The ISRI Fiber Recycling
Readiness Tool
The ISRI Fiber Recycling Readiness Tool focuses specifically on recycling post-consumer fiber-based packaging that will be marketed in the United States.
The ISRI Fiber Recycling Readiness Tool
The ISRI 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 ISRI 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 ISRI Paper Recyclability MRF (Materials Recovery Facility) Survey conducted by Moore & Associates on behalf of ISRI.
- 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.
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 RISRI 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
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.
Ownership. ISRI 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. ISRI’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. ISRI 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 ISRI expressly disclaims. ISRI intends to regularly update the Tool to reflect new advancements and best practices in fiber-based packaging.
Miscellaneous. ISRI will consider all relevant matters presented during any public comment periods and will respond in some form to all comments received. ISRI 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 ISRI, to the extent permitted by law. ISRI 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@isri.org
- REFERENCES
ISRI “Learning from the MRF Survey”, February 2020
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
- 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.