Building a bridge to circularity

The National Stewardship Action Council (NSAC) celebrated its 10^th anniversary in 2025. The national nonprofit organization's mission is to build a responsible, circular economy in the U.S. by bringing together government, industry and nonprofit partners.

In that time, its role has evolved from solely policy advocacy to convening stakeholders at the state and national levels and providing implementation support for legislation, Executive Director and CEO Heidi Sanborn says.

“Over its first decade, NSAC helped move circular economy and stewardship policies from concept to negotiation and passage while building trust across industry, government, nonprofit and communities,” she says.

“Looking ahead, the next decade will be defined by whether these policies actually deliver,” Sanborn continues. “Our focus is on implementation performance, worker safety, market outcomes, cost control and ensuring policies function as designed. We’re scaling national working groups because the future of circular economy policies and solutions will be written in operations, safety records and supply chains, not just legislation.”

While NSAC’s first decade was about proving that circular economy and product stewardship were viable and necessary, it’s next decade will be focused on proving they work in the U.S., she says.

In the following interview, Sanborn shares more about the role NSAC is taking to help advance policy and its beliefs concerning producers’ role in ensuring circularity.

Q: How did this evolution within NSAC take place? What were the catalysts?

Heidi Sanborn (HS): It was very purposeful. It was organic. It was a need we saw to be filled. And we first saw it on S.B. 54 [California’s 2022 Plastic Pollution Prevention and Packaging Producer Responsibility Act]. I said, ‘My gosh, these stakeholders from all over the world don't know how California rulemaking works. They don't know how to stay tapped in to make comments. They don't know how to make their voice heard.’ And I was really worried that [CalRecycle] would get a whole bunch of comments from stakeholders that had never met each other, had no idea of what each other's issues were, and they'd all be in a vacuum, and then the agency would have all these conflicting requests for the regs that they really couldn't resolve. What can we do in our little sphere of influence to help resolve that? And I really wanted this bill. I've put so much heart and soul into it and spent so many years building up to the fact that we can even get a bill of this magnitude passed and signed that it meant a lot to me, personally, and to the organization that this work. I did not see a path to it working well on the regulatory side if we did not convene a very broad group of stakeholders.

Q: Why do you think circular economy policies are gaining interest?

HS: Circular economy policy is gaining traction because it delivers benefits far beyond environmental outcomes and redemocratizing waste systems so the public can “vote” with their dollars based on truthful labeling and make purchasing decisions based on facts, which drive costs down.

If people buy a product labeled as “recyclable” but it's not, we must sort it out of recycling streams, and it adds costs to sorting and disposal. Communities, businesses and policymakers are increasingly focused on affordability, supply chain reliability, national security and public safety. That all comes from responsibly designed products made and remade in North America.

There’s also growing recognition that rising system costs, fire risks and insurability challenges can’t be solved through voluntary programs or messaging alone. People want systems that work, including ones that protect workers, safeguard public health, keep costs off taxpayers and ensure materials actually become new products.

Circular economy policy is increasingly about economic resilience, creating American jobs and domestic capacity, not just diverting “waste.”  Material markets and updates of recycled materials in new products, not messaging, determine whether recycling works.

Q: NSAC plans to scale its S.B. 54 Implementation Working Group into a national Packaging and EPR Implementation Working Group. What is your timeline, and what do you hope to accomplish?

HS: Our first meeting of the National Packaging and EPR Implementation Working Group [was] Jan. 22, and we’ll build a regular cadence throughout 2026. The goal is to create a national forum where states, producers, local governments, haulers, recyclers and end-market manufacturers can share implementation lessons in real time.

Before year-end, we want to identify common implementation challenges and themes across states, surface best practices early, reduce duplication and help programs and rulemaking stay aligned with legislative intent as they move into operation.

2026 is when packaging EPR becomes real in multiple states. Our job is to help implementation deliver on its economic, environmental and public health benefits and then to message that to the public. We’re building a national table where operational realities inform policy decisions before systems get locked in.

Q: How confident are you that packaging EPR will deliver on its promises? What is the greatest threat to that?

HS: It can, and that's been proven around the world. The problem is the lessons that have been learned that we got into the bill need to follow through in the regs and the implementation by CAA [Circular Action Alliance, the producer responsibility organization, or PRO, for California's S.B. 54] and oversight of the agency. If all those things, any one of those four things, go off the rails, this won't work as intended. And there are people and industries that don't want this to work as intended, so we are in a constant battle.

I always tell people, getting the bill is great, but that's just the beginning of the race because then you've got to really focus on this back-end side. And a lot of people don't. We have always done that. We've done three cleanup bills on the original [California] carpet bill since [it was established] in 2010 because, until it works correctly, you don't stop because it makes EPR look like it doesn't work. I want to make sure they all work and we learn the lessons. And that's why I also wanted to go national, because a lot of what we learn in California when we go first, ... we've already seen it. We've already heard it. We've already dealt with it. I want them to know how hard it is to get the stuff done, even in California, and learn the lessons and hold the bar up because every state that drops the bar makes it easier for the next one to drop the bar, and they copy a bad model. So that's part of the national collaboration.

Q: Tell me more about your Household Hazardous Waste (HHW) Working Group. How does expanding it beyond local governments strengthen the work?

HS: HHW and hard-to-manage materials affect the entire system from collection and transport to processing, worker safety and insurance costs and insurability. Expanding the working group to include haulers, manufacturers, recyclers, associations, PROs and NGOs [nongovernmental organizations] ensures solutions are practical, scalable and grounded in real-world operations. It takes all of us—everyone involved in this space needs to be involved in fixing this space and ensuring the safety of our essential workers and the public.

A major focus across our industry is safety: stopping fires, protecting essential workers, safeguarding public health and keeping facilities and fleets insurable. These are not abstract concerns; they are defining whether systems can function at all.

We need effective policies and solutions that prioritize essential worker safety, protect public health and safety, keep our industry insurable and stop the fires.

Q: What kind of interest do you see for EPR around HHW, and why is it the right solution?

HS: Interest in EPR for HHW is growing because local governments cannot manage rising risks and costs alone, and HHW is contaminating clean streams of recyclables and organics and ending up in landfills even when they are banned from disposal. EPR aligns shared responsibility with product design, labeling, funding,and access, instead of shifting those burdens onto communities, workers and ratepayers.

When designed well, EPR reduces risk, improves consistency and ensures safer end-of-life management nationwide. This can also happen with ordinances at the local level.

EPR is about stopping the externalization of risk and cost onto communities and workers. If we want safer systems, responsibility has to follow the product.

Q: Tell me about NSAC’s work to advance critical mineral recovery while reducing fire risks and strengthening domestic supply chains.

HS: NSAC has participated in national-level workgroups that bring together public agencies, private companies and nonprofit organizations across the materials and manufacturing landscape. Critical mineral recovery is now a clear priority for the current administration and is tied directly to national security, domestic manufacturing and supply chain resilience.

Batteries illustrate both the challenge and the opportunity. When mismanaged, they create serious fire and safety risks. When managed responsibly, they offer a pathway to recover critical minerals needed for American manufacturing while protecting workers and infrastructure.

Critical mineral recovery has become a national priority, and batteries present both a real risk and a real opportunity. This is where worker safety, supply chain resilience and national security intersect.

Q: Why is it important to grow the National Textile Circularity Working Group? What do you see coming legislatively?

HS: Textiles are one of the fastest-growing waste streams, yet they already support a strong reuse, resale and repair economy. Policy interest is growing over the next one to three years, and the risk is that poorly designed systems could undermine what already works.

Our role is to ensure future policies support reuse, repair and resale, including Right to Repair, and reflect real market conditions.

For textiles, real circularity means supporting reuse, repair and resale and existing infrastructure not just managing waste after value has been lost. Policy is coming, and our responsibility is to make sure it supports the early adopters aligns with real-world systems.

Q: In the area of textiles, how can policy leverage the work organizations like Goodwill are already doing in this area and its expertise? How can we best address the collection issue for textiles?

HS: I'm really glad you brought that up. My biggest concern with textiles is that we get PROs that are brands that have their own virgin products that will not want repurposed, repaired textiles competing with their sales. We saw this a bit with paint, where the paint is mainly shipped overseas and to not sell against U.S. brands of virgin paint because the profit margin is a lot lower. I worry about that a lot because Goodwill has been around, I think, 130 years. Planet Aid has been around 30-35 years, and they have a huge infrastructure, and I'm very concerned that the PRO will bypass [that infrastructure] and do their own thing or not give them the proper support.

Q: What truth-in-labeling issues are you trying to address?

HS: Misleading recyclability, flush-ability and compostability claims drive contamination, increase costs due to infrastructure damage and erode public trust. Consumers want honest information, and systems need consistent definitions and enforcement to function properly.

Truth-in-labeling is about protecting infrastructure investments and preventing avoidable system failures. Truth in labeling is a cost-control and trust issue. If labels lie, the system breaks.

Q: How critical is it for recycling to win back public trust? Has mislabeling been the biggest contributor to this erosion?

HS: It is the No. 1 thing. We cannot reduce contamination in the system until the labels are accurate. And it's like the Wild West. People can put almost anything on the label. There's no police in town, no sheriff. Nobody's getting caught. Nobody cares. They can say it's recyclable when it's not, compostable when it's not, flushable when it's not, and then we have to pass bills to try and get them to stop lying. The whole system is screwed up. And I want a federal, enforceable you-can't-lie-on-the label policy.

I'm very proud to that we co-sponsored S.B. 343 that says you can't use the chasing arrows on your own plastics unless it's got a certain recycling rate. Now, at the federal level, we're seeing actions to preempt that.

It has to start with truthful labeling, but it really should be federal. We'd love to have a national discussion about what's the right standard to make enforceable at the federal level.

Q: How likely is a national deposit-return system? What states show promise? Can DRS expand beyond beverages?

HS: States continue to be laboratories for policy innovation. A national DRS remains politically complex, but momentum continues at the state level. States to watch include New Hampshire, Rhode Island and efforts to revamp New York’s deposit system.

DRS works best for beverage containers because of volume and standardization, and it greatly reduces littering and feeds existing U.S. aluminum, glass and plastic recycling plants. Expansion beyond beverages requires careful design to maintain performance.

DRS is one of the most proven tools we have for clean material and domestic supply. The question isn’t whether DRS works. It’s how we modernize and strengthen what it already does to improve it.

Q: How does NSAC ensure the legislation it helps pass actually delivers on its promises?

NSAC stays engaged well beyond passage through rulemaking, implementation and performance evaluation. Our working groups surface operational challenges early and help protect legislative intent while allowing refinements that improve outcomes.

Policy doesn’t succeed at passage. It succeeds when it performs. Refinements are how you protect intent while improving results.

In closing, 2026 is likely to be defined by whether recycling can earn back the public trust by delivering real recycling that has stronger supply chains and real economic and environmental outcomes, proving that what’s made in America can be ReMade in America.