FPA Submits Comments on the NERC/NEWMOA Model Minimum Postconsumer Recycled Content Requirements for Plastic Products and Packaging Legislation

The Flexible Packaging Association (FPA) applauds and supports your efforts in taking steps to proactively address the issue of minimum post-consumer recycled (PCR) content requirements. We believe that a suite of options is necessary to address plastics circularity and that well-crafted public policy is a major piece of that puzzle. Unfortunately, as currently drafted, FPA finds the NERC/NEWMOA proposed Model Minimum Postconsumer Recycled Content Requirements for Plastic Products and Packaging Legislation’s definition of “Producer” is problematic and erroneously targets packaging manufacturers (converters) of plastic packaging, instead of the product manufacturers; specifically the second bullet point.