Don’t Get Trashed — Is Recycling Discarded Mail Profitable? — Part II

In our previous post of “Marketing Sustainably,” we introduced an expert discussion on whether or not recycling collection of discarded mail, catalogs, printed communications and paper packaging is profitable, and why this matters is an important business consideration for the direct marketing field. In this post, we continue and conclude the discussion with our two experts, Monica Garvey, director of sustainability, Verso Paper, and Meta Brophy, director of procurement operations, Consumer Reports.

In our previous post of “Marketing Sustainably,we introduced an expert discussion on whether or not recycling collection of discarded mail, catalogs, printed communications and paper packaging is profitable, and why this matters is an important business consideration for the direct marketing field.

In this post, we continue and conclude the discussion with our two experts, Monica Garvey, director of sustainability, Verso Paper, and Meta Brophy, director of procurement operations, Consumer Reports. The conversation is based on a Town Square presentation that took place at the Direct Marketing Association’s recent DMA2012 annual conference.

Chet Dalzell: If much of the recovered fiber goes overseas, what’s the benefit to my company or organization in supporting recycling in North America?

Monica Garvey: The benefit—companies can promote that they support the use of recycled paper because they believe that recovered fiber is a valuable resource that can supplement virgin fiber. Recycling extends the life of a valuable natural resource, and contributes to a company’s socially responsible positioning. While it’s true that the less fiber supply there is locally, the higher the cost for the products made from that recovered fiber domestically, it’s still important to encourage recycling collection. Because recovered fiber is a global commodity, it is subject to demand-and-supply price fluctuations. If demand should drop overseas, and prices moderate, there may be greater supply at more moderate prices here at home, helping North American manufacturers; however, this is very unlikely. RISI, the leading information provider for the global forest products industry, projects that over the next five years, world recovered paper demand will continue to grow aggressively from fiber-poor regions such as China and India. Demand will run up against limited supply of recovered paper in the U.S. and other parts of the developed world and create a growing shortage of recovered paper worldwide.

CD: Is there a way to guarantee that recovered fiber stays at home (in the United States, for example)?

Meta Brophy: Yes! Special partnerships and programs exist that collect paper at local facilities and use the fiber domestically, allocating the recovered paper for specific use. ReMag, for example, is a private firm that places kiosks at local collection points—retailers, supermarket chains—where consumers can drop their catalogs, magazines and other papers and receive discounts, coupons and retailer promotions in exchange. These collections ensure a quality supply of recovered fiber for specific manufacturing uses. It’s a win-win for all stakeholders involved.

I recommend mailers use the DMA “Recycle Please” logo and participate in programs such as ReMag to encourage more consumers to recycle, and to increase the convenience and ease of recycling.

CD: What’s the harm of landfilling discarded paper—there’s plenty of landfill space out there, right?

MG: Landfill costs vary significantly around the country—depending on hauling distances, and the costs involved in operating landfills. In addition, there are also environmental costs. By diverting usable fiber from landfills, we not only extend the useful life of a valuable raw material, but also reduce greenhouse gas emissions (methane) that result when landfilled paper products degrade over time. There are also greenhouse gases that are released from hauling post-consumer waste. While carbon emissions may not yet be assessed, taxed or regulated in the United States, many national and global brands already participate in strategies to calculate and reduce their carbon emissions, and their corporate owners may participate in carbon trading regimes.

CD: You’ve brought up regulation, Monica. I’ve heard of “Extended Producer Responsibility” (EPR) legislation. Does EPR extend to direct marketers in any way?

MG: EPR refers to policy intended to shift responsibility for the end-of-life of products and/or packaging from the municipality to the manufacturer/brand owner. It can be expressed at a state level via specific product legislation, framework legislation, governor’s directive, or a solid waste management plan. EPR has begun to appear in proposals at the state level in the United States. EPR, for better or worse, recognizes that there are costs associated with waste management on all levels—not just landfilling, but waste-to-energy, recycling collection and even reuse.

These waste management costs currently are paid for in our taxes, but governments are looking to divert such costs so that they are paid for by those who actually make and use scrutinized products. Thus EPR can result in increased costs, were states to enact such regulation on particular products such as paper, packaging and electronic and computer equipment. Greatest pressure to enact EPR most likely focuses on products where end-of-life disposition involves hazardous materials where recycling and return programs may make only a negligible difference. Many will state that the natural fibers in paper along with the extremely high recovery rate of 67 percent makes paper a poor choice for inclusion in any state EPR legislation. That is also why the more we support the efficiency and effectiveness of existing recycling collection programs, the less pressure there may be to enact EPR regulations directly. It will likely vary state to state where specific concerns and challenges may exist.

CD: Does the public really care if this material gets recycled? Do they participate in recycling programs?

MB: Yes, they do. Even a public that’s skeptical of “greenwashing”—environmental claims that are suspect, unsubstantiated or less than credible—participates in recycling collection in greater numbers. Both EPA and American Forest & Paper Association data tell us the amount of paper collected is now well more than half of total paper produced, and still growing—despite the recent recession and continued economic uncertainty. Recycling collection programs at the hometown level are politically popular, too—people like to take actions that they believe can make a difference. And as long as the costs of landfilling exceed the costs or possible revenue gain of recycling, it’s good for the taxpayer, too.

CD: At the end of the day, what’s in recycling for my brand, and the direct marketing business overall?

MB: I see at least three direct benefits—and nearly no downside. First, a brand’s image benefits when it embraces social responsibility as an objective. Second, being a responsible steward of natural resources, and promoting environmental performance in a way that avoids running afoul of the Federal Trade Commission’s new Green Guides environmental claims—positions a brand well in practice and public perception. And, third, and I see this firsthand in my own organization, both the employee base and the supply chain are more deeply engaged and motivated as a result, too. Certainly, in the direct marketing business overall, there are similar gains—and I’m excited that the DMA has embraced this goal for our marketing discipline.

Making a Green Claim: (Not) Waiting for the FTC Green Guides

Direct marketers and mailers making environmental claims have a number of resources available to them to help make such statements meaningful to consumers. The most important of those to U.S. marketers are the Federal Trade Commission’s Green Guides—officially titled “Guide for the Use of Environmental Marketing Claims”—which were enacted in 1992, and updated in 1996 and 1998. In 2007, the FTC initiated a new effort to update the Green Guides once again—and here we are in 2012 still waiting for this next edition.

Direct marketers and mailers making environmental claims have a number of resources available to them to help make such statements meaningful to consumers. The most important of those to U.S. marketers are the Federal Trade Commission’s Green Guides—officially titled “Guide for the Use of Environmental Marketing Claims”—which were enacted in 1992, and updated in 1996 and 1998. In 2007, the FTC initiated a new effort to update the Green Guides once again—and here we are in 2012 still waiting for this next edition.

The Green Guides, as currently written, give insight into use of such specific claims as biodegradable, compostable, recyclable, recycled content and ozone safe. While they are “guides,” they are enforceable. The FTC can and has brought forth cases where marketers’ claims did not measure up to the examples that pepper the Green Guides throughout.

In a recent Direct Marketing Association Compliance Series Webinar (February 14), DMA’s Jerry Cerasale, senior vice president of government affairs, said there is no indication that the Green Guides‘ updates—promised some time ago—will be published shortly, or what might be holding them up. If there are differences of opinions among government scientists about certain claims or terminology, or if FTC staff have unresolved policy questions related to potentially new Green Guides content, the truth is we really just don’t know. However, the current iteration of the Green Guides certainly does give us good direction, which I’ll enumerate here.

First, as with any marketing claim—green or not—each claim must be “truthful,” “clear” and “substantiated.” Many of my colleagues know that “go green—go digital” claims many banks, utilities and financial service companies print on monthly statements are a pet peeve of mine. While I have no issue with persuading customers to switch to electronic statements, for those customers who want to, I do have a big problem with couching the digital migration as an environmental choice. Chances are the brand has made no effort to document the net environmental benefits of doing so. Just supposing that an e-statement “saves trees” is not substantiated, or, if there is an attempt to do so, it is largely based on spurious associations with deforestation, something that is not happening in North America. While I’m not a lawyer, I would be very wary about making such claims statements on a brand’s envelopes because of the FTC’s substantiation expectation.

Second, when making a marketing claim—on a mail piece, on packaging, on a product—it must be clear what the claim pertains to, as in the mail piece itself, the packaging itself or the product itself. For example, making a “recyclable” claim might be seen as deceptive if the packaging is recyclable, but the product it protects is not. Thus, be very clear with labels as to what the claim applies.

Next, we need to ensure claims are not overstated. For example, growing the amount of recycled content “by 50 percent” would be seen as deceptive if the content were to nudge from 2 percent to 3 percent. Similarly, making a “biodegradable” claim is highly suspect when an item destined to today’s air-tight and water-tight landfills largely stays there inert—it’s only biodegradable when it’s a piece of litter exposed to sunlight and the elements, hardly the intended end of life. Stating some item is “eco-safe” would be seen to be deceptive if there is no proof, or if it refers to one attribute of a product or item, as opposed to the product or item overall.

The term “recycled content” is important to consider because the FTC does not count material in the manufacturing process that is normally reused, and thus never first discarded as waste. Only if the material is recovered from the waste stream and reused may it be considered “recycled.” There are “pre-consumer,” “post-industrial” and “post-consumer” forms of recycled content, but in all cases, these types of labeled recycled content must be recovered from waste. Thus, it’s common to see recycled-content papers with labels such as “made with 100-percent recovered fiber, with 20-percent post-consumer content.”

Finally, though not part of the Green Guides, the FTC in a staff opinion gave the Direct Marketing Association and direct marketers the go-ahead to enable “recyclable” and “recycle please” messages on catalogs and direct mail pieces. That distinction in 2006 was important. Prior to the opinion, that type of label was not permissible, because even though mail or catalogs technically were recyclable, less than two-thirds of the nation’s households had local access to recycling collection programs for this material. Thus, it would be seen as deceptive if local facilities were non-existent. Even the qualified “recyclable where local facilities exist” would be seen as deceptive without having the two-thirds threshold in place first. Thankfully, we’ve met that threshold and now can implement consumer education programs such as DMA’s “Recycle Please” logo initiative (launched in 2007).

While we’ve seen a draft for public comment of the next Green Guides, the final draft is—as of this date—yet to come. Therefore, it’s probably not wise to guess as to what will be in the next version, or what will be left out. (To visit the October 2010 draft, go here: http://www.ftc.gov/bcp/edu/microsites/energy/about_guides.shtml )

As a communicator, I also have at least one other “green claims” resource—an organization called TerraChoice, now part of Underwriters Laboratory, which actually consults (or has consulted) with the FTC and the Canadian Standards Association, as well as many Fortune 500 brands. Its Web site, www.sinsofgreenwashing.org, documents seven “sins” of environmental marketing claims, sins such as hidden tradeoffs and no proof. In its most recent 2010 report, only 5 percent of consumer product claims were found to be “sin free,” which truth-be-told was an improvement over 2009!

Between the current edition of the FTC Green Guides, TerraChoice, and the DMA’s own Guidelines for Ethical Business Practice, direct marketers don’t have to wait around for the FTC to (finally) issue its next Green Guides rendition to make an honest, truthful environmental marketing claim. With Earth Day around the corner, just do some diligence to be sin-free and stop saying “Go Green, Go Digital”!

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