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Waste industry urges investment, warns against packaging EPR and highlights battery safety
Summary
Michael Hoffman of the National Waste & Recycling Association told Tennessee senators that private capital can expand recycling and processing if markets are stable, cautioned that packaging EPR may raise costs without improving recovery, and urged action on battery disposal safety and market stability.
Michael Hoffman, president and CEO of the National Waste & Recycling Association, told the Senate Energy, Agricultural and Natural Resources Committee that the waste and recycling sector is capital‑intensive and that private investment will follow only if there is a reliable market for collected materials.
"We are exceedingly capital intensive," Hoffman said, describing trucks, recycling facilities and modern materials‑recovery infrastructure and noting that a modern single‑stream recycling facility can cost tens of millions. He told senators that, nationally, roughly half of post‑collection material goes to landfill while about 30% is recycled; he contrasted that with Tennessee data presented in the hearing, which Hoffman described as landfilling "a little over 90%" and recycling "a little over 6%."
Hoffman warned that packaging extended producer responsibility (EPR) programs can double or triple the cost of recycling administration and said his association's view — and a commissioned study he cited — is that EPR has not reliably improved recovery rates or stabilized secondary markets in the examples they studied. "EPR won't help drive that," he said in the hearing when asked whether EPR would create the market stability recyclers need.
Instead, Hoffman urged alternatives such as "content commitments" from producers to create a level playing field and stabilize secondary markets, and he said the private sector is prepared to invest billions if it can be confident of material supply.
Hoffman also highlighted other policy and safety issues. He urged action on battery disposal, saying lithium‑ion batteries present a growing fire risk in the residential waste stream and recommending public awareness campaigns and industry‑backed programs for safe battery collection. He endorsed battery‑focused EPR while cautioning against packaging EPR as a tool for expanding collection.
During questions, senators pressed about the role of composting and PFAS. Hoffman said composting works well where there is a large commercial agriculture market to absorb organics but cautioned that compost output may exceed local demand in many Tennessee settings. On PFAS, Hoffman identified wastewater treatment sludges (POTW sludge) as a significant national PFAS source and discussed sequestration challenges in long‑term waste management.
Hoffman closed by urging a consistent, transparent permitting environment and public engagement to allow private capital to modernize recycling infrastructure while policymakers balance costs and recovery goals. The committee accepted his remarks for consideration and returned to other business.
