Written on: July 1, 2026 by SPRAY
In May, the Household & Commercial Products Association (HCPA) held its Mid-Year Meeting at a new venue—The Capital Hilton in Washington, D.C.
During the General Session, the HCPA thanked Stephen J. Caldeira and his nearly 10 years of outstanding leadership as he prepares to conclude his tenure as President & CEO in July 2026. The Association noted that, since joining HCPA in 2017, Caldeira has guided it through a period of growth and innovation. Under his leadership, HCPA strengthened its voice in Washington, advanced key policy priorities and deepened its value to members navigating an increasingly complex regulatory landscape.
Among his many contributions, Caldeira spearheaded the rebrand of the Consumer Specialty Products Association (CSPA) to HCPA. He is widely recognized as one of Washington’s most effective and trusted advocates, consistently recognized by The Hill as a Top Lobbyist and honored with CEO Update’s Trade Association CEO of the Year Award in 2022.
The HCPA said in a statement, “Those who have worked with [Caldeira] know him not only for his policy expertise, but also for his kindness, integrity and unique ability to bring people together across different perspectives. Beyond his professional impact, Steve has been a generous and engaged leader in the broader community, contributing his time, expertise and leadership to numerous boards and advisory groups.
“While we are saddened to see this chapter come to a close, we are deeply grateful for the lasting impact Steve has had on HCPA, the industry we serve and the many people who have had the privilege of working alongside him.”
Aerosol Products Division
During the Aerosol Products Division Program, the A Can-Do Conversation: Aerosol Recycling & Sustainability panel featured Sami Ki, HCPA Senior Manager, Sustainability & Product Stewardship; Manon Pascal, Regulatory Affairs Manager, Lindal North America; and Allison Lim, Innovation Analyst, RTI International.
Ki presented an Aerosol Recycling Initiative (ARI) Update. Highlights from Phase 1 include the research of the environmental and economic impact of improved aerosol recycling; analysis of the state of current recycling-related labeling on aerosols; can testing to assess the amount of residual content remaining in aerosols; consumer survey to understand current awareness and the publishing of a White Paper. Findings of the White Paper showed the benefits of a 50% recycling rate of aerosols:
• $39M+ in material revenues
• $43M+ in direct wages paid
• $8.5M+ landfill tipping fees saved
• 13k tons of aluminum recycled content
• 137k tons of steel recycled content
• 366,622 MTCO2e GHG reductions
The next phase progressed toward targets, and the highlights of Phase 2 include forming the ARI Labeling Task Force to develop a guide with message options to meet the labeling goal; engaging materials recovery facilities (MRFs), municipalities and retailers to offer aerosol recycling access; and advocating for inclusion of aerosol cans on Statewide “recyclable” lists.
ARI collaborated with RTI Innovation Advisors to produce and publish the “MRF Playbook”; partnered with Circular Action Alliance (CAA) in the Portland, OR, Metro area to create consumer educational messaging; conducted baseline residue testing from cans collected at Far West MRF in Portland; and worked with Kessler Consulting to engage the city of Sarasota, FL, and Waste Pro towards explicit acceptance of aerosols.
The ARI, CAA and metro local governments developed consumer education messaging—How to Recycle Empty Aerosol Cans—with the goal of improving acceptance of empty aerosol products in the Portland, OR, Metro area. The marketing campaign was launched mainly via social media, but also via mailers.
Residue testing was conducted to establish a baseline. Samples were sourced from Far West MRF in July 2025, with two totes containing a total of 2,385 aerosol containers collected (1,884 steel aerosol containers [78.99%], 492 aluminum aerosol containers [20.63%] and nine plastic aerosol containers (0.38%). Sorting and testing was completed in September 2025 at Recycle Aerosol in Tennessee.
The total aggregate residue level was 10.7%; by comparison, 2023 testing had an average residue level of 11.5% overall.
On the horizon, the second round of can testing will be done at Far West and an outside MRF to determine the impact of the marketing campaign on consumer behavior. An operations assessment and residue testing will be conducted at a Waste Pro MRF. An aerosol recycling education messaging toolkit will be created and the MRF Playbook will be leveraged to engage MRFs on explicit acceptance of aerosols. A guidance document for design of aerosol product for recyclability will be developed.
Pascal presented How Packaging & Packaging Waste Regulation (PPWR) is reshaping aerosol sustainability in the EU. PPWR addresses packaging lifecycle and it’s potentially negative impacts on the environment and human health; waste prevention to harmonize national measures and improve the internal market; and more sustainable packaging solutions. This will impact aerosol design, such as the substances in packaging and minimum recycled content. Regulatory constraints will affect labeling and extended producer responsibility (EPR), as well as packaging minimization. Uncertainty remains concerning recyclability grades. EPR changes under PPWR will include clearer regulation, a less fragmented national EPR system, more uniform fee structures, a broader scope (such as e-commerce) and a design-driven approach.
Lim presented Lessons from Aerosol Can Recycling. RTI International partnered with the ARI, led by the Can Manufacturers Institute (CMI) and the HCPA, to identify and understand the incentives and barriers influencing MRFs’ acceptance of aerosol cans. RTI interviewed 14 MRFs across 11 States to capture a broad view of aerosol recycling practices and barriers. Six explicitly accept empty aerosol cans; four accept them but do not explicitly state that; and four do not accept empty aerosol cans.
Three key risks to accepting aerosol cans were identified based on interviews with MRFs across the U.S.:
1. Safety: Aerosol cans, particularly non-empty cans, can cause fires/explosions that put workers at risk and can damage equipment.
2. Downstream contamination: Aerosol cans may be viewed as contaminants in other metal streams, creating challenges for downstream processors and buyers.
3. Lack of end market: There may not be readily accessible buyers for bales containing aerosol cans, limiting the economic viability of acceptance.
Lim noted that all three risks are real but that all three are manageable with the right procedures. Regarding safety, aerosol fires are proportionally rare, compared to lithium ion batteries (40%) and propane cylinders (20%). Non-empty cans are the primary hazard, but front-end sorting stations and education can intercept most risk. Prevention and mitigation frameworks make acceptance operationally safer, while resident education on “empty means empty” can reduce non-empty cans at the source.
Contamination risk is driven by non-empty cans and aerosols ending up in the wrong bale and both are preventable. Clear acceptance criteria communicated upstream to municipalities and residents is the highest-leverage intervention. Equipment upgrades and quality control at sorting stations can reduce downstream contamination impact.
Concerning lack of end market, brokers and scrap managers readily accept steel bales without price penalties or rejections, said Lim. Sheet mills reject aluminum aerosols, but secondary processors provide viable pathways. The end market concern is often a perception gap—MRFs are avoiding aerosols based on assumptions that buyers don’t share and proactive buyer conversations before acceptance decisions are a key first step.
Empty aerosol cans can be recycled, noted Lim. Facilities doing this well aren’t exceptional—they’re informed. The Yes, We Can! playbook provides the operational toolkit to start closing the information gap.
Cindy Newberg, Chemicals, Coatings & Products Division Director, Office of Air & Radiation, U.S. Environmental Protection Agency (EPA), presented Overview for Aerosols. The American Innovation & Manufacturing (AIM) Act authorizes the EPA to regulate hydrofluorocarbons (HFCs) in three main ways: phase down HFC production and consumption through an allowance allocation and trading program; manage use and reuse of HFCs by maximizing reclamation and minimizing releases from equipment; and transition sectors to next-generation technologies through restrictions on use of HFCs. Newburg offered an extensive amount of technology transition resources and encouraged those who had questions or who wanted to join the Technology Transitions contact list, to send an email to: [email protected].
Brian Houston, GM, Foam, Aerosol & Solvents, Solstice Advanced Materials, presented U.S. Aerosol Policy Landscape. PFAS (perfluoroalkyl and polyfluoroalkyl substances) policy in U.S. States remains an active discussion. The aerosol sector is impacted by PFAS, HFC and volatile organic compound (VOC) regulations. However, there are innovation opportunities via medical and Significant New Alternatives Policy Program (SNAP) exemptions.
Product classes in Medical Exemptions include over-the-counter drug products, such as sunscreen, acne cream or dandruff shampoo, as well as medical devices, such as topical anesthetic spray. Therefore, innovation can move forward with topical pain relief sprays, for example.
Steven Andrews, Acting Senior Regular Regulations Officer, U.S. Dept. of Transportation (DOT) Pipeline & Hazardous Materials Safety Administration (PHMSA), presented New & Upcoming Initiatives. Recent key Executive Orders include Unleashing Prosperity Through Deregulation (EO 14192) and Unleashing American Energy (EO 14154). In April 2025, DOT issued a Request for Information, seeking input on regulations or guidance to repeal or modify to cut costs and improve efficiency while maintaining safety. In June 2025, PHMSA issued Advance Notice of Proposed Rulemaking (ANPRM) (HM-265B) seeking feedback on opportunities to improve Hazardous Materials Regulations (HMR).
On July 1, 2025, PHMSA published 17 Notice of Proposed Rulemakings (NPRMs) in the Federal Register, seeking to eliminate outdated, unnecessary and overly burdensome regulatory requirements within the HMR. The vast majority of comments received were supportive, with some helpful feedback, as well. The Final Rules were projected to be published in Spring 2026, but were not yet available.
Other open rulemaking actions include HM-268A—Aerosol Definition Harmonization; HM-266—Modernizing Regulations to Facilitate Transportation of Hazmat Using Highly Automated Transportation Systems; and HM-267— Modernizing Regulations to Facilitate Transportation of Spacecraft and Space Related Hazmat.
In 2025, PHMSA implemented the 30-day pending interpretation process to modernize how it provides regulatory guidance. The change was driven by two primary goals: transparency and stakeholder engagement. PHMSA conducts a preliminary review of an incoming Letter of Intent[CH1.1] request, which is posted to a public “Pending” page on the PHMSA website (separated into Pipeline and Hazmat sections). Stakeholders have 30 days to submit comments; PHMSA reviews the comments and then issues a final, written interpretation or denies the request.
Don Burger, Director of the Special Permits Program, PHMSA, presented Intersections: Special Permits & Aerosols. A special permit is a document that sets forth alternative requirements, or variances, to the HMR requirements. It is, in effect, a permission slip to perform an action that would not otherwise be allowed under the terms of the HMR. An applicant must demonstrate that the proposed alternative achieve a level of safety, at least equal to that required by the regulation. If no regulation exists, the proposal must be consistent with the public interest.
There are many instances where special permits have been issued for use by the aerosol industry, for example, thin-walled aerosol cans; alternative to hot water bath tests; alternative pressure relief systems; pure gases in aerosol cans; higher pressure gases in aerosol cans; and plastic aerosol cans. Special permits have introduced innovation into the aerosol industry, Burger emphasized.
Sometimes regulation and innovation appear to be separate from one another but special permits exist at the intersection of innovation and regulation. They have introduced innovation into the aerosol industry and will continue to do so into the future, he concluded.
