Responsible Markets (REM) Standard – Public Comment

Circular Action Alliance (CAA) invites interest holders to review and comment on the draft Certification Standard for Responsible Markets: For Recycling of Paper, Packaging and Food Serviceware (REM Standard). Feedback will help strengthen the clarity, feasibility and effectiveness of the final standard.

The Certification Standard for Responsible Markets: For Recycling of Paper, Packaging, and Food Serviceware is a draft certification standard developed by Circular Action Alliance (CAA), in collaboration with SCS Standards and Assurance Systems (SCS SAS), to support implementation of Responsible End Market (REM) requirements established in U.S. Extended Producer Responsibility (EPR) laws.

The REM Standard is intended to provide a consistent set of operational and documentation requirements for verifying how covered materials are managed downstream of collection and sorting across states with EPR requirements, while maintaining appropriate protections for confidential business information.

In addition to supporting statutory compliance, the REM Standard is designed to improve transparency, consistency and confidence in recycling outcomes across the value chain.

What is the REM Standard?

Standard Development Committee?

The REM Standard is informed by input from a Standard Development Committee (SDC) representing regulators, environmental organizations, academic experts and industry organizations.

SDC Members:

  • Aluminum Association

  • American Chemistry Council

  • American Forest & Paper Association

  • Arizona State University

  • Association of Plastic Recyclers

  • Colorado Department of Public Health and Environment

  • Glass Packaging Institute

  • GreenBlue

  • Minnesota Pollution Control Agency

  • National Waste and Recycling Association (NWRA)

  • Oregon Department of Environmental Quality

  • Recycled Materials Association (ReMA, formerly ISRI)

  • Washington Department of Ecology

  • World Wildlife Fund (WWF)

Submit a Public Comment

CAA invites interest holders from across the recycling value chain to participate in shaping the REM Standard by submitting public comment.

To submit comments:

  1. Access the comment form via the button above.

  2. Enter your contact information into the form (required).

  3. Specify the type of comment you are submitting (general, editorial or technical).

  4. Submit your comments one at a time. Note that all comments require a proposed resolution and at least one of the following is required for editorial or technical comments:

    - Line #
    - Clause/subclause #
    - Paragraph/table/figure #

  5. You can submit as many comments as you'd like by continuing through the survey.

NOTE: Comments submitted without a proposed resolution will be reviewed for context only and will not be integrated into forthcoming revisions.

Public Webinar: Introduction to the REM Standard

CAA will host a public informational webinar to introduce the draft REM Standard, outline key elements of the proposal and explain how to participate in the public comment process.

May 12, 2026 | 1:00–2:00 PM ET

Frequently Asked Questions (FAQ)

  • The REM Standard is a draft certification standard developed to support verification of REM requirements established in U.S. Extended Producer Responsibility (EPR) laws for paper, packaging and food serviceware.

  • Recycling systems have become increasingly complex, particularly as EPR laws are adopted in multiple states. While these laws share common objectives, differences in implementation can create fragmented REM requirements, leading to an inconsistent approach for identification, verification and audit.

    The REM Standard is intended to support greater alignment and consistency across states, helping end markets operate with a clear standard for verification and audit rather than inconsistent state‑by‑state approaches. At the same time, the standard is designed to improve transparency and confidence in downstream recycling outcomes by defining common expectations for REMs, specifically legal compliance, transparency in chain of custody, environmental soundness, and assurance of processing.

  • Many EPR laws require that covered materials be managed through responsible end markets. The REM Standard is intended to support implementation of those requirements through harmonized, third-party certification audits.

  • No. The REM Standard creates a single audit process whereby an end market can be verified for all requirements across EPR states it receives materials from. It does not replace statutory or regulatory requirements but instead drives consistency in their application, reducing confusion for end markets and minimizing the cost and effort to ensure responsibility across all states.

  • The REM Standard is being developed with the support of SCS Standards and Assurance Systems (SCS). SCS is an American National Standards Institute (ANSI) Accredited Standard Developer, and they ensure the process follows the established ANSI guidelines for open, consensus-driven engagement. A Standard Development Committee comprised of interest holders from state regulatory agencies, industry associations, NGOs and academia provides consistent feedback and deliberation of the standard requirements. SCS guides the committee discussion sessions and reviews their comments to provide clear direction on the standard text. SCS also leads the public comment process and reviews comments submitted through CAA’s survey.

  • The committee provides technical and policy input by reviewing draft proposals, public feedback and pilot audit results. Participation does not constitute endorsement.

  • Interest holders involved in or supporting recycling markets downstream of collection and sorting are encouraged to provide feedback.

  • No. Individual submissions will not be published. Comments will be anonymized and summarized.

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