The South African Plastics Recycling Organisation (SAPRO), as the representative voice of the plastic recycling industry, addresses the concerns raised by PlasticsSA relating to the On-Pack Recycling Labels (OPRLs) and their criticism of the 30% threshold for recyclability. While we respect PlasticsSA’s role in advocating for the interests of virgin plastic producers, we must challenge the premise of their arguments and provide a comprehensive perspective grounded in the realities of the law, the recycling industry, and sustainability imperatives.

Introduction
The position advanced by PlasticsSA, namely that ‘If it’s plastic, rinse it and recycle it,’ while simplistic, undermines the nuanced challenges faced by the recycling industry. SAPRO asserts that the 30% threshold is not only necessary but pivotal to ensuring that recyclability claims align with the practical realities of waste management and the broader environmental objectives outlined in South Africa’s Extended Producer Responsibility (EPR) regulations.

We highlight four primary areas of concern with PlasticsSA’s position:

• Possible non-compliance with legislation
• Economic burdens on the recycling sector
• Erosion of consumer trust in OPRLs
• Negative impacts on innovation and environmental accountability

Legal compliance and the EPR Framework
South Africa’s National Environmental Management: Waste Act (NEMWA) and associated EPR regulations specifically mandate accurate and verifiable environmental claims, with a focus on preventing misleading or deceptive representations. International Standards Organisation (ISO) 14021, incorporated into the South African Bureau of Standards (SABS) framework and included as part of the EPR legislation, defines recyclability as contingent upon the actual collection, processing, and repurposing of materials.

The SAPRO 30% threshold aligns with international best practices that establish clear benchmarks for recyclability. These benchmarks ensure that recyclability claims are substantiated by tangible outcomes, thereby minimising the risk of regulatory non-compliance and subsequent legal repercussions for brand owners and producers.

The planned UN Plastics Treaty to end Plastic Pollution is expected to standardise the definition of ‘Recyclable’ globally and align with stricter criteria for what can be considered truly recyclable. As a participating nation, South Africa should align rather than undermine this kind of progress.

Economic burdens on the recycling sector
PlasticsSA’s call to classify all plastics as recyclable disregards the operational realities faced by recyclers. Packaging and other items labelled as recyclable, but lacking practical recyclability, introduce significant costs into the value chain, including:

• Sorting and contamination costs: Non-recyclable materials increase the financial burden on Material Recovery Facilities (MRFs) and recyclables collectors, as these items require additional sorting and disposal costs.
• Transportation inefficiencies: The movement of non-recyclable waste through the recycling stream inflates logistics costs and undermines economic sustainability.
• Quality issues: Contamination of recyclables with non-recyclable material leads to lower quality resin produced by recyclers and loss of market opportunities.

Recyclers in South Africa already face production loss rates of up to 40%, partly due to contamination and the inclusion of non-recyclable items. This inefficiency not only threatens the viability of recycling businesses but also jeopardises the broader sustainability goals of the industry.

Consumer trust and credibility of OPRLs
On-Pack Recycling Labels are a critical tool for educating consumers and guiding waste management behaviours. However, their efficacy hinges on credibility. The incorrect labelling of non-recyclable plastics as recyclable undermines consumer confidence in OPRLs and, by extension, the recycling system as a whole.

Consumers are increasingly discerning and will react negatively to perceived greenwashing. When consumers discover that items labelled as recyclable are not being recycled, they are likely to lose trust not only in the label but also in the broader claims of sustainability made by the plastics industry. Maintaining stringent criteria, such as the 30% threshold, is essential to preserving the integrity of OPRLs and sustaining public trust in recycling efforts. An item to encourage behavioural change throughout the value chain.

Driving innovation and accountability
The call to lower the bar for recyclability standards risks stifling innovation in packaging design and material development. SAPRO supports the principle of ‘Design for Recycling’ (D4R), which incentivises brand owners to create packaging that aligns with the capabilities and requirements of our existing recycling industry.

By maintaining the 30% threshold, South Africa can drive meaningful improvements in packaging design, ensuring that materials are not only technically recyclable but also practically and economically viable to recycle. This approach supports the long-term sustainability of the plastics industry by fostering innovation and enhancing the environmental performance of packaging solutions.

Rebuttal to specific claims by PlasticsSA

Claim: The 30% threshold is impractical due to insufficient data

SAPRO’s response: SAPRO unsuccessfully engaged PlasticsSA to partner on data collection for their annual recycling survey. While data collection remains a challenge, the threshold provides a clear and measurable benchmark for recyclability. Establishing such a benchmark incentivises the collection of accurate data and drives the development of systems to monitor and improve recycling rates.

Claim: Advising against recycling items below the 30% threshold undermines the recycling industry

SAPRO’s response: Allowing non-recyclable materials into the recycling stream increases costs and undermines the sector’s economic viability. Clear guidelines based on the 30% threshold help streamline operations and ensure resources are directed toward genuinely recyclable materials. SAPRO provides provisions for products with strong EPR schemes, where collection is critical for increasing the recycling rate from below 30% to within scope. In such cases, where demand has been created and supply is the bottleneck, brand owners are encouraged to use the OPRL to catch up.

Claim: The message to consumers should be to recycle all clean mono-material plastics

SAPRO’s response: Simplistic messaging oversimplifies the complexities of recycling. Consumers are capable of understanding nuanced instructions when provided with clear, credible information. However, they are not capable of distinguishing between mono-materials and multi-materials as suggested. Correct labelling helps consumers make informed choices and reduces the prevalence of wish-cycling.

The path forward
SAPRO acknowledges the importance of collaboration across the plastics value chain to achieve shared sustainability goals. However, this collaboration must be rooted in an evidence-based and practical approach to recyclability.

We advocate for the following measures:

• Adoption of the 30% threshold: Aligning with international best practices, this benchmark ensures that recyclability claims are credible and verifiable.
• Enhanced consumer education: Comprehensive campaigns to inform consumers about the realities of recycling and the importance of adhering to OPRL guidelines.
• Strengthened regulatory oversight: Clear and enforceable standards for recyclability claims to prevent greenwashing and support fair competition.
• Investment in recycling infrastructure: Expansion of collection, sorting, and processing capacities to accommodate a broader range of recyclable materials.
• Use SAPRO guidelines: SAPRO with the support of the Nedbank Green Trust and Polyco invested heavily in SA’s first-of-its-kind online tool for determining recyclability. Brand owners are encouraged to visit https://www.designedforearth.com/ to check the recyclability of their packaging.

Conclusion
The challenges faced by the recycling industry require a balanced and forward-thinking approach. By endorsing the 30% threshold for OPRLs, South Africa can uphold the integrity of its recycling system, drive innovation and ensure compliance with EPR legislation. SAPRO remains committed to working with stakeholders across the value chain to build a sustainable future for plastics circularity in South Africa.

www.sapro.com