An Assessment of the U.S. Recycling
System: Financial Estimates to
Modernize Material Recovery
Infrastructure
August 2024
EPA 530-R-24-010
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Contents
Executive Summary ES-1
Methodology ES-2
Summary of Infrastructure Investment Estimates ES-2
Considerations ES-5
Section 1: Introduction 1
1.1 Report Purpose 1
1.2 Scope of Assessment and Key Definitions 1
Section 2: Financial Assessment and Estimates for Packaging Materials
2.1 Introduction and Overview 1
2.2 Methodology 1
2.3 Summary of Identified Infrastructure Stock and Gaps 4
2.3.1 Generation and Collection 4
2.3.2 Sorting and Processing 6
2.3.3 Recycling End Markets 8
2.4 Assessment of Financial Estimates 9
2.4.1 Generation and Collection 10
2.4.2 Sorting and Processing 16
2.5 Summary and Investment Considerations 18
Section 3: Financial Assessment and Estimates for Organic Materials 23
3.1 Introduction and Overview 23
3.2 Methodology 23
3.3 Summary of Identified Infrastructure Stock and Gaps 26
3.3.1 Generation and Collection 26
3.3.2 Sorting and Processing 27
3.3.3 Recycling End Markets 29
3.4 Assessment of Financial Estimates 30
3.4.1 Composting 32
3.4.2 Anaerobic Digestion 37
3.4.3 Livestock Feed 40
3.5 Summary and Investment Considerations 41
Section 4: Financial and Resource Support 46
4.1 Government Financing Options 46
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4.2 Private Sector Financing 48
4.3 Public-Private Partnership 48
4.4 Fee-Based Programs 49
Section 5: Additional Materials for Future Consideration 50
5.1 Electronics 50
5.2 Textiles 52
5.3 Plastics #3 to #7 53
Section 6: Summary and Beyond 2030 58
6.1 Summary of Infrastructure Investment Estimates 58
6.2 Beyond 2030 59
References 61
Appendix A. Packaging Material Recycling Opportunity Maps 68
Appendix B. Organic Material Recycling Opportunity Maps 72
Appendix C. Summary of Available Case Studies 74
C.l Introduction 74
C.2 Methodology 74
C.3 Overview of Case Studies 74
C.4 Addressing Needs for Specific Materials in Local Recycling Programs 76
C.5 Addressing Needs in the Recycling Process 77
C.6 Addressing Recycling Knowledge and Policy 78
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Executive Summary
As part of the Fiscal Year (FY) 2021 appropriations bill passed in December 2019, House Report 116-448
directs the Environmental Protection Agency (referred to as "EPA" or "the Agency" for the remainder of
this report) to "develop estimates of the infrastructure investment required to modernize the Material
Recovery infrastructure...[and] develop estimates for the amounts of investment needed to provide all
citizens with access to recycling services on par with access to disposal."1 In direct response, EPA
developed estimates of the total infrastructure investment required to modernize recycling
infrastructure, improve consumer recycling education, and provide all residents with equivalent access
to recycling services (i.e., opportunities to recycle are on par with trash disposal services, such as
residents having access to both curbside trash and curbside recycling services). The goal of these
investments is to achieve consistent collection across the nation and maximize the efficient recovery of
materials.
The U.S. recycling system faces significant challenges in improving recycling. A U.S. Government
Accountability Office (GAO) report published in December 2020 flagged several key challenges in
improving recycling in the U.S., which include the contamination of recyclables, low recycling collection
rates, limited market demand for recycled materials, low profitability for operating commercial recycling
programs, and limited information to support decision-making about recycling.2 In 2021, Congress
passed the Infrastructure
Investment and Jobs Act, also
known as the Bipartisan
Infrastructure Law (BIL), to fund
improvements to post-
consumer materials
management, infrastructure,
and recycling programs through
the Solid Waste Infrastructure
for Recycling (SWIFR) grant
program.3
To delineate the analysis scope,
summarized in Exhibit ES-1, EPA
focused on quantifying and
assessing the level of
investment needed to provide
all residents access to recycling
services on par with access to
Exhibit ES-1. Scope of Infrastructure Investment Assessment
Recyclable materials:
Ferrous metal cans
Nonferrous metal beverage
containers and aluminum foil
Paper
Cardboard/boxboard
Glass
Plastics #1 (PET)
Plastics #2 (HPDE)
Food waste
Yard waste
1 U.S. House of Representatives. 2021. House Report 116-448. Accessed online Sept. 2022: https://www.congress.gov/congressional-
report/116th-congress/house-report/448
2 U.S. Government Accountability Office. 2020. Recycling: Building on Existing Federal Efforts Could Help Address Cross-Cutting Challenges.
Accessed online Sept. 2021: https://www.gao.gov/products/gao-21-87
3 U.S. Congress H.R.3684- 117th Congress, 2021. Infrastructure Investment and Jobs Act. Congress.gov, Library of Congress. Accessed online
Jan. 2024: https://www.congress.gov/bill/117th-congress/house-bill/3684.
ES-1
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trash disposal, using the nation's 2030 50 percent recycling goal as a framework to measure success of
recycling investments. Specifically, EPA focused its analysis on:
• Packaging and organic recyclable materials as the combined tonnages of these materials
account for 82 percent of the municipal solid waste stream (MSW) and are therefore essential
targets in providing communities with access to recycling services on par with access to trash
disposal.4
• Proven, existing technologies to recycle these materials at a national level. This includes
mechanical technologies that process commonly-recycled materials (e.g., metals, plastics, paper,
and glass) through Material Recovery Facilities (MRFs) and biological technologies that process
organic materials (e.g., food waste and yard waste) as livestock feed and through composting
and anaerobic digestion facilities.5
Methodology
To develop investment estimates, EPA:
• Assessed the current stock of U.S. recycling infrastructure and identified associated gaps within
the recycling system that must be addressed to modernize infrastructure and provide all
residents with access to recycling services on par with access to trash disposal.
• Determined the level of investment needed to fill such gaps using secondary sources and a
thorough literature review of 125 documents published between 2015 and 2021 that focus on
key improvements and associated costs of improving the U.S. recycling system. Cost information
relies primarily on data from The Recycling Partnership's Paying It Forward report6, the Institute
for Local Self-Reliance's (in partnership with the National Recycling Coalition and Zero Waste
USA) American Recycling Infrastructure Plan,7 ReFED's Roadmap to 2030 report,8 and ReFED's
Insights Engine.9 EPA did not collect any primary data for this report.
• Conducted a series of interviews with U.S. recycling system stakeholders and experts to verify
research findings and refine cost estimates.
Summary of Infrastructure Investment Estimates
Based on available information, an estimated total investment of $36 to $43 billion, summarized in
Exhibit ES-2, would improve curbside collection, drop-off, and processing infrastructure (i.e., MRFs,
packaging material specific recycling facilities, composting, AD, and livestock infrastructure) by 2030.
This level of investment, which would leverage combined funding and financing mechanisms from
stakeholders across the entire recycling system including federal, state, and municipal governments, the
private sector, hybrid public-private partnerships, and fee-based programs, could lead to the potential
4 U.S. EPA. 2022. Guide to the Facts and Figures Report about Materials, Waste and Recycling. Accessed online Aug. 2022:
https://www.epa.gov/facts-and-figures-about-materials-waste-and-recvcling/guide-facts-and-figures-report-about
5 The report scope does not include recovery technologies that are not yet used at scale (e.g., plastics chemical recycling, which transforms
recycled plastic into a virgin-like resin).
6 The Recycling Partnership. 2021. Paying it Forward: How Investment in Recycling Will Pay Dividends. Accessed online Sept. 2021:
https://recvclingpartnership.org/read-paving-it-forward/
7 Institute for Local Self-Reliance (ISRI). 2021. "Recycling Infrastructure Plan Released." Accessed online May 2022: https://ilsr.org/recycling-
infrastructure-plan-rel eased/
8 ReFED. 2021. Roadmap to 2030: Reducing U.S. Food Waste by 50% and the ReFED Insights Engine. Accessed online May 2022:
https://refed.org/uploads/refed roadmap2Q3Q-FINAL.pdf.
9 ReFED. 2022. ReFED Insights Engine. Accessed online May 2022: https://insights.refed.org/? ga=2.257273867.1212413126.1660677635-
778134506.1657051175.
ES-2
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recovery of an additional 82 to 89 million tons of packaging and organic waste, a 91 percent increase in
recovery over current levels. This increased tonnage of recovered material could increase the nation's
recycling rate from its current level of 32 percent to 61 percent, allowing the U.S. to surpass the national
recycling goal of 50 percent set by EPA.10
Exhibit ES-2. Summary Education, Outreach, and Infrastructure Investment Cost Estimates.
Cost Category Low-End Estimate High-End Estimate
Packaging Materials
Curbside Collection
$19,900,000,000
$21,500,000,000
Glass Separation (Curbside)
$2,900,000,000
$2,900,000,000
Drop Off
$1,900,000,000
$3,400,000,000
Deposit Redemption System
$100,000,000
$100,000,000
Curbside + Dropoff
$21,800,000,000
$24,900,000,000
Curbside + Dropoff + Deposit Redemption System
$21,900,000,000
$25,000,000,000
Curbside + Dropoff + Glass Separation
$24,700,000,000
$27,800,000,000
Curbside + Dropoff + Glass Separation + Deposit Redemption System
$24,800,000,000
$27,900,000,000
Organic Materials
At-Home Composting
$380,000,000
$380,000,000
Community Composting
$4,700,000,000
$4,700,000,000
Centralized Composting
$8,700,000,000
$9,400,000,000
Centralized Anaerobic Digestion
$422,000,000
$436,000,000
Water Resource Recovery Facility (WRRF) Anaerobic Digestion
$77,000,000
$96,000,000
Animal Feed
$449,000,000
$504,000,000
Organics Total
$14,700,000,000
$15,500,000,000
Total Recycling Investment
$36,000,000,000
$43,000,000,000
Note: Low-end and high-end estimates are driven by various factors. For packaging, the low-end estimates assume
that facilities will not receive the latest technology upgrades (e.g., optical sorters, robotic arms, etc.) while the
high-end estimates assume that facilities will be upgraded or modernized with the latest technology, resulting in
higher capital costs. Technology upgrades would work to reduce contamination and improve recycling output
quality. For organics, the low-end estimates assume that not all existing facilities are operating at full capacity and
could intake a portion of the potentially recoverable materials, resulting in reduced capital costs. The high-end
estimate assumes that facilities will not operate any closer to full capacity and that comparatively more facilities
will need to be built, which will result in higher capital costs. Cost estimates do not factor in benefits associated
with recycling, including potential revenue from the sale of recycled commodities, GHG emissions and pollutant
reduction, conservation of landfill space, etc.
10 U.S. EPA. 2018. National Overview: Facts and Figures on Materials, Wastes and Recycling. Accessed online Aug. 2022:
https ://www. epa .gov/facts-a nd-figures-a bout-mater ia Is-waste-a n d-recvcl i n g/nationa l-overvi ew-facts-a nd-figures-
materials#:~:text=The%20recvcling%20rate%20(including%20composting,person%20per%20dav%20for%20recvcling.
ES-3
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1
Cost Category
Low-End Estimate
High-End Estimate
Estimated using:
(1) Eunomia. 2021. The 50 States of Recycling. Prepared for the Ball Corporation.
(2) U.S. Census Bureau. 2022. 2019 American Community Survey.
(3) State waste management reports.
(4) The Recycling Partnership. 2021. Paying it Forward: How Investment in Recycling Will Pay Dividends.
(5) U.S. EPA Office of Resource Conservation and Recovery. 2020. 2019 Wasted Food Report.
(6) U.S. Census Bureau. 2022. 2019 American Community Survey.
(7) Natural Resources Defense Council. 2017. Estimating Quantities and Types of Food Waste at the City Level. Accessed online May 2022:
https://www.nrdc.org/sites/default/files/food-waste-citv-level-report.pdf.
(8) ReFed. 2016. A Roadmap to Reduce U.S. Food Waste by 20%: Technical Appendix. Accessed online May 2022:
https://refed.org/downloads/ReFED Technical Appendix.pdf.
(9) The Recycling Partnership. 2021. Paying it Forward: How Investment in Recycling Will Pay Dividends. Accessed online Sept. 2021:
https://recvclingpartnership.org/read-paving-it-forward/
(10) U.S. Composting Council. 2021. "Organics Bans and Mandates." Accessed online May 2022: https://www.compostingcouncil.org/page/organicsbans.
(11) U.S. Composting Council. The Case for Centralized Compost Manufacturing Infrastructure. Accessed May 2022.
(12) U.S. EPA. 2021. Anaerobic Digestion Facilities Processing Food Waste in the United States (2017 & 2018). Accessed online May 2022:
https://www.epa.gov/sites/default/files/2021-02/documents/2021 final ad report feb 2 with links.pdf.
(13) Interviews with industry experts.
To modernize recycling infrastructure, improve consumer recycling education, and provide all residents
with equivalent access to recycling services, the investments would need to address identified gaps in
recycling infrastructure across all stages in the U.S. recycling system:
• Generation and collection: Currently, access to recycling services is not equivalent to that of
trash disposal services. Roughly 40 percent of households do not have access to recycling
services for packaging materials equivalent in quality to trash disposal services and roughly 91
percent of households do not have access to recycling services for organic materials equivalent
in quality to trash disposal services (e.g., residents have curbside trash collection but must take
packaging materials/organic materials to a drop-off center to be recycled).11,12
• Sorting and processing: The current U.S. packaging and organic materials sorting and processing
universe includes approximately 10,000 facilities that currently recycle 65 million tons of
material.13 While some facilities have been recently updated with the latest sorting and
processing technology and have expanded capacity, many facilities still require technological
updates to streamline the sortation process and more efficiently address contamination of
incoming materials. In addition, there are many regions of the U.S. with few or no recycling
facilities.
• End markets: A successful recycling system requires robust end markets to accept processed
materials. The U.S. recycling market currently includes around 200,000 facilities that can directly
use the end product produced from the recycling process for input in material manufacturing or
operations.14 Currently, few existing policies and economic incentives exist to encourage the use
of recycled materials in production and operation and support end market development.
In addressing the identified gaps in the recycling system, investments in education, collection, and
processing capacity should be made simultaneously, along with policies to disincentivize landfilling
materials (e.g., pay-as-you-throw programs) and to promote the use and sale of recycled material (e.g.,
11 The Recycling Partnership. 2021. Paying it Forward: How Investment in Recycling Will Pay Dividends. Accessed online Sept. 2021:
https://recvclingpartnership.org/read-paving-it-forward/
12 GreenBlue. 2022. Mapping Urban Access to Composting Programs. Accessed online May 2022:
https://greenblue.org/work/compostingaccess/.
13 U.S. EPA. 2022. Recycling Infrastructure and Market Opportunities Map. https://www.epa.gov/circulareconomv/recvcling-infrastructure-and-
market-opportunities-map.
14 U.S. EPA. 2022. Recycling Infrastructure and Market Opportunities Map. https://www.epa.gov/circulareconomv/recvcling-infrastructure-and-
market-opportunities-map.
ES-4
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minimum post-consumer recycled content mandates). Recycling programs across the U.S. can leverage
financing mechanisms such as private equity, public-private partnerships, and government grants to
fund investment in such recycling projects and programs.
Considerations
While the expansion of recycling infrastructure is needed nationwide, there are select regions,
specifically the South, Southwest, and Rocky Mountains, with high rates of potentially recyclable
material and a general lack of recycling infrastructure.15 It may be beneficial to focus initial investments,
including investments in education and outreach to motivate behavior change, in these areas using
proven technology and infrastructure as they represent high-need, high-reward regions. Exhibit ES-3
shows opportunities for potentially high glass recovery in dark blue. (Additional packaging materials
maps can be found in Appendix A.) Exhibit ES-4 shows opportunities for organics recycling, shown in
dark green.
Beyond 2030, recycling assessments will need to expand to include materials beyond conventionally
recycled packaging and organics, such as electronics, textiles, and plastics #3 to #7. These assessments
should include thoughtful consideration of how to maximize source reduction and promote reuse, as
well as how best to upgrade and integrate infrastructure required for recycling. In addition, future
analyses should align with circular economy considerations. Currently, the U.S. has a linear material
supply chain involving extraction, use, and disposal. A more circular economy would provide more
meaningful and lasting waste reduction as it recaptures waste and uses it as a valuable input for
manufacturing. This type of system is not only oriented toward lifecycle impacts of materials but also
would focus on waste elimination through alternative materials use and design to reuse, restore, and
even regenerate materials, maintaining value for as long as possible.
Exhibit ES-3. Example Geographic Prioritization of Investment: Potentially Recyclable Glass16
15 Note that areas in the South, Southwest, and Rocky Mountains currently lack the critical infrastructure to process additional packaging and
organic materials for a variety of legislative, policy, and administrative reasons.
16 Data retrieved from the Recycling Infrastructure and Market Opportunities Map. https://www.epa.gov/circulareconomv/recvcling-
infrastructure-and-market-opportunities-map.
0 04-130
130 - 360
ES-5
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Exhibit ES-4. Geographic Prioritization Analysis for Organics Recycling Investment Opportunities.17
O U.S. Major Cities
o AD facilities (food only)
o AD facilities (all)
• Composting facilities (food only)
o Composting facilities (all)
Potentially recoverable organic materials (tons)
0.40-1,700
1,700-4,600
H 4.600 - 8,400
8,400- 18,600
17 Data retrieved from the Recycling Infrastructure and Market Opportunities Map. https://www.epa.gov/circulareconomv/recvcling-
infrastructure-and-market-opportunities-map.
ES-6
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Section 1: Introduction
1.1 Report Purpose
The U.S. recycling system faces significant challenges to improve
recycling. Changes in the international trade of municipal solid waste
(MSW) recyclables have impacted the domestic recycling system by
limiting U.S. recycling exports, a constraint that appears to have
exposed weak points in the aging U.S. system. A U.S. Government
Accountability Office (GAO) report published in December 2020
flagged several key challenges in improving recycling in the U.S.:18
Report Purpose: EPA developed this
report at the request of Congress.
This report summarizes estimates of
the total infrastructure investment
required to modernize recycling
infrastructure, improve consumer
recycling education, and provide all
residents with access to recycling
services on par with access to trash
disposal.
1. Contamination of recyclables;
2. Low recycling collection rates;
3. Limited market demand for recycled materials;
4. Low profitability for operating commercial recycling programs; and
5. Limited information to support decision-making about recycling
House Report 116-448, as part of the Fiscal Year (FY) 2021 appropriations bill passed in December 2019,
directs EPA to "develop estimates of the infrastructure investment required to modernize the Material
Recovery infrastructure...[and] develop estimates for the amounts of investment needed to provide all
citizens with access to recycling services on par with access to disposal."19 In direct response, EPA
developed estimates of the total infrastructure investment from stakeholders across the recycling system
that would modernize recycling infrastructure, improve consumer recycling education, and provide all
residents with access to recycling services on par with access to trash disposal, with the goal of achieving
consistent collection across the nation and maximizing the efficient reuse of materials.
As an initial step in developing investment estimates, EPA
identified existing proposals, reports, case studies, and
secondary data that evaluate the financial gaps and needs
in and of the U.S. recycling system. Building from that
effort, EPA used the identified data and reports, along
with interviews with recycling experts, to analyze the
current state of the U.S. recycling infrastructure stock and
infrastructure gaps, estimate the cost to fill those gaps,
and finally, examine the potential financial mechanisms to
address such gaps.
1.2 Scope of Assessment and Key Definitions
To delineate the scope of this analysis, EPA focused on
quantifying and assessing the level of investment needed
to provide all residents with access to recycling services
on par with access to trash disposal, using the nation's
EPA focused its analysis on those
materials with proven technologies
already used to process materials
at scale and that have established
recycling ei rkets. The
materials of focus are packaging
a c materials, which
together account for 82 percent of
tno iMunicipal solid waste stream
and erefore essential targets
in providing residents with access
to recycling services on par with
access to trash disposal.
18 U.S. Government Accountability Office. 2020. Recycling: Building on Existing Federal Efforts Could Help Address Cross-Cutting Challenges.
Accessed online Sept. 2021: https://www.gao.gov/products/gao-21-87
19 U.S. House of Representatives. 2021. House Report 116-448. Accessed online Sept. 2022: https://www.congress.gov/congressional-
report/116th-congress/house-report/448
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2030 50 percent recycling goal as a framework to measure the success of recycling investments.20 EPA
directed its efforts toward identifying near-term opportunities for increasing effective recycling across the
nation's existing recycling system (e.g., collection, sortation, processing, etc.) within a 2030 timeframe for
recycling technologies that are already used to process materials at scale and that have established
recycling end markets (i.e., recycled materials are traded and sold in commodity markets nationwide).
To effectively target achievable investments in the
2030 timeframe, the analysis focuses specifically
on MSW packaging material and organic materials
with established recycling end markets. The
primary materials of interest include ferrous metal
cans, nonferrous metal beverage containers,
aluminum foil, paper, cardboard/boxboard, glass,
plastics #1, plastics #2, and organic material (i.e.,
food waste and yard waste). Packaging and organic
materials account for 82 percent of the municipal
solid waste stream and are therefore essential
targets in providing residents with access to
recycling services on par with access to trash
disposal.21
Other materials such as textiles, electronics, and plastics #3 to #7 are equally important and require
thoughtful consideration of how best to upgrade and integrate infrastructure required for recycling, as
well as how to develop end markets. However, these materials are not included in the scope of the
current assessment due to material flow and cost data limitations as well as a lack of demonstrated, wide-
scale, and proven (or feasible) recovery technologies and established end markets. As more data on these
materials become available, EPA will consider updating the assessment accordingly.
Key terms that frame the assessment scope are defined below:
• Anaerobic digestion (or co-digestion) - the breaking down of organic material with bacteria in the
absence of oxygen (i.e., anaerobic). This process generates biogas and nutrient-rich matter. Co-
digestion refers to the simultaneous anaerobic digestion of food and other organic material in one
digester. This process includes fermentation (i.e., converting carbohydrates - such as glucose,
fructose, and sucrose - via microbes into alcohols) in the absence of oxygen to create products
such as biofuels.
• Composting - the process of breaking down organic material with bacteria in oxygen-rich
(aerobic) environments. Composting produces organic material that can be used as a soil
amendment.
• Equivalent access - refers to when opportunities to recycle are on par with trash disposal services
(i.e., opportunities to recycle are on par with trash disposal services, such as residents having
access to both curbside trash and curbside recycling services).
20U.S. EPA. 2022. G uide to the Facts and Figures Report about Materials, Waste and Recycling. Accessed online Aug. 2022:
https://www.epa.gov/recvclingstrategy/us-national-recvcling-goal
21 U.S. EPA. 2022. Guide to the Facts and Figures Report about Materials, Waste and Recycling. Accessed online Aug. 2022:
https://www.epa.gov/facts-and-figures-about-rnaterials-waste-and-recvcling/guide-facts-and-figures-report-about
The plastic numbering system, or Resin Identification
Code (RIC) is a set of symbols included on plastic products
that identify the plastic resin out of which the product is
made. Plastics are labeled with numbers #1-7:
• Plastics #1: PET typically used for beverage bottles (e.g.,
water bottles)
• Plastics #2: HDPE typically used for milk jugs and laundry
detergent bottles
• Plastics #3: PVC typically used for pipes
• Plastics #4: LDPE typically used for shrink wrap or other
flexible plastic packaging
• Plastics #5: PP typically used for straws and single-use
food ware
• Plastics #6: PS typically used for packing peanuts
• Plastics #7: Miscellaneous
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• Organic materials - refers to food waste (e.g., fruits and vegetables, grains, coffee grounds, etc.)
and yard waste (e.g., leaves, sticks, grass clippings, etc.).
• Packaging materials - refers to ferrous and nonferrous metal cans and foil, paper,
cardboard/boxboard, glass containers (e.g., bottles and jars), and plastic containers used to
package both solid and liquid products (including plastics #1 and #2).
• Recycling - refers to the series of activities by which discarded or used materials, products, or
substances are collected, sorted, processed, and/or converted into feedstock for use in the
manufacture of new products.
• Recycling infrastructure and technology - infrastructure that encompasses the general recycling
process as it currently exists in the U.S., beginning with generation, collection, sortation,
processing, and finally, end market use of recycled materials (e.g., product manufacturing).
Exhibit 1-1 depicts the scope of this report and Exhibit 1-2 visually depicts the recycling system for
packaging and organic materials in the U.S.
Exhibit 1-1. Scope of Infrastructure Investment Assessment*
Generation and
collection of recyclable
materials from the
residential,
institutional, and
commercial sectors
Recyclable materials:
Ferrous metal cans
Nonferrous metal beverage
containers and aluminum foil
Paper
Cardboard/boxboard
Glass
Plastics #1 (PET)
Plastics #2 (HPDE)
Food waste
Yard waste
Sorting and
processing of
recyclable materials
in recycling,
composting, and AD
nfrastructure
*Note: This assessment focuses on existing infrastructure to collect and process materials that have proven, existing technologies
for recycling as well as known end markets for the recycled products at a national level. This includes mechanical technologies that
process commonly-recycled materials (e.g., metals, plastics, paper, and glass) through Municipal Recovery Facilities (MRFs) and
biological technologies that process organic materials (e.g., food waste and yard waste) as livestock feed and through composting
and anaerobic digestion facilities. The report scope does not include recovery technologies that are not yet used at scale (e.g.,
plastics chemical recycling, which transforms recycled plastic into a virgin-like resin).
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Exhibit 1-2. U.S. Recycling System for Packaging and Organic Materials
Generation
Single and multi-
family residential
Commercial
1111
Institutional
Organics Recycling End \
Products
Electricity
Animal Feed
Finished compost
Product Manufacturing
Paper mills
j^jGlass product manufacturing
"plastic product manufacturing
Steel and aluminum millsJ
Collection
Curbside recycling
^ Redemption centers
j&t Drop off centers
[ftL. Transfer stations
Organics Recycling
Anaerobic Digestion
Q Livestock farms
Composting
\
Packaging Recycling
pjiilj MRF and baling operations
Plastic reclaimers
Pulp Mills
Glass beneficiation
In alignment with existing federal efforts to improve the recycling system, EPA also developed this report
keeping parallel recycling initiatives in mind. These initiatives include:
the Agency's current National Recycling Strategy and
subsequent documents in EPA's Circular Economy
series;
a nationwide information collection request for
recycling data (e-ICR);
two grant programs authorized by the Bipartisan
Infrastructure Law focused on improving the nation's
recycling infrastructure, decreasing contamination,
standardizing measurement, increasing data
collection, and expanding consumer recycling
education and outreach; and
concerted efforts to bolster the recycling market
through the creation of supporting tools and maps.
This assessment focuses on
existing recycling infrastructure
to collect and process materials
with known end markets for
recycled products at a national
level and focuses on proven,
existing technologies to recycle
these materials. The report
scope does not include recovery
technologies that are not yet
used at scale.
The remainder of this report provides more detail on the
financial estimates to modernize recycling infrastructure,
improve consumer recycling education, and provide all residents with access to recycling services on par
with access to trash disposal. This report is organized as follows:
• Section 2:. Financial Assessment and Estimates for Packaging Materials describes the current
recycling infrastructure and infrastructure gaps for packaging materials, provides a breakdown of
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financial investments needed to address identified gaps, and details geographic priorities for
investment.
• Section 3:. Financial Assessment and Estimates for Organic Materials describes the current
recycling infrastructure and infrastructure gaps for organic materials, provides a breakdown of
financial investments needed to address identified gaps, and details geographic priorities for
investment.
• Section 4:. Financial and Resource Support describes the financial mechanisms that could be
considered to address the investments identified to upgrade the nation's recycling infrastructure
and provide all residents with access to recycling services on par with access to trash disposal.
• Section 5:. Additional Materials for Future Consideration describes considerations in improving
the nation's recycling system for other materials outside of the assessment scope, such as textiles,
plastics #3 to #7, and electronics.
• Section 6:. Summary and Beyond 2030 provides a summary of the investments needed to
modernize recycling infrastructure, improve consumer recycling education, and provide all
residents with access to recycling services on par with access to trash disposal and summarizes
considerations to improve recycling beyond 2030.
• Appendix A provides maps of existing recycling infrastructure for packaging materials and
potentially recyclable material tonnage across the U.S.
• Appendix B provides maps of existing recycling infrastructure for organic materials and potentially
recyclable material tonnage across the U.S.
• Appendix C provides documented case studies and project examples highlighting specific real-
world and place-based applications of recycling solutions.
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Section 2: Financial Assessment and Estimates for Packaging Materials
2.1 Introduction and Overview
The current U.S. recycling system diverts several
commonly-recycled packaging materials from the
municipal solid waste stream. EPA estimates that the
nation generates around 96 million tons of packaging
materials waste and recycles 39 percent of this waste.
This analysis estimates that an additional 38 to 45
million tons of packaging material could be recycled by
expanding recycling access and infrastructure (e.g.,
more collection trucks, more recycling carts, etc.).22
This expansion of the U.S. recycling infrastructure would require an investment of $22 to $28 billion for
improvements to curbside collection, drop-off, and processing infrastructure (i.e., material recovery
facilities, or MRFs). This level of investment from cities, states, private companies, public-private
partnerships, and the federal government through legislation such as the Bipartisan Infrastructure Law
would provide households with equivalent access to packaging material recycling as trash disposal services
and could increase the nation's overall recycling rate to approximately 45 to 47 percent, close to EPA's
nationwide goal of 50 percent. This report details the following below:
• Discusses EPA's methodology to estimate the investment required to modernize recycling
infrastructure, improve consumer recycling education, and provide all residents with access to
recycling services on par with access to trash disposal;
• Describes gaps within the existing packaging materials recycling system;
• Estimates the investment needed to improve infrastructure and address identified gaps; and
• Discusses logistical considerations such as investment timing, geographic focus, and policy
environments required to make lasting change.
2.2 Methodology
To estimate the level of investment needed to modernize recycling infrastructure, improve consumer
recycling education, and provide all residents with access to recycling services on par with access to trash
disposal, EPA identified strategies for expanding U.S. residential recycling infrastructure, from ensuring
equivalent access to curbside collection and drop-off stations to developing glass separation and deposit
redemption systems. The National Recycling Goal, which is to attain a national recycling rate of 50 percent
by 2030, serves as a framework to measure the success of identified recycling investments.
The scope of packaging materials focuses on those with proven technologies to process materials at scale
and have established recycling end markets. Only packaging materials from the residential sector are
included in this analysis; commercial and industrial recycling are out of scope. The list of packaging
materials comprises ferrous metal cans, nonferrous metal beverage containers, aluminum foil, paper,
cardboard/boxboard, glass, plastics #1 (polyethylene terephthalate, or PET), and plastics #2 (high-density
polyethylene, or HDPE). Textiles, electronics, and plastics #3 through #7 are excluded from this analysis
22 This estimate assumes no source reduction, no major changes in processing technology, some level of contamination, and participation rate of
78.6 percent, consistent with the participation rate used by The Recycling Partnership. 2021. Paying it Forward: How Investment in Recycling Will
Pay Dividends. Accessed online Sept. 2021: https://recvclingpartnership.org/read-paving-it-forward/.
An investment of $22 to $28 billion is needed to
recycle the 38 to 45 million tons of currently potentially
recyclable packaging material (i.e., glass bottles,
aluminum/steel cans, paper, cardboard, and plastics #1
and #2). An investment of this scale would require
funding from stakeholders across the entire recycling
system, including federal, state, and municipal
governments, the private sector, hybrid public-private
partnerships, and fee-based programs. This would
increase the nation's recycling rate from 32 percent to
approximately 45 to 47 percent.
1
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because they are not widely accepted for residential recycling, rely on emerging recycling technologies, or
lack a robust end market.23 Exhibit 1-1 illustrates the full scope of this report.
The model for packaging materials makes several assumptions to develop investment estimates, address
information gaps, and account for scarce national-level data on materials, infrastructure, and MRF
capacity and throughput. These are highlighted throughout the report, but three key assumptions are
outlined below:
1. With the investments outlined in this report, the participation rate for packaging materials for
both single-family and multi-family households would be 78.6%.24 This means that even with
investments to make recycling accessible to all residents and to improve the overall recycling
system, not everyone who has access to recycling services will choose to recycle.
2. The increase in residential recycled materials will require either constructing new MRFs or
upgrading the design and capacity of existing MRFs to improve utilization. Low-end estimates
assume that existing facilities are operating at less than 100% capacity and can manage an
increase in materials, while high-end estimates assume that facilities are operating at or near
100% capacity and must be upgraded or modernized with the latest technology, such as optical
sorters or robotic arms.
3. All urban households are assumed to recycle packaging materials via curbside collection and all
rural households are assumed to recycle packaging materials via drop-off services. Urban
households will not recycle via drop-off and curbside is assumed to be unavailable for rural
households. The reason for this simplified assumption is because in previous studies, there was a
delineation between curbside collection and drop-off based on the type of recycling program
listed on the municipality's website.
Generation and recycling tonnage estimates used per capita rates from the Ball Corporation's 50States of
Recycling report from 2021 applied to state-level population data from the 2019 American Community
Survey.25,26 EPA estimated the tonnage of potentially recyclable packaging material using an approach
consistent with the 50 States of Recycling report, subtracting the quantity of recovered material from the
total amount of material generated for each type of packaging material in each state. Data for paper
generation and recycling were unavailable for most states, so EPA estimated missing values using the
difference between average per capita generation and recycling for select states reporting paper data,
applied to the same state-level population data. It is important to note that the state paper generation
data are self-reported, not independently verified, collected at irregular intervals, and contain varying
levels of detail about community recycling programs.
In addition, this report quantifies the existing infrastructure stock and estimates the total number of
additional MRFs needed to address identified gaps in the U.S. recycling system, using information from
23 Interviews with industry experts suggest there are developing end markets for plastics #4 (LDPE) and #5 (PP). Plastic #7 is sometimes used in
manufacturing but is not recycled widely. The Pew Charitable Trusts report indicates no existing or anticipated end markets for plastics #3 (PVC)
and #6 (PS). Source: Pew Charitable Trusts. 2020. Breaking the Plastic Wave. Accessed online Sept. 2021: https://www.pewtrusts.org/en/research-
and-analvsis/articles/2020/07/23/breaking-the-plastic-wave-top-findings
24 This value is derived from TRP's estimate of increased recycling access for single family households in the U.S. (additional single-family
households served/total U.S. single-family households). It is also applied to multifamily households because the goal is equivalent access, or
recycling service on par with trash disposal services. Multifamily households stand to benefit considerably from improvements to recycling
collection.
25 Eunomia. 2021. The 50 States of Recycling. Prepared for the Boll Corporation. Accessed online Oct. 2021:
https://www.ball.com/sustainability/real-circularity/50-states-of-recycling
26 U.S. Census Bureau. 2022. 2019 American Community Survey. Accessed online May 2022: https://www.census.gov/programs-survevs/acs
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EPA's Recycling Infrastructure and Market Opportunities map, which provides data for MRFs and
materials-specific processing facilities.27 EPA identified key costs (e.g., equipment for collection and
processing, operation, education, etc.) for both infrastructure expansion and new infrastructure.
Both the e-ICR and Solid Waste Infrastructure for Recycling (SWIFR) grant program funded through the
Bipartisan Infrastructure Law (BIL) serve as unique opportunities to collect recycling data on a community
level and verify or adjust current, national-level estimates; if possible, these may be incorporated in future
recycling infrastructure needs analyses. Exhibit 2-1 summarizes generation, recycling, and potentially
recyclable packaging material by type.
Exhibit 2-1. Packaging Material Generation, Recycling, and Potentially Recyclable Material (2019).
Packaging Material
Generation
(Tons)
Recycling
(Tons)
Potentially Recyclable
Material (Tons)
PET Bottles
3.3 million
764,000
2.5 million
PET Rigid
766,000
45,000
721,000
HDPE Bottles
2.2 million
499,000
1.7 million
Aluminum
1.5 million
553,000
950,000
Steel
1.8 million
562,000
1.2 million
Cardboard
34.2 million
18.3 million
15.9 million
Paper
42.3 million
12.5 million
29.8 million
Glass
9.9 million
4.1 million
5.8 million
Total
96 million
37.3 million
58.6 million
Estimated using:
(1) Eunomia. 2021. The 50 States of Recycling. Prepared for the Boil Corporation.
(2) U.S. Census Bureau. 2022. 2019 American Community Survey.
(3) State waste management reports.
Furthermore, EPA conducted a thorough review of available recycling infrastructure literature: 125
documents focused on key improvements and associated costs of expanding the aging U.S. recycling
system (published between 2015 and 2021). (A complete list of references can be found in the References
section of this report). Cost information relies primarily on data from The Recycling Partnership's Paying It
Forward and the Institute for Local Self-Reliance's (in partnership with the National Recycling Coalition and
Zero Waste USA) American Recycling Infrastructure Plan for the Recycling is Infrastructure Too
Campaign.28,29 Estimates also integrate findings from interviews with experts in the domestic recycling
system:
• Container Recycling Institute
• EPA's Office of Resource Conservation and Recovery
• EPA's Tribal Waste Management Program
• Environmental Research and Education Foundation
27 U.S. EPA. 2022. Recycling Infrastructure and Market Opportunities Map. https://www.epa.gov/circulareconomy/recvcling-infrastructure-and-
market-opportunities-map.
28 The Recycling Partnership. 2021. Paying it Forward: How Investment in Recycling Will Pay Dividends. Accessed online Sept. 2021:
https:// r ec vcl i ngpa rtners h i p. org / r ea d-pa vi ng-it-for wa r d /
29 Institute for Local Self-Reliance (ISRI). 2021. "Recycling Infrastructure Plan Released." Accessed online May 2022: https://ilsr.org/recycling-
infrastructure-plan-rel eased/
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• Northeast Recycling Council
• Southeast Recycling Development Council
• Solid Waste Association of North America
• The Recycling Partnership
• Sustainable Packaging Coalition
EPA was not able to locate existing data regarding collection/drop-off equipment and operation needs,
processing, and end markets in tribal communities prior to the publication of this report, so tribal
community needs are discussed qualitatively throughout.
Finally, EPA conducted a high-level spatial analysis, identifying geographic areas within which to prioritize
investment. This work leverages EPA's Recycling Infrastructure and Market Opportunities map where
generation, recycling, and uncaptured recycling quantities, by material type, are mapped against existing
recycling infrastructure.30 The existing recycling infrastructure includes MRFs, material specific recycling
facilities (e.g., plastics recycling facilities, metal recycling facilities, etc.), and potential end markets (e.g.,
paper mills, smelters, etc.). The map is used to identify the geographic distribution of residential recycling
infrastructure stocks and gaps and to consider region-specific needs. Additionally, the report goes one
step further by overlaying data from EPA's EJScreen tool to review and discuss how environmental justice
factors must be incorporated into proposals to upgrade the U.S. recycling system.31
2.3 Summary of Identified Infrastructure Stock and Gaps
In developing investment estimates, EPA first identified the existing infrastructure stock and gaps that
need to be filled to expand residential curbside collection and drop-off programs, and to aggregate and
process more materials through existing and new MRFs. An overview of the infrastructure stock and gaps
for packaging materials, organized by recycling system stage follows below.32
2.3.1 Generation and Collection
Residential packaging material waste is either recycled or managed through landfilling or incineration.33
This assessment focuses on two main types of recycling collection:
• Curbside collection, where a municipal or private hauler drives through communities to pick up
carts of recycled material and brings it to a transfer station, and
• Drop-off, where residents bring their own household packaging material waste to a "convenience
center" (i.e., a drop-off station).
Currently, 6 percent of homes across the U.S. do not have access to any recycling services such as curbside
recycling collection through the municipality, options for subscription-based service (whereby customers
pay a recurring fee for their recycling to be picked up on a regular basis), or drop-off locations within the
municipal boundary. Additionally, roughly 40 percent of households do not have access to recycling
services equivalent in quality to trash disposal (e.g., residents have curbside trash collection but must take
30 U.S. EPA. 2022. Recycling Infrastructure and Market Opportunities Map. https://www.epa.gov/circulareconomv/recvcling-infrastructure-and-
market-opportunities-map.
31 U.S. EPA. 2023. EJScreen: Environmental Justice Screening and Mapping Tool. Accessed online January 2023: https://www.epa.gov/eiscreen.
32 Note that insufficient materials management infrastructure in the U.S. to collect and process recycling is a documented issue. State and local
governments have made significant efforts to divert waste from landfills. These efforts have been documented in a number of published reports
and case studies. Appendix C provides some specific real-world and place-based applications of recycling solutions.
33 The scope of this report is limited to generators in the residential sector only. Commercial and industrial generation and collection is considered
out of scope for this assessment of infrastructure stocks and gaps.
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packaging materials to a drop-off center to be recycled).34,35 Multi-family units are at a particular
disadvantage: 12 percent of multi-family units do not have access to any recycling services.36,37 Equivalent
access to curbside collection and drop-off, where recycling services are as accessible as trash disposal
services, is an important starting place for the analysis of infrastructure gaps.38 Equivalent access would
require adjustments to the following:
• Curbside collection: 81 percent of single-family households have access to curbside collection
(i.e., through their municipality or through a private subscription service), while only 27 percent of
multi-family households have on-property collection.39 By contrast, 14 percent of single-family
households and 61 percent of multi-family households have access to drop-off stations. While
many urban municipalities have some form of drop-off station or convenience center for drop-off
in addition to municipal or subscription curbside collection services, multi-family buildings are
often left out of curbside collection altogether, leaving off-site drop-off as their only option. Multi-
family buildings' recycling collection needs are similar to commercial collection needs (e.g., they
require an aggregation bin and possibly a different type of truck for pickup). In some states, multi-
family properties over a certain size are considered businesses, and therefore not eligible for
municipally-run curbside programs. Multi-family building owners may either choose to contract
with recycling collection services and increase unit rental rates to accommodate the cost of the
service or leave it up to households to transport their recycling to a drop-off station. In either
case, recycling access for a majority of multi-family households are not on par with trash disposal.
• Drop-off collection: Drop-off recycling is a sole option for many rural communities, and though
this technically constitutes "access" to recycling services for households,40 convenience stations
(i.e., residential trash and recycling drop-off locations) may be more than 20 miles away, across
town lines, or some distance away from public transportation routes. No matter the travel
required, drop-off recycling access is not considered equivalent unless it is on-par with trash
disposal (i.e., households must transport both trash and recycling to a "convenience station"
because curbside pickup is not available through their municipalities or subscription services).
• Education: Curbside collection and drop-off program expansion require an investment for
household education to help reduce contamination at the source (i.e., the household). Source
contamination issues identified by industry expert interviewees range from improper disposal
(e.g., bagged recyclables) to food residues on the insides of plastic containers, and inclusion of
material that is not actually recyclable (e.g., broken furniture). Universally accessible educational
34 The Recycling Partnership. 2020. 2020 State of Curbside Recycling Report. Accessed online Sept. 2021: https://recvclingpartnership.org/wp-
content/uploads/dlm uploads/2020/02/2020-State-of-Curbside-Recvcling.pdf
35 The Recycling Partnership. 2021. Paying it Forward: How Investment in Recycling Will Pay Dividends. Accessed online Sept. 2021:
https://recvclingpartnership.org/read-paving-it-forward/
36 The Recycling Partnership. 2021. Paying it Forward: How Investment in Recycling Will Pay Dividends. Accessed online Sept. 2021:
https://recvclingpartnership.org/read-paving-it-forward/
37 Multi-family buildings are defined as buildings with 5 or more housing units.
38 Equivalent access to recycling is defined throughout this report as access to recycling equivalent to access to garbage disposal. It is a measure
that harmonizes the recycling needs of urban and rural communities that have different design priorities for effective recycling, and it is consistent
to "equitable access" definitions used by The Recycling Partnership in their reports. The terminology is different here, but the measure is the
same.
39 The Recycling Partnership. 2021. Paying it Forward: How Investment in Recycling Will Pay Dividends. Accessed online Sept. 2021:
https://recvclingpartnership.org/read-paving-it-forward/
40 Sustainable Packaging Coalition. 2021. 2020 to 2021 Centralized Study on Availability of Recycling. Accessed online Oct. 2021:
https://sustainablepackaging.org/spc-releases-comprehensive-update-of-its-centralized-availabilitv-of-recvcling-studv/.
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materials to reach populations with varying languages, knowledge of acceptable materials, and/or
cultural contexts is crucial to a well-functioning system.
As part of this analysis, EPA also looked at recycling programs in tribal communities. While tribal recycling
and waste management is tribe-specific (i.e., with different resources, priorities, governance, etc.), many
federally recognized tribes receive funding from EPA's Indian Environmental General Assistance Program
(GAP) to manage their own solid waste. GAP grants fund for activities like developing integrated solid
waste management plans, implementing curbside collection, and educating tribal citizens on recycling.
Through GAP, many tribes have the funding to support a single environmental program staffer who must
juggle multiple competing environmental program interests (e.g., air quality monitoring, water quality
monitoring, and above-ground tank inspections). As a result, these positions often experience regular
turnover, making it difficult to consistently staff and manage recycling programs. Service agreements
and/or contracts with haulers are also identified as an area of need for tribes. EPA recently held a listening
session for the design of the SWIFR Tribal Grant Program where commenters identified that they need
technical assistance to negotiate recycling pick up in rural areas with low population density, as affordable
collection services are difficult to secure given the geographically remote nature of many communities.
Due to lack of quantitative data, EPA did not develop estimates for recycling infrastructure in tribal
communities, but considerations for infrastructure expansion will be discussed qualitatively in Section 2.4.
The expansion of curbside recycling programs to areas that presently have drop-off centers would require
investment in collection bins, carts, and trucks, as well as aggregation bins (e.g., compacting roll-offs or
front-end containers) for multi-family buildings. This investment would convert to curbside collection
some proportion of urban single and multi-family homes that currently have access to drop-off recycling
only, thereby lowering a barrier to recycling participation. Expanding drop-off programs in rural areas
would require investment in containers or compacters, supporting infrastructure like signage, tools (e.g.,
pitchforks or small forklift vehicles), and staffing. No matter the specific features of the recycling program,
ultimately the expansion of recycling collection programs requires accessibility considerations such as the
provision of recycling services on par with trash disposal services.
2.3.2 Sorting and Processing
The current U.S. material sorting and processing universe includes a total of 5,863 facilities designed to
recover packaging material waste, including:41
• 421 MRFs that process multiple types of packaging material
• 83 glass recycling and beneficiation facilities (secondary processing facilities that address
contamination by crushing, cleaning, and sorting glass into cullet)
• 5,099 metals recycling facilities that process either aluminum or steel42
• 57 paper recycling facilities
• 203 plastics recycling facilities.
41 Data for plastic, paper, glass, and MRFs come from EPA's Recycling Infrastructure and Market Opportunities Map.
https://www.epa.gov/circulareconomv/recvcling-infrastructure-and-market-opportunities-map.
42 Data for metal recovery facilities come from the National Disaster Debris Recovery Facilities (EPA) point data layer, filtered to include only
"metals" and "recovery" facilities. Source: U.S. EPA. 2022. US EPA Disaster Debris Recovery Tool. Accessed online Aug. 2022:
https://services.arcgis.com/cj9YHowT8TU7DUvn/arcgis/rest/services/EPA Disaster Debris Recovery Data/FeatureServer
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As a whole, these facilities process more than 37 million tons
of recoverable material. While some facilities have been Currently, Utilization data and
recently updated with the latest sorting and processing recycling experts suggest that
technology and expanded capacity (e.g., Waste Management on average, MRFs operate at a
facilities), many of these facilities still require technological throughput capacity of j
updates.43 Technological updates can include upgrades to percent, leaving an average
sortation and conveyance equipment, such as optical sorters, , . , ,
. , . unused throughput capacity of
picker robots, and additional storage bunker capacity.
Additionally, MRF operations data suggest that a majority of iirceillt.
MRFs are not operating at full capacity. Currently, utilization
data and recycling experts suggest that on average,44 MRFs operate at a throughput capacity of just 56
percent, leaving an average unused throughput capacity of 44 percent. In addition, there are many regions
of the U.S. with few or no MRFs.45 (See Appendix A for maps of existing recycling infrastructure by
material type processed.)
Regardless of location or daily throughput capacity, all MRFs are currently struggling with inbound
contamination from the generation and collection of materials for recycling, which affects operating
efficiency, residual contamination, and end-product quality.46 Key sources of contamination include:
• Glass breakage
• Complex packaging labeled as "recyclable" but requiring consumers to disassemble pieces or
remove labels before placing in recycling bins
• Black carbon plastic (optical scanners cannot process this material)
• Materials that are not widely accepted such as plastics #3, #6, and #7 47
While interviews with packaging recycling industry experts suggest that a change from single stream to
dual stream collection would improve the quality of recycled material through reduced inbound
contamination, interviewees also suggested that this would be a cost-prohibitive challenge. Interviewees
identified glass separation as a possible middle path, reducing inbound contamination through the source
separation of the largest contaminating material (glass). MRF operators reportedly do not prefer to
process glass because glass is abrasive and grinds down equipment over time, increasing maintenance
costs. Glass also breaks easily, and crushed glass shards or dust may get into bales of other recycled
material such as paper. For this reason, glass is often sent to landfills as alternative daily cover (i.e.,
protection against animal scavenging, fire prevention, odor and pollution control). Combining glass with
other materials during collection also reduces the quality and value of the glass waste stream itself.
Markets for recycled glass highly value source-separated beverage containers (e.g., through deposit return
programs); interviews with industry experts suggest that values and reuse options for mixed glass are
typically more constrained.
43 The Recycling Partnership. 2021. Paying it Forward: How Investment in Recycling Will Pay Dividends. Accessed online Sept. 2021:
https://recvclingpartnership.org/read-paving-it-forward/
44 While the data are from U.S. MRFs, the data are limited to a small subset of MRFs reporting their throughput capacity.
45 Note: This analysis examines regional patterns in MRF siting and generation of potentially recyclable material in Section 2.5.
46 Inbound contamination is the contamination of materials collected by haulers from residential sources. Residual contamination refers to post-
processing contamination at MRFs.
47 According to multiple industry experts interviewed, plastic #4 film is often collected at grocery stores and sold directly to end market users,
while plastic #5 is becoming a more widely accepted material.
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Two additional areas where change is needed to bring about more effective and efficient recycling include
1) consistent messaging about the materials accepted by recycling and glass separation programs in
differing jurisdictions, and 2) materials alignment with MRF processing equipment. While consistent
messaging for collection is contingent on the acceptance of similar materials by MRFs, interviews with
industry experts suggest that guidelines across neighboring municipalities often differ, even in cases
where collected materials are sent to the same MRF. To further add to the confusion, lists of materials
accepted at MRFs for recycling change periodically. The Recycling Partnership's 2019 State of Curbside
Survey found that roughly one-third of surveyed programs made changes to the list of materials they
collect or accept in the past two years.48 A significant second component contributing to recycling
ineffectiveness is that the types of items accepted in collection programs and the types of items that are
targeted for recycling by materials management facilities may be misaligned. For instance, a community
may engage and contract with a waste hauler stipulating that a certain material must be accepted for
collection (e.g., clean pizza boxes). While the hauler is contractually obligated to collect certain items, the
recycling facility that eventually receives these items may not sort or process them (e.g., recycling facilities
may not process pizza boxes due to historic trends with contamination associated with food residue and
grease). This misalignment may happen in both directions: items listed as acceptable in a collection
program may not be sorted and sold by the receiving MRF and items listed as being prohibited in a
collection program may indeed be sorted and sold by the receiving MRF. Alignment of municipal recycling
guidelines with MRF-accepted materials is a clear way to reduce contamination and inefficiency in any
recycling system.
In total, the effective expansion of recycling infrastructure requires targeted investment to address
capacity, technology, labor, contamination, and staff education needs across MRFs and facilities with a
range of operating conditions. Similarly, the expansion of sorting and processing infrastructure requires
equity considerations such as siting and limiting operational disruption (e.g., traffic) to surrounding
communities.
2.3.3 Recycling End Markets
A successful recycling system requires robust recycling end markets to accept processed materials. The
U.S. recycling market currently includes around 1,000 end market facilities that can directly use the end
product produced from the recycling process for input in material manufacturing (e.g., glass container
manufacturers, smelters, foundries, paper mills, etc.).49
Currently, few existing policies and economic incentives support end market development by encouraging
the use of recycled materials in products. In addition, contamination stemming from the generation and
collection stage affects commodity quality and prices for most materials. Interviews with recycling
industry experts suggest that a reduction in contamination from glass specifically would improve
commodity quality and prices for all other packaging materials.
Ultimately, the expansion of recycling end markets would require investment to bolster domestic markets
for recycled commodities as well as improve and/or ensure the quality of recycled commodities. Since
48 The Recycling Partnership, "2020 State of Curbside Recycling Report/' February 13, 2020. Available here: https://recvclingpartnership.org/wp-
content/uploads/dlm uploads/2020/02/2020-State-of-Curbside-Recvcling.pdf
49 U.S. EPA. 2022. Recycling Infrastructure and Market Opportunities Map. https://www.epa.gov/circulareconomv/recvcling-infrastructure-and-
market-opportunities-map.
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China's National Sword policy was enacted in 2018,50 MRF operators have already increased investments
in sorting equipment, purchasing robotic pickers and optical sorters as a means of increasing processing
throughput and quality.51 Technology improvements and automation with artificial intelligence and
robotics continue to be an important investment trend in the recycling industry to strengthen the quality
of recycled commodities. In addition, while consumers may be the driving source of contamination in the
residential recycling stream, producers also have the capacity and responsibility to design packaging
materials to support the reduction of consumer contamination (e.g., eliminating or reformatting large
shrink sleeve labels, a contaminant, from PET bottles for improved capture rates).52
2.4 Assessment of Financial Estimates
Research identified several priorities for investment in future opportunities to capture packaging
materials. An investment focused on materials with existing end markets would ensure: a) equivalent
access to curbside and drop-off collection on par with trash disposal, b) options for reducing
contamination by separating glass, and c) goal achievement by 2030. A summary of the investment
estimates for two recycling scenarios - single stream and glass separation - organized by recycling system
stage: generation and collection, sorting and processing, and end markets is provided below, in
Exhibit 2-2. Within each of these scenarios, the analysis also considers a national-level bottle bill add-on
scenario.
Exhibit 2-2. Summary Investment Cost Estimates for Packaging Materials.
Curbside
Collection
Capital (Deposit Redemption System
only)
$100,000,000
$100,000,000
Capital (without Deposit Redemption
System)
$6,900,000,000
$8,500,000,000
Operating (excludes MRFs)
$13,000,000,000
$13,000,000,000
Subtotal
$19,900,000,000
$21,500,000,000
Glass Separation
(Curbside)
Capital
$2,700,000,000
$2,700,000,000
Operating (processing and trucking)
$225,000,000
$240,000,000
Subtotal
$2,900,000,000
$2,900,000,000
Drop Off
Capital
$602,000,000
$2,100,000,000
Operating (MRFs only)
$1,300,000,000
$1,300,000,000
Subtotal
$1,900,000,000
$3,400,000,000
ALL
Curbside + Dropoff
$21,800,000,000
$24,900,000,000
Curbside + Dropoff + Deposit
Redemption System
$21,900,000,000
$25,000,000,000
Curbside + Dropoff + Glass Separation
$24,700,000,000
$27,800,000,000
50 China's National Sword Policy bans the import of most plastics and other materials from foreign sources. For more information see:
https://www.epa.gov/smm/sustainable-materials-management-smm-web-academy-webinar-chinas-green-sword-impacts-state-and
51 Quinn, M. (2022, Sept. 14) "National Sword kicked off a wave of MRF investments. 5 years later, tech and funding continue to advance." Waste
Dive. Accessed online Nov. 2022: https://www.wastedive.com/news/national-sword-five-vears-mrf-robotics-recvcling-investment/630731/
52 Goldsberry, C. (2014, May 7). "Recycling issues continue to plague shrink sleeve labels." Plastics Today. Accessed online Aug. 2022:
https://www.plasticstodav.com/recvcling-issues-continue-plague-shrink-sleeve-labels
9
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System
Component
Cost Category
Low-End Estimate
Curbside + Dropoff + Glass Separation +
Deposit Redemption System
$24,800,000,000
$27,900,000,000
Note: The low-end estimates assume that facilities will not receive the latest technology upgrades (e.g., optical
sorters, robotic arms, etc.) while the high-end estimates assume that facilities will be upgraded or modernized with
the latest technology, resulting in higher capital costs. Technology upgrades would work to reduce contamination
and improve recycling output quality.
Estimated using:
(1) Eunomia. 2021. The 50 States of Recycling. Prepared for the Boll Corporation.
(2) U.S. Census Bureau. 2022. 2019 American Community Survey.
(3) State waste management reports.
(4) The Recycling Partnership. 2021. Paying it Forward: How Investment in Recycling Will Pay Dividends.
(5) Cost values from interviews with industry experts.
2.4.1 Generation and Collection
To improve recycling, an expansion of residential curbside and drop-off collection opportunities is needed.
Expansion of residential curbside collection, particularly to multi-family units, is a critical step in improving
the U.S. recycling system in both volume and equity. Expansion of drop-off collection is important to
providing access to recycling services for rural households. Expansion of curbside and drop-off collection
will improve participation among currently non-participating households and provide access to recycling
services for multi-family building residents and other households without current access. Currently,
households without access to recycling services on par
with trash disposal must either transport their recycling
to a drop-off facility or trash their recyclables.
In addition, there is room for improving collection within
the subset of households that already participate in
curbside recycling - they can receive carts to ease the
transport of recyclable material between their dwelling
or garage, and households that currently use bags to
collect materials for recycling could receive bins. (Bags
are often disposed with the recycling and contaminate
the recyclable materials with plastic film.)
2.4.1.1 Curbside Collection
EPA estimates that capital improvements to curbside
collection in urban areas in the U.S. would cost between
$6.9 billion and $8.5 billion, including the costs
associated with collection bins, education, trucks, etc.53
These capital cost estimates are closely linked with the total count of households, and much of the capital
cost relates to household education and equipment (e.g., bins, carts). Exhibit 2-3 has an example model of
accepted packaging materials messaging from a recycling program in Beaufort, North Carolina.
Education. An investment in packaging recycling
infrastructure includes education efforts to reduce
contamination at the source, prior to collection.
Using household-level cost information from The
Recycling Partnership ($10/household), EPA
estimates that a total investment of $1.2 billion for
U.S. household education is needed to develop
materials that are universally accessible to educate
communities on which packaging materials are
accepted locally, with an emphasis on simple
messaging conveyed primarily with graphics and
images (e.g., Do's and Don'ts with examples of what
can and cannot be recycled), as well as translations
where needed (both language and culturally-relevant
examples). Importantly, this investment also includes
temporary cart-tagging programs to support urban
communities with particularly low recycling rates or
high contamination rates (i.e., loss).
53 The Ball Corporation 202150 States of Recycling report describes urban residents as a proportion of the total population in a state. EPA
subtracted from 100% to back out the corresponding rural proportion. Source: Eunomia. 2021. The 50 States of Recycling. Prepared for the Ball
Corporation. Accessed online Oct. 2021: https://www.ball.com/getattachment/na/Vision/Sustainabilitv/Real-Circularitv/50-States-of-Recvcling-
Eunomia-Report-Final-Published-March-30-2021-UPDATED-v2.pdf.aspx?lang=en-US&ext=.pdf
10
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Exhibit 2-3. Accepted Materials Messaging from Beaufort, North Carolina.54
D0N7TANGLE0R CONTAMINATE
RECYCLE MORE
FOR A GREENER STATE
; v*1
GLASS
BottiM and (art
tm
KEEP THESE OUT OF THE RECYCLING BIN!
ti* HI
® dotting or tnUH
sc
RECYCLING
* rjJw (Mfl and dry pdxtK Mgn
I wrap Met to iff* grocery Hort
AN of the curbside collection capital cost estimates assume new MRF construction to process the
additional curbside material, along with improved utilization of existing MRF design capacity.55 The low-
end estimates assume that facilities will not receive the latest technology upgrades (e.g., optical sorters,
robotic arms, etc.) while the high-end estimates assume that facilities will be upgraded or modernized
with the latest technology, resulting in higher capital costs. Technology upgrades would work to reduce
contamination and improve recycling output quality. Total annual collection operations are estimated to
cost $13 billion, which includes administration, transportation and fuel,56 and salary for recycling service
employees. Investment estimates vary between single-family and multi-family:
54 Town of Beaufort, NC. 2022. Solid Waste and Recycling Guidelines. Accessed online Sept 2022:
https://www.beaufortnc.org/community/page/solid-waste-recvcling-guidelines
55 Existing MRFs operate at an average of 50 - 60 percent of total capacity, leaving 40-50 percent capacity unused.
56 Transportation does not include new trucks, as this would be considered a capital cost.
ii
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Single-family urban: Using the methodology described in Section 2.2, EPA estimates an
investment of $38.2 million for urban in-home bins ($8/bin), $1.3 billion for carts ($50/cart), and
$798 million for household level education for single family households ($10/household).57
Assuming that 78.6 percent of single-family
households are served by these changes in the
recycling system,58 this investment would increase
curbside recycling by 24.1 million tons.
Multi-family urban: EPA estimates that an
investment of $10.1 million for urban multi-family
in-home bins and $335 million for carts is needed to
improve material recycling so that it is on par with
trash disposal opportunities.59 Multi-family
buildings also require larger bins to aggregate
materials from the entire building (i.e., all the
contents from individual units' in-home bins). EPA
estimates $1.2 billion is needed for aggregation
bins. An additional $210 million for household level
education is needed to ensure that multi-family
building residents collect only appropriate materials
and clean them effectively. Assuming that 78.6
percent of multi-family households are served by
these changes in the recycling system,60 this
investment would increase curbside recycling by
6.2 million tons.
The low-end estimates assume
that facilities will not receive the
latest technology upgrades (e.g.,
optical sorters, robotic arms, etc.)
while the high-end estimates
assume that facilities will be
upgraded or modernized with the
latest technology, resulting in
higher capital costs. Technology
upgrades would work to reduce
contamination and improve
recycling output quality.
Investments in single-family and multi-family urban
curbside collection could result in 30.2 million tons of
potentially recyclable material, or a recycling rate of 42
percent.
EPA also explored the possible impact of a nationwide
deposit redemption system (DRS) to provide economic
incentives to recycle and also ensure higher-quality
materials recycling for specific containers. The Institute for
Local Self Reliance's 2021 Recycling Infrastructure Plan
estimated an initial cost of $100 million to implement a
nationwide bottle deposit program, where consumers are charged a deposit for their beverage container
Bottle Deposit Programs. Currently, 10 states
have deposit programs: California, Connecticut,
Hawaii, Iowa, Maine, Massachusetts, Michigan,
New York, Oregon, and Vermont. Deposit
programs collect the following bottle-format
packaging materials: aluminum, PET plastic, and
glass. A 2021 report by Reloop identifies that
beverage container landfilled waste can be up to
79 percent lower in jurisdictions with bottle
deposit redemption systems, when compared to
jurisdictions that do not host such programs.
(Source: Reloop Platform. 2021. What we waste.
Accessed online May 2022:
https://www.reloopplatform.org/wp-
content/uploads/2021/04/What-We-Waste-
Reloop-Report-April-2021-l.pdf)
57 Cost assumptions are from The Recycling Partnership's 2021 Paying it Forward Report and confirmed via interview.
58 This value is derived from TRP's estimate of increased recycling access for single family households in the U.S. (additional single-family
households served/total U.S. single-family households).
59 The estimate for multi-family carts is imprecise. Many multi-family buildings may not need carts because residents can walk down to the parking
lot to empty their in-home bins into a larger aggregating bin; however, others may choose to have a cart (or more) for floor-level collection for the
building manager or superintendent to wheel down to the aggregation bin.
60 This value is derived from TRP's estimate of increased recycling access for single family households in the U.S. (additional single-family
households served/total U.S. single-family households); however, we apply it for multifamily households as well, because the goal is equivalent
access, or recycling service on par with trash disposal services. Multifamily households stand to benefit considerably from improvements to
recycling collection.
12
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purchases, to be refunded upon return of the container (bottle redemption).61 EPA assumes DRS diversion
rates consistent with industry data: 40 percent of aluminum (298,000 tons),62 28 percent of glass (1.9
million tons),63 and 25 percent of PET bottles (839,000 tons).64 The additional material from DRS would
increase the total collection of packaging material by more than 3 million tons, which would result in a
recycling rate of 43 percent when combined with curbside collection. Using this total tonnage, the initial
capital cost of $100 million breaks down to $33/ton of deposit-eligible material.
Exhibit 2-4. Investment Cost Estimates for Curbside Collection with Deposit Redemption System.
Cost Category
Low-End Estimate
High-End Estimate
Capital (with Deposit Redemption System)
$100,000,000
$100,000,000
Capital (without Deposit Redemption System)
$6,900,000,000
$8,500,000,000
Operating65
$13,000,000,000
$13,000,000,000
Total
$19,900,000,000
$21,500,000,000
Note: The low-end estimates assume that facilities will not receive the latest technology upgrades
(e.g., optical sorters, robotic arms, etc.) while the high-end estimates assume that facilities will be
upgraded or modernized with the latest technology, resulting in higher capital costs. Technology
upgrades would work to reduce contamination and improve recycling output quality.
Estimated using:
(1) Eunomia. 2021. The 50 States of Recycling. Prepared for the Boll Corporation.
(2) U.S. Census Bureau. 2022. 2019 American Community Survey.
(3) The Recycling Partnership. 2021. Paying it Forward: How Investment in Recycling Will Pay Dividends.
(4) Cost values from interviews with industry experts.
2.4.1.2 Glass separation
Recycling industry experts who were interviewed suggested that glass separation is a viable strategy for
reducing contamination at the source (i.e., curbside pickup or drop-off) while preserving the overall
simplicity of single-stream recycling. Glass separation would parse out a contaminant of concern for MRFs,
reducing their maintenance costs while simultaneously improving the quality of the remaining material
they sell to end markets.
EPA estimates a total cost of approximately $3 billion would be required to implement a glass separation
program for urban households across the U.S. (single-family and multi-family). Rural drop-off facilities
often already have source separation capacity (i.e., a separate bin for glass), so they are assumed to
require no updates. Capital cost represents 92 percent of the total investment, or $2.7 billion. As with
curbside collection, capital cost assumptions for urban residential glass separation include in-home bins
61 Institute for Local Self-Reliance. 2021. "Recycling Infrastructure Plan Released." Accessed online May 2022: https://ilsr.org/recvcling~
infrastructure-plan-released/.
62 Container Recycling Institute. 2022. "Aluminum Facts & Statistics." Accessed online May 2022: https://www.container-
recvcling.org/index.php/factsstatistics/aluminum.
63 Container Recycling Institute. 2022. "Aluminum Facts & Statistics." Accessed online May 2022: https://www.container-
recvcling.org/index.php/factsstatistics/aluminum
64 The Recycling Partnership. 2021. Paying it Forward: How Investment in Recycling Will Pay Dividends. Accessed online Sept. 2021:
https:// r ec vcl i ngpa rtners h i p. org/r ea d-pa vi ng-it-for wa r d/
65 The Recycling Partnership. 2021. Paying it Forward: How Investment in Recycling Will Pay Dividends. Accessed online Sept. 2021:
https:// r ec vcl i ngpa rtners h i p. org/r ea d-pa vi ng-it-for wa r d/
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and carts. EPA assumes no additional education investment
for a glass separation program (i.e., this cost is built-in to the
cost of collection/drop-off education for households). In-home
bin cost is estimated to be $48 million, because EPA assumes
that the cost applies only to the fraction of households
requiring a second bin for glass separation. Cart cost is
assumed to be $1.9 billion (individual cost of $60/cart, $10
higher than the base cost described above because of the dual
separation bin design). Capital cost for trucks is estimated to
be $775 million ($250,000/truck).
Interviews with industry experts suggested a cost of $45/ton
to operate a glass separation program, resulting in a processing cost between $163 million and $172
million. The final estimated range of a recycling program including glass separation is $2.9 billion to $3.0
billion. Glass separation can be expected to increase recycled glass by 3.6 million to 3.8 million tons, which
has a market value of $36 million to $38 million (assuming an average market price of $10 per ton of glass
cullet).66, 67 Adding glass separation to curbside collection would result in a national recycling rate of 44
percent.
Exhibit 2-5. Investment Cost Estimates for Glass Separation in Curbside Collection.68
Cost Category
Low-End Estimate
High-End Estimate
Capital
$2,700,000,000
$2,700,000,000
Operating69
$225,000,000
$237,000,000
Total
$2,900,000,000
$2,900,000,000
Note: Low-end estimates are driven by a 95 percent glass recovery assumption, high-
end estimates assume 100 percent glass recovery.
Estimated using:
(1) Eunomia. 2021. The 50 States of Recycling. Prepared for the Boil Corporation.
(2) U.S. Census Bureau. 2022. 2019 American Community Survey.
(3) The Recycling Partnership. 2021. Paying it Forward: How Investment in Recycling Will Pay Dividends.
(4) Cost values from interviews with industry experts.
2.4.1.3 Drop-off programs
Subject matter experts widely acknowledged that rural communities need improved access to functioning
recycling drop-off systems. One expert interviewee identified that for some households in states with low
population density, such as Wyoming, the nearest drop-off station can be up to 300 miles away.70 At such
a distance, it is neither time nor cost-effective for rural households to drop off their recycling. For the
present infrastructure investment assessment, EPA assumes that all rural households would be eligible for
66 The lower end of this range assumes 95 percent capture, the average practice yield at a MRF. Source: Glass Recycling Coalition. 2017. Glass
Recycling Benefits Calculator. Accessed online July 2022: https://www.glassrecvcles.org/industrv-tools-l/benefits-calculator/
67 ScrapMonster. 2022. Glass Cullet Prices in the U.S. and Canada. Accessed online Aug. 2022: https://www.scrapmonster.com/scrap-
vard/price/glass-cullet/335
68 Dropoff collection operations are assumed to be $13 billion for collection identified in Exhibit 2-3. As such, listing the operations cost here would
be duplicative.
69 Source: Recycling industry expert interviews. This value includes trucking costs (fuel and operation).
70 This statistic was cited by an interviewee from EPA OLEM.
Project Example: Thetford Recycling Center.
To reduce contamination of recyclables, the
Thetford Recycling Center in Vermont, a
transfer station which serves around 2,700
residents with drop-off services, requests glass
be separated from the rest of recyclables. In
2021, the program collected 43.4 tons of glass,
which was transported to New London, NH
and crushed for road and construction
projects. (Source: Northeast Recycling Council.
2022. Successful Glass Recycling in Rural
Communities. Webinar accessed June 2022).
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drop-off access that establishes options for drop-off at locations equivalent to trash disposal locations,
rather than curbside collection. Additionally, urban households are assumed to not participate in drop-off
programs.71
EPA estimates that capital investment between $602 million and $2.1 billion will be needed to improve
recycling drop-off stations and supporting hub-and-spoke infrastructure. Similar to curbside collection
capital cost, this estimate includes the cost for bins, collection stations, and education (e.g., flyers and
ancillary signage). Capital cost for drop-off stations is estimated to be $102 million (including trucks
needed to transport materials to MRFs), with another $59 million for supporting hub-and-spoke
infrastructure. Education cost for rural households (single and multi-family) is estimated at $240 million.
Operating costs are assumed to be linked to MRF operating costs, $1.3 billion. These costs together bring
the total cost of nationwide drop-off system improvements to between $1.9 billion and $3.4 billion.
Investment in expanded drop-off infrastructure would result in an additional 7.6 million tons of potentially
recyclable packaging materials, and a national recycling rate of 35 percent. When combined with the
previously described investment in curbside collection, the potential national recycling rate climbs to 45
percent.
Exhibit 2-6. Investment Cost Estimates for Drop-off.
Cost Category
Low-End Estimate
High-End Estimate
Capital
$602,000,000
$2,100,000,000
Operating
$1,300,000,000
$1,300,000,000
Total
$1,900,000,000
$3,400,000,000
Note: The low-end estimates assume that facilities will not receive the latest technology
upgrades (e.g., optical sorters, robotic arms, etc.) while the high-end estimates assume
that facilities will be upgraded or modernized with the latest technology, resulting in
higher capital costs. Technology upgrades would work to reduce contamination and
improve recycling output quality.
Estimated using:
(1) Eunomia. 2021. The 50 States of Recycling. Prepared for the Boil Corporation.
(2) U.S. Census Bureau. 2022. 2019 American Community Survey.
(3) The Recycling Partnership. 2021. Paying it Forward: How Investment in Recycling Will Pay Dividends.
(4) Cost values from interviews with industry experts.
2.4.1.4 Tribal communities
In terms of infrastructure for tribal communities, robust recycling programs require investment for in-
home bins, collection trucks and drop-off stations (depending on how spatially dispersed the community
is), security, and education (e.g., signage). Operations would require station employees as well. During a
recent tribal feedback listening session for EPA's SWIFR grant program, EPA heard from several tribal
Nation representatives that illegal dumping, limited access to transportation and recycling processing
71 Importantly, this is a simplifying assumption. Urban and suburban households in many municipalities have access to a drop-off station in
addition to a curbside collection subscription service. Many families opt out of the subscription option in favor of the lower-cost or even free drop-
off option provided by the municipality's waste management program.
15
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infrastructure, and a lack of end markets for recycled materials are key issues that need to be addressed
on tribal lands.
2.4.2 Sorting and Processing
For improvements to collection to be successful, simultaneous capital investment in collection
trucks/haulers and material recovery facilities is necessary. EPA uses The Recycling Partnership's estimate
of $930 million for the capital cost of new trucks to collect and transport the potentially recyclable
packaging material to the processers (without glass separation). Based on the methodology described in
Section 2.2, the Agency estimates that the capital cost of upgrading existing recycling facilities with
improved sorting equipment to both reduce contamination and ensure ability to process larger volumes
would be $3.1 billion. The cost of expanding capacity and building new recycling facilities is estimated to
be $5.4 billion, while the annual MRF operating cost is estimated at $1.3 billion, as summarized in
Exhibit 2-7. I mportantly, these values are all integrated into the curbside collection and drop-off estimates
discussed above but are included here for completeness.
Exhibit 2-7. Investment Cost Estimates for Sorting and Processing.
Cost Category
Without Glass
With Glass
MRF Capital (New Construction + Upgrades)
$5,400,000,000
$5,400,000,000
MRF Capital (Upgrades)
$3,100,000,000
$3,100,000,000
Trucks Capital
$930,000,000
$1,700,000,000
Operating
$1,300,000,000
$1,400,000,000
Total
$10,700,000,000
$11,600,000,000
Note: Low-end and high-end estimates are driven by the exclusion/inclusion of glass processing
and transportation infrastructure, as well as higher glass operating costs.
Estimated using:
(1) Eunomia. 2021. The 50 States of Recycling. Prepared for the Boil Corporation.
(2) U.S. Census Bureau. 2022. 2019 American Community Survey.
(3) The Recycling Partnership. 2021. Paying it Forward: How Investment in Recycling Will Pay Dividends.
(4) Cost values from interviews with industry experts.
EPA's estimate for the total number of MRFs needed to accommodate expanded access to recycling
services diverges from The Recycling Partnership's published values. State-level packaging waste
generation numbers drive EPA's estimate for total number of MRFs needed to process the potentially
recyclable material (by dividing total potentially recyclable packaging material by an average annual MRF
throughput of 60,640 tons).72 This analysis estimates the total number of new MRFs needed (476) by
subtracting existing MRF underutilized capacity (20.2 million tons per year total) from MRF capacity needs
estimated at the state level (58.7 million tons per year total) and then dividing by the average annual MRF
throughput. Existing MRFs are assumed to have additional underutilized capacity.73
72 MRF capacity is estimated using the average tons per day design (i.e., nameplate plant capacity) and the average tons per day (actual average
throughput, or 182 tons per day). Tons per year is estimated using 333.34 operational days, which stems from the textbook 8,000 operating
hours/year assumption used by engineers in calculating plant capacity (see for example Sinnott, R.K. (2005) Coulson & Richardson's Chemical
Engineering Design. Elsevier Coulson & Richardson's Chemical Engineering Series, 6, 231, 477).
73 The excess MRF capacity (an average throughput of 203 tons per day) is a value identified by RTI in an interview. Extrapolated to tons per year
using the same assumptions outlined in FN 65.
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Lack of MRF data is a key limitation for the present analysis. Without robust data on facility throughput
capacity, the present analysis of where new and upgraded MRFs are needed and thresholds for material
distances traveled to MRFs falls short of providing precise information about where these facilities should
be constructed, or which MRFs should be upgraded. While MRF opportunities are discussed further in
Section 2.5 and mapped by individual material in Appendix A, the present assessment is limited by the
data available. A feasibility study is needed to set a regional limit on how far materials can travel to target
specific regions where new MRFs should be constructed, and existing MRFs upgraded. Distance traveled
to MRFs should be informed by material weight, types of materials accepted by nearby processing
facilities, trucking load weight restrictions (tonnage values differ by state), and existing nearby MRF
processing capacity. The present analysis handles these limits on spatial information by assuming an
average processing capacity and treating existing facilities as if they could all be upgraded to improve
efficiency and capture underutilized capacity.
Another key limitation of this analysis is that fire insurance costs for MRFs are not included in the
operating cost estimates due to a lack of data. As such, the annual MRF operating cost in Exhibit 2-7 may
be an underestimate. Battery fires are a growing issue for MRFs and may result in facility damage and/or
increased insurance cost. Previous EPA research indicates that MRF fire insurance is a changing landscape,
and as insurers leave the recycling and waste management market, some facilities are turning to self-
insurance (which may require up to tens of millions of dollars).74,75 Education for consumers to reduce
contamination through removal of batteries prior to recycling and policies for standardized and clear
product labels indicating the presence of batteries and instructions for how to recycle are required to
reduce the risk of battery-caused facility fire.76 It is important to note that pursuant to the Bi-Partisan
Infrastructure Law, EPA is required to develop a battery collection best practices report, and labelling
guidelines and education materials to improve battery recycling.
Finally, the financial estimates above do not address
cost, energy, and resource savings associated with
recycling packaging materials. The following are some
examples of possible savings from the use of recycled
material inputs:
• Revenue from the sale of recycled packaging
materials;
• Energy savings and associated GHG emission
savings through use of recycled (rather than
virgin) materials;
• Resource savings, such as reduced water use,
use of raw materials, mining waste, and fossil-fuel
• Reduced burden on existing landfills.
74 U.S. EPA. 2021. An Analysis of Lithium-ion Battery Fires in Waste Management and Recycling. Prepared by the Office of Resource Conservation
and Recovery. EPA 530-R-21-002. Accessed online Jul. 2022: https://www.epa.gov/svstem/files/documents/2021-08/lithium-ion-batterv-report-
update-7.01 508.pdf.
75 Taylor, B. 2018. After the fire, a new alarm is sounded. Waste Today. Published 2018, December 7. Accessed online Aug. 2022:
https://www.wastetodavmagazine.com/article/lithium-ion-batterv-waste-mrf-fires-insurance/
76 Institute for Local Self Reliance (ISRI), Solid Waste Association of North America (SWANA), and the National Waste and Recycling Association
(NWRA). 2020. Guide for Developing Lithium Battery Management Practices at Materials Recovery Facilities. Accessed online Aug. 2022:
https://www.isri.org/docs/default-source/default-document-librarv/mrf-lithium-batterv-guidance.pdf?sfvrsn=2
Recycled Material Commodity Prices. The blended
commodity price for single stream recovered
materials with residuals is $169.75, and $180.73
without residuals. Based on these commodity prices,
the total additional recoverable material from
curbside collection alone has a potential value ranging
from $5.1 to $5.4 billion. The potential value from
additional material tonnage from improved drop-off
ranges from $1.5 to $1.6 billion. (Source: Northeast
Recycling Council (NERC), 2022. NERC Recycling
Markets Value Reports. Accessed online Aug. 2022:
https://nerc.org/news-and-updates/nerc-recvcling-
markets-value-reports)
based chemicals; and
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2.5 Summary and Investment Considerations
EPA estimates that an investment of $22 to $28 billion is needed to modernize recycling infrastructure,
improve consumer recycling education, and provide all residents with access to recycling services on par
with access to trash disposal for packaging materials. This level of investment would result in an additional
38 to 45 million tons of recycled packaging material, increasing the U.S. recycling rate from 32 percent to
45 to 47 percent, close to the Agency's goal of increasing nationwide recycling to 50 percent by 2030.77
To be effective, investment in collection and drop-off
infrastructure should be aligned with investment in
expanded processing infrastructure (MRFs and
material-specific facilities) and education. MRF
processing capacity needs to be increased in concert
with curbside and drop-off collection because the
distribution of these facilities may not be optimal to
handle the increased volume of potentially recyclable
packaging material. Packaging recycling expert
interviewees recommended targeting locations with
very little infrastructure (e.g., Wyoming), as well as
locations where MRF capacity is not being fully utilized.
As described in Section 2.4, many MRFs typically
operate between 50 to 60 percent of their total
capacity,78 so some initial increases to total nationwide
processing capacity may simply require hiring more full-
time employees to operate on a second or third shift
and capture the underutilized but existing capacity.
A key factor missing from this analysis is the impact to end market prices from an increased supply of
recycled materials. Estimating the price impact for end markets is out of scope for the present analysis.
Qualitatively, increased recycled material supply linked with access to collection equivalent to trash
disposal services and increased MRF processing capacity could lead to an overall decrease in market prices
for recycled materials for which demand is low. Alternatively, where producers have an appetite for more
recycled feedstock, a change in the availability of recycled content could result in industry decisions to
expand manufacturing capacity. An anticipated decrease in market prices for recycled material could be
combated somewhat by policies encouraging higher recycled material content in manufacturing.
Policies to reduce packaging materials at the source by encouraging the use of recycled feedstock in
product manufacturing are important. President Biden's Executive Order 14057 on Catalyzing Clean
Energy Industries and Jobs through Federal Sustainability can be leveraged for this exact purpose. Under
Section 208, it directs the federal government, the largest purchaser in the world, to purchase sustainable
Comparison with Existing Estimates. Several recent
estimates have been developed for the investment
needed to promote equitable access to curbside
collection and drop-off and correspondingly expand
MRF capacity. A popular study is The Recycling
Partnership's 2021 Paying it Forward report.
The Recycling Partnership estimates that $28 billion is
needed to provide some form of recycling access for
all U.S. households by 2025 (excluding flexible plastics
and film). This value falls at the higher end of EPA's
estimated total cost range: $22 billion to $28 billion.
EPA's estimate includes a lower bound due to the
consideration of a variety of infrastructure solutions,
including curbside collection and drop-off only, glass
separation, and a national deposit redemption
system. EPA's lower bound estimates do not include
MRF upgrades or modernization, resulting in a
reduced capital cost.
77 U.S. EPA. 2018. National Overview: Facts and Figures on Materials, Wastes and Recycling. Accessed online May 2022:
https://www.epa.gov/facts-and-figures-about-rnaterials-waste-and-recvcling/national-overview-facts-and-figures-
rnaterials#:~:text=The%20recvcling%20rate%20(including%20cornposting.person%20per%20dav%20for%20recvcling.
78 This statistic was cited in an interview with RTI International.
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products, and specifically mandates purchasing products that contain recycled content.79 The Executive
Order further directs government agencies to purchase sustainable products and services recommended
by EPA. EPA maintains Recommendations on Specifications, Standards, and Ecolabels for Federal
Purchasing to identify credible standards and ecolabels and facilitate purchasing of sustainable products.
Recycled content criteria are specified by recommended standards and ecolabels for most product
categories.80 EPA's purchasing recommendations are also used outside of the federal space by state and
local governments, companies, and other institutional purchasers. For example, EPA established a
Comprehensive Procurement Guideline (CPG) Program in the 1990s, coordinated through the Agency's
Sustainable Materials Management initiative.81 The CPG Program provides a public-facing product supplier
directory, as well as a list of designated products that meet certain criteria for recovered, post-consumer,
or bio-based content to encourage the use of recycled materials. In response to H.R. 5376 - Inflation
Reduction Act of 2022 (introduced September 2021),82 EPA is working on guidelines for Environmental
Product Declarations as well (i.e., improved standards and more transparent labeling for product claims of
reduced carbon impact).83
Policies are also needed to require clear labels and reduce consumer confusion about what is and is not
recyclable to improve recycling of packaging materials. For instance, the Climate Leadership and
Environmental Action for our Nation's Future Act (H.R. 1512 - CLEAN Future Act, introduced in March
2021) aims to establish a national bottle deposit redemption program and standards for recycled
content.84 The Act also calls for a pause in permitting for new plastics manufacturing facilities and directs
the National Academy of Sciences to study the impact of single-use plastic bans. Finally, the act charges
EPA with developing grants for a host of waste reduction initiatives, including recycling education, source
reduction and zero waste initiatives. To the extent that this and other related policies pass, EPA,
legislators, and other key policymakers may wish to revisit the infrastructure investment assessment as
source reduction can significantly reduce the generation of packaging waste, and consequently the
regional infrastructure and financial investment needed to address potentially recyclable packaging
materials.
Where policy is crucial to improving packaging recycling at a national level, a more regional approach is
needed to focus infrastructure investments. There are several U.S. regions with both a substantial
generation of potentially recyclable packaging material waste and a notable lack of recycling
infrastructure. EPA mapped existing MRFs, material-specific recycling facilities, and potentially recyclable
material tonnage across the U.S. to develop a list of priority regional areas for recycling infrastructure
79 EO 14057 Section 208 states: "Agencies shall reduce emissions, promote environmental stewardship, support resilient supply chains, drive
innovation, and incentivize markets for sustainable products and services by prioritizing products that can be reused, refurbished, or recycled;
maximizing environmental benefits and cost savings through use of full lifecycle cost methodologies; purchasing products that contain recycled
content, are biobased, or are energy and water efficient, in accordance with relevant statutory requirements; and, to the maximum extent
practicable, purchasing sustainable products and services identified or recommended by the Environmental Protection Agency (EPA)."
https://www.whitehouse.gov/briefing-room/presidential-actions/2021/12/08/executive-order-on-catalvzing-clean-energy-industries-and-iobs-
through-federal-sustainabilitv/
80 EPA Recommendations on Specifications, Standards, and Ecolabels for Federal Purchasing are available at:
https://www.epa.gov/greenerproducts/recommendations-specifications-standards-and-ecolabels-federal-purchasing
81 U.S. EPA. 2022. Comprehensive Procurement Guideline Program. Accessed Nov. 2022: https://www.epa.gov/smm/comprehensive-
procurement-guideline-cpg-program#content
82117th Congress. 2022. House Bill 5376: Inflation Reduction Act of 2022. Accessed online Nov. 2022: https://www.congress.gov/bill/117th-
congress/house-bill/5376/text/rh
83 U.S. EPA. 2022. Inflation Reduction Acy Non-Regulatory Dockets for Public Input. Accessed online Nov. 2022: https://www.epa.gov/air-and-
radiation/inflation-reduction-act-non-regulatorv-dockets-public-input
84 117th Congress. 2021. House Bill 1512: Climate Leadership and Environmental Action for our Nation's Future Act or the CLEAN Future Act.
Accessed online Sept. 2022: https://www.congress.gov/bill/117th-congress/house-bill/1512.
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investment. Using this qualitative geographic analytical approach, EPA identified opportunities in the
following regions (opportunities for glass are shown in Exhibit 2-8, additional packaging materials maps
can be found in Appendix A):85
• South (in particular, parts of Kentucky, Louisiana, Mississippi, Alabama, Georgia)
• Southwest (in particular, Texas, Arizona, and New Mexico)
• Rocky Mountains (in particular, Wyoming, Montana, Colorado, Idaho, Nevada)
Exhibit 2-8. Example Geographic Prioritization of Investment: Potentially Recyclable Glass86
Legend
<> U.S. Major Cities
O MRFs
• Glass Recycling Facilities
Potentially recoverable glass (tons)
0.04-130
H 130- 360
¦I 360 - 640
H 640 - 1,000
¦M ,000-2,000
Furthermore, the specific recycling needs of communities with environmental justice concerns, such as
those with low-income, high unemployment, large populations of people of color, and other factors, must
be considered in a way that is sensitive to the unique challenges those communities face. While the
literature review yielded few results on the intersection of environmental justice and recycling,
policymakers must pay close attention to the needs of disadvantaged and marginalized populations that
may be disproportionately affected by changes to and impacts from the recycling system and municipal
85 Note that areas in the South, Southwest, and Rocky Mountains currently lack the critical infrastructure to process additional packaging materials
for a variety of legislative, policy, and administrative reasons.
86 Data retrieved from the Recycling Infrastructure and Market Opportunities Map. https://www.epa.gov/circulareconomv/recvcling-
infrastructure-and-market-opportunities-map.
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solid waste management in general, particularly relating to the development of new waste management
facilities. For example, communities near MRFs may be adversely affected by health impacts resulting
from MRF operations, including noise, harmful emissions, and exposure to harmful or toxic chemicals.
These communities may also have unique concerns when accessing recycling services that must be
accounted for when pursuing equivalent access across the country.
Exhibit 2-9 displays current material recovery facilities and glass recovery facilities overlayed with the
Supplemental Demographic Index from EPA's EJScreen.87 This index is based on the average of five
socioeconomic indicators; low-income, unemployment, limited English, less than high school education,
and low life expectancy. This map illustrates how communities that are higher on the Supplemental
Demographic Index (indicated by orange or red) are more likely to be located in areas that lack adequate
recycling infrastructure (e.g., the South, Southwest, and Rocky Mountains) and have a high rate of
potentially recoverable glass, as shown in Exhibit 2-8. This analysis serves only as a foundational
framework for incorporating environmental justice considerations into recycling, but they must be equally
analyzed when determining opportunities to finance these investments.
87 U.S. EPA. 2022. EJ and Supplemental Indexes in EJScreen. Accessed online January 2023: https://www.epa.gov/eiscreen/ei-and-supplemental-
indexes-eiscreen#what-supplemental
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Exhibit 2-9. Example Geographic Prioritization with Environmental Justice Considerations: Potentially
Recyclable Glass88
88 Data retrieved from the Recycling Infrastructure and Market Opportunities Map. https://www.epa.gov/circulareconomv/recvcling-
infrastructure-and-market-opportunities-map.
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Section 3: Financial Assessment and Estimates for Organic Materials
3.1 Introduction and Overview
Organic materials can be recycled across the nation through
a variety of proven management methods, such as
composting, anaerobic digestion (AD), rendering, and as
livestock feed. Currently, EPA estimates that the nation
generates more than 101 million tons of organic waste and
recycles approximately 28 percent of this organic waste.
EPA estimates that an additional 44 million tons could be
recycled through an expansion of composting, AD, and
livestock feed infrastructure.89
This expansion of U.S. organics recycling infrastructure, which is fundamentally and structurally different
from the packaging materials recycling infrastructure discussed in Section 2, would require an investment
of $14 to $16 billion for improvements to curbside collection, drop-off, and processing infrastructure so
that access to organics recycling services is on par with access to trash disposal. This level of investment
from cities, states, private companies, public-private partnerships, and the federal government through
legislation such as the Bipartisan Infrastructure Law could increase the nation's overall recycling rate
from its current level of 32 percent to 47 percent, close to EPA's nationwide goal of 50 percent. This
report details the following below:
• Discusses EPA's assumptions and methodology to estimate the investment that would modernize
recycling infrastructure, improve consumer recycling education, and provide all residents with
access to recycling services on par with access to trash disposal;
• Describes gaps within the existing organics recycling system;
• Details the investment estimates to improve infrastructure and address identified gaps; and
• Provides logistical considerations such as investment timing, geographic focus, and policy
environment required to make lasting change.
3.2 Methodology
To develop an estimated level of investment needed to improve organics recycling to be equivalent in
access to trash disposal, EPA first identified proven technologies that could recycle current quantities of
organic materials at scale. Using available information from EPA's Excess Food Opportunities map, which
provides a comprehensive list of organics recycling facilities in operation, EPA analyzed the current
organics recycling infrastructure stock and estimated how much additional infrastructure would be
needed to facilitate equivalent access for organics recycling.90 EPA then identified key costs (e.g.,
equipment for collection and processing, operation, education, etc.) for infrastructure expansion for both
capacity expansion and new infrastructure construction.
Similar to the assessment on packaging materials, the National Recycling Goal of attaining a national
recycling rate of 50 percent by 2030 serves as a framework to measure the success of identified
89 This estimate assumes no source reduction and no major changes in processing technology. In addition, investment estimates throughout this
report do not consider the expansion of rendering infrastructure due to limited cost and material volume data. To the extent that this information
becomes available in the future, EPA may consider updating this analysis.
90 U.S. EPA. 2022. Excess Food Opportunities Map. Accessed online May 2022: https://www.epa.gov/sustainable-management-food/excess-food-
opportunities-map.
A total investment of $14 to $16 billion is
needed to improve organics recycling access
(e.g., composting, anaerobic digestion, and
livestock feed) for food waste and yard waste so
that it is on par with access to trash disposal. This
would increase the nation's recycling rate from
32 percent to approximately 47 percent. Similar
to packaging materials, an investment of this
scale would require funding from stakeholders
across the entire recycling system.
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investments needed for organics recycling. The scope of organic materials includes food and yard waste
from the residential, commercial, and institutional sectors; this differs from the assessment on packaging
materials, which considers only residential sources. The change in scope between the two material types
is based on the availability of data; national-level data on packaging materials focused primarily on the
residential sector whereas data sources for organic materials combined the residential, commercial, and
institutional sectors. Exhibit 1-1 illustrates the full scope of this report.
The model for organic materials makes several assumptions to develop investment estimates and account
for national-level information and data gaps, all of which are highlighted throughout the report. Four key
assumptions are outlined below:
1. While food and yard waste are critical materials in the waste stream, there is no known current
national participation rate for organics recycling; therefore, this report uses the same participation
rate for organic materials as packaging materials (78.6%). Providing equal access to both organics
recycling and packaging recycling relies on the assumption that both material types will be
recycled at a similar rate. Even with investments to make recycling accessible to all residents and
improve the overall recycling system, not everyone who has access to recycling services will
choose to recycle.
2. The increase in materials collected via curbside systems will require either constructing new
organics recycling facilities, such as composting or anaerobic digestion facilities, or upgrading the
design and capacity of current organics recycling facilities to improve utilization. Low-end
estimates assume that existing facilities are operating at less than 100% capacity and can manage
an increase in materials, while high-end estimates assume that facilities are operating at or near
100% capacity and must be upgraded or modernized.
3. Source reduction for organic materials is outside the scope of this assessment, as organics
recycling is the primary material management pathway of consideration.
4. All urban households, including multi-family units, are assumed to have access to curbside organic
waste pickup, and all rural residents are assumed to have access to either organic waste drop-off
services or at-home composting opportunities. Additionally, composting facilities are assumed to
only process residential organic waste while anaerobic digestion facilities are assumed to only
process commercial and institutional waste.
Food waste generation and recycling tonnages were obtained from the Agency's 2019 wasted food report,
which include tonnages of food waste generated and recycled by sector and by management pathway.91
To arrive at national level estimates of yard waste generation and recycling tonnages, EPA obtained yard
waste data from available state waste management reports and calculated per capita generation and
recycling rates for reporting states. EPA then calculated an average per capita generation and recycling
rate from the available data and applied it to state-level population data to arrive at national estimates.92
It is important to note that these state data are self-reported, not independently verified, collected at
irregular intervals, and contain varying levels of detail about community recycling programs. Both the e-
ICR and SWIFR grant program funded through the Bipartisan Infrastructure Law (BIL) serve as unique
opportunities to collect recycling data on a community level and verify or adjust current, national-level
91 U.S. EPA Office of Resource Conservation and Recovery. 2022. 2019 Wasted Food Report, https://www.epa.gov/svstem/fiies/documents/2023-
03/2019%20Wasted%20Food%20Report 508 opt ec.pdf.
92 U.S. Census Bureau. 2022. 2019 American Community Survey. Accessed online May 2022: https://www.census.gov/programs-survevs/acs
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estimates and may be incorporated in future recycling infrastructure needs analyses. Exhibit 3-1
summarizes the tonnage of organic material currently generated and recycled.
Exhibit 3-1. Current Organic Material Generation and Recycling (2019).
Organic Material
Tonnage
Generated
Tonnage
Recycled
Current
Recycling Rate
Food waste
66 million
7.5 million
11%
Yard waste
35 million
20.7 million
59%
Total
101 million
28.2 million
28%
Estimated using:
(1) U.S. EPA Office of Resource Conservation and Recovery. 2022. 2019 Wasted Food Report.
https://www.epa.gov/svstem/files/documents/2023-03/2019%20Wasted%20Food%20Report 508 opt ec.pdf.
(2) State waste management reports.
(3) U.S. Census Bureau. 2022. 2019 American Community Survey.
EPA developed investment estimates using a thorough review of recycling infrastructure literature: 125
documents focused on key improvements and associated costs of expanding the aging U.S. recycling
system (published between 2015 and 2021). (A complete list of references can be found in the References
section of this report.) Cost information for organic materials was drawn primarily from ReFED's Roadmap
to 2030 report and Insights Engine.93,94 Estimates also integrate findings from interviews with experts in
the domestic recycling system:
• American Biogas Council
• BioCycle
• Environmental Research and Education Foundation
• EPA's AD Funding Opportunity Program
• EPA's Office of Resource Conservation and Recovery
• EPA's Tribal Waste Management Program
• Institute for Local Self-Reliance
• Northeast Recycling Council
• ReFED
• Resource Recycling Systems
• U.S. Composting Council
• Waste Management
EPA was not able to locate existing data regarding collection/drop-off equipment and operation,
processing, and end markets in tribal communities prior to the publication of this report. As a result, tribal
community needs are discussed qualitatively throughout this assessment.
Finally, EPA conducted a high-level spatial analysis, identifying geographic areas within which to prioritize
investment. This work leverages EPA's Recycling Markets and Opportunities map where generation,
recycling, and potentially recyclable materials, by organic material type, are mapped against existing
93 ReFED. 2021. Roadmap to 2030: Reducing U.S. Food Waste by 50% and the ReFED Insights Engine. Accessed online May 2022:
https://refed.org/uploads/refed roadmap2030-FINAL.pdf.
94 ReFED. 2022. ReFED Insights Engine. Accessed online May 2022: https://insights.refed.org/? ga=2.257273867.1212413126.1660677635-
778134506.1657051175.
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recycling infrastructure.95 The existing recycling infrastructure includes industrial composters, community-
scale composters, and anaerobic digestors. Similar to the packaging materials section, the report goes one
step further by overlaying data from EPA's EJScreen tool to review and discuss how environmental justice
factors must be incorporated into proposals to upgrade organics recycling within the U.S.96
3.3 Summary of Identified Infrastructure Stock and Gaps
To determine the investment necessary to improve the U.S. recycling system so that access to organics
recycling is equal to access to trash disposal, EPA first identified the existing infrastructure stocks and gaps
within the generation and collection, sorting and processing, and end market stages of the organics
recycling system for the residential, commercial, and institutional sectors.97 An overview of infrastructure
stock and gaps for organic materials, organized by recycling system stage, is provided below.
3.3.1 Generation and Collection
Like packaging materials, organic waste is collected through either curbside pick-up or drop-off programs.
For food waste, only 27 percent of the U.S. population currently has access to recycling services (although
actual participation rates are unknown), in which food waste is either picked up through a curbside service
or dropped off:98
• Around 19 percent of the total U.S. population has access to food waste curbside collection
programs either through their municipality or through a private subscription service.
o Around 3 percent of the total U.S. population has equivalent access to food waste
curbside collection as they do to trash disposal.
• Around 8 percent of the total U.S. population has access to drop-off programs that accept food
waste.
o Around 6 percent of the total U.S. population has equivalent access to food waste drop-off
programs as they do to trash disposal.
Yard waste collection services are more readily available in comparison to food waste. There are currently
27 states with yard waste landfill bans. The 56 percent of the nation's population that reside in these
states have access to either curbside or drop-off yard waste recycling services, depending on municipal
program offerings; however, details of these offerings are not known on a city-level nor are details on yard
waste collection offerings in states without bans due to limited publicly available information.
It is important to note that much like recycling for packaging materials, access to organic recycling services
for multi-family residents differ from single-family residents. For example, while a municipality may offer
curbside organics collection, in some states, as with packaging recycling, multi-family properties over a
certain size are considered businesses, and therefore are not eligible for municipally-run curbside
programs. In addition, depending on the program, privately-run curbside composting programs may or
may not be available to multi-family properties.
95 U.S. EPA. 2022. Recycling Infrastructure and Market Opportunities Map. https://www.epa.gov/circulareconomv/recvcling-infrastructure-and-
market-opportunities-map.
96 U.S. EPA. 2023. EJScreen: Environmental Justice Screening and Mapping Tool. Accessed online January 2023: https://www.epa.gov/eiscreen.
97 Note that insufficient materials management infrastructure in the U.S. to collect and process recycling is a documented issue. State and local
governments have made significant efforts to divert waste from landfills. These efforts have been documented in a number of published reports
and case studies. Appendix C provides some specific real-world and place-based applications of recycling solutions.
98 GreenBlue. 2022. Mapping Urban Access to Composting Programs. Accessed online May 2022: https://greenblue.org/work/compostingaccess/.
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Currently, there is a need for additional infrastructure to expand organics recycling services to the
approximate 91 percent of the nation that do not have equivalent access to organics recycling as they do
to trash disposal. The successful expansion of collection services would have to include the following:
• Curbside collection: Investment in collection bins, collection staff, and trucks, as well as on-
property aggregation bins (e.g., compacting roll-offs or front-end containers). In particular for
multi-family units, recycling collection needs are similar to commercial collection needs (e.g., they
require a latched aggregation bin and possibly a different type of truck for pickup).
• Drop-off programs: Investment in centralized collection areas, staffing, containers, and supporting
infrastructure like signage and tools (e.g., pitchforks or small forklift vehicles). Equity
considerations, such as accessibility, also need to be considered, particularly for those whose
access is limited to drop-off programs but do not have the means to transport their collected
organic materials to centralized drop-off locations.
• Education: Both curbside collection and drop-off program expansion also require an investment
for household education to help reduce contamination at the source and alert communities of the
availability of local organics recycling services. For instance, a recent survey conducted by the
Institute for Local Self-Reliance found that approximately half of its 200 members noted
unawareness from the local community of existing composting programs as a key challenge in
successful recycling operations." One member noted that customers were still landfilling
compostable items even though organics collection is included in the price of trash/recycling
collection. Universally accessible education materials to reach populations with varying languages,
knowledge of acceptable materials, and/or cultural contexts are crucial to a well-functioning
system.
For tribal communities in particular, feedback sessions indicate that much like recycling for packaging
materials, transportation cost is one of the largest expenses to rural communities, especially tribal nations,
given the geographically remote nature of many communities.100 In some territories, like the
Commonwealth of the Northern Mariana Islands, communities experience both high transportation costs
and dependance on few shippers. This issue is particularly serious for food waste because it is heavier than
most discarded materials due to its moisture retaining properties.
3.3.2 Sorting and Processing
The U.S. currently hosts infrastructure to recycle organic waste, which includes, approximately:
• 3,000 composting facilities in the U.S. (not including at-home, residential composting, community
composting sites, or drop-off sites) that manage food and/or yard waste, which vary in size from
large-scale centralized composting operations to smaller-scale composting operations;101
• 275 AD facilities that manage food waste, which vary in operation from stand-alone to on-farm
digesters focusing on food waste to large-scale co-digestion with biosolids at wastewater
treatment plants; and102
99 Institute for Local Self-Reliance. 2022. Challenges Facing Community Composters: Community Composter Census Data.
100 U.S. EPA. 2022. Tribal Communities: Feedback Specific to Stakeholder Types. Accessed May 2022.
101 U.S. EPA. 2022. Excess Food Opportunities Map. Accessed online May 2022: https://www.epa.gov/sustainable-management-food/excess-food-
opportunities-map.
102 U.S. EPA. 2022. Anaerobic Digestion Facilities Processing Food Waste in the United States (2019). Accessed online May 2022:
https://www.epa.gov/anaerobic-digestion/anaerobic-digestion-facilities-processing-food-waste-united-states-survev.
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• 1.5 million farms, spanning 671 million acres, located in 40 states that do not have prohibitions on
food waste for animal feed.103 While there is no data on how many farms accept food waste as
animal feed, recent data suggest that 14 percent of excess food is sent to feed animals, most
coming from pre-consumer generators, such as grocery stores and wholesalers.104
These facilities collectively process around 28.3 million tons of organic waste from the residential,
commercial, and institutional sectors, which represents 28 percent of total organic waste generated.105
While some of these facilities are not operating at full capacity, the need still exists for additional organics
recycling processing infrastructure. The successful construction and operation of additional facilities will
have to address the same challenges that current facilities struggle with, which are detailed below:
• Feedstock contamination: Contamination of organic material, typically with glass, food service
packaging, and produce stickers, affects operating efficiency and overall compost quality. While
screening and depackaging equipment can capture large inert materials, this equipment can be
expensive and reduce the cost-effectiveness of organics recycling operations.
• Land constraints: Organic waste, in the form of food waste, is heavy and therefore expensive to
transport. For cost-effectiveness, facilities should be located within communities (e.g., at
community gardens, local farms, public parks, and schools) to reduce transportation needs.
However, the availability of land in population-dense areas is often limited. Furthermore, if land is
available, the surrounding community may still oppose the construction of organics recycling
infrastructure due to perceived concerns related to odor and pest management.
• Labor and equipment: Composting requires a manual labor workforce in its operations (e.g., to
screen for contaminants or to turn the compost) and AD requires technical labor to load feedstock
and monitor digestion systems. For tribal communities and small-scale community programs, in
particular, it is often difficult to obtain enough technical labor for cost-efficient operations. While
equipment can be used in place of labor, equipment can be costly to purchase and small-scale
operations may not have the available upfront capital. This challenge was emphasized as a key
barrier for tribal communities in national feedback listening sessions for EPA's SWIFR grant
program hosted for Tribal Nations.106
• Permitting: The permitting process differs depending on the volume of organic material managed,
feedstock accepted, and type of operation. While some states have a streamlined permitting
process for organics recycling, others have a more complicated and time-intensive process. A
recent survey conducted by the Institute for Local Self-Reliance found that some states took 14
months to approve composting license applications.107
• Market Factors: Depending on the state, tipping fees for landfills and incineration may be lower
than tipping fees for organics recycling infrastructure. Low landfill and incineration tipping fees
103 USDA. 2022. Farms and Land in Farms 2021 Summary. Accessed online May 2022:
https://www.nass.usda.gov/Publications/Todavs Reports/reports/fnio0222.pdf. Harvard Law School Center for Health Law and Policy Innovation.
2016. Leftovers for Livestock: A Legal Guide for Using Food Scraps as Animal Feed. Accessed online May 2022: https://chlpi.org/wp-
content/uploads/2013/12/Leftovers-for-Livestock A-Legal-Guide August-2016.pdf.
104 U.S. EPA Office of Resource Conservation and Recovery. 2020. 2018 Wasted Food Report. Accessed online May 2022:
https://www.epa.gov/sites/default/files/2020-ll/documents/2018 wasted food report-11-9-20 final .pdf.
105 Estimated using: (1) U.S. EPA Office of Resource Conservation and Recovery. 2020. 2019 Wasted Food Report; (2) State waste management
reports; and (3) U.S. Census Bureau. 2022. 2019 American Community Survey.
106 U.S. EPA. 2022. Tribal Communities: Feedback Specific to Stakeholder Types. Accessed May 2022.
107 Institute for Local Self-Reliance. 2022. Challenges Facing Community Composters: Community Composter Census Data.
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make it difficult for recycling organics infrastructure to compete in the materials management
market cost-effectively.
• Education: Education is particularly important as participating residents, institutions, and
businesses need detailed training materials and resources to understand which organic waste
types to recycle.
The expansion of organics recycling infrastructure would require investment to address the challenges
listed above as well as equity considerations such as siting and limiting operational disruption (e.g., traffic)
to surrounding communities.
3.3.3 Recycling End Markets
Recycling organics produces end products with existing market value and distribution systems. The
composting process produces finished compost, which can serve as a fertilizer, landscaping, or engineering
material. The current global composting market is valued at $5.6 billion in 2020 and is expected to
increase by 33.9 percent and reach $7.5 billion by the end of 2027.108 In the U.S., there are over 200,000
landscaping companies and public garden spaces and 1.5 million farms that can use and apply finished
compost.109,110The anaerobic digestion process can produce either biogas (for use as fuel in alternative
vehicles) or electricity and digestate, which can also serve as a fertilizer, landscaping, or engineering
material. Annual revenue from electricity generation at anaerobic digestion facilities typically ranges
between $300,000 to $400,000 per facility.111 This range is highly variable and depends on local energy
market conditions.
Despite this forecasted increase, there are gaps in the U.S. recycling market that must be addressed to
promote a robust end market for organics recycling. Currently, there is a lack of policies and economic
incentives to encourage the use of organic recycled materials on the local, state, and federal level.
Interviews with organics recycling experts noted that the market price of synthetic fertilizer can be less
expensive than compost; the price of synthetic fertilizer, however, does not reflect the costs to the
environment associated with its use. For synthetic fertilizers that are over-applied, excess nutrients can
run-off into surrounding waterways, causing algae blooms and negatively impacting water quality. In
addition, excessive use of synthetic fertilizers can lead to issues such as soil degradation, nitrogen
leaching, soil compaction, reduction in soil organic matter, and loss of soil carbon. Conversely, compost
and digestate are natural materials and provide a slow release of the appropriate amount of nutrients
needed, improving soil quality and avoiding adverse water quality impacts. Policies that limit the use of
synthetic fertilizer, educate the market on the negative externalities associated with synthetic fertilizers,
and encourage the use of compost and digestate through post-consumer content mandates (e.g.,
requiring municipal landscaping and green infrastructure projects use a certain percentage of finished
compost or digestate) would help to bolster the existing end market for recycled organic products.
108 GlobeNewswire. 2022. "Compost Market 2022." Accessed online May 2022: https://www.globenewswire.com/en/news-
release/2022/01/13/2366344/0/en/Compost-Market-2022-Revenue-USD-7516-5-mn-Growth-Prospects-Price-Trends-Share-Forecast-bv-2027-
Report-bv-Absol ute-Reports. html#:~:text=Market%20Analvsis%20and%20lnsights%3A%20Global,3.9%25%20during%202021%2D2027.
109 U.S. EPA. 2022. Recycling Infrastructure and Market Opportunities Map. https://www.epa.gov/circulareconomv/recvcling-infrastructure-and-
market-opportunities-map.
110 USDA. 2022. Farms and Land in Farms 2021 Summary. Accessed online May 2022:
https://www.nass.usda.gov/Publications/Todavs Reports/reports/fnlo0222.pdf.
111 Cowley, Cortney and B. Wade Brorsen. 2018. "Anaerobic Digester Production and Cost Functions." Ecological Economics, Vol. 152. Accessed
online May 2022: https://www.sciencedirect.com/science/article/abs/pii/S0921800918305500?fr=RR-
2&ref=pdf download&rr=7425f313c8f03b94.
29
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For anaerobic digestion, the current categorization of biogas in the renewable fuels market can affect the
financial viability of many anaerobic digestion facilities. To enhance markets for renewable fuel, EPA
developed the Renewable Fuel Standard, a trading and enforcement program whereby refiners or
importers of gasoline or diesel fuel are required to comply with renewable fuel volume obligations by
either blending renewable fuels into conventional transportation fuels or obtaining credits, called
renewable identification numbers (RINs). RINs can fall into a number of different categories based on the
feedstocks and/or processes used to produce the renewable fuel. Each RIN category carries a different
market value to incentivize the use of certain feedstocks or production processes. EPA is currently re-
examining the RINs classification for biogas from anaerobic digestion and is expected to announce
changes by the end of the year that could greatly improve the economics of operating anerobic digestion
facilities (i.e., the profit margins could be three times higher for biogas producers under the anticipated
new RIN classification).112
3.4 Assessment of Financial Estimates
Improved infrastructure for recycling pathways including composting, anaerobic digestion, and livestock
feed can provide equivalent access to organics recycling and successfully capture potentially recyclable
organic materials.113 Exhibit 3-2 summarizes the investment estimates for recycling organic material.
Details on the investment estimates, organized by infrastructure type, are included below.
Exhibit 3-2. Summary Investment Cost Estimates for Recycling Organic Material.
Organics Recycling Method
Cost Category
Low-End Estimate
High-End Estimate
At-Home Composting
Education & Outreach
$92,000,000
$92,000,000
Collection
$0
$0
Capital
$290,000,000
$290,000,000
Operating
$0
$0
Subtotal
$380,000,000
$380,000,000
Community Composting
Education & Outreach
$1,200,000,000
$1,200,000,000
Collection
$1,600,000,000
$1,600,000,000
Capital
$1,100,000,000
$1,100,000,000
Operating
$710,000,000
$710,000,000
Subtotal
$4,700,000,000
$4,700,000,000
Centralized Composting
Education & Outreach
$1,000,000,000
$1,000,000,000
Collection
$5,900,000,000
$5,900,000,000
Capital
$1,200,000,000
$2,000,000,000
Operating
$530,000,000
$530,000,000
Subtotal
$8,700,000,000
$9,400,000,000
Centralized Anaerobic Digestion
Education & Outreach
$8,400,000
$8,400,000
Collection
$160,700,000
$160,700,000
112 BioCycle. 2017. 101 for RINs. Accessed online May 2022: https://www.biocvcle.net/101-for-
rins/#:~:text=A%20kev%20difference%20between%20D3,of%20the%20solid%20waste%20industry.
113 Note: EPA's estimates of the percentage of organic waste managed by each organics recycling method is aligned with how organic materials are
currently managed. The percentage breakdown is detailed here: U.S. EPA Office of Resource Conservation and Recovery. 2020. 2018 Wasted Food
Report. Accessed online May 2022: https://www.epa.gov/sites/default/files/2020-ll/documents/2018 wasted food report-11-9-20 final .pdf
30
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Organics Recycling Method
Cost Category
Low-End Estimate
High-End Estimate
Capital
$135,200,000
$149,500,000
Operating
$117,600,000
$117,600,000
Subtotal
$421,900,000
$436,200,000
Education & Outreach
$8,400,000
$8,400,000
WRRF Anaerobic Digestion
Collection
$0
$0
Capital
$48,000,000
$67,000,000
Operating
$20,000,000
$20,000,000
Subtotal
$77,000,000
$96,000,000
Education & Outreach
$0
$0
Animal Feed
Collection
$310,000,000
$350,000,000
Capital
$66,000,000
$75,000,000
Operating
$75,000,000
$84,000,000
Subtotal
$450,000,000
$500,000,000
Total
$14,700,000,000
$15,500,000,000
Note: Low-end and high-end estimates are driven by the count and capacity of new and upgraded recycling
facilities. The low-end estimates assume that not all existing facilities are operating at full capacity and could
intake a portion of the potentially recoverable materials, resulting in reduced capital costs. EPA's high-end
estimate assumes that facilities will not operate any closer to full capacity and that comparatively more facilities
will need to be built, which will result in higher capital costs.
Estimated using:
(1) U.S. EPA Office of Resource Conservation and Recovery. 2020. 2019 Wasted Food Report.
(2) State waste management reports.
(3) U.S. Census Bureau. 2022. 2019 American Community Survey.
(4) Natural Resources Defense Council. 2017. Estimating Quantities and Types of Food Waste at the City Level. Accessed online May 2022:
httDs://www.nrdc.ore/sites/default/files/food-waste-citv-level-reDort.Ddf.
(5) ReFed. 2016. A Roadmap to Reduce U.S. Food Waste by 20%: Technical Appendix. Accessed online May 2022:
httDs://refed.ore/downloads/ReFED Technical ADDendix.odf.
(6) The Recycling Partnership. 2021. Paying it Forward: How Investment in Recycling Will Pay Dividends. Accessed online Sept. 2021:
httDs://recvclineDartnershiD.ore/read-Davine-it-forward/
(7) U.S. Composting Council. 2021. "Organics Bans and Mandates." Accessed online May 2022:
httDs://www.comDostinecouncil.ore/Daee/oreanicsbans.
(8) U.S. Composting Council. The Case for Centralized Compost Manufacturing Infrastructure. Accessed May 2022.
(9) U.S. EPA. 2021. Anaerobic Digestion Facilities Processing Food Waste in the United States (2017 & 2018). Accessed online May 2022:
httDs://www.eDa.eov/sites/default/files/2021-02/documents/2021 final ad report feb 2 with links.odf.
| (8) Interviews with industry experts.
The investment estimates for organics are based on several core assumptions:
1. At a minimum, all urban residents (including multi-family units) will have access to curbside
organic waste pickup.
2. At a minimum, all rural residents will have access to organic waste drop-off services or at-home
composting opportunities.
3. While organics recycling programs will be available to all so that recycling services are on par with
trash disposal services, 78.6 percent of the eligible population will participate in organics recycling,
31
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mirroring the current participation rate in recycling programs for communities with equal access
to trash and recycling services.114
4. Commercial and institutional sectors will participate in organic recycling programs.
5. Anaerobic digestion does not process residential waste and only processes commercial and
institutional waste.
3.4.1 Composting
Composting is a natural process of recycling
organic material into a rich soil amendment.
Composting can serve as a viable option to
divert organic wastes such as food waste and
yard waste from landfills. These materials can
be collected then composted to produce a
valuable material (i.e., compost). Compost can
then be distributed to landscapers, farmers, and
other businesses and residents as a valuable soil
amendment. This soil amendment can be used
to promote agricultural productivity, further
supporting the growth of more food and plants
and reducing the need for synthetic fertilizer
and topsoil. The soil amendment can also be
used for engineering purposes (e.g., erosion
control and stormwater management).
There are three types of composting models considered in the estimates: at-home composting,
community composting, and centralized composting:
• At-home composting entails single-family households composting food and yard waste in
backyard settings through the use of tumblers or piles that are routinely turned.
• Community composting also entails composting through tumblers or piles that are routinely
turned, but at a larger scale (approximately 2,500 tons per year) at community gardens, local
farms, public parks, schools, etc.115 Community composting operations usually involve the
community, typically through volunteer opportunities to manage the compost, and compost is
kept and used within the community.116 Organic waste is typically collected through drop-off
services for community composting, although curbside hauling services do exist for select
programs.
• Centralized composting, also known as industrial composting, involves large-scale composting
facilities that process commercial, residential, and institutional food waste, in facilities with
approximately 50,000 tons per year or more of processing capacity.117 These facilities are typically
114 The Recycling Partnership. 2021. Paying it Forward: How Investment in Recycling Will Pay Dividends. Accessed online Sept. 2021:
https://recvclingpartnership.org/read-paving-it-forward/
115 ReFed. 2016. A Roadmap to Reduce U.S. Food Waste by 20%: Technical Appendix. Accessed online May 2022:
https://refed.org/downloads/ReFED Technical Appendix.pdf.
116 Institute for Local Self-Reliance. 2019. Community Composting Done Right: A Guide to Best Management Practices. Accessed online May 2022:
https://ilsr.org/composting-bmp-guide/.
117 U.S. Composting Council. The Case for Centralized Compost Manufacturing Infrastructure. Accessed May 2022.
Successful composting requires a healthy balance of both food
and yard waste. Composting requires a balanced mix of
materials that are rich in nitrogen or protein (also known as
"greens") and materials that are rich in carbon or carbohydrate
(also known as "browns"). The success of any compost project
relies on the existence of naturally occurring microorganisms to
break down organic waste and convert the waste into compost.
"Greens" help the microorganisms grow and multiply quickly
while the "browns" serve as a food source for the
microorganisms and allow air to filter through. Materials such
as food, wood, and grass and leaf clippings serve as valuable
sources of "greens" for a compost pile while materials such as
wood waste, e.g., tree branches and woody debris, serve as
valuable sources of "browns." (Source: Hu, Sheila. 2020.
"Composting 101." Natural Resources Defense Council.
Accessed online May 2022:
https://www.nrdc.org/stories/composting-101.)
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managed by a private compost companies or solid waste agencies and organic waste is typically
collected through curbside pick-up or drop-off.
EPA estimates an investment of $13.8 to $14.5 billion is needed to modernize composting infrastructure.
This investment would result in an additional 38 million tons of organics recycled, increasing the national
recycling rate to 45 percent. Exhibit 3-3 below provides a breakdown of investment estimates for
composting.
Exhibit 3-3. Investment Cost Estimates for Composting Food Waste and Yard Waste.
Composting Model
Cost Category
Low-End Estimate
High-End Estimate
Education & Outreach
$92,000,000
$92,000,000
Collection
$0
$0
At-Home Composting
Capital
$290,000,000
$290,000,000
Operating
$0
$0
Subtotal
$380,000,000
$380,000,000
Education & Outreach
$1,200,000,000
$1,200,000,000
Collection
$1,600,000,000
$1,600,000,000
Community Composting
Capital
$1,100,000,000
$1,100,000,000
Operating
$710,000,000
$710,000,000
Subtotal
$4,700,000,000
$4,700,000,000
Education & Outreach
$1,000,000,000
$1,000,000,000
Collection
$5,900,000,000
$5,900,000,000
Centralized Composting
Capital
$1,200,000,000
$2,000,000,000
Operating
$530,000,000
$530,000,000
Subtotal
$8,700,000,000
$9,400,000,000
Total
$13,800,000,000
$14,500,000,000
Note: Low-end and high-end estimates are driven by the count and capacity of new and upgraded recycling
facilities. The low-end estimates assume that not all existing facilities are operating at full capacity and could
intake a portion of the potentially recoverable materials, resulting in reduced capital costs. EPA's high-end
estimate assumes that facilities will not operate any closer to full capacity and that comparatively more facilities
will need to be built, which will result in higher capital costs.
Estimated using:
(1) Natural Resources Defense Council. 2017. Estimating Quantities and Types of Food Waste at the City Level. Accessed online May 2022:
httDs://www.nrdc.ore/sites/default/files/food-waste-citv-level-reDort.Ddf.
(2) ReFed. 2016. A Roadmap to Reduce U.S. Food Waste by 20%: Technical Appendix. Accessed online May 2022:
httDs://refed.ore/downloads/ReFED Technical ADDendix.odf.
(3) The Recycling Partnership. 2021. Paying it Forward: How Investment in Recycling Will Pay Dividends. Accessed online Sept. 2021:
httDs://recvclineDartnershiD.ore/read-Davine-it-forward/
(4) U.S. Composting Council. 2021. "Organics Bans and Mandates." Accessed online May 2022:
httDs://www.comDostinecouncil.ore/Daee/oreanicsbans.
(5) U.S. Composting Council. The Case for Centralized Compost Manufacturing Infrastructure. Accessed May 2022.
(6) Interviews with industry experts.
33
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EPA's composting estimates assume that:
• 45.6 percent of participating rural households will
compost at-home while the remaining 54.4 percent
will drop-off their organic material at community
com posters,118
• In addition to managing organic material from 54.4
percent of participating rural households, community
composters will manage 50 percent of organic
material from urban households119
• Centralized composters will manage all other organic
materials from commercial entities, institutional
entities, and the remaining 50 percent of urban households (both single and multi-family
households) not served by community composting.120
To avoid odor and pest issues, it is further assumed that at-home and community composting can only
compost vegetative waste (e.g., fruit and vegetable scraps), which represents 78 percent of generated
food waste.121 The analysis assumes that community compost operations cannot take food waste such as
meat and fish; liquids, oil, and grease (FOG); and dairy and eggs, though centralized composting
operations can accept all types of food and yard waste as part of curbside programs. Centralized
composting operations can process all types of food waste as these facilities have specialized industrial
equipment that can quickly compost organic material, reducing the potential for odor and pest issues
typically associated with composting non-
vegetative organic material.
EPA's low-end and high-end estimates are driven by
assumptions made on existing capacity for
centralized composting. EPA's low-end estimates
assume that around 204 new centralized
composting facilities will need to be built as states
with existing yard waste bans can retrofit existing
yard waste collection piles to include food waste
composting.122 EPA's high-end estimates assume
that states with existing yard waste bans cannot
118 EPA assumes that of all the participating rural households, 54.4 percent will compost via community centers and 45.6 percent will compost at
home. Since evidence-based data on rural composting participation and breakdown rates are not available, this assumption is based on the
percentage of the rural population living within metro areas as a proxy. Source: U.S. Census Bureau. 2016. Life Off the Highway: A Snapshot of
Rural America. Accessed Oct 2022: https://www.census.gov/newsroorn/blogs/randorn-
sarnplings/2016/12/life off the highwav.htrnl#:~:text=0ver%20half%20(54.4%20percent)%20of.population%20lives%20in%20rural%20areas
Based on feedback from the U.S. Composting Council, rural areas that are fairly close to a metropolitan area will likely have ample community
composting programs and will likely not be posed with prohibitively long distances to organic waste drop off sites while rural areas that are not
located close to a metropolitan area will likely face prohibitively long distances to travel to an organic waste drop off site and therefore, would
likely compost at home.
119 U.S. Composting Council. The Case for Centralized Compost Manufacturing Infrastructure. Accessed May 2022.
120 U.S. Composting Council. The Case for Centralized Compost Manufacturing Infrastructure. Accessed May 2022.
121 Natural Resources Defense Council. 2017. Estimating Quantities and Types of Food Waste at the City Level. Accessed online May 2022:
https://www.nrdc.org/sites/default/files/food-waste-citv-level-report.pdf.
122 U.S. Composting Council. 2021. "Organics Bans and Mandates." Accessed online May 2022:
https://www.compostingcouncil.org/page/organicsbans.
Equity Benefits of Community
Composting. Community composting
serves as a valuable resource to rural
households, as rural households are
typically not served by curbside programs
due to lack of density. However,
community composting, which may offer
pick-up services, can provide rural
residents, in particular those who do not
have the means to easily transport their
organic waste or cannot physically compost
at-home, access to organic recycling
services.
Tribal Community Project Example: Composting at the
Ho-Chunk Nation. For over 15 years, the Ho-Chunk Nation
has diverted over 50,000 pounds of food waste annually
from its local Majestic Pines Casino. Created with the help
of a Solid Waste Management Assistance Grant from the
U.S. EPA's Region 5 office, the composting program is
operated by the Nation's Health Office staff and distributes
the finished compost first to gardens in the Nation's
communities and then to individual members. (Source:
Jerome Goldstein. 2008. Tribal Composting Projects Across
The U.S. BioCycle. Accessed online Aug. 2022:
https://www.biocvcle.net/tribal-composting-proiects-
across-the-u-s/.)
34
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retrofit existing yard waste collection piles to include food waste composting so that approximately 450
new centralized composting facilities will need to be built, resulting in higher capital costs.
For investments in collection, EPA's estimate assumes that for centralized composting, collection costs
cover the costs of collection bins (e.g., kitchen top collection bins and secure toters for curbside pick-up)
and fuel to collect and transport organic waste from generators to a surrounding centralized composting
facility. EPA's estimate assumes that for community composting, collection costs cover the costs of
collection bins (e.g., kitchen top collection bins), but organic waste generators drop-off the organic waste
at existing local infrastructure such as farmers markets, transfer stations, or directly at community
composting sites. Due to the variability of community composting programs that offer and do not offer
collection services, the cost of these pick-up services for community composting programs is not included
in the national level estimate. In addition, given the on-site nature of at-home composting, EPA has
assumed no associated collection costs.
Capital costs for at-home and community composting operations include small scale equipment such as
rakes, shovels, and bins to turn and store the compost. For centralized composting, capital costs include
large-scale equipment such as trucks for collection, front-end loaders, bulldozers, compost turners, brush
chippers, and tub grinders. Both community and centralized composting capital costs include equipment
such as magnets and screens to address and reduce possible contamination. For centralized composting,
additional start-up costs, such as land acquisition, site prep, and permitting are included in estimates for
new construction.
Operating costs for community and centralized composting include the associated equipment and labor
costs for operations. While at-home composting requires residents to devote time to maintaining their
own compost piles, EPA has not included the time costs associated with management of residential
compost piles.
Key to all three composting operations is
education. All three composting models
consider the cost of educating residents and
applicable businesses and institutions on the
availability of composting programs and how
and what to compost. Education and outreach
costs are around $10 per household per year for
centralized and community models and likely
take the form of flyers, infographics, and other
written announcements on public platforms
(e.g., town websites, social media, etc.).123
Exhibit 3-4 has an example model of accepted
composting materials messaging from an
organics recycling program in Cambridge,
Massachusetts. Education for at-home
composting is much more involved and is
assumed to be $36 per household per year as
123 The Recycling Partnership. 2021. Paying it Forward: How Investment in Recycling Will Pay Dividends. Accessed online Sept. 2021:
https://recvclingpartnership.org/read-paving-it-forward/
Project Example: At-Home Composting Education in Orlando,
Florida. The City of Orlando hosts a robust residential
composting program. Residents living in single-family homes
are able to request a free composter from the Solid Waste
Division office. The office delivers the composter along with in-
depth, step-by-step materials on how to start composting. The
city's composting website also hosts publicly available videos on
how to start, maintain, and harvest compost along with a phone
line to call if residents need help troubleshooting their own
composting bins. As of October 2019, more than 6,500
residents have participated in the city's at-home composting
program. (Source: City of Orlando. 2022. Food Waste Drop-Off.
Accessed online Aug. 2022: https://www.orlando.gov/Our-
Government/Departments-Offices/Executive-
Offices/CAO/Sustainabilitv-Resilience/Green-Works-Focus-
Areas/Zero-Waste/Food-Waste-Drop-off & City of Orlando.
2022. Request a Free Composter. Accessed online Aug. 2022:
https://www.orlando.gov/Trash-Recvcling/Reauest-a-Free-
Composter)
35
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at-home composting requires hands-on or virtual training sessions to educate residents on how to
compost properly,124
Exhibit 3-4. Example Composting Messaging from the Cambridge, Massachusetts Composting Program.
WHAT GOES IN THE BIN
ALL FOOD SCRAPS including:
NOT
ACCEPTED
• Recycling
• Trash
• Yard Waste
• Pet Waste
617.349.4800
CambridgeMA.Gov/
ZeroWaste
KEEP THIS BIN LOCKED TO KEEP CRITTERS OUT ZERt- WASTE
Finally, it is important to note that the financial estimates above do not incorporate any benefits
associated with cost savings or revenue from the use and sale of finished compost as different models
accrue these benefits in different forms and thus cannot be easily modeled. Composting can produce
potential benefits, which include but are not limited to:
• Revenue for community and centralized composters, who can sell the produced compost to
landscapers, gardeners, farmers, and state and federal agencies (e.g., Department of
Transportation) The current price for compost ranges between $13 to $35 per cubic yard (the
price varies by feedstock material and finished product quality).125 Revenue from the sale of
compost can fund and compensate labor, supporting local jobs within communities.
• Cost savings incurred by residents and farmers, who can reduce the amount spent on synthetic
fertilizers from the use of compost.
124 ReFed. 2016. A Roadmap to Reduce U.S. Food Waste by 20%: Technical Appendix. Accessed online May 2022:
https://refed.org/downloads/ReFED Technical Appendix.pdf.
125 Waste360. 2004. "Doing the Dirty Work." Accessed online May 2022: https://www.waste360.com/composting-and-organic-waste/doing-dirty-
work.
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36
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• Cost savings to all at-home and community composters, who can save money on garbage disposal
costs through food waste and yard waste diversion.
• Resource savings (e.g., fuel and
water) and GHG emissions savings
associated with avoided production
of synthetic fertilizers.
• Ecosystem-wide benefits from
avoided water pollution and soil
degradation issues usually associated
with the use of synthetic fertilizers.
3.4.2 Anaerobic Digestion
Anaerobic digestion is a process through
which bacteria break down organic matter,
such as animal manure, wastewater
biosolids, and food wastes, in the absence of
oxygen. Anaerobic digestion for biogas
production takes place in a sealed vessel
called a reactor, which is designed and
constructed in various shapes and sizes
specific to the site and feedstock conditions.
Anaerobic digestion produces two valuable outputs: biogas and digestate. The energy in biogas can be
used like natural gas to provide heat, generate electricity, and power cooling systems, among other uses.
Biogas can also be purified to generate renewable natural gas (RNG). This can be sold and injected into the
natural gas distribution system, compressed and used as vehicle fuel, or processed further to generate
alternative transportation fuel, energy products, or other biochemicals and bioproducts. Digestate is the
residual material left after the digestion process. With appropriate treatment, digestate can be used as a
soil amendment or fertilizer.
There are two types of anaerobic digestion models considered in the report's estimates: centralized
anaerobic digestion and anaerobic digestion co-located with water resource recovery facilities (WRRF).
Centralized anaerobic digesters include standalone facilities located in industrial, commercial, or on-farm
settings, and food waste is typically trucked to
these facilities. WRRF anaerobic digestion
involve anaerobic digestion operations at water
resource recovery facilities (i.e., wastewater
treatment plants) that process both food waste
and sludge simultaneously. Typically, food
waste is delivered to these facilities through in-
sink disposals and sewage lines, but it can also
be trucked.
EPA estimates an investment of $499 million to
$532 million is needed to modernize anaerobic
digestion infrastructure and facilitate
Equity Benefits. Composting locally, either through community
composting or at-home composting, yields many equity benefits.
Such benefits include but are not limited to:
• Greener neighborhoods and improved local soils,
• Enhanced food security and fewer food deserts, and
• Less truck traffic from hauling garbage.
Community composting in particular also leads to:
• Social inclusion and empowerment through hands on volunteer
and education opportunities, and
• More local jobs and technical training.
Source: (Institute for Local Self-Reliance. 2014. State of Composting
in the U.S. Accessed online May 2022: https://cdn.ilsr.org/wp-
content/uploads/2014/07/state-of-composting-in-
us.pdf? el=l*4fxke0* ga*MTczNiE0MTc4LiE2NTY2MzevNDk.* ga
M3134750WM *MTY2MTI 10TclMi44LiEuMTY2MTl 10Tc2M i4wLiAu
MA..& ga=2.211537365.1967080789.1661184465-
173614178.1656638249.)
Tribal Community Project Example: Anaerobic Digestion at the
Forest County Potawatomi Community. Since 2013, the Forest
County Potawatomi Community has diverted 16 million gallons
of food waste annually to its 2-megawatt anaerobic digester.
The biogas produced is used to generate electricity, which is
sold to the local utility and used to power approximately 1,600
homes in the community. Excess heat is recovered and
beneficially reused. (Source: U.S. Department of Energy's Office
of Energy Efficiency and Renewable Energy. 2022. Renewable
Energy Deployment Projects for Forest County Potawatomi
Community. Accessed online Aug. 2022:
https://www.energv.gov/eere/technology-to-
market/renewable-energv-deplovment-proiects-forest-countv-
potawatomi-communitv.)
37
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equivalent access to organics recycling. This investment would result in an additional 2.1 million tons of
organics recycled, increasing the national recycling rate to 33 percent. Exhibit 3-5 below provides a
breakdown of investment estimates.
Exhibit 3-5. Investment Cost Estimates for Anaerobically Digesting Food Waste.
Anaerobic Digestion Model
Cost Category
Low-End
Estimate
High-End
Estimate
Education & Outreach
$8,400,000
$8,400,000
Collection
$160,700,000
$160,700,000
Centralized Anaerobic Digestion
Capital
$135,200,000
$149,500,000
Operating
$117,600,000
$117,600,000
Subtotal
$421,900,000
$436,200,000
Education & Outreach
$8,400,000
$8,400,000
Collection
$0
$0
WRRF Anaerobic Digestion
Capital
$48,000,000
$67,000,000
Operating
$20,000,000
$20,000,000
Subtotal
$77,000,000
$96,000,000
Total
$499,000,000
$532,000,000
Note: Low-end and high-end estimates are driven by the count and capacity of new and upgraded
recycling facilities. The low-end estimates assume that not all existing facilities are operating at full
capacity and could intake a portion of the potentially recoverable materials, resulting in reduced capital
costs. EPA's high-end estimate assumes that facilities will not operate any closer to full capacity and that
comparatively more facilities will need to be built, which will result in higher capital costs.
Estimated using:
(1) ReFed. 2016. A Roadmap to Reduce U.S. Food Waste by 20%: Technical Appendix. Accessed online May 2022:
httDs://refed.ore/downloads/ReFED Technical ADDendix.odf.
(2) U.S. EPA. 2021. Anaerobic Digestion Facilities Processing Food Waste in the United States (2017 & 2018). Accessed online May
2022: httDs://www.eDa.eov/sites/default/files/2021-02/documents/2021 final ad report feb 2 with links.odf.
(3) U.S. EPA Office of Resource Conservation and Recovery. 2020. 2019 Wasted Food Report.
(4) Interviews with industry experts.
In terms of specific pathways, EPA's estimates assume that:
• Of MSW food waste, only commercial and institutional food waste gets managed by anaerobic
digestion, due to the need for consistent feedstock as noted by the recycling experts interviewed
residential food waste does not typically meet requirements for consistency. (Currently, only 1
percent of MSW food waste from the residential sector is managed by anaerobic digestion.)126
• 86 percent of food waste quantities available for anaerobic digestion is managed by centralized
anaerobic digestion facilities while the remaining 14 percent is managed by WRRF anaerobic
digestion.127
126 U.S. EPA Office of Resource Conservation and Recovery. 2020. 2019 Wasted Food Report.
127 U.S. EPA. 2021. Anaerobic Digestion Facilities Processing Food Waste in the United States (2017 & 2018). Accessed online May 2022:
https://www.epa.gov/sites/default/files/2021-02/documents/2021 final ad report feb 2 with links.pdf.
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For centralized anaerobic digestion, EPA's low-end and high-end estimates are driven by assumptions
related to existing capacity. There are currently 275 anaerobic digesters in operation.128 EPA's low-end
estimates assume that around 13 new AD facilities will need to be built because not all existing anaerobic
digestion facilities are operating at full capacity.129 EPA's high-end estimates assume that all existing AD
facilities will not operate any closer to full capacity and that around 25 new AD facilities will need to be
built to manage MSW generated food waste, resulting in higher capital costs. (Note that these estimates
for newly constructed AD facilities only cover new AD construction to manage MSW food waste through
anaerobic digestion. For efforts to capture food waste from non-MSW sources, such as food
manufacturers, the total number of AD facilities needed will likely be higher. Currently, 97 percent of food
waste managed by anaerobic digestion stems from non-MSW sources, such as food manufacturers and
processors.)130
For collection, EPA's estimate assumes that for centralized anaerobic digestion, collection costs cover the
costs of collection bins (e.g., secure toters for curbside pick-up from commercial and institutional settings)
and fuel to collect and transport food waste from generators to a surrounding centralized anaerobic
digestion facility. EPA assumes no collection associated with WRRF anaerobic digestion as food waste
managed by water resources recovery facilities are delivered to the facilities through in-sink disposals and
existing sewer lines.
EPA's estimate of capital costs for anaerobic digestion includes infrastructure and equipment costs such
as anaerobic vessels and monitoring equipment. Additional start-up costs, such as land acquisition, site
prep, and permitting are included in estimates for new construction. For WRRF anaerobic digestion in
particular, capital costs are only assumed for the food waste anaerobic digestion portion of new WRRFs
and does not include capital costs associated with general wastewater treatment.131 Operating costs
include the associated equipment and labor costs for operations and maintenance.
Finally, given the need for consistent, non-contaminated feedstock, centralized anaerobic digestion
estimates also include investment estimates for education and outreach. Education and outreach costs
are around $10 per commercial and institutional establishment per year and likely take the form of
distributing flyers and infographics.132
The financial estimates above do not incorporate
any benefits associated with cost savings or
revenue from the use and sale of biogas and
digestate produced from anaerobic digestion
operations. Anaerobic digestion can produce
potential benefits, which include but are not
limited to:
Additional benefits from fleet electrification. As waste
management providers look to electrify fleets, the
production of electricity from anaerobic digestion could
be possibly used to power collection vehicles for
anaerobic digestion facilities. This could provide added
benefits for emissions and pollution reduction and noise
reduction from waste collection.
128 U.S. EPA. 2022. Anaerobic Digestion Facilities Processing Food Waste in the United States (2019). Accessed online May 2022:
https://www.epa.gov/anaerobic-digestion/anaerobic-digestion-facilities-processing-food-waste-united-states-survev.
129 U.S. EPA. 2021. Anaerobic Digestion Facilities Processing Food Waste in the United States (2017 & 2018). Accessed online May 2022:
https://www.epa.gov/sites/default/files/2021-02/docurnents/2021 final ad report feb 2 with links.pdf.
130 U.S. EPA Office of Resource Conservation and Recovery. 2022. 2019 Wasted Food Report.
131 Due to data limitations, EPA's estimates do not consider expanding anaerobic digestion systems to current WRRFs, although this option may be
technologically feasible.
132 The Recycling Partnership. 2021. Paying it Forward: How Investment in Recycling Will Pay Dividends. Accessed online Sept. 2021:
https://recvclingpartnership.org/read-paving-it-forward/.
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• Revenue for operators, who can sell the produced biogas and digestate.
• Cost savings to all participating institutional and commercial customers, who can save money on
garbage disposal costs through food waste diversion.
• Resource (e.g., fuel and water) and GHG emissions savings associated with avoided production of
synthetic fertilizers and energy from fossil fuels.
• Ecosystem-wide benefits from the production of renewable energy in place of fossil fuel-derived
energy.
3.4.3 Livestock Feed
Food waste that is no longer edible to humans but still safe for animals can be re-purposed and recycled
into livestock feed. Typically, vegetative wastes are fed to cows, sheep, goats, and poultry while vegetative
and meat wastes are fed to swine. EPA estimates an investment of $450 million to $500 million is needed
to modernize livestock feed infrastructure and facilitate equivalent access to organics recycling. This
investment would result in an additional 3.9 to 4.4 million tons of organics recycled, increasing the
national recycling rate to 33 to 34 percent. Exhibit 3-6 below provides a breakdown of investment
estimates.
Exhibit 3-6. Investment Cost Estimates for Recycling Food Waste as Animal Feed.
Cost Category
Low-End Estimate
High-End Estimate
Collection
$310,000,000
$350,000,000
Capital
$66,000,000
$75,000,000
Operating
$75,000,000
$84,000,000
Total
$450,000,000
$500,000,000
Note: EPA's low-end and high-end estimates are driven by how much food waste is potentially
recycled as livestock feed. For low-end estimates, estimates assume that states with any restrictions
on livestock feed will not participate in recycling food waste into livestock feed. The higher-end
estimates assume that states with select feed restrictions regarding meat as livestock feed will not
participate in recycling food waste into livestock feed.
Estimated using:
(1) Natural Resources Defense Council. 2017. Estimating Quantities and Types of Food Waste at the City Level. Accessed
online Mav 2022: https://www.nrdc.org/sites/default/files/food-waste-citv-level-reDort.Ddf.
(2) ReFed. 2016. A Roadmap to Reduce U.S. Food Waste by 20%: Technical Appendix. Accessed online May 2022:
https://refed.org/downloads/ReFED Technical Appendix.pdf.
(3) U.S. EPA Office of Resource Conservation and Recovery. 2020. 2019 Wasted Food Report.
EPA's low-end and high-end estimates are driven by how much food waste is potentially recycled as
livestock feed. To prevent disease outbreaks associated with animal feed (e.g., mad cow disease, also
known as foot-and-mouth disease in swine and bovine spongiform encephalopathy), several existing
federal and state laws and regulations limit how much food waste can be recycled as livestock feed. Some
states have feed restrictions on using both meat and vegetative waste for livestock feed, while other
states have feed restrictions on using meat waste as livestock feed but do allow for using vegetative waste
as livestock feed. EPA's low-end estimate assumes 3.9 million tons of food waste is available for recycling
as livestock feed while EPA's high-end estimate assumes that 4.4 million tons of food waste is available for
recycling as livestock feed. EPA's low-end estimate assumes that the states with any type of restriction
(e.g., meat waste only or both meat and vegetative waste) on feeding food waste to livestock will not
40
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recycle food waste as livestock feed.133 EPA's high-end estimate assumes that all states will recycle food
waste as livestock feed except for the states that currently have restrictions on feeding meat waste to
livestock (i.e., states that only restrict meat waste will still recycle vegetative waste in the high-end
scenario).134
EPA's estimate assumes that collection costs cover the costs of fuel to collect and transport animal feed
from food waste generators to surrounding livestock farms. Given the need for consistent, large volume,
and unprocessed food waste as livestock feed, EPA assumes that only commercial entities such as grocery
stores (as opposed to other generators like the residential sector) are likely to use livestock feed as an
organics recycling method. Capital costs include the purchase of heat treatment and dehydration
equipment to comply with existing federal livestock feed regulations and reduce the weight of food waste
to minimize transport costs. Operating costs include the costs associated with operating the food waste
treatment equipment and distributing and feeding the food waste to livestock.
It is important to note that the financial estimates above do not incorporate any cost savings associated
with recycling food waste into livestock feed. Recycling food waste into livestock feed can produce
potential benefits and associated cost savings, which include, but are not limited to:
• Cost savings incurred by farmers, who can use food waste to supplement costly animal feed.
• Cost savings to food waste generators, who can save money on garbage disposal costs through
food waste diversion.
• Resource savings (e.g., fuel, water, etc.) and GHG emissions savings associated with the avoidance
of growing and distributing food specifically as animal feed.
3.5 Summary and Investment Considerations
EPA estimates that an investment of $14 to $16
billion in composting, AD, and livestock
infrastructure by 2030 could potentially recover an
additional 44 million tons, increasing the nation's
overall recycling rate from its current level of 32
percent to 47 percent, close to EPA's nationwide
goal of 50 percent. Notably, investment estimates in
this report do not factor in source reduction and its
effect on existing food waste generation quantities.
Upcoming grants (such as grant programs under the
Bi-Partisan Infrastructure Law), legislation enacted
by Congress (such as the Bill Emerson Good
Samaritan Food Donation Act and the Food
Donation Improvement Act), and proposed
legislation (such as the Healthy Meals, Healthy Kids
Act and the Zero Food Waste Act) all work to reduce
or prevent food waste by increasing opportunities
for food rescue, reallocating surplus food, and
Comparison with Existing Estimates. There are currently other
estimates publicly available on the level of investment needed
to expand recycling infrastructure opportunities for organic
materials. A popular study is ReFED's Roadmap to 2030 report,
which estimates that an investment of $14 billion is needed to
reduce and recycle food waste by 2030. EPA provides a higher
bound estimate for several reasons:
• ReFED assumes that source reduction will serve as the driving
factor behind food waste reduction, avoiding the need for
unnecessary infrastructure. EPA's estimates assume that
food waste will continue at the same rate of generation at
present levels. Investment in source reduction is typically
cheaper than that for infrastructure on a per ton basis.
• The ReFED model does not include cost estimates for yard
waste. EPA's estimate includes costs for recycling food and
yard waste together.
• The ReFED model does not include cost estimates associated
with collection bins, large-scale outreach and education, land
acquisition, site preparation, permitting, etc.
133 These states include Alabama, Delaware, Idaho, Illinois, Kansas, Kentucky, Louisiana, Mississippi, Nebraska, North Dakota, Oregon, South
Carolina, South Dakota, Texas, Vermont, and Wisconsin.
134 These states include Alabama, Illinois, Kansas, Kentucky, Louisiana, Mississippi, North Dakota, Oregon, South Dakota, and Wisconsin.
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restricting the disposal of food waste.135 136-137<138 To the extent that Congress enacts currently pending
legislation, EPA may wish to revisit the infrastructure investment assessment as source reduction can
significantly reduce the generation of food waste and, consequently, the regional infrastructure and
financial investment needed to address potentially recyclable organic materials.
For successful capture of potentially recyclable
organics waste, investments in collection,
education, and building organics recycling
processing capacity should be made
simultaneously. Multiple organics recycling
experts interviewed recommend recycling
providers and municipalities to work together
first to assess local interest in participating in
recycling programs, the availability of organics for
recycling, the availability of land for recycling
infrastructure, and available financing options
(including grants), then expand or build new
infrastructure accordingly (see Section 4 for more
information on financing mechanisms). To avoid
situations with multiple service providers
overbuilding capacity for the expected volume of
organic feedstock in a specific region, experts
advise local permitting departments to be
included in initial assessment conversations as
permitting officials will have deep knowledge on
local proposed infrastructure projects and
possible sites that meet permitting requirements
for recycling infrastructure expansion.
Policies to promote the use and sale of recycled
organic material should also be made
concurrently with other investments to spur the
demand and investment for organics recycling infrastructure. Policies such as pay-as-you-throw programs,
where landfills charge residents and businesses for the collection of MSW based on the amount thrown
away, or organic waste landfill bans could help to disincentivize the landfilling of organic materials and
instead lead to recycling such materials. For instance, five states now have landfill food waste bans.
Massachusetts's landfill ban on commercial food waste, implemented in 2014, increased annual food
rescue and organics recycling from a baseline of 100,000 tons in 2010 to more than 270,000 tons in
135 42 U.S.C. 1791. Bill Emerson Good Samaritan Food Donation Act. Accessed online Nov. 2024
https://uscode.house.gov/view.xhtrnl?rea=(title:42%20section:1791%20edition:prelirn)%200R%20(granuleid:llSC-prelirn-title42-
%20sectionl791)&f=treesort&edition=prelirn&nurn=0&iurnpTo=true
136117th Congress. 2021. Senate Bill 3281: Food Donation Improvement Act of 2021. Accessed online Aug. 2022:
https://www.congress.gov/bill/117th-congress/senate-bill/3281.
137117th Congress. 2022. House Bill 8450: Healthy Meals; Healthy Kids Act. Accessed online Aug. 2022: https://www.congress.gov/bill/117th-
congr ess/ho us e-bill/8450/actions?r=l&s=l.
138117th Congress. 2021. House Bill 4444: Zero Food Waste Act. Accessed online Aug. 2022: https://www.congress.gov/bill/117th-congress/house-
bill/4444?s=8&r=2.
Investment estimates do not factor in the growing complexity
associated with compostable packaging and serviceware. As
the use of compostable packaging becomes mainstream, issues
associated with increased contamination arise as compostable
packaging and non-compostable packaging can appear to be
very similar, confusing consumers. Replacing all packaging with
compostable packaging may ultimately work to increase the
quantity of material available for organics recycling and reduce
contamination. However, the uptake of compostable packaging
is currently unknown as research in the intended and
unintended impacts of compostable packaging is currently in its
early stages.
For instance, initial research suggests that compostable
packaging may lead to an increase in microplastics, remnants of
plastics from coatings found in packaging, in finished compost.
Once land applied, these microplastics can enter the ecosystem,
potentially exposing wildlife and humans to dangerous
concentrations of chemicals found in microplastics, such as
PFAS and dioxins. However, the exact impacts of compostable
packaging are currently unknown and not yet widely
researched. Currently, many composting facilities do not accept
BPI-certified compostable packaging and serviceware as it does
not break down well in facilities and results in contamination.
As more information on compostable packaging becomes
available, EPA may consider updating the analysis and estimates
accordingly. (Source: Woods End Laboratories and Ecocycle.
2018. Microplastics in Compost. Accessed online May 2022:
https://www.ecocvcle.org/files/pdfs/microplastics in compost
summarv.pdf.)
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2016.139 Currently, California has expanded its existing landfill ban on organic waste by instituting SB 1383
("Short-Lived Climate Pollutant Reduction" law), which aims to ban organic waste from residences and
businesses to ultimately divert 75 percent of organic waste from landfill by 2025.140 A subject matter
expert interviewed noted that cities with mandatory organics recycling programs were able to achieve a
minimum 50 percent participation rate within the first year.141
A key factor missing from this analysis is the impact to end market prices from an increased supply of
recycled materials. Estimating the price impact for end markets is out of scope for the present analysis.
Qualitatively, increased recycled material supply linked with access to collection equivalent to trash
disposal services and increased organic material processing capacity could lead to an overall decrease in
market prices for finished compost/digestate for which demand is low. A forecasted decrease in market
prices for finished compost/digestate could be combated somewhat by policies encouraging the use and
application of recycled organic material. Policies, such as recycled purchasing mandates, could spur the
market for recycled organic materials. The American Biogas Council recommends having municipalities
institute specific policies to drive the market for organic recycling outputs, such as ordinances mandating
finished compost and digestate be used for local landscaping projects.
While the expansion of organics infrastructure is needed nationwide, there are select regional areas with
high rates of potentially recyclable organics waste and a general lack of organics recycling infrastructure; it
may be beneficial to focus initial infrastructure investments in these areas first. EPA conducted a
qualitative spatial needs analysis using the Recycling Infrastructure and Market Opportunities map, which
maps current recycling infrastructure against existing quantities of organic waste generated. Latest
available data indicate that there are geographic areas generating high volumes of potentially recyclable
organics waste (denoted in Exhibit 3-7 as dark green) and currently do not have the surrounding
infrastructure to manage the tonnage of potentially recyclable organic waste.
139 Rosengren, C. 2016. "Massachusetts Commercial Food Waste Ban Has Generated $175M in Economic Activity/' WasteDive. Accessed online
Sept. 2022: https://www.wastedive.com/news/massachusetts-commercial-food-waste-ban-has-generated-175m-in-economic-act/432904/
140 Waste Management. 2021. "What is SB 1383?" Accessed online Sept. 2022: https://www.wm.com/us/en/sbl383
141 This statistic was cited in an interview with BioCycle.
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Exhibit 3-7. Geographic Prioritization Anaiysis for Organics Recycling Investment Opportunities.142
O U.S. Major Cities
° AD facilities (food only)
o AD facilities (all)
• Composting facilities (food only)
o Composting facilities (all)
Potentially recoverable organic materials (tons)
0.40- 1,700
1,700-4,600
WM 4,600 -8,400
M 8,400 - 18,600
These geographic regions include the:
• South (in particular, parts of Louisiana, Alabama and Mississippi);
• Southwest (in particular, parts of Texas, Arizona, New Mexico, and Oklahoma); and
• Rocky Mountains (in particular, parts of Montana, Idaho, Colorado, and Nevada).
Investments in these geographic areas may help to rapidly capture large volumes of organic waste.143 (See
Appendix B for detailed maps of organic feedstock and composting and anaerobic digestion
infrastructure.)
Finally, when considering equivalent access to organics recycling on par with access to trash disposal,
communities with higher rates of low-income, unemployed, and other disadvantaged populations must be
considered. The development of new composting or anaerobic digestion facilities may uniquely and
disproportionately impact marginalized communities, such as through an increased risk of odor, noise,
traffic congestion, and associated health concerns. Policymakers should pay close attention to the needs
142 Data retrieved from the Recycling Infrastructure and Market Opportunities Map. https://www.epa.gov/circulareconomy/recvcling-
infrastructure-and-market-opportunities-map.
143 Note that areas in the South, Southwest, and Rocky Mountains currently lack the critical infrastructure to process additional organic materials
for a variety of legislative, policy, and administrative reasons.
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of these communities and ensure that they both have equivalent access to organics recycling services and
are not unfairly affected by investments in recycling infrastructure.
Exhibit 3-8 displays several types of composting and anaerobic digestion facilities overlayed with the
Supplemental Demographic Index from EPA's EJScreen.144 This index is based on the average of five
socioeconomic indicators; low-income, unemployment, limited English, less than high school education,
and low life expectancy. The map below illustrates how communities that are higher on the Supplemental
Demographic Index (indicated by orange or red) are more likely to be located in areas that lack adequate
organics recycling infrastructure (e.g., the South, Southwest, and Rocky Mountains) and have a high rate
of potentially recoverable organic waste, as shown in Exhibit 3-7. Similar to the environmental justice
analysis on packaging materials and infrastructure, this spatial evaluation should serve only as a
foundational framework for incorporating environmental justice into organics recycling, as well as to
highlight the need for further consideration when determining opportunities to finance investments.
Exhibit 3-8. Geographic Prioritization Analysis with Environmental Justice Considerations for Organics
Recycling Investment Opportunities145
Legend
© AD facilities (food only)
O AD facilities (all)
• Composting facilities (food only)
O Composting facilities (all)
EJScreen Supplemental Demographic Index
¦|0-
19-39
39-60
60 - 80
80 - 99
144 U.S. EPA. 2022. EJ and Supplemental Indexes in EJScreen. Accessed online January 2023: https://www.epa.gov/eiscreen/ei-and-supplemental-
indexes-eiscreen#what-supplemental
145 Data retrieved from the Recycling Infrastructure and Market Opportunities Map. https://www.epa.gov/circulareconomv/recvcling-
infrastructure-and-market-opportunities-map.
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Section 4: Financial and Resource Support
Several mechanisms can be used to finance recycling infrastructure investments detailed in Sections 2 and
3 of this report. These mechanisms include financing of different types from government, private sector,
hybrid public-private partnerships, and fee-based programs, which are discussed in more detail in the
sections below.
4.1 Government Financing Options
Resources are often provided by local, state, and federal governments to finance recycling programs. The
most common form of government financing is grants, which typically assist recycling programs by
covering a portion of total project costs. In return, grant recipients are required to provide grant programs
with periodic project updates and an explanation of how funds were used. The federal government
currently hosts a number of grant programs to support the construction and expansion of recycling
infrastructure, some of which are detailed below:
• EPA's Solid Waste Infrastructure and Recycling (SWIFR) Grants - $275,000,000 ($55 million
nationally/year from FY22-26). These grants support improvements to local post-consumer
materials management, including state waste management planning and implementation,
municipal recycling infrastructure improvements, and assist local waste management authorities
in making improvements to local waste management systems. States, territories (including the
District of Columbia), federally-recognized tribes, Intertribal Consortia, former reservations, and
Alaskan Native Villages are also eligible. More information about the SWIFR Grants can be found
on EPA's website.
• EPA's Recycling Education and Outreach Grants - $75,000,000 ($15 million nationally/year from
FY22-26). These grants are focused on improving material recycling, recovery, management, and
reduction. Projects funded through the grant program inform the public about residential or
community waste prevention or recycling programs and provide information about the recycled
materials that are accepted to increase collection rates and decrease contamination across the
nation. More information about the SWIFR Grants can be found on EPA's website.
• EPA's Hazardous Waste Management Grant Program for Tribes - $300,000 in FY22. These grants
support tribes or Intertribal Consortia in the development and implementation of hazardous
waste management on tribal lands, including education and infrastructure to encourage recycling,
reuse, and source reduction among tribal
communities.
• EPA's Indian Environmental General Assistance
Program (GAP) - $66,250,000 in FY22. GAP funds
may be used to fund activities that are necessary
for the tribe to plan and develop solid waste and
material recovery infrastructure and provide solid
waste and material recovery services on reservation
lands.
• EPA's AD Funding Opportunity - $2,000,000
nationally/year with an individual award range of
$50,000 to $200,000. These grants support
diversion of food waste and organic materials from
Tribal Community Considerations. Many tribes
depend on GAP to fund environmental program
staff positions, and GAP comes with a host of
reporting requirements unique to the grant. Due
to frequent staff turnover in tribal solid waste
management programs, there is a significant loss
of institutional knowledge for maintaining this
critical source of funding. During a recent
listening session for EPA's Solid Waste
Infrastructure and Recycling (SWIFR) grant, EPA
heard from several commenters that capacity
issues to apply for, manage, and implement
grants to fund recycling programs are a problem
for tribes.
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landfills through the acceleration and
development of new AD facilities or capacity
expansion for existing AD facilities.
• USDA's Community Compost and Food Waste
Reduction Program - $2,000,000
nationally/year. These grants support
composting projects that divert organics from
the landfill, including community garden and
on-farm composting projects. This program
will see an additional $30 million investment
toward a feasibility study to support a
national-level food loss and waste prevention
strategy.146
Other forms of direct government financing include
bond issuance. Federal, state, and local governments
can issue bonds to raise money for public service
facilities and infrastructure, such as roads, bridges,
hospitals, and material management facilities. The
bond issuer (i.e., state and/or local governments) sells
the bond to the bond holder (i.e., the investor). The
bond holder lends the bond issuer a fixed amount of
funds for a certain time period in exchange for
regularly scheduled interest payments, which are
typically exempt from national taxes and hold a long
maturity period. Bond issuers generally provide bond
holders with annual financial information until they
mature or are redeemed. Bonds are typically issued in
situations where municipalities are unable to fully fund
their own materials management operations.
Another popular form of government financing is income tax credits. Federal, state, and local
governments can provide tax credits that may be used as an incentive to private industry to fund projects
that broadly benefit the public and use recycled content in product manufacturing to spur demand within
the recycling industry. For instance, many states host state recycling tax incentive programs where
recycling providers can receive a percentage-based income tax credit for the cost of recycling equipment
or an employment income tax credit for each employee hired in service of incorporating recycled products
into product manufacturing.147
Several proposed bills may increase future grant
opportunities geared toward municipal recycling
programs. For instance, bills such as the Realizing the
Economic Opportunities and Values of Expanding
Recycling Act (RECOVER) Act, will provide up to $500
million in matching federal grants for improvements
to MRFs, curbside collection systems, and education
programs. (Source: 117th Congress. 2021. House Bill
2357: RECOVER Act. Accessed online Aug. 2022:
https://www.congress.gov/bill/117th-
congress/house-bill/2357/text?r=l&s=l.)
Other bills for consideration focus on increasing
recycling infrastructure in specific locations. For
instance, bills such as the Recycling Infrastructure and
Accessibility Act would grant between $500,000 and
$15 million each for projects that make recycling
services more accessible to rural and disadvantaged
communities that do not have reliable or nearby
access to MRFs. (Source: 117th Congress. Senate Bill
3742: Recycling Infrastructure and Accessibility Act of
2022. Accessed online Aug. 2022:
https://www.congress.gov/bill/117th-
congress/senate-bill/3742.)
Other bills for consideration focus on recycling more
specific materials. For instance, the Cultivating
Organic Matter through the Promotion of Sustainable
Techniques (COMPOST) Act, currently before the
House Subcommittee on Conservation and Forestry,
would allocate $200 million a year through 2031 for
composting infrastructure projects through grants
and loan guarantees. (Source: 117th Congress. House
Bill 4443: COMPOST Act. Accessed online Aug. 2022:
https://www.congress.gov/bill/117th-
congress/house-bill/4443.)
146 USDA. 2022. "USDA Announces Framework for Shoring Up the Food Supply Chain and Transforming the Food System to Be Fairer, More
Competitive, More Resilient." Press Release No. 0116.22, published on USDA.gov. Accessed online June 2022: https://www.usda.gov/rnedia/press~
releases/2022/06/Ol/usda-announces-framework-shoring-food-supplv-chain-and-transfonTiing
147 U.S. EPA. 2016. EPA Web Archive: State Recycling Tax Incentives. Accessed online May 2022:
https://archive.epa.gov/wastes/conserve/tools/rmd/web/html/rec-tax.html.
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For all government-based funding, it is important to note that financing mechanisms should be directed
toward proven recycling technologies due to limited resource ability for municipalities to take on risk
associated with new, emerging technologies.
4.2 Private Sector Financing
There are many private sector financing options with varying
levels of application to different types and locations of
recycling-related projects. Popular financing mechanisms
include equity, in which investors provide funding toward
specific materials management projects. In return, equity
investors typically require a stake in the recycling operation or
some other form of return for their investment. The most
common form of equity investment is selling stock in publicly-
owned companies; privately-owned companies may arrange
similar forms of financing for specific direct investors.
Another popular financing mechanism is debt financing, in
which businesses, (i.e., recycling providers) take out loans from
banks, credit unions, and other savings institutions. Typically, a
bank provides the loan for a pre-determined period of time and
the borrower (i.e., the materials management provider) repays
the loan within the allotted time with interest.
Finally, the other source of private sector financing is own-source revenue, wherein a business uses its
own funds generated from existing revenue to fund the expansion of existing or construct new
infrastructure. This option is available to established recycling providers with the capital necessary to
pursue construction without financing.
These options are most applicable for private sector businesses such as subscription-based collection
service providers (whereby they charge a recurring fee to pick up recycling on a regular basis), recyclers,
and end-market buyers, who typically see a higher return on
their infrastructure investments than state, municipal, or tribal
governments.
Project example: Waste Management.
Waste Management, a comprehensive
waste and environmental services
company operating across the U.S.,
recently announced their plans to invest
$800 million over the next three years in
their recycling facilities. This investment is
geared toward automating internal
recycling processes and expanding
infrastructure to underserved
geographies. (Source: WasteDive. 2022.
"Waste Management Planning $1.6B in
ESG investments." Accessed online Nov
2022:
https://www.wastedive.com/news/waste
-management-q4-2021-esg-rng-recvcling-
automation/618103/)
4.3 Public-Private Partnership
Public-private partnerships can vary considerably from project
to project. In a public-private partnership, a government entity
supports a private entity by subsidizing some portion of total
investment costs for a service that the government entity
would not otherwise be able to provide. This type of financial
agreement can be particularly helpful for the recycling
infrastructure sector as a private company can purchase the
land, pay engineers to design the facility, operate the facility,
Project example: Atlas Organics Durham.
This 65,000 ton per year facility in
Durham, NC composts yard waste, food
waste, and biosolids through a public-
private partnership with the City of
Durham. The company has an 11-year
contract with the City to process these
feedstocks, ensuring a consistent source
of revenue while the City is able to make
gains on goals to reduce waste sent to
the landfill. (Source: Atlas Organics. 2022.
"Atlas Organics in North Carolina."
Accessed online May 2022:
https://atlasorganics.net/locations/north-
carolina/durham/.)
and sell recyclable commodities to continue financing future
operations. Municipalities can streamline the permitting process during the construction phase, oversee
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the collection of recycled materials during the operations phase, and ensure the consistent flow of
recycling feedstocks.
Successful public-private partnerships require consistent collaboration between government officials,
community organizations, and recycling service providers.
4.4 Fee-Based Programs
Structured fee programs also serve as a possible financing instrument. For instance, landfill tipping fees or
a pay-as-you-throw fee programs can work to reflect the "true" cost of landfill disposal and provide
residents with an understanding of the cost of waste. In pay-as-you-throw programs, fees are typically
weight-based and capture the costs associated with the maintenance and operating costs to operate a
landfill in compliance with state and federal regulations. The average tipping fee in the U.S. is $53.72 per
ton and regional MSW tip fees range from $39.66 per ton in the South-Central region to $72.03 per ton in
the Pacific region.148 By internalizing the costs of landfilling through a fee, local recycling programs can
fund various projects and incentivize residents and businesses to reduce reliance on landfill disposal
through recovery and recycling.
Additional structure fee programs, such as bottle deposit programs (analyzed in Section 2 of this report)
can help to fund recycling programs.149 Beverage container deposit programs require a minimum
refundable deposit on beer, soft drink, and other beverage containers to ensure a high rate of recycling or
reuse. This deposit is refunded when containers are returned for recycling or reuse. When consumers
choose not to redeem their used beverage containers for the deposit value (either because they recycled
them through curbside or other public recycling programs or threw them in the trash), the deposit money
is considered "unclaimed." Depending on the state, state agencies can collect unclaimed deposit funds to
fund recycling programs. Currently, eight of the 10 states with bottle deposit programs re-allocate 75 to
100 percent of unclaimed deposits to state agencies to fund and manage municipal recycling programs,
educate the public on recycling programs, and promote markets for recycled material. In 2021,
Connecticut, Maine, Massachusetts, Michigan, New York, and Vermont re-allocated approximately $350
million in unclaimed deposits toward state recycling programs.150
148 Environmental Research & Education Foundation. 2021. Analysis of MSW Landfill Tipping Fees — 2020. Accessed Aug. 2022:
https://www.erefdn.org/product/analvsis-msw-landfin-tipping-fees-2/
149 Currently, 10 states have deposit programs: California, Connecticut, Hawaii, Iowa, Maine, Massachusetts, Michigan, New York, Oregon, and
Vermont.
150 Container Recycling Institute. 2022. Bottle Bill Resource Guide: The Fate of Unclaimed or Abandoned Deposits. Accessed Aug. 2022:
https://www.bottlebin.org/index.php/about-bottle-bins/the-fate-of-unclaimed-or-abandoned-deposits
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Section 5: Additional Materials for Future Consideration
EPA determined the scope of this assessment to include packaging and organic materials with established
end markets and proven technology to process materials at scale; this is part of the focus on near-term
investments needed to provide recycling services that are on par with disposal. As a result, materials such
as electronics (including batteries), textiles, and plastics #3 to #7 are not included in this assessment.
However, it is important to note that these materials are growing in significance and require thoughtful
consideration of how to maximize source reduction and promote reuse, as well as how best to upgrade
and integrate infrastructure required for recycling. These topics are discussed in the sections below.
5.1 Electronics
Electronics waste is a fast-growing material waste stream with unique challenges and opportunities
related to disassembly and recovery of high-value components that include rare metals. While 25 states
and the District of Columbia have enacted legislation establishing statewide electronics waste, or e-waste,
recycling programs, recent data suggest that the U.S. generates 6.7 million tons of electronic waste and
only captures 16 percent for recycling.151,152
Product redesign is one critical strategy in the effort to
reduce the landfill of electronics waste. A recent UN
report notes that electronic products need to be
designed for reuse, durability, and safe recycling.153
Design elements should incorporate durability and ease
of repair to ensure that devices are kept in circulation
longer, reducing overall generation of electronic waste.
In addition, easy disassembly should also be
incorporated into the product design so that recyclable
components can be seamlessly extracted and recycled at
the end of the product's life.
Recycling infrastructure is needed to process and
recapture potentially valuable recyclable electronic
product components, which include plastics, glass, and
precious metals such as silver, gold, palladium, and copper. Currently, there are 772 identified certified
electronics recyclers in the U.S.,154 as shown in Exhibit 5-1.
Global electronic waste generation is expected to more than double by 2050.155 Given the rapid growth of
this waste stream, investment in additional collection and processing infrastructure is needed to bolster
recycling rates and capture future generation of electronics waste.
151 National Conference of State Legislatures. 2018. Electronic Waste Recycling. Accessed online July 2022:
https://www.ncsl.org/research/environrnent-and-natural-resources/e-waste-recvcling-legislation.aspx.
152 The Global E-Waste Statistics Partnership. 2022. Global E-Waste Monitor Statistics. Accessed online July 2022: https://globalewaste.org/niap/.
153 World Economic Forum and Platform for Accelerating The Circular Economy. 2019. A New Circular Vision for Electronics. Accessed online July
2022: https://www3.weforum.org/docs/WEF A New Circular Vision for Electronics.pdf.
154 Certified electronics recyclers have demonstrated through audits and other means that they continually meet specific high environmental
standards and safely manage used electronics. Once certified, continual oversight by the independent accredited certifying body holds the recycler
to the particular standard.
155 World Economic Forum and Platform for Accelerating The Circular Economy. 2019. A New Circular Vision for Electronics. Accessed online July
2022: https://www3.weforum.org/docs/WEF A New Circular Vision for Electronics.pdf.
Project Example. Through its electronics extended
producer responsibility policy, California charges
an advanced recovery fee (i.e., a deposit) on
electronics purchases, to be returned when the
electronics are recycled rather than disposed,
promoting diversion of electronic waste from
landfills. The fee serves as a source of revenue for
the government, netting tens of millions of dollars
each year, which has the potential to support
complementary recycling and/or consumer
education programs. (Source: Gregory, J. and
Kirchain, R. 2007. A Framework for Evaluating the
Economic Performance of Recycling Systems: A
Case Study of North American Electronics
Recycling Systems. Accessed online Sept 2021:
https://pubs.acs.org/doi/pdf/10.1021/es702666v.)
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Exhibit 5-1. Map of Certified Electronics Recycling Facilities156
Currently, electronics recycling is challenged by the need for toxic material handling precautions for
worker safety and pollution prevention (e.g., acid or lead and other heavy metals require personal
protection and strict handling protocols). Due to the combustion potential of lithium-ion batteries in some
electronic devices, fire hazard mitigation and suppression measures are also necessary.
Battery fires may result in significant facility damages and can raise insurance costs. EPA published a
report in 2021 analyzing lithium-ion battery fires in MRFs and other waste management facilities.157 The
report describes facility fires with substantial MRF damage costs, ranging from hundreds of thousands of
dollars to millions of dollars in direct damages. Total facility loss is also possible if the damage is extensive
enough. For example, the Shoreway Environmental Center in San Carlos, California had a battery fire in
2016 that was estimated to have caused $8.5 million in damages to the facility and its equipment. Fires
also create logistical problems for the recycling system. If a facility is under partial or total reconstruction
156 Data retrieved from the Recycling Infrastructure and Market Opportunities Map. https://www.epa.gov/circulareconomv/recvcling-
infrastructure-and-market-opportunities-map.
157 U.S. EPA. 2021. An Analysis of Lithium-ion Battery Fires in Waste Management and Recycling. Prepared by the Office of Resource Conservation
and Recovery. EPA 530-R-21-002. Accessed online Jul. 2022: https://www.epa.gov/system/files/documents/2021-08/lithium-ion-batterv-report-
update-7.01 508.pdf.
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(or lost altogether), it cannot process recovered
material; e.g., packaging material waste must either be
landfilled or rerouted to another facility. Lithium-ion
batteries may also combust while in transit and cause
the hauler/collection truck to catch fire. The total loss of
a truck could cost between $250,000 to $300,000 and
may introduce up to an entire truckload of recoverable
material directly into the environment (putting
waterways and surrounding habitats at risk for
contamination). Battery fires are a growing concern as
electronics waste generation increases. Policy will be
necessary to address this issue and properly recover valuable trace metals from batteries.
5.2 Textiles
Textiles are another fast-growing material waste stream. Textiles are a significant component of MSW
across the U.S.; textiles comprised approximately 5 percent (13 million tons) of total U.S. MSW in 2018.158
Approximately 15 percent of textiles generated from the residential, commercial, and institutional sectors
are currently recycled.159
Source reduction is a critical strategy for reducing textile waste. While source reduction of textiles can be
difficult due to consumer preferences and retail brand promotion of fast fashion marketing, source
reduction through rent/recommerce/resale business models is growing in popularity (e.g., online thrift
retail). Moreover, these models are expected to expand to impact home furnishings, upholstery, and
linens markets. The American Recycling Infrastructure Plan proposes federal funding for reuse initiatives
to be disbursed as grants for the creation of reuse and repair centers across the U.S., totaling to $250
million per year for three years.160
However, reuse and repair cannot absorb all textile waste.161 Technology exists to currently recycle
textiles, however, this technology is not integrated at scale. Examples include machines that automate the
cleaning and color-sorting of used textiles and RFID tagging on clothing so that textile types (e.g., cotton,
polyester, etc.) can be quickly identified and sorted for recycling.162 Currently, there are approximately 77
textile facilities in operation in the U.S., as shown in Exhibit 5-2.
Infrastructure cost estimates for recycling textiles is not widely available. A report conducted by Metabolic
for the city of Charlotte, North Carolina estimates that the annual costs of moving to a closed loop textile
supply chain would cost $10,000 in investment; $30,000 in rent; $9,000 in fuel and utilities; $112,000 in
employee wages; and $3,260,000 payments to third parties (though the role for third parties is unclear).163
158 U.S. EPA. 2018. Advancing Sustainable Materials Management: 2018 Fact Sheet. Accessed online Oct. 2021:
https://www.epa.Eov/sites/default/files/2020-ll/documents/2018 ff fact sheet.pdf
159 U.S. EPA. 2022. Textiles: Material-Specific Data. Accessed online July 2022: https://www.epa.gov/facts-and-figures-about-materials-waste-and-
recvcling/textiles-material-specific-data#:~:text=The%20recvcling%20rate%20for%20all,the%20American%20Textile%20Recvcling%20Service
160 Gedert, B., Drake, J., Liss, G. 2021. Recycling Infrastructure Plan. Prepared for the Recycling Is Infrastructure Too Campaign. Accessed online Oct
2021: https://resource-recvcling.eom/recvcling/wp-content/uploads/sites/3/2021/07/Recvcling-lnfrastructure-Plan-Final.pdf
161 Ellen MacArthur Foundation. 2017. A new textiles economy: Redesigning fashion's future. Accessed online Oct. 2021:
http://www.ellenmacarthurfoundation.org/publications
162 RRS. 2020. Textile Recovery in the U.S.: A Roadmap to Circularity. Accessed online Oct. 2021: https://recvcle.com/white-paper-textile-recoverv-
in-the-us/#download-paper
163 Metabolic. 2018. Circular Charlotte: Towards a zero waste and inclusive city. Accessed online Oct. 2021:
https://www.metabolic.org/proiects/circular-charlotte/
The threat of battery fire in MRFsand in collection
trucks has inspired Rumpke Waste & Recycling in
Cincinnati, Ohio to establish standard operating
procedures for removing ignited batteries from
conveyors and extinguishing fires at the MRF. (Source:
U.S. EPA. 2021. An Analysis of Lithium-ion Battery
Fires in Waste Management and Recycling. Prepared
by the Office of Resource Conservation and Recovery.
EPA 530-R-21-002. Accessed online Jul. 2022:
https://www.epa.gov/svstem/files/documents/2021-
08/lithium-ion-batterv-report-update-7.01 508.pdf)
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While it appears that the investment is focused on the hotel and hospital linen, towel, and uniform value
chain, it is unclear how many textile recycling facilities could result from this investment, or what portion
of overall textile wastes in the area would be addressed.
Exhibit 5-2, Map of Textile Recycling Facilities164
Legend
O U.S. Major Cities
• Textile Recycling Facilities
5.3 Plastics #3 to #7
Finally, plastic waste is a fast-growing material waste stream. Plastics comprised 18.5 percent (27 million
tons) of total MSW landfilled in 2018, and 16.3 percent (5.6 million tons) of all combusted MSW.165 In
2016, the U.S. generated more plastic waste than any other country in the world (42 million metric
tons).166 The U.S. plastics recycling rate was only 8.7 percent in 2018 (3.1 million tons).167 Most plastics fall
into the category of plastics #3-7 (24 thousand tons, or 68 percent of total U.S. plastic MSW generation),
but the infrastructure to recycle these plastic types are limited. Recycling opportunities are limited for
plastics #3-7 due to:
164 Data retrieved from the Recycling Infrastructure and Market Opportunities Map. https://www.epa.gov/circulareconomv/recvcling-
infrastructure-and-market-opportunities-map.
165 U.S. EPA. 2018. Facts and Figures about Materials, Waste and Recycling: Plastics: Material-Specific Data. Accessed online Nov. 2021:
https://www.epa.gov/facts-and-figures-about-materials-waste-and-recvcling/plastics-material-specific-data.
166 National Academies of Sciences, Engineering, and Medicine 2021. Reckoning with the U.S. Role in Global Ocean Plastic Waste. Washington, DC:
The National Academies Press, https://doi.org/10.17226/26132.
167 U.S. EPA. 2018. Facts and Figures about Materials, Waste and Recycling: Plastics: Material-Specific Data. Accessed online Nov. 2021:
https://www.epa.gov/facts-and-figures-about-materials-waste-and-recvcling/plastics-material-specific-data.
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1. A lack of available cost-effective recycling technologies to process these materials; and
2. A lack of end markets to use recycled outputs in manufacturing (although end market conditions
vary by plastic resin).
In many locales, only PET and HDPE (#1-2 plastics, respectively) are collected for recycling, and only those
plastic types have established recycling systems and secondary markets at a national level.168
Studies note that source reduction is critical to addressing the growing problem of plastic waste. Source
reduction, especially for plastics #3, #6, and #7, is key because given the nature of particular resins,
recycling may not be the best pathway due to lack of available end markets and lack of cost-effective
means for recycling. Pew Charitable Trusts estimates that reduction and substitution of plastics can
address nearly half of the plastic waste projected for 2040 (under business-as-usual conditions) by cutting
it off at the source. Recommendations for encouraging source reduction include plastic elimination and
consideration of product end-of-life in design (e.g., design products for reuse or optimal recycling).
Producers can also redesign or replace materials to eliminate unnecessary plastic packaging. Substitution
of plastics with paper or compostable material can
reduce up to 1/6 of global plastics by 2040.169
Policies such as extended producer responsibility
(EPR), a policy approach under which producers
are given a significant responsibility - financial
and/or physical - for the treatment or disposal of
post-consumer products, can support the redesign
of plastic packaging. California recently enacted an
EPR law aimed at single-use packaging and food
service ware. The law, the Plastic Pollution
Prevention and Packaging Producer Responsibility
Act (Senate Bill 54), would require all covered
material sold in or imported into California to be
recyclable or compostable by 2032.170
Reports emphasize that reducing or otherwise
preventing plastic release into the environment
from known sources is critical. Tires, textiles,
intermediate plastic pellet formats for product
manufacturing, and personal care products are all
sources of microplastic (< 5 mm) that can end up in
waterways, oceans, and food systems, all of which
can be reduced and addressed through policy. The
American Recycling Infrastructure Plan proposes
both production and use changes, including
product redesign development grants (with an
168 The Recycling Partnership. 2021. Paying it Forward: How Investment in Recycling Will Pay Dividends. Accessed online Sept. 2021:
https://recvclingpartnership.org/read-paving-it-forward/.
169 Pew Charitable Trusts. 2020. Breaking the Plastic Wave. Accessed online Sept. 2021: https://www.pewtrusts.org/en/research-and-
analvsis/articles/2020/07/23/breaking-the-plastic-wave-top-findings.
170 The National Law Review. 2022. California Enacts EPR Law Aimed at Single-Use Plastic Packaging and Food Service Ware. Accessed online Sept.
2022: https://www.natlawreview.com/article/california-enacts-epr-law-aimed-single-use-plastic-packaging-and-food-service-ware
The plastic numbering system, or Resin Identification
Code (RIC) is used for identifying resins and indicating how
they should be processed. Plastics are labeled with
numbers #1-7:
• Plastics #1: PET typically used for beverage bottles (e.g.,
water bottles)
• Plastics #2: HDPE typically used for milk jugs and laundry
detergent bottles
• Plastics #3: PVC typically used for pipes
• Plastics #4: LDPE typically used for shrink wrap or other
flexible plastic packaging
• Plastics #5: PP typically used for straws and single-use
food ware
• Plastics #6: PS typically used for packing peanuts
• Plastics #7: Miscellaneous
Recycling experts note that end markets are possibly
developing for plastics #4 and #5, which can represent a
future area of focus for which to increase recycling
opportunities. A study by RRS suggests that current
markets could expand to absorb an increased wholesale
supply of mixed flexible film plastics #4 and #5 as inputs for
plastic decking, pavers, and railroad ties. (Source: RRS.
2020. Materials Recovery for the Future: Flexible Packaging
Recycling in Material Recovery Facilities Pilot. Accessed
online September 2021:
https://www.materialsrecovervforthefuture.com/wp-
content/uploads/MRFF-Pilot-Report-2020-Final.pdf)
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annual investment of $150 million for three years) to promote industry innovation and the installation of
water refill stations in National Parks and public land locations (e.g., rest areas) to replace single-use water
bottles (with an annual investment of $25 million for three years).171
While source reduction strategies are a key method for reducing the growing generation of plastics waste,
the use of plastics is fully ingrained in the material economy and recycling solutions are needed to address
plastic waste produced. As noted in this report, technology systems and markets exist to effectively
recycle plastics #1 and #2. Currently, plastics #3 to #7 do not have robust end markets, and some types of
plastic (#3 and #6) are unlikely to see end market development due to difficulties establishing recycling
technologies and components in the resins that limit options for end markets. While some companies
manufacture products (e.g., luggage) with recycled
plastic #5 and #7,172 plastic #7 is not widely collected
or processed for use in manufacturing.
Recycling experts note that end markets are possibly
developing for plastics #4 and #5, which can represent
a future area of focus for which to increase recycling
opportunities. A study by RRS suggests that current
markets could expand to absorb an increased
wholesale supply of mixed flexible film plastics #4 and
#5 as inputs for plastic decking, pavers, and railroad
ties.173
Currently, technology exists to recycle plastics #4 and
#5, but large investments would have to be made at
MRFs to successfully recycle and bale these materials
at scale. This would entail incorporating additional
sorting mechanisms (e.g., acute air blowers for
separating plastic #4 from other materials, optical
sorters to identify and separate plastics #5) and more quality control steps.174 In addition to recycling
infrastructure, significant additional investment is needed to build collection systems for plastics #4 as this
material would require separate collection and processing infrastructure. (Note: The collection of plastics
#5 can be integrated into existing recycling collection systems, as optical sorters can be used to identify
and separately process this material.) Currently, plastics #4 are viewed as a contaminant at MRFs because
these film materials clog rolling conveyors and prevent the efficient movement of other materials through
the MRF.
Project Example: A pilot study at a MRF in Birdsboro,
Pennsylvania focused on sortation improvements for
plastic #4 flexible packaging (e.g., chip bags, pet food
bags, plastic film) processing. Ten surrounding
communities participated, recycling their flexible
plastic packaging along with commonly recycled
plastics. The facility processes this flexible plastic into
a product called rFlex with the help of advanced
sorting, quality control stations for contaminant
removal, and other process optimization
advancements. More than 50 other facilities in the
U.S. were identified as possible candidates for flexible
packaging MRF upgrades, with an estimated cost of
$3.7 million per facility. (Source: RRS. 2020. Materials
Recovery for the Future: Flexible Packaging Recycling
in Material Recovery Facilities Pilot. Accessed online
September 2021:
https://www.materialsrecovervforthefuture.com/wp-
content/uploads/MRFF-Pilot-Report-2020-Final.pdfl
171 Gedert, B., Drake, J., Liss, G. 2021. Recycling Infrastructure Plan. Prepared for the Recycling Is Infrastructure Too Campaign. Accessed online Oct
2021: https://resource-recvcling.eom/recvcling/wp-content/uploads/sites/3/2021/07/Recvcling-lnfrastructure-Plan-Final.pdf.
172 Samsonite. 2020. Our Responsible Journey: Samsonite Environmental, Social and Governance Report 2020. Accessed online Jan. 2022:
https://corporate.samsonite.eom/on/demandware.static/-/Sites-lnvestorRelations-Librarv/default/dw268d8861/PDF/ESG-reports-
policies/2020/E Samsonite%202020%20ESG%20Report%20(Final%202021-05-07).pdf.
173 RRS. 2020. Materials Recovery for the Future: Flexible Packaging Recycling in Material Recovery Facilities Pilot. Accessed online September
2021: https://www.materialsrecovervforthefuture.com/wp-content/uploads/MRFF-Pilot-Report-2020-Final.pdf.
174 RRS. 2020. Materials Recovery for the Future: Flexible Packaging Recycling in Material Recovery Facilities Pilot. Accessed online September
2021: https://www.materialsrecovervforthefuture.com/wp-content/uploads/MRFF-Pilot-Report-2020-Final.pdf.
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Significant efforts are also required to create a
robust end market for plastics #4 and #5. At
present, there are only two vendors in the U.S.
that accept recycled plastics #5 as a feedstock for
manufacturing products such as decking and
outdoor furniture. Small quantities of plastics #4
are also currently captured and recycled into new
plastic bags or combined with plastics #5 to
produce plastic lumber. The Recycling Partnership
estimates that $4 billion is required to expand
residential recycling collection and processing to
include plastics #3-7, but this amount does not
address the development of end markets for each
of these materials.175
Finally, in addition to investments needed to
reduce plastic waste generation and build robust
recycling systems and infrastructure for
additional plastic resins, investment to support
policy actions, such as federal requirements for
product pigment, composition, and standardized
labeling can reduce contamination and improve
plastics recycling, including:
• Require or prevent the use of certain pigments for improved plastics capture in the MRF sorting
process (e.g., eliminate carbon black, a pigment not read by optical scanners in the sortation
process).176-177
• Tax or eliminate subsidies for virgin plastic production to encourage use of recycled plastics
and/or plastics alternatives.178
• Incentivize the use of recycled plastics in new manufactured products to increase the demand for
recycled plastics.179180
175 The Recycling Partnership. 2021. Paying it Forward: How Investment in Recycling Will Pay Dividends. Accessed online Sept. 2021:
https://recvclingpartnership.org/read-paving-it-forward/.
176 Closed Loop Partners. 2020. The Circular Shift: Four Key Drivers of Circularity in North America. Accessed online Sept. 2021:
https://www.closedlooppartners.com/wp-content/uploads/2021/01/The-Circular-Shift Closed-Loop-Partners-2020.pdf
177 OECD. 2018. Improving Markets for Recycled Plastics: Trends, Prospects, and Policy Responses. Accessed online Sept. 2021: https://read.oecd-
ilibrarv.org/environment/improving-markets-for-recvcled-plastics 9789264301016-en#pagel.
178 Rewarding Efforts to Decrease Unrecycled Contaminants in Ecosystems Act of 2021. S.2545 - 117th Congress. 2021. Accessed online Jan. 2022:
https://www.congress.gov/biii/117th-congress/senate-biii/2645/titles?r=14&s=l.
179 Gedert, B., Drake, J., Liss, G. 2021. Recycling Infrastructure Plan. Prepared for the Recycling Is Infrastructure Too Campaign. Accessed online Oct
2021: https://resource-recvcling.eom/recvcling/wp-content/uploads/sites/3/2021/07/Recvcling-lnfrastructure-Plan-Final.pdf.
180 Incentivizing use of recycled plastics is complex and depends heavily on the price of virgin materials (and inputs, such as crude oil, from which
plastics are fabricated), quality of recycled plastic resin, which may suffer from contamination, and the demand for wholesale recycled plastic,
which may drive up cost. See for more information: Roth, R. 2020. Recyclable Material Wholesaling in the United States. IBISWorld Industry Report
42393; and Brooks, B. 2021, March 11. Recycled Plastics Market Becoming More Liquid and Globalized as Demand Soars. S&P Global.
https://www.spglobal.com/platts/en/market-insights/blogs/petrochemicals/031121-recvcled-plastics-global-market-commoditization-standards-
Pricing.
Complexity of Current Labeling for Plastic Resins and its
Impact on Recycling
Plastic manufacturers include RICs on plastic bottles and
containers. The RIC label is designed to indicate the type of
plastic, rather than the recyclability of the plastic. The existing
logo has a triangle with chasing arrows, which looks like the
"recycle" symbol. This and other packaging labeling
inconsistencies have confused consumers according to a 2020
GAO report. (Source: U.S. Government Accountability Office.
2020. Recycling: Building on Existing Federal Efforts Could Help
Address Cross-Cutting Challenges. Accessed online Sept. 2021:
https://www.g30.gov/products/gao-21-87)
ASTM international, a standards organization that regularly
publishes technical guidance and standards, now recommends
a solid triangle icon. In 2021, California passed SB 343,
The Truth in Labeling for Recyclable Materials bill, which
prohibits the use of the "chasing arrows" symbol (or any other
indication of recyclability) on products or packaging that are
not deemed "recyclable" under criteria to be established by
the California Department of Resources Recycling and
Recovery. (Source: Californians Against Waste. 2022. SB 343
(Allen) Truth in Recycling. Accessed online Aug. 2022:
https://www.cawrecvcles.org/sb343)
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• Require manufacturers to use the same polymers for all bottle components (e.g., label, cap) to
improve product recyclability and produce higher-quality recycled plastic with lower rates of
contamination.181182
• Change the Resin Identification Code (RIC) or other recycling label to explicitly detail recycling
instructions. This may reduce ambiguity for consumers who may be trying to understand which
products are and are not recyclable, limiting source contamination.183
181 Pew Charitable Trusts. 2020. Breaking the Plastic Wave. Accessed online Sept. 2021: https://www.pewtrusts.org/en/research-and-
analvsis/articles/2020/07/23/breaking-the-plastic-wave-top-findings.
182 Seidel, C. et al. 2020. A Roadmap to Support the Circularity and Recycling of Plastics in Canada -Technical Standards, Regulations and Research.
CSA Group. Accessed online Sept. 2021: https://www.csagroup.org/wp-content/uploads/CSA-Group-Research-Roadmap-to-Support-Circularitv-
and-Recvcling.pdf.
183 United Nations Environment Programme. 2020. "Can I Recycle This?" A Global mapping and Assessment of Standards, Labels and Claims on
Plastic Packaging. Accessed online Sept. 2021: https://www.consumersinternational.org/media/352255/canirecvclethis-finalreport.pdf.
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Section 6: Summary and Beyond 2030
6.1 Summary of Infrastructure Investment Estimates
To modernize recycling infrastructure, improve consumer recycling education, and provide all residents
with equivalent access to recycling services, EPA estimates that a total investment of $36 to $43 billion,
summarized in Exhibit 6-1, is needed. This investment, which would leverage combined funding and
financing mechanisms from stakeholders across the entire recycling system including federal, state, and
municipal governments, the private sector, hybrid public-private partnerships, and fee-based programs,
could potentially recover an additional 82 to 89 million tons of packaging and organic waste, increasing
the nation's recycling rate from its current level of 32 percent to 61 percent and allowing the U.S. to
surpass the national recycling goal of 50 percent set by EPA.184
Exhibit 6-1. Summary Education, Outreach, and Infrastructure Investment Cost Estimates for Packaging
and Organic Materials.
Cost Category
Low-End Estimate
High-End Estimate
Packaging Materials
Curbside Collection
$19,900,000,000
$21,500,000,000
Glass Separation (Curbside)
$2,900,000,000
$2,900,000,000
Drop Off
$1,900,000,000
$3,400,000,000
Deposit Redemption System
$100,000,000
$100,000,000
Curbside + Dropoff
$21,800,000,000
$24,900,000,000
Curbside + Dropoff + Deposit Redemption System
$21,900,000,000
$25,000,000,000
Curbside + Dropoff + Glass Separation
$24,700,000,000
$27,800,000,000
Curbside + Dropoff + Glass Separation + Deposit
Redemption System
$24,800,000,000
$27,900,000,000
Organic Materials
At-Home Composting
$380,000,000
$380,000,000
Community Composting
$4,700,000,000
$4,700,000,000
Centralized Composting
$8,700,000,000
$9,400,000,000
Centralized Anaerobic Digestion
$422,000,000
$436,000,000
Water Resource Recovery Facility (WRRF) Anaerobic
Digestion
$77,000,000
$96,000,000
Animal Feed
$449,000,000
$504,000,000
Organics Total
$14,700,000,000
$15,500,000,000
Total Recycling Investment
$36,000,000,000
$43,000,000,000
Note: Low-end and high-end estimates are driven by various factors. For packaging, the low-end estimates assume
that facilities will not receive the latest technology upgrades (e.g., optical sorters, robotic arms, etc.) while the
high-end estimates assume that facilities will be upgraded or modernized with the latest technology, resulting in
higher capital costs. Technology upgrades would work to reduce contamination and improve recycling output
quality. For organics, the low-end estimates assume that not all existing facilities are operating at full capacity and
could intake a portion of the potentially recoverable materials, resulting in reduced capital costs. EPA's high-end
184 U.S. EPA. 2018. National Overview: Facts and Figures on Materials, Wastes and Recycling. Accessed online Aug. 2022:
https ://www. epa .gov/facts-a nd-figures-a bout-mater ia Is-waste-a n d-recvcl i n g/nationa l-overvi ew-facts-a nd-figures-
materials#:~:text=The%20recvcling%20rate%20(including%20composting,person%20per%20dav%20for%20recvcling.
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Cost Category
Low-End Estimate
High-End Estimate
estimate assumes that facilities will not operate any closer to full capacity and that comparatively more facilities
will need to be built, which will result in higher capital costs.
Estimated using:
(1) Eunomia. 2021. The 50 States of Recycling. Prepared for the Ball Corporation.
(2) U.S. Census Bureau. 2022. 2019 American Community Survey.
(3) State waste management reports.
(4) The Recycling Partnership. 2021. Paying it Forward: How Investment in Recycling Will Pay Dividends.
(5) U.S. EPA Office of Resource Conservation and Recovery. 2020. 2019 Wasted Food Report.
(6) U.S. Census Bureau. 2022. 2019 American Community Survey.
(7) Natural Resources Defense Council. 2017. Estimating Quantities and Types of Food Waste at the City Level. Accessed online May 2022:
https://www.nrdc.org/sites/default/files/food-waste-citv-level-report.pdf.
(8) ReFed. 2016. A Roadmap to Reduce U.S. Food Waste by 20%: Technical Appendix. Accessed online May 2022:
https://refed.org/downloads/ReFED Technical Appendix.pdf.
(9) The Recycling Partnership. 2021. Paying it Forward: How Investment in Recycling Will Pay Dividends. Accessed online Sept. 2021:
https://recvcl i ngpa rtnersh i p. org/rea d-pa vi ng-it-forwa rd/
(10) U.S. Composting Council. 2021. "Organics Bans and Mandates." Accessed online May 2022: https://www.compostingcouncii.org/page/organicsbans.
(11) U.S. Composting Council. The Case for Centralized Compost Manufacturing Infrastructure. Accessed May 2022.
(12) U.S. EPA. 2021. Anaerobic Digestion Facilities Processing Food Waste in the United States (2017 & 2018). Accessed online May 2022:
https://www.epa.gov/sites/default/files/2021-02/documents/2021 final ad report feb 2 with links.pdf.
(13) Interviews with industry experts.
For successful capture of potentially recyclable packaging and organics waste, investments in collection,
education, and processing capacity should be made simultaneously, along with policies to disincentivize
landfilling materials (e.g., pay-as-you-throw programs) and to promote the use and sale of recycled
material (e.g., minimum post-consumer recycled content mandates). Financing mechanisms, such as
private equity, public-private partnerships, and government grant programs can be used to fund such
projects and programs.
While the expansion of recycling infrastructure is needed nationwide, there are select regions with high
rates of potentially recyclable material and a general lack of recycling infrastructure. For packaging
materials recycling, these areas include the:
• South (parts of Kentucky, Mississippi, Alabama, and Georgia);
• Southwest (parts of Texas, Arizona, and New Mexico); and
• Rocky Mountains (parts of Wyoming, Montana, Colorado, Idaho, and Nevada).
For organics recycling, these areas include the:
• South (in particular, parts of Louisiana, Alabama and Mississippi);
• Southwest (parts of Texas, Arizona, New Mexico, and Oklahoma); and
• Rocky Mountains (parts of Montana, Idaho, Colorado, and Nevada).
It may be beneficial to focus initial investments, including investments in education and outreach to
motivate behavior change, in these areas using proven technology and infrastructure as they represent
high-need, high-reward regions.185
6.2 Beyond 2030
Beyond 2030, recycling assessments will have to expand to include materials beyond conventionally
recycled packaging and organics, such as electronics, textiles, and plastics #3 to #7. These assessments
185 Note that areas in the South, Southwest, and Rocky Mountains currently lack the critical infrastructure to process additional packaging and
organic materials for a variety of legislative, policy, and administrative reasons.
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should include thoughtful consideration of how to maximize source reduction and promote reuse, as well
as how best to upgrade and integrate infrastructure required for recycling.
In addition, future analyses should align with circular economy considerations. Currently, the U.S. (and
much of the rest of the world) has a linear material supply chain involving extraction, use, and disposal. A
circular economy provides more meaningful and lasting waste reduction; however, circularity will require
systemic change not limited to recycling. A circular economy is oriented toward systems and lifecycle
impacts; focused on waste elimination through product redesign and alternative materials use; and
designed to reuse, restore, and even regenerate materials, maintaining value as long as possible. A circular
economy recaptures waste and uses it as a valuable
input for manufacturing.
EPA recognizes that while some elements of circularity
do exist in the U.S., the current U.S. economy is far
from achieving a nationwide circular economic
structure. In November 2021, EPA released the
National Recycling Strategy: Part One of a Series on
Building a Circular Economy that outlined the agency's
vision on moving towards a circular economy. An
important part of this transformation is creating a
viable system for reusing and recycling materials, including those that are not traditionally seen as
"recyclable." Ultimately, MRF modernization will require additional capacity and technology to process
more and different types of materials which, in turn, will require thoughtful planning anticipating a more
circular economy in the future.
The term "circular economy" means an economy
that uses 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 the
superior design of materials, products, and
systems (including business models).
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U.S. EPA Office of Resource Conservation and Recovery. 2022. 2019 Wasted Food Report.
https://www.epa.gov/system/files/documents/2023-
03/2019%20Wasted%20Food%20Report 508 opt ec.pdf
U.S. Government Accountability Office. 2020. Recycling: Building on Existing Federal Efforts Could Help
Address Cross-Cutting Challenges. Accessed online Sept. 2021: https://www.gao.gov/products/gao-21-87
U.S. House of Representatives. 2021. House Report 116-448. Accessed online Sept. 2022:
https://www.congress.gov/congressional-report/116th-congress/house-report/448
USDA. 2022. Farms and Land in Farms 2021 Summary. Accessed online May 2022:
https://www.nass.usda.gov/Publications/Todavs Reports/reports/fnlo0222.pdf
USDA. 2022. "USDA Announces Framework for Shoring Up the Food Supply Chain and Transforming the
Food System to Be Fairer, More Competitive, More Resilient." Press Release No. 0116.22, published on
USDA.gov. Accessed online June 2022: https://www.usda.gov/media/press-releases/2022/Q6/01/usda-
announces-framework-shoring-food-supplv-chain-and-transforming
Waste360. 2004. "Doing the Dirty Work." Accessed online May 2022:
https://www.waste360.com/composting-and-organic-waste/doing-dirtv-work
WasteDive. 2022. "Waste Management Planning $1.6B in ESG investments." Accessed online Nov 2022:
https://www.wastedive.com/news/waste-management-q4-2021-esg-rng-recvcling-automation/618103/
Waste Management. 2021. "What is SB 1383?" Accessed online Sept. 2022:
https://www.wm.com/us/en/sbl383
Woods End Laboratories and Ecocycle. 2018. Microplastics in Compost. Accessed online May 2022:
https://www.ecocvcle.org/files/pdfs/microplastics in compost summarv.pdf
World Economic Forum and Platform for Accelerating The Circular Economy. 2019. A New Circular Vision
for Electronics. Accessed online July 2022:
https://www3.weforum.org/docs/WEF A New Circular Vision for Electronics.pdf
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Appendix A. Packaging Material Recycling Opportunity Maps186
Exhibit A-l. Aluminum recycling tonnage and facilities (MRFs and metal recycling facilities).
Legend
O U.S. Major Cities
• MRFs
• Metal Recycling Facilities
Potentially recoverable aluminum (tons)
0.01 - 25
HI 25 - 70
H 70-120
M 120 - 200
H 200 - 360
Exhibit A-2. Steel recycling tonnage and facilities (MRFs and metal recycling facilities).
Legend
O U.S. Major Cities
® MRFs
• Metal Recycling Facilities
Potentially recoverable steel (tons)
0.01 - 40
H40-120
H 120-230
H 230 - 390
wm 390 - 690
186 Data retrieved from the Recycling Infrastructure and Market Opportunities Map. https://www.epa.gov/circulareconomv/recvcling-
infrastructure-and-market-opportunities-map.
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Exhibit A-3. Cardboard recycling tonnage and facilities (MRFs and paper recycling facilities).
Legend
O U.S. Major Cities
O MRFs
• Paper Recycling Facilities
Potentially recoverable cardboard (tons)
0.10-350
M 350 - 930
M 930 - 1,700
M 1,700-2,600
H 2,600 - 5,300
Exhibit A-4. Paper recycling tonnage and facilities (MRFs and paper recycling facilities).
Legend
O U.S. Major Cities
O MRFs
• Paper Recycling Facilities
Potentially recoverable paper (tons)
0-630
H 630 - 1.700
HI 1,700 -3.100
H 3,100 -5,000
H 5,000 - 10,000
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Exhibit A-4. PET bottles recycling tonnage and facilities (MRFs and plastic recycling facilities).
Legend
O U.S. Major Cities
• MRFs
• Plastic Recycling Facilities
Potentially recoverable PET bottles (tons)
0-70
H70-180
M 180-330
H 330 - 540
WM 540 - 1,000
Exhibit A-5. Other PET rigid recycling tonnage and facilities (MRFs and plastic recycling facilities).
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Exhibit A-6. HOPE recycling tonnage and facilities (MRFs and plastic recycling facilities).
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Appendix B. Organic Material Recycling Opportunity Maps18
Exhibit B-l. Organic material recycling tonnage and composting facilities.
Legend
O U.S. Major Cities
• Composting facilities (food only)
o Composting facilities (all)
Potentially recoverable food (tons)
0- 1,300
1,300 - 3,600
3,600 - 6,500
6,500 - 14,500
187 Data retrieved from the Recycling Infrastructure and Market Opportunities Map. https://www.epa.gov/circulareconomv/recvcling-
infrastructure-and-market-opportunities-map.
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Exhibit B-2. Food waste recycling tonnage and anaerobic digestion facilities.
,<3
Legend
O U.S. Major Cities
o AD facilities (food only)
o AD facilities (all)
Potentially recoverable food (tons)
0- 1,300
1,300 - 3,600
3,600 - 6,500
6,500 - 14,500
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Appendix C. Summary of Available Case Studies
C.l Introduction
Insufficient materials management infrastructure in the U.S. to collect and process recycling is a
documented issue. State and local governments have made significant efforts to divert waste from
landfills, resulting in lowered greenhouse gas emissions and air pollutants (e.g., PM2.5), increased longevity
of materials through recycling/repurposing, and increased local recycling rates.188,189 These efforts have
been documented in a number of published reports and case studies, which is defined herein as a
document highlighting specific real-world and place-based applications of recycling solutions.
The following sections describe the methodology used to identify and analyze such case studies (Section
C.2) and summarize case study contents by key attributes (Section C.3). Sections C.4 - C.6 summarize case
study results organized by the recommendations presented in the reports to address key needs in the
current recycling system for specific materials, specific stages within the recycling process, and
educational opportunities on and incentives to bolster recycling.
C.2 Methodology
EPA used Scopus, Google Scholar, and available state and local waste and materials characterization
reports to identify case studies. In total, EPA reviewed 71 documents, including peer-reviewed academic
journal articles (14), SWMPs (8), and other reports and articles (49). The scope of the literature search was
limited to documents published between 2012 through 2021 (with a few exceptions)190 and primarily
limited to the U.S.
C.3 Overview of Case Studies
Case studies identified and reviewed differed in terms of material focus, stage in the recycling system
discussed, geographic area evaluated, and year of assessment. In terms of materials discussed, general
MSW is highlighted with most frequency in the case studies. Among specific materials, the largest number
of case studies focus on plastics, followed by food, metal, glass, paper, and to a smaller extent, electronics
waste, textiles, mattresses, and batteries. Exhibit C-l summarizes the material focus of reviewed case
studies.
Exhibit C-l. Material Focus of Reviewed Case Studies, By Frequency and Proportion
Material Type
Count
Percentage
MSW
31
48%
Plastics
17
27%
Food
17
27%
Metal
11
17%
Glass
8
13%
Paper
7
11%
188 Jordan, P., M. Krause, G. Chickering, D. Carson, AND T. Tolaymat. Impact of Food Waste Diversion on Landfill Emissions. Global Waste
Management Symposium, Indian Wells, California, February 23 - 26, 2020.
189 State of California (Updated: 2021, November 17). California's Short-Lived Climate Pollutant Reduction Strategy. CalRecycle. Retrieved
November 22, 2021, from https://www.calrecvcle.ca.gov/organics/slcp
190 There are three case studies reviewed outside the 2012 through 2021 timeframe; one each from 2007, 2010 and 2011. These were identified
outside of the general literature search scope as potentially relevant for electronics waste recycling, composting at a large university, and a small-
scale study on infrastructure implementation and associated costs and benefits identified via references in existing reports/case studies.
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Material Type
Count
Percentage
Electronics waste
3
5%
Textiles
1
2%
Mattresses
1
2%
Batteries
1
2%
*Note: Percentages do not add to 100% because most case studies mention more than one material type.
Case studies most commonly target collection (75 percent), followed by generation (25 percent), and
sorting/processing (20 percent). A smaller number focus on product manufacturing (as it relates to end
markets for recycled materials). Case studies targeting product manufacturing typically focus on
generation of alternate products using recycled materials, and increased capacity to remanufacture
recycled products while case studies focusing on generation are typically consumer-facing and emphasize
source reduction. Exhibit C-2 summarizes the stages in the recycling system discussed in reviewed case
studies.
Exhibit C-2. Recycling Stages Discussed in Reviewed Case Studies, By Frequency and Proportion
Targeted Stage in Recycling System
Count
Percentage
Collection
48
75%
Generation
16
25%
Sortation and Processing
13
20%
Product manufacturing (as it relates to
end markets for recycled materials)
9
14%
*Note: Percentages do not add to 100% because many case studies mention more than one stage.
Exhibit C-3 summarizes the number of case studies by state and year published.
Exhibit C-3. Case Studies Counts by U.S. State/Region and Year Published
Count of case studies
r ¦ v*
V
8 8
. . . I
I
10
Powered by Bing ^ ^ ^
D GeoNames, Microsoft, TomTom
The Southeast (EPA Region 4) is the least-covered region in terms of both case studies and reports, with
the exception of Florida. The Midwest (EPA Regions 5, 7, and 8) has some representation in this sample of
documents but is similarly lacking coverage. Most case studies cover the Southwest (EPA Regions 6 and 9),
Northwest (EPA Region 10) and the Northeastern U.S. (EPA Regions 1 and 2). More than half the case
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studies (40 of 71) EPA reviewed were published between 2017 and 2021 (Exhibit C-3). It is important to
note that the absence of case studies in a particular region or state does not necessarily imply an absence
of recycling initiatives.
C.4 Addressing Needs for Specific Materials in Local Recycling Programs
As with the reports reviewed, case studies noted that significant infrastructure improvements are needed
to recycle non-commonly recycled material types, such as plastics #3-7, food waste, textiles, electronics,
and other materials, and point to specific successful efforts to recycle these materials. Case study results
for these materials are summarized below:
• Plastics: A pilot study at a MRF in Birdsboro, Pennsylvania focused on sortation improvements for
flexible packaging (e.g., chip bags, petfood bags, plastic film) processing.191 Ten surrounding
communities participated, recycling their flexible plastic packaging along with commonly recycled
plastics. The facility processes this flexible plastic into a product called rFlex with the help of
advanced sorting, quality control stations for contaminant removal, and other process
optimization advancements. More than 50 other facilities in the U.S. were identified as possible
candidates for flexible packaging MRF upgrades, with an estimated cost of $3.7 million per facility.
• Food waste and organics: The University of Michigan assessed the cost and benefits of
implementing a composting program at the university.192 The study (which recommended a $1.0
million dollar capital investment for an in-vessel composter and a $40/ton variable cost for labor,
utilities, etc.), documented that the university's composting tonnages more than doubled in four
years.
• Textiles: A study finds that 85 percent of textiles in New York State are landfilled, with the
remaining 15 percent recycled through donations at clothing banks, thrift stores, etc. Eileen
Fisher, a clothing brand, collected over 200,000 garments between 2009-2014 through their take-
back program. The corporation offered $5 gift cards to customers for returning garments and used
the textiles to repurpose into alternative garments.
• Electronic waste: California started charging an advanced recovery fee (i.e., a deposit) on
electronics purchases, to be returned when the electronics are recycled, rather than disposed,
promoting diversion of electronic waste from landfills.193 The fee serves as a source of revenue for
the government, netting tens of millions of dollars each year, which has the potential to support
complementary recycling and/or consumer education programs.
• Mattresses: The Cambridge, Massachusetts Mattress Recycling Program was launched in 2019 to
reclaim the 75 percent of mattress material that is recyclable. Residents can schedule curbside
pickup online without charge. The total cost of recycling is $46 per mattress (split between the
Massachusetts Department of Environmental Protection and the City of Cambridge). A total of
9,335 mattresses have been recycled since the start of the program.
191 RRS. 2020. Materials Recovery for the Future: Flexible Packaging Recycling in Material Recovery Facilities Pilot. Accessed online September
2021: https://www.materialsrecovervforthefuture.com/wp-content/uploads/MRFF-Pilot-Report-2020-FinaLpdf
192 RRS, "University of Michigan: Composting Program/' 2010. Available at: https://recvcle.com/case-studies/universitv-of-michigan-composting-
program/. Accessed on: Sept 2021.
193 Gregory, J. and Kirchain, R., "A Framework for Evaluating the Economic Performance of Recycling Systems: A Case Study of North American
Electronics Recycling Systems," 2007. Available at: https://pubs.acs.org/doi/pdf/10.1021/es702666v. Accessed on: Sept 2021.
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C.5 Addressing Needs in the Recycling Process
The identified case studies explore funding for infrastructure development to address needs in the
recycling process as a possible action step toward increasing recycling. Strategies for recycling system
process improvements and infrastructure development mainly focused on collection and drop-off and are
summarized below:
• A pilot study at a large southeastern university campus increased collection areas for recyclable
bottles and cans across two campus buildings. The increase in collection points was not
supplemented with consumer education or promotion of the increases. The increase in collection
areas, alone, yielded a jump in volume of recycled materials by 65-250 percent at the different
locations, with the cumulative effect resulting in a 130 percent increase in recycled material
volume collected.194 Increasing collection areas have shown success in tribal communities as well.
For example, the Confederated Tribes of the Umatilla Indian invested $1.3 million, through the
tribe's revenues and grants from various government and private agencies, to set up a community
waste transfer station. This allowed the tribe to restrict open dumping and increase diversion
from their landfill. Tribal members pay $22.7 per month for curbside collection.195
• Tribal communities have also shown that recycling collection events can help to improve recycling
rates for materials that are not typically managed through curbside programs. For instance,
Snoqualmie Indian Tribe and the City of North Bend in Washington have worked together to host
an annual recycling event since 2015 to collect non-packaging items such as tires, appliances,
electronics, and other household items. The event allows residents to recycle items free of charge.
In 2019, the event collected over 36 tons of materials, including 188 tires and over six tons of
electronics.196
• An environmental-economic assessment of curbside recycling in Central Florida showed that
increasing frequency of composting and recycling collection and decreasing frequency of trash
collection both lead to increased recycling rates and materials volume in the recycling stream.197
The case study details avoided costs per ton from recyclables diversion of $40 (if diverted from
landfilling) and $60-80 (from waste-to-energy). The success of increased food waste diversion with
increased collection frequency is also illustrated in the case study of Berkeley, California.198
Berkeley gradually increased the frequency of yard waste and food waste collection from monthly
in 1990, to weekly in 2014. Berkeley now has a 58 percent organic waste diversion, and the
participation rate has increased from 30 percent in 2007 to 70 percent in 2014.
194 Largo-Wight E., De Longpre Johnston D., Wight J., "The efficacy of a theory-based, participatory recycling intervention on a college campus/'
2013.
195 NCAI Policy Research Center, "Investing in healthy tribal communities: Strengthening solid waste management through tribal public health
law/' 2014. Available at: https://www.ncai.org/policv-research-center/research-data/prc-publications/NCAI-SolidWasteManagement.pdf.
Accessed on: November 23, 2021.
196 ECOS. 2019. Green Report - Tribal and Rural Waste Management. Available at: https://www.ecos.org/wp-
content/uploads/2019/10/TribalManagementGreenReport2019.pdf, accessed on Nov 2021.
197 Maimoun, M. A., Reinhard, D. R., and Madani, K., "An environmental-economic assessment of residential curbside collection programs in
Central Florida/' 2016. Available at: https://www.sciencedirect.com/science/article/abs/pii/S0956053X1630188X. Accessed on: Oct 2021.
198 Layzer, J. A. and Schulman, A., "Municipal Curbside Compostables Collection: What Works and Why?", 2014. Available at:
https://dusp.mit.edu/sites/dusp.mit.edu/files/attachments/proiect/Municipal%20Curbside%20Compostables%20Collection%20%20What%20Wor
ks%20and%20Whv.pdf. Accessed on: Sept 2021.
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C.6 Addressing Recycling Knowledge and Policy
As noted in the reports, education and policy are paramount in improving the quality of recycled material
through reduced contamination and incentivizing recycling. In alignment with the reports, consumer
education emerged as a key case study topic, the results of which are summarized below:
• Alameda County, California's curbside compostable collection program captured 270 pounds of
organics per capita and diverted more than 50 percent of the estimated total residential organic
material in 2011.199 The county attributes half the organics collection volume to their community
education programs, which consist of regional marketing campaigns and multimedia outreach
(e.g., bill inserts in pizza boxes and coffee cups and mailers to inform residents of the availability
of a community composting program and what can and cannot be composted).
• Direct consumer education through curbside inspections and tagging can reduce contamination
of recycling set out for collection. For instance, four trained inspectors in Brooklyn, Ohio in 2020
went through recycling containers left out for curbside collection and noted which items were
erroneously recycled (e.g., plastic bags, food wrappers, plastic wrap, etc.) and informed residents
through an "Oops" tag. By the end of the eight-week project, the recycling contamination rate for
the city decreased from 38 percent to 20 percent.200 The project was funded through a $21,000
grant provided by the state of Ohio.
• WM's Smart TruckSM technology is a more long-term capital-driven approach to addressing source
contamination: the truck has a mounted camera for tracking contamination, photographing
improper recycling for customer recycling quality control, and contamination pattern recognition
with Al software. WM provides customers with feedback through bin tags or photos, reducing
contamination by 89 percent in three months during one Northern California pilot study.201
• WM also educates their drivers in recognizing contaminants, performs regular surveys to
ascertain driver knowledge of recycling and common contaminants, and provide guidance to
support drivers in educating customers, especially during bin tagging and enforcement campaigns.
Drivers are a key resource for quality control and limiting contamination in MRFs further
downstream; for example, driver education efforts reduced WM MRF contamination by 16
percent in 2020.
In addition to education, almost all case studies discussed, at some level, policy interventions that
establish and/or regulate the waste collection and recycling markets, which are summarized below:
• The town of Wenham, MA instituted a volume-based fee rate (i.e., pay-as-you-throw) that
limited residential trash collection to one, 35-gallon container per week and charged for additional
trash generation. Recyclable materials could be placed and collected curbside free of charge. The
program helped to reduce waste by 30 percent and saved an estimated $70,000 in trash collection
and disposal costs.202
199 Layzer, J. A. and Schulman, A., "Municipal Curbside Compostables Collection: What Works and Why?", 2014. Available at:
https://dusp.mit.edu/sites/dusp.mit.edu/files/attachments/proiect/Municipal%20Curbside%20Compostables%20Collection%20%20What%20Wor
ks%20and%20Whv.pdf. Accessed on: Sept 2021.
200 Krouse, P., "Brooklyn greatly reduced contamination in its recycling stream by issuing 'Oops!' tags to non-compliant residents/' September
2021. Available at: https://www.cleveland.com/news/2021/09/brooklvn-greatlv-reduced-contamination-in-its-recvcling-stream-bv-issuing-oops-
tags-to-non-compliant-residents.html
201 WM. 2021. The People Behind Our Progress. Sustoinobility Report. Accessed online Nov. 2021:
https://sustainabilitv.wm.com/downloads/WM 2021 SR.pdf
202 NERC. 2013. Rural/Small Town Organics Management Case Study - Hamilton and Wenham Massachusetts Curbside Composting Program.
Accessed online November 2021: https://nerc.org/documents/Qrganics/Case%20Studv Hamilton%20MA.pdf
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• Banning materials at landfills can lead to increases in material specific recycling rates. For
instance, Vermont's landfill ban on food waste has led to an increase in composting at the
Lamoille Regional Solid Waste District from 146 tons to 166 tons in six months.203
• A case study from Cambridge, MA states that simplifying a permitting process for new MRFs and
vertical integration at existing MRFs can lead to increased ability to collect and process recyclable
materials.204
• Charging an advanced recovery fee (ARF) (i.e., a deposit) has proven to be a successful tool for
increased recycling. For example, bottle bills states in the U.S. that impose a $0.05 or $0.10 charge
on the purchase of each bottled/canned product, recoverable upon return at deposit sites, have
achieved an 80 percent recycling rate for deposit materials.205
In all, the case studies offer a window into on-the-ground facility improvements and unique initiatives that
may be replicated on a national level. Where reports look to the future and consider what is needed for
improvement, case studies provide insights into what has and has not been successful in the past.
203 DeLeon, A., "Composting has spiked since food scraps were banned from landfills/' July 2021. Available at:
https://vtdigger.org/2021/07/15/composting-has-spiked-since-food-scraps-were-banned-from-landfins/
204 Layzer, J. A. and Schulman, A., "Municipal Curbside Compostables Collection: What Works and Why?", 2014. Available at:
https://dusp.mit.edu/sites/dusp.mit.edu/files/attachments/proiect/Municipal%20Curbside%20Compostables%20Collection%20%20What%20Wor
ks%20and%20Whv.pdf. Accessed on: Sept 2021.
205 Ball Corporation, "The 50 States of Recycling/' 2021. Available here: https://www.ball.com/getattachment/na/Vision/Sustainabilitv/Real-
Circularitv/50-States-of-Recvcling-Eunomia-Report-Final-Published-March-30-2021-UPDATED-v2.pdf.aspx?lang=en-US&ext=.pdf
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