Category Archives: Closing the Loop

Mikhail Davis

Administering EPR: Can AB 2398 Revive Carpet Recycling in California?

Extended Producer Responsibility (EPR): An environmental policy approach under which the responsibility of producers for their products is extended to include the social costs of waste management, including the environmental impact of waste disposal (OECD, 2005)

EPR comes to the carpet industry

On July 1 a new era began for carpet, one in which it joins the ranks of soda bottles and cans, paint, batteries, electronics, lightbulbs and the other consumer products whose end-of-life disposal is affected by state EPR legislation. We are proud of the 228M lbs. of carpet Interface has diverted since 1996 with our ReEntry 2.0 system, but the larger context for our industry is that over 90% of old carpet still ends up in the landfill every year. In search of an industry wide solution, the state of California just implemented the first Extended Producer Responsibility legislation for carpet.

In October 2010, Governor Schwarzenegger signed California’s new Carpet Stewardship law (AB 2398) and as of July 1, a 5¢ per yard assessment was added to all carpet sold in California. The money collected will create a fund that will be distributed by CARE (Carpet America Recycling Effort) to recyclers to incentivize new investment in collection and processing. Based on past sales numbers, the fund should receive about $5M every year from the assessment.

Will California’s approach work?

Whether or not access to this money will be sufficient to convince processors and manufacturers to invest in new infrastructure remains to be seen. For our part, InterfaceFLOR has already made these investments by creating the ReEntry 2.0 carpet recycling system, which efficiently converts InterfaceFLOR and similar products into new carpet tiles. While we have not completely closed the loop we continue to expand and refine our collection and processing network each year.

Some skeptical product stewardship activists have described AB 2398 as $5M in “magic pixie dust” to be sprinkled about in hopes that new carpet recycling entrepreneurs will emerge. My ongoing research reveals the tenuous state of California’s specialty recycling industry; only two sizable commercial broadloom recyclers operate in the state right now and many recyclers I worked with only two years ago are now out of business. One state recycling expert estimated that $25M per year would be required to build a robust market for carpet recycling, but conceded that $5M from the new law will be enough to keep existing recyclers in business.

EPR Beyond California

As a member of CARE, we hope the law will help carpet diversion numbers improve dramatically, but if they do not, critics will point out that the law provides incentives, but is not an effective means of holding producers responsible.

More than ten other states are watching California as they consider EPR legislation to address carpet waste. If the history of EPR legislation for electronics takeback (pioneered in CA, now law in 25 states) is any guide, each state may adopt completely different rules, including some that move beyond incentives and hold each manufacturer financially responsible for getting their own products recycled at end of life.

InterfaceFLOR sees getting our products back as essential to our future growth, and the new legislative landscape of EPR represents an opportunity to expand ReEntry 2.0 and secure our supply of recycled raw materials. While the new California law isn’t perfect, it is an important first step toward making carpet recycling an economic reality, not merely a promise unfulfilled.

This is the first in a series of posts on the subject of Closing the Loop, so I welcome your suggestion for questions to address in future posts.

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