Connecticut’s new product stewardship bill could harm recycling industry, says ISRI

By Paul Ploumis

SEATTLE (Scrap Monster): The Institute of Scrap Recycling Industries’ (ISRI) New England Chapter has submitted a testimony before the Connecticut General Assembly Joint Environment Committee, opposing the new product stewardship bill HB 7067. The world recycling body alleged that the proposed legislation could prove harmful to the recycling industry.

ISRI appreciated the hard work put in by the Connecticut Department of Energy and Environmental Protection (DEEP) staff in implementing the state’s existing product stewardship programs. It noted that such programs may be necessary for certain products that lack end markets. However, such programs are not needed for used and end-of-life materials that enjoy high market demand. The HB 7067 leaves open the possibility of government implementing product stewardship programs for recyclable materials, it added. ISRI opposed the idea of holding producers financially responsible to collect and recycle those items that are sold into markets without subsidies or at non-competitive fixed prices.

According to ISRI, the bill is drafted in a way that ignores the immense potential of the existing recycling industry. It urged that DEEP must conduct a comprehensive market analysis prior to identifying a new product to be qualified under the stewardship plan. In addition, the economic efficiency of recycling programs must be ensured through competitive bidding process. The current legislation does not contain reference to market evaluation. Neither does it offer any guarantee that product stewardship programs will not run into viable markets. The bill doesn’t require DEEP to seek advice and consent by recyclers, which in turn will cause undue harm to Connecticut’s recycling industry. After all, ISRI believes that it is illogical to pursue discussions on product stewardship programs without first consulting the recycling industry.

Meantime, ISRI stated that it would continue to support a competitive marketplace that does not restrict, direct or interfere with the free flow of recyclable materials. On the other hand, it would oppose imposed fee and mandates that hold producers financially responsible to collect and recycle products that are manufactured into commodity grade materials and sold into viable markets without financial backing. ISRI’s Design for Recycling policy requires manufacturers to ensure that their products are designed and manufactured so that it can be safely and economically recycled to the maximum extent possible. The existing recycling infrastructure must be given an equal opportunity to participate in programs that impose fees on recyclables, it noted.

HB 7067 states that the DEEP Commissioner shall be responsible to adopt regulations to identify covered products that shall be included in a product stewardship program. The commissioner has the authority to include any provisions in such regulations. The bill also grants authority to the commissioner to amend such regulations from time to time. ISRI alleged that the legislation would give uncontrolled authority to the commissioner in implementing extended producer responsibility (EPR) programs for any object or substance that falls under the clause of the regulation.

About ISRI

The Institute of Scrap Recycling Industries, Inc. (ISRI) is the Voice of the Recycling Industry. ISRI represents more than 1,600 companies in 21 chapters nationwide that process, broker and industrially consume scrap commodities, including metals, paper, plastics, glass, rubber, electronics and textiles. With headquarters in Washington, DC, the Institute provides safety, education, advocacy, and compliance training, and promotes public awareness of the vital role recycling plays in the U.S. economy, global trade, the environment and sustainable development.