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Date: September 15, 2025
RE: Bill 83 — Plastic & Polystyrene Waste Reduction Ordinance
Aloha Chair Villegas, Vice Chair Kagiwada, and Members of the Council,
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Zero Waste Hawaii Island supports Bill 83 with amendments that strengthen the role of
reuse. This policy has the potential to directly support the success of the Hilo Reusable
Foodware Program —a unique opportunity where Hilo will become a leader in demonstrating
the feasibility of reuse systems operating at scale. The program will establish the necessary
washing, collection, and redistribution infrastructure —creating a holistic system that enables
true system -level change and generates local green jobs. If amended to reflect reuse as a
priority solution, this ordinance could help ensure the program's long-term success, lower costs
for businesses, and make reuse a cornerstone of the County's waste reduction strategy.
We encourage the Council to view solutions as Good, Better, and Best:
• Good— Compostingand Recycling: Useful startingpoints in situations where reduction
and reuse are not yet feasible. These approaches still create waste streams and rely on
limited infrastructure, buttheyprovide a pathway for diversion and can reduce landfill
impacts. For example, countywide requirement for compostable foodware would
streamline implementation of zero waste events by reducing the volume of non-
compostable materials, making sorting less labor-intensive, and lowering
contamination.
• Better —Reuse: Prevents waste at the source, lowers costs over time, and creates local
green jobs. With H ilo's new reuse program launching, this is the solution that should be
prioritized wherever services are available —and expanded to new locations over time.
• Best— Reduction: The most impactful solution, eliminating unnecessary consumption
altogether and advancing true zero waste.
Currently, Hawai'i County has no commercial composting facilities permitted to process
foodware, meaning most compostables end up in the landfill. By contrast, the County —in
partnership with ZWHI, Hawaii Sea Grant, and Perpetual —is about to launch a reusable
foodware system in Hilo that will include return bins and collection points across town to
streamline returns. Strengthening the role of reuse in Bill 83 is a chance to craft policy that
truly empowers the Hilo Reusable Foodware System —expanding participation, reducing
per -unit costs for local businesses, creating local green jobs, and helping the program
become economically self-sufficient.
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Recommendations for Strengthening Bill 83
1. Strengthen the definition of "reusable."
The current definition is too broad and risks creating loopholes. Reuse only reduces
waste when containers are part of a fu nctioni ng system that ensures they are returned,
sanitized, and used enough times to offset their higher production footprint. Without
this, "reusable" items may still be discarded after one use —undermining the bill's
intent.
Example language for improved definition:
"Reusable means designed and manufactured for multiple uses and intended to be
returned, sanitized, and reused as part of a system for reuse, where foodware or
serviceware are circulated for the same original purpose."
2. Clarify Section 20-05-02 to explicitly include "reusable."
Although "reusable" appears in the section title, it is not referenced in the operative
text. We recommend revising the section to read:
"Any food providers and County facility user selling, distributing, or otherwise providing
food to the public in disposable foodware or with disposable serviceware shall do so
usingfoodware or serviceware that is CMA-certified or visibly labelled as compostable
with a BPI certification mark, or reusable."
Including "reusable" here is critical, but only alongside a strengthened definition to
avoid loopholes (e.g., thicker single -use items being labeled "reusable").
3. Define "food provider" more clearly.
The phrase "a person, business, or other establishment that sells or provides prepared
food to the public" leaves room for interpretation. For clarity, consider language such
as:
"Food provider means any person, business, institution, or other entity that sells or
otherwise distributes prepared food to consumers, including but not limited to
restaurants, cafes, food trucks, caterers, grocery store delis, schools, and hospitals."
Clearer definitions help avoid uncertainty around schools, hospitals, caterers, and
community events.
4. Enforcement priorities based on infrastructure.
Enforcement should focus on whichever solution —reuse or compostables—has real
collection and processing systems in place. For example, reuse should be prioritized in
Hilo once the new program launches, while compostables could be considered in
regions where permitted facilities exist.
Proposed language:
"Enforcement shall give priority to foodware and serviceware solutions for which
complete collection and processing systems are available in the region, including reuse
services and commercial composting facilities capable of processing the material
provided. Where multiple solutions are operational, the choice of solution may be
determined at the discretion of the Director. In regions without available infrastructure,
enforcement shall focus on feasible compliance measures that best align with the intent
of this ordinance."
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Conclusion
Bill 83 represents a timely and powerful opportunity. With strengthened language on reuse,
the County can align with true zero waste principles, support the launch of the Hilo program,
and ensure that reuse thrives as a model for the island and beyond.
Mahalo nui for your leadership on this important matter, and for considering these
amendments.
Respectfully submitted,
Jennifer Navarra
Program Director
Zero Waste Hawaii Island
THE ZERO WASTE HIERARCHY 8.0
RETHINK/REDESIGN
REDUCE
REUSE
RECYCLE/COMPOST
MATERIAL RECOVERY
RESIDUALS MANAGEMENT
(Biological treatment and stabilized landfllling)
UNACCEPTABLE -
(Incineration and'waste-to-energy")
For detailed version visit www.zwia.org&wh
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Zero Waste International Alliance - https-.//zwia.orglzwh/