Richard Sieg, Inmar Regulatory Counsel
As the U.S. Environmental Protection Agency (EPA) reconsiders how its hazardous waste regulations should apply to the retail sector, retailers and supply chain providers should showcase their sustainability programs. What the agency will see is that there is an interesting and important convergence among manufacturers, retailers and others in the forward and reverse supply chain and in the U.S. Environmental Protection Agency (EPA) waste program. 
For many years, the EPA has encouraged a hierarchical list of approaches for managing waste: Reduce, reuse, recycle and (only after exhausting those efforts) disposal.  That is the stuff of sustainability. 
Reduce
Among Inmar’s services is data collection on retailers’ product returns.  One of the benefits of having visibility into this kind of information is that it allows retailers to evaluate ways to reduce returns. It also allows manufacturers to evaluate packaging as a potential cause of rendering product unsaleable.  Product deemed not usable for sale to consumers most often winds up in the waste stream.
Inmar’s data collection and analysis meets the EPA’s most-preferred standards for managing waste-stream reduction. Developing ways to avoid creating waste to begin with is a good way to reduce EPA’s interest in your supply chain – waste not created is waste not regulated.
Reuse
Reuse is second only to reduce as the EPA’s preferred method of managing America’s waste problem. Another of Inmar’s reverse supply chain services that is valuable in meeting EPA standards is the liquidation of viable product to the secondary market and donation programs.  In our comments submitted to EPA, in response to the EPA’s Notice of Data Availability for Managing Hazardous Waste in the Retail Sector, we noted that it is not unusual for a majority of a client’s returns to be liquidated and donated. Without secondary market sales and liquidation programs, that’s product that only a few years ago, in many cases, would have wound up in landfills. 
Recycle
Recycling is one of the more accessible options in managing the nation’s waste problem.  Inmar’s regulatory experts work hard to find recycling solutions for products that are either not viable or not available for reuse. There is a patchwork of state regulations that must be navigated to legally recycle some materials, but this is merely a hurdle to recycling.
Inmar’s experts regularly help clients see recycling opportunities for a broad variety of product, and categories.  Recycling is better than destruction in that the product is reused in a different form, extending the life cycle of the resources initially utilized to make the product and reducing the use of first-use resources.  When destruction is necessary, Inmar’s experts help our clients safely and compliantly manage disposition according to the strict, constantly shifting patchwork of complex federal, state and local waste-management regulations. 
So, as EPA is reconsidering the regulatory requirements for managing hazardous waste in the retail sector, we must ensure that we show the agency a clear and accurate picture of the inherent benefits of reverse logistics practices already in place. Our partnership with our clients is synergistic. With Inmar’s multiple recognitions and Green Supply Chain Awards, we strive to help our clients be better stewards of the environment through effective management of products that become unsaleable.
The current rules EPA utilizes to regulate retail supply chain mainly apply to management of industrial wastes that the rules were originally written for; we hope EPA will see that those rules don’t translate well for consumer-product disposition. Any regulatory changes EPA makes should reflect recognition of existing, ongoing industry efforts to reduce risk in managing returned consumer products through responsible reverse logistics programs and the societal benefits inherent to the process.  Reduce, Reuse, Recycle – Reverse Distribution.
Questions? Comments? Contact Richard at Richard.Sieg@inmar.com

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