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Changes to CA's Rigid Plastic Packaging Container Program

Posted by Chandler Slavin on Sep 12, 2014 8:17:00 AM

Hello and happy Friday my sustainable packaging friends!

Today I am going to pick up where I left off re: California's Rigid Plastic Packaging Container program (hereafter, RPPC). Please see my August 25th post, "California's Rigid Plastic Packaging Container Program, is it working?" for context on this legislation.

Below is an overview of CA RPPC program as per Victor Bell's (President of Environmental Packaging International) presentation at the Annual AVPM meeting last year during Pack Expo in Las Vegas. Dordan is attending Pack Expo in McCormick Place this year, so feel free to stop by to continue the conversation. Click here to register for FREE with Dordan's comp code

As of January 1, 2013, regulatory changes to the CA RPPC program were made effective, expanding the types of containers now liable; hence, all the recent hoopla. 

Enacted in 1991, the RPPC law intended to reduce the amount of plastic waste disposed of in California and increase the use of recycled, post-consumer plastic in packaging. The law applies to manufacturers/producers/generators of products sold in regulated RPPC's.

As originally defined, an RPPC meant:

  • A relatively inflexible container
  • Made entirely of plastic
  • With a capacity of 8 ounces or more, up to 5 gallons
  • Capable of multiple re closers (this one is a biggie)

All subject RPPC's were required to be made with at least 25% post consumer plastic OR meet one of the other statutory compliance options (there are a bunch).

To clear up confusion, changes to the program were made that provide guidance on:

  • Number of closures
  • Hinges and handles
  • Foldable/tube containers
  • Long-life packaging

For some reason, plastic bags are always exempt; and, containers without lids (like buckets), since they are not capable of closure.

What is now liable, fortunately or unfortunately, are trapped blisters. You know, those fancy paper-based billboards with a "trapped" thermoform blister in the middle that you often see at Costco or Sam's Club? "Trapped" means that the plastic blister is literally trapped (via flange or other design elements) within the paper-based component, be it by sealing or design technologies. Pretty much every competitor of Dordan has developed some type of trapped blister for retail solution with a printing or thermoforming partner, the idea being that you reduce the amount of plastic needed when converting from clamshell to a largely paper-based package; "paper based" can be anything from thin-flute corrugate to SBS board and everything in between. If you mill it, they will come.

Who knows why these trapped blisters are now liable under CA RPPC as they are made largely of printed and laminated paper and contaminated plastic (think glue, adhesives); both of which, a real heel to recycle.

But moving on, and this is where it gets better, now packages capable of at least one closure are liable. Originally, only those RPPC's capable of multiple closures were subject. That means those that would be closed and re-closed with an attached or unattached relatively inflexible lid. Now, any package that is designed to close, including during manufacture and fulfillment processes, will be subject to regulation. You show me a container that isn't designed to close and I will show you a Chicago Indian summer (it's 56 degrees downtown right now).

For example, previously, caulking tubes sold with a lid were regulated while those without were not; now, both are subject.

The updated regulations include factors for identifying responsibility, like:

  • Ownership of the brand name
  • Primary control over product design
  • Primary control over container design

Product manufacturers who are found to use RPPCs are notified of the registration requirements in writing. The product manufacturer must register by submitting contact information within 90 calendar days of receiving a notice. The penalty for late or non-registration range from $1,000-$50,000, depending on time frame.

Each year, a portion of product manufacturers who registered are notified that they have been selected for precertification. These manufacturers have one year's notice that they may be select to certify compliance.

A small number of product manufacturers who received precertification notices will be randomly selected to submit a compliance certification.

To comply, the RPPC must meet one of the following options:

  • 25% post-consumer material content
    • Corporate averaging
  • Source reduction
    • Reduced by 10% by one of four methods: container weight or product concentration or both or comparison to a similar product
    • Corporate averaging
  • Reuse
    • Reused by end of life at least 5 times
  • Refill
    • Replenished by product manufacturer at least 5 times
  • 45% recycling rate
    • If it's a brand-specific package used in conjunction with a particular generic product line or that holds a single type of generic product or is made of a single resin type
  • Floral industry
    • Reused for at least 2 years
  • Alternative container compliance
    • PCM (at least 25%) was used in the manufacturing RPPCs subject or not subject to the law
    • CA-generated post consumer material used in other products or packaging to be credited toward the PCM-content option (I don't know what this means).

While the presentation from which I take this information was delivered in 2013, there was only violation data from 2005:

PETCO, container violation, $42,025.23

Office Max, container violation, $34,350.61

Sony Corporation, container violation, $50,000

In my August 25th I pose the question, "Is it working?" That is, is this legislation working to increase plastics recycling and post consumer recycled content in plastic packaging sold in California? How do the economics play out? Who is supposed to eat the price premium of post consumer plastic material? How can California keep the recycling and re-manufacturing plastics market within the confines to California when we live in a global market of production and consumption? How are California recyclers supposed to compete with Chinese buyers of plastic scrap? 

I emailed my friends at the California Board of Integrated Waste Management, who are responsible for drafting and enforcing this legislation, inquiring into the economics of the program. Unfortunately, I received no response and continue to remain dumbfounded at this program and how it is supposed to help plastics recycling. If you have any insight on these issues, please comment in the comment field below! 

To learn about the efforts of the plastics and recycling industries to incorporate PET thermoform containers into the existing recycling infrastructure, I encourage you to download my 2013 Recycling Report.
Above: trapped blister package, now liable under CA RPPC

Death to composter: zero waste, bio plastics, and bees!

Posted by Chandler Slavin on Aug 25, 2014 9:14:29 AM

Hello and happy Monday! Can we please just pause for a moment and recognize that we are now in the last week of August?! What the what?! Where has the summer gone!

Sooo some time ago I implemented a zero waste to landfill initiative at Dordan that looked to divert all of Dordan's waste from landfill by recycling, composting, upcycling, and repurposing. I visited Burt's Bees manufacturing facility in Durham, North Carolina, and learned best in class waste diversion tactics that I applied to Dordan's ZWTL challenge.

The first step in moving towards zero waste is to perform a waste audit; that is, an assessment of the types of waste produced at Dordan. Good ole dumpster diving. Here I am pre and post dumpster dive, notice the misery of the latter?


If you can't manage what you can't measure, then quantifying the types of waste generated at a manufacturing facility is the first step towards achieving zero waste.

After performing several waste audits at Dordan, we isolated the "low hanging fruit"; those materials that made up the majority of the waste stream and were therefore the easiest to collect and resell to recyclers. We began baling our corrugate for recycling; and, we collected our damaged wood skids and material cores. Dordan has always collected and recycled its plastic scrap and aluminum as these materials have post-industrial value. Making the business case for recycling the other materials, however, was a bit more of a challenge.

The main "economic problem" with working towards zero waste to landfill is it often times costs more to collect and resell to recyclers than it does to landfill the material. For recycling to be profitable, you need to generate the quantity required to justify collection. Often times, collection is the most expensive part of recycling, be it post consumer (curb side) or post industrial (like Dordan and zero waste). So a way to overcome this economic barrier is to condense the material at the source and warehouse until the desirable quantity is achieve to justify a sale to secondary markets; hence, on site bailers, condensifiers, etc. This is not ideal for small or medium manufacturers and those with limited warehousing space.

Another approach to this issue of generating sufficient supply to justify collection and resale is the milk man concept; that is, having several manufacturers located geographically close to one another agree to collect the same types of post industrial materials i.e. corrugate, for recycling. Then, selecting one buyer to pick up the same material at the different facilities, providing the quantity to justify the collection as the value of the recyclate will be more than the cost of collection and resale.

To this vein, Dordan joined Chicago's Waste to Profit Network, a working group of Chicagoland manufacturers working towards zero waste or looking for "byproduct synergies" i.e. one man's trash is another man's treasure. This Network created and manages Cirrus, an online tool for manufactures interested in resellling or buying post-industrial materials otherwise destined for landfill.

Unfortunately, Dordan found no by-product synergies with other manufacturers using the tool; and, was unable to partner with other local manufactures to collaborate on the collection and resale of common post industrial materials.

Another portion of a company's waste stream is "organic waste"; that is, food and yard waste. One of the best ways to manage organic waste is to compost. As such, Dordan constructed a home composter on its property and began collecting all the food waste and yard waste generated by the company.

Two years later, I regret to inform my sustainable packaging devotees that the compost project was a total failure. Not only were we unable to create the necessary environment to encourage microbial ingestion, but we were also unable to achieve the right balance of "wet" to "dry" waste. The former being food waste and the latter being other organic matter, like office paper or leaves.

As such, it was my responsibility to put this initiative to death. Check out the video below of my bro and I demolishing the composter last week. And, learn about home compostable bio plastics and bees! During the video I reference Dordan's Bio Resin Show N Tell as the culmination of our R&D into bio based/biodegradable/compostable and otherwise "green" plastics. You can download that research here.



Dordan featured on "Plastics News Now:" Plastic Execs take the ALS ice bucket challenge

Posted by Chandler Slavin on Aug 21, 2014 11:24:12 AM


So this is hilarious. I got a tweet yesterday that Dordan is featured on Plastics News' "Plastics News Now" weekly news video segment and IT'S TRUE, WE ARE! It is so cool! Titled "Plastics Execs take the ice bucket challenge," this video segment also discusses Northface and its initiative to source all recycled PET for its clothes by 2016 AND innovations in prosthetics, thanks to plastics! Yours truly comes in around the 2:00 minute mark. Enjoy!



Dordan's ALS ice bucket challenge

Posted by Chandler Slavin on Aug 20, 2014 9:29:56 AM

Hey world!

The ALS ice bucket challenge has taken social media by storm; raising awarness, creating community, and encouraging dialogue. Not to mention, raising money for a great cause. 

Dordan's Sales Manager Aric Slavin (and my brother) and myself were challenged by other family members to the ALS ice bucket challenge. See our fabulous videos below. Notice my Dordan swag?!

To learn more about ALS and to donate, visit the ALS Association website. Ahhhh, the power of social media can be glorious. 

Is this for real?! CA company turns carbon emissions into plastics

Posted by Chandler Slavin on Aug 11, 2014 10:15:11 AM

Hello and happy Monday!

The other day our lead packaging engineer emailed me a link to this story, which describes a California company that captures carbon from the air and converts to plastics. What the what?! Let me pause for a moment as you re read that sentence and ponder its amazing ridiculousness.

And the fact that this news story was published via CBS news, a "real" news source, ponders me further.

Bioplastics are cool but critics point to the feedstocks being derived from otherwise valuable bi-products of food production as reason not to applaud. If this technology is for real, and a literal pollutant can be captured and repurposed as the carbon feedstock of plastics, then my mind is blown.

I reached out to one of my friends in the material science and engineered resins space, asking if this technology was viable. He confirmed that Dell was in fact into "carbon air;" Dell is not a company to doubt in the space of sustainable packaging solutions. They were one of the first consumer electronic brands to use Ecovative Design's mushroom based protective packaging for their laptop computers, which was admirable as heck! So yeah, keep your eyes peeled for more commentary on this air carbon business. Science is awesome!

Air carbon plastic bags

Pictured: Dell's "air carbon" plastic bags, CBS News

NPR's "The Weird, Underappreciated World of Plastic Packaging"

Posted by Chandler Slavin on Jul 30, 2014 8:21:00 AM


I have spent a lot of time making a case for the sustainability of plastics and plastic packaging to combat all the misinformation that dominates contemporary discussions of plastics and the environment. Susan Freinkel's Plastics, A Toxic Love Story, discusses the sociological construction of plastics as evolving from representative of man's mastery over the natural environment after WW1 to representative of our society's over consumptive habits. In other words, in targeting plastic bags or plastic bottles, we are scapegoating our collective fear of our ever-depleting natural environment onto a tangible item, thereby ignoring the underlying mechanisms that facilitate our unsustainable models of production and consumption. Heady stuff!

So color me surprised when I came across this pro plastics article from liberal newsource NPR. Titled "The Weird, Underappreciated World of Plastic Packaging," this piece looks to highlight how plastic packaging reduces food waste and is in fact an engineering marvel, not a waste of resources, but an efficient and innovative use thereof. Author Maanvi Singh writes,

Like it or not, plastic packaging has become an ingrained part of the food system.

While it's clearly wasteful to buy salad, sandwiches and chips encased in plastic and then promptly throw that plastic away, we take for granted how it keeps so much of what we eat fresh and portable.

And behind many of those packages that allow us to eat on the go or savor perishable cookies or fish imported from the other side of the globe is a whole lot of science and innovation.

Click here to keep reading.

It are articles like these that will begin to change the perception of plastics in our social imagination from cheap and wasteful to demonstrative of human ingenuity, which any chemical or packaging engineer will argue they clearly are (no pun intended!).

Plastic packaging

California's Rigid Plastic Packaging Container Program: Is it working?

Posted by Chandler Slavin on Jul 22, 2014 12:30:00 PM

Hey guys,

We have had several customers approach us with questions about California's Rigid Plastic Packaging Container Program; what it is, and how to become compliant? I may have mentioned that at last year's Pack Expo in Las Vegas the AVPM, which I served on the Board of, invited Victor Bell of Environmental Packaging International to present on this topic. He and his company work to help international brands meet various environmental and reporting compliancy issues. I have received permission to post portions of this presentation here, for my devoted sustainable packaging loves.

Before I get into the nitty gritty, however, I think it is important to put this legislation into perspective. In its essence, this program looks to increase recycling of rigid plastic containers in California. This is in part to support another piece of legislation in CA (The Integrated Waste Management Act of 1989), which requires cities and counties to reduce the amount of waste disposed in landfills by 50% by 2000 through source reduction, recycling, and composting. The RPPC bill aims to increase recycling of plastic containers (and reduce the amount of plastic containers going to landfill) by requiring increasing levels of postconsumer recycled materials be incorporated into plastic containers sold in California. The law states,

...It is therefore, the intent of the Legislature to spur markets for plastic materials collected for recycling by requiring manufactures utilizing increasing amounts of postconsumer recycled material in their rigid plastic containers only if the use of that material does not present an unreasonably risk to the public health and safety, and to achieve high recycling rates for these rigid plastic packaging containers.

Sounds rad. I like recycling. I like waste diversion. But I honestly don't really get it. And here is why: in 2012 Moore Recycling Associates reports that plastic PET thermoformed containers (plastic clamshells, blisters, trays, etc.) are now "accepted for recycling in the majority of American communities," and therefore, technically recyclable. This was an awesome accomplishment for all plastics and PET stakeholders and the result of years of collaboration, investment, and execution: Industry had to demonstrate to recyclers that collecting PET plastic rigid containers would provide value and not contaminate the existing PET bottle stream; municipalities had to communicate to residents what materials were now accepted via curb side systems; specs for purchasing PET thermoform and bottle bales and PET thermoform only bales had to be created and published; sorting and baling technologies had to be developed to allow for the efficient sortation and sale of PET thermoform containers; and, domestic and international markets had to be assured of a consistent, quality stream of post consumer PET thermoform recyclate. What I am trying to say is that the plastics industry brought their A game when it came to getting PET thermoformed containers included in the country's recycling infrastructure.

Fast forward to 2013 and reports show that plastic rigid containers continue to be accepted for recycling, at a rate much high than their paperboard and molded pulp counterparts. So hey, Whole Foods, your molded pulp takeout containers are all going to landfill, sorry. Unless you have partnered with a local composting facility that will accept the dirty containers for composting, which is super doubtful being that there is only a handful in the country, none which to my knowledge have partnered with retailers like Whole Foods. But I am getting off track.

So great, we are accepting plastic rigid containers for recycling. But are they actually being recycled? Any plastics buyer will tell you that post consumer PET regrind has a cost premium, as you conceptually pay for the process of recycling, which is more expensive than the process of virgin material production (plastics production is a by product of fossil fuel extraction). So we now are requiring brands to increase the amount of post consumer plastic in the packaging they buy even though this material is more expensive than virgin or post industrial plastics and even though these same brands are already sourcing the cheapest products from the cheapest labor pools of the world in order to remain competitive in the global retail environment.

I thought that an economically sustainable model for post consumer plastics recycling could be achieved where the cost of recycling is competitive with the cost of virgin material production (2010 Recycling Report). After further research, however, I have concluded that recycling will always be a cost; the question now needs to become, who's cost (2013 Recycling Report)?

These sentiments are echoed in an email exchange I had with my friend at CalRecycle, the same friend who guided me through the research that later culminated in my 2010 Recycling Report (available above for download). I explained that I have grown frustrated with trying to increase the recycling rates of post consumer plastic packaging because it doesn't seem as though a sustainable economic model exists, which would catalyze increased plastics recycling. In other words, if there was money to be made in recycling post consumer plastics, we would recycle post consumer plastics.

I write,

I feel as though I have arrived at a cross roads of sorts with my research; what else do you think the industry needs to do to increase plastic recycling rates? If thermoforms can be recycled now, will they? Not unless there is economic motivation to do so. Or political requirement? Is that what the California Rigid Plastic Packaging Container Program attempts to facilitate? That is, increasing plastic recycling in California by requiring recycled content in the packaging? Who is supposed to pay for the premium cost of post consumer plastics recyclate?

My friend responds,

You have found yourself faced with the same issue we at CalRecycle (or any group looking to increase recycling rates) eventually finds themselves. There's no good real answer. Once you have removed the technological barriers to recycling, how do you take that next step and actually make it happen? If you ask the free market folks they will say that if it can be done, the free market will do it. If the free market doesn't do it then it can't be done without expensive government requirements and/or subsidies. Others feel that you need to develop the end market by developing buyers for goods made from recycled content and yet others say you must make it easier for the collection, sorting, recycling processes to provide feedstock at a reasonable price.

All of these approaches have been tried for nearly every material and some work better than others but it's very specific to the material in question and nothing is a "silver bullet."

I think you are right that the intent of [CA RPPC] is to increase recycling by requiring more recycled content in rigid plastic packages. But who pays for the premium? Ultimately the consumers (theoretically at least), however the cost of materials would be initially borne by the packaging manufacturer (though there is nothing that I' aware of that specifically dictates how the economics work).*

How is it possible that this CA RPPC program has been on the books since 1991 yet we are still unsure of how the economics work? What is the status of this program? Is it increasing recycling? Is it working?

*Please note: the response above is from my friend at CalRecycle, who does not work on the RPPC program, and therefore can't be considered as speaking on behalf of the RPPC group. I have reached out to the RPPC group at CalRecycle to attain information on the program's success. Stay tuned!!!

I will post Bell's presentation re: CA RPPC program, in my next blog. Thought I'd let you mull this over for a bit.

Below is a 5 minute presentaion I gave on the economics of recycling post consumer plastic packaging for RECOUP's Plastics Recycling Conference. It provides a nice overview of my research. And a sweet mug shot.

plastic clamshell

Above: Example of PET thermoformed plastic container

Paper vs. plastic re: recycling, myths dispelled

Posted by Chandler Slavin on Jul 21, 2014 9:32:00 AM

Hello all!

I don't know how I missed this April Packaging World article, which describes the results of a survey of 700 material recovery facilities about what types of packaging are accepted for recycling. As we know, to claim a package is "recyclable" means that the package has to be accepted for recycling in the "majority of America communities" i.e. over 50%. As such, this type of research is helpful for communicating the realitiy of recycling in America. 

According the surveys, "Rigid plastic items like cups and takeout containers made from plastic had the second highest acceptance ratings, between 50% and 70% of the MRFs included in the study."

And..."Cups, beverage carriers, containers and egg cartons made from coated paper, molded pulp and styrofoam had the lowest acceptance ratings at under 50% of the MRFs included." 

Dang oh dang! I knew that as per this Report plastic thermoformed containers are considered recyclable as the majority of communities accept them for recycling BUT I didn't know that the acceptance rate was so high compared to the paper-based packaging alternatives! 

For more details on the survey, click here

So, who's ready to buy some thermoformed plastic egg cartons?! Go recycling!

To learn about the insane progress in thermoformed container recycling I encourage you to check out my reports, available for download below. 

Recycling Report (2010): the truth about blister and clamshell recycling in America with suggestions for the industry

Recycling Report (2013): the state of post-consumer PET recycling, past, present & future

paper egg cartonplastic egg carton

Left: molded pulp egg carton, limited recyclability; right: plastic egg carton, recyclable 

Press Release: Dordan brings interactive, educational displays to International Pack Expo

Posted by Chandler Slavin on Jul 15, 2014 4:19:00 PM

Dordan ManufacturingInternational Pack Expo

Chicago—November 2, 2014—Dordan Manufacturing returns to International Pack Expo with interactive displays aimed at educating show attendees about custom thermoformed packaging solutions and sustainable packaging.

Touch, smell, see and er, taste? the latest and greatest bio-based/biodegradable/compostable and otherwise ‘green’ plastics with Dordan’s Bio Resin Show N Tell; learn about Dordan’s Design for Thermoforming Process with 3D package design modeling videos and photo-realistic package design renderings; and, discover how Seeing it Sells it with Klockner’s eyetracking study.

Dordan’s Bio Resin Show N Tell is an environmental comparative of 9+ alternative resins; cost and performance analysis included. By understanding the capabilities and limitations of the available “eco-plastics,” Dordan hopes to provide Pack Expo attendees with the information required to make more informed packaging decisions. To be unveiled in Chicago is fourth-generation algae plastic, demonstrating continuing innovations in synthesizing aquatic biomass for plastic applications.

Dordan is an engineering-based designer and manufacturer of custom thermoformed packaging solutions. All of our package designs are therefore 100% thermoformable and optimize the capabilities inherent in the art of thermoforming. Learn about our Design for Thermoforming Process with 3D package modeling videos and photo-realistic package renderings, streaming live in an interactive package design exhibit.

“Now more than ever, brand owners and their suppliers are held accountable by consumers, retailers and regulatory agencies to reduce the environmental impact of their supply chains,” says Chandler Slavin, sustainability coordinator and marketing manager, Dordan Manufacturing, Inc. “Our philosophy behind the ‘Design for Thermoforming Process’ was to empower them with a holistic approach to design strategy, material selection and machinery usage — minimizing inefficiencies along the way and helping fully understand the sustainability-enhancing measures behind their packaging.”

And lastly, learn how package design dictates product sales with Klockner’s groundbreaking eyetracking study video, streaming in HD in this exhibit from Dordan. By fashioning retail shoppers with heat mapping eyetracking glasses, it was determined that clamshell packaging facilitates product sales 402% times more than paperboard boxes.

Located in the Lakeside Upper Hall, booth #8403, Dordan looks forward to sharing its educational and interactive exhibits with the international packaging community.

About Dordan Manufacturing Co. Inc.

Dordan Manufacturing is an engineering-based designer and manufacture of custom thermoformed packaging solutions, like plastic clamshells, blisters, trays and components. Based 50 miles Northwest of Chicago in Woodstock IL, Dordan is a 50,000 square foot facility equipped with sophisticated software and machining technologies. Family owned and operated, Dordan has 50-years-experience designing and manufacturing thermoforms parts that perform. Dordan Manufacturing is ISO 9001:2008 certified for the design, manufacture, and distribution of thermoformed packaging.

Buy 'Made in America' this 4th of July

Posted by Chandler Slavin on Jul 2, 2014 7:11:00 AM

Hello world!

In anticipation of our great country's Birthday, I thought I would take a moment to mention the good people of the Made in America Movement. This grassroots organization works to educate consumers on the political and economic importance of buying made in America products. 

For members of the Made in America Movement, buying American products equates to creating American jobs. And what is more patriotic than supporting a working future for America this 4th of July?!

As an American manufacture of custom thermoformed packaging, Dordan is proud to support the Made in America Movement.

Take the pledge to buy American this Independence Day.