City Council
Staff Report
From: City Manager
Report Type: INFORMATION REPORTS
Lead Department: Public Works
Meeting Date: November 3, 2025
Report #: 2505-4678
TITLE
Informational Report on the 2023 and 2024 GreenWaste of Palo Alto Certificate of End Use and Traceability Reports; CEQA Status – Not a Project
RECOMMENDATION
This is an Informational Report and action by Council is not required.
BACKGROUND
GreenWaste of Palo Alto (GWPA) is the City’s contracted refuse hauler for the collection of recyclable, compostable, and landfill materials. Palo Alto’s recyclables are processed at the GreenWaste Materials Recovery Facility (GreenWaste MRF) in San Jose, where they are combined with recyclables from other communities, sorted by type, baled, and marketed. As part of its contract, GWPA is required to submit a Certificate of End Use and Traceability Report detailing the final disposition of materials and their environmental and social impacts associated with the further offsite marketing and processing of Palo Alto’s recyclables. GWPA has previously submitted the Initial Review of Certificate of End Use & Traceability Data for Fiscal Years 20191, 20202, 20213, 20224, and 2023 (Attachment A).
On May 24, 20215 City Council adopted five directives focused on enhancing transparency and oversight regarding international shipments of Palo Alto’s recyclable materials. Staff addressed all five directives. In 2022, the Cities of Palo Alto and San Jose co-hosted virtual forums with 1 Fiscal Year 2019 Initial Review of Certificate of End Use & Traceability Data, 2019 - https://www.cityofpaloalto.org/files/assets/public/zero-waste/fy-2019-traceability-report_gwpa.pdf%20 2 Fiscal Year 2020 Initial Review of Certificate of End Use & Traceability Data, 2020 - https://www.cityofpaloalto.org/files/assets/public/zero-waste/fy-2020-traceability-report_gwpa.pdf 3 City Council, January 24, 2022; Agenda item #14; CMR #13535; https://portal.laserfiche.com/Portal/DocView.aspx?id=59321&repo=r-704298fc 4 City Council, December 19, 2022; Agenda item #22; CMR #14835; https://portal.laserfiche.com/Portal/DocView.aspx?id=59046&repo=r-704298fc 5 City Council, May 24, 2021; Agenda item #7; CMR #11632 https://portal.laserfiche.com/Portal/DocView.aspx?id=195989&repo=r-704298fc
other jurisdictions, industry stakeholders, and recycling processors to explore interest in legislative advocacy to improve traceability in global recycling markets. However, insufficient regional support was identified for such legislative efforts. Despite increased requirements, GWPA reported challenges in providing detailed data on international shipments due to vendor confidentiality restrictions. To further assess global recycling logistics, the City contracted Edgar & Associates, Inc. (EAI) in August 2022, to research and summarized the current recycling market structures and logistics to enhance oversight and transparency in the marketing, handling, and processing of recyclable materials collected from the City’s collections. EAI's findings concluded that recyclable materials can be tracked to the port of entry in a foreign country, but not to specific processing facilities. EAI found limited documentation on the handling and recycling of materials once they leave U.S. ports. EAI confirmed GWPA’s findings, concluding that there is currently no way to track recyclable materials beyond their initial sale, making the secondary markets untraceable. These findings reinforced the City’s current policy focus on expanding domestic recycling options and pursue long-term domestic recycling for cardboard and PET thermoformed plastics. On December 12, 202211, Council approved a long- term contract amendment requiring GWPA to process Palo Alto’s recyclable materials, specifically mixed paper and mixed rigid plastics, through domestic markets. As a result, approximately 60 percent of Palo Alto’s recyclable materials are now handled domestically, significantly reducing the reliance on international markets to only 40 percent. Staff has addressed Council’s 2021 directives, including efforts to enhance transparency and oversight of recyclable materials. As part of these ongoing efforts, this informational report makes the latest GWPA traceability reports available to both Council and the public.
ANALYSIS
GWPA’s reports, titled “Initial Review of Certificate of End Use & Traceability Data” for Fiscal Year 2023 (Attachment A) and 2024 (Attachment B), summarize the traceability data and online review of information relative to recycling international markets. The reports include the supplementary marketing, processing, and disposal information from GreenWaste’s primary purchasers and summarize the recyclable materials tonnages by commodity types, the spread of domestic compared to the export markets, and the location of secondary processing. In Fiscal Year 2023:
Approximately 15,700 tons of recyclable materials was processed from Palo Alto. Of this total approximately 68 percent remained in the United States while approximately 32 percent was exported internationally. The report highlights the extended program for domestic processing of mixed paper and mixed rigid plastics and GreenWaste’s pursuit of advanced processing technologies at their facilities. In Fiscal Year 2024:
11 City Council, December 12, 2022; Agenda item #4; CMR #14834 https://portal.laserfiche.com/Portal/DocView.aspx?id=59016&repo=r-704298fc Approximately 15,600 tons of recyclable materials was processed from Palo Alto with approximately 58 percent remaining in the United States and 42 percent exported internationally. The report highlights the continuous effort to process recyclable domestically primarily mixed paper and mixed rigid plastics. The decrease in overall domestic recycling was due to the limited and volatile domestic market for cardboard.
GreenWaste is working on securing a more permanent market.
These trends reflect progress toward Council's directives and demonstrate the City’s commitment to promoting responsible and transparent recycling practices
FISCAL/RESOURCE IMPACT
There is no direct fiscal impact associated with this informational report.
STAKEHOLDER ENGAGEMENT
This report provides a routine update for City Council and the public. No additional stakeholder engagement was required
ENVIRONMENTAL REVIEW
This item is informational in nature and does not constitute a project under the California Environmental Quality Act (CEQA).
ATTACHMENTS
Attachment A: GWPA Traceability Report – 2023
Attachment B: GWPA Traceability Report – 2024
APPROVED BY:
Brad Eggleston, Director Public Works/City Engineer