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ISRI responds to EPA plastic pollution reduction strategy

A stack of plastic bales
Bales of collected plastic bottles are stacked in a large row. Adobe Stock Images

The Institute of Scrap Recycling Industries (ISRI) has submitted comments in response to the U.S. Environmental Protection Agency (EPA) request for public comment on its Draft National Strategy to Prevent Plastic Pollution.

"Plastics are an extremely diverse, resourceful group of materials used in our daily lives," says ISRI President Robin Wiener. "Given the complexity of the recycling system and plastics in particular, there simply is no one single answer to the challenges facing plastics materials management in the United States. We applaud EPA for a proposed strategy that recognizes there are many solutions that, taken together, can make a significant difference in keeping plastic out of the environment and instead, circulate these valuable material resources into the manufacturing supply chain. We welcome the opportunity to further collaborate with the Agency and others to advance this proposed strategy."

ISRI's key recommendations

  • Improve markets for recycling plastics through policies that do not interfere with existing efficient markets and encourage the maturation of developing markets through technological innovation, incentives, and other efforts.
  • Encourage policies that incentivize manufacturers to design their products for recycling after their useful lives, to use greater amounts of recycled content in manufacturing, and to use recyclable and recycled content in packaging provided there are no negative implications to the product's recyclability.
  • As an alternative to full ratification of the Basel Convention, continued leadership of the U.S. government at the Organization of Economic Cooperation and Development (OECD) on plastics-related issues in order to provide plastics recyclers with further legal clarity and access to global markets.
  • Explore continued federal funding for U.S. government-led public-private partnerships focused on research and development of innovative technologies and implementation of design for recycling principles.
  • Explore the development of an accredited, voluntary third-party certification program, such as or similar to the Recycling Industry Operating Standard (RIOS), for plastics recyclers to increase the safe and effective management of plastics recyclables in the U.S. and strengthen the domestic manufacturing supply chain.
  • Exclude processes that convert materials to fuels, fuel ingredients, or energy from being considered a recycling practice.
  • Prioritize additional funding opportunities for recycling accessibility and infrastructure in under-resourced communities.

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