The Global EPS Sustainability Alliance is a collaboration between EPS manufacturers, extended producer responsibility PROs, recyclers, and others to advance the circular economy for expanded polystyrene (EPS) packaging in five continents that are working to support environmental policy solutions at local, regional, and global levels.
The GESA coalition represents the EPS industry in Africa, North America, Europe, Asia, and Australia. Our member organizations include:
The treaty is an important opportunity to address plastic pollution from a clean slate perspective and take a novel problem-solving approach; however, ambitious goals must be balanced with the reality of implementation challenges.
EPS packaging plays an important role in the global distribution of essential goods, and we hope to see the treaty deliver new solutions and to harmonize policies that we see are already working.
Environmental Producer Responsibility (EPR) is a tried-and-true policy tool that could achieve faster and more efficient implementation with the help of harmonized international oversight. The EPS industry also supports reuse and recycling policy measures but cautions that these are not one-size-fits-all since different countries may have different waste management capabilities or may be at various stages of product developments for technologies that can create a more circular economy. In some regions or countries, landfill bans may be a good solution, but feasibility studies must be conducted to affirm potential effectiveness.
The plastic pollution treaty should incorporate policy solutions that encompass both commercial and residential waste streams. An overfocus on residential waste could disadvantage economies of scale in the recycling equation. For residential waste, there needs to be recognition that the consumer is the first point of custody for packaging waste and that increased accountability measures could play a big role in reducing packaging pollution. Consumer education, in and of itself, is not working, and labeling systems need to be greatly improved and more easily accessible.
A QR approach to labeling could be effective and the treaty offers the potential to streamline the adoption of a universal labeling system that is easily updated as changes in packaging material choices and waste management disposal capabilities improve.
Members of GESA became accredited to monitor and engage in the treaty development process. There is recognition that the plastic industry plays an important role to inform UN member state negotiators.
GESA’s role is to provide information and insight to negotiators and increase awareness of effective waste management solutions. We also serve as a resource to better understand expanded polystyrene environmental dynamics, including manufacturing energy use, GHG emissions, recycling technologies, and research on packaging science. GESA has been encouraged with the opportunity to provide substantive comments along with other stakeholders that facilitate the collection of a broad-spectrum opinion pool.
The treaty is considering policy to define problematic plastic. To date, this has been addressed on a theoretical basis only. Detailed and robust criteria are needed as a starting point because of the multi-faceted considerations that must be accounted for, including production, use, disposal, chemical makeup, and functionality, to be further considered against replacement alternatives to gauge the net-positive or net-negative trade-offs.
Further, the implementation of potential restrictions for problematic plastic needs careful evaluation. In 2021, Australia passed a law restricting certain plastic packaging materials. It immediately had to reverse its decision to include EPS, which is essential to shipment viability for white goods, fresh fish, and many other products. Portsmouth University published a policy analysis paper, A Global Review of Plastics Policies To Support Improved Decision Making and Public Accountability, looking at the effectiveness of packaging material bans, ultimately concluding there was very little evidence to indicate the effectiveness of this approach.
There has been a noted lack of independent scientific review of the treaty policy options under consideration. This was publicly recognized at a recent conference, The Global Plastics Summit, hosted by Economist Impact in Bangkok last month, with over 350 attendees from 60 countries.
There are two aspects of unintended consequences, one is to validate the environmental trade-offs that may come from material substitution scenarios outlined in the treaty Zero Draft options. Packaging science and environmental science have important roles to play to ensure net-negative environmental impacts don’t occur. The environmental science needs to address a larger data set beyond chemical composition and end-of-life waste management.
The EPS industry recommends the treaty adopt and implement the use of Packaging Product Category Rules that would facilitate the development of Environmental Product Declarations. This approach would expand material comparisons to include energy consumption, ozone depletion, acidification, eutrophication, ecotoxicity, and human health impacts. These are consensus-based protocols developed under ISO 14025 that stipulate third-party review and certification. It would ensure paper and other non-plastic alternatives are adequately evaluated as well.
Another is the need for uniform data collection. Even if material substitutions are validated, the performance of a packaging system needs to be monitored for increased damage rates, which would result in higher environmental impacts due to remanufacturing and reshipping of replacements for each incident.
Policy effectiveness also needs to be measured so that corrective action can be taken when policy implementation is proven ineffective in practice. Without a scientific evaluation and comparison method based on quantifiable data points, there is a tremendous amount of room for error and detrimental environmental outcomes.
GESA advocates for the following positions as part of its recommendations:
More information on these positions can be found on the GESA website at globaleps.org.
Since the early 1990’s global efforts to collaborate with original equipment manufacturers to recycle EPS have resulted in long-standing growth in the commercial sector, this foundation established economies of scale that facilitate the addition of residential waste streams. This means there are stable end-use markets for collected material, and there is now some momentum in the adoption of community recycling opportunities for EPS. This is evidenced in the U.S., Australia, India, and others that are collaborating with civil society to include EPS in their waste management portfolios.
Leading resin producers RAPAC, Epsilyte, Styropek, Nexkemia, and BASF have all developed proprietary formulas that will allow EPS fabricators to incorporate ≥30% recycled content in the manufacturing of many applications. Seventy-nine million pounds of online capacity is already serving North American markets, with projections for an additional 150 million pounds of capacity.
Chemistry-driven innovations have made these advancements possible. Recycled content resin offers equal performance properties to virgin materials, thereby reducing the use of virgin materials and reducing environmental impact. The recycled content will be used in the manufacturing of many products, including protective packaging, bicycle helmets, construction, drainage and septic aggregate, and more. Some EPS molders have conducted successful trials with the recycled content resin and are planning to be market-ready by 2024.
Recycled content EPS has been technically achievable for some time, but historically, end users have not been motivated to use it. That trend is changing. With more stringent policy recommendations stemming from national governments, there is mounting pressure for the private sector to take a second look at recycled content capabilities.
One aspect of the environmental equation that is not coming to light is the potential for increased damage by substituting alternative materials that don’t offer the same in-transit protection. The exponential environmental damage caused by spoiled food or product returns must be accounted for. This involves further research by packaging academia and extensive testing that can confirm alternative materials don’t cause increased damage rates. This is another part of the comparative analysis that is needed to avoid unintended consequences.
This is perhaps the most important part of the equation. An ordinary person in their everyday life can take action in their home and work environments, and most people know what this means – minimize consumption (use less), recycle, repurpose, and reuse.
People largely understand these concepts, but there are two major things issues that need to be addressed: 1) the notion that it should be easy; and 2) accountability.
For every item that needs to be disposed of, consumers or workers are the first point in the chain of custody, making this a crucial step in the process. To ensure materials are handled correctly, individuals must adequately inform themselves of the correct disposal method. Becoming informed is an action.
Awareness that disposal practices evolve over time, means individuals must engage in continuous education efforts. This means staying abreast of company policy, residential recycling guidelines, community collection events, and other information sources. Behavioral changes are tantamount to collective success and eradicating plastic pollution. Littering, open burning, and illegal dumping all contribute.
While companies can be fined for non-compliance, consumers are typically not held responsible. There has been consideration for policies aimed at residential waste streams, like pay-as-you-throw and warning notifications (followed by monetary penalties), for improper disposal.
GESA is a global organization with the ability to connect waste management professionals, civil servants, government, small business interests, and citizens with EPS recycling solutions and opportunities. EPS industry contingencies offer these information resources via social media and other news outlets.
Selva Ozelli Esq, CPA is a legal and finance executive with diversified experience dealing with highly complex issues in the field of international taxation and related matters within the banking, securities, Fintech, alternative and traditional investment funds. Her first of its kind legal analyses involving tax laws, Foreign Corrupt Practices Act (FCPA), blockchain technology, solar technology and the environment and have been published in journals, books and by the OECD. Her writings have been translated into 15 languages.