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brand in Hawaii, packaging producers have no way of knowing whether the final product (that <br />uses the packaging) will be sold in or out of the state. <br /> <br />FPA is also concerned that HB1316 gives very broad authority to the Department to determine <br />definitions, such as recyclability, compostability and resues, which should be definted through <br />national standards, such as FTC and ASTEM. In addition, the dates for implementation and plan <br />amendments/resubmissions are far too aggressive, particularly for the first ever of its kind EPR <br />program in the Country. Finally, there are NO antitrust protections for the supply chain <br />implementing this new system, including fees on packaging to support the plan and impliement <br />the program. This and the the extremely stringent penalties, including joint and several liability <br />for producers, is wholly inappropriate and defeats the purpose of having a constructive and <br />successful PRO representing various CPG competitors. <br /> <br />For these reasons, FPA opposes the current draft of HB1316,GFF but stands ready to assist in <br />amending the bill so that it comports with the PSI/FPA elements and supports a meaningful EPR <br />program for packaging; providing the necessary investment in new infrastructure and markets for <br />all packaging, including flexible packaging. In advance, thank you for your consideration. If we <br />can provide further information or answer any questions, please do not hesitate to contact me at <br />410-694-0800 or akeane@flexpack.org <br /> <br />