Sustainability Is Here To Stay
Sustainability as a concept has been with the printing industry for quite some time, with the initial focus occurring in the mid-1990s with print customers asking the question: “Are you a ‘green’ printer?” Since the 1990s, we continue to see ebbs and flows in both the interest on the part of the print industry in sustainability, as well as the simultaneous evolution surrounding the topic. Over the past several years, a renewed intensity in sustainability has emerged with new focuses on microplastics; ocean plastics; circular economy; environmental, social, and governance (ESG) scoring; and extended producer responsibility.
Depending upon the market you are in, becoming a sustainable operation is rapidly evolving from “nice to do” to a “must do” to help maintain your customer base and support their sustainability efforts. For example, Apple just announced that 110 of their global supply chain partners will be moving to 100% renewable energy for their Apple production as part of their commitment to be carbon neutral across its entire business, manufacturing supply chain, and product life cycle by 2030.
Part of what is driving the transition is legality, the other is pressure from the general public on companies to take complete responsibility for the products and services they provide. President Biden has made it clear that climate action is a priority for his administration. He has moved quickly to deliver on his campaign promises by issuing executive orders that cancel the controversial Keystone XL oil pipeline and return the U.S. to the Paris (Climate) Agreement.
The Biden Administration is committed to issuing new regulations for cars, power plants, and other large sources of greenhouse gasses. Biden established a National Climate Task Force comprised of the heads of federal departments and agencies. The mission of the Task Force is to identify actions that can be taken to reduce climate pollution and increase resistance to climate-change impacts.
When China and other countries in Southeast Asia stopped the importation of printed paper, plastic including plastic packaging, scrap metal, and other wastes for recycling, the discussion shifted to focus on a circular economy and away from a linear economy as it relates to the use and disposal of products. With overseas recycling markets no longer available, the economics of recycling turned upside-down, causing markets to crash. The refusal of wastes brought attention to the prevalence of plastics being found that were improperly managed and leaked into the ocean and other environments.
This created a public outcry causing legislation to be passed at the state and local level banning the use of “single use plastics.” In addition, legislation is being considered at the state and federal level to force companies to take responsibility for their waste. This legislation is known as Extended Producer Responsibility, and it is designed to make the producer responsible for the fate of their packaging. It is a tax on printed paper and plastics that helps pay for recovery and recycling activities.
End of Life Becomes More Important
The action by China and other countries in Southeast Asia has brought forth a discussion on what happens to a product when it has fulfilled its primary purpose. Is it to be simply discarded, or can it be recycled or repurposed into a different product? The latter is propelling the discussion, giving rise to an entirely new concept embodied by the term circularity. It is becoming increasingly difficult to just simply view landfilling as an acceptable end point for a product, and producers are being pushed hard to change the status quo.
The emergence and growing support for Extended Producer Responsibility legislation has sent a clear signal to those who produce products that they need to be responsible for their product throughout its entire life cycle — including the packaging. This pressure is forcing many companies to reconsider how they produce and package their products.
The responses vary but fit into some common actions, including incorporating recycled content, changing substrates completely to materials that are much easier to recycle, and redesigning products so they can be readily repurposed or recycled. While this trend started as a trickle, it is now starting to pick up momentum and has become more of a steady stream. The stream is still small, but it is anticipated to continue to get larger over the next several years.
Chemicals Come into Focus
Another area garnering attention concerns chemicals contained in products. The two main pressure points are regulatory and customer specifications. Increased awareness on the part of state legislatures regarding the potential toxicity of certain chemicals has spurred development of specific lists of chemicals that are to be banned from products.
One of the most well-known chemical-specific rules is California’s Proposition 65, which is formally known as the Safe Drinking Water and Toxic Enforcement Act of 1986. Proposition 65 requires companies selling or placing products into commerce in California to place a warning statement on their product if it contains a chemical “known to the State of California” to either cause cancer or pose a harm for reproduction. It is not uncommon for many printing operations to have their customers formally request that a letter of conformance be provided.
State chemical policy has evolved since Proposition 65. California, as well as the State of Washington, have passed legislation requiring certain consumer products that contain toxic chemicals be reviewed and possibly regulated to either require the chemical to be eliminated, replaced with something safer, or the product is otherwise restricted in its sale, use, or application. Regarding products produced by the printing industry, California has identified food packaging that contains perfluoroalkyl and polyfluoroalkyl substances (PFAS), bisphenol A (BPA), polystyrene, and ortho-phthalates. The State of Washington has identified printing inks as a significant source of inadvertently generated polychlorinated biphenyls (PCBs) due to the presence of certain pigments.
Model legislation offered by the Toxics in Packaging Clearinghouse (TPCH) has been revised to also add PFAS and ortho-phthalates as regulated chemicals. The previous TPCH Model Legislation and laws has been enacted in 19 states and prohibited the intentional use of cadmium, lead, mercury, and hexavalent chromium in any finished package or packaging component.
In addition to these regulatory requirements, customers are issuing their own lists of chemicals to be banned. In December 2020, Amazon issued a list of 17 chemicals for use in the packaging of its Amazon Kitchen brands. The announcement also included a ban on six plastics deemed to be unrecyclable. Amazon’s new commitment is the latest update to its “safer chemicals policy,” first launched in 2018.
Likewise, the Apparel and Footwear International RSL Management (AFIRM) Group focus has been the continuous advancement of chemicals management, including phasing out or limiting restricted substances to established limits in apparel, footwear, and accessories. Their members use the limits as specifications for their supply chain partners.
Create an Action Plan
At this point in the evolution of sustainability and the emerging circular economy, the customer is dictating your actions as they relate to your relationship with them. However, it is clear that additional legislation and regulation is on its way. Legislation and regulation mandating actions will not be a perfect solution, as by their nature they are always complicated, confusing, and sometimes conflicting. Nevertheless, success in the new circular economy driven market will be easier for those companies who take the time to understand what is occurring, and create action plans to work in a proactive manner with their customers.
The situation to be avoided at all costs is one where your largest customer informs you they can no longer do business with you because what you are providing them no long meets their requirements and specifications. The future belongs to those who plan.
It all starts with developing a clear and full understanding of your current state with your operations and product mix. The next step is to have discussions with your major suppliers regarding how they are responding, and if they do not appear to be responsive, perhaps it is time to find some new partners.
You also need to engage in discussions with your customer base to see how they are addressing becoming more circular. If you are armed with factual information and solutions, you may find that you will be welcomed as a valuable resource, which can be a game changer in your relationship.
In addition, you need to go public. Making a public statement as to the direction you wish to take lends a strong degree of accountability to your efforts. This is also known as development of a Sustainable Management Policy. When developing this policy statement, it is recommended that you consider including the following elements:
- A statement emphasizing the facility’s commitment to compliance with environmental, health, and safety requirements.
- Indication of the facility’s commitment to continuous improvement — including areas not subject to regulation — that addresses your operation and the products produced.
- A commitment to pollution prevention that emphasizes source reduction, reuse, and recycling.
- A method and commitment to sharing information on sustainability performance with external stakeholders.
Once developed, post your policy on your website and share with your employees, suppliers, and customer base. This is your public commitment to the sustainability journey. Understand that the journey is a continuous one, as we are only at the beginning of the new circular economy and we will see many changes along the path.
We Are Here to Help
If you need help developing a plan, you can access a team of experts at PRINTING United Alliance that will provide you with specific resources to address your business operation’s unique needs. Members of PRINTING United Alliance have access to additional exclusive resources. For more information on how we can help, or to become a member of PRINTING United Alliance, visit sgia.org.
Gary A. Jones is the director of environmental, health and safety (EHS) affairs at PRINTING United Alliance in Fairfax, VA. His primary responsibility is to monitor and analyze EHS regulatory activities at all domestic and some international government levels. He provides representation on behalf of the printing and specialty graphic imaging industry. In doing so, Mr. Jones works closely with the federal and state-level Environmental Protection Agencies (EPA), Occupational Safety and Health Agency (OSHA), Department of Transportation (DOT), and other agencies. He also provides membership assistance on EHS compliance and sustainability programs through a variety of approaches including responding to inquiries, presentations, writing, and consulting services.
Mr. Jones is also supporting PRINTING United Alliance’s efforts for the Sustainable Green Printing Partnership (SGP). SGP is dedicated to assisting printing operations respond to the customer demand for sustainable printing.
He holds a BS in biology from LaRoche College and an MS in chemistry from the University of Pittsburgh.