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Date: October 7, 2025
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RE: Bill 83 — Plastic & Polystyrene Waste Reduction Ordinance
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Aloha Chair Villegas, Vice Chair Kagiwada, and Members of the Council,
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Testimony in Support of Strengthening Reuse Provisions in Bill 83
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This policy has the potential to directly support the success of reuse systems operating at scale
and advance the County's broader zero waste goals. Reuse is widely recognized as the most
environmentally preferable solution because it prevents waste at the source, reduces demand
for raw material extraction and manufacturing, and avoids the greenhouse gas emissions and
pollution associated with single -use production, transportation, and disposal. It also supports
local economic resilience by creating jobs in collection, washing, and redistribution —building
circular systems that keep materials in use longer and out of the landfill.
If amended to include reuse as a solution, Bill 83 could help ensure the long-term success of
legitimate reuse programs, lower costs for businesses overtime, and make reuse a cornerstone
of the County's waste reduction strategy.
Recommendations for Strengthening Bill 83
1. Include "Reusable" in the Operative Language
Although "reusable" appears in the section title, it is not explicitly referenced in the operative
text. Including it will ensure reuse is recognized as a compliant and encouraged solution,
alongside compostable options.
2. 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 functioning system that ensures they are returned, sanitized, and used
enough times to offset their higher production footprint.
Without clear guidance, other counties have seen businesses adopt thicker single -use plastics
and label them "reusable," undermining the intent of the ordinance and increasing plastic
waste. Strengthening the definition will ensure only legitimate reuse systems are supported and
enforced.
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There are currently no bio-based plastics available on the market designed for reuse, so reuse
programs should focus on durable materials such as stainless steel, glass, and high -quality,
long-lasting plastics that can withstand repeated washing and recirculation.
In some cases, plastics may still need to be considered —for example, where no viable market
alternatives currently exist, such as the need for clear, see -through containers or lids. In these
situations, plastics should be used thoughtfully and selectively, prioritizing applications where
chemical leaching concerns are minimal and, where possible, ensuring that the primary
food -contact surfaces are made from non -plastic materials.
Additional Considerations — Not All Compostable Materials Are the Same
While PLA-based compostable plastics —the most widely used and cost-effective compostable
plastic on the market —represent a step in the right direction, they do not fully address the
concerns associated with traditional plastics (Please read the Eunomia Report).
PLA can still fragment into microplastics when exposed to heat, UV light, repeated use, and if it
ends up in the environment. It also requires specific industrial composting conditions to fully
break down —conditions not currently available on -island —so it often behaves like
conventional plastic in local disposal settings.
In contrast, fiber -based compostable products can be more effectively managed locally, as
they do not require industrial composting conditions to break down.
Conclusion
Bill 83 represents a timely opportunity to strengthen the County's commitment to waste
reduction. By including reuse in the operative language and clarifying its definition to prevent
loopholes, the County can ensure that future policies truly advance zero waste goals, support
legitimate reuse systems, and avoid unintended outcomes from poorly defined terms.
There are no perfect solutions —each approach involves trade-offs. We encourage the Council
to consider the zero -waste hierarchy and prioritize solutions that deliver the greatest overall
environmental benefit, rather than focusing solely on material type. Efforts aimed at broadly
banning fossil fuel -based plastics are understandable, but they can overlook the reality that
bio-based plastics are still plastics and continue to create environmental concerns as
described above. A holistic approach —one that considers upstream and downstream
impacts —will ensure the County invests in systems that most effectively reduce waste, conserve
resources, and protect our environment.
Respectfully submitted,
Jennifer Navarra, Program Director
Zero Waste Hawaii Island
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