Sustainability and Packaging Presentation, Blog

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Sustainability and Packaging
Chandler Slavin,
Sustainability
Coordinator,
Dordan Mfg.
What is Sustainable
Packaging?
In a perfect world…
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According to the SPC, Sustainable Packaging:
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Is beneficial, safe & healthy for individuals and communities
throughout its life cycle;
Meets market criteria for both performance and cost;
Is sourced, manufactured, transported, and recycled using renewable
energy;
Is manufactured using clean production technologies and best
practices;
Is made from materials healthy in all probable end of life scenarios;
Is physically designed to optimize materials and energy;
Is effectively recovered and utilized in biological and/or industrial
closed loop cycles.
In reality…
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In my opinion, today there is no such thing as a truly
sustainable package; all commodities consume
energy and emit GHG equivalents during production.
While paper comes from trees and plastic fossil fuel,
both utilize natural resources as their feedstock; both
consume energy during their procurement and
conversion; and, both emit chemicals into the
atmosphere throughout their lifecycle.
So what’s all this jazz about
“Sustainability?”
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According to the WWF’s Living Planet
Report, which is a biannual analysis of the
carrying capacity of the globe compared with
resource consumption, our current
approaches to production and consumption
are not sustainable:
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Population x Consumption > Planet
Yikes!
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We estimate that current demand for the Earth’s
resources is 1.25 times what scientists believe
our planet can sustain. And by the way, that’s
with 6 billion people, not the 9 billion world
population predicted by mid-century.
Put another way, according to the findings in our
Living Planet Index, on September 25 of this
year our resource use surpassed what is
sustainable. What this would mean as a financial
issue is that we are living off our principle; as a
farmer it means we are eating our seed.
We need to use less and produce more
from less…
What does this mean for packaging?
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Because of the contemporary anxiety over
our depleting resources, single-use,
disposable packaging has been targeted as
a manifestation of our over-consumptive
society.
Think bag bans, bottle bills, PS bans and the
like…
The “Green” Consumer
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Market research shows that consumers will buy a
product/package with a “green” presence over a
product/package that is perceived to have a negative
impact on the social and ecological environments.
While most surveys indicate consumers are willing to
pay more for “green” products, this is often not the
case.
Therefore, it has been concluded that if at a
comparable cost and performance, consumers will
buy the “green” product/package over the
product/package not identifying with “green” values.
What’s important for you
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Because of these cultural shifts and the changing
landscape of the packaging industry, it is important
for you as packaging professionals to understand the
various dimensions of “sustainability” as it pertains to
packaging.
By understanding these issues, you will be able to
make more informed packaging choices, which will
resonate with your customer and end consumer.
Presentation Overview, Part I
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How to measure “Sustainability:”
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LCA and LCI
Sustainability Metrics
COMPASS
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Go Phone package redesign
Walmart Scorecard
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Direct and Indirect suppliers
Scorecard metrics
Scorecard completion
SVN Scorecard discussion
How to measure sustainability,
continued
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Walmart Supplier Assessment
P&G Scorecard
Global Packaging Project
Consumer Goods Forum
Sustainability Index
Presentation Overview, Part II
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Traditional packaging materials sustainability
profiles:
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Energy consumption
GHG emissions
Water and biotic consumption
Global warming
Deforestation
Presentation Overview, Part III
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Waste management of traditional packaging
materials
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MSW, US EPA 2007
Generation and recovery rates, US EPA 2008
Recycling initiative
Presentation Overview, Part IV
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Environmental labeling guidelines for
packaging:
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FTC, EPI
Greenwashing, Walmart Expo,
greenerpackage.com
Dos and don’ts of green claims
Recyclability claims
Bio/oxo/photo degradability claims
Comparative claims
Presentation Overview, Part V
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Extended producer responsibility/product
stewardship
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EPR and packaging
Who does it affect?
What you should do about it
How to avoid high EPR fees
What you should require from your suppliers
The advantage of the domestic supplier
Presentation Overview, Part VI
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Bio-based polymers sustainability
considerations
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Sustainable sourcing
Complete biodegradation
End-of-life management
Energy requirements/GHG emissions of
production vs. traditional resins
Ready?
Part I: How to measure “Sustainability”
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LCA stands for life cycle analysis, which is a
popular approach to understanding the
environmental profiles of products and
services.
LCA considers the entire life cycle of a
product or service, from its procurement to
conversion, manufacture, distribution, and
end of life.
LCA and LCI
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If one wanted to perform a LCA of a product
or service, one would need at least three
different LCI data sets, which stands for life
cycle inventory data. These data sets would
be averaged to determine the metrics used
for the product or service LCA.
LCI data is primary data that is collected for a
specific product or service.
LCI, example
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If Dordan wanted to measure the environmental
requirements of its manufacturing facility in order to
contribute to the metrics used in LCAs for material
converters, Dordan would have to collect data about
its operating processes, such as the energy
requirements of manufacturing and distributing its
products.
This data would be consider LCI data, and would be
used in the development of metrics for performing
LCA of thermoforming operations.
Sustainable Metrics
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The LCI data collected for the performance of LCAs
of a product or service are based on sustainability
metrics.
Metrics are the various environmental indicators
considered in LCAs that help measure sustainability.
These include, but are not limited to, greenhouse
gas emissions, fossil fuel consumption, water
consumption, biotic consumption, aquatic toxicity,
eutrophication, etc.
COMPASS, overview
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COMPASS is a life-cycle based, environmental modeling
software that allows you to compare the environmental
performances of different packages, based on material
selection and packaging weight.
COMPASS contains life cycle inventory data from raw material
sourcing, primary packaging material manufacture, conversion,
and end-of-life.
Transportation and purchased electricity within these phases is
also included.
In addition, COMPASS includes end-of-life probabilities for
waste scenarios such as recycling, waste-to-energy
incineration, landfill, composting, and litter.
COMPASS and LCAs
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This tool uses LCI data in order to create the
metrics used to perform LCAs.
If no LCI data has been collected about a
certain material or service i.e. RPET, then
one can not perform an LCA of said material
or service.
COMPASS example, introduction
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Dordan uses COMPASS to run
environmental comparisons between
different packaging materials and designs.
One instance in which Dordan used
COMPASS to illustrate the environmental
improvements of a package redesign is the
Go Phone package comparison.
Old Go Phone package
Redesign approach
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Redesign package to achieve a smaller
product-to-package ratio;
Reduce the gauge of the clamshell from
0.030" to 0.025" and the inner tray from
0.045" to 0.035;"
Change the clamshell from convex to flat,
thereby eliminating the snap-on lid.
New Go Phone package
Go Phone package redesign savings
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29% cost savings compared to previous package;
For the same amount of product sold, reduced the
total packaging weight by 25%;
Reduced C02 emissions by 25%;
Reduced total usage of packaging, saving
transportation costs and energy use;
The slimmer design allows for more products per
pallet and an increased number of units per foot of
retail space.
See the difference?
The proof is in the pudding…
COMPASS packaging comparison results:
 http://www.dordan.com/Go_Phone_COMPAS
S.xps
COMPASS Summary
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In short, COMPASS can be utilized in the following
ways:
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Allows packaging engineers to compare the environmental
impacts of their package designs using a life cycle
approach.
Helps engineers make more informed material selections
and design decisions early in the development process.
Allows Marketing teams to articulate packaging
improvements, which should resonate with customers and
the end consumer.
Allows Sales teams to “reverse-engineer” competitors
packages in order to show how package can be improved to
yield a better environmental profile.
Questions about COMPASS as a tool
for measuring sustainability?
Retailers and measuring sustainability,
overview
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Many retailers are investigating the different tools
available for measuring sustainability, for both
products and packages.
Examples include:
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Walmart Scorecard and Supplier Sustainability Assessment
Global Packaging Project
Consumer Goods Forum
P&G Scorecard
Sustainability Index
Walmart Scorecard, introduction
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Like COMPASS, the Walmart Scorecard uses
available LCI data sets to perform LCAs of different
packages, based on material and packaging
weight.
ECRM created the software for the Walmart
Scorecard, which stands for “Efficient collaborative
retail marketing.”
Based on the environmental profile of one’s
package, suppliers receive Scores, which conveys
a packages assumed “sustainability.”
Scores for packaging only; based on ITEM level.
Scorecard and suppliers
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Direct suppliers to Walmart are required to
enter their packaging information into the
Scorecard software via “retail link,” which is
per vendor number and item number.
Indirect suppliers are encouraged to
subscribe to the Walmart Packaging
Modeling Software, which uses the metrics of
the Scorecard to perform LCAs of different
packages.
Scorecard metrics
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Metrics considered:
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Material type
material weight
material distance
packaging efficiency.
Material distance considers the point the
package travels from point of conversion to
point of fulfillment.
Scorecard completion
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The Walmart Scorecard is a constantly evolving
tool.
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.
Scores are based on comparisons with others in
your product category i.e. dairy.
As more companies submit their Scores, your
Score is likely to change, depending on your
competitor's performance.
SVN meeting, Scorecard discussion
“Sustainable Material metric?”
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What does a “sustainable material” mean?
Until clarified, should everyone get the same Score?
Should we remove the metric?
Is Recovery taken into consideration?
Is it a LCA based approach?
Does it consider conversion or primary production?
What about toxics?
Sourcing certificates?
SVN meeting, Scorecard discussion,
continued
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SVN determined that it would be helpful to
have a health and safety metric AND a
sustainable sourcing metric, which together
would be blanketed under the metric
“sustainable material.”
SVN Questions
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Add an ink/laminate metric?
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Only if proof is provided that argues that such a metric is
necessary.
International manufacturing vs. domestic metric?
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Had considered a point of origin because overseas
manufacturing has different environmental profiles than
domestic manufacturing i.e. labor laws, environmental
regulations, etc.; however, unable to quantify at this time.
It maybe considered in the future.
Walmart Scorecard questions?
Walmart, Supplier Sustainability
Assessment
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Consists of 15 questions, which are asked
of all product suppliers to Walmart.
“Scores” based on CORPORATE level.
Global Packaging Project
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Walmart funds this but is not the only CPG
company on the board;
GPP looks for a GLOBAL metric for
assessing the sustainability of packages and
products;
This is bigger than the Scorecard, as the
Scorecard will be one component utilized in
the metrics.
GPP, continued
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The GPP metrics look to take into account
the Scorecard metrics, COMPASS, the
SPC’s Sustainable Packaging Metrics, and
other existing and legitimate metrics.
If one wants the inclusion of another metric
i.e. sustainable sourcing, it must be reviewed
for application prior to being incorporated into
the GPP metrics.
Consumer Good Forum
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The GPP grew out of the CGF, which was
originally called the Global CEO Forum.
The relationship between the CGF and GPP
has yet to be determined.
P&G Scorecard
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Release in May 2010;
This tool is designed to help suppliers meet
sustainability targets, for both packaging and
products.
It utilizes existing data sets to determine the
“sustainability” of a product, package, or
service.
Sustainability Index
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The assessment is part of the Sustainability
Index, which is a project of the
Sustainability Consortium.
Walmart funds this organization but is not
the only CPGs company that participates.
Ambiguous organization and role;
Assumed to provide metrics to GPP.
Retailers, organizations, tools and
sustainability
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It has yet to be determined what the
governance will be over the different tools to
measure sustainability i.e. Walmart
Scorecard vs. P&G Scorecard vs.
COMPASS, etc.
It has yet to be determined what the
governance will be over the different
organizations i.e. GPP vs. CGF vs.
Sustainability Index.
Questions on how to measure
sustainability?
Part II: Packaging Materials
Sustainability Profiles, introduction
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Different packaging materials have different
environmental requirements, based on their
feedstock and procurement.
It is important to acknowledge that no
packaging material is “the” sustainable
packaging material; each has its advantages
and disadvantages in the context of
environmental considerations.
Packaging materials and energy
consumption
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Each packaging material type consumes
energy during its procurement and
conversion.
Packaging materials of focus: paper and
plastic.
Graph analysis
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This graph represents the energy (million
Btus) consumed per 1,000 lbs of plastic
produced.
The average energy consumed for the
production of 1,000 lbs of plastic is: 9.94
million Btus.
Graph analysis
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This graph represents the energy (million
Btus) consumed per 1,000 lbs of material
produced.
The total energy consumed in the production
of 1,000 lbs of fiber-based packaging is 8.96
million Btus.
Energy requirements comparison,
paper and plastic
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These graphs illustrates that while plastic is
made from fossil fuel and paper is made from
trees, the energy required to produce the two
packaging materials is comparable.
This is because the energy-intensive threestep process pulp undergoes in its
conversion to paper.
Embedded energy of plastics
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If plastic and paper have similar energy consumption
requirements for production, why is plastic targeted
as a waste of our fossil fuel and paper seen as the
environmentally friendly alternative?
Because most of the energy consumed in resin
production (around 88%) is embedded in the
material itself, available for recovery post-consumer
via waste-to-energy (hereafter, WTE).
Graph analysis
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This graph illustrates the energy (million
Btus) embedded per 1,000 lbs of plastic
material, which is available for recovery via
waste-to-energy.
Plastics and incineration, misc.
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According to the journal of Resources, Conservation and
Recycling, “Polyolefins commonly used in [plastic] packaging
can generate twice as much energy as coal and almost as
much energy as fuel oil. When plastics are processed in
modern WTE facilities, they can help other waste combust
more completely, leaving less ash for disposal.”
Moreover, because there are 114 WTE facilities operating in the
U.S. today, generating enough energy to meet the power needs
of 1.2 million homes plastic packaging should not be viewed as
a wasteful consumption of fossil fuel but as a viable form of
energy available for latter recovery.
Plastic and energy, misc.
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in a recent Franklin Associates Ltd. study that
analyzed the carrying capacity ratios of different
packaging materials, it was determined that plastic
has a value of 34 and paper 6.9. This means that 34
ounces of juice could be carried in 1 ounce of plastic
and 6.9 ounces could be carried in 1 ounce of paper.
The study also found that by using plastic packaging,
product manufactures save enough energy each
year to power a city of 1 million homes for roughly
3.5 years.
Plastics and energy, summary
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The energy required to produce plastic is comparable with that
of paper production.
Most of the energy consumed in its production of plastic is
embedded in the resin itself, available for later recovery.
The density of plastic allows for lighter and therefore less
shipments, thereby saving energy in production, conversion
and transportation.
The carrying capacity of plastic allows for less material
consumed for the same packaging application, therefore
reducing the volume of packaging waste and the overall energy
consumption.
Questions on packaging materials and
energy?
Packaging materials and GHG
emissions, introduction and data
limitations
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As with energy consumption of production,
different packaging materials release
different amounts of GHG equivalents.
Due to proprietary data sets, I am unable to
perform an “apples-to-apples” comparison
between paper and plastic in regard to GHG
generated per 1,000 lbs of material
produced.
Graph analysis
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This graph represents how many thousand
GHG equivalents are generated per 1,000
lbs of material produced.
Fiber-based packaging production,
overview
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The production of fiber-based packaging
materials is broken down into three
processes:
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The pulping process, achieved through chemical
or kraft pulping;
the bleaching process;
and, the paper making process.
Processes emissions
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Overall, the pulping processes are the
sector’s primary source of air emissions and
water discharges of pollutants.
The bleaching process, however, generates
chlorinated byproducts—chloroform, dioxins,
furans—that pose particular environmental
concern for their persistence,
bioaccumulatability, and toxicity.
Paper Laminates and VOCs
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It is also important to note that coated and
laminated paper products, like those found in
many packaging applications, are associated
with significant reporting of releases and
other waste management TRI chemicals;
including emissions of volatile organic
compounds (hereafter, VOCs) and
discharges of wastewater containing
solvents, colorants and other contaminants.
Blue: Air emissions
Red: Water discharges
Graph analysis
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This graph represents the total air and water
emissions generated during pulp and paper
production in the United States in 1996.
This report is the most recent Toxics Release
Inventory Report released by the US EPA.
Graph analysis
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This graph illustrates the total production
related waste generated in pulp and paper
production in 1996 in the US.
Fiber-based packaging production
related-waste
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Taken together, the U.S. pulp and paper
industry (SIC Code 26) generated
1,599,797,509 lbs of production-related
waste in 1996 i.e. air emissions, water
discharges, etc.
GHG emissions and Global Warming
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According to the 2009 report released by the U.S.
Global Change Research Program, the largest factor
contributing to global warming is increased
greenhouse gas emissions such as carbon dioxide,
methane, nitrous oxide, water vapor, halocarbons,
soot, etc.; deforestation, agricultural practices and
irrigation also have greatly contributed.
Climate change will most dramatically stress water
resources, and crop and livestock production will be
increasingly challenged.
Fiber-based packaging production and
water consumption
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As the USGCRP report indicates, water scarcity will become an
increasingly challenging problem with the elevation of the
global climate. According to the EPA’s “Toxics Release
Inventory Data for the Pulp and Paper Industries,” the pulp and
paper sector is the country’s largest industrial process water
user.
Therefore, because the production of paper from wood requires
large amounts of water and steam, marketing paper as more
environmentally “friendly” than plastic is without ecological merit
when considered in the context of global warming because of
the value of water for economic and human sustainment and
the extensive water requirements for pulp and paper
production.
Fiber-based packaging, deforestation
and global warming
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As the USGCRP report explains,
deforestation is a leading contributor to the
increased emission of greenhouse gases; as
such, the emphasis on paper as the
sustainable packaging material needs to take
into account the greenhouse gases emitted
during deforestation and the extensive
consumption of our natural resources.
Fiber-based packaging production and
deforestation
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The US Forest Service estimates that the sustainable
production of timber on all the land under its jurisdiction is
about 550 pounds per acre per annum.
Packaging grade paper requires about 1.1 to 1.2 pounds of
wood per pound of paper or about 500 pounds of paper per
acre.
To produce the required 82 billion pounds of paper needed
to replace all plastic packaging would therefore need an
additional 162 million acres of forestland developed to
paper production.
To put this in perspective, this is the area of six US states
the size of Tennessee.
Paper production, emissions and
consumption summary
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Paper packaging production requires deforestation, which contributes
to greenhouse gas emissions and consumes high concentrations of
biotic and mineral resources.
The pulp and paper sector consumes more water than any other
industry. This is a problem as water becomes increasingly scarce with
the elevating global temperature.
Paper production releases large amounts of greenhouse gases into the
atmosphere.
Paper production releases high concentrations of VOCs into our water
and land, contributing to aquatic toxicity and eutrophication.
Replacing all packaging applications with fiber-based packaging
materials would require the appropriation of more land for deforestation
than we currently have access too, therefore increasing the burden of
packaging on the environment as articulated above.
Questions on packaging materials and
GHG emissions, global warming, and
deforestation?
Part III: Waste management of
packaging materials, introduction
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There are different avenues a packaging
material may take post-consumer. Some
materials get landfilled, others are recycled,
and others still are incinerated with waste-toenergy.
Municipal Solid Waste, material type
Container and Packaging MSW Data, 2007 (U.S. EPA 2008)
Aluminum
2%
St eel
3%
Wood
11%
Paper & Paperboard
Plast ic
Glass
15%
Paper & Paperboard
52%
Glass
Wood
St eel
Aluminum
Plast ic
17%
Graph analysis
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This graph illustrates the amount of
packaging material that ended up in a landfill
in the U.S. in 2007.
Paper is the largest contributor to the landfill,
comprising 52% of our MSW.
MSW: Generation and recovery
Blue: Generation
Red: Recovery
Graph analysis
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This graph illustrates the amount (millions of
tons) of packaging material generated in the
US in 2008 AND the amount recovered postconsumer.
While paper has the highest generation of
the packaging material types, it also has the
highest recovery.
However, this recovery is attributed mostly to
newspapers and corrugated boxes.
“Paper” packaging recovery rates,
expanded
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http://www.epa.gov/epawaste/nonhaz/munici
pal/pubs/msw2008data.pdf
Paperboard packaging/other paper
packaging recovery= Neg.?
Recyclable vs. recycled?
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Anything is theoretically recyclable if the
collecting, sorting, and processing
technology exist and if there is an end
market for this material.
However, few material/packaging types are
actually recycled in America due to the
economics governing recycling.
Example of recyclable vs. recycled:
Dordan’s clamshell recycling initiative
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Currently, thermoform packaging is not recycled in
American, although theoretically it can be recycled.
A material/package is considered “recycled” if >60%
of American communities have access to recycling
facilities that process said material/package.
We have been trying to find a way to recycle our
clamshell packages for several months now. I have a
blog, which narrates our day-to-day attempts to
integrate thermoforms into the existing recycling
infrastructure.
Recycling initiative
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www.recyclablepackaging.org
I am the co-lead of the PET subcommittee of
Walmart-Canada’s Material Optimization
Committee. Hopefully I can help them reach
their goal of zero waste for PET packaging
post-consumer, both bottle-grade and
thermo-grade. If Canada can do it, so can
we!
Approach to recycling initiative, # 1
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Integrate our RPET thermoforms into the existing
PET bottle recycling infrastructure:
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Sent 50 of our RPET clamshells to the MRF to run
through their optical sorting technology to see if our
clams are “read” like PET bottles. If so, then the issue of
integrating RPET clams into the bottle recycling
infrastructure has nothing to do with sorting technology.
Test found that their was no optical difference between
our RPET clams and PET bottles.
Recycling initiative, # 1, continued
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What this means is that If our RPET clams were
accepted for recycling with PET bottles, when they
would move down the line they would be sorted with
PET bottles and baled together for purchase.
However, according to WM, even if our RPET clams
made it into the PET bottle bales, when the bale is
bought by a reprocessor, they throw away RPET clams.
Therefore, it is not WM who determines what materials
are recycled but those who buy said material post
consumer for reprocessing.
What’s the deal?
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Buyers of balled PET bottles do not want
RPET clams in the mix, even if the same
material, for the following reasons:
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“Look-a-like” syndrome, fear of PVC
contamination;
different IV’s;
different melting points;
“fly” and “bale” differently due to different shapes
and sizes.
Problem with initiative
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Like anything, recycling is a business, which
requires:
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Supply
Demand
Technology
Investment
While RPET thermoforms can be recycled, they are
not because limited supply, limited demand, lack of
technology, and no investment.
Recycling initiative, # 1, pilot
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Dordan is investigating a pilot program whereby they
would designate a bale at a local WM that would
accept both PET bottles and RPET clamshells.
This mixed bale would be purchased by our material
supplier of RPET, who would grind and extrude the
mixed bale into thermoformable sheets.
We would buy this material and test it on our
machines to see its performance.
Approach to recycling initiative, # 2
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Create a new stream of low-grade, mixed
rigid plastic packaging, which would either be
incinerated for energy or recycled into timber
applications for parks and decks.
This market exists on the East and West
coasts where international markets purchase
our plastic scrap post-consumer for
incineration or reprocessing.
Questions on the waste management
of packaging materials?
Part III: Green Claims, overview
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The FTC is starting to persecute those
making unsubstantiated environmental
claims on packaging.
Example of “greenwashing”
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According to an FTC statement issued last month, the
commission issued letters to 78 U.S. retailers and
manufacturers warning that they may be breaking the law
by selling textile products that are labeled and advertised
as “bamboo,” but that actually contained manufactured
rayon.
The statement also said the companies have been warned
against making eco-friendly claims about bamboo fibers—
which are produced using harsh chemicals that release air
pollutants, the statement said.
Bamboo greenwashing claims,
continued


Failure to properly label and advertise these
products violates the FTC Act and the
commission’s Textile Rule, the FTC said.
Making unsubstantiated green claims has
real costs.
Example of real cost, California Law


Any company that advertises its product
using broad claims of environmental
friendliness such as “ecologically sound,”
“environmentally safe,” “green,” or any
similar term must provide written
documentation supporting such claim to any
member of the public upon request.
Failure to do so results in a misdemeanor
punishable by jail and/or a fine up to $2,500.
Retailers and greenwashing

Retailers such as Walmart are taking an
aggressive role at tackling products and
packages that make unsubstantiated green
claims.
5th Annual Walmart Stores, Inc.
Sustainable Packaging Exposition
example




EPI audited the environmental claims at the
Walmart Expo for all packaging vendors.
EPI audited both the Packaging Success
Story and the 7Rs handout.
70% were rejected in the first review.
All were eventually approved; however, most
had to dramatically change their marketing
language.
Walmart Expo, green claims

According to the EPI, the biggest issues
were:
–
–
–
–
Claims of recyclability;
no proof;
biodegradable/degradable claims;
ambiguous comparative claims.
Anti-greenwashing efforts



The greenerpackage.com database for
packaging suppliers requires documentation
supporting any environmental claim.
The database is linked to Walmart’s
Sustainable Packaging Scorecard Modeling
tool.
http://www.greenerpackage.com/database.
EPI’s Six Sins of Greenwashing






Sin of hidden tradeoff
Sin of no proof
Sin of vagueness
Sin of irrelevance
Sin of fibbing
Sin of the lesser of two evils
EPI research

Study of 1,018 consumer products that make
environmental claims found that “all but one
made claims that are demonstrably false or
that risk misleading intended audiences.”
EPI’s Six Virtues of Green Labeling






Tell the truth;
use specific claims—do not make broad
environmental claims i.e. “green” or “sustainable;”
don’t overstate a product’s attributes;
use clear and prominent qualifications;
have reliable data to back up your claims;
make sure a consumer can clearly understand the
meaning behind the claim.
Recyclable claims

A basis for the claim i.e. study or survey results of municipal
recycling facilities, must be stated when making ‘recyclable’
claims on packaging that is not traditionally accepted for
recycling.
–
–
–
–
You must consider both the material and packaging type i.e. PET
bottle versus PET clamshell;
You must review what is collected by communities and what is
accepted at recycling facilities;
Must be available to a substantial majority of consumers or
communities (60%)
Closed recycling systems are OK if well qualified i.e. in-store plastic
bag collection programs.
Availability of facilities for recycling

Recyclable in the US:
–
–
–
–
–
–
–
–
–
Glass bottles and jars (clear, green and brown)
PET bottles with necks (clear, light green and very light
blue)
HDPE bottles with necks (all colors, accept black)
Aluminum cans
Steel cans
Newspaper
Corrugate (non-waxed)
Paperboard without “bling” (although EPA data ambiguous)
Paper without “bling”
Availability of facilities for recycling

Not presently recyclable:
–
–
–
–
–
–
–
–
–
–
Glass (other than clear, light green and very light blue)
PET bottles (other than clear, light green, and very light
blue)
All other PET i.e. clamshells, blisters, trays, etc.
HDPE (black and non-bottle HDPE)
All plastic film and bags
Paperboard with “bling”
Paper with “bling”
Waxed corrugate
Packaging with food contamination
Laminates
Other claims…





Recycled content claims: specify post-consumer and
post-industrial; include % values;
Degradable/biodegradable/photo/oxo: Qualify claim
with intended disposal environment; include rate and
extent of degradation.
Comparative claims: Claims should be sufficiently
qualified and clear as to what is being compared.
Use of green dot: Use of green dot is only allowed
with valid trademark license.
Claims based on Walmart Scorecard: Specify what
change altered score and how.
Questions on making green claims?
Extended producer responsibility,
introduction


EPR stands for extended producer responsibility, which is
a strategy to place a shared responsibility for end-of-life
product management on the producers, and all entities
involved in the supply chain, instead of the general
public; while encouraging product design changes that
minimize a negative impact on human health and the
environment at every stage of the product’s life cycle.
First implemented with the management of electronic
waste and vehicles, EPR now extends to packaging:
Today, over 30 countries mandate EPR legislation for
packaging.
EPR geographical scope

While EPR legislation has historically been confined
to member states of the EU due to the
implementation of the 1994 EU Directive on
Packaging and Packaging Waste, it is now
expanding into the American and Canadian markets.
Accordingly, it is in all producers’ interests to familiar
themselves with EPR requirements in order to avoid
the costs associated with failing to comply with said
requirements.
EPR legislation, overview

EPR legislation is composed of three basic
elements:
–
–
–
waste management financing;
product design;
and, informational requirements.
EPR and waste management financing
–
Waste management financing refers to the
funding of the recovery of electronic and
packaging waste; producers can therefore choose
to comply individually or collectively. If chosen to
comply individually, producers must set up their
own system for the recovery of electronic and
packaging waste; if chosen to comply collectively,
producers must join an organization that assumes
responsibility for recovering their packaging and
electronic waste, as in the case with the Fost Plus
system in Belgium.
EPR and product design



Product design requirements refer to material restrictions and
design for recycling/reuse. These design requirements often
extend to electronics, batteries and packaging .
An example of a material restriction mandate is the EU RoHS
Directive, which requires that the materials used in
packaging/consumer goods/electronics do not contain any
heavy metals.
An example of a design for recycling/reuse mandate is the EU
WEEE Directive, which requires member states to meet targets
for recycling and/or reuse, thereby granting authority to the
state to mandate certain design for end of life requirements
from producers.
EPR and labeling requirements


EPR legislation often includes a requirement to label
the product, user manual, and/or packaging to inform
the consumer that s/he should not place the product
in the trash but rather drop off the product at a
designated collection location for separate disposal.
This extends to packaging, as illustrated through the
development of various labeling schemes for
packaging to inform the consumer what to do after
use.
EPR and packaging

According to Victor Bell, the President of
Environmental Packaging International, “The
centerpiece of the environmental movement
in Europe is a set of new packaging
standards being developed; they are called
the “Essential Requirements” and all
packages must meet them before they can
be sold in Europe.”
Essential requirements, # 1

Requirements for packaging recoverable through
recycling:
–
–
This standard will require that the person responsible for
placing the packaging on the market ensure that the design
of the packaging includes consideration for the recycling of
the materials from which it is produced and that the
selection of raw materials used ensure that recycling
processes are not negatively affected i.e. PVC labels on
PET containers.
Additionally, this standard will require that the design of the
packaging is compatible with the available recycling
technology and that the environmental impact cause by
recycling is taken into account.
Essential requirements, # 2

Requirements for packaging recoverable through
composting and biodegradation B Test scheme and
evaluation criteria for final acceptance of packaging:
–
–
This Standard requires that constituents known to be
harmful to the environment during biological treatment not
deliberately introduced into packaging or packaging
materials.
The Standard establishes tests and guidelines for
packaging and packaging materials to be designated as
organically recoverable.
Essential requirements, # 3

Requirements for packaging recoverable in
the form of energy, including specification of
minimum calorific value:
–
This Standard defines and specifies the
requirements for packaging to allow the overall
optimization of energy recovery.
Essential requirements, # 4

Reduction of waste (prevention by source
reduction):
–
This Standard require that the person responsible
for placing the packaging on the market
demonstrate that the minimum adequate amount
of packaging has been used, taking into account
the critical functions of the packaging (protection,
safety, storage, application and marketing).
Essential requirements, # 5

Reuse:
–
This Standard outlines the requirements for
packaging to be deemed to be recoverable.
Essential requirements, # 6

Requirements for measuring and verifying
heavy metals present in packaging (CEN
report):
–
This report addresses the environmental impact
from heavy metals in packaging after incineration
or land filling. The report confirms the heavy
metals limits outlined in the Packaging Directive
i.e. packaging must contain less than 100 ppm of
the sum of the concentration levels of lead,
cadmium, mercury, and hexavalent.
Do I have to meet all 6 Standards?



As presently structured, all packaging will be
required to meet the standard for heavy metals and
other hazardous substances requirements (CEN
report).
If you claim that your packaging is reusable, than
you will be required to meet the reuse standard.
Finally, you will be required to meet at least one of
the recovery standards (Material, Energy and/or
Organic).
What to take away from this…

Taken together, it is important for packagers
to take the Essential Requirements into
consideration in the design phase and
establish a paper trail documenting how each
standard was incorporated into their
packaging design protocol.
Who does EPR laws effect?

EPR laws affect product producers:
–
–
–
Producers would be defined as either the direct
manufacturer of a product that sells or distributes in the
[member state] under its own name or a brand name;
or, an entity that is not a manufacturer but is the owner or
licensee of a trademark or brand name of a product sold
or distributed in the [member state] under their own
brand;
or, an entity that imports the product into [the member
state] for sale or distribution.
“Producers?”


“Producers” are not considered “manufactures”
because the term “manufacturer” is too narrow.
For example, many manufacturers are located
overseas and work under contract to the brand
owner. It is the brand owner who makes design and
marketing decisions; therefore, it is the brand owner
who is responsible for funding the recovery of their
products’ post-consumer packaging waste.
“Producers?”


Also, many retailers are producers because
they sell products under their own brand.
Generally, the producer will be the brand
owner.
What should you do about EPR laws?

In order to comply with EPR requirements, electronic products
and consumer goods’ packages must be viewed at the
component level to ensure that he entire product and package
complies with the various requirements:
–
–
Material Considerations: In order to comply with material restrictions
(EU RoHS), producers will have to ensure that component
specifications are written so as to forbid regulated materials and to
obtain certification from the supply chain.
If the legislation requires producers to design products/packages that
meet recycling/reuse targets, product/package designers will need to
consider how to improve recyclability.
What should you do about EPR laws,
continued?


Often times, EPR legislation requires
companies to submit reports on waste
generation and product material contents
[e.g. packaging weight by component].
In order to ensure compliance and therefore
pay minimal fees for managing electronic
and packaging waste, consumer
goods/electronic producers should collect
and maintain a bill of materials database.
What you should do about EPR laws,
continued?



Producers should require that their suppliers submit
third-party certification documenting compliance with
the relevant standards.
Examples include a letter of certification from
material suppliers documenting compliance with the
EU RoHS Directive.
It is also helpful to establish a due diligence protocol
to ensure that all procedures established to enable
compliance are, in fact, being respected
How to avoid high EPR fees

Understand the requirements:
–
–
–
Producers of electronics and those who are responsible for putting
consumer products’ packages on the market must understand the
requirements in the markets in which their products and packages
are sold.
To do otherwise may result in bad press, fines, and the possibility of
getting their products and packages banned from the market.
By understanding the waste fees associated with products and
packages, producers could design product—and require their
packaging suppliers to design packages—that incur lower fees,
thereby creating a marketing advantage over those who do not.
How to avoid high EPR fees

Incorporating waste fees into the cost of
the product:
–
–
There are many fees that producers are now
required to pay to fund their products’ and
packages’ disposal/recycling at end of life.
Waste fees are associated with EPR legislation
are real costs.
How to avoid high EPR fees

Maintain necessary data points:
–
–
–
–
EPR mandates place new data demands on the producer of electronic
goods/those responsible for bringing packaging to the market.
In order to be able to generate reports for electronics, battery and
packaging waste fee payments and maintain documentation on material
composition, producers must maintain data on, for example, weight,
detailed material composition, and component type.
As is seen in Europe, it is recommended that producers develop a
compliance software tool that aids in complying with these requirements.
An example of this is the Pack.NET software system developed by
Foresite Systems, which calculates waste fees and generates
compliance reports for all worldwide electronics, battery and packaging
regulations.
How to avoid high EPR fees



EPR fees are often based on product/package type
or the weight of the product/package.
Therefore, electronic producers and product
packagers should design products and packages
that do not have any heavy metals or hazardous
constituents.
Additionally, because fees are dependent on the
weight of both the product and package, it is
important to design electronics and packages with
lightweight and safe materials.
How to avoid high EPR fees

If the material is classified as laminated you
pay larger fees.
EPR example, Canada’s Waste
Diversion Act, 2002


This law says that industry has to pay for
50% of the net cost for municipalities to run
their Blue Box program.
Stewardship Ontario was set up specifically
to collect that money from industry and give it
to the municipalities.
Blue Box Program



The Blue Box Program is similar to our curbside recycling in the States.
Unlike the States, however, Canadians are
encouraged to recycle a lot more material.
The “designated” material types accepted for
recycling via the Blue Box Program are listed
here:
http://www.stewardshipontario.ca/bluebox/pdf
/materialcategories.pdf.
Material type and fees


There are different fees for different materials,
depending on the ease of recovering said material
post-consumer. In other words, the harder a package
is to recycle or recover, the higher the associated fee
will be.
The fees change every year; here’s the latest:
http://www.stewardshipontario.ca/bluebox/fees/fees_
rates.htm.
Fee analysis


For example, if you sold a polystyrene
container into the Canadian market, you
would be required to pay 24.65 cents per kg.
However, there are all sorts of
restrictions/exemptions/etc. so it gets very
complicated.
What you should require from your
suppliers, overview



In order to ensure compliance, suppliers
must understand their obligations and the
requirements that affect their products and
packages;
they must certify that their products and
packages will meet these requirements;
and, they must provide key third-party data
on their products and packages.
What you should require from your
suppliers

Consumer goods companies/ electronic
producers should obtain the following data
from their suppliers to ensure compliance:
–
For the consumer product/electronic good:



Sales by country and month,
declared weight and/or volume of the product,
and the product-to-package ratio.
What you should require from your
suppliers, continued

For the package:
–
Data by packaging component:


In most cases, manufactures must be prepared to provide data on
each specific component of the package, not just the package as a
whole.
Additionally, packagers need to establish a program to obtain
certification from suppliers to assure that their products comply
with the EPR requirements.
What you should require from your
suppliers, continued

For the package, continued:
–
–
–
Primary package material and weight;
Secondary package material and weight;
Transport package, material and weight;
What you should require from your
suppliers, continued

Material type of primary, secondary and
transport packages needs to be classified
into the following:
–
–
–
–
–
Plastic by resin type
Paper
Glass
Aluminum
Composite
What you should require from your
suppliers, continued


Data must be collected in regard to the
number of uses for the primary, secondary,
and transport packages: Reusable or
refillable?
Data must be collected in regard to the
percentage of recycled content in the
primary, secondary, and transport packages.
–
Distinctions must be made between pre- and
post- consumer material.
The advantage of domestic suppliers



Despite the increasing trend toward international
manufacturers, brand-owners remain legally responsible for
compliance with EPR legislation.
Therefore, while it may be cheaper to source product and
packaging overseas, it is more difficult to ensure compliance
with EPR requirements because of data gathering obstacles
and the absence of a due diligence protocol throughout the
supply chain.
By sourcing domestically, consumer goods
companies/electronic producers can have harmonized
reporting, which will improve compliance, reduce compliance
costs, reduce paperwork, improve data accuracy, and send a
clear message to producers on how to improve their packaging
and products.
The advantage of sourcing direct from
the manufacturer



Because consumer goods companies are held liable for
EPR compliance, it is in their interests to source packaging
direct from the manufacturer in order to ensure that the
mandates are met and the necessary certifications are
received.
By sourcing direct, it is easier to attain and maintain the
data points necessary for EPR compliance i.e. materials
and weight of package and its components.
Moreover, sourcing direct allows for better supply chain
management via the implementation of a due diligence
protocol and data reporting.
Questions on EPR and packaging?
What is “Biodegradability?”

Biodegradability is an end of life option that
allows one to harness the power of
microorganisms present in a selected
disposal environment to completely remove
plastic products designed for biodegradability
from the environmental compartment via the
microbial food chain in a timely, safe, and
efficacious manner.
How “Biodegradation” works:

Microorganisms utilize carbon product to extract
chemical energy for their life processes. They do so
by:
–
–
–
Breaking the material (carbohydrates, carbon product) into
small molecules by secreting enzymes or the environment
does it.
Transporting the small molecules inside the microorganisms
cell.
Oxidizing the small molecules (again inside the cell) to CO2
and water, and releasing energy that is utilized by the
microorganism for its life processes in a complex
biochemical process involving participation of three
metabolically interrelated processes.
Part IV: Bio-based polymers,
introduction

Designing plastics that can be completely
consumed by microorganisms present in the
disposal environment in a short time frame
can be a safe and environmentally
responsible approach for the end-of-life
management of single use, disposable
packaging.
However…

When considering any bio-based resin, there
are some environmental considerations one
must take into account. These include:
–
–
–
–
end-of-life management,
complete biodegradation;
its agricultural-based feedstock;
and, the energy required and the greenhouse
gasses emitted during production.
End-of-life management
considerations

Because biodegradation is an end of life option that
harnesses microorganisms present in the selected
disposal environment, one must clearly identify the
‘disposal environment’ when discussing the
biodegradability of a bio-based resin. Examples
include:
–
–
–
–
biodegradability under composting conditions;
under soil conditions;
under anaerobic conditions (anaerobic digestors, landfills);
or, marine conditions
Bio-based resins intended disposal
environment


Most bio-based resins used in packaging
applications are designed to biodegrade in
an industrial composting facility and one
should require some type of certification or
standard from material suppliers, ensuring
compostability.
Available certifications include BPI
certification or ASTM D6400 certification.
Problems with intended disposal
environment


Unfortunately, little research has been done
on how many industrial composting facilities
exist in the United States and how bio-based
plastic packaging impacts the integrity of the
compost.
However, the Sustainable Packaging
Coalition did perform a survey of 40
composting facilities in the U.S., which
provides some insight.
SPC’s Composting Survey




According to their research, 36 of the 40 facilities
surveyed accept compostable packaging.
These facilities reported no negative impact of
including bio-based plastic packaging in the
compost.
Of the 4 facilities that do not accept compostable
packaging, 3 are taking certain packaging on a pilot
basis and are considering accepting compostable
packaging in the future.
Of the facilities surveyed, 67.5% require some kind
of certification of compostability.
Industrial Composting Facilities, their
preference


Because value for composters is found in organic
waste, I assume most facilities would not accept biobased plastic packaging for non-food applications
because the lack of associated food waste and
therefore value.
As Susan Thoman of Cedar Grove Composting
articulated in her presentation at the spring SPC
meeting, composters only want compostable food
packaging because the associated food waste adds
value to the compost whereas the compostable
packaging has no value, positive or negative, to the
integrity of the compost product.
Likelihood of composting


Because there are so few industrial composting
facilities available, the likelihood that your bio-based
plastic packaging will find its way to its intended end
of life management environment is rare.
While the idea of biodegradation and compostability
for plastic packaging may resonate with consumers,
the industrial composting infrastructure is in its
infancy and requires a considerable amount of
investment in order to develop to the point where it
would be an effective and economical option to
manage plastic packaging waste post consumer.
Questions on the end-of-life
consideration of bio-based plastic
packaging?
Complete biodegradation
consideration



A number of polymers in the market are designed to
degradable i.e. they fragment into smaller pieces
and may degrade to residues invisible to the naked
eye.
While it is assumed that the breakdown products will
eventually biodegrade there is no data to document
complete biodegradability within a reasonably short
time period (e.g. a single growing season/one year).
Hence hydrophobic, high surface area plastic
residues may migrate into water and other
compartments of the ecosystem.
Plastic fragments and the environment

In a recent Science article Thompson et al.
(2004) reported that plastic debris around the
globe can erode (degrade) away and end up
as microscopic granular or fiber-like
fragments, and these fragments have been
steadily accumulating in the oceans. Their
experiments show that marine animals
consume microscopic bits of plastic, as seen
in the digestive tract of an amphipod.
Plastic fragments and toxicity


The Algalita Marine Research Foundation report that
degraded plastic residues can attract and hold
hydrophobic elements like PCB and DDT up to one
million times background levels.
The PCB’s and DDT’s are at background levels in
soil and diluted our so as to not pose significant risk.
However, degradable plastic residues with these
high surface areas concentrate these chemicals,
resulting in a toxic legacy in a form that may pose
risks to the environment.
Complete biodegradability, summary

Designing degradable plastics without
ensuring that the degraded fragments are
completely assimilated by the microbial
populations in the disposal infrastructure in a
short time period has the potential to harm
the environment more that if it was not made
to degrade.
Questions on the complete
biodegradation of bio-based plastic
packaging?
Agricultural feedstock considerations



Most commercially available bio-based resins are produced
from sugar or starch derived from food crops such as corn and
sugarcane.
Over the past few years, the use of food crops to produce
biofuels has become highly controversial; the same may
happen with bio-based resins.
However, this is only if the scale of bio-based polymer
production grows. According to Telles VP Findlen, “If the
bioplastics industry grows to be 10% of the traditional plastics
industry, then around 100 billion pounds of starch will be
necessary, and there is no question that that will have an effect
on agricultural commodities.”
Feedstock procurement considerations

Because sugar is the most productive food
crop, it makes an ideal feedstock for biobased resin production; however, if all BioPE and Bio-PET came from sugarcane, we
would need 2.5 times as much land in
sugarcane. Unfortunately, this can not be
done sustainably.
.
Agricultural-based feedstock
considerations, summary


When considering bio-based resins, one should take
into consideration the feedstock from which it is
derived and the various environmental requirements
that go into procuring said feedstock.
While the current production of bio-based resins is
not to scale to compete with sugarcane production
for food, it is important to understand the
environmental and social ramifications of sourcing
materials from agriculturally based products.
Questions on feedstock procurement?
Energy requirements and fossil fuel
consumption of bio-based polymer
production, introduction


Obviously sourcing plastics from bio-based
resources as opposed to fossil fuel is an
intriguing option for those looking to reduce
the burden of packaging on the environment.
However, if the energy required to produce
bio-based plastics exceeds the energy
consumed in the production of traditional
resins, then the sustainability profile of biobased plastics can be compromised.
In the old days…

When bio-based plastics first became
commercially available, the processing
technologies were not developed to the point
where producing plastics from bio-based
sources consumed less energy than
producing traditional, fossil-fuel based
plastics.
Today, things have changed!


The bio-plastics industry has dramatically evolved
and is now able to produce certain bio-based resins
with less energy when compared with traditional
resins.
Natureworks Ingeo PLA (2005), for instance, is
processed in such a way that it actually consumes
less energy and emits fewer greenhouse gas
equivalents during production when compared with
traditional, fossil-fuel based resins.
LCA study, introduction


The Institute for Energy and Environmental
Research (IFEU), Heidelberg, Germany, conducted
the head-to-head lifecycle comparison on more than
40 different combinations of clamshell packaging
made from Ingeo PLA, PET and rPET.
Both PLA and rPET clamshells outperformed PET
packaging in terms of lower overall greenhouse gas
emissions and lower overall energy consumed and
PLA exceeded rPET in its environmental
performance.
LCA study, results



According to the study, clamshell packaging
consisting of 100 percent rPET emitted 62.7
kilograms of C02 equivalents per 1,000 clamshells
over its complete life cycle.
PLA clamshells emitted even less, with 61.7
kilograms C02 equivalents per 1,000 clamshells.
Energy consumed over the lifecycle for 100 percent
rPET clamshells was 0.88 GJ.
This compared to o.72 GJ for the Ingeo 2005 resin,
which is an 18% reduction in energy consumed.
Bio-based plastics considerations,
summary



Taken together, one would assume that the 2005 Ingeo PLA is
a more sustainable option than traditional plastics, as manifest
through this study.
However, it is important to take into account the other
dimensions discussed above, such as end of life management,
complete biodegradation, and sustainable sourcing.
By understanding the advantages and disadvantages of biobased resins from an environmental perspective, packaging
professionals can make informed material selections and truly
comprehend the ecological ramifications of their packaging
selections and designs.
Questions on bio-based plastic
packaging?
In conclusion…


“Sustainability” as it pertains to packaging
refers to a multitude of broad and
complicated issues.
It is difficult to understand the various
ramifications of the “green” movement on the
packaging industry; however, if we do our
due diligence and research, we will be ahead
of the curve.
Thanks for listening!
For existing questions,
email me at:
Cslavin@dordan.com
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