1 GreenWaste of Palo Alto
Initial Review of Certificate of
End Use & Traceability Data,
2023
February 1, 2024
Contact:
Eric Cissna
[email protected]
650-798-5994
2765 Lafayette St.
Santa Clara, CA 95050
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Table of Contents
Table of Contents ........................................................................................................................................................... 2 Background & Expectations ......................................................................................................................................... 3 Progress and Action Plan ............................................................................................................................................. 6 Summary ....................................................................................................................................................................... 10 CellMark Inc. (Novato, CA) ..................................................................................................................................... 15 Berg Mill Supply/Classic Fibres (Los Angeles, CA)............................................................................................ 18 Fibre Trade Inc. (Burlingame, CA) ......................................................................................................................... 20 Newport CH International (Orange, CA) ............................................................................................................... 21 Direct Pack Recycling (Azusa, CA) ....................................................................................................................... 23 Envision Plastics (Chino, CA) ................................................................................................................................. 25
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Background & Expectations
GreenWaste of Palo Alto, LLC and GreenWaste Recovery, LLC GreenWaste of Palo Alto, LLC (GWPA) is the City of Palo Alto’s (City) contracted solid waste, recyclable materials, and compostable materials collection and processing contractor. The Agreement between GWPA and the City (GWPA Agreement) commenced in October 2008, and has since been amended and restated in June 2015, and again amended and restated in January 2019, with the term extended through June 30, 2026.
Under the GWPA Agreement, GWPA collects recyclable materials, compostable materials, and solid waste from City residents and commercial businesses. Recyclable materials are transported to the GreenWaste San Jose Material Recovery Facility (MRF), where they are processed for recovery. At the MRF, comingled recyclables are processed to remove contamination and separated by material type (e.g., paper, cardboard, plastic, metal, etc.). The MRF then sells the separate d recovered materials to brokers and/or secondary processors for further recycling. Compostable materials are transported to the GreenWaste Renewable Energy Digestion Facility, where they undergo anaerobic digestion to produce renewable energy and a feedstock for compost.
Effective January 1, 2022, following a City procurement process, GWPA began transporting municipal solid waste (MSW) to the MRF for processing under the Solid Waste Processing and Disposal Services Agreement (MSW Processing Agreement). This material is processed at the MRF to recover both compostable materials and recyclables.
The materials managed by the GWPA Agreement and the MSW Processing Agreement are disparate.
GWPA collects approximately 16,000 tons of recyclable material annually for processing at the MRF.
Additionally, per monthly reporting required by the MSW Processing Agreement, approximately 852 tons of recyclables were recovered from the City’s solid waste stream in Fiscal Year 2023, representing 5.5% of the overall solid waste stream.
Commodities Markets & Trade Secrets
GreenWaste Recovery, LLC (GWR) is a recyclables processor and markets its own recyclable commodities.
Over the last five years, the recycling industry has gotten more complex due to the changing landscape of new international guidelines and restrictions on shipments of recyclables.
CalRecycle succinctly summarizes some of the recent changes that have had significant impacts on the recycling industry:
“The export of recyclable materials is a key component of California’s recycling infrastructure.
Changes to international policies restricting imports of recyclable materials, the declining global market for plastic and paper scrap, and the impending Basel Convention plastic waste amendments that will make exporting plastic scrap more challenging continue to pose a significant challenge to the solid waste and recycling industry, local governments, and Californians.” (https://www.calrecycle.ca.gov/markets/nationalsword)
GWR has witnessed firsthand the impacts of these changes . In 2017, a paper mill in Santa Clara closed due to high production costs and fluctuating Old Corrugated Cardboard (OCC) prices ( 2022 Traceability
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Report). Material previously sent to this local facility was forced to be sent out of state to mills in the Midwest, Louisiana, and Georgia.
As the marketers of their own recyclable commodities, GWR has borne witness to how unstructured commodities markets can be. GWR sells its recycled materials to brokers and/or secondary processors.
Once the material is sold, it may change hands many times or undergo further processing before reaching its ultimate destination. Brokers may have incomplete information regarding the final destination of the materials or they may be unwilling to share th e information they do possess due to confidentiality concerns. Once at port, materials are sent to various plants, making the full life cycle of commodities extremely difficult to track. Furthermore, recyclables brokers are not in a position to place requirements on customers.
Information on commodity markets, pricing, buyers, and other information pertaining to commodity sales transactions constitute confidential and proprietary corporate Trade Secrets. This information is not of public knowledge or general knowledge in the trade or business and has an intrinsic value preserved by being safeguarded from disclosure. GWR and its brokers stand to be harmed by the disclosure of Trade Secrets as follows:
• Losing markets for specific materials (e.g., plastic clamshells or film plastics), • Losing local markets and only having available domestic or international markets, • Losing domestic markets and only having available international markets, or • Jeopardizing relationships with buyers, with the potential to lose business.
For the reasons detailed above, it has continued to be a challenge to ascertain additional information regarding the final disposition of recovered recyclables. GWR and GWPA are not alone in this challenge to gather a complete data set. The World Wildlife Fund (WWF) established Resource: Plastic in cooperation with five Principal Members (Keurig Dr Pepper, McDonald’s Corporation, Procter & Gamble, Starbucks, and The Coca-Cola Company) in 2020 and released its inaugural Transparent 2020 report. The report identified the significant data gaps: “ The lack of data on waste management globally is a shared challenge —no one institution can address it alone…”
(https://resource-plastic.com/pdf/Transparent2020.pdf).
An updated report was released in December 2021, and further calls for filling critical data gaps and improving data confidence: “Filling critical data gaps and actively sharing information will improve the quality and precision of our understanding of the plastic waste system. There is a clear need for better waste management and fate data at the national level, international coordination on plastic data collection efforts, and agreement on common terminology and best practices.” (https://resource-
plastic.com/backend/sites/default/files/2021-12/Transparent%202021%2012-1-21.pdf)
A third report in December 2022 continues to appeal for improving data confidence and transparency :
“ReSource has called for collaboration to fill key data gaps and improve data confidence levels. As the list of stakeholders interested in understanding the state of the plastic waste crisis expands to include investors, financial institutions, and policy makers, this call to action is more relevant than ever.” The report continues with a promising development : “ The Global Treaty on Plastic Pollution, which t he United Nations began negotiations on in late 2022, has the potential to set an important high- level framework for information, especially for country -level reporting and disclosures. Furthermore, a collaborative effort to create a standardized plastic disclosure framework for the private sector was announced in fall 2022 by CDP, The Pew Charitable Trusts, Minderoo Foundation, and the Ellen MacArthur Foundation. Both developments are exciting
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steps toward the consistent and standardized reporting process that ReSource has long called for. ” (https://files.worldwildlife.org/wwfcmsprod/files/Publication/file/9dsv7winop_WWF_Transparent_2022_FINAL_12.5.22.pdf?_ga =2.226735320.473129063.1689098649-1688916787.1689098648) New Agreement Amendment & Expectations
At the end of 2018, while City staff was updating their Zero Waste Plan and wrapping up negotiations with GWPA on an Agreement Amendment and extension, City Council gave City staff direction to report on the intermediate and final disposition of Palo Alto’s recovered paper and plastic. City staff and GWPA agreed that as a goal, GWPA would attempt to gather information on the environmental and social implicatio ns associated with the full life cycle of Palo Alto Recyclable Materials.
The expectation of the new Attachment to the Agreement, “Environmental and Social Impacts of Processing Recyclable Materials”, was that GWPA would request information from the “primary purchasers” of Palo Alto’s recyclable materials and then conduct a desk study based on the provided information.
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Progress and Action Plan
Domestic Processing Availability
Recycling operations across North America are adding processing capacity to accommodate the growing amount of material displaced by export market upheavals. Domestic innovation is growing but continues to be far from providing sufficient capacity for all recycled materials generated domestically. This is especially true in California, where inefficient permitting processes and bureaucratic delays can make permitting new recycling facilities, such as pulp and paper plants, lengthy and challenging. The permitting process for building in-state recycling infrastructure will need to be streamlined and consolidated in order to meet the increasing demand for these facilities.
GWPA has worked with GWR to identify and secure space with existing domestic processors of cardboard, paper, and plastic to provide greater assurances regarding the ultimate disposition of the City’s material and to ensure that the processing adheres to the United States’ environmental standards. Domestic markets are generally more expensive and competitive than international markets and securing space with these processors can be a challenge due to limited capacity.
To confront this market challenge, City staff and GWPA developed a three-month pilot program which took place between April and June 2022 to take 100% of Palo Alto’s mixed paper and mixed rigid plastics to processing facilities within the United States. Mi xed paper is comprised of various types of paper that is collected from residents and businesses in Palo Alto such as colored paper, magazines, junk mail, envelopes, and paper bags. Mixed rigid plastic is primarily comprised of plastic items including buck ets, toys, and milk crates. During the pilot, mixed paper was sent to a pulp and paper mill in northern Louisiana, while mixed rigid plastic was sent to a processing facility in southern California.
In June 2022, City Council approved this program to continue in Fiscal Year 2023 with the goal to keep 59% of the recyclable materials in the United States to be processed, reducing the amount to be exported to about 41% with only cardboard and PET plastic clamshells being processed internationally. Cardboard was not selected as a material to be kept domestically since it is high quality, contains low contaminants, is desired by processing facilities, and has consistent market demand to be recycled. Additionally, the added cost of recycling cardboard domestically has proven to be prohibitive in the current market environment. However, the domestic market that GWR identified and presented to the City remains available at this time. PET plastic clamshells were not selected to be kept domestically because there are not currently viable domestic markets available for this material. While PET plastic clamshells are processed internationally, they are still being processed within North America at a recycling facili ty in Mexico.
In Fiscal Year 2023, approximately 3,507 tons of Palo Alto’s mixed paper w ere processed and recycled within the United States at the same northern Louisiana facility utilized during the pilot program.
Additionally, approximately 151 tons of mixed rigid plastic w ere processed and recycled at a domestic facility in St. Louis, Missouri.
GWR Facility Upgrades
To ensure that the largest percentage of material s processed at the MRF are in proper condition to be recycled, GWR focuses on ensuring commodities are clean and contamination-free. In May 2019, the MRF completed an upgrade to its single stream recyclables line, the line on which Palo Alto’s materials are processed. This upgrade included the installation of six optical sorters to reduce contamination and produce cleaner, higher quality recovered recyclables. These optical sorters improve the quality of mixe d
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paper and newsprint by repelling plastic away from paper using infrared lasers. These lasers identify the various types of plastic that, in the past, inadvertently ended up mixed in the paper stream and recover them based on their unique resin type. Both the paper and plastics are then separated, sorted, and bailed for marketing.
In February 2020, the MRF was upgraded again with two MAX-AI autonomous quality control systems (one of which featured two sorting units), which were programmed to identify specific material types and extract anything that does not belong in its respective stream. The first unit removes non- HPDE contamination, and the second unit selects HPDE-natural. By ensuring a clean product, GWR gains a strong position in the market, and reduces the risk of downstream issues.
The MRF is currently working on further upgrades with the addition of another optical sorter. This optical sorter will be calibrated to sort #2 - #7 plastics out of the residue stream, which are typically destined for disposal. With this additional optical sorter, more plastics will be diverted from disposal and be recycled, increasing the overall diversion of these materials.
Mixed Paper Composting Pilot
Together with the GreenWaste Z-Best Composting Facility (Z-Best), GWR conducted a pilot project in 2021 for the City to determine the effectiveness and associated costs relative to composting mixed paper recovered from the single stream recyclables line . The methodology for this pilot can be referenced in GWPA’s 2022 Traceability Report
.
Ultimately there was insufficient capacity at Z-Best for this mixed paper stream in 2021. With California’s implementation of Senate Bill 1383, organics capacity across the state is in high demand. However, the Z- Best composting facility will be undergoing significant expansion over the next 2 years, which will allow it to accept additional material for composting. Once the expansion is complete, low quality mixed paper recovered from Palo Alto’s solid waste and recyclables streams could be directed to the facility for composting, creating more opportunities for increased diversion and local outlets for these material types.
Advanced Processing Technologies
ByFusion
In January 2022, GWPA presented the City with an opportunity to pilot a new plastics recycling technology through ByFusion. ByFusion has developed a steam-based technology that can recycle discarded plastic into 22-pound blocks that can be used as a building material for sheds, retaining walls, benches, furniture, micro homes, and more. ByFusion can take multiple types of post -consumer, low-grade plastics such as grocery bags, contaminated food containers, and miscellaneous mixed plastics #1-#7. Because the plastic is super -heated using steam, these plastics can be processed mixed, clean , or contaminated. This technology could offer another avenue for recycling otherwise low-grade, contaminated plastics recovered from Palo Alto’s solid waste stream at the GWR MRF.
In May 2022, Tucson, AZ, approved a 4-year contract with ByFusion to construct a production facility and install a ByFusion machine. Tucson plans to use the block -making machine on a small -scale basis to create building materials for park benches, waste enclosures, murals, and small buildings.
While the ByFusion technology is promising, Palo Alto is not currently considering the use for the plastic blocks at scale. However, GWR remains committed to exploring this emerging technology and research on long term feasibility study and environmental impacts if requested.
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California Recycling Legislation
The California Legislature passed several recycling -related bills in 2021 and 2022 that target plastic pollution and aim to spur domestic or in -state recycling while also modernizing the state’s recycling infrastructure. These bills are designed to assist and guide generat ors, waste haulers, municipalities, processors, and recyclers on various aspects of California’s recycling system. As a waste hauler and waste processor, GWPA and GW R are looking forward to seeing how these laws progress and improve California’s recycling system.
The following is a summary of the most notable bills.
• SB 54: Requires all packaging in California to be recyclable or compostable by 2032 and shifts the burden of collecting, processing, and recycling from consumers and municipalities to manufacturers who produce and sell plastic packaging and products. https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201720180SB54) • AB 881: Reclassifies low value plastic waste exports to other countries as “disposal” instead of “recycling”. The law is designed to help the state and CalRecycle more accurately measure how much plastic is getting recycled.
(https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202120220AB881) • SB 343: Prohibits plastic manufacturers from using the “chasing arrows” recycling symbol on items that aren’t recyclable. Creates a CalRecycle -approved list of items that are commonly recyclable in California.
(https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202120220SB343) • AB 1276: Reduces plastic waste by prohibiting restaurants from offering single-use food ware to customers unless requested.
(https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202120220AB1276) • AB 793: In 2023, CalRecycle began enforcement of this law, which mandates recycled content in plastic beverage bottles. As of January 1st, beverage manufacturers will now face penalties and fines if they do not have at least 15% recycled content in plastic bottles. This mandate increases to 25% recycled content in 2025 and 50% in 2030, with the overall goal to increase the available markets and outlets for post-consumer recycled plastics.
California Statewide Commission on Recycling Markets and Curbside Recycling In 2019, the California Legislature and Governor created the Statewide Commission on Recycling Markets and Curbside Recycling to provide guidance and recommendations to CalRecycle regarding California’s ambitious recycling goals. The purpose is to provide insight into the complex recycling industry as well as an industry perspective when CalRecycle and the State Legislature are crafting policies and legislation.
Many of the recommendations are designed to reconfigure recycling market development efforts to improve effectiveness and take steps to ensure that materials separated for recovery will not be processed in a manner that contradicts the environmental and social intent of recovery efforts. The report specifies that some of the work “involves reconciling the conflicts between ambitious recovery goals and the realities of markets and permitting processes.”.
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The report identifies the following priorities for statewide recycling market development:
• “Approximately 10,000,000 tons of paper fibers are exported annually from California ports, with about 80% generated in California. Recycled paper pulping is an emerging industry trend, avoiding bale contamination issues by creating market grade pulp for paper making. A successful market development effort focused on paper pulping would overcome reliance on bale exports, create local jobs and business opportunities, and strengthen California’s recycling infrastructure. This effort could include siting assistance, local and state permitting coordination, feedstock identification and acquisition, financing options.
• Existing tax incentive programs such as CAEFTA could be focused on prioritizing end use markets for recovered materials.
• California’s economy offers potential to expand existing business use of recycled materials by working to identify manufacturers who could substitute virgin materials for recycled feedstock.
Business development tools can mine databases to identify those manufacturers, and market development professionals could work with those manufacturers to convert to recycled feedstock.
• Myriad opportunities exist to work with existing small reuse and repair businesses. Statewide source reduction can be enhanced by identifying and responding to their needs, especially expansion and business start-up potential to replace single-use items.” (https://www2.calrecycle.ca.gov/Docs/Web/121911)
As this report demonstrates, there is work being done by CalRecycle and other state agencies to stimulate market demand for post-consumer recyclables and spur the development of statewide recycling infrastructure within California.
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Summary
GWR and GWPA staff worked in coordination to obtain supplementary marketing, processing, and disposal information from GWR’s primary purchasers. The following tables summarize materials sorted by commodity types, the spread of domestic vs. export markets, and the location of secondary processing (if applicable) as reported by GWR’s primary purchasers. The information contained in Table 1 summarizes the facility -wide materials and markets for the MRF as a whole. Palo Alto’s portion is estimated and summarized in Table 2. Table 3 summarizes the primary purchasers of Palo Alto’s recyclable materials.
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Table 1: GreenWaste Recovery MRF Tonnage Summary - Facility Wide
Product
Specifications
FY 2023 Actual
Tonnage
Material Type
Breakdown
Domestic Export
Aluminum Cans 1,694.99 1.26% 100% 0%
Aluminum Foil/Scrap 367.02 0.27% 100% 0%
Ferrous/Tin 3,379.58 2.52% 100% 0%
Glass, Commingled 30,486.93 22.73% 100% 0%
Plastic, HDPE Color 1,811.41 1.35% 87% 13%
Plastic, HDPE Natural 1,453.16 1.08% 87% 13%
Plastic, PET Bottles 4,695.26 3.50% 97% 3%
Plastic, PET
Clamshells 1,084.04 0.81% 0% 100%
Plastic, Mixed Rigid 2,212.75 1.65% 46% 54%
Plastic, #2 - #7 2,369.63 1.77% 46% 54%
Film Plastics 261.10 0.19% 100% 0%
Mixed Paper 15,926.14 11.87% 20% 80%
Cardboard 59,902.93 44.66% 7% 93%
Scrap Metal 8,376.48 6.25% 100% 0%
E-Waste 106.70 0.08% 100% 0%
Total 134,128.12 100% 45.89%1 54.11%1
1 Weighted Average
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Palo Alto Only Tonnage Estimate Summaries
Determining Palo Alto’s tonnage for each recyclable material category presents a challenge because once Palo Alto’s recyclables are delivered to the MRF, they are combined with recyclables from other communities. In previous reports, Table 2 has been used to estimate Palo Alto’s share of the total recyclable material processed by the MRF. In Fiscal Year 2023, Palo Alto’s recyclables made up 11.74% of the MRF’s total material, or 15,976 tons . This percentage was used in Table 2 to estimate Palo Alto’s tonnage for each material type, based on the facility-wide data from the MRF.
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Table 2: Palo Alto’s Estimated Tonnage as a Percentage of MRF’s Total Product Specifications Palo Alto Tonnage
(est. 11.74% of MRF) Domestic Export
Aluminum Cans 198.99 100% 0%
Aluminum Foil/Scrap 43.09 100% 0%
Ferrous/Tin 396.76 100% 0%
Glass, Commingled 3,579.17 100% 0%
Plastic HDPE Color 212.66 100% 0%
Plastic, HDPE Natural 170.60 100% 0%
Plastic, PET Bottles 551.22 100% 0%
Plastic, PET Clamshells 127.27 0% 100%
Plastic, Mixed Rigid 259.78 100% 0%
Plastic, #2 - # 7 278.19 100% 0%
Film Plastic 30.65 100% 0%
Mixed Paper 1,869.73 100% 0%
Cardboard 7,032.61 30% 70%
Scrap Metal 983.40 100% 0%
E-Waste 12.53 100% 0%
Total 15,746.64 67.93%1 32.07%1
1 Weighted Average
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Table 3: Primary Purchaser Summary – Palo Alto’s Plastics & Fiber
Product Specifications: Primary Purchasers
(for material types covered in this report)
Plastic, HDPE Envision Plastics: Domestic
Plastic, PET Bottles
CellMark: Domestic
Berg Mill: Domestic
Plastic, PET Clamshells Direct Pack: International
Plastic, Mixed Rigid CellMark: Domestic
Plastic, #2 - #7 CellMark: Domestic
Film Plastic CellMark: Domestic
Mixed Paper CellMark: Domestic
Cardboard
CellMark: Domestic
Berg Mill: International & Domestic
Fibre Trade: International & Domestic
Newport CH International: International & Domestic
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CellMark Inc. (Novato, CA)
In Fiscal Year 2023, CellMark became the primary purchaser of Palo Alto’s cardboard, paper, and plastics because it predominantly utilizes domestic markets for these material types. CellMark submitted partial traceability data for the cardboard, mixed paper, PET, mixed plastic s, and film plastics it purchased from GWR.
CellMark is both a brokerage and a secondary processor, and its purchasers are secondary processors.
For plastic, the secondary processing includes chipping, washing, and pelletizing. For cardboard and paper, the secondary processing includes pulpifying.
Per the CellMark website, CellMark participates in initiatives to ensure sustainability. CellMark comments on its sustainability via its CSR webpages (https://www.cellmark.com/ideas-values/sustainability-csr/):
“CellMark is proud to conduct our services and business activities with a high degree of ethics and awareness of sustainability. We adhere to defined common standards for our performance, participate in multiple initiatives in support of sustainability and continually look for ways to improve our performance.” “We respect and comply with local legislation and environmental regulations in all of our global operations.
We enable our employees to participate in charitable initiatives, and we invite our business partners to join us in our support of different non-profit organizations locally and globally.” “CellMark supports and works actively to comply with international guidelines regarding environment, human rights, and business ethics, including the following:
• The UN Global Compact Initiative.
• Internationally proclaimed human rights standards and conventions (in particular the International Bill of Human Rights, the United Nations Guiding Principles on Business and Human Rights, the eight core conventions of the International Labour Organization , and Article 32 of the United Nations Convention on the Rights of the Child).
• The OECD Convention on combating bribery of Foreign Public Officials in International Business Transactions.
• The OECD Guidelines for Multinational Enterprises.”
“We do not ship any restricted material, for example dual -use goods, without proper permit… Each employee is encouraged to share the Code of Conduct with our business partners. We expect them to acknowledge and respect it in the context of their own particular culture.”
(https://www.cellmark.com/wp-content/uploads/2015/11/CellMark-Code-of-Conduct.pdf) CellMark’s 2022 Annual Sustainability Report, published in May 2023, stated the company maintained its Silver status in the EcoVadis supply chain audit. The audit investigates four core areas: Labor & Human Rights, Environment, Ethics, and Sustainable Procurement (https://ecovadis.com/ratings/).
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The following is a diagram showing which U.S. cities and states the cardboard, paper, and plastics purchased by CellMark are sent to.
CellMark’s 2022 Sustainability Report provided an update on its Total Fiber Recovery facility:
CellMark: Significant events in 2022
“CellMark entered into a partnership with Total Fiber Recovery to build an 80 million USD recycled pulp production facility in the city of Chesapeake, Virginia, USA. The new facility and joint venture are both called Total Fiber Recovery @ Chesapeake (or TFRC) and should be operational in Q4, 2023. CellMark Recycling will supply 300 000 tons of mixed paper and old corrugated containers, annually, as feedstock to the facility. The recycled brown pulp produced by the facility will be sold exclusively by CellMark Pulp.” (https://www.cellmark.com/wp-content/uploads/2023/06/CellMark-Sustainability-Report-2022.pdf) An internet search resulted in a pertinent article posted on July 6, 2022:
Total Fiber Recovery starts work on Virginia facility
“Chesapeake, Virginia-based Total Fiber Recovery of Chesapeake (TFRC) says it has started construction of its $80 million recycled pulp production facility in that city.
TFRC is a joint venture between Oregon-based Total Fiber Recovery (TFR) and Swedish company CellMark Inc. Material consumed by the facility will be supplied by CellMark’s Recycled Fiber Division, and the pulp produced will be marketed by CellMark’s Pulp Division.
TFR plans to begin operations in Chesapeake in the fourth quarter of 2023 and annually process up to 300,000 tons of mixed paper and old corrugated containers (OCC).”
https://www.recyclingtoday.com/article/total-fiber-paper-recycling-investment-chesapeak-virginia-cellmark-bhs/ A June 21, 2021, press release published in Utah Business provided more insight into CellMark’s Crossroads Paper Plant:
Cardboard Shafter, CA
Mixed Paper Shreveport, LA
PET Rome, GA
Mixed Rigid
Plastic St. Louis, MO
Mixed Plastic
#2 - #7 Jurupa Valley, CA & Ironton, OH
Film Plastic Modesto, CA
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Peterson Real Assets makes growth equity investment in Crossroads Paper “Peterson Real Assets, a subsidiary of Peterson Partners, Inc. has made a growth equity investment in Crossroads Paper, a 100 percent recycled paper mill to be built in the Mountain West to serve for the growing demand for e-commerce, agriculture, and industrial packaging in the Western United States.
The Crossroads Paper site selection process is underway, with a final determination expected by year end.”
https://www.utahbusiness.com/peterson-real-assets-makes-growth-equity-investment-in-crossroads paper/#:~:text=Salt%20Lake%20City%20%E2%80%94%20Peterson%20Real,in%20the%20Western%20United%20States An internet search resulted in a pertinent article posted on May 3, 2021:
CellMark acquires Paper Tube & Core Corp.
“The Norwalk, Connecticut-based North American recycling business unit of CellMark has acquired Paper Tube & Core Corp. (PT&C). That Paterson, New Jersey -based firm specializes in collecting, repurposing and recycling large paper cores and tubes on a global scale.” https://www.recyclingtoday.com/article/cellmark-paper-tube-new-jersey-recycling-acquisition/ An internet search resulted in a pertinent article posted on July 22, 2019:
New Frontiers in paper production
“In mid-July, Crossroads Paper held a press conference to announce its plans to build a paper mill in the Salt Lake City area that will recycle old corrugated containers (OCC) and residential mixed paper into new paper that will then be used to make boxes for manufacturers, farmers and e-commerce companies.
The Sasine brothers’ partners include […]Sweden-based Cellmark, which specializes in international trade and distribution of raw materials related to the global pulp and paper industry.” https://www.recyclingtoday.com/article/crossroads-paper-recycled-containerboard-salt-lake-valley/
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Berg Mill Supply/Classic Fibres (Los Angeles, CA)
Berg Mill did not submit any traceability data but did provide basic information about the company. In Fiscal Year 2023, Berg Mill purchased a portion of Palo Alto’s cardboard from GWR.
Berg Mill Supply is a brokerage. Berg Mill elected not to complete the traceability form as to not provide proprietary data. Berg Mill provides general data on its website about the destination of its exports. Per the Berg Mill Supply website: (https://bergmill.com/about/where-berg-mill-ships/) “Our mission statement and vision is our belief in contributing to a sustainable planet, leading us on our path of environmental management for future generations. Berg Mill’s purpose is to create value by offering green solutions to those generating waste and to consumers looking to recycle.”
“Berg Mill Supply Co., Inc. redirects waste from material recovery facilities (MRF) in the United States to end users in international locations, where the material is processed and a new material is produced.”
“We sell material suitable for many different countries abroad such as China Indonesia Korea Vietnam Thailand India Myanmar Malaysia Pakistan Laos Costa Rica Brazil USA.”
The following is a diagram showing which countries the cardboard purchased by Berg Mill is sent to.
A blog posted by Berg Mill on December 2, 2019, stated the following:
“But it isn’t just China’s import restrictions that have caused a downswing in mixed paper value. The market started taking a dive after the U.S. economic downturn in 2010, nearly a decade ago. The good news is that new international markets are opening for U.S. mixed paper, for example India, where a box manufacturer that uses recovered fiber, is opening a plant in the coming months.”
(https://bergmill.com/2019/12/02/turning-over-a-new-leaf-in-paper-recycling-with-ai-technology/)
Cardboard Did not provide
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A blog posted by Berg Mill on August 12, 2019, stated the following:
“With no global regulations against these exports, it is poor and developing nations that will end up paying the price for cleaning up after the U.S.… For recycling to flourish to its full potential, we must process our recyclables in domestic, modern fact ories that are designed to properly shelter toxins from workers and the environment.”
(https://bergmill.com/2019/08/12/your-recycling-may-not-be-going-where-you-think/) A blog posted by Berg Mill on June 10, 2019, stated the following:
“While recent news in recycling has been discouraging due to China’s National Sword and other foreign imported scrap bans, Berg Mill is ever committed to keeping your recyclables moving… Ultimately, domestic recycling has the potential to become superior t o importing scrap both economically and environmentally."
(https://bergmill.com/2019/06/10/recycling-challenges-bring-opportunities-for-growth/) An internet search resulted in a pertinent article posted on June 3, 2018:
“According to leading US recycling firm Berg Mill Supply, “all grades of plastic have seen a major shift to secondary markets” from 2016 to 2017, when China’s import restrictions came to light. In that period, Malaysia took in five times more polyvinyl chloride (PVC), while Vietnam more than doubled imports of polyethylene terephthalate (PET).
”
(https://www.channelnewsasia.com/news/singapore/china-bans-plastic-waste-whats-next-for-recycling-in-singapore-10281026)
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Fibre Trade Inc. (Burlingame, CA)
Fibre Trade submitted partial traceability data for the portion of Palo Alto’s cardboard it purchased from GWR in Fiscal Year 2023.
Fibre Trade is a brokerage. Per its website, Fibre Trade is a direct exporter of primarily recovered paper, pulp, and mineral products from the USA, Europe, Australia, New Zealand, and Japan to affiliated paper mills all over the world.
(https://www.fibretrade.net/)
The following is a diagram showing which countries the cardboard purchased by Fibre Trade is sent to.
Cardboard USA, Mexico, Southeast Asia (per 2021)
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Newport CH International (Orange, CA)
Newport CH International did not submit traceability data but did provide basic information about the company. Newport purchased a portion of Palo Alto’s cardboard from GWR in Fiscal Year 2023.
Newport both manufactures products and is a brokerage. Per its website, Newport focuses on the purchase and direct export sale of recyclable paper, plastics, as well as agricultural products. The following statement is made on the Newport CH International website.
“Our expertise is sourcing recyclable paper and plastics throughout North America. We are direct export shippers for the recycling industry, supplying numerous mills in China, as well as many other Asian countries. We provide quality raw material for their state of the art mills and manufacturing facilities.
Our overseas customers have the assurance of consistent supply and quality. Newport CH handles all logistics in-house, including shipping line rate negotiations, bookings and local drayage assistance.
We take care of all required export documentation and banking transactions from our corporate office in Orange, California. To facilitate our exports to China we are AQSIQ certified and are an approved CCIC self-inspection company. In addition, we hold ISO 9001 and ISO 14001 certifications for our global quali ty management system, demonstrating our organizations continued commitment to quality. Newport CH strives to encourage growth in the recycling industry by being supportive and involved with numerous state and local government agencies.
Through our office in Shanghai, China we are able to work directly with the mill buyers in order to meet their requirements. We are in constant communication with our Shanghai office to stay apprised of any market changes or concerns with material arriving into China.” (http://newportch.com/)
The following is a diagram showing which countries the cardboard purchased by Newport CH International is sent to.
An internet search resulted in a pertinent article posted on March 25, 2021:
Malaysia declares reported shipments of US plastic wastes to Asia are illegal “Governments are beginning to react to recent warnings issued by the Basel Action Network (BAN) of likely illegal exports of plastic waste from the US.
Due to recent amendments adopted by the 188 Parties to the Basel Convention, as of January 1, 2021, parties will be unable to import US plastic wastes unless they are very pure and unmixed. In its announcement, BAN highlighted recent data showing the US exports have not diminished despite the new rules and flagged three active shipments moving to Indonesia, Malaysia, and India.
In Indonesia, the government appears to be uncertain as to what to do about the two containers of plastic waste that have already arrived at the port of Belwan on board a Mediterranean Shipping Company (MSC) vessel from California, USA. Three more from the same exporter — Newport CH International, are also on their way to Indonesia.”
(https://www.recycling-magazine.com/2021/03/25/malaysia-declares-reported-shipments-of-us-plastic-wastes-to- asia-are-illegal/)
Cardboard Did not provide
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An internet search resulted in a pertinent article posted on December 3, 2019:
Signals point to all-out recycled fiber ban in China
“We’re diversifying, we’re going to try to maximize our sales to other countries,” said Jimmy Yang, CEO of Newport Beach, Calif.-based Newport CH International, a major broker of recovered fiber to China. “We’re expecting volume to drop, that’s just reality – we enjoyed great markets for the past 20 years, and maybe things are going to change now.”
“At the meeting, officials told the companies to anticipate lower import license volumes during the fourth quarter of this year, said Yang, whose business has at times moved up to 90% of its fiber to China. He noted Chinese officials said a ban is coming in 2021 for all paper grades except newsprint, which could continue to enter the country for newspaper production.” (https://resource-recycling.com/recycling/2019/12/03/signals-point-to-all-out-recycled-fiber-ban-in-china/) An internet search resulted in a pertinent article posted on April 3, 2019:
China's recyclers look at Latin America, Caribbean
“Hamilton Wen, director of the plastics division at trading firm Newport CH International LLC in Orange, Calif., said in a panel at the conference that recyclers face complex questions as they analyze where it makes business sense to recycle and also react to governments worldwide limiting imports of scrap.”
"It's definitely cheaper in these other countries, but how long are they going to let you do it," he said. ‘I think eventually, end game, it probably will come back here [to the United States]. Whatever we're creating probably we should recycle it here’… added that the business case can make it too expensive to do some types of recycling in higher-cost countries.”
(https://www.plasticsnews.com/article/20190403/NEWS/190409967/china-s-recyclers-look-at-latin-america- caribbean)
An internet search resulted in a pertinent article posted on February 28, 2018:
Exporters talk Chinese ban’s operational and financial impacts “Newport CH International, like many exporters, has made dramatic operational changes since the ban impact started to spread. The company acts as a broker, so it tries to find markets offering the best price and stable demand. For the past 20 years, that has consistently been China, Wen said. The only variation was where inside China the company would send the material.”
“Now, that’s completely off the table as far as scrap, so we’ve had to completely reshift, and look for new markets basically anywhere in the world,” Wen said. “Places we’ve never looked for previously, but now we’re having to travel to look for processors, look for end users. It’s pretty much a complete upheaval of our entire plastic brokerage business.”
“Wen said there are not enough end users to handle all the material on the market, so they are able to demand higher quality, whereas it used to be a seller’s market. Wen predicts markets will develop for low-grade plastics, although they will take time to develop. He said there is already a little more demand coming back for the materials as a result of market development that’s taken place since the ban, and that further development is currently underway.”
(https://resource-recycling.com/plastics/2018/02/28/exporters-talk-chinese-bans-operational-financial-impacts/)
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Direct Pack Recycling (Azusa, CA)
Direct Pack Recycling is the primary purchaser of Palo Alto’s PET clamshells. PET Clamshells are thermoformed plastic packaging, typically used for food packaging. Examples include plastic salad containers, take out containers, and fruit containers.
Per its website, Direct Pack is a leader in sustainable and innovative thermoformed food packaging recycling and manufacturing.
“We operate our own recycling and reclaiming facility. With capacity to recycle 20,000 tons of PET plastic per year, it allows us to move closer to a full circle manufacturing process.” “In our full circle process, we use post-consumer recycled PET bottles and thermoformed packaging to make new food containers. At Direct Pack Recycling we sort, wash and flake recycled PET material that then goes to one of our thermoforming facilities to b e turned into new strawberry, lettuce, salad or take-out containers. After use, our containers can be recycled again – they are not garbage, but a valuable infinite resource.
“Since 2020, Direct Pack Recycling has recycled over 74.4 million pounds of plastics – not only bottles but also mixed thermoformed PET containers – and repurposed them back into new packaging.” (https://www.directpackinc.com/about-us/)
The following is a diagram showing which countries the PET clamshells purchased by Direct Pack Recycling are sent to.
A blog posted by Direct Pack on December 5, 2022, stated the following about its PET recycling efforts:
50M Lbs. Milestone of Recycled PET
“In less than three years, Direct Pack has purchased 50 million lbs. of recycled PET bales from different Material Recovery Facilities (MRFs) in the US. These bales consist of post-consumer recycled #1 PET bottles as well as thermoformed packaging, and we take the bales to Direct Pack Recycling, our own reclaiming and recycling facility. There we turn the recycled materials into “new” raw material again in a full circle process. We are very grateful for the mutually beneficial collaboration with our MRF partners in California, Arizona, Washington, Nevada and Texas. As the MRFs collect more and more thermoformed #1 PET packaging from their local communities, we can include more of that material in our manufacturing of new packaging containers. Thereby we create a true, fully circular business model, where PET is an infinite resource that is recycled and reused again and again.” (https://www.directpackinc.com/50m-lbs-milestone-of-recycled-pet/) A blog posted by Direct Pack on January 31, 2021, stated the following:
2021 Another Record Year of Recycled PET
In 2021, Direct Pack, Inc. and its BOTTLEBOX® brand had another record year in using post-consumer recycled PET material: saving 46.9 million pounds of plastic from ending up in landfills and the ocean and making its way into our products. That is equivale nt to using over 2 billion recycled beverage bottles in just one year… Since 2011 when we started measuring our rPET usage, we have used the equivalent of 9.8 billion recycled bottles, which is the same as saving 305 million pounds of CO2 from
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the atmosphere. In other terms, it means saving energy enough to power 24,114 households or taking 29,357 cars off the road for a year.
(https://www.directpackinc.com/2021-another-record-year-of-recycled-pet/) A blog posted by Direct Pack on October 26, 2020, stated the following about its manufacturing facility in Mexico:
Direct Pack Mexico Receives an Outstanding 2020 AIB Audit Performance “In its second official American Institute of Baking (AIB) Audit, Direct Pack’s manufacturing facility in Guadalajara scored an outstanding 905 points. The Guadalajara Team’s success is reflective of our outstanding team work…”
(https://www.directpackinc.com/direct-pack-mexico-receives-an-outstanding-2020-aib-audit-performance/)
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Envision Plastics (Chino, CA)
Envision Plastics is a leading recycler of HDPE plastics and supplier of Post- Consumer Resin (PCR).
Envision purchases HDPE from GWR and washes, chips, and pelletizes the material. Envision lists six different products that it creates from recovered plastic: Ecoprime®, Natural Color, Mixed Color, Oceanbound Plastic, Prisma®, and Deodorized.
The following is a diagram showing which U.S. states the HDPE purchased by Envision Plastics is sent to.
Envision Plastics is headquartered in Reidsville, North Carolina and has a West Coast plant in Chino, California. Envision’s parent company, Altium Packaging (previously Consolidated Container Company) includes “Act with Integrity and in Compliance” as one of its core values. (https://altiumpkg.com/why-altium/our-
guiding-principles/)
An internet search resulted in a pertinent article posted on June 27, 2023:
Envision adding second line for recycled HDPE, PP
Envision Plastics is leaning into demand for PCR and putting millions of dollars into adding another recycled food-grade HDPE and PP processing line at an existing facility.
The expansion at Envision’s Reidsville, N.C. plant gives the company flexibility to switch between producing its HDPE, dubbed “EcoPrime,” and post -consumer PP. The additional production line will increase Envision’s capacity to produce EcoPrime by 50%...
There is another facility in Chino, Calif., that produces EcoPrime. Envision’s current combined capacity is about 55 million pounds of EcoPrime annually. The second line in North Carolina will add another between 25 million and 30 million pounds annually...
EcoPrime is FDA -authorized, curbside collected, recycled HDPE resin that, even in 100% PCR containers, is fit for direct contact with food and beverages, a press release noted. It has earned letters of no-objection from the U.S. Food and Drug Administration and Health Canada, so it can be used in a wide range of applications including rigid bottles, caps and closures, and blown film, for industries such as dairy, water, cosmetics and nutraceuticals.
(https://resource-recycling.com/plastics/2023/06/27/envision-adding-second-line-for-recycled-hdpe-pp/) A March 6, 2023 article detailed Envision Plastic’s recent EcoVadis award:
Envision Plastics Receives EcoVadis Silver Award for Sustainability Envision Plastics, a leading producer of mechanically recycled High Density Polyethylene and Polypropylene Post-Consumer Resin (HDPE and PP PCR) products in North America, announced today that it earned a silver recognition medal from EcoVadis for its sustainability efforts. Envision’s ranking puts them within the top 20% of those participating in the assessment and indicates their ongoing commitment to sustainability, with an emphasis on environmental policies, carbon footprint, labor, and safety laws. It also shows an increase in the company’s rating from last year. (https://www.prweb.com/releases/2023/03/prweb19202224.htm) HDPE Chino, CA & Reidsville, NC
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Finally, Envison Plastics OceanBound Plastic recycling program aims to remove 10 million pounds of plastic before it enters the ocean at “At Risk Zones” defined by areas within 50km of coastline, with a focus on communities lacking formal waste collection. According to their FAQ webpage on the program, Envision Plastics works with partners “to professionalize the collection stream, collect this plastic, and manufacture it into usable products.”
(https://envisionplastics.com/oceanbound-plastic/)