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Chemistry, Materials & Packaging
US Plastics Pact Unveils List of 11 ‘Problematic and Unnecessary’ Materials to Be Eliminated by 2025

The US Pact’s brands, retailers and materials manufacturers are seek to develop immediate solutions to the 11 ubiquitous and unrecyclable materials — but the plastics industry is up in arms.

Today, the US Plastics Pact released its Problematic and Unnecessary Materials List — a first step to accelerate progress toward a circular economy for plastic packaging in the United States. The list identifies 11 materials that are not currently reusable, recyclable or compostable at scale in the US and are not projected to be kept in a closed loop in practice and at scale by 2025.

The publication of the list fulfills a commitment by the US Pact to “define a list of packaging that is problematic or unnecessary by 2021,” an objective in the coalition’s Roadmap to 2025. The list was developed by US Pact members — more than 100 businesses, non-profit, and government organizations. These “Activators” will develop guidance on circular alternatives to eliminate the items on the list by 2025.

The US Pact’s CPG, retailer and converter Activator companies produce 33 percent of plastic packaging in scope in the US by weight. In 2020, before the establishment of the list, 66 percent of business Activators were already making individual plans and taking steps to wholly eliminate specific materials, formats and components, or move from non-recyclable to recyclable package designs.

The US Pact’s Problematic and Unnecessary Materials List is comprised of the following items:

  • Cutlery*

  • Intentionally added¹ Per- and Polyfluoroalkyl Substances (PFAS)²

  • Non-detectable pigments such as Carbon Black)

  • Opaque or pigmented PET bottles (any color other than transparent blue or green)

  • Oxo-degradable additives, including oxo-biodegradable additives

  • PETG – Polyethylene Terephthalate Glycol in rigid packaging

  • Problematic Label Constructions – including adhesives, inks, materials (e.g., PETG, PVC, PLA, paper). Avoid formats/materials/features that render a package Detrimental or Non-Recyclable per the APR Design® Guide. Labels should meet APR Preferred guidance for coverage and compatibility and be tested in any areas where this is unclear.

  • Polystyrene – including EPS (Expanded Polystyrene)

  • PVC – Polyvinyl Chloride, including PVDC (Polyvinylidene Chloride)

  • Stirrers*

  • Straws*

The list applies exclusively to plastic packaging. Medical plastics used in clinical, hospital, and related laboratory and research settings are not included. Definitions used in the criteria derive from the Ellen MacArthur Foundation’s New Plastics Economy Global commitment criteria, which provides the framework for the US Pact. Participation in the US Pact is voluntary and does not necessarily signify an individual Activator’s endorsement of the list.

“We thank our Activators for their commitment to working together to deliver on the US Pact’s targets,” said, Emily Tipaldo, US Pact Executive Director. “The elimination of these problematic and unnecessary materials will enable advancements in circular package design, increase opportunities for recovery, and enhance the quality of recycled content available for manufacturers.”

“Recycling will only work if we stop pumping contaminants and unrecyclable materials into the system,” said Dr. Anja Malawi Brandon, US Plastics Policy Analyst at Ocean Conservancy. “And among other measures, we need recycling to work if we want to keep plastics out of our ocean. Our research shows that a majority of the trash found on beaches and waterways around the world every year during Ocean Conservancy’s International Coastal Cleanup is effectively unrecyclable. Phasing out these 11 materials will go a long way in cleaning up the recycling stream and our coastlines.”

Materials on the Problematic and Unnecessary Materials List do not meet the US Pact definition of reusable, recyclable or compostable, known as “Criterion 1” — the criterion deemed most critical by US Pact Activators.

Materials on the list also met one or more of the following concerns:

Criterion 2: Contain hazardous chemicals or create hazardous conditions that pose a significant risk to human health or the environment (applying the precautionary principle) during its manufacturing, recycling (whether mechanical or chemical) or composting process;

Criterion 3: Can be avoided (or replaced by a reuse model) while maintaining utility;

Criterion 4: Hinder or disrupt the recyclability or compostability of other items; and/or

Criterion 5: Have a high likelihood of being littered or ending up in the natural environment.

Unsurprisingly, not everyone is on board — the plastics industry is a bit taken aback by the Materials List and is asking the US Pact to work together on solutions, rather than banning these materials outright.

"Unfortunately, the US Plastics Pact lacked a transparent, third-party, data-driven and scientific approach; and its process seems to be rooted in ideology and a predetermined, misguided outcome,” says Joshua Baca, VP of Plastics at the American Chemistry Council. “In fact, the list of plastic materials they suggest be eliminated by 2025 will only hinder the acceleration of a circular economy, slow progress toward a lower carbon future, and reduce our ability to use greater amounts of recycled material in plastic packaging.

"Amid a global supply chain and inflation crisis, the recommendations put forth by the US Plastics Pact will worsen setbacks at a time when consumers are looking for certainty, not further disruption, of global supply chains. Additionally, the Pact’s recommendations are likely to increase food waste, promote the use of many materials with a higher carbon footprint than plastics, and do little to achieve the plastics value chain’s ambitious sustainability goals.

“Our hope is that the Pact will partner with us to leverage our industry’s expertise and the extensive work we've done to achieve a more circular economy for all materials by scaling the growth of innovative recycling technologies — rather than to promote de facto bans on certain types of plastic packaging. ACC and its member companies remain committed partners in sustainability and will continue the hard work needed to achieve circularity across the plastics value chain with concrete and measurable actions."

Meanwhile, the US Pact says it will continue to investigate additional items for potential elimination.


*When non-reusable, non-recyclable, or non-compostable per US Pact definitions and provided as an ancillary item to the primary container. For instance, a packet of plastic cutlery provided with a prepared salad or a straw/stirrer provided with an on-the-go beverage would be defined as problematic whereas cutlery, straws, or stirrers sold as a product would not.

¹ “Intentionally added” either in the package or in the manufacturing of that package.

² Perfluoroalkyl and polyfluoroalkyl substances (PFAS) are defined as the class of fluorinated organic chemicals containing at least one fully fluorinated carbon atom at or above 100 parts per million, as measured in total organic fluorine.

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