The IFPA recently released its stance on EPR laws, emphasizing the need to balance environmental goals with the operational needs of the fresh produce supply chain. Here is an executive summary outlining the association’s perspective on the topic.

Overview of EPR Policy Position

The Association promotes policies for recycling, composting, and a circular economy, emphasizing packaging's role in food safety, quality, and affordability. It warns that higher packaging costs from EPR laws could increase food prices and threaten access, impacting food security. The Association highlights the importance of packaging in safety, waste reduction, and consumer info, urging policies that balance environmental gain with supply chain realities, food loss prevention, and consumer needs.

Packaging’s Critical Role

Packaging is vital for preventing spoilage, ensuring safety, maintaining product quality, and enabling traceability in the fresh produce supply chain. Cost-increasing or access-restricting packaging changes could raise food waste and reduce produce availability. Packaging also helps vulnerable groups through donations and community programs. EPR policies should protect these essential functions that support food safety and consumer access.

Principles for Effective EPR Policies

The Association promotes policies for using recycled, recyclable, compostable, and proven materials. It highlights the need for supporting infrastructure for material recovery, balancing environmental goals with supply chain, food safety, and affordability.

Key Policy Considerations

When framing EPR policies, address interstate commerce by establishing clear national guidelines. Ensure transparency, fairness, and predictability for compliance. Policies should avoid harming perishable food systems while promoting a circular economy and recycling. Recognize the environmental benefits of recycled content and the role of packaging in food safety.

Performance and Material Standards

Policies should focus on reducing food waste rather than just packaging weight. Packaging that clearly reduces spoilage or food loss should be exempt from strict regulations. Eco-modulation should be allowed based on proven environmental benefits and lifecycle assessments, with effective food waste reduction benefits receiving favorable treatment and potential compliance delays.

Recyclability and Infrastructure

Defining recyclability consistently across states prevents penalizing well-performing packaging, even with limited local recycling facilities. Building recycling infrastructure and markets for recovered materials is essential, along with recognizing technically recyclable packaging in areas with limited infrastructure.

Compostable Packaging

The Association advocates for including compostable packaging in eco-modulation, despite infrastructure limits. Standards should match certification, and phased implementation is needed in areas with limited composting. Promoting composting benefits for unsold or expired food supports the Association's goals.

Interstate Consistency and Predictability

Transparent oversight of EPR implementers is crucial for effective regulation. Standardized definitions, reporting, and timelines reduce compliance complexity. Aligning policies with realistic redesign and operational cycles prevents disruptions and supports smooth EPR law implementation.

Automation and Equipment Compatibility

Packaging materials in the fresh produce supply chain must be compatible with existing packing and automation equipment to ensure ongoing operations, given the investments in automated infrastructure. Policies could extend transition timelines for new packaging needing more automation, include equipment compatibility in eco-modulation and regulations, and support R&D grants and pilot programs for sustainable, compatible packaging solutions.

The association issued its recommendation regarding specific packaging for EPR exclusion, covering primary, secondary, and tertiary packaging.