Draft Product Stewardship Action Plan For Carpet December 5, 2000

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1 Draft Product Stewardship Action Plan For Carpet Why Carpet is a Waste Management Problem Carpet is identified as a candidate for product stewardship for two reasons. First, while carpet does not pose a toxicity hazard, it is a bulky item that represents a cost to generators for handling and disposal. Second, certain carpet manufacturers have already adopted product stewardship as an operating principle, offering take-back programs and recycled content products. Product Stewardship Goals Discarded carpet should be collected and recycled in ways that involve manufacturers and/or retailers assuming some financial and/or physical responsibility for the product at end of life. Carpet should be designed to minimize its environmental impacts throughout its life including reduction of waste and toxicity and to facilitate recycling at end-of-life. Carpet components should be labeled to facilitate resin and backing identification. Consumers should be well informed of the reuse, recycling and recovery options for discarded carpet. State procurement guidelines should be developed to prioritize the purchase of environmentally-preferable carpet. Background Carpet Industry and Production In 1998, carpet production in the US was estimated to be 1.8 billion square yards. The five largest manufacturers are Shaw Industries, Mohawk Industries, Beaulieu of America, Collins & Aikman and Interface Flooring Systems. The four largest resin manufacturers are Honeywell, DuPont, Solutia and BASF. Average life of residential carpet is seven to ten years while commercial carpet is approximately five to eight years. Face fiber represents almost 50 percent of the carpet s weight. Nylon 6,6 represents 40 percent of all carpet fibers discarded while nylon 6 represents 30 percent. PET is ten percent and Olefin (polypropylene) is 15 percent. Eighty percent of U.S. carpet production occurs within a 65 mile radius of Dalton, GA.

2 Carpet Waste Generation Approximately 1.75 million tons of carpet is disposed annually in the U.S. A recent MSW composition study in Minnesota identified carpet as constituting 2.4 percent or 77,000 tons of MSW. Massachusetts estimates that 46,000 tons of carpet are discarded annually in that state. The EPA estimates that less than one percent of post-consumer carpet was recycled in It is estimated that approximately 65 percent of discarded carpet originates from residential sources. Opportunities and Barriers to Implementing Product Stewardship Programs The difficulty with the identification of fiber types has hindered the recycling of carpet since recyclers must devote resources to facilitate identification. Few markets exist for nylon 6,6, the most widely used resin for carpet. The infrastructure for collection and processing of discarded carpet, particularly from residential sources, is virtually non-existent. Government policy and programs have not generally targeted carpet as a material of concern and thus not encouraged the recycling of carpet. For instance, until recently, recycled content carpet or other products made from recycled carpet have not been specified for government procurement. Carpet manufacturers and recyclers are generally clustered in the Southeastern United States often making transportation from other regions difficult. Survey of Product Stewardship-Related Activities Government Policy Europe: Carpet Recycling Europe is an initiative of the European carpet industry to collect and recycle discarded carpeting. The initiative began in February 1998 and is financially supported by 87 European carpet mills; they actively started recycling carpet in early Carpet Recycling Europe has an aggressive plan to construct ten carpet sorting plants in the next five years. United States: Since carpet poses little threat from a toxicity perspective, very little policy at the federal, state or local level targets carpet as an item of concern. For instance, carpet is not an item yet subject to disposal bans. 2

3 Midwestern Workgroup on Carpet Recycling The Carpet Workgroup, a joint project of the states of Minnesota, Iowa, and Wisconsin, and the U.S. EPA, met six times between February and November 2000 to create a product stewardship solution for discarded carpet that does not rely on government financing. Workgroup participants included: Carpet manufacturers: Collins & Aikman, J and J Industries, Milliken, Interface and Mohawk Industries. Fiber manufacturers: DuPont, BASF, and Honeywell. Non-governmental organizations: Recycling Association of Minnesota, Associated Recyclers of Wisconsin, Citizens for a Better Environment, and the Carpet and Rug Institute, Northwest Product Stewardship Council. Recyclers: Reynolds Urethane and Carpet Pad Recovery LLC. Local Government: Winona County, MN, The Solid Waste Management Coordinating Board, Twin Cities Metropolitan Area, La Crosse County, WI, Lake County, IL. State attendees at November meeting: Florida, Georgia, North Carolina, South Carolina, Oregon, Ohio, Indiana, Tennessee, NERC The outcomes of the Midwestern Workgroup on Carpet Recycling include: Negotiated Outcomes. To achieve the goal of a flexible, industry-led approach, manufacturers and government will: develop a negotiated schedule for the eventual elimination of land disposal and incineration of post-consumer carpet; and establish escalating goals for recycling and reuse. Third-Party Organization. Carpet manufacturers recognize that they have a role in the management of post-consumer carpet and that increasing reuse and recycling of carpet would be accomplished most efficiently through a coordinated approach. The workgroup agreed to the creation of an organization sponsored and organized by industry that would achieve the negotiated outcomes. Responsibilities of the third-party organization may include: Negotiate the outcomes with government Implementation of negotiated outcomes Promotion of closed-loop recycling Determine standards for membership Establish evaluation/performance tracking Develop industry research agenda Coordinate market development efforts 3

4 Establish financial instruments to support programs Apportion financial responsibilities among members Support procurement guidelines Conduct annual reporting function Model Procurement Guidelines. The Workgroup recognizes the importance of enhancing markets for the sale of environmentally preferable carpet and developed model procurement guidelines for adoption by public entities. These model procurement guidelines are tailored to support the efforts of the third-party organization and enhance product stewardship activities. The model procurement guidelines will include the following provisions: Recyclability of new carpet installed. Reclamation for carpet that is being replaced. Indoor air-quality standards. Minimum recycled-content standards. Government Activities Federal: The federal Comprehensive Procurement Guidelines issued by EPA specify recycled content for PET carpet. Minnesota: Minnesota has implemented procurement guidelines that offer recycled content carpet products (nylon and PET) as well as requiring manufacturers to offer reclamation for Massachusetts: Massachusetts has created and implemented procurement guidelines offering recycled content carpet products (nylon and PET). The contract also requires all vendors on the contract must offer Industry Leaders Milliken Milliken Carpet reclaims, refurbishes and re-sells commercial carpet tiles Collins & Aikman Collins & Aikman collects vinyl-backed carpet tiles from commercial sources for recycling into new backing. Currently offers a product with the highest overall postconsumer content level in the industry. Interface Interface Flooring offers reclamation program for old carpet from commercial sources when new product is installed. Interface also offers a leasing option whereby they will maintain and ultimately take-back a carpet at end-of-life. 4

5 DuPont DuPont conducts limited recycling of nylon 6,6 collected through its commercial carpeting division. The recycled content products produced include among others, automobile parts and carpet backing Honeywell Honeywell recently opened a facility in Augusta, Georgia to recycle 200 million pounds of nylon 6 annually into new nylon fibers for use in a variety of products. BASF BASF collects and recycles BASF carpet at end of life for no fee. BASF also accepts non-basf carpet for a fee. Next Steps to Achieve Product Stewardship for Carpet Negotiate Outcomes: Following the work of the Midwestern Workgroup on Carpet Recycling, the negotiated outcomes process to determine reuse and recycling rates for a ten-year timeframe will be initiated in February, Specific activities: Select and brief government representatives. Develop criteria for selecting reuse and recycling rates. Finalize and adopt Model Procurement Guidelines: A procurement small group consisting of Midwestern Workgroup members is refining the model procurement guidelines and is expected to complete a draft in January. Specific provisions of the model procurement guidelines include recycled-content, recyclability, reclamation and indoor air-quality standards. Specific activities: Circulate draft guidelines for review and comment Develop implementation strategy for public and private entities. Assist in the creation of the Third-Organization: The Carpet and Rug Institute is circulating a memorandum of understanding to its members to secure support for the third-party organization. 5