The Issue

       Miller Brewing Company is test marketing the first plastic beer bottle in the US. Although the bottle is made primarily of the same kind of plastic used in soda bottles (#1 PET or PETE), its color and design pose problems for plastic recycling systems. The way Miller addresses these problems will either create an opportunity for growth of plastics recycling, or do damage to the environment and the struggling PET recycling industry.

       The Miller plastic beer bottle's amber tint, new barrier material, and metal cap and label make it incompatible with the existing recycled PET recycling systems. Those elements will increase costs for PET recycling and may contaminate the PET stream so as to make it impossible for recyclers who handle the Miller bottle to sell their reclaimed plastic to high value markets. Furthermore, the initial production of bottles lacks any recycled content and replaces the more recyclable glass and aluminum containers currently in use.

       Since most plastics recyclers are struggling already, this combination of increased costs and lost revenues could literally drive them out of business -- and it will be the local governments and taxpayers who will pay the price to either keep them in business or dispose of our plastics. On the other hand, Miller has an opportunity to take responsibility for its new package and help re-energize the plastics recycling industry.

Background

       In November, 1998, the Miller Brewing Company began to test market its Miller Genuine Draft, Miller Lite and Icehouse brands in 20 ounce and 1 liter plastic bottles. The tests are taking place in Los Angeles CA, Phoenix/Tucson AZ, Dallas/Fort Worth TX, San Antonio TX, Miami FL, and Norfolk VA. The tests are expected to last several months, after which Miller will determine whether to roll out the new bottle nationwide.

       Miller is using a new five-layer plastic bottle designed and produced by Continental PET. Three of the bottle's five layers are PET (polyethylene terephthalate), and the remaining two are made up of a new polyamide barrier. The barrier allows the bottle to achieve a four month shelf life by ensuring that little oxygen enters the bottle and little carbonation escapes. While the bottle's five layer construction is capable of incorporating 25 to 40 percent recycled PET, the bottles being produced today do not include any recycled content.

Impacts on the PET Recycling Industry

       Although Miller's test is relatively small scale, this new bottle could have significant impacts on the recycling system and the PET industry. It is the first plastic bottle to provide the shelf-life brewers are looking for at a competitive price - and the first package to challenge glass and aluminum in the beer market. If it is successful, and most expect it will be, many brewers are expected to follow suit, first targeting sales at stadiums, beaches and other places where glass and aluminum are restricted, and later for broader use in non-premium brands.

       The implications of this new introduction could be staggering, since there are 2½ times as many beer containers that could be shifted to plastic from glass and aluminum than there are plastic soft drink bottles currently in use. By weight, the potential plastic beer bottle market would be 25 percent more than the entire stream of PET bottles (soft drink and custom) currently collected by recycling programs. Given the scale of this potential market, if the bottle is not practically and realistically recyclable, even partial displacement of glass and aluminum beer containers is of very deep concern.

       What's worse is that this bottle is being introduced to a PET recycling infrastructure that has already become dangerously unstable. While aluminum and glass have a proven track record of recyclability and use of recycled content, plastics recycling continues to struggle. For example, the percentage of the PET soft drink bottles produced that are collected for recycling (known as the recycling rate) has dropped dramatically for three years in a row, from 50 percent in 1994 to only 36 percent in 1997. That rate is even lower in states without a container-deposit return system ("bottle bill"). No other recyclable material has ever dropped by more than 5 percent, and none has ever dropped for two years in a row. In late 1996 and early 1997, the market price for reclaimed PET reached historic lows. And, squeezed by high costs and low margins, major players in the PET recycling industry are bowing out.

       A key reason for the decline in plastics recycling rates is the fact that plastics production is far outpacing the use of recycled plastic. In 1997 alone, PET production increased 138,000 tons -- over 15 times the tonnage increase in PET recycling. Only 16 percent of recycled PET is turned back into new containers. Without manufacturers utilizing recycled PET in their bottles, recyclers are forced to look for other markets to utilize this material.

Recycling Problems with Miller's Bottle

       While this innovative bottle design opens a new and large market to PET, it is incompatible with current PET recycling systems and creates significant challenges for recyclers.

Color: The most significant concern for recyclers is that two brands, Miller Lite and Icehouse, are being tested in amber tinted plastic (Miller Genuine Draft is in a clear plastic bottle). There is almost no amber PET in today's recycling stream, so our systems are not designed to sort amber from clear or green PET. Amber bottles are serious contaminants in clear PET streams. And, early indications are that the chemical composition of the amber dye does not allow for its combination with green PET for markets open to that color, like strapping. In early 1999, two PET processors (Envipco and Wellman) are expected to conduct recyclability testing. Recyclers Ask: Will Miller ensure that their amber bottle is compatible with clear and/or green PET streams?

Recycled Content: The Miller bottle was designed to incorporate 25 to 40 percent recycled content. While Miller and Continental have both indicated informally that they plan to add recycled content, none is being used in the test markets. Neither Continental PET nor Miller have formally committed to use recycled content when the bottle is rolled out nationally. Recyclers Ask: Will Miller commit to use recycled content in any continued marketing of this plastic bottle?

Barrier: The barrier Miller is using is a new material which has not been tested thoroughly to determine whether it is compatible with PET in our recycling and processing systems and/or what impact it will have on the quality and marketability of the PET stream. Sources at Continental PET state that the two polyamide barrier layers comprise less than five percent of the bottle's weight and that preliminary tests indicate that 30 to 40 percent of the barrier material will be aspirated or float off during normal processing. Continental PET officials expect that the remaining barrier materials will be absorbed without contaminating the PET for future use. The tests being done at Wellman and Envipco will confirm or deny these expectations. Recyclers Ask: Will Miller ensure that the barrier's composition doesn't reduce the quality of the PET so as to preclude better paying high-end markets?

Caps and Labels: In order to ease market acceptance of the new plastic beer bottle, Miller is using an aluminum cap and metalized labels, similar to those used on its glass bottles. Both of those package elements are difficult, if not impossible, to completely remove in today's plastic recycling systems. As a result, the caps and labels could cripple plastics processing systems. Officials at Miller indicate that they are researching a plastic cap that provides the necessary barrier properties to keep its beer fresh, but have made no commitment to eliminate the aluminum caps once the plastic cap's performance issues are addressed. Sources at Miller indicate the company has no plans to eliminate or adapt the metalized labels. Recyclers Ask: Will Miller modify or eliminate the metal cap and metalized label to eliminate additional processing costs for recyclers?

Marketability: Continental PET and Miller have both indicated informally that Continental PET will provide a market for the Miller amber PET bottles and use them to produce new Miller PET bottles. Continental has not indicated what it will pay for the amber PET nor has it or Miller committed that the price paid will cover the additional sorting and processing costs the bottle will impose on recyclers. This commitment has not been made formally. But, even if it were, local governments and recyclers can't be expected to collect and market Miller bottles separately for recycling. Recyclers Ask: Will Miller ensure that their plastic beer bottle is marketable with the current recycled PET streams?

Coding for Recycling: When it introduced the bottle, Miller asserted that the bottles... "will be marked with a '#1-PETE' recycling designation, meaning consumers will be able to recycle it," despite the fact that serious testing for compatibility with today's PET recycling stream has not yet been completed. Several state plastic container coding laws, including California (one of the test market states) define multi-layer bottles like the new Miller beer bottle as "#7, Other," or require that any multi-layer bottle with a #1, PETE designation be compatible with the PET stream. Until it can be demonstrated that the Miller bottle is compatible with the current recycled PET stream, the bottle should not be labeled with the #1-PETE. Recyclers Ask: Will Miller remove the #1-PETE designation until tests have been completed and the bottle is proven to be 100 percent compatible with the recycled PET stream?

The need for producer responsibility

       What is alarming is not the challenges the bottle creates, but Miller's lack of attention to or acknowledgment of those challenges. Miller's decisions, by its own admission, have been driven primarily by marketing, with insufficient regard given to the impacts of the bottle on the recycling stream. The bottles are now finding their way into recycling programs in the test markets and those programs do not have the capacity to sort, market, or otherwise process the containers. So, the bottles are either contaminating the PET stream, or being thrown away. And, Miller has made no commitment to aid in the development of mechanisms to adapt our recycling systems to accommodate their new bottle once it goes national.

       The GrassRoots Recycling Network is urging that Miller make the following commitments before rolling out the new plastic bottle nationwide:

1. Ensure that the Miller bottle is compatible with current PET recycling.

2. Ensure that the bottle will not increase costs for local governments and recyclers.

3. Remove the #1 PETE SPI Code designation (and use #7 Other) until the bottle has been demonstrated to be compatible with the PET recycling.

4. Use at least 25 percent recycled content in all bottles.

      The choice is clear. Miller can shirk its responsibility, saddle taxpayers and local governments with additional costs and disposal burdens, and drive a nail in the coffin of the PET recycling industry. Or, it can take responsibility for its innovation, ensure that its bottle is compatible with the current PET recycling system and doesn't add any costs to recycling programs.

What you can do

       Recycling advocates, public officials and consumers in the six test market areas and around the country should let Miller know that it must take responsibility for its new bottle. Miller must ensure that if and when the bottle is rolled out nationally, it will be made compatible with the current recycled PET streams and will not increase the costs for local governments and recyclers.

       You can help send a message to the Miller Brewing Company that it can not disregard the impacts its new package has on our recycling programs by taking the following actions:

1. Write a letter to Miller Brewing Company: Let Miller know that it should not roll out the new package, and that you will not buy it, until the company takes responsibility for its impacts on the waste stream. Address your concerns to:
      John N. MacDonough       Phone: (414) 931-2000
      Chief Executive Officer       Fax: (414) 931-3735
      Miller Brewing Company
      3939 W. Highland Blvd.
      Milwaukee, WI 53201-0482

Send copies of your letter to:

• Dan Barthold, Director of Environmental & Energy Engineering, Miller Brewing Co. (same address).
• GrassRoots Recycling Network, P.O. Box 49283, Athens, GA 30604.
• Plastics News, 814 National Press Blvd, Washington, DC 20046.
• Beverage World, 226 26th Street, 10th Floor, New York, NY 10001.
• Your local newspaper.

2. Work to pass a resolution: You can pass an organizational, local government or state-wide resolution calling on Miller to commit that its new bottle will (1) be compatible with the current recycled PET stream, (2) include recycled content, and (3) not impose additional costs on local governments, taxpayers, or PET recyclers. A model resolution is available from GRRN.

3. Educate the Public: Inform consumers that they should not buy or use the Miller plastic bottle until the company takes responsibility for its introduction.

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