This first edition of the Tool is for fiber-based packaging that are currently bought and sold, or will be launched in the United States. Biodegradability and compostability are not addressed by the Tool. 
 
The focus of the Tool is to determine whether the packaging can be effectively flow through the current residential recycling infrastructure and does not assess recycled content. For packaging to be recycled in the U.S., the following criteria need to be met:   

• The packaging meets the U.S. Federal Trade Commission (FTC) requirements for recyclable claims.  
• The packaging is likely to be successfully sorted into a market-ready bale of like material at a MRF.  
• The material can be cost effectively processed at a paper mill into suitable feedstock for production of new products.  

The Tool assesses the packaging, unfilled and separated from the product, after use by consumers. The determination of the Tool is based on the whole packaging in its typical condition after use. Whole includes all packaging components such as staples, labels, seals, lids and closures, handles, and any other integrated components that would typically be found on the packaging. The packaging is then collected from residential curbside recycling collection, subscription services, and drop-off locations. 
 
The following types of fiber-based packaging are included in the Tool, but this list is intended to be illustrative only, not exhaustive. Refer to the grade definitions  in the ReMA Specifications:  Paper Stock – Specs22 (isrispecs.org)
 
Most commonly used fiber-based packaging:  

• Corrugated boxes                                                                      

• Paperboard folding cartons – URB, CRB  
• Paperboard folding cartons – SBS  
• Paperboard folding cartons – CUK  
• Molded fiber packaging  
• Kraft paper bags 

• Cartons – aseptic and gable-top multilayer containers  
• Fiber-based multi-layer containers with metal/poly  
• Fiber-based flexible packaging with poly barrier (pouches)  
• Paper cups and foodservice packaging; pizza boxes  
• Paper mailing envelopes  

The following characteristics are scored in the packaging evaluation:  

• Physical size of the packaging  
• Distribution volume of the product (local, regional, national)  
• Percentage of recycling programs that accept the packaging type  

• Likelihood that packaging will be successfully sorted at the MRF  
• The packaging is explicitly included in ISRI’s current paper grades  
• The extent that non-paper elements added to the packaging would generate unacceptably high contamination and/or low yields when recycled by the end-market mill  

The scoring system is qualitative. Packaging is scored on each of the characteristics listed above using points-based rating scales. Each point in the scale reflects a continuum from less to more able to pass through the recycling system. The final result indicates when packaging does not pose consistent challenges in the residential recycling stream. The higher the score, the more likely the packaging will pass through the recycling system. 
  
Different scales have been selected for different characteristics so that scales reflect the relative importance of the various characteristics to the recycling system in general. The scoring is done on a pass/fail basis. 

A final result of “Green” means the package meets the Tool criteria and will pass through the average MRF in the U.S. A final result of “Yellow” means the package did not meet the criteria but could pass through the average MRF with some modifications, or that it would pass through the recycling infrastructure in some local/regional systems, but not others. A result of “Red” means that the package did not meet the criteria, and there are significant compatibility issues with the package and the current recycling system in the US.  

What is the Fiber Recycling Readiness Tool (Tool) and why is it important?
The Tool is a science-based online resource for brands, packaging companies, and other industry users to assess the extent to which fiber-based packaging is likely to pass through the current U.S. residential recycling system and whether it poses known challenges for that system.

The Tool assists manufacturers in designing for recycling. If the packaging flows easily through the current recycling system,  a “green” score is given and the applicant receives a confirmation email. If not, then ways the packaging can be altered to achieve a “green” designation are provided. The applicant can redesign the packaging so that it receives a “green” designation.

The Tool focuses specifically on post-residential consumer fiber-based packaging that will be marketed in the United States.

Who should use the Tool?
The primary audiences for the Tool are fiber-based packaging manufacturers and brand owners of consumer products that use fiber packaging. Some common end-use markets are food and beverage, personal care, and electronics.

What is the history behind the Tool and why now?
Brands have expressed their desire to convert current packaging materials into fiber-based packaging. One important feature of the packaging is for it to flow through the current recycling infrastructure. This impacts the complete lifecycle of packaging—including design, collection, processing, and being used into new products. Because of the magnitude of change to fiber-based packaging, ReMA created the Tool to meet this industry need.

Do I need to be an ReMA member to use the tool?
No. The Tool is accessible to members and nonmembers alike for the betterment of the fiber recycling industry.

Do I need an ReMA account to access the tool?
No, there is no login is required.

What should I have ready before I start the Tool?
To complete the Tool, you will need to have the specifications of your packaging handy, so that you can accurately answer questions about the packaging’s material composition, size, and shape. Progress on the Tool cannot be saved, so you will need to have this information prepared in advance.

Is the Tool easy to use?
Yes. The Tool is a simple online resource that asks a series of questions that will identify the packaging characteristics that are most impactful to its going through the current recycling infrastructure and provides a straightforward end result of Green (Meets Criteria), Red (Does Not Meet Criteria) or Yellow (Could Meet Criteria With Modifications). If the result is Yellow or Red, the tool also provides customized feedback on how the packaging can more readily go through the current recycling infrastructure. The Tool’s design provides clarity to brands and packaging companies on packaging and its attributes that flow through the current U.S. recycling infrastructure. It was designed to be straightforward and effective.

How does the Tool benefit ReMA members?
ReMA members can point stakeholders to the Tool when they have questions about whether their package will be recycled. It allows the industry to assess fiber-based packaging compatibility with the recycling system based the packaging’s design, and on the overall MRF and mill infrastructure in the US, instead of testing at just one or two facilities.

Who was involved in the creation of the Tool?
Like the ReMA Specifications, this Tool was designed using ReMA member expertise across all aspects of the entire recycling infrastructure cycle, in addition to relying on the MRF research conducted by Bill Moore & Associates. Non-ReMA member advisors were consulted throughout the process. To achieve the important goal of transparency, ReMA has met, and will continue to meet, with any stakeholders that wish to know more about the Tool. Using nonmember advisors also helped achieve this important goal.

How does the Tool relate to Design for Recycling®?
The design of the packaging is the first step of the Tool’s purpose which is to help reduce confusion on the part of packaging and product manufacturers, and consumers, regarding the types of fiber-based packaging that can or cannot be recycled, given pressure points in the current recycling system. Using the principles of ReMA’s Design for Recycling® will increase the likelihood for fiber-based packaging to flow through the current recycling infrastructure.

Does the Tool assess recycled content or compostability?
The Tool does not assess recycled content, nor compostability. For packaging to be recycled in the U.S., the following criteria need to be met:

• The packaging meets the U.S. Federal Trade Commission (FTC) requirements for recyclable claims.
• The packaging is likely to be successfully sorted into a market-ready bale of like material at a materials recovery facility (MRF).
• The material can be cost effectively processed at a paper mill into suitable feedstock for production of new products.

The Tool assesses packaging, unfilled and separated from the product, after-use by consumers. If the packaging is not likely to flow through the current U.S. recycling infrastructure and be made into a new product, written feedback on how the packaging could be improved is provided to the applicant. This feedback will help in the future design of that packaging.

How often will the Tool be updated?
The ReMA working group continues to monitor the current U.S. recycling infrastructure and will provide updates accordingly.

What if I want to assess the recycling readiness of packaging that is not fiber-based?
The Recycling Partnership offers the Circular Packaging Assessment Tool which provides guidance on other packaging materials. If the material is plastic, one can also consult t The Association of Plastic Recyclers | APR Design® Guide (plasticsrecycling.org). How2Recycle, Home Page – How2Recycle, is another resource that assesses recycling readiness of other packaging materials.

What is the relationship between this Tool and The Recycling Partnership’s Circular Packaging Assessment?
ReMA and The Recycling Partnership (TRP) are actively collaborating to ensure that brands, packaging manufacturers, and other users are receiving clear and consistent guidance on fiber packaging recycling through their two complementary tools: the ReMA Fiber Recycling Readiness Tool and TRP’s Circular Packaging Assessment Tool.

TRP’s assessment tool provides an overview of all material packaging, includes digitized design guides from industry associations, and leverages the Partnership’s recycling access database to provide localized information on packaging acceptance in recycling programs. High level feedback is provided for a material’s inclusion in the ISRI Specifications and the material’s performance within eight criteria of end markets.

ReMA’s readiness tool provides more detailed review and feedback on fiber-based packaging specifically. In particular, ReMA’s tool assesses end market contaminants and their cumulative impact on the ability of the package to pass through the current U.S. recycling infrastructure. It can also be used by designers and engineers considering or testing innovative packaging formats given the level of granularity provided on individual design elements.

What else?
The Tool is based on United States recycling infrastructure. The results will not apply to how packaging would pass through the recycling system in other global markets. The Tool is based on self-reported information and is only as accurate as the information that a user inputs about the packaging’s characteristics. Users should prepare themselves with all relevant and up-to-date specifications on their packaging before getting started, to ensure an accurate result.

Ownership. ReMA is the sole owner of the Tool, and any creative derivative works thereof. By reviewing and submitting comments in response to this public notice, all commentators agree not to modify or duplicate the Tool in any way. All rights are reserved.   
  
Warranties. ReMA’s Recyclability Tool is a tool and should be used as a tool. The Tool should not be relied on as the sole determinate of recyclability, and it does not exempt users from any additional applicable federal or state requirements. Because of ongoing technological advancements and the inherent limitations of the current recycling system, this Tool cannot anticipate how these advancements might impact fiber-based packaging. ReMA offers the information stated in the Tool in good faith, but without warranty of any kind, either expressed or implied, including WARRANTIES OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE, which ReMA expressly disclaims. ReMA intends to regularly update the Tool to reflect new advancements and best practices in fiber-based packaging.  
  

Miscellaneous. ReMA will consider all relevant matters presented during any public comment periods and will respond in some form to all comments received. ReMA reserves the right to modify comment periods and to choose which comments are incorporated into the final version of this Tool, if any.

The identities of all commentators and their respective comments, and the identities of all users of the Tool and their individual data will be kept confidential by ReMA, to the extent permitted by law. ReMA may use data generated by the tool that has been anonymized and aggregated.

The Fiber Recycling Readiness Tool, the information in the Tool, and any feedback provided to the user of the Tool, does not constitute legal advice.

For general questions about the terms, please contact hlyons@recycledmaterials.org

1. REFERENCES

ReMA “Learning from the MRF Survey”, February 2020 

ReMA Design for Recycling® 

AF&PA Mill Survey “Design Guidance for Recyclability – Paper-Based Packaging”, 2021

SPC (Sustainable Packaging Coalition) “2020-2021 Centralized Study on Availability of Recycling”

Walmart – Recycling Playbook, October 2019

WRAP Design Tips for Recycling, Fall 2019

CEPI Paper-Based Packaging Recyclability Guidelines, November 2019

1. FEDERAL TRADE COMMISSION GREEN GUIDES

The FTC’s guidelines for environmental marketing claims are as follows: 

260.6 Certifications and Seals of Approval 

(a)   It is deceptive to misrepresent, directly or by implication, that a product, packaging, or service has been endorsed or certified by an independent third party. 

(b)   A marketer’s use of the name, logo, or seal of approval of a third-party certifier or organization may be an endorsement, which should meet the criteria for endorsements provided in the FTC’s Endorsement Guides, 16 CFR part 255, including Definitions (§ 255.0), General Considerations (§ 255.1), Expert Endorsements (§ 255.3), Endorsements by Organizations (§ 255.4), and Disclosure of Material Connections (§ 255.5). 

(c)  Third-party certification does not eliminate a marketer’s obligation to ensure that it has substantiation for all claims reasonably communicated by the certification. 

(d)   A marketer’s use of an environmental certification or seal of approval likely conveys that the product offers a general environmental benefit (see § 260.4) if the certification or seal does not convey the basis for the certification or seal, either through the name or some other means. Because it is highly unlikely that marketers can substantiate general environmental benefit claims, marketers should not use environmental certifications or seals that do not convey the basis for the certification. 

(e)   Marketers can qualify general environmental benefit claims conveyed by environmental certifications and seals of approval to prevent deception about the nature of the environmental benefit being asserted. To avoid deception, marketers should use clear and prominent qualifying language that clearly conveys that the certification or seal refers only to specific and limited benefits. 

Examples can be found at the following link: 

https://www.govregs.com/regulations/expand/title16_chapterI_part260_section260.6#regulation_5 

260.12 Recyclable Claims 

(a)    It is deceptive to misrepresent, directly or by implication, that a product or package is recyclable. A product or package should not be marketed as recyclable unless it can be collected, separated, or otherwise recovered from the waste stream through an established recycling program for reuse or use in manufacturing or assembling another item.  

(b)   Marketers should clearly and prominently qualify recyclable claims to the extent necessary to avoid deception about the availability of recycling programs and collection sites to consumers.  

(1)   When recycling facilities are available to a substantial majority of consumers or communities where the item is sold, marketers can make unqualified recyclable claims. The term “substantial majority,” as used in this context, means at least 60 percent.  

(2)   When recycling facilities are available to less than a substantial majority of consumers or communities where the item is sold, marketers should qualify all recyclable claims.  

• Marketers may always qualify recyclable claims by stating the percentage of consumers or communities that have access to facilities that recycle the item.  
• Alternatively, marketers may use qualifications that vary in strength depending on facility availability. The lower the level of access to an appropriate facility is, the more strongly the marketer should emphasize the limited availability of recycling for the product. For example, if recycling facilities are available to slightly less than a substantial majority of consumers or communities where the item is sold, a marketer may qualify a recyclable claim by stating: “This product [package] may not be recyclable in your area,” or “Recycling facilities for this product [package] may not exist in your area.”  
• If recycling facilities are available only to a few consumers, marketers should use stronger clarifications. For example, a marketer in this situation may qualify its recyclable claim by stating: “This product [package] is recyclable only in the few communities that have appropriate recycling facilities.”  

(c)   Marketers can make unqualified recyclable claims for a product or package if the entire product or package, excluding minor incidental components, is recyclable. For items that are partially made of recyclable components, marketers should clearly and prominently qualify the recyclable claim to avoid deception about which portions are recyclable.  

(d)   If any component significantly limits the ability to recycle the item, any recyclable claim would be deceptive. An item that is made from recyclable material, but, because of its shape, size, or some other attribute, is not accepted in recycling programs, should not be marketed as recyclable.