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Home My WebLink AboutCOM 0482.075 2024-2026rpr3 PERPETUAL September 11, 2025 c7 C) , Subject: Comments on Bill 083: An Ordinance Amending Chapter 20 Of The Hawai'i County Code,'(1983�E,_ 2016 Edition, As Amended), Relating To Plastic And Polystyrene Waste �z `� o Aloha County Council Members, Tic Mahalo for your efforts to address plastic waste and pollution and for the opportunity to provide commenron Bill083. Perpetual is a non-profit that provides technical expertise to enable the creation of reusable foodware systems that provide a great user experience, are affordable and convenient for businesses, and are designed through an inclusive process with the community to be economically viable, healthy and safe, integrated with city planning, and environmentally superior to disposables. I co-founded Perpetual having spent 17 years working on sustainability projects across business, government, and civil society, and 8 of those years working specifically on solutions to address plastic waste. I am including a list of my publications for your additional reference. Perpetual is currently partnering with Zero Waste Hawai'i Island, Hawai'i Sea Grant, and the County of Hawai'i to implement a reusable foodware system in Hilo, HI. This work, which has been underway for nearly three years, has demonstrated the strong community and business interest in reducing waste on the island and the need for viable alternatives to disposable packaging. This is a $3.8M project, and it is establishing the infrastructure to enable convenient, efficient, safe reuse: a fully -equipped commercial washing facility, —225 collection points, two collection vehicles, durable transport packaging for moving clean and dirty items, and an inventory of stainless steel foodware items including containers, cups, and school trays. While Perpetual does not take a position on this bill, we appreciate the opportunity to share our subject matter expertise as well as insights from other jurisdictions where reuse and plastic reduction measures have been implemented to help inform local decision -making. 1. Alignment of Policy with Available Infrastructure. The effectiveness of single -use plastic reduction ordinances depends on aligning policy requirements with locally available infrastructure. Where reuse systems are in place, supportive policy has led to a significant increase in reuse adoption. For example, in Tubingen, Germany, a local tax on single -use packaging resulted in a fourfold rise in the number of businesses offering reusable options. A local tax is just one example of a policy incentive and is not being specifically recommended here. Behavioral science research shows that consumers tend to follow the default option. Making reuse the default can drive higher adoption rates and support both the economic and environmental benefits of reuse at scale. At the same time, maintaining compostables as an option preserves consumer choice in situations where reusables are not feasible. By contrast, mandating compostable foodware on Hawai'i Island —where no appropriate local composting facility exists —would result in the same outcome as single -use plastic packaging: landfilling. For context, all waste from Hilo, including foodware, is currently hauled more than 70 miles to Pu'uanahulu at an annual cost of over $14 million. 2. Clear and Consistent Definitions Comm. Ref. To: Ref. Date P 1 025 Experience in other jurisdictions also suggests that clear definitions play a critical role. For example, after New Jersey's bag ban was implemented with a broad definition of "reusable," many retailers shifted to thicker plastic bags labeled as reusable that were often discarded after only one or a few uses, directly resulting in nearly tripling plastic consumption. To avoid such unintended outcomes, effective policies elsewhere have emphasized definitions that require reuse as part of a system — meaning foodware must be designed, collected, sanitized, and redistributed for multiple rotations. International standards, such as ISO 18601, the EU's Packaging and Packaging Waste Regulation, and the Ellen MacArthur Foundation's glossary, consistently define "reuse" as the use of an item for the same intended purpose multiple times. These definitions are included at the end of this document for easy reference. Mahalo for your consideration. We hope these insights are useful as you deliberate on this matter. Sincerely, Ellie Moss Co -Executive Director Perpetual Attachment 1: List of my relevant publications • Lead author of Sea of Opportunity: Supply Chain Investment Opportunities to Address Marine Plastic Pollution. Published by Encourage Capital in partnership with Vulcan. • Expert Advisor on Breaking the Plastic Wave: A Comprehensive Assessment of Pathways Towards Stopping Ocean Plastic Pollution as well as an advisor on the upcoming Breaking the Plastic Wave 2 to be published in December 2025. Published by The Pew Charitable Trusts in partnership with Systemiq. • Co -lead author of Leveraging Multi -Target Strategies to Address Plastic Pollution in the Context of an Already Stressed Ocean, one of the Blue Papers published by the High Level Panel for a Sustainable Ocean Economy, facilitated by the World Resources Institute (WRI). • Lead author of The Dirty Truth About Disposable Foodware, a quantitative and qualitative analysis of disposable foodware use in the U.S. and a report sharing the findings and highlighting solutions, in particular reuse systems. Published by The Overbrook Foundation. • Lead author of Reducing Plastic Pollution: Campaigns That Work - Insights and examples to maximize the effectiveness of campaigns for sustainable elastic consumption. Published by The Stockholm Environmental Institute (SEI) and The One Planet Network. • Lead author of "Can I Recycle This?" A Global Mapping and Assessment of Standards. Labels. and Claims on Plastic Packaging, mapping the current landscape of consumer information, and highlighting good practices and areas where action should be taken. Published by Consumers International & the UN Environment Programme. Attachment 2: Widely Accepted Definitions of Reuse from Reputable Organizations Source Definition NewERA for INC-4 Any process or operation in which an item (e.g. packaging) is used again for the same purpose for which it was originally designed. Ellen MacArthur Foundation's The repeated use of a product or component for its intended purpose Circular Economy Glossary without significant modification. ISO 18601:2013 Packaging and Operation by which packaging is refilled or used for the same purpose for the environment which it was conceived, with or without the support of auxiliary products present on the market enabling the packaging to be refilled. Packaging and Packaging Any operation by which reusable packaging is used again multiple times for Waste Regulation (PPWR) (EU) the same purpose for which it was conceived. US Plastics Pact Operation by which packaging is refilled or used for the same purpose for which it was conceived, with or without the support of auxiliary products (1) present on the market, enabling the packaging to be refilled. Source: ISO 18603:2013, Packaging and the environment — Reuse, modified (clarification in note 1 below). Note 1. An auxiliary product is a product used to support the refilling/loading of reusable packaging. (... ) An example of an auxiliary product is a detergent pouch used to refill a reusable container at home (ISO 18603). As per ISO 18603, auxiliary products that are one-way products (i.e., designed to be used once) are not.considered reusable packaging. • Further explanatory notes: o Attention should be paid to the intended use and function of the packaging to verify whether it is being reused for the same purpose or a secondary use. In the latter case, the packaging is not considered as reusable packaging (ISO 18603, 'Packaging used for the same purpose'). For example, the use of a package as a penholder or as decoration cannot be qualified as reuse. o A package is considered reusable if the design of the packaging enables the principal components to accomplish a number of trips or rotations in normally predictable conditions of use (ISO 18603). According to ISO 18601, a packaging component is a part of packaging that can be separated by hand or by using simple physical means (for example a cap, a lid, a (non inmold) label).