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<br />Phone: +1 651-288-3431 <br /> <br /> <br /> <br /> <br />(A.) <br />product; <br />(B.) If subparagraph (A) does not apply, a person who is not the manufacturer of a covered <br />product under the manufacturers own brand, but is the owner or licensee of a trademark <br />under which a covered product is used in a commercial enterprise, sold, offered for sale or <br />distributed in the State, whether or not the trademark is registered; or <br />(C.) If subparagraphs (A) and (B) do not apply, a person who imports the product that uses the <br />covered product into the State for use in a commercial enterprise, sale, offer for sale or <br />distribution in the state. <br />3. Recyclable Definition (p. 10) The current definition is broad and open to interpretation based on <br />several factors, including market conditions. We believe a better approach is to allow the Producer <br />Responsibility Organization (PRO) to establish recyclable criteria and standards to be submitted to and <br />approved by the Department . <br /> <br />4. Department Program Costs and Producer Payments (pg. 15-16) The amount of the annual <br /> annual program costs should be established and capped <br />in the legislation. <br /> <br />5. Reuse and Recycling Performance Requirements (pg. 22-23) Current language grants the <br />Department authority to change and set new performance requirements. The responsibility to change <br />performance requirements as needed should instead be the responsibility of the PRO, in cooperation <br />with the Department and advisory committee. <br /> <br />6. Needs Assessment: AMERIPEN has articulated, in our principles, that a needs assessment to <br />determine the total budget needed for an EPR program and to develop infrastructure is needed before a <br />stewardship plan is implemented. A needs assessment should be included in this legislation and the <br />effective date should be delayed one year to allow for the development of this needs assessment. <br /># # # <br /> <br />AMERIPEN recognizes the need to improve the recycling system in Hawaii and beyond and we remain <br />committed to being a partner to find the right path forward. We hope that the information provided <br />above provides useful ways to start the conversations to make this legislation more feasible and that will <br />lead to an improved recycling system in Hawaii, bringing more packaging to a place of circularity. We <br />believe that improving the recycling system is and always will be a shared responsibility. Therefore, we <br />hope that our comments are helpful in creating a pathway to developing a truly workable program <br />under this legislation. <br /> <br />We look forward to a continued dialogue with you and hope to work on <br />pragmatic suggestions as this legislation is considered and could be amended in the future. <br />Page 2 of 2 Opposition Hawaii House Bill 1316 February 9, 2021 <br /> <br />