments around the Framework’s 5 building blocks (which in turn have 8 total criteria).
What does this mean for the Pathway to Circularity Recyclability Framework?
Now that we’ve evaluated all responses from the public comment period, it begs the questions of “What did we learn?” and “What comes next?”. Here are our top takeaways:
1. We recognize the impact and importance of the Framework
The public comment period served two key purposes: it was both a bellwether of sentiment on the content and it demonstrated the importance of the Framework itself. Put another way, by the many people that cared enough to provide feedback we know that the Framework is impactful! Our first key takeaway is, therefore, that the high volume of comments is evidence of the critical need for this framework, and the industry desire for these guidelines … and soon!
2. We’ll be making some changes
We are beyond grateful for the collective expertise of all the stakeholders who took time to review the draft Framework. There were some areas where we received straightforward suggestions from several stakeholders that improved the efficacy of the Framework.
As an example, we received several comments pointing to the importance of preventing toxins from entering the recycling stream by building material health considerations into the “Design” building block. We fully support the importance of material health in this context, and we intend to incorporate this in the Framework in partnership with industry partners.
Equally, some feedback pointed to small but significant choices of language that can send important signals to the industry. “Design for Recyclability” is more accurate than “Design for Circularity” in the context of this Framework – done. And “Optional” is not enough for some of the key criteria – great point. Let’s reinforce the importance by making these “Recommended” instead. Thank you for pushing us in a better direction.
3. We’ll put our thinking caps back on
Some aspects of the feedback do not have straightforward solutions. While the challenges may be clear, the solutions are not always immediately apparent. But that doesn’t mean there isn’t a better way forward, we just have a bit more work ahead to identify some solutions. So that’s the plan.
For example, we received a significant volume of feedback challenging us to better address the facilitation of innovation in the recycling system. The Framework is designed to root us all in the reality of what can be recycled today, while pushing us towards a true innovative future that takes the system into account. However, we acknowledge that there must also be incentives to pursue positive change, so we are committed to exploring an on-ramp for packages considered to be in transition towards recyclability.
While this is just one example, there are a few areas where we don’t have all the answers yet; we’re committed to revisiting them with support from the Circularity Council, and transparently sharing the solution development process through broader stakeholder engagement.
4. There are opportunities for greater clarity in places
When it comes to communicating new and complex concepts, there can be room for misinterpretation. While it’s always been our goal to make the Framework as straightforward and user-friendly as possible, we learned from feedback received that there are still opportunities for greater clarity.
For example, some comments alluded to the need for openness to different and/or new collection mechanisms for packaging, new and emerging processing technologies etc. While we agree that these may play an important role, the current Framework is deliberately designed to focus on municipal sources of recycling access (including curbside and residential drop-off services for both single and multifamily residences, but excluding in-store drop-off programs, deposit return systems and other collection mechanisms) that are currently available at scale. We will seek to clarify this by renaming the Framework “The Residential Recyclability Framework” (where residential refers to the scope noted above).
The intent of creating clear assessment boundaries is not to rule out the importance of alternative collection methods, nor the possibility that other frameworks (or variations of this one) could be used to accommodate alternative channels or new technologies as they scale, but simply to clarify intended scope.
5. We’re moving forward
While the draft Framework represents a big and important step forward, there is a lot more still to come! We will be delivering further updates to the Framework, including greater specificity around the assessment of key criteria, in early 2022. Several other workstreams will also launch in 2022 to begin addressing known gaps that are keeping various packaging types from achieving recyclability. For example, The Partnership is exploring additional material-specific coalitions such as a PET Recycling Coalition to improve access for PET thermoforms and PET bottle capture while increasing overall system efficiency.
Meanwhile, don’t forget that the Framework will ultimately be a dynamic and evolving tool with room to adapt for innovation in packaging design and other developments, based on its clear building blocks and transparent criteria.
6. We will keep you posted
The goal of the public comment period was to get the broadest possible stakeholder input and improve the Framework in partnership with the whole industry: we want to build it together. We remain committed to that transparent mechanism for driving change and welcome every opportunity to broaden industry input.
If you’re interested in learning more or participating in further discussions around the development of the Framework, please:
Last but not least, full responses are available
You can download and read our thematic responses here.
*We counted every remark / comment / individual feedback as a “comment” i.e. each comment raised within one submission was evaluated as a separate comment, including multiple comments on criteria/building blocks.