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There’s More to Sustainable Packaging than Meets the Eye

By Balaji Jayaseelan
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People today are more eco-conscious than ever. The last several years have seen a growing awareness of the impact of human behavior on the environment, and COVID-19 brought real-life context to the catastrophic effects of a global crisis. Lifestyle changes during the pandemic empowered people to make choices with a positive impact for the collective good. In a June 2021 PricewaterhouseCoopers survey , half of global consumers said they’ve become more eco-friendly since the COVID-19 pandemic. Consumers are changing their behaviors, educating themselves about the businesses they support, and evaluating the products they buy through a “green” lens. Terms like circular economy, zero-waste, ESG and carbon footprint are now part of the common vernacular, and sustainability is no longer a nice-to-have but a business imperative.

Cannabis consumers, in particular, value sustainability. They are conscientious of what they’re putting into their bodies and the planet. There is increased interest in brands and businesses that use responsible growing practices, eco-efficient manufacturing, and sustainable packaging. In a nationwide survey conducted by Canivate Growing Systems, 79% of U.S. cannabis consumers said they support establishing environmental standards. And in 2021, the Sustainable Cannabis Coalition (SCC) was formed to promote sustainability best practices.

Sustainable packaging is an important way that brands can show a commitment to the environment. Packaging is a highly visible and tangible representation of your brand and one that matters to consumers. A July 2021 Adweek/Morning Consult poll found that 77% of consumers believe it is the brand owners’ responsibility to make sure their packaging is recyclable. According to Nielsen, of the top five sustainability attributes consumers are willing to pay more for, three are packaging-focused: Recycled packaging, reduced packaging and reusable packaging. While cannabis packaging has unique regulatory requirements and safety guidelines, it can still be eco-friendly. Sustainable cannabis packaging has the necessary properties to protect against moisture and maintain freshness and smell. It can also be child-resistant and include other unique cannabis functionalities.

Image: Nielsen, 2019

When it comes to sustainable cannabis packaging, that which you may believe to be the “greenest” option may not be sustainable at all. Many factors go into this determination, including packaging material, weight, distance traveled from supplier to manufacturer, water and energy usage and more. At Berlin Packaging , we take a comprehensive and integrated approach to sustainability to ensure our solutions meet customer objectives and consumer expectations. We use life-cycle analysis to quantify a product’s environmental impact throughout its entire life cycle, including sourcing/raw materials extraction, manufacturing, distribution and end-of-life. This analysis ensures that the solutions we provide are effective, impactful, and don’t contribute to greenwashing.

One key pillar of sustainable cannabis packaging is material circulation – using recycled and recyclable plastics and alternative materials. It’s important to understand that not all plastics are created equal. HDPE and PET are fully recyclable and have a ~30% recyclability rate. Polypropylene, on the other hand, while recyclable, only has roughly a 3% recyclability rate. Color can also play a role. PET is valued for its transparency, so colored and opaque plastics are not considered recyclable.

Continuous innovation and technological improvements have contributed to several eco-friendlier plastic packaging solutions. One popular choice for many of today’s brands is post-consumer recycled (PCR) materials. Using recycled plastic reduces single-use plastic waste that fills our landfills and threatens our waterways. Bio-plastics, made using renewable plant-based materials, are another sustainable option. Berlin Packaging has partnered with numerous premium packaging manufacturers to provide sustainable solutions for our customers. Many of our offerings – suitable for flower, pre-rolls, edibles, concentrates and more – can be produced using PCR or bio-plastics.

Material circulation means using recycled and recyclable plastics and alternative materials.

We’re also seeing brands embrace new compostable, biodegradable and paper packaging options. Berlin Packaging offers pre-roll tubes that are 100% compostable in industrial or municipal facilities and are better for the environment while also protecting the product inside. With zero migration, zero odor, and zero visibility, these air-tight tubes maintain freshness and meet regulatory requirements. We also offer a variety of paper tubes for pre-rolls, vape carts, and flower that are reusable, recyclable, and biodegradable.

Other sustainable packaging strategies include refill & reuse systems, which have gained popularity over the past several years, especially among personal care categories. Other tactics to consider when evaluating your package’s sustainability scorecard are eliminating unneeded packaging components like outer wraps and neck seals, ensuring labels are recyclable, and lightweighting (reducing the weight of your package). Berlin Packaging evaluates all of these avenues when developing sustainable packaging solutions.

Beyond the packaging itself, we encourage our customers to consider aligning their branding design and on-pack messaging to tell their sustainability story. We’re seeing many brands elevate their packaging sustainability benefits on their packaging’s primary display panel. The How2Recycle labeling program is another tool that helps educate consumers about how to dispose of packaging to ensure it gets recycled properly. Berlin Packaging’s sustainability specialists assist companies with comprehensive messaging strategies. Given the rise of greenwashing and consumer confusion and skepticism, effective and impactful messaging is a critical part of a sustainable packaging strategy.

Working with packaging suppliers and design partners who understand the cannabis market and have sustainability expertise is key to a brand’s success. A holistic approach that considers consumer insights, design functionality, aesthetics, manufacturability, regulatory requirements and sustainability results in packaging solutions that grow sales and build brand loyalty.

New Guidance on Waste Disposal for Hemp Producers

By Stephanie McGraw, Emily Sellers
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On January 15, 2021, the USDA published its final rule on US hemp production. The rule, which becomes effective on March 22, 2021, expands and formalizes previous guidance related to waste disposal of noncompliant or “hot” crops (crops with a THC concentration above .3 percent). Importantly for the industry, the new disposal rules remove unduly burdensome DEA oversight and provides for remediation options.

Producers will not be required to use a DEA reverse distributor or law enforcement to dispose of noncompliant plants. Instead, producers will be able to use common on-farm practices for disposal. Some of these disposal options include, but are not limited to, plowing under non-compliant plants, composting into “green manure” for use on the same land, tilling, disking, burial or burning. By eliminating DEA involvement from this process, the USDA rules serve to streamline disposal options for producers of this agricultural commodity.

Alternatively, the final rule permits “remediation” of noncompliant plants. Allowing producers to remove and destroy noncompliant flower material – while retaining stalk, stems, leaf material and seeds – is an important crop and cost-saving measure for producers, especially smaller producers. Remediation can also occur by shredding the entire plant to create “biomass” and then re-testing the biomass for compliance. Biomass that fails the retesting is noncompliant hemp and must be destroyed. The USDA has issued an additional guidance document on remediation. Importantly, this guidance advises that lots should be kept separate during the biomass creation process, remediated biomass must be stored and labeled apart from each other and from other compliant hemp lots and seeds removed from non-compliant hemp should not be used for propagative purposes.

The final rules have strict record keeping requirements, such rules ultimately protect producers and should be embraced. For example, producers must document the disposal of all noncompliant plants by completing the “USDA Hemp Plan Producer Disposal Form.” Producers must also maintain records on all remediated plants, including an original copy of the resample test results. Records must be kept for a minimum of three years. While USDA has not yet conducted any random audits, the department may conduct random audits of licensees.

Although this federal guidance brings some clarity to hemp producers, there still remains litigation risks associated with waste disposal. There are unknown environmental impacts from the industry and there is potential tort liability or compliance issues with federal and state regulations. For example, as mentioned above, although burning and composting disposal options for noncompliant plants, the final rule does not address the potential risk for nuisance complaints from smoke or odor associated with these methods.

At the federal level, there could be compliance issues with the Resource Conservation and Recovery Act (RCRA), Comprehensive Environmental Response Compensation and Liability Act (CERCLA) and ancillary regulations like Occupation Safety and Health Administration (OSHA). In addition to government enforcement under RCRA and CERCLA, these hazardous waste laws also permit private party suits. Although plant material from cultivation is not considered hazardous, process liquids from extraction or distillation (ethanol, acetone, etc.) are hazardous. Under RCRA, an individual can bring an “imminent and substantial endangerment” citizen suit against anyone generating or storing hazardous waste in a way the presents imminent and substantial endangerment to health or the environment. Under CERCLA, private parties who incur costs for removal or remediation may sue to recover costs from other responsible parties.

At the state level, there could be issues with state agency guidance and state laws. For example, California has multiple state agencies that oversee cannabis and hemp production and disposal. CA Prop 65 mandates warnings for products with certain chemicals, including pesticides, heavy metals and THC. The California Environmental Quality Act (CEQA) requires the evaluation of the environmental impact of runoff or pesticides prior to issuing a cultivation permit. Both environmental impact laws permit a form of private action.

Given the varied and evolving rules and regulation on hemp cultivation, it remains essential for hemp producers to seek guidance and the help of professionals when entering this highly regulated industry.

Managing Cannabis Waste and Protecting Your Business from Risk

By David Laks
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Cannabis producers know that they cannot treat plant waste like common yard waste. They need to develop a detailed waste disposal plan in order get a license to operate.

Failing to follow the approved plan and improperly disposing of dry waste materials and waste products from oil extraction leads to fines, liabilities or even having your license rescinded.

Learning to deal with cannabis waste appropriately is crucial to the success of an operation. There are a number of strict controls in place for dealing with any kind of hazardous waste, which can’t just be sent to a landfill or composting facility.

In the US, the EPA and state governments provide guidelines for disposing of hazardous waste properly, and other countries have federal and local requirements as well. The EPA, like other environmental bodies, differentiates between two types of waste: solid and liquid.

Solid waste disposal: The guideline for identifying solid waste is that it’s “unrecognizable and unusable.” This means no one should be able to look at a bag of waste and know immediately that it is cannabis. Many cannabis operations have a facility on site for grinding down the waste into smaller bits. If the waste is non-hazardous, it is mixed with other non-cannabis organics such as garden trimmings and then composted or sent to the appropriate landfill. If it’s hazardous, it’s mixed with cat litter, sand, plastic or sawdust and sent to the appropriate landfill.

Liquid waste disposal: Liquid waste is a bit more complicated. It must be disposed of properly or sent to a hazardous waste treatment facility. Cannabis operations must partner with a shipping company to dispose of the hazardous waste appropriately, unless they transport it themselves.

It can be confusing to manage the risks of proper disposal of cannabis waste. Keep it simple by following these three tips:

  1. Become an expert in all the legal restrictions – and follow them. Federal restrictions will guide you overall, but local (i.e., state and municipal) restrictions are equally important and may vary.
  2. Seek out experienced, reputable disposal companies – and hire the best one.Look for one that is familiar with handling hazardous waste in general and cannabis waste in particular.
  3. Familiarize yourself with the guidelines for proper tracking, transportation and sign-offs – and follow them.Completing all appropriate documentation ensures you have a paper trail to protect you in the event of an audit. Much of the documentation creates a written record so inspectors can confirm appropriate handling.

Waste disposal policies should be reviewed regularly as state and municipal regulations can change. At the same time, it would be wise to review your environmental insurance policy to ensure your business is covered for any accidental releases.

It can be tempting to take shortcuts – saving both money and time – when it comes to hazardous waste disposal. But properly disposing of hazardous materials can demonstrate your organization’s credibility and financial wellbeing, and it can also save you from unnecessary risk.

Biros' Blog

Sustainability of Cultivation in 2016, Part II

By Aaron G. Biros
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In the second part of this series, I speak with Alex Cooley, vice president of Solstice, to find out what particular solutions growers can use to increase efficiency. Last month, I introduced the challenge of growing cannabis more sustainably. To recap, I raised the issue of sustainability as an economic, social and environmental problem and referenced recent pesticide issues in Colorado and carbon footprint estimates of growing cannabis.

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The growers at Solstice put their plants under a trellis net to increase yield.

Alex Cooley is the vice president of Solstice, a cultivation and processing business based in Washington. Solstice is at the forefront of the industry for innovating in energy, water and raw materials efficiency. I sat down with Cooley to discuss exactly what you can do to grow cannabis sustainably.

“Switching to outdoors or greenhouse will always be more sustainable than indoor, but depending on the type of facility, energy efficiency and specifically lighting should be at top of mind,” says Cooley. “Just looking at your bottom line, it is cheaper to use energy efficient lighting sources such as plasma or LED lighting, which will reduce your need for air conditioning and your overall energy consumption.”

Looking into sustainable technologies is one of the quicker ways to improve your overall efficiency. “We are big believers in VRF [variable refrigerant flow] HVAC systems because it is one of the most energy efficient ways to cool a large space in the world,” adds Cooley. “Use a smart water filtration system that gets away from wasting water by catching condensate off AC and dehumidifiers, filtering and then reusing that water.”

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Indoor cultivator facilities use high powered lights that give off heat, requiring an efficient air cooling system like VRF HVAC.

Utilizing your waste streams is another relatively simple and cost effective practice to grow cannabis sustainably. “Our soil and biomass goes through a composting company, we recapture any of our waste fertilizer and runoff for reuse,” says Cooley. “We try to use post-consumer or fully recyclable packaging to reduce what would go into the waste streams.”

So some of the low hanging fruit to improve your bottom line and overall sustainability, according to Alex Cooley, include things like reusing materials, composting, increasing energy efficiency and saving water. These are some of the easily implementable standard operating procedures that directly address inefficiency in your operation.

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The tops of plants are beginning to flower in this Solstice indoor facility.

In the next part of this series, I will discuss Terra Tech’s approach to sustainable cultivation, which utilizes the “Dutch hydroponic greenhouse model” on a large scale growing produce such as thyme and basil, but are now taking their technologies and expertise to the cannabis industry. I will also discuss the benefits of using a third party certification, Clean Green Certified, to not only help grow cannabis more ecofriendly, but also market your final product as such. Stay tuned for more in Sustainability of Cultivation in 2016, Part III.