December 2020

Ensuring sustainable consumption of aerosol containers

There are ongoing discussions throughout the world about our waste problems. As countries and regions try to come up with different solutions, they all have the same goal of decreasing the amount of waste and improving sustainability.

Government agencies and key stakeholders want to establish new strategies, identify investment opportunities for technology and infrastructure and develop international agreements to globally reduce waste.

From a young age, we’re taught about the 3Rs—Reduce, Reuse, Recycle—to help minimize waste and conserve resources. All industries, including the aerosol industry, must continually look at products, packaging and best practices to help contribute positively to society and minimize our impact on the environment.

One way to reduce waste is to not create it in the first place. Industries are looking at packaging as an area for potential innovation in order to continue to deliver safe products while also reducing the amount of packaging materials. Globally, the aerosol industry has innovated to reduce the amount of metal needed for its containers. However, in the U.S., the aerosol industry is subject to requirements that limit the ability to reduce the amount of metal needed for a finished container.

Reusing products is another way to effectively limit waste, but the aerosol delivery form is currently designed as a single-use package. The potential redesign of an aerosol product for reusability has been discussed, e.g. how the refilling could be done and done safely and whether such a refillable design is actually more sustainable.

For aerosol products, recycling is currently the most optimal way to minimize the impact of the product’s packaging on the environment. Recycling requires cooperation by both consumers and workers to dispose of empty aerosol products properly.

Most aerosol containers are made with steel or aluminum. Both materials are readily recyclable when empty and have value within the recycling stream, as research1 shows that approximately 70% of U.S. consumers have the ability to recycle these products. However, there continues to be a disconnect with many consumers and workers that empty aerosol products are recyclable, in part because 30% of U.S. consumers don’t have access to empty aerosol product recycling.

There are inconsistencies between municipalities about what products can and cannot be recycled (including aerosol containers) that have led to a number of challenges. This provides an opportunity for a more uniform solution, and fortunately, the U.S. Environmental Protection Agency (EPA) is in the process of developing a National Recycling Strategy2. This program will focus on reducing the contamination in the recycling stream, improving processing efficiency and improving domestic markets so that recycled materials can remain in the U.S. to be reused in future products.

The Household & Commercial Products Association (HCPA) provided comments to the EPA on its draft National Recycling Strategy. HCPA stressed the need for a harmonized national recycling system, without restricting the implementation of future technological developments, as well as clear and consistent messaging to consumers about what materials can and cannot be recycled.

HCPA also signed the America Recycles Pledge3, which is a commitment to work together with the EPA and other signatories to build on existing efforts to address the challenges facing the nation’s recycling system and to identify solutions that create a more resilient materials economy and protect the environment.

There’s also activity within several States, as they can often move faster than the Federal government. Multiple industries have voluntarily moved forward with the development of stewardship programs to address the disposal of their products; however, several States are looking at potential Extended Producer Responsibility (EPR) legislation to share the responsibility for end-of-life product management with industry. Multiple States have also convened recycling committees to strengthen recycling streams. However, States don’t always look at recycling processes in the ways that industry would like, which may result in certain States making different decisions on what is considered recyclable and potentially creating more confusion by adding to the patchwork of acceptable materials for recycling.

Ultimately, the goal is for every aerosol container to be recycled the same way as any other metal container. Not only are steel and aluminum valuable in the recycling stream, but recycling these metals saves energy and natural resources, thus reducing waste in more ways than one.

With an increase in government and public stakeholder activity focused on waste disposal, HCPA is partnering with the Can Manufacturers Institute (CMI) and Pet Food Institute (PFI) for the initial phase of a new recycling project. This project isn’t focused on the consumer side of recycling, but on the municipality side; we’ll be interviewing material recovery facilities (MRFs) and end-market processors who recycle scrap metal in order to learn what the aerosol industry can do to increase its acceptance and improve its processing of empty aerosol products (and pet food containers). Ultimately, we need to be able to answer the following questions: Why doesn’t every U.S. consumer have the ability to recycle their empty aerosol products and what can we do to make that a reality?

The aerosol industry conducted a study that assessed the risk of aerosol products within the recycling stream4, but that research is now almost 25 years old. However, the lessons from this study are still applicable. For example, the likelihood of a significant accident is very low. Still, the technology and procedures at MRFs have since been updated and the requirements of those that purchase scrap metal and recycle it into new materials have, in some cases, been significantly altered. The aerosol industry needs to ensure that it’s operating on the most up-to-date information in order to move forward.

There are still many questions that we don’t have answers to. For example, once the MRF has the container, are we sure it progresses through the entire system to be recycled? We assume that the steel container is separated by a magnet and makes it all the way to a company that will smelt the steel so that new products can eventually be produced. However, that may not be a correct assumption as we have also heard anecdotally that smaller and slimmer aluminum aerosol cans have the ability to “fall through the cracks” during the sorting process and end up in a landfill. If this is indeed true, we need to know what size container is necessary so that an aluminum aerosol container makes it through the entire sorting process and can be recycled into new material.

The goal of this project is to better understand the waste disposal system for aerosol products and the technical barriers to recycling more containers. Then, with this increased understanding from research, the HCPA, CMI and other stakeholders will embark on an effort to get more aerosol containers recycled and make the system more circular.

Beyond the sorting of aerosol containers, why is it that more of the end-market processors who purchase bales of scrap metal don’t accept aerosol containers? At this point, we are not aware of any market acceptance issues with steel aerosol containers, although it’s certainly something that needs to be confirmed.

On the other hand, there are several end-markets where aluminum aerosol containers don’t meet specifications. The aerosol industry has always prided itself on the high quality of its aluminum containers, so why aren’t they meeting these endmarket specifications—and does that really matter when there are other end-markets that will readily purchase aluminum aerosol containers that are mixed with other aluminum scrap? Ultimately, what is the capacity of these end-markets and if we were able to get consumers and workers to recycle every single aerosol product that they use, is there a stable market for these containers?

There are many other things we hope to learn within the initial phase of this project. From there, we’ll develop a roadmap to determine what the next steps are, with the ultimate goal of having every aerosol container processed into new material for future products.

I encourage every person in the aerosol industry to get involved with this project. It is of the utmost importance that every stakeholder provides input into this and future projects. If you would like to get involved, please contact me at [email protected]. SPRAY

1 Sustainable Packaging Coalition: 2015-2016 Centralized Study of the Availability of Recycling for Aerosol Containers can be found here

2 EPA’s draft National Recycling Strategy can be found here

3 link

4 Kumar R. Bhimavarapu & Dimitrios M. Karydas. Recycling Aerosol Cans: A Risk Assessment. Factory Mutual Research Corp. April 1996.