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ISRI submits comments to EPA regarding update of Comprehensive Procurement Guidelines

Comments emphasise economic and environmental benefits of recycling driven by government purchases of products with recycled content.


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Legislation
 
July 9 2020
 
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The Institute of Scrap Recycling Industries (ISRI) announced it has submitted comments to the U.S. Environmental Protection Agency (EPA) in support of consideration of an update to the EPA’s Comprehensive Procurement Guidelines (CPG).

In its comments, ISRI said it is encouraging enhancement of the CPG to reflect current market availability of additional goods made from recycled content and the amount of recycled content that can be incorporated into these products. ISRI also suggests the increased purchases of these products by government procurement officials for purposes of stimulating recycling and doing more to divert end of life materials from landfills through the use of an enhanced CPG.

Excerpts of ISRI’s comments follow (full text of comments)

… Through these comments, ISRI intends to

  • Suggest separate EPA rule-making that clearly defines recycling and related terms;
  • Support the enhancement of the CPG to reflect current market availability of additional goods made from recycled content and the amount of recycled content that can be incorporated into these products; and
  • Promote increased purchases of these products by government procurement officials for purposes of stimulating recycling and doing more to divert end of life materials from landfills through the use of an enhanced CPG.

We encourage EPA to consider initiating a rule-making process for purposes of updating the CPG, and that the comments included herein could be incorporated into that process.

… The CPG is a vitally important resource for promoting sustainability and the resilience of the U.S. manufacturing supply chain, of which recycling is an essential first step. The guidance set out in the CPG for procurement officials in federal, state and local governments provide a critical market for recycled materials; the purchasing of products made with recycled content spurs more recycling activity in the United States.

… Therefore, to understand “recycled content” and the economic and environmental benefits to be achieved from purchasing goods made with recycled content, we believe it is imperative that EPA pursue a separate rule-making that improves the definitions for ‘recycling’, ‘recyclable’ and ‘recycled material.’  For purposes of these comments – and to consider for rule-making – ISRI defines these terms in the following way:

Recycling is the series of activities during which obsolete, previously used, off-specification, surplus, or incidentally produced materials are processed into specification-grade commodities, and consumed as raw-material feedstock, in lieu of virgin materials, in the manufacture of new products. The series of activities that make up recycling may include collection, processing, and/or brokering, and shall result in subsequent consumption by a materials manufacturer.

A “Recyclable” material is an obsolete, previously used, off-specification, surplus, or incidentally produced material for processing into a specification-grade commodity for which a market exists.

Recycled Material is material that was initially obsolete, previously used, off-specification, surplus, or incidentally produced and that has been processed into a specification-grade commodity for use in materials manufacturing...

… We reiterate our hope that a rule-making on the definition of ‘recycling’, ‘recyclable’ and ‘recycled material’ will be considered as a support to the goals trying to be achieved through the EPA Comprehensive Procurement Guidelines. We also look forward to engaging in a rule-making process with EPA in which the comments provided herein – which includes proposed additional products that are available in the marketplace and made from recycled content as well as changes to recycled content levels in existing products – could be incorporated to enhance the CPG. Doing so will stimulate additional recycling in the United States, which will lead to greater environmental and economic benefits for the United States. It is vital to the overall success of the U.S. recycling industry that government procurement help to drive demand for recycled materials, which will, in turn, drive more opportunity for growth in recycling.