EPA Comprehensive Procurement Guidelines (CPG) for Pallets

​With Earth Day right around the corner, let's take a closer look at how pallets made from post-consumer material fit into the EPA's guidelines for making environmentally-conscious purchasing decisions. And, how things aren't always as they first appear.

If you're old enough to remember the 80s, you may recall that's when recycling became the next big thing. Here we are almost 40 years later, and although recycling continues to be an important part of the environmentally preferable hierarchy, we have learned a lot about what recycling can and cannot do.

The first Earth Day took place on April 22, 1970 in the US and is now celebrated every April 22 worldwide.

EPA Waste Management History

First a little history about the EPA's venture into waste management. This country's primary law governing waste management was passed by congress in 1976. Since amended and enhanced many times, The Resource Conservation and Recovery Act remains the foundation that underpins all regulations that govern how we handle waste. This act started a wave of mandates, fundamentally forcing businesses and individuals to recycle certain materials. All this, without a clear science-based idea of how a lot of those recycled materials were to be re-used.

In order to help this situation, the EPA created the Comprehensive Procurement Guidelines (CPG) program in 1995. This further mandated that government agencies and anyone doing business with the government agencies (above a certain dollar level) follow a specific recycled content guideline when purchasing a host of products that could be made with recycled content. The list is, indeed, comprehensive.

As this is a blog post about pallets, we will stick to the unit load platform (added to the program in 1997). Here is a chart showing the EPA's current suggested levels of recycled content for pallets:

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Recommended Recovered Materials Content Levels for Pallets Containing Recovered Wood, Plastic or Paperboard

Source: EPA CPG

Unexpected Results

Pretty clear-cut, right? Well, not so much. As the act evolved, the idea of doing actual lifecycle studies showed that many products, including pallets, were more environmentally preferable when made from post-industrial recycled or virgin materials. Yikes, Batman! Monkey wrench in the works!

​Subsequently, the EPA came up with this statement:

EPA's recommendation does not preclude a procuring agency from purchasing pallets manufactured from another material. It simply requires that a procuring agency, when purchasing pallets made from wood, plastic, or paperboard, purchase these items made with recovered materials when these items meet applicable specifications and performance requirements.

Not exactly a back-peddle, but with lifecycle studies showing that recycled content is not a slam dunk to environmental preferability, the DEP gave the market an out.
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A Case for Virgin Material Pallets

A large Bay Area publisher already had some environmental accomplishments, including pioneering the use of recycled content newspaper. Waste reduction consultants got involved to determine how the publisher might further improve its environmental performance. The experts assessed the publisher’s operations and determined that they had an ideal distribution system for reusable plastic pallets. After extensive testing that included lifecycle data, the publisher won a $75,000.00 grant to purchase virgin material plastic pallets as the most environmentally preferable choice.
Source: StopWaste.org

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Environmentally Responsible Choices

When the time comes to decide on what pallet is right for your application, consider all the resources available to you. Making the environmentally responsible choice might be more complicated than just following guidelines like those found in the EPA's CPG program. Talk to a pallet professional or post your questions here.

Get ALL the facts. Oh, and by the way, studies show that the environmentally preferable choice is often the most economical.

Post by: Hartson Poland, Business Development - Plastic