Scope
The U.S. Plastics Pact work is broad and encompasses most packaging and some related ancillary materials but with key caveats and nuances, as described below.
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Plastic packaging
The U.S. Pact considers all post-consumer plastic packaging to be in scope. Post-consumer material is defined by ISO (14021) as follows:
Material generated by households or by commercial, industrial and institutional facilities in their role as end users of the product which can no longer be used for its intended purpose. This includes returns of material from the distribution chain. It excludes pre-consumer material (e.g. production scrap).
In other words, primary, secondary, and tertiary packaging with both consumer and commercial applications will be considered in scope. This recognizes that all of these packaging types have consequential environmental impacts and that each are feasibly subject to substantive and necessary action.
It also aligns with ISO definitions of “packaging”:
ISO 21067: packaging (This International Standard specifies preferred terms and definitions related to packaging and materials handling, for use in international commerce)
ISO 14021: packaging (This International Standard specifies requirements for self-declared environmental claims, including statements, symbols and graphics, regarding products)
Note 1 to entry: For the purposes of this International Standard, the term “packaging” also includes any item that is physically attached to, or included with, a product or its container for the purpose of marketing the product or communicating information about the product. |
For additional clarity, this scope therefore includes the following categories of plastic packaging:
Primary packaging
For the purposes of the U.S. Plastics Pact, primary packaging is defined as packaging that contains the finished or final products, sometimes called retail or consumer packaging. This packaging is used to contain, preserve, protect and inform the end user. It is the total packaging that the end-user will ultimately discard via reuse, recycling, landfill or other disposal routes. The primary package can be made of a number of components, e.g. for a multi-pack of water bottles this would include the PET bottles, their caps, labels and the plastic shrink film. Primary packaging includes all packaging up to the point of sale. It also includes retail/shopping bags and plastic produce bags, as well as primary packaging that is durable and reusable in nature.
Secondary packaging
For the purposes of the U.S. Plastics Pact, secondary packaging is defined as packaging additional to the primary packaging that is used for protection and collation of individual units during storage, transport and distribution. Secondary packaging can be used in some sectors to display primary packs on shelf. This category also includes packaging purposely made to display multiple product units for sale, in order to speed restocking from storeroom to shelf.
Secondary packaging is closely connected to and functions in many instances like primary packaging, and thus logically falls within scope. This would include secondary packaging that is durable and reusable in nature.
Tertiary packaging
For the purposes of the U.S. Plastics Pact, tertiary packaging is defined as outer packaging, including pallets, slip sheets, stretch wrap, strapping and any plastic labels, used for the shipment and distribution of goods. This packaging is also referred to as transport or transit packaging and is rarely seen by the final consumer (e.g., household or individual). Reusable transit packaging (e.g. reusable plastic pallets) is not needed to be reported apart from its initial first use.
Tertiary packaging is also in scope for the U.S. Plastics Pact. These materials may be more challenging to track and measure and therefore may not be fully accounted for in annual reporting. However, they represent opportunities for reuse and recycled content – furthering progress toward a circular economy – and are in scope for USPP projects and deliverables.
Business to Consumer (B2C) and Business to Business (B2B) Considerations
While the vast majority of primary and secondary packaging can be found in B2C pathways, the inclusion of tertiary packaging will involve B2B pathways, thus bringing both B2C and B2B under the Pact’s scope. Regardless, the overall focus is still on post-consumer material. In many cases, the consumer in an individual or a household, but commercial businesses, institutions (e.g., schools, hospitals), and industrial facilities are also consumers of primary, secondary, and tertiary packaging. In some cases it may be necessary to make the distinction between B2B and B2C pathways in reporting given corollary differences in material fate, e.g. B2B LDPE film meets the requirement for recyclability according to EMF definitions, but B2C LDPE film does not.
Further Observations on Packaging Distinctions and Related Pact Work
It should be noted that some materials may be ambiguous according to these categories. In other words, the same formats may be considered primary packaging in some applications, and secondary or even tertiary packaging in others.
It is also noted that the proposed inclusion of all of these types of packaging does not necessarily mean that the U.S. Plastics Pact, as a group of Activator organizations, will necessarily be in a position to substantially influence all of them, let alone in an equal manner.
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Ancillary plastic materials
Additional plastics products are ambiguous in terms of meeting the definition of “packaging,” but they are purchased, used, and discarded in patterns similar to primary packaging, and in some use cases, function as primary packaging. They also have environmental consequences and are feasibly subject to substantive and necessary action under the U.S. Pact. In addition, they are represented in the anticipated Pact reporting platform and to some degree in available or developable data for Target 3. Therefore, the following specific plastic ancillary material formats are considered in scope for the U.S. Plastics Pact:
- Cups
- Utensils
- Straws
- Plates
- Bowls and takeout containers
- Carry-out bags
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Additional packaging with plastic content: poly-coated paper
Other types of packaging have plastics elements, most prominently in the form of coatings on certain paper packaging – e.g., paper cups, gable top and aseptic containers, frozen food boxes, ice cream cartons, some fast-food packaging, and other forms of poly-coated papers. These forms of plastic are outside of the scope for the USPP due to the relatively low plastic content of these multi-material items and their inclusion in circularity initiatives of other industries.
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Plastics in Durable Products
Plastics in durable, non-packaging products (e.g. appliances, electronics, furnishings, etc.) are currently outside of the scope of work for the U.S. Plastics Pact, but that could be reconsidered in the future. All USPP Activators are purchasers, users, and discarders of plastics materials in durable products. To see overall improvement on the fate and impacts of all plastics, significant progress must be made on the recyclability, reusability, potential reduction and actual recycling of these materials, as well as assessment of their status as potentially “unnecessary” or “problematic.”
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Other Non-Durable Plastic Products
Additional kinds of plastic products that fall within EPA’s categories of “non-durable goods” in its annual Facts and Figures report are outside of scope for the USPP, including trash bags and the category of “all other non-durables,” characterized by EPA as “plastics in disposable diapers, clothing, footwear, etc.” However, to see overall improvement on the fate and impacts of all plastics, significant progress must be made on the recyclability, reusability, potential reduction and actual recycling of these materials. Therefore, it is recommended to revisit this exclusion as the work of the U.S. Plastics Pact evolves.
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Medical Plastics
Medical plastics, defined as plastics used and generated in clinical, hospital, and related laboratory and research settings, are outside of the scope for the USPP. These materials present very significant and complicated challenges due to human safety factors and are very difficult to distinguish in available data, in addition to not being represented in the USPP Activator base. However, the USPP may revisit this exclusion as the work evolves, recognizing that these plastic streams have environmental impacts and would benefit from focused attention on reduction, recyclability, and recycling.
This exclusion does not apply to pharmaceutical packaging e.g. OTC or prescription medicines packaged in plastic. While there are very specific guidelines for this type of packaging issued by FDA/The United States Pharmacopeial Convention, at this time the requirements are not deemed to be odds with the goals of the U.S. Plastics Pact.