Recycled Input Validation
July 13, 2016
Introductions
Deepak Goel
Terry Turner
John Graebin
Kim Holmes
Kathy
Paolo Foglia
RS Bala
Recycled Input Verification Feedback
Should there be stricter requirements for Material Collectors and Concentrators?
Material Declaration Form – CBs might have difficulty getting into a concentrator based on just a MDF. Should the MDF be changed to a Reclaimed Material Supplier Agreement?
- Concentrators may not be interested in a full agreement and it may reduce the supply
CB: It’s very difficult currently because we have no relationship, and we don’t know how to cover the cost.
Many of the systems are very informal; there is no proper organization here. It is very difficult to organize any verification.
In the US and Europe it is more formal. But in other countries, it is not possible.
For the Material Concentrators, it is more likely for this to happen.
Usually the recycler is collecting the form from the direct supplier.
Both the Material Collectors and Concentrators should be under some kind of agreement. We could collect some basic information, as it is now. In this way, we don’t have the right to perform the 10% verification.
Alternatively, we could change the standard to say that even those kind of organizations should be included into the scope of the standard. In this case, they would apply to a formal type of approval.
We are starting to get questions from downstream if we can “guarantee” that we don’t have bottles that were collected from child labor. We have forms from our supplier on wastewater, etc. The real control over those issues is with the collector.
If adopt this criteria, we have to say that we do not accept any informal material collection. We could accomplish assurance by not allowing material collected through informal means, anything from Bangladesh, etc.
I have seen cases where materials are not accepted from Mexico, Thailand, or even parts of the US. If it’s something that the standard cannot control, then maybe it’s worth stating that we can’t control that far back.
Material Collection:
-individual rag pickers
-lack of organization
-child labor
-chemical / environmental impacts
-verylow risk of fraud of “recycled”
Statement about how far the standard is able to control these areas.
- Require Material Concentrators to list the region the materials came from.
Material Concentrators:
-more formalized
-likely have a legal organization
-low risk of fraud of “recycled” materials
-strategy to address the risk varies across region and sector
Currently:
Reclaimed Material Declaration Form – submitted to the Material Recycler
- Include Material Concentrators in the scope of certification.
- This is not practical because no one will apply for this certification. There is not a market value for the material that would be certified. It would be difficult to convince them to pay for certification.
- There are several types of Concentrators, they would not be open to certification. The large ones might be open to this, but not the small ones. Sometimes these goods are sold through a trader, he does not have the financial incentive to dig into further paperwork.
- The same is true for the plastics industry. Adopting this could impede adoption across other industries.
- Material Concentrators sign an agreement with CBs or with the Material Recycler.
- There may be a high number of Material Concentrators for Material Recyclers from regions around the world.
- It could still be difficult to get 10% of these verified; the cost would be too high for many Material Recyclers.
- CBs cover the cost of additional 10% verification (give some guidance for auditors on what the verification looks like).
- 10% (at least one) of all Material Concentrators for each Material Recycler must be verified.
- Including Concentrators and Traders, there are about 50.
- Remove the 10% verification requirement.
Include a requirement that shows what the recycler has done for due diligence:
major suppliers: questionnaire, licensed businesses, permitted for discharges, no environmental discharge violations, supplies an affidavit that is specific to the material that is received, a signed document declares what type of recycled it actually is. We do the same in China, but haven’t yet adopted the more extensive form.
Additional resources on regulation and legislation in China.
Should we expand the scope of the standard to include re-purposed, re-make as well?
In the case of down, this could be already certified. It is related to the idea of waste. We also introduced the concept of by-product. These are reconditioned to provide the qualities necessary to be sold into the market.
We can include this with no changes to the standard.
Re-purpose and re-make would need to be defined really carefully in order to be added into the standard.
In the case of the pair of jeans, this meets the definition of waste being used as something else. Without introducing any new concept.
Fallout from cotton spinning would also qualify.
Waste being used in a new product.
Material that is going back at least one stage in manufacturing.
Moving the fallout from the carded spinning line to the combed spinning line should not be accepted.
Is there a value-add transformation? This would keep in line with US FTC Green Guides.
How do we ensure that consumers are aware of what they are buying? It could confuse the final consumer for re-make or re-use to be allowed by the standard.
Legislation may cover the safety of the material.
Create a document of examples, add it to website so that it is easy to maintain.
Should we expand the scope of the standard to include only allowing input materials that are recyclable?
The question of recyclability covers a wide range of factors: design, material composition, etc.
I would propose not to include it in this version of the standard. It is clearer to keep the focus on verifying recycled material content. Perhaps a new standard could address recyclability later on. It should be a separate topic.
Recommend that we don’t confound the two issues. It is a challenge to determine who is allowed to determine if something is recyclable. It could change very quickly, and different parties may interpret it differently.
Much of the glass put in recycling facilities is not actually recycled, because of the distance and financial incentive. It would be going too far to include this in the standard.
The current minimum percentages are: RCS 5%, GRS 20%, GRS Labeling 50%.
Should these be adjusted? By material type?
There are some suppliers that are not able or not interested in recycled content percentages higher than 15%.
Recycled cotton blend – cannot go beyond 30% recycled cotton.
15% for GRS – labeling 30%
Electronics, there are some provisions for some materials. Their minimum content is very low because supply is low. It can be really difficult to have high percentages.
The existing levels may be difficult for other industries to meet.
This is something that could be better addressed by brands.
Need resources on good content allowances for other industries. Some standards use a points system based on percentage of recycled content.
Keep current minimums and add allowances by material or product type. Request additional info from IWG members.