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The American Forestry and Paper Association (AF&PA) says unintended consequences could affect existing paper recycling programs in the state if New York’s new extended producer responsibility (EPR) proposal is adopted.
The organization claims the proposal is a one-size-fits-all EPR program that could undermine or even reverse the success of paper recycling. The AF&PA says the proposal is too vague and would create uncertainty in the paper recycling industry. Terry Webber, AF&PA vice president of industry affairs, says the uncertainty can harm the industry because of the amount of time and investment needed to advance paper recycling infrastructure.
"The EPR proposals in Albany currently take a one-size-fits-all approach, which fails to recognize important differences between materials," Webber says. "This blanket approach could easily erode the success we see in paper and paper-based packaging."
Webber says a poorly designed EPR program would erect unnecessary obstacles throughout the paper recycling system. The obstacles could then discourage or curtail additional industry investment, making recovered paper markets more costly and less efficient. EPR expenses imposed on paper producers risk increasing costs on everyday items for consumers. It could also impact the paper industry’s 28,000 employees who work in 224 facilities across New York in jobs that meet $1.69 billion in annual payroll and generate $211 million in state and local taxes.
“We’d like to see more clarity in the legislative language before they kick it over to the regulatory process,” Webber says. “Ultimately, we’re asking policymakers to focus on improving recycling for materials with low recovery rates instead of creating mandates and fees for paper producers that could direct capital away from investing in recycling infrastructure.”
Webber says EPR policies should be designed to avoid disrupting paper recycling infrastructure and not require one material to subsidize a competing material’s recycling infrastructure development.
Under the proposed EPR program, manufacturers will be responsible for managing their products and packaging at the end of their useful lives—meaning taxpayers wouldn’t pay for recycling anymore.
Recently, the Association of Plastic Recyclers (APR), Washington, endorsed the proposal, saying it would incentivize producers to generate less packaging overall and make the packaging they do use nontoxic and easier to reuse and recycle, fostering a circular economy for New York.
The APR says New York’s average recycling rate is currently at 18 percent and average contamination rates in the U.S. are more than 25 percent. Most plastic recyclers in New York are not operating at full capacity and need more material to meet the demand for recycled resin.
According to the EPA, more paper by weight is recovered for recycling than plastic, glass, steel and aluminum combined.