Alex Truelove

Re: AB 1789, OPPOSE The Biodegradable Products Institute (BPI) is North America's leading authority on compostable products and packaging, certifying over 50,000 products from collection bags to food containers. For more than two decades, BPI???has?given?composters and?consumers?confidence in?compostability?claims?with the backing of science-based standards,?while enabling authentically sustainable choices for brands and packagers. BPI champions a systems-wide transition to the circular bioeconomy through rigorous testing, policy advocacy, and industry collaboration, building the infrastructure for "A World Without Organic Waste"—where food scraps and certified compostable packaging become resources. BPI is a?non-profit?501(c)(6). To learn more, visit www.bpiworld.org and follow us on LinkedIn.? We’ve enjoyed the opportunity to interact with Representative Parshall previously and appreciate New Hampshire’s effort to reduce harmful waste, including through EPR legislation, however we strongly oppose this iteration. Unlike other statewide EPR laws across the country, this bill fails to recognize the benefits of composting and compostable products, despite their paying fees into the proposed program. As a result, organics waste management will suffer as money paid by compostable products will be diverted towards non-compost activities, dissuading their use and increasing contamination in compost streams, hurting local businesses. Without programmatic support, compostable products and the organic waste they carry may continue to reach landfills where they can create methane emissions instead of creating a valuable soil amendment in compost. We primarily oppose the following elements: Failure to define “composting” or “compostable.” Though composting is mentioned once, and compostable products are covered, nowhere are these terms defined, including standards for disintegration, independent third-party certification, or product eligibility. Failure to include a member of the compost industry on any advisory body. EPR bills in Colorado and California have included at least one member of the compost industry in an advisory board or council to provide valuable industry input (read: composter, not compostable product-maker) Failure to recognize certified compostable products as a specific packaging category. While categories are specified for ‘paper’ and ‘cardboard’ and various plastic resin types, “Other plastic resin types not specifically identified here” utterly fails to recognize the unique benefits of compostability (food waste diversion, degradability in compost). Failure to specify funding opportunities for compost infrastructure. While the bill distributes funds to reimburse “costs associated with the implementation of reduction and refill and reuse programs, collection, transportation, and recycling of packaging materials,” it fails again to support compostable products within the program and the compost programs they support. We remain happy to work with the legislature to develop language that aligns with existing laws throughout the country and recognizes the benefits provided by certified compostable products alongside reusable and readily recyclable ones. Sincerely, Alexander Truelove Senior Policy Manager, BPI alexander@bpi-world.org