2021-08-25 EMC agenda item 5-b(1) - HB1316_TESTIMONY_EEP_02-09-21_

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AMERIPEN American Institute for Packaging and the Environment Opposition House Bill 1316 Hawaii House Energy and Environmental Protection Committee February 9, 2021 Chair Lowen, Vice- Chair Marten and Members of the House Energy and Environmental Protection Committee, AMERIPEN the American Institute for Packaging and the Environment appreciates the opportunity to comment on House Bill 1316 that seeks to establish an extended producer responsibility (EPR) mandate for packaging and printed material. While AMERIPEN has developed principles for financing to support the goals of improving packaging recycling and recovery, we cannot support HB 1316 in its current form. AMERIPEN is a coalition of packaging producers, users and end-of-life materials managers dedicated to improving packaging and the environment. We are the only material neutral packaging association in the United States. Our membership represents the entire packaging supply chain, including materials suppliers, packaging producers, consumer packaged goods companies and end-of-life materials managers. We focus on science and data to define and support our public policy positions and our comments are based on this rigorous research rooted in our commitment to achieve sustainable packaging and efficient recycling policies. AMERIPEN recognizes that the health of a recycling system is critical and that there is a shared responsibility that packaging producers and others can play in improving the recycling system. Following below are our key concerns and recommendations for HB 1316 that must be addressed to truly create a workable packaging producer responsibility program in Hawaii. AMERIPEN Key Concerns: 1. Packaging Definition (pg. 6) The definition of packaging creates a critical standard for the implementation of the program. Currently, the definition appears to include tertiary (or business to business) packaging and secondary packaging. The definition should only encompass packaging that is consumer facing: Materials used for the containment, protection, delivery, presentation or distribution of a product at the time that the product leaves a point of sale or is received by the consumer of the product. 2. Producer Definition (pg. 8) The current definition is too broad and open to misinterpretation because it does not assign a clear hierarchy of responsibility brand owner or importers/distributors or other party. We suggest this clearer definition for producer: