The Household & Commercial Products Association (HCPA) submitted the following letter to Senator Udall and Representative Lowenthal in response to the discussion draft of the proposed legislation to address plastic waste.


The Household & Commercial Products Association (HCPA) applauds your collective leadership in crafting solutions to reduce plastic waste. We could not agree more that waste management and recycling are important issues facing our country and the global environment and require a national perspective and solution. We also want to thank you both for accepting comments and feedback from key stakeholders. We truly value the opportunity to submit our thoughts on how Congress and the Federal Government can further address this issue and help resolve the crisis we face. We look forward to engaging in future conversations surrounding this important legislation.

HCPA is the premier trade association representing companies that manufacture and sell $180 billion annually of products used for cleaning, protecting, maintaining, and disinfecting homes and commercial environments. HCPA member companies employ 200,000 people in the U.S. whose work helps consumers and workers to create cleaner, healthier and more productive lives.

Our Products

HCPA members manufacture and market trusted, and familiar consumer products found in virtually every household in America. Those products are sold in packaging made of aluminum, steel, cardboard, and of course, plastic.  Our members have worked tirelessly to reduce packaging and use recyclable or post-consumer materials, while also ensuring that each product is safe for consumers to handle and store. In some cases, like in the case of consumer pesticide products, plastic is the preferred method of packaging to ensure that more hazardous products are still safe to handle. These products can remain in some consumers’ homes for days, weeks, or months, depending on their frequency of use and the issue they are designed to address.  Because the consumer decides when to dispose of their product, the consumer kicks off the system that should ultimately result in proper waste disposal. Unfortunately, even when a consumer chooses to recycle, the result is not guaranteed – stories have emerged of local recycling systems disposing of recyclable waste in landfills or otherwise failing to provide this critical service.

The Issue

Although the waste disposal process starts with the consumer, it can’t end with the consumer – prioritizing standardized recycling systems across the country can help meet consumers where they live and work.

HCPA fully supports the goal of increasing American recycling rates and diverting recyclable materials away from the waste stream in order to replace the use of new, raw materials. From our respectful point of view, the issue is that there is no “American” recycling system. The EPA found that only 34 percent of recyclable material is ultimately recycled, and the rate is even lower for plastic, at only nine percent. These unfortunate realities do not reflect a lack of willpower or determination from consumers or manufacturers, but instead demonstrate a lack of knowledge of how recycling works and the disparate recycling standards among the nearly 10,000 unique recycling programs throughout the country.

With so many programs spread over such a large area, properly educating Americans about what can be recycled, when, and where has proven very difficult. Recycling systems vary from city to city and county to county, without regard for consistency or uniformity. Some recycling systems include curbside pickup, while others require consumer deposits at local recycling centers. Some are single stream, others use a sorted collection. This piecemeal system has created an environment where only 4 percent of Americans say they do not find recycling confusing.

The Solution

HCPA and its members are committed partners in this critically important endeavor to increase recycling rates, and not just reacting to popular opinion but because it is the right outcome for the global environment. We believe that recycling, and the systems that facilitate it, should be considered basic infrastructure needs of a functioning American economy and should be standardized nationally to ensure that all Americans can contribute to achieving our shared goal of increased recycling. It is hard to imagine a fully circular economy when the basic recycling infrastructure features enormous local disparities and standards that confound most consumers.

Proposals to increase recycling rates should consider recycling not as a collection of compartmentalized, local programs, but instead as a national priority deserving of a clear direction. A strong federal system of uniform recycling services and standards, followed by public education, is the type of commitment that this critical piece of infrastructure deserves. This will allow all Americans, living in both urban and rural areas of all political persuasions, to participate in the preservation of our environment and our economy. Recycling infrastructure should be a national priority like transportation and utilities, and not just viewed as a passing thought left for localities to address. The federal government similarly invests in the construction and maintenance of highways and roads, providing support and standardization for a nationwide network. And perhaps most importantly, all drivers understand the meaning of the road signs.

To that end, we encourage you both to view increased recycling rates as an opportunity to expand our understanding of “critical infrastructure” so that we can improve environmental quality and waste management processes. By placing the weight of the federal government behind this much-needed initiative, as well as offering guidance and financial incentives to state and local governments that are willing to help, will help to facilitate a national standard that will enable educating all citizens on the importance and mechanics of recycling.


Americans want to be part of the solution to this environmental and economic challenge, so the federal government should meet them halfway. The challenge of increasing recycling rates faces all of us, consumers and businesses alike, and requires a national solution. Eighty percent of Americans feel that future generations will not be forgiving should government fail to find a solution to this problem. This means that together, we need to make recycling and diversion from landfills a priority on a national scale. This issue should be a national priority that focuses all aspects of the economy and American innovation on the goal of ensuring that Americans have the right tools, knowledge, and services to properly dispose of waste. HCPA and its members look to the federal government for its leadership and convening power on such an important issue and welcome the opportunity to participate in future discussions with other stakeholders.

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