CARE plan disapproved, California carpet recycling uncertain

On April 18, 2017, the Director of CalRecycle announced that Carpet America Recovery Effort (CARE)’s revised carpet stewardship plan was disapproved. CARE was allowed to continue to operate under their 2016 plan for 60 days while they submit a new plan and CalRecycle staff planned for commencing enforcement actions against manufacturers. At the June 20, 2017 public meeting, CalRecycle presented its final Enforcement Plan (PDF) and next steps. By July 1, CalRecycle will notify manufacturers of the August 15 compliance deadline; manufacturers must provide a written response to CalRecycle by Aug. 15, 2017 that they intend to:

  • Remain a member of CARE and that “CARE will need to submit a complete carpet stewardship plan to the Department [CalRecycle] by Oct. 19, 2017, in order for the manufacturer to avoid penalties,” or
  • Join an “alternative carpet stewardship organization that will be submitting a carpet stewardship plan” to the Department by Oct. 19, 2017, or
  • Submit an individual carpet stewardship plan to the Department by Oct. 19, 2017.

The plan further outlines CalRecycle enforcement actions and priorities. CARE’s plan, CalRecycle’s FAQs, comments, the disapproval, and more are all available on CalRecycle's carpet stewardship plans website.

Resource Recycling covered CalRecycle’s disapproval of CARE’s plan and the history of the "long-brewing conflict... [and] rare public breakdown", while CARE shared their perspective in April and June 2017 carpet stewardship program updates.

The Global Alliance for Incinerator Alternatives (GAIA) and Changing Markets wrote two recent reports critical of CARE and carpet manufacturers. In the December 2016 report, Swept Under the Carpet: Exposing the Greenwash of the U.S. Carpet Industry, “Industry proponents point the finger at outside causes - such as low oil prices, or unfavorable market conditions” when responding to the failure of California’s program. “But in reality CARE is largely responsible with its badly designed and implemented plan that fails to take into account concerns of other actors and mostly benefits the big carpet manufacturers.”

GAIA concludes that the “real barriers in moving the U.S. carpet industry in a more sustainable direction are complacency, greenwashing, and the lobbying efforts of carpet manufacturers to maintain the status quo... [GAIA’s investigation] found that the major leaders in the industry worked in tandem to undermine the success of the California Carpet Stewardship Act (AB 2398), and successfully prevented similar producer responsibility or product stewardship schemes from passing in any other state. This kept recycling rates low and resulted in billions of pounds of carpets ending up in landfills and being incinerated across the country.”

GAIA’s April 2017 report, The CAREless Carpet Industry: A Critique of the California Carpet Stewardship Program’s Reliance on Incineration, concludes that “CARE has implemented a program that fails to (1) properly incentivize recycling and the use of recycled content, (2) provide adequate subsidies for collection and recycling, and (3) implement the necessary industry and consumer education to support a serious carpet recycling program in California.”