vvEPA

Draft National Strategy

to Prevent Plastic

Pollution

Part of a Series on Building a

Circular Economy for All

EPA Office of Resource
Conservation and Recovery
April 2023

EPA530-R-23-006


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Disclaimer

The Draft National Strategy to Prevent Plastic Pollution represents potential actions where
the United States Environmental Protection Agency can work with stakeholders and does
not imply approval for any specific action under Executive Order 12866 or the Paperwork
Reduction Act. All potential federal government activities included in this strategy are
subject to budgetary constraints, interagency processes, stakeholder input, and other
approvals, including the weighing of priorities and available resources by the Administration
in formulating its annual budget and by Congress in legislating appropriations. This
document is not intended, nor can it be relied upon, to create any rights enforceable by any
party in litigation with the United States. This document does not impose legally binding
requirements. Mention of case studies; public, private, or nonprofit entities; trade names; or
commercial products or services in this document does not and should not be construed to
constitute an endorsement or recommendation of any such product or service for use in any
manner.


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Table of Contents

Executive Summary	1

Objective A: Reduce pollution during plastic production 	1

Objective B: Improve post-use materials management	2

Objective C: Prevent trash and micro/nanoplastics from entering waterways and remove escaped

trash from the environment	2

Next Steps	3

Plastic Waste Is Both a U.S. and a Global Challenge	6

Increasing the Circularity of Plastic Products Can Reduce Plastic Pollution 	10

Developing the Draft National Strategy to Prevent Plastic Pollution	13

Goal and Scope of the Strategy	15

Objective A. Reduce Pollution During Plastic Production	17

A1. Reduce the production and consumption of single-use, unrecyclable, or frequently littered

plastic products	17

A2. Minimize pollution across the life cycle of plastic products	19

Objective B. Improve Post-Use Materials Management	23

B1. Conduct a study of the effectiveness of existing public policies and incentives upon the reuse,

collection, recycling, and conservation of materials	23

B2. Develop or expand capacity to maximize the reuse of materials	23

B3. Facilitate more effective composting and degradation of certified compostable products	24

B4. Increase solid waste collection and ensure that solid waste management does not adversely

impact communities, including those overburdened by pollution	26

B5. Increase public understanding of the impact of plastic mismanagement and how to

appropriately manage plastic products and other waste	28

B6. Explore possible ratification of the Basel Convention and encourage environmentally sound

management of scrap and recyclables traded with other countries	29

Objective C. Prevent Trash and Micro/Nanoplastics from Entering Waterways and

Remove Escaped Trash from the Environment 	31

C1. Identify and implement policies, programs, technical assistance, and compliance assurance
actions that effectively prevent trash/micro/nanoplastics from getting into waterways or
remove such waste from waterways once it is there	31

C2. Improve water management to increase trash and micro/nanoplastic capture in waterways and

stormwater/wastewater systems	32

C3. Increase and improve measurement of trash loadings into waterways to inform management

interventions	33


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C4. Increase public awareness of the impacts of plastic products and other types of trash

in waterways	34

C5. Increase and coordinate research on micro/nanoplastics in waterways and oceans	35

Next Steps	37

References	39


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Executive Summary

The Draft National Strategy to Prevent Plastic Pollution, which is part of EPA's Series on Building a
Circular Economy for All, provides voluntary actions that can be implemented in the United States
aimed at eliminating the release of plastic waste from land-based sources into the environment
by 2040.1 EPA endeavors to provide an innovative, equitable approach to reduce and recover
plastic and other waste, as well as prevent plastic pollution from harming human health and the
environment, particularly for communities already overburdened by pollution. Plastic pollution has
accumulated overtime and will continue to grow as plastic production increases. Therefore, the
Draft National Strategy to Prevent Plastic Pollution, together with EPA's National Recycling Strategy,
identifies how EPA can work collaboratively with stakeholders to prevent plastic pollution and
reduce, reuse, recycle, collect, and capture plastic and other waste from land-based sources.

With input from stakeholders, EPA identified three draft objectives for the strategy:

>	Objective A: Reduce pollution during plastic production

>	Objective B: Improve post-use materials management

>	Objective C: Prevent trash and micro/nanoplastics from entering waterways and remove
escaped trash from the environment

The proposed actions under each objective support United States' shift to a circular approach that is
restorative or regenerative by design, enables resources to maintain their highest value for as long as
possible, and aims to eliminate waste in the management of plastic products.

Objective A: Reduce pollution during plastic production

Designing products for reuse and recycling, using less impactful materials, phasing out unnecessary
products, and ensuring proper controls at plastic production facilities are important upstream actions
that manufacturers or consumers can take that can reduce pollution throughout the life cycle of
plastic products.

Proposed Actions:

A1. Red uce the production and consumption of single-use, unrecyclable, or frequently littered
plastic products.

A2. M inimize pollution across the life cycle of plastic products.

1 See the U.S. submission for the second session of the UNEP Intergovernmental Negotiating Committee
on plastic pollution: https://wedocs.unep.ora/bitstream/handle/20.500.11822/41810/USsubmission.
pdf?sequence=1&isAllowed=v.

a


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Objective B: Improve post-use materials management

While EPA's National Recycling Strategy identified actions to improve recycling, further increases in
circularity can be achieved through other pathways, such as reuse, refill and composting.

Proposed Actions:

B1. Conduct a study of the effectiveness of existing public policies and incentives upon the
reuse, collection, recycling, and conservation of materials.

B2. Develop or expand capacity to maximize the reuse of materials.

B3. Facilitate more effective composting and degradation of certified compostable products.

B4. I ncrease solid waste collection and ensure that solid waste management does not adversely
impact communities, including those overburdened by pollution.

B5. I ncrease public understanding of the impact of plastic mismanagement and how to
appropriately manage plastic products and other waste.

B6. Explore possible ratification of the Basel Convention and encourage environmentally sound
management of scrap and recyclables traded with other countries.

Objective C: Prevent trash and micro/nanoplastics from entering
waterways and remove escaped trash from the environment

Interventions to address trash and microplastics that escape into the environment are necessary for
long-term reductions of plastic and other waste in waterways and oceans.

Proposed Actions:

C1. Identify and implement policies, programs, technical assistance, and compliance assurance
actions that effectively prevent trash/microplastics from getting into waterways or remove
such waste from waterways once it is there.

C2. Improve water management to increase trash capture in waterways and stormwater/
wastewater systems.

C3. Increase and improve measurement of trash loadings into waterways to inform management
interventions.

C4. Increase public awareness of the impacts of plastic products and other types of trash in
waterways.

C5. Increase and coordinate research on micro/nanoplastics in waterways and oceans.


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Next Steps

EPA is opening a 45-day public comment period with the release of this draft strategy. Due to the
action-oriented nature of the draft strategy and the need for commitments to execute it, EPA will
continue outreach and engagement during the comment period and during finalization of the
strategy Implementation of the strategy is expected to be an iterative process as resources, entities
leading efforts, and needs change over time. EPA intends to help facilitate the implementation of
actions in the strategy and will provide routine status updates to interested stakeholders.

EPA is seeking feedback on the following questions:

>	Which actions are the most important and would have the greatest positive impact at the
local, regional, national, and global levels?

Consider:

o Which actions can best protect human health and environmental quality?

o Which actions are most important to address environmental justice and climate
impacts?

o What are the key steps and milestones necessary to successfully implement the actions
in the draft strategy?

>	What are the most important roles and/or actions for federal agencies to lead?

>	Is your organization willing to lead an action or collaborate with others to implement the
actions?

o What factors would your organization consider when determining whether to lead an
action?

>	What are potential unintended consequences of the proposed actions that could impact
communities considered overburdened or vulnerable, such as shifts in production or
management methods?

>	What key metrics and indicators should EPA use to measure progress in reducing plastic and
other waste in waterways and oceans?

>	What criteria should processes other than mechanical recycling meet to be considered
"recycling activities" (e.g., "plastics-to-plastics outputs are 'recycling' if the output is a
product that could again be recycled into another product or to extent that it can achieve
viable feedstock for new plastic materials")? How should health and environmental impacts
be considered in these criteria?

>	Are there other actions that should be included in the Strategy?

o Should EPA expand the scope of the strategy to include sea-based sources?

o Should specific types of plastic products be targeted for reduction or reuse in this
strategy?

>	Do you have any additional information or recommendations for EPA regarding these or
other proposed actions in the draft strategy?


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Introduction

Plastic products are both versatile and inexpensive, when considered outside of the context of their
broader environmental and health impacts. Because they are both durable and lightweight, plastic
products have found prominence in the construction, transportation, and packaging industries
(OECD, 2022a). In addition, plastic innovations have contributed to many life-saving products that
have revolutionized the health care industry. Despite some potential benefits, plastic pollution
presents complex challenges to addressing the climate crisis and advancing environmental justice
that will persist as its production and use increase as projected.

Over the last 20 years, the global annual production of plastic products has more than doubled
despite insufficient waste management capacity globally, and as a result, plastic waste has also
doubled. In 2019, roughly 23 percent of global plastic waste was either improperly disposed,
burned, or leaked into the environment (OECD, 2022a). Plastic products account for approximately
85 percent of total global marine waste and between 70 and 80 percent of all waste that ends up
in land and marine environments combined (UNEP, 2021; NASEM, 2022). Plastic products in the
environment tend to break down over time to form very small pieces called microplastics, which can
pose serious threats to wildlife and may potentially harm human health (NASEM, 2022). In 2022,
the pervasiveness and persistence of plastic waste in the environment drove the United Nations
Environmental Programme's (UNEP) Environmental Assembly (UNEA) to launch the development of
an international, legally binding instrument on plastic pollution (UNEA, 2022).2

The United States plays a critical role in reducing global plastic pollution as a major global plastic
producer and plastic waste generator. While regulation and solid waste management programs
have shown success in reducing waste, a collaborative effort by stakeholders across the value chain
of plastic products—including governments, environmental organizations, industry, academia, and
the public—will be needed to build a more circular plastics economy and reduce plastic pollution
across the life cycle. While EPA's National Recycling Strategy identified actions to improve the U.S.
municipal solid waste recycling system, additional actions are needed to further increase circularity
through other pathways. The Draft National Strategy to Prevent Plastic Pollution identifies actions
EPA can implement, in collaboration with stakeholders, to eliminate the release of plastic waste into
the environment by 2040.3 This strategy, together with the National Recycling Strategy, satisfies
Congress' direction to EPA in Section 301 of the Save Our Seas 2.0 Act (2020) to develop a strategy
to improve post-consumer materials management and infrastructure for the purpose of reducing
plastic waste and other post-consumer materials in waterways and oceans.

2	See Intergovernmental Negotiating Committee on plastic pollution: https://www.unep.org/about-un-environment/
inc-plastic-pollution.

3	This strategy is aligned with the U.S. submission to the UNEP Intergovernmental Negotiating Committee
on plastic pollution: https://wedocs.unep.ora/bitstream/handle/20.500.11822/41810/USsubmission.
pdf?sequence=1&isAllowed=v.

Va


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The Draft National Strategy to Prevent Plastic Pollution has three main objectives to address the
production, consumption, and end of life stages of plastic products, in addition to addressing other
solid waste materials of concern: (A) reduce pollution during plastic production, (B) improve post-use
materials management, and (C) prevent trash and microplastics from entering waterways and remove
escaped trash from the environment. There are multiple voluntary actions identified under each
objective.

Plastic Waste Is Both a U.S. and a Global Challenge

Globally, plastic production continues to increase rapidly, and most plastic products are not reused
or recycled at the end of their life. Over the last 20 years, global plastic production, consumption,
and waste have increased steeply as innovations for plastic applications continue to rise. The
Organisation for Economic Co-operation and Development's (OECD's) Global Plastics Outlook
(2022b) projects plastic use and waste to almost triple by 2060, with half of all plastic products
being landfilled. Furthermore, less than a fifth is projected to be recycled while leakage into the
environment is estimated to double to almost 49 million tons4 per year by 2060 (OECD, 2022b).

The United States plays a critical role in the global economy of plastic products. North America is a
major producer of plastic products, producing 19 percent of global plastic products in 2015 (UNEP,
2018). The United States also uses more plastic products than other countries. According to the
OECD, the United States consumed 18 percent of global plastic products in 2019, and plastic use
per capita was higher than in any other country globally. The OECD estimated, on average, that a
resident of the United States used approximately 1.8 times more plastic products than a resident of
the European Union (EU) in 2019 (OECD, 2022a).

Much of the plastic that is produced will end up as waste. In 2018, only nine percent of plastic
collected through municipal solid waste was recycled in the United States (U.S. EPA, 2020). In 2016,
the United States had roughly 4.3 percent of the world's population but generated 10.5 percent5 of
global plastic waste (NASEM, 2022; OECD, 2022a). As shown in Table 1, the United States had the
largest plastic waste footprint of any country in 2019, generating approximately 486 pounds6 per
capita (OECD, 2022a).

4

5

6

Converted from 44 million metric tons (OECD, 2022b).

Calculated from statistics provided in Global Plastics Outlook 1 (OECD, 2022a).
Converted from 220.5 kg/cap (OECD, 2022a).


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Table 1: 2019 global plastic waste generation per capita (OECD, 2022a)



Pounds per Capita





United States

486



OECD America

Canada

392





Other OECD America

128

OECD

OECD Europe

OECD EUa countries

268



OECD non-EU countries

208



OECD Pacific

OECD Asia

152



OECD Oceania

137



Other America

Latin America

96



Eurasia

Other EU

166



Other Eurasia

117

Non-OECD

Middle East

Middle East and North Africa

83

and Africa

Other Africa

32





China

103



Other Asia

India

31





Other non-OECD Asia

47

EPA's estimates of plastic products in the municipal solid waste stream show that plastic waste
is growing. Plastic products in the U.S. municipal solid waste stream predominantly consist of
containers and packaging, which includes some single-use products such as bags, wraps, and bottles
(U.S. EPA, 2020). Plastic waste has increased continuously in the U.S. municipal solid waste system
since 1960, with the greatest increases occurring between 1980 and 2000 (Figure 1) (U.S. EPA, 2020),
Research suggests that plastic waste generation in the United States increased from 0.4 percent
of total municipal solid waste generated in 1960 to 12.2 percent in 2018, reaching 13.2 percent in
2017 (U.S. EPA, 2020). These estimates do not include plastic waste from other sources, such as
agricultural waste.


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40.000,000

30,000,000

i/>

c

20,000,000

10,000,000

1960

1970

1980

1990

2000 2005

Year

2010

2015

2017 2018*

Figure 1: Total plastic waste in the U.S. municipal solid waste system since 1960

(U.S. EPA, 2020).

The environmental and economic
impacts of plastic products and their
byproducts are felt across their life
cycles, including their production,
use, and disposal. In 2019, plastic
products were responsible for 3.4
percent of global greenhouse gas
emissions throughout their life cycles,
with 90 percent of these emissions
coming from the production and
conversion of fossil fuels into new
plastic products (OECD, 2022a). If
the world continues with business
as usual, greenhouse gas emissions
associated with the life cycle of
plastic products are expected to
double by 2060 (OECD, 2022b).

Without intervention, it is projected
that by 2050 the global plastics
industry will account for 20 percent
of total oil consumption and up to 15
percent of global carbon emissions
(World Economic Forum et al., 2016).

Figure 2: Pathways of land-based sources of plastic
pollution (image courtesy of Santa Clara Valley Urban
Runoff Pollution Prevention Program).

Plastic products that end up in waterways and oceans from U.S. land-based sources come from
three primary sources: 1) plastic products that are littered, illegally dumped, or have otherwise
escaped the solid waste management system; 2) plastic waste that the United States exports to
other countries for recycling and are subsequently mismanaged; and 3) micro/nanoplastics from
transportation, wastewater, and other sources. Land-based sources account for up to 80 percent of

How Trash Gets Into Creeks

LITTER FROV
-V* CARS &
TRUCKS

ILLEGAL
DUMPING

PEDESTRIAN
UTTER


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plastic waste that pollutes waterways and oceans (NASEM,
2022). Figure 2 depicts the pathways of common land-
based sources of plastic pollution, including litter from cars,
trucks, and garbage and recycling bins; pedestrian litter;
and illegal dumping activities. Plastic pollution from land-
based sources includes littered items such as packaging
(including flexible films), single-use products, durable
consumer products, household products, and microplastics
(such as tire wear particles and microfibers from textiles). An
analysis conducted by Law et al. (2020) estimated that the
United States contributed between 0.56 and 1.60 million

Circular economy is defined in the
Save Our Seas 2.0 Act as "a systems-
focused approach and involves industrial
processes and economic activities that
are restorative or regenerative by design,
enable resources used in such processes
and activities to maintain their highest
values for as long as possible, and aim
for the elimination of waste through
superior design of materials, products,
and systems (including business
models)."

tons7 of plastic waste to the coastal environment in 2016.8
This amount includes waste exported to other countries, making the United States' contribution to
global plastic waste leakage larger than in previous estimates. The authors estimate that this range
represents between 2.33 and 2.98 percent of the total amount of plastic waste generated in the
United States (Law et al., 2020). In addition to land-based sources of plastic pollution, abandoned,
lost, or otherwise discarded boating, fishing, or aquaculture gear are another primary source of
plastic waste in waterways and oceans. This strategy addresses land-based sources of plastic waste
that enter the environment and does not address sea-based sources of plastic pollution.

In addition to environmental
impacts, there are growing
health concerns related to plastic
products. Some animal studies
have raised concerns regarding
endocrine-disrupting effects from
chemicals that may leach out of
plastics, including impacts on the
reproductive system (NASEM,
2022). Microplastics have also
been found in human placentas
after birth, despite the use of
a plastic-free birthing protocol
(NASEM, 2022).

Environmental justice is the fair treatment and meaningful
involvement of all people regardless of race, color, national origin,
or income with respect to the development, implementation, and
enforcement of environmental laws, regulations, and policies.
For the first time, EPA's 2022-2026 Strategic Plan includes a new
strategic goal focused solely on advancing environmental justice
and civil rights. EPA will center its mission on integrating justice,
equity, and civil rights across the nation's environmental protection
enterprise, including waste management. By doing so, EPA will
advance the promise of clean air, clean water, and safe land to the
many communities across the country that have not received the
full benefits of EPA's decades of progress. Disparate impacts on
communities affected by plastic, from production to waste, make
environmental justice a central consideration within this strategy.

7	Converted to short tons from the metric tons reported in Law et al. (2020).

8	The Law et al. (2020) article did not look at microplastics from transportation, wastewater, and other sources.


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Communities with environmental justice concerns, including disadvantaged communities, are
disproportionately impacted by adverse health outcomes associated with the life cycle of plastic
products. These communities can experience disproportionate burdens from production and
waste management processes. Additionally, Indigenous communities that rely on natural resources
for sustenance have been impacted by the extraction of natural resources used to manufacture
plastic products, which can affect their quality of life, economy and health (NASEM, 2022).

Many "fenceline" communities in the United States—communities that surround chemical and
petrochemical processing facilities—consist primarily of minority and low-income populations who
suffer disproportionately from increased respiratory and nervous system diseases from exposure to
toxic pollutants from production or hazardous waste facilities (NASEM, 2022) in addition to other
social, economic, and ecological burdens they experience.

The business-as-usual approach to managing plastic waste is unsustainable. According to Pew
Charitable Trust's report, Breaking the Plastics Wave (2022), the cost of managing plastic waste
from now until 2040 will be $70 billion greater than it could be if the world adopted a fully circular
approach. Other economic risks related to plastic waste include physical damage to ships and fishing
assets, reduced fish catches from declining fish stocks, loss of property values, and reduced income
to the tourism industry (Pew, 2022). Environmental and health impacts are also expected to increase
due to an increase in plastic products and microplastics in aquatic environments (OECD, 2022b).
Because of these concerns, there is a global consensus that a unified, comprehensive approach is
needed to tackle the plastic pollution problem, in March 2022, the United Nations Environment
Assembly launched the process to develop an international, legally binding instrument to reduce
plastic pollution.

Increasing the Circularity of Plastic Products Can Reduce
Plastic Pollution

The United States has an opportunity to show
leadership in reducing plastic pollution. New and
innovative approaches are necessary to reduce and
recover plastic materials and improve economic,
social, and environmental impacts. Figure 3
illustrates the flow of materials in a circular economy.

It distinguishes between stock management of
finite materials and renewables flow management.

Specifically, the right side of the diagram (stock
management) illustrates how finite materials and
products, such as plastic products are ideally kept in
use for as long as possible in a circular economy via
practices like sharing, reusing, remanufacturing, and

recycling. To reduce plastic pollution and increase the circularity of plastic products, a coordinated
effort across the entire value chain—including federal, state, local, and Tribal governments;
environmental organizations; industry; academia; and the public—is necessary.


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RENEWABLE*

RENEWABLES FLOW MANAGEMENT

STOCK MANAGEMENT

REGENERATION

EXTRACTION OF

BIOCHEMICAL

FEEDSTOCK'

1	Hunting ana fishing

2	Can take both po«-h
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Million metric tons per year

450

Eliminate
Reuse (consumer)

Reuse (new delivery models)
Paper

Coated paper

Compostables

Mechanical recycling
-closed loop (CL)
Mechanical recycling
-open loop (OL)

Chemical recycling
-plastic to plastic (P2P)

Chemical conversion
-plastic to fuel (P2F)

Landfill
Incineration

Open burning
Terrestrial pollution
Ocean pollution

0

©

Reduce:
130 (30%)

Substitute:
71 (17%)

Recycle:
84 (20%)

Dispc
loi (;

Mismanaged:
44 (10%)

2016

2020

2030

2040

This "wedges" figure shows the share of treatment options for the plastic that enters the system over time under the System Change Scenario. Any plastic that enters
the system has a single fate, or a single "wedge." The numbers include macroplastic and microplastic.

Image Credit: The Pew Charitable Trusts.

Figure 4: Wedge analysis in the "System Change Scenario" shows up to an
80 percent reduction in plastic pollution (Pew, 2020).

The United States can be a leader in developing an innovative, circular approach to reducing plastic
pollution while growing the economy and fulfilling America's needs. Already, the United States is a
leader in plastic circularity innovation. Between 2010 and 2014, the United States was among the
top three countries with the highest number of patents focused on plastic circularity in the world
(Figure 5) (OECD, 2022a).


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All plastics innovation
Increasing plastics circularity

Technological specialisation in circular plastics innovation
relative to all plastics innovation (+/-)

ll h .¦		

Japan USA China Korea Germany France	UK Chinese Australia Spain

Taipei

Figure 5: Innovations in plastics and plastic circularity worldwide (OECD, 2022a).

This innovation was incentivized by many state and local government policies that address plastic
pollution by curbing plastic use and increasing recycling. The United States is looking to accelerate
leadership in innovations and technology to reduce plastic waste in oceans and landfills through the
U.S. Department of Energy's Strategy for Plastics Innovation, which focuses on advancing plastics
recycling technologies and manufacturing plastic products that are recyclable by design
(U.S. DOE, n.d.)

Recycling initiatives are part of the solution. However, we need more upstream solutions to
addressing plastic pollution, such as reducing the use of unnecessary plastic, designing for circularity,
and increasing innovations in systems that extend the lifespan of products, such as repair and reuse.

Developing the Draft National Strategy to Prevent Plastic Pollution

In December 2020, the Save Our Seas 2.0 Act was signed into law in response to the growing local,
national, and international concerns over plastic pollution and marine debris. Section 301 of the
Act charges EPA, in consultation with stakeholders, with developing a strategy to improve post-
consumer materials management and infrastructure to reduce plastic waste and other post-consumer
materials in waterways and oceans. Congress further required that EPA:

"distribute the strategy to States; and . . . make it publicly available, including
for use by. . . for-profit private entities involved in post-consumer
materials management and other nongovernmental entities."

This strategy, together with the National Recycling Strategy, satisfies Congress' direction to EPA.
EPA's National Recycling Strategy, part one of the series of strategies on building a circular economy
for all, was published in November 2021 and primarily focuses on enhancing and advancing the
national municipal solid waste recycling system, including plastic products in municipal solid waste.
This strategy, the Draft National Strategy to Prevent Plastic Pollution, builds upon the National


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Recycling Strategy's focus on actions to reduce, reuse, collect, and capture plastic waste. Other
strategies in the strategy series will focus on different parts of building a more circular economy for
all, including a strategy on textiles.

EPA has been working to conserve and recover resources for decades under the Resource
Conservation and Recovery Act (RCRA). In EPA's report, Beyond RCRA: Waste and Materials
Management in the Year 2020 (2003), the Agency identified that many global environmental
challenges can be addressed through reducing waste and increasing the efficient and sustainable
use of resources, as well as preventing exposures to humans and ecosystems from the use of
hazardous chemicals and managing waste and cleaning up chemical releases in an environmentally
sound manner. In addition, EPA's Sustainable Materials Management: The Road Ahead (2009), EPA
identified a Sustainable Materials Management (SMM) approach for EPA's work. A circular economy
approach under the SMM umbrella demonstrates continuity in EPA's emphasis on reducing the life
cycle impacts of materials, reducing the use of harmful materials, and decoupling materials use from
economic growth.

To inform the development of this strategy, EPA held several stakeholder engagement meetings in
November 2021 and received input from the following organizations:

>	State, Tribal, and local agencies. The Association of State and Territorial Solid Waste
Management Officials (ASTSWMO), the Eastern Band of Cherokee Indians, Environmental
Council of the States (ECOS), the Mississippi River Cities and Towns Initiative, the St. Louis
Civil Rights Enforcement Agency, the National Tribal Caucus, the Santee Sioux Nation, the
Nez Perce Tribe, the Sac and Fox Nation of Missouri, the Tribal Waste and Response Steering
Committee, and the U.S. Conference of Mayors.

>	Nonprofit organizations/nongovernmental organizations (NPO/NGOs). Beyond Plastics,
Center for Biological Diversity, Ellen MacArthur Foundation, Five Gyres, Keep America
Beautiful, Manufacturing Communities Collaborative, Ocean Conservancy, Pew Charitable
Trusts, and the National Environmental Justice Advisory Council.

>	Private sector/industry. American Institutes for Packaging and the Environment, American
Chemistry Council Closed Loop Partners, Patagonia, Plastics Industry Association,

Sustainable Packaging Coalition, and the U.S. Plastics Pact.

>	Academia. Duke University, Iowa State University, Sea Education Association, University of
California, Davis, the University of Cincinnati, the University of Georgia, and the University of
Massachusetts Lowell.

Between November 2021 and July 2022, EPA hosted virtual meetings across the country with
interested stakeholders to inform the development of new grant programs established by the
Infrastructure Investment and Jobs Act, which further informed the development of this strategy.


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Throughout the development of the strategy, EPA has coordinated with the following federal
agencies: National Science Foundation (NSF), the U.S. Agency for International Development
(USAID), the U.S. Department of Agriculture (USDA), the U.S. Department of Commerce (DOC)
(including the International Trade Administration [ITA], National Oceanic and Atmospheric
Administration [NOAA], and the National Institute of Standards and Technology [NIST]), the U.S.
Department of Defense (DOD), the U.S. Department of Energy (DOE), the U.S. Department of State
(DOS), the Federal Trade Commission (FTC), the U.S. General Services Administration (GSA), and the
U.S. Trade Representative (USTR).

Goal and Scope of the Strategy

The Draft National Strategy to Prevent Plastic Pollution aims to identify actions needed to eliminate
the release of plastic waste from land-based sources into the environment by 2040.9 This strategy
aligns with and supports EPA's National Recycling Goal to increase the U.S. recycling rate to 50
percent by 2030.

This is a domestic strategy that identifies strategic objectives and voluntary actions where EPA
can work collaboratively with U.S. stakeholders to prevent plastic pollution through initiatives that
reduce, reuse, collect, and capture plastic and other waste from land-based sources. The proposed
actions under each objective create opportunities to shift from a linear approach in plastic materials
management to a circular system that is restorative or regenerative by design, enables resources to
maintain their highest value for as long as possible, and aims for the elimination of waste.

EPA is promoting circular economy policies while excluding processes that convert solid waste to
fuels, fuel ingredients, or energy from being considered as a recycling practice in the Draft National
Strategy to Prevent Plastic Pollution and the implementation of the National Recycling Strategy.

EPA's National Recycling Strategy primarily focused on mechanical recycling of municipal solid waste
but welcomed further discussion on technologies often referred to as "chemical recycling," such as
pyrolysis. EPA now understands that some of these technologies, produce fuels and/or intermediate
materials used in the manufacturing or processing of fuel or fuel substitutes. EPA reaffirms that
the Agency does not consider activities that convert non-hazardous solid waste to fuels or fuel
substitutes ("plastics-to-fuel") or for energy production to be "recycling" activities.10 EPA also aims to
ensure that a U.S. circular economy approach for plastic products reduces greenhouse gas emissions
and protects overburdened communities from facilities that can increase the generation of hazardous
waste and other forms of pollution. Additionally, EPA is aware of concerns about the potential health
and environmental risks posed by impurities that may be present in pyrolysis oils generated from
plastic waste. Accordingly, EPA intends to require companies submitting new pyrolysis oil chemicals
to the Agency for review under TSCA to conduct testing for impurities that could be present in the
new chemical substance prior to approval, and ongoing testing to ensure there is no variability in the
plastic waste stream that is used to generate the pyrolysis oil.

9	U.S. Submission UNEP's Intergovernmental Negotiating Committee on plastic pollution (INC-2)
https://wedocs.unep.orq/bitstream/handle/20.500.11822/41810/USsubmission.pdf?sequence=1&isAllowed=y

10	See EPA's 1997 Measuring Recycling: A Guide for State and Local Governments
https://archive.epa.qov/wastes/conserve/tools/recmeas/web/pdf/quide.pdf


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Sea-based sources are not in the scope of this strategy. The Save Our Seas 2.0 Act, however,
requests several reports on various aspects of sea-based sources, which are currently under
development. Additionally, we note that NOAA has several programs to address sea-based sources,
which are described in depth at the following website: https://marinedebris.noaa.gov/.

Solid Waste vs. Trash

This strategy uses both the term "solid waste" and "trash" in different parts of the document
because those terms are used by different groups of professionals that manage plastic waste in the
waste management system or when it ends up in waterways.

Solid waste, as defined by the Resource Conservation and Recovery Act, means any garbage or
refuse; sludge from a wastewater treatment plant, water supply treatment plant, or air pollution
control facility; and other discarded material resulting from industrial, commercial, mining, and
agricultural operations and from community activities. This term is commonly used in sectors that
collect, recycle, and dispose plastic waste.

Trash is not defined by statute but is commonly used in water management programs to mean any
persistent solid material that is manufactured or processed and has been disposed of or abandoned
in the environment. Trash, though typically intended to be contained via waste management
systems, may end up polluting the water environment because of littering, unintentional spillage, or
other means.


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Objective A. Reduce Pollution During
Plastic Production

Most plastic products found in the environment are items that are single-use, unrecyclable, or
frequently littered. To minimize the associated environmental impacts of these plastics it is essential
to reduce the increasing rates of both plastic production and consumption in the United States and
to address pollution that occurs along the life cycle of plastics products. It is also important to reduce
impacts from the production of materials, which can negatively impact the environment and human
health, especially in disadvantaged or underserved communities with environmental justice concerns.

A1. Reduce the production and consumption of single-use,
unrecyclable, or frequently Ittered plastic products.

Various policy approaches should be employed to encourage stakeholders to reduce the production
and use of single-use, unrecyclable, or frequently littered plastic products.

A1.1: Identify single-use, unrecyclable, or frequently littered plastic products and identify
alternative materials, products, or systems with fewer impacts on the environment.

Identifying and communicating the types of products with adverse environmental impacts
could help shift consumption away from these products. To this end, a list of single-
use, unrecyclable, difficult to recycle, or frequently littered plastic products that may be
reduced or eliminated should be developed that can be integrated within company,
government, and organizational purchasing policies and procurement guidelines. This
list should be shared widely with the public for use. Where possible, also consider
alternative materials or delivery systems (e.g., product as a service) that could minimize
environmental impacts.


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A1.2: Develop a plan to reduce single-use products across the federal government.

To reduce negative environmental impacts and costs, the federal government should
identify opportunities to reduce single-use, unrecyclable, difficult to recycle, or
frequently littered products that it procures and evaluate pathways to phase out single-
use, unrecyclable, or frequently littered products, utilizing the information identified
in A1.1. The EPA should recommend specifications, standards, ecolabels, or other
mechanisms that the federal government can leverage in the acquisition process to
reduce its plastics footprint. The federal government should provide these resources
to the federal acquisition workforce on a new or existing sustainable purchasing tool
to identify products or delivery systems that can replace single use products, such as
GSA's Green Procurement Compilation or Sustainable Facilities Tool (SFTool). EPA also
produces "Recommendations of Specifications, Standards, and Ecolabels" to help federal
purchasers identify and procure environmentally preferable products and services.

A1.3: Create an innovation challenge program to develop alternatives to single-use,
unrecyclable, or frequently littered plastic products.

An innovation challenge program would promote and encourage the development of
innovative alternatives to single-use, unrecyclable, or frequently littered plastic products.
For instance, Section C of the Save Our Seas 2.0 Act establishes the Genius Prize for Save
Our Seas Innovations (Save Our Seas 2.0 Act, 2020). The Genius Prize prioritizes projects
that advance solutions that can help decrease plastic marine debris. A similar innovation
challenge program could be supported through various funding opportunities across the
federal government and through public-private partnerships.

A1.4: Identify effective policy tools and approaches to reduce production of single-use,
unrecyclable, or frequently littered plastic products.

Policymakers at all levels of government need to understand the impact that various
policy tools and approaches have on the production of single-use, unrecyclable, or
frequently littered plastic products, as well as the resulting environmental, economic, and
social impacts. The federal government should conduct a study or literature review to
identify effective policy tools and approaches and share the results broadly.

A1.5: Set a new goal to reduce the production of single-use, unrecyclable, or frequently
littered plastic products.

Setting a new national voluntary goal to reduce the production of single-use,
unrecyclable, or frequently littered products identified in A1.1 is needed. This new
goal would help galvanize action across the country, support and promote the use of
alternative products and reuse programs.


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A2. Minimize pollution across the life cycle of plastic products

Manufacturers have a pivotal opportunity to design products and systems that have fewer negative
human health and environmental impacts throughout the life cycle. Manufacturers must ensure that
their plastic production operations meet relevant environmental regulatory standards at the federal,
state, Tribal and local levels. They also have an opportunity to further reduce pollution from plastic
production operations.

A2.1: Increase the availability of data on plastic products produced and perform life cycle
assessments to better understand the health, environmental, social, and economic
impacts of plastic products and their alternatives.

More data are needed to understand plastic production and the impacts of plastic
products across their life cycle. Life cycle assessments (LCAs) can improve understanding
of the health, environmental, social, and economic impacts of products across the lifespan
from production to end of life. LCAs are excellent tools for determining the valuation and
externalities of plastic products. Conducting LCAs and making the data publicly available
to companies, communities, and other organizations for consideration and decision-
making is critical. Specific attention should be given to areas where gaps exist in our
understanding of plastic products and alternative materials (e.g., paper, glass, cardboard,
metal) and where vulnerable communities are impacted.

A2.2: Review, develop, update, and use sustainability standards, ecolabels, certifications, and
design guidelines that decrease the environmental impacts of plastic products across
their life cycle.

Standards, ecolabels, certifications, and design guidelines can be designed to promote
circularity and decrease negative environmental and human health impacts. A review
and gap analysis of existing standards, ecolabels, certifications, and design guidelines
is needed to identify areas where additional standards are necessary (or where existing
standards may need to be strengthened) to decrease negative environmental impacts
across the life cycle of plastic products. As part of this review, identification of common
data fields that online purchasing platforms can use to accurately identify products that
meet the standards, ecolabels, certifications, and design guidelines is needed to avoid
inaccurate labeling on online purchasing platforms and greenwashing. Furthermore,
appropriate methods and standards for the determination of chemicals of concern,
including PFAS, could be established for recycled content to ensure protection of human
health and the environment.


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A2.3: Review and improve government purchasing criteria to reduce life cycle environmental
impacts from plastic products in government purchasing.

Governments often use purchasing criteria to guide how they should make purchasing
decisions. Criteria should be evaluated to ensure that the government is purchasing
sustainable products, including products that have recycled content or can be reused.
EPA's Comprehensive Procurement Guidelines (CPG) program establishes recommended
minimum recycled content levels for certain categories of products purchased by the
federal government (U.S. EPA, 2023). As directed in the 2021 Infrastructure Investment
and Jobs Act, EPA should continue to periodically review the CPGs to determine if
changes are warranted. EPA can also consider leveraging the CPG program to develop
a registry of applicable products that meet the minimum recycled content levels, which
would help purchasers in easily finding and purchasing the compliant products.

Other procurement standards and guidelines should also be reviewed and improved,
where needed, to reduce the life cycle environmental impacts from government
purchasing. Extended producer responsibility (EPR) approaches for key products and
materials should also be explored for potential use in government purchasing criteria to
further decrease the volume of solid waste that must be treated, stored, or disposed.

A2.4: Conduct evaluations to ensure that production facilities within the plastic sector are in
compliance with applicable federal, state, Tribal and local regulatory requirements.

Consistent implementation and enforcement of regulations at all levels of government
can reduce or prevent environmental and human health risks posed by existing or
proposed new plastic production facilities, particularly those that use or release toxic or
other harmful chemical or additives. Various instruments and approaches can be used
to ensure compliance with regulatory requirement and the need to ensure careful and
full evaluation of any proposed new facilities or expansions of existing facilities, under all
applicable requirements as follows:

A2.4a: For existing facilities in the plastic sector and facilities producing inputs used
by the plastic sector, examine existing authorities, policies, and actions to
determine how they could be adjusted or built upon to avoid and reduce
negative environmental or human health impacts, including safety threats like
chemical leaks, fires, and explosions.

A2.4b: Review and update, as appropriate, regulations relating to air emissions and
water discharges of pollutants or waste disposal from plastic production and
recycling facilities, and other health and safety measures, including regulation
of the production and transport of plastic pellets. In addition, work across the
federal government to prevent accidental releases of hazardous chemicals
related to plastic production into the environment during transit.


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A2.5: Map existing and proposed plastic production facilities, as well as evaluate their
environmental justice and public health impacts on neighboring communities.

The locations of existing plastic production and recycling facilities and proposed
new facilities should be mapped to analyze potential disproportionate impacts on
disadvantaged and vulnerable communities, including air toxics and other air emissions,
as well as water and waste impacts. Tools, such as EPA's Environmental Justice Screening
and Mapping Tool ("EJScreen 2.0), the Council on Environmental Quality's Climate
and Economic Justice Screening Tool (CEJST) or Center for Disease Control's Social
Vulnerability Index, are available, and the analysis of potential impacts should also make
use of other tools, research, information from environmental monitoring, and feedback
received from impacted or potentially impacted communities.

A2.6: Develop methods to measure reductions in greenhouse gas emissions from the life cycle
of plastic products and alternative materials as part of meeting global, national, and
state greenhouse gas emissions goals.

A full understanding of the link between the production, use, recycling, and disposal of
various types of plastic products and associated greenhouse gas emissions are important
to addressing climate change. Policymakers must also understand the environmental
trade-offs that result from the use of alternative materials. Methods need to be developed
to better understand and measure any reductions in greenhouse gas emissions
associated with the use of alternative materials or products, and more greenhouse gas
data needs to be made available. Existing models, such as the U.S. Environmentally-
Extended Input-Output Model and EPA's Waste Reduction Model (WARM) or Federal
Life Cycle Assessment (LCA) Commons, should be used to support life cycle analyses of
environmental impacts of plastic products and their alternatives.

A2.7: Coordinate domestic and international interests to support the development of
international standards, including product labelling, to increase the circularity of
plastic products.

Adopting and further refining
international standards for circularity
will help support sustainable trade
efforts and will reduce barriers to
achieving a more circular economy.

Product labelling is often included
in product standards and can be an
important lever for communicating
product recyclability and transparency
about chemicals in products. The
United States should continue
to support the development of
international standards to increase the
circularity of plastic products.


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Objective B. Improve Post-Use Materials
Management

The United States should employ more circular approaches to reduce the life cycle environmental
impacts of plastic products. While EPA's National Recycling Strategy extensively identified actions to
improve the U.S. recycling system, further increases in circularity can be achieved by developing:

>	Reuse systems for plastic and alternative products,

>	Composting systems for certified compostable materials, and

>	Increased public outreach and education on proper management.

Promoting product use to its fullest extent equates to cost savings for consumers, as well as
reductions in the amount of waste disposed of in landfills and in greenhouse gas emissions from
production. Where waste disposal is necessary, it should be done in a manner that minimizes impacts
to human health and the environment.

B1. Conduct a study of the effectiveness of existing public policies
and incentives upon the reuse, collection, recycling, and
conservation of materials.

State, territorial, tribal, and local governments have implemented policies that have been effective
at increasing the reuse, collection, recycling, and conservation of materials. Extended producer
responsibility policies and deposit refund schemes are two examples of policies that have been
effective at achieving circularity goals in some jurisdictions at the state and local levels. A study
is needed to assess the effectiveness of existing public policy frameworks to investigate, identify,
and share best practices in programs and policies aimed to increase reuse or refill, collection, and
recycling efforts. This study can then be used to inform the development of recommended actions.

)cus on

J*


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reducing single-use, unrecyclable, and frequently littered items, while also providing job
opportunities for the local community.

B2.2: Research and identify obstacles to reuse and propose innovative, viable solutions.

Faced with large volumes of mixed plastic waste that has little or no market value, many
jurisdictions are assessing existing and new avenues to support reuse where appropriate.
This action promotes continued work to identify obstacles and friction points that limit the
viability of reuse systems, identify possible existing solutions, as well as to encourage new
innovative solutions to those obstacles.

B3. Facilitate more effective composting and degradation of certified
compostable products.

Certified compostable products can replace plastic products in some cases. However, composting
programs and infrastructure are not readily available across the United States, and not all
composting facilities accept or can effectively process certified compostable products. Furthermore,
consumers and businesses need to be educated on how to properly source and separate certified
compostable products and where they can effectively compost those products.

B3.1: Evaluate maps of available composting infrastructure and determine infrastructure

needs, including considerations for communities with environmental justice concerns.

To expand access of composting programs to more communities, a gap and needs
assessment should be conducted by examining existing maps of available municipal
composting infrastructure. This should include considerations for the needs of
communities with environmental justice concerns. Several resource maps have been
developed and are publicly available that show both opportunities and constraints in
composting capabilities and capacities. For instance, GreenBlue (2023) has developed an
interactive map that tracks composting facilities throughout the United States (including
location and types of packaging accepted). The U.S. Composting Council (2023) also
maintains an interactive map of facilities that produce compost certified under the Seal
Testing Assurance Program.

B3.2: Research the use and environmental impacts
of certified compostable plastic products.

Certified compostable products can have
adverse environmental impacts as they are
no less prone to being littered or "leaked"
into the environment. These products are
designed to break down under controlled
conditions, such as in industrial composting
facilities, not in the natural environment.

Case studies and research can be used
to determine the life cycle environmental
impacts of these products and to identify


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the barriers composting facilities face with regards to accepting certified compostable
products. Such a study could also identify the changes in product design, collection,
or policy needed to reduce the life cycle environmental impacts of these products
and ensure that they are managed soundly Releases of micro/nanoplastics should be
considered.

B3.3: Provide funding to improve composting capacity for communities within the United
States that have a greater need for support.

Improving the capacity of communities to participate in composting programs is an
important component of the circular economy for all compostable products. Both federal
funding and private sector leveraging of funds are needed to help establish composting
opportunities across the United States, with a specific focus on opportunities to provide
support for disadvantaged and rural communities.

B3.4: Review and, if needed, update compostable product standards to ensure that certified
and labeled products fully decompose in composting facilities and do not negatively
impact the composting process or the quality of the final compost product.

Contamination can be a major problem in the quality of final compost products. Plastic
products can contaminate compost, resulting in plastic and microplastic pollution when
compost is applied to the soil. Compostable product standards are necessary to prevent
contamination from entering the system. Ensuring that products perform as intended
is important to maintaining quality assurance across the composting process and in
final products. For example, experts could develop and share best practices for testing
compostable products to reduce plastic contamination in compost.

B3.5: Evaluate claims made by companies about the degradability of plastic products to
eliminate "greenwashing" and misleading claims by marketers.

Degradability claims are sometimes included on products that are not degradable.

Claims should be evaluated in conjunction with "truth in labeling" efforts addressed
in the Federal Trade Commission's Guides for the Use of Environmental Marketing
Claims ("Green Guides") and in Action B5.2 below. Concerns related to the inadequate
documentary standards, definitions and greater accountability with such claims need to
be appropriately addressed.

B3.6: Identify gaps in the measurement of composted materials and develop methodologies
for consistent, harmonized measurement.

Gaps exist in the understanding of compostable products and the extent to which
products break down under recommended conditions. Materials which could be deemed
compostable may in fact cause contamination in home and industrial composting
systems. A systematic series of studies that include real-world conditions at commercial
composting facilities can help to better measure, understand the variations, and make
recommendations for different and improved compostable products.


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B4. Increase solid waste collection and ensure that solid waste

management does not adversely impact communities, including
those overburdened by pollution.

Effective collection decreases the leakage of plastic products. Improvements are needed in some
solid waste collection bins and trucks to ensure that plastic waste does not leak once collected.
Increased collection of plastic waste is needed in hotspots for plastic pollution.

B4.1: Increase awareness and availability of public and private sector funding for

improvements to recycling and collection programs, and strategies for accessing this
funding.

Grants, such as those provided by the Solid Waste Infrastructure for Recycling grant
program authorized by the Save Our Seas 2.0 Act, can be used to support improvements
in local post-consumer materials management and infrastructure and recycling programs
and to assist local authorities in making improvements to municipal waste management
systems. Funding support for communities where recycling collection rates may be low,
specifically in rural or minority populations, can have a positive impact on the reduction of
plastic waste. Use the environmental justice analysis results from Action B4.4 to inform the
design and implementation of this action to reduce disparities in resource management
infrastructure, funding, technology, and access.

B4.2: Fund research, development, demonstration, and deployment of technologies and

processes that ensure that collected waste enters and stays in the waste management
system.

Successful management of waste requires equipment supporting collection and
transportation that is able to keep the waste contained and that is placed in ways that
encourage people to use it. Funding for social/ behavioral research could identify the
ways that equipment could be improved to promote use, while funding for technological
research could identify new innovative equipment that ensures that waste stays contained
once collected. Use the environmental justice analysis results from Action B4.4 to
inform the design and implementation of this action to reduce disparities in resource
management infrastructure, funding, technology, and access.

B4.3: Develop guidance and recommendations for efficient, cost-effective, and locally
appropriate solid waste collection techniques.

Guidance and recommendations are needed for efficient, cost-effective, and locally
appropriate solid waste collection techniques that encourage proper disposal and
prevent loss, including recommendations for bin placement, bin containment systems,
and bin labeling. Use the environmental justice analysis results from Action B4.4 to
inform the design and implementation of this action to reduce disparities in resource
management infrastructure, funding, technology, and access.


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B4.4: Perform an environmental justice assessment for non-hazardous solid waste

management facilities, including recycling facilities, incinerators, landfills, and chemical
recycling facilities, and for other emerging or novel processes.

As other actions in this strategy are taken, it is important to actively assess the
environmental and health burdens that new and existing waste management facilities
impose on surrounding communities, including communities with environmental justice
concerns. Understanding potential impacts allows EPA to discourage or disincentivize
any technologies or processes that: (i) increase air pollution; (ii) increase the generation
of hazardous wastes; (iii) fail to use a circular economy approach that is restorative or
regenerative by design; or (iv) maintain or increase pollution in communities that are
already overburdened. It also allows EPA to work closely with potentially impacted
communities to address environmental and health concerns. This analysis would be
done in conjunction with Action B1.3 ("Conduct an environmental justice assessment
of non-hazardous solid waste management infrastructure in the U.S.") of EPA's National
Recycling Strategy. Tools, such as EPA's Environmental Justice Screening and Mapping
Tool (EJScreen 2.0), the Council on Environmental Quality's Climate and Economic
Justice Screening Tool (CEJST) or Center for Disease Control's Social Vulnerability Index,
are available, and the analysis of potential impacts should also make use of other tools,
research, information from environmental monitoring, and feedback received from
impacted or potentially impacted communities..

B4.5: Assess the social costs of plastic waste (including
litter cleanup) and how those costs could be
reduced via reduction/prevention solutions.

Analyze the social costs of non-hazardous
solid waste, particularly plastic waste, to assess
causes, outcomes, and potential waste reduction
solutions and to address concerns related to
environmental justice.

B4.6: Explore the development of an accredited,

voluntary third-party certification program for plastic recyclers to increase the safe and
effective management of plastic recyclables in the United States.

Such certification systems have been successful in safely managing other materials, such
as used electronics. The certification system should address multiple aspects of sound
recycling, including ensuring that exports of plastic waste and scrap follow applicable
domestic and international law. Once launched, develop tools and materials that
encourage governments at all levels, American public, businesses, states, territories, and
tribal nations to use certified recyclers. Involve States, territories, tribal nations, NGOs and
other stakeholders on the key elements of program development.


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B4.7: Standardize measurement and increase data collection.

Standardized measurement methods, standardized definitions, and additional data are
needed to improve the estimates of non-hazardous solid waste collected, managed,
imported, and exported, as well as the amount that escapes the solid waste management
system into the environment. This action would be performed in conjunction with
Objective E ("Standardize measurement and increase data collection") of EPA's National
Recycling Strategy.

B5. Increase public understanding of the impact of plastic

mismanagement and how to appropriately manage plastic
products and other waste.

Consumers play a pivotal role in determining how plastic products are used and disposed of.
To reduce the amount of plastic and other waste that ends up in waterways and oceans, it is
essential to gain a better understanding of how messaging is perceived by consumers and to make
improvements in messaging.

B5.1: Identify effective ways to increase public understanding of waste reduction, materials
reuse, and composting options.

Clear and persuasive public communication can help modify behavior and result in
increased waste reduction, reuse, and composting. National messaging around these
behaviors can be developed, building on Action C1 ("Enhance education and outreach
to the public on the value of recycling and how to recycle properly") in EPA's National
Recycling Strategy, as well as on recycling education and outreach grants funded by the
2021 Infrastructure Investment and Jobs Act. Recommended approaches for improving
messaging consistency and effectiveness include:

B5.1a: Develop common messages about reduction, reuse, and composting,

especially for targeted priority materials, such as single-use, unrecyclable, and
frequently littered materials.

B5.1b: Develop a national program to educate the public about reduction, reuse, and
composting. Enlist the assistance of traditional and social media, governments,
waste haulers, and product manufacturers to disseminate messaging that is
contextually relevant across diverse groups and geographies.

B5.2: Increase awareness among businesses of the Federal Trade Commission's Guides for the
Use of Environmental Marketing Claims ("Green Guides").

FTC's Green Guides provide guidance to businesses on how to make non-deceptive
environmental claims with considerations for consumer perception of those claims.
Specifically, the Green Guides state marketers should not claim their products are
"recyclable" unless recycling facilities for those products are available to a substantial
majority of consumers or communities where the item is sold. Businesses should make
greater use of the Green Guides to make truthful claims. Efforts to increase awareness of
the Green Guides and the consequences of deceptive environmental claims should also
be initiated with federal suppliers.


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B5.3: Review plastic resin identification codes to determine if changes are needed to reduce
confusion around the recyclability of plastic products.

Governments and organizations at different levels have been reviewing the use of resin
identification codes. This work should ensure that the codes used reflect the purpose
for which they were created and do not perpetuate consumer confusion around what is
recyclable.

B6. Explore possible ratification of the Basel Convention and
encourage environmentally sound management of scrap and
recyclables traded with other countries.

B6.1: Support the Basel Convention.

Some countries continue to strengthen their recycling and waste management systems
and may face challenges to ensure that scrap and recyclables are managed in an
environmentally sound manner, especially in communities with environmental justice
concerns. The Basel Convention requires parties to control the transboundary movements
of certain materials and hazardous wastes covered by the treaty and to take measures
to prohibit certain exports if parties have reason to believe the exports would not be
managed in an environmentally sound manner. Plastic scrap and waste amendments were
adopted by Parties to the Basel Convention in 2019 to control exports and imports of
most plastic scrap and waste. As a result of these changes, transboundary movements of
most plastic scrap and waste to countries party to the Convention are allowed only with
the prior written consent of the importing country and any transit countries, a process
known as prior notice and consent. The amendments took effect on January 1, 2021.

Currently, EPA has authority under the Resource Conservation and Recovery Act to
control transboundary movements of most hazardous recyclables and waste, but not
all waste controlled under the Basel Convention on the Control of Transboundary
Movements of Hazardous Wastes and Their Disposal.11 The United States signed the
Basel Convention in 1990, and the Senate gave its advice and consent to ratification in
1992. The United States should explore options for strengthening U.S. participation in the
Basel Convention, including options that would enable ratification.

B6.2: Encourage environmentally sound management practices to support protection of
human health and the environment.

The United States supports environmentally sound management of scrap and recyclable
materials. In conjunction with exploring options for strengthening U.S. participation in
the Basel Convention, EPA should identify ways to enhance practices to ensure that
environmentally sound management of scrap and recyclable materials can benefit circular
economy approaches.

11 See Basel Convention on the Control of Transboundary Movements of Hazardous Wastes:

https://www.unep.orq/resources/report/basel-convention-control-transboundary-movements-hazardous-wastes


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Objective C. Prevent Trash and Micro/
Nanoplastics from Entering Waterways and
Remove Escaped Trash from the Environment

Interventions are necessary to prevent littering and to ensure that trash (including plastic waste) and
microplastics do not enter waterways. Such interventions could include implementing programs to
reduce littering and illegal dumping; installing trash-capture technologies to collect and remove
trash from stormwater, wastewater,, and surface waters; and increasing street sweeping to remove
trash before it is carried by stormwater or wind into waterways. Efforts to manage escaped trash can
be hindered by a lack of reliable data on the amount and type of trash in domestic waterways and
the areas of concentration. A greater understanding of the sources, pathways, and sinks of trash in
communities across the United States would help decision-makers prioritize intervention options
and maximize the impact of litter prevention and removal efforts. It would also help decision-makers
address important equity and environmental justice concerns.

Similarly, interventions to reduce micro/nanoplastic emissions into the environment are needed to
address potential risks to human and ecosystem health, particularly given the expected increase
in plastic production over the coming years. Micro/nanoplastics include those that result from
the degradation of plastic waste as well as microplastics that enter the environment already in
microplastic form (such as microbeads, microfibers, and plastic pellets). Significant knowledge gaps
currently exist about the sources, fate, and impact of these particles in the lithosphere, hydrosphere,
and atmosphere and about the source-pathway-sink relationships influencing such transport.

C1. Identify and implement policies, programs, technical assistance,
and compliance assurance actions that effectively prevent trash/
micro/nanoplastics from getting into waterways or remove such
waste from waterways once it is there.

C1.1: Conduct analyses on the cost, effectiveness, and equity of policies/programs addressing
the problems of litter, illegal dumping, and unintentional spillage of trash, in particular in
disadvantaged and vulnerable communities.

Stakeholders need to understand the likely cost
ranges, effectiveness, and equity ramifications
for different policies and programs addressing
litter, illegal dumping, and unintentional trash
spillage that different levels of government could
potentially institute to address the problem of
trash in waterways. A better understanding of
the implications of various policy options wili
allow governments to be more effective, fair, and
efficient in their policy choices. Environmental
justice analyses, such as proposed in A2.5 above,
of policy options should be considered wherever possible.


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C1.2: Explore expanded use of Clean Water Act authorities to significantly reduce trash
loadings into waterways.

Implementation of regulatory tools can help reduce trash loadings in waterways. EPA,
in collaboration with select stakeholders, should comprehensively assess how existing
Clean Water Act programs can be more expansively and effectively utilized to address
trash loadings into waterways. Such programs could include National Pollutant Discharge
Elimination System (NPDES) permits, Total Maximum Daily Load development, water
quality standards, impaired waterbody listings, nonpoint source management plans,
effluent limitation guidelines, and pretreatment standards. An analysis of the effectiveness
of such programs in addressing trash should be conducted and the results conveyed to
those administering and implementing the programs.

C1.3: Provide technical assistance to include new or improved trash reduction/removal actions
and provisions in watershed plans, stormwater management plans, area management
plans, and other related plans.

Many watershed plans, stormwater management plans, and other area management
plans fail to effectively address trash removal and reduction, even where trash is a
problem for the watershed or other areas. To create more relevant plans to address
trash—or to do so more effectively—plan developers should seek assistance and
guidance from stakeholders with knowledge about local trash issues, including guidance
on effective actions and provisions that would address the main sources of the local trash
problem. Technical assistance should also include financial planning to identify funding
and finance options and incorporate trash capture infrastructure investments into asset
management planning. Communities that are already overburdened may need further
support to incorporate effective trash mitigation actions into existing plans.

9'


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accruing from effective trash capture systems should also be articulated and quantified
where possible to make a case to decision-makers for funding and installation of such
systems.

C2.2: Fund research, development, demonstration, deployment, and maintenance of existing
and new technologies and processes that capture trash or micro/nanoplastics in
waterways, stormwater, and wastewater.

The lack of dedicated funding is one of the most significant barriers to getting effective
trash capture systems in place. Research is also needed to inform the development of
capture technologies; for example, technologies to reduce micro/nanoplastics discharge
from commercial and residential washing machines should also be explored.

Funders should look expansively at creating and promoting funding programs
and mechanisms that can help meet trash and micro/nanoplastics capture needs.
Administrators of funding programs that could potentially fund trash and micro/
nanoplastics capture but that have been underutilized for that purpose should consider
prioritizing and/or promoting the use of those funding sources for the capital as well
as maintenance costs of trash and micro/nanoplastics capture technologies. Financial
support for research on the detection, capture, and (where viable) removal of trash or
micro/nanoplastics in stormwater, wastewater, terrestrial, freshwater/riverine, and marine
environment should also be addressed.

C3. Increase and improve measurement of trash loadings into
waterways to inform management interventions.

C3.1: Explore the possibility of a national tracking and reporting plan that would produce
estimates of the amounts, types, and locations of materials that enter waterways or
oceans.

A system for measuring and monitoring
loadings of trash, especially plastic waste,

U.S. waterways would be helpful to suppoi
the development of effective and targeted
mitigation strategies. Federal agencies
(in collaboration with stakeholders from
academia, the private sector, and NGOs)
should lead efforts to design a tracking
and reporting plan for trash loadings into
U.S. waterways on a national scale. U.S.
government agencies should coordinate
with international bodies, as appropriate,
to ensure that any national data tracking
and reporting plan produces data that are
consistent with international efforts.


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C3.2: Evaluate opportunities for using more precise modeling approaches to establish a

baseline for the amounts and types of materials that escape into U.S. waterways and
oceans.

Obtaining reliable baseline measurements of the amounts of trash in waterways and
oceans is critical for measuring the success of mitigation efforts and interventions over
time. Some researchers have already developed models that could be used to estimate
the amounts of various types of trash that escape into waterways, but the accuracy of
these models could be improved with more refined modeling approaches, better data, or
both. As appropriate, any approved national modeling approach should be incorporated
into the plan for tracking and reporting trash loadings into U.S. waterways, as described
in Action C3.1 above.

C3.3: Disseminate information on trash assessment protocols and the appropriate usage of
these protocols.

Many researchers, community groups, volunteers, and other stakeholders are engaged
in efforts to collect data on trash. However, stakeholders are not always aware of the
most appropriate protocol to use. EPA and its partners should endeavor to use multiple
communication channels to educate stakeholders about available assessment protocols,
including information about the appropriate usage for each protocol and how data from
different protocols might be effectively used. Stakeholders should be encouraged to use
trash assessment protocols as a standard part of their cleanup and trash capture efforts to
inform potential interventions.

C4. Increase public awareness of the impacts of plastic products and
other types of trash in waterways.

C4.1: Develop messaging and educational materials about the nature and impacts of trash
pollution and what targeted audiences can do to help address the problem.

As a complement to Action B5, which focuses on education on proper waste
management, there is a need for public outreach education efforts to reduce littering
and illegal dumping. High-quality, plain language education and outreach materials
should be developed or collected for use by educators, NGOs, and other stakeholders
across the country. Where available, litter survey data should be used to focus anti-
littering messaging for each geographic region on frequently littered items. Materials
could be provided in a variety of languages using multiple delivery methods. Equity
concerns should also be proactively addressed, and specific messaging appropriate for
communities with environmental justice concerns should be assessed and developed.


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C4.2: Research and disseminate information on successful outreach and education practices
and programs to motivate positive behavior change.

Stakeholders and partners who are positioned to drive behavior change, at the tribal,
state, and local, levels, often need support to develop successful outreach and education
practices and programs to reduce pollution. Stakeholders and entities should conduct
and compile research on best practices for outreach that maximize the chances of
producing positive behavioral changes. This information should then be disseminated
for use by organizations that are designing and implementing anti-littering campaigns
or other types of campaigns aimed at reducing trash pollution. A searchable central
repository for such information should be developed and maintained.

C4.3: Conduct campaigns using known best practices to raise public awareness of the trash
pollution problem and encourage behavior changes that reduce trash pollution.

Without more public awareness, the public will not engage in behaviors that avoid or
help reduce trash pollution. Interested parties should conduct outreach and education
campaigns aimed at reducing trash pollution in waterways through behavioral changes
such as properly disposing of trash and recyclables and reducing single-use plastic
consumption. Community-based social marketing and equity principles should be
adhered to wherever possible. Partnerships with schools, NGOs, and private entities
should also be considered, where appropriate, to support these efforts.

C5. Increase and coordinate research on micro/nanoplastics in
waterways and oceans.

C5.1: Conduct research and disseminate information on the sources, transport, fate,
concentrations, impacts, and remediation of microplastic pollution.

It is important to identify and categorize the major sources of micro/nanoplastics and
the pathways micro/nanoplastics take to enter waterways. Furthermore, identifying and
categorizing the major impacts of micro/nanoplastic pollution and effective remediation
methods are still critical needs, as are measuring and cataloguing microplastic
concentrations in domestic waterways and our oceans. Funders and researchers should
disseminate available information, as well as address remaining data gaps.

C5.2: Support the development of management practices and technologies to remove
microplastics (including microfibers) from effluent and waterways.

Funding and research are greatly needed to support the development of best
management practices (BMPs) and technologies to remove microplastics from waterways.
Wastewater treatment plant operators and stormwater planners would benefit from
comparative information on application of BMPs and about the efficiency with which
different treatment technologies remove microplastics of different types and sizes from
wastewater and stormwater. Active collaboration between government and the private
sector should be pursued for BMP and technology development.


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C5.3: Develop definitions for micro/nanoplastics and standardized methods for their
collection, extraction, quantification, and characterization.

Because there is no generally accepted definition for microplastics, data about
microplastics are not currently harmonized. Stakeholders should work collaboratively
to identify existing national and international micro/nanoplastics definitions, including
those for microfibers. It is also critical to develop standardized methods for collecting,
extracting, quantifying, and characterizing microplastics that appear in waterways (both
in the water column and in sediment) and in various media (e.g., drinking water, surface
water, indoor/outdoor air, soil, biota). These methods should be based on existing
microplastics research methods.


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Next Steps

EPA is opening a 45-day public comment period on this draft strategy. Due to the action-oriented
nature of the draft strategy and the need for commitments to execute it, EPA will continue outreach
and engagement during the comment period and the finalization of the strategy Implementation of
the strategy is expected to be an iterative process as resources, entities leading efforts, and needs
change over time. EPA intends to help facilitate the implementation of actions in the strategy and
will provide routine status updates to interested stakeholders.


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EPA Office of Resource
Conservation and Recovery


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