Pressure Points
Ensuring sustainable
consumption of aerosol containers
There are ongoing discussions throughout the world about
our waste problems. As countries and regions try to come
up with different solutions, they all have the same goal of
decreasing the amount of waste and improving sustainability.
Government agencies and key stakeholders want to establish
new strategies, identify investment opportunities for technology
and infrastructure and develop international agreements to globally
reduce waste.
From a young age, we’re taught about the 3Rs—Reduce, Reuse,
Recycle—to help minimize waste and conserve resources. All
industries, including the aerosol industry, must continually look
at products, packaging and best practices to help contribute positively
to society and minimize our impact on the environment.
One way to reduce waste is to not create it in the first place.
Industries are looking at packaging as an area for potential innovation
in order to continue to deliver safe products while also
reducing the amount of packaging materials. Globally, the aerosol
industry has innovated to reduce the amount of metal needed for
its containers. However, in the U.S., the aerosol industry is subject
to requirements that limit the ability to reduce the amount of
metal needed for a finished container.
Reusing products is another way to effectively limit waste, but
the aerosol delivery form is currently designed as a single-use package.
The potential redesign of an aerosol product for reusability has
been discussed, e.g. how the refilling could be done and done safely
and whether such a refillable design is actually more sustainable.
For aerosol products, recycling is currently the most optimal
way to minimize the impact of the product’s packaging on the
environment. Recycling requires cooperation by both consumers
and workers to dispose of empty aerosol products properly.
Most aerosol containers are made with steel or aluminum.
Both materials are readily recyclable when empty and have value
within the recycling stream, as research1 shows that approximately
70% of U.S. consumers have the ability to recycle these products.
However, there continues to be a disconnect with many consumers
and workers that empty aerosol products are recyclable, in part
because 30% of U.S. consumers don’t have access to empty aerosol
product recycling.
There are inconsistencies between municipalities about what
products can and cannot be recycled (including aerosol containers)
that have led to a number of challenges. This provides an
opportunity for a more uniform solution, and fortunately, the
U.S. Environmental Protection Agency (EPA) is in the process
of developing a National Recycling Strategy2. This program will
focus on reducing the contamination in the recycling stream,
improving processing efficiency and improving domestic markets
so that recycled materials can remain in the U.S. to be reused in
future products.
The Household & Commercial Products Association (HCPA)
provided comments to the EPA on its draft National Recycling
Strategy. HCPA stressed the need for a harmonized national
recycling system, without restricting the implementation of future
technological developments, as well as clear and consistent messaging
to consumers about what materials can and cannot be
recycled.
HCPA also signed the America Recycles Pledge3, which is a commitment
to work together with the EPA and other signatories to
build on existing efforts to address the challenges facing the nation’s
recycling system and to identify solutions that create a more
resilient materials economy and protect the environment.
There’s also activity within several States, as they can often
move faster than the Federal government. Multiple industries
have voluntarily moved forward with the development of stewardship
programs to address the disposal of their products; however,
several States are looking at potential Extended Producer Responsibility
(EPR) legislation to share the responsibility for end-of-life
product management with industry. Multiple States have also
convened recycling committees to strengthen recycling streams.
However, States don’t always look at recycling processes in the
ways that industry would like, which may result in certain States
making different decisions on what is considered recyclable and
potentially creating more confusion by adding to the patchwork
of acceptable materials for recycling.
Ultimately, the goal is for every aerosol container to be recycled
the same way as any other metal container. Not only are steel and
aluminum valuable in the recycling stream, but recycling these
metals saves energy and natural resources, thus reducing waste in
more ways than one.
With an increase in government and public stakeholder activity
focused on waste disposal, HCPA is partnering with the Can
Manufacturers Institute (CMI) and Pet Food Institute (PFI) for
the initial phase of a new recycling project. This project isn’t
focused on the consumer side of recycling, but on the municipality
side; we’ll be interviewing material recovery facilities (MRFs)
and end-market processors who recycle scrap metal in order to
learn what the aerosol industry can do to increase its acceptance
and improve its processing of empty aerosol products (and pet
food containers). Ultimately, we need to be able to answer the
following questions: Why doesn’t every U.S. consumer have the ability
to recycle their empty aerosol products and what can we do to make that
a reality?
The aerosol industry conducted a study that assessed the risk
of aerosol products within the recycling stream4, but that research
is now almost 25 years old. However, the lessons from this study
are still applicable. For example, the likelihood of a significant
accident is very low. Still, the technology and procedures at MRFs
have since been updated and the requirements of those that
purchase scrap metal and recycle it into new materials have, in
some cases, been significantly altered. The aerosol industry needs
to ensure that it’s operating on the most up-to-date information in
order to move forward.
There are still many questions that we don’t have answers to.
For example, once the MRF has the container, are we sure it pro-
10 Spray December 2020
NICHOLAS GEORGES
HCPA VP of Scientific
& International Affairs
ngeorges@thehcpa.org
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