Ensuring Uniformity in Packaging Standards and Disposal/Recyclability

Consumer and industrial products often require special packaging to provide for adequate package integrity in transport and sale and efficient and safe use by consumers and workers. Thus, CSPA members have both an economic and a practical interest in selecting the type of packaging that best matches consumers’ needs and the characteristics of the product. Many CSPA members also incorporate environmental policy objectives, including use of recycled content in their packaging and utilizing packaging materials that may easily be recycled in existing curbside collection programs, where practical and permissible.

Attempts by states to impose requirements dictating recycled content in packaging material used for pesticide products directly contravenes federal authority under FIFRA. Moreover, many CSPA members have voiced concern about their ability to comply with overlapping requirements of both Department of Transportation (DOT) and individual states which, in some cases, may preclude use of non-virgin packaging material. Furthermore, the adoption of state-specific requirements can significantly impede nationwide distribution of consumer products. CSPA member companies have significant commercial and practical interest in preserving the integrity of federal authority to regulate household and industrial pesticide products.

CSPA actively engages in legislative advocacy efforts to ensure that members’ products, and particularly all FIFRA- and DOT-regulated products, are exempt from any state efforts to mandate recycled content in rigid plastic containers. CSPA will actively oppose any attempt to impose bans or restrictions on aerosol packaging.

CSPA is also extremely active in promoting aerosol recycling over the past 20 years. These efforts began in the 1990s with studies to demonstrate the safety and technical feasibility of including empty aerosol containers in mixed recycling programs and inclusion with other metal containers in material recovery facilities. After the technical feasibility was established for safe aerosol recycling, CSPA began to promote state and local curbside and drop-off recycling programs to not only accept and recycle aerosols, but encourage consumers to do so. CSPA has often partnered with other organizations in accomplishing these goals.

A 2016 survey on aerosol products conducted by CSPA reports that nearly 3.8 billion aerosol cans are produced in the United States alone, but the rate of recycling for those products is still relatively low compared with other consumer products. It wasn’t so long ago that aerosol cans weren’t even thought of as recyclable—by consumers and manufacturers alike—but great progress has been made.

Through the work of CSPA—whose member companies include some of the largest aerosol product manufacturers in the world—and the Consumer Aerosol Products Council (CAPCO), 68% of member company products now contain “Please Recycle When Empty” labels on their cans.

And through continued regulatory policies, public awareness promotions and consumer education—by CSPA, CAPCO, the Steel Recycling Institute (SRI) and others—over the past thirty years, more than 7,500 curbside programs and 10,000 drop-off programs accept aerosol cans for recycling. More Americans than ever have convenient access to steel aerosol can recycling.

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