How Do We Navigate EPR? Lorax COO Michelle Carvell

Connect with Lorax EPI here: https://www.loraxcompliance.com/

Follow Lorax on LinkedIn: https://www.linkedin.com/company/lorax-compliance-ltd/

How do we make sure we are in compliance with EPR laws and more? 
What can we do to prepare for future laws? 
Can we get our data organized to make this a more streamlined process? 

Getting to interview Michelle Carvell was a true pleasure and I highly recommend reaching out to her and the team at Lorax EPI 

Check out our sponsor Orora Packaging Solutions 
https://ororapackagingsolutions.com/

https://specright.com/?utm_campaign=2024%20Influencers&utm_source=cory%20connors&utm_content=home%20page 

https://www.linkedin.com/in/cory-connors/

I'm here to help you make your packaging more sustainable! Reach out today and I'll get back to you asap.

This podcast is an independent production and the podcast production is an original work of the author. All rights of ownership and reproduction are retained—copyright 2022.

Transcript

Cory Connors: 0:31

Welcome to sustainable packaging with Cory Connors. Today's guest is my very special friend, Michelle Carvell, the COO of Lorax EPI. How are you, Michelle?

Michelle Carvell: 0:42

I am very well, thank you. It's evening here. I can see the sun coming through your blinds, but it's probably gone from where I am today.

Cory Connors: 0:49

All the way from Rugby, England. I'm so excited to interview you. We've spent lots of time at different events together. And, the, this is actually the second podcast we've done together. The first one was with our friend, Adam Peake, and we forgot to turn the sound on. So I'm thrilled and thankful that you agreed to do this again. And, the things have changed a lot in the world of packaging. True,

Michelle Carvell: 1:14

but I think we'll probably keep the topic the same.

Cory Connors: 1:16

Yes, we're going to talk about,

Michelle Carvell: 1:18

exactly the same thing. Well,

Cory Connors: 1:20

and when people ask me, which they often do, is, who should I talk to about extended producer responsibility? in compliance. I send them to you and your team at Lorax. So keep up the good work. You're doing great things. but first let's talk a little bit about your background. How did you get to be where you are today?

Michelle Carvell: 1:38

well, I think if you had asked, the 18 year old me, would I open up a job in packaging compliance? The answer would resoundedly have been no. I, I had earmarked myself a career to go and work in British Airways, I think a long time ago, and what definitely didn't have this on my horizon or my plan or anything. But I, what happened after university, you know, as I think most people do, they look around and try and get the first trainee job they can and see how they can get some experience and go off and do something. And that's what I did. I ended up in a project management, software project management, trainee software project management job, actually. And, it just happened to be for a software company that did, compliance, I guess you could say. So it was a lot of extended producer responsibility, which was not unusual then, but certainly not common and ROS legislation, REACH legislation. So understanding that full picture of legislation that affected products and packaging. And I started there and I guess I really. enjoyed it. I enjoyed doing the legislative understanding. I enjoyed problem solving. I enjoyed fitting, I found a real passion in trying to understand puzzles with data and trying to see how, you could answer questions with data that maybe didn't always exist or, things that you needed to do. And find ways around that. so I did that for, I think, 10, 11 years. I stayed at the same company and then myself and a couple of others decided to start a business of our own. And this time we focused very much just on extended producer responsibility. And I think we did have some quite lofty goals at the beginning that we would do everything else because that's what we had experience in. and one of my co founders then, he had written a Previous software. It was, he'd written a number of versions of producer responsibility, reporting engines. And so we just said, yeah, we'll start with EPI. okay. We know that. and I think what happened then was there was this sort of explosion of, interest in plastic in the field, in all the sort of the, finally we always joke that, we'd been a pretty boring dinner guest for our entire lives, rabbiting on about. packaging, but all of a sudden, since David Attenborough did various documentaries, then we were a little bit interesting and we were. right in the position where we knew a lot about that field. and we had people that were interested in working with us. So then we started Lorax. It's nearly 10 years, 10 years at the end of this year. that Lorax would have been going, which is, fantastic and something I'm incredibly proud of. And we have just continued to embed in EPR and focusing, a lot on the packaging side, because I think that's been a high priority for us. Companies, but we also look at all extended producer responsibility legislation, such as batteries and electronics and textiles now, which is very, like a growing field and other deposit programs as well. And I think, it's been. A wonderful journey to grow a business in something that you love doing

Cory Connors: 4:36

excellent points. And you're exactly right. it's obvious to me and to the people that hear you speak at the events that we go to that you're passionate about this and, To the point where I think you've become one of the premier experts in the industry and My i'm not sure about that. Well, i'll give you that title I think you've earned it and I think that when people ask me where do I go for extended producer responsibility information? I don't send them to a website or anything like that. I say Check out Lorax and check out Michelle and her team, they can actually help you, guide you through this process. it's not an easy thing to do, but let's, well, that's

Michelle Carvell: 5:17

very kind. I think one thing I think is, I guess EPR also is its own beast. it's its own field and even within that, I guess we. Still don't do everything in there. we really try to keep away from policy advocacy. we certainly don't tell people how laws should be made. We have our own ideas, but our niche has always tried to been to help solve the downstream problem of, well, now you've got to deal with it and trying to help people. Manage the outcome of the law rather than try to create a law.

Cory Connors: 5:47

that's an excellent, point because if you're advocating for one thing, and then you're reporting on it over here, there could be some concern with, pulling from both sides. And I think staying out of that, side of things makes a lot of sense. Well done.

Michelle Carvell: 6:02

Yeah. Yeah,

Cory Connors: 6:04

so I know what a Lorax does, I think, but can you explain it to the audience so that they, the people who would need to see you can come to you.

Michelle Carvell: 6:14

Yeah, sure. So, we started with the intention of providing a technology solution so that companies could scale the reporting of EPR. And I think that comes because, in reality, EPR It's maths. It's complicated maths sometimes, but it's maths. It's understanding what you've placed into a market. It's understanding the routes that the products took to get there. It's understanding how to classify products into certain groups and packaging into certain categories. but I think the problem that we face a lot at the moment is that the scale of it has become. Unmanageable and companies that have to work with, 50, 60 different countries who have embedded legislation, another few which are bringing in legislation and then put that across multiple disciplines of packaging electronics and all the other fields where you have to report like that. and then look at the upcoming side of things like a global plastics treaty and how that might affect things, and also consider voluntary commitments like Ellen MacArthur Foundation reporting and plastic taxes and other things that can use that data, then it almost becomes like a system and you need a system to be able to support it. So, our vision was always that we would bring a piece of software, and to do that, and that's what we do at the moment. However, I think in, in doing that, then what we also understand is that there are plenty of people who, even though EPR is a reasonably mature piece of legislation, in Europe and in other parts of the world, it's actually doesn't mean that everybody understands it. So you often have to then wrap that service of providing a technology solution with services around it, such as helping them understand, am I obligated? Okay, what should I be doing? How do I register? What type of data do I need? How can I pull that from the various systems internally? And Create a really good database, which is comprehensive enough to be able to allow me to do the reporting. And then at the end of that, once you've created reports to support with the auditing process, and to also use that data for other things like packaging strategy. And could we make database decisions now? Because actually we really do know what the content of our packaging is, and we can understand really how much recycled content we have and the colors that are being used. And we can now see that on a global basis because we've been investing in putting in a good system. So, LORAX in general does that, which is to bring together all those different layers, which you have to have just for simply reporting to EPR and put those into solutions, which we can offer to our clients. And on top of all of that, we have to keep ahead of the legislation to understand what's coming down the line, how it will affect our. software products in terms of coding it and bringing those templates to life and also how those pieces of legislation could affect our clients. So we offer a number of services to do with legislation tracking and horizon scanning.

Cory Connors: 8:58

Excellent. So it can even look ahead to say, if this law changes to this, which we think it will, this is how it will affect you. And that's important. If you can overlay, if

Michelle Carvell: 9:11

you can overlay knowledge of legislation with, here's my data and here's my packaging portfolio, you can start to really pinpoint the pain points over the next two, three, four, five, 10 years, because even looking ahead to something like the PPWR, which just went through parliament today, then you can say that, well, which parts of my portfolio currently would not be considered recyclable, which parts of my packaging look over to the U S plastics pack to still contain PVC. All these things where we see materials might be banned or affected or restricted in the future, if you overlay that legislation to the data, to the footprint, then it really gives you a very clear idea of what's going on. the impact of the legislative problem.

Cory Connors: 9:52

So, excellent. the biggest comment I get on this, from customers in the packaging world are, we're scared. We're not sure what to do. We, we're uncertain and it sounds like Lorax provides that certainty. and can help you plan to avoid the fear and to avoid the, costs that will be associated with mistakes here. these things. You can't avoid

Michelle Carvell: 10:17

the cost in general, I'm afraid. no, the costs are there for a reason. The costs are there to help improve recycling infrastructure and recycling outcomes. But yes, to help. we're not lawyers. We certainly aren't going to come at this from a legal counsel perspective, but we, I guess are here to. Take some of that worry away because it is already happening. And I think you're probably seeing this more because of the location you're in, which is with new US EPR legislation. Of course, people are nervous, but it has been in place already in a number of countries. It has good improving outcomes here where we can see real Benefits from having a system like this which enable producers to pay and then for recycling infrastructure to be built. So I think they. They probably, and I'm glad they're nervous because it means they care actually, and they're also going to be invested in the outcome of it. And that's why I think some of these very much producer led schemes that we see now coming through are going to be, productive because they're going to, the businesses that are building into them are going to want to see a good outcome from the money that they're paying towards it. And that's all we really want here is people who are invested in the future and ensuring that they, the packaging that they use does not end up being waste.

Cory Connors: 11:29

And that's it. that's the whole point of this whole thing is a circular economy eventually, and I think people are okay with fees. they're gonna, they're gonna pay them begrudgingly, but I think what they're concerned about is penalties and being wrong and saying, oh, no, I didn't know we couldn't use PVC, or I didn't know we couldn't use this kind of single use plastic for this kind of thing. Because we didn't research it well enough, so, well said this is, globally funded by all of the companies and, going to be an absolute imperative role in a more sustainable packaging future. I think. so that's exciting to me.

Michelle Carvell: 12:07

Yeah, absolutely. And me too. And, I think for look for many years, we've looked at the U S as a, we'll, they won't, they will never get across the line. I think that a couple of years ago when it did, there was a real sense of like, wow, okay, this actually could really move the needle. And now of course, right this week, we've just had the global plastics treated negotiations in Canada. And that is another step forward as far as I'm concerned in terms of legislative developments and. Whilst, of course, they're focusing on plastic, it, this will affect all materials and it will have an impact on packaging EPR as we know it over the next 5 to 10 years, because if we, if this mandates EPR programs in every country, then this will mean we will really have to look at this as a global problem, not a European problem. Some states in Canada problem and a couple of markets elsewhere, it will be everywhere.

Cory Connors: 12:56

And that's always been difficult to explain to people is what does that mean? Oregon has a law and California has a law and Washington has a law, but I live in Oklahoma. Do I, does it matter to me? Well, are you going to deliver any of your items to Oregon or California? Then yes, it does affect you and wow, okay. That's a big deal. Now, all of a sudden,

Michelle Carvell: 13:19

yeah. Yeah. And also, look ahead just because three States, four States, five States, maybe soon six States have passed it. And are moving forward with it, then it's an indicative sign that this is a trend and no matter what the, state legislature does today, there are moves still to have federal policies in this area. A global policy will come in and will absolutely influence that as well. So I think this, even if it's not a today problem, it's definitely a tomorrow problem.

Cory Connors: 13:51

Very well said. and we often mention, well, prepare for the most aggressive one. if California requires 30 percent post consumer recycled material, then I think everybody else will follow suit. It's my thought are, but I wanted to ask you, are there any EPR laws that, make you nervous? Like you've heard rumors about, Oh, this might happen this way. Anything that you think would be really disruptive in a negative way? Okay.

Michelle Carvell: 14:18

Yeah, well, I would actually say California, I think, is really pushing the needle on that because post consumer recycled content, of course, is, widely talked about now as a metric, which people want to have to be able to push the secondary markets of material. But I would say, It's the other pieces of California legislation, which concern me and concern me from a data perspective. I guess what I'm concerned about is how will businesses really track source reduction, which is one of the mandated pieces under California that is going to be technically quite difficult for companies to be able to do. how will we. systemize the definition of reuse and how will we then manage that as well? I think the reuse and refill is such a, growing, growingly discussed market. And I love the conversations that are having, I always go to a data place, which is, and how will I calculate it? how do I know that, the refill pump that I bought was linked to the refill pouch that I then filled it with, no, no business will ever know that about my behavior, your behavior. You may have filled it with two pouches. I did it with three, those types of questions about how will we really prove that the reuse and the refillable metrics are working? Those things really interest me. And I'm not sure I 100 percent have the answer because I don't know if there's enough data out there to perfectly answer those questions. And that's why. Those laws worry me because how will a company show their compliance? Because that's really all a company needs to do under the, all the company. That's what a company really needs to do under this is to be compliant with the legislation. But if the legislation is incredibly complicated, I think that makes it. difficult. And I think that's where a lot of this worry has come from. And then the source of worry for, certainly for a US EPR, because, the level that people are starting with US EPR is high. we're not starting with a, let's just look at total paper and total plastic and, we'll get going and then we'll refine it over time, which is really what the European perspective has been. there are lessons learned with Europe, of course, which are now being applied to the US. But that means we're starting at quite a complicated level already. And I think that's the nervousness piece there is that now all of a sudden companies are thinking, that the how is worrying them.

Cory Connors: 16:32

Excellent point. There seems to be no way that they could track how many times something gets reused or how many times, cause that affects everything. And unless it had some kind of a unique QR code on each. piece, or some kind of a way to track the UPC or, it's fascinating these complications. That would only

Michelle Carvell: 16:51

be for, refill models, for example. if you just reuse something around your house, or maybe I, next time I buy another company's refill pouch and I fill my pump with somebody else's refill, there's no way of really linking those two things together. So trying to solve that data piece, I think is. Yeah, well, something I really relish looking forward to doing.

Cory Connors: 17:11

I love how you embrace that challenge. And, speaking of data, I wanted to talk about Specright and your partnership with Specright and why is that such a valuable connection to have both Lorax and Specright, as suppliers for your company?

Michelle Carvell: 17:29

Yeah. So, one of the, one of the main challenges that we've always had with EPR reporting has been the level of data that companies have available to do it. And so the, the, the buzzword of the set of the century, eco modulation, which is what everybody talks and worries about, which is what does this really mean? What does modulation mean? How does it, how will my packaging be weighted financially according to whatever metrics are put in place by a market? But those things. are only able to be enacted if somebody has really good data, you can only claim a bonus on recycled content. If if it's got recycled content in, you can only claim, a bonus on not using carbon black, if you know that it is or isn't carbon black. And so one of the things that we really, found very beneficial with specright, is this challenge of data, because if you can at least start with a really good data set, Baseline of your products. And you have a specification system that allows you to go to that level and track it. Then you're already onto a great start because you can feed data and our partnership feeds through API's data from specright to us, where we can do the calculations for EPI reports. And at that stage, you'll then calculate them on much better quality of data. Whereas, in the past, I can tell you that we often end up with Reams of Excel sheets of people. Well, here's stuff I did. And, this is how I put it together. Or, I've got a bit over here in this system and I've got a bit more over here in this system. And can we somehow mash them together? But starting with a single specification system, which is what specright offers just allows that data quality level to be increased.

Cory Connors: 19:02

I don't know how many companies will report without something like specright? and Lorax, I don't understand how they're going to do it. Like you said, they're going to piecemeal it together. It's going to, it's going to take them sometimes, 10 to 12 people working, I remember stories from the specright? Summit of people talking about how this used to take us a month and a half. And now it takes us an hour and a half. And that's really amazing to, to be a part of that, solution and much simpler. cause. So, what's the number one?

Michelle Carvell: 19:33

Oh,

Cory Connors: 19:35

that's, well, as long as she's sustainable. No, I'm kidding. what's the number one thing that people come to you with, am I in compliance or what do they ask you first?

Michelle Carvell: 19:45

yeah, I guess it's a number of, it's a number of things of, there's no one thing. I guess we get asked a lot, the sort of the three main questions, what is it? who's going to do it, who should be responsible for this, it's my job because I don't really want to have this job. and then also finally, how am I going to resolve this problem? And do I need systems and, we talk about systems, but as I said at the beginning, it's maths. If you've got one product and you sell it globally, you could manage this on a spreadsheet. No problem. But you will find it hard if you sell one product in one country, no issue, but if you're a retailer and you've got 50, 000 SKUs and you've got to collect data from your vendors and you've then got to go out and, manage that piece of then translation into each of the schemes and understanding that you've got enough depth of material to be able to do that, then I think the how starts to then get complicated. And that's when, you see a benefit in using an outside service. but certainly, yes, at the moment, lots of people are saying, yes, am I obligated? Is this going to be me? And of course, early indications we can work out, but until rulemaking is finalized in the US, we aren't going to know a hundred percent. we're not making

Cory Connors: 20:48

it easy. Are we? No,

Michelle Carvell: 20:49

well, no, but you have to be admired for a getting there in the first place and be going in with trying to capture everything, which is going to be a problem. And that's, that is the challenge that we are trying to make a better recycling systems. We're trying to make, the infrastructure better. And that does mean we've got to look at the whole picture of packaging. And that therefore means. Bringing everybody into the value in the value chain who's responsible.

Cory Connors: 21:15

Well, and this is why you're such a hot commodity at these events for, as a speaker, you'll be speaking, at, The sustainable packaging summit in Amsterdam. Is that right?

Michelle Carvell: 21:26

Yes, I'll be moderating a panel there.

Cory Connors: 21:29

Wonderful. I can't wait. that's one of my favorite events every year, and I really look forward to that. the amount of, new information in that, group is incredible and, can be, a little bit overwhelming, but very good and very helpful. So I look forward to hearing you speak there.

Michelle Carvell: 21:47

Last year, I think I heard, I really enjoyed a lot of the talk about chemical recycling because I really felt they went into that in a lot of depth. And I really enjoyed that they were able to bring people from each continent together to talk about the waste management in each continent. It's quite rare that you go to these events, we always find Brands are represented, retailers are represented, the sort of packaging value chains, with the converters and manufacturers are there, but we don't always hear a lot about that MRF side. And so I guess I really valued hearing that sort of on the ground waste management story.

Cory Connors: 22:23

Absolutely. I was honored to get to moderate a panel last year about plastics, the circularity of plastics, and every guest was from a different continent.

Michelle Carvell: 22:33

Yeah.

Cory Connors: 22:33

And, and

Michelle Carvell: 22:33

you were great. Thank you.

Cory Connors: 22:36

Thank you. That was, it was exciting to get to hear from, someone from Africa and someone from Europe. And so, it was just wonderful. An incredible experience, and I agree this is Tim Sykes has really done a good job with his team of making this a global experience. And, so it's, I can't wait for November. So we'll see you all there.

Michelle Carvell: 22:55

You certainly will.

Cory Connors: 22:57

Yeah. So anything else that you wanted to say, can you tell us how to get in touch with you and your team at Lorax?

Michelle Carvell: 23:03

Sure. Well, we have a website, loraxcompliance. com. You can contact us at info at loraxcompliance. com or myself and my team are on LinkedIn. and you can find us there.

Cory Connors: 23:14

Thank you so much, Michelle. This has been amazing.

Michelle Carvell: 23:17

Yeah. Pleasure. Thanks, Corey.