Modern-day packaging is beautifully complex. From the bulky outer shell of cardboard boxes to the inner, individual plastic casings, all packaging has been specifically designed to optimize a vast set of criteria. Package protection, durability, cost, space-usage, material-usage/material type, consumer safety, and marketability are just a subset of the criteria that bring together a multitude of disciplines from advanced mathematics to consumer psychology. But despite all of this careful design, modern-day parcels contain too much packaging and pose an immediate threat to public health.
According to studies from the National Institute of Health (NIH), inhalation and direct contact of certain plastics just from consumer packaging have been shown to lead to cancers, diabetes, neurological disorders, hormone imbalances, and various other negative health effects. Current restrictions against such “non-hazardous” waste are small, largely not enforced local regulations. Given its scale and threat to public health, the U.S. federal government must elevate packaged waste to a hazardous status. Doing so will allow for the Environmental Protection Agency to better oversee and regulate the packaging and disposal of goods through the Resource Conservation and Recovery Act (RCRA). The threat packaging poses to public health can only effectively be reduced through unilateral EPA regulation.
Can overpackaging alone be that big of a problem?
To gauge the scope of waste, it helps to breakdown the scale and process of domestic goods transport. In 2018, there were over 13.5 billion packages delivered within the United States. That equates to about 428 shipping parcels delivered every second or over forty packages delivered per U.S. resident per year. But every parcel is comprised of so much more than the outer shell (typically cardboard). Beyond this outer “shipper” layer, packages typically have cushioning or a stabilizing material such as bubble wrap, air pillows, or packing peanuts. This layer is sometimes followed by a tertiary packaging layer like a pallet, banding, or shrink wrap. Next is the secondary packaging layer that protects the primary packaging of a good like the cardboard around a plastic cereal bag. The primary layer is the layer closest to the good in transport and is usually comprised of more plastic (glass, steel, aluminum, and paper are found at this level as well). Five layers is too many. Altogether in the U.S., these layers account for 80 million tons of “container and packaging” waste or one third of all annual, domestic waste.
Is all of this packaging essential?
Many U.S. couriers like UPS define the essential roles of packages to be damage prevention, cube (space) optimization, and material usage in that order. However, even with these optimization measures, a 2018 survey by Forbes and DS Smith on 44 U.S. retailers found that on average 25% of the retailers’ packaging was empty and wasted space (ranging from 18% for clothing up to 64% for glassware). Not only is this empty space inefficient, but also necessitates the use of up to 25% more interior padding. According to UPS, such space inefficiencies cost an extra $48 billion in packaging costs worldwide. The extra material usage also substantially contributes some 20 million tons of U.S. “container and packaging” waste. This waste is only projected to rise with e-commerce sales more than doubling since 2012.
Where does all this excess shipping waste end up?
Although there are five main destinations for shipping materials after use (reuse, recycling, landfills, incinerators, and the environment), the natural environment has accumulated a majority of this waste. According to Roland Geyer, an industrial ecologist at UCSB, about 60% of all plastics ever manufactured have made it into the natural environment. Most plastics do so within the same year. In 2015 alone, of the 146 million metric tons of plastics used for global packaging, 141 million metric tons were immediately thrown out. Although the U.S. now recycles and incinerates up to 23% of waste plastics, that still means that nearly three of every four pieces of plastic waste will spend the next 1,000 years biodegrading in a landfill or the natural environment (e.g. oceans, waterways, plains, etc.). Numerous NIH studies have shown that this accumulation of plastics, paper/cardboard, and other packaging materials wreaks havoc on the natural environment and public health.
What is currently protecting the environment and public health?
Currently, zero unilateral, federal regulations regarding packaging exist. The U.S. Food and Drug Administration (FDA) has the authority to regulate select packaging outlined within the Federal Food, Drug, and Cosmetic Act. Under the RCRA, the EPA has full authority to regulate “generation, transportation, treatment, and storage” of mostly select “hazardous” materials. But any regulation beyond the FDA and EPA, falls to the discretion of local and state governments. While some state regulations in places like those in California and Oregon have been successful in reducing plastic container and Styrofoam usage/waste via complete bans, local measures are largely contentious, weakly enforced, and vary state-by-state. Without a centralized, federal oversight, enforcement, and push for regulation, the public health risks associated with overpackaging will continue to rise.
What measures should be taken?
By emphasizing the public health risks associated with excessive packaging debris and highlighting the interstate commerce associated with the distribution of such packages, the EPA can make a case to elevate packaging materials (particularly plastics) to a hazardous waste status subject to federal regulation. Such a status would allow for the EPA to gain greater regulatory power over the entire lifecycle of packaging materials. With this expanded purview, the EPA could (1) regulate all U.S. retailers and couriers through measures like “on-demand packaging” (custom-fit parcels), dimensional pricing (cost relative to both weight and size), overpackaging fines, and criminal violations. The EPA can even instruct that couriers and retailers adopt machine learning models for optimal package for transport (similar to Amazon’s “matrix”). Large couriers and retailers like Target and Amazon have started implementing a mix of these options and have reduced excess packaging by some 300 million boxes. And (2), the EPA could apply current hazardous waste standards to proposed national packaging standards to ensure nationwide compliance. Similar standards and compliance measures were successfully employed with the RCRA in 1976 and were responsible for restoring public health and 18 million acres of contaminated land.
Only by centralizing, regulating, and mandating these waste reduction techniques can the U.S. hope to dramatically reduce the 25% of excess “container and packaging” waste and lay the groundwork for future packaging waste reduction strategies.
 Neet, Rustagi et al., Public health impact of plastics: An Overview, National Institute of Health, (NIH, 2011).
 Summary of the Resource Conservation and Recovery Act, Environmental Protection Agency, (EPA, 2019).
 Package Delivery Statistics, Parcel Pending, (Parcel Pending, 2020).
 Packaging: At the Forefront of E-Commerce Growth & Sustainability, Ameripen, (Ameripen 2014).
 Plastics: Material-Specific Data, Environmental Protection Agency, (EPA, 2019).
 Packaging, Ameripen, (Ameripen 2014).
 The Empty Space Economy, Forbes Insights & DS Smith, (Forbes, 2018).
 How Product Packaging can Drive Startup Success, United Parcel Service, (UPS, 2019).
 Plastics, EPA, (EPA, 2019).
 Richtel, Matt, E-Commerce: Convenience Built on a Mountain of Cardboard, New York Times, (NYT, 2016).
 Dengler, Roni, Humans have made 8.3 billion tons of plastic. Where does it all go?, PBS, (PBS 2017).
 Plastics, EPA, (EPA, 2019); The Lifecycle of Plastics, World Wildlife Fund, (WWF, 2018).
 Public health impact of plastics: An Overview, National Institute of Health, (NIH, 2011).
 U.S. Packaging Regulations, Qorpak, (Berlin Packaging, 2020).
 Packaging, Ameripen, (Ameripen 2014).
 Wilson, Mark, The Hot New Product Amazon and Target are Obsessing Over? Boxes, Fast Company, (FC, 2019).
 Celebrating 40 years of the RCRA, The EPA Blog, (EPA, 2016).
3 thoughts on “Overpackaging: A “Hazardous” Public Health Crisis by Tommy Hessel”
Great article, Tommy! The first thing that stands out to me is the millions of tons of shipping waste that ends up in the environment after use. I knew that plastic pollution was severe, but seeing numbers like 141 out of 146 million metric tons of plastic being immediately thrown out is powerful and really puts the problem into perspective. We need to invest in solutions to this packaging problem that produce less single-use waste.
I was also surprised to hear that there are no federal regulations regarding packaging. Because of the high volume of interstate shipping, one would think that the federal government would clarify the rules in this area, rather than leaving it to the states and producing confusion. A federal push for cleaner shipping and packaging options could produce widespread benefits. This might be easier if agencies like the EPA were empowered to accomplish their foundational goals, rather than being constantly defunded and weakened.
Thank you for such an informative blog, Tommy! I really enjoyed reading it. I think that you covered this issue in a really comprehensive manner. I was not even aware of the direct public health risks of contact with plastic packaging, so I am glad that I learned that today, which I believe highlights the amount of education that is necessary on this. I think that with a movement for more education on this, the EPA could make a strong case to move plastics into a hazardous waste category that they have more regulatory power over.
Another thought that I had while reading is how this issue has very clear impacts to public health, environmental health, and the economy. Based on this, I think it is more feasible to bring bipartisan support to reducing overpackaging. I was surprised to hear the number of $48 billion in extra costs for inefficient packaging. I believe this is a powerful point you made and I’m glad you brought light to it, especially because of how little recycling actually happens. My parents moved about a year ago to a town in South Carolina and our county does not even recycle plastic, glass, or cans, which was very shocking to me. Given differences between localities just in recycling, I can easily imagine how much of a problem it is on the prevention side of trying to reduce the plastic to begin with. I agree that a centralized solution makes the most sense.
It’s good to read about this very under-discussed and important topic! I really like how your proposed solution is very specific and seemingly very doable, and you lay out the case very effectively, from an environmental as well as economic standpoint why something needs to be done about excessive packaging. It was sadly not surprising to me how wasteful U.S. companies and governmental bodies are, this seems to be a trend across industries despite it being awful policy from any perspective. I think the only way this will actually get tackled is if there is a very strong advocate in the role of EPA administrator, which obviously is not going to happen with Trump, although there is a small possibility with Biden. I say a strong advocate because it probably won’t reach the level where a typical politician or political appointee would care much about it, even though it should ostensibly help businesses along with consumers and the environment. It’s good that Target and Amazon have done this, but that’s not an excuse for not regulating, many shippers still don’t try to streamline packaging nearly as much as they could, and government action is probably the fastest way to get them to change their practices.