Slides from Sapna Thottathil, Associate Director of Sustainability, Office of the President, University of California, Office of the President, presented at the Sustainable Purchasing Leadership Council’s 2019 Summit in Portland, OR.
New Sustainable Procurement Policy
Led by our Sustainable Procurement Working Group
The main policy provides some key principles, definitions and targets for
Economically & Socially Responsible as well as Green Spend.
Sustainable Procurement Guidelines
1. Defines what is UC “Green” or environmentally preferable
2. Defines what is UC "Economically and Socially Responsible“
3. Defines UC “Sustainable Spend” (piloting)
4. Provides guidance for solicitations (beyond certifications)
• Defines “packaging foam,” which includes all types of
polymeric foam used for packaging/cushioning, including
those made from polystyrene (EPS or “Styrofoam”) and
Polyethylene (EPE), among others
• Applies to all packaging materials except lab and medical
• Is already in effect for food service facilities (as of Aug. 2018)
• References the Sustainable Procurement Guidelines (where
implementation and exemption procedures will be explained)
UC 2019 Foam Policy
2019 Foam Policy Language
Packaging foam: Any open or closed cell, solidified, polymeric foam used for cushioning or packaging, including but not
limited to: Ethylene-vinyl acetate (EVA) foam, Low-density polyethylene (LDPE) foam, Polychloroprene foam (Neoprene),
Polypropylene (PP) foam, Polystyrene (PS) foam (including expanded polystyrene (EPS), extruded polystyrene foam (XPS) and
polystyrene paper (PSP)), Polyurethane (PU) foams, Polyethylene foams, Polyvinyl chloride (PVC) foam, and Microcellular
foam. Not included is easily biodegradable, plant-based foams such as those derived from corn or mushrooms.
III. F. Zero Waste
5. By 2020, the University will prohibit the sale, procurement or distribution of packaging foam, such as food
containers and packaging material, other than that utilized for laboratory supply or medical packaging and products.
The University seeks to reduce, reuse and find alternatives for packaging foam used for laboratory and medical
a. No packaging foam or expanded polystyrene (EPS) shall be used in foodservice facilities for takeaway
For implementation guidelines as they relate to the procurement of goods for University of California campuses,
reference the University of California Sustainable Procurement Guidelines.
V. G. Sustainable Procurement
7. In accordance with section III.F.5., the University has disallowed the use of packaging foam by 2020. For
implementation procedures, reference the University of California Sustainable Procurement Guidelines.
State of Foam in Supplier Packaging
Example #2 Information Technology Supplier:
• Late 2017 – Shipped 4 models in molded pulp
• FY18 - Rolled out 9 products with molded pulp,
with goal to have all products with fiber-based
cushion design (in addition to EPE cushions).
• 2019 - Piloting low-end lines with molded fiber
• Use “100% Recycled/Recyclable Expanded
Polyethylene (EPE)” for some lines.
• Moving some lines to hybrid solutions -
replacing certain amount of EPS/Styrofoam
cushions with fiber-based packaging.
Example #1 Furniture Manufacturer:
• Minimally use EPS on some products for
• Switch to EPP would cost over $1 million
• 1-3 year plan to reduce usage of EPS and
Arcel, but struggling to find viable
alternatives that provide same level of
• Agree Zero Waste is a great target for
packaging, but notes that the life-cycle
impacts resulting from damaged product
could exceed those of some foam packaging
Proposed Exemption Process for Suppliers
1. Provide a description of all non-compliant foam packaging material(s) for which an exemption is being requested.
Include the type of foam material (i.e. expanded polyethylene) and a description of the specific uses of the material
(i.e. laserjet printers).
2. Provide an explanation for why your company requires the use of these foam packaging materials for these specific
3. What is the duration of the exemption you are requesting (maximum 12 months)?
4. Provide an explanation to support the determination that there is no suitable compliant alternative or that all
suitable compliant alternatives cost more that 15% more than the non-complying foam packaging materials.
5. State your company's strategy for eliminating the use of all foam packaging materials listed in Question #1, and for
identifying environmentally preferable functional alternatives. Provide a phase out date for each foam material
listed. If there is no suitable functional alternative, provide a factual explanation to support that determination. If all
suitable functional alternatives cost more than 15% more than the non-complying foam packaging materials,
include this in your explanation.
6. State your company’s approach to achieving each phase out.
7. Explain any potential obstacles in the marketplace that might prevent your company from achieving stated phase
8. Define take-back programs in place for any foam packaging materials used by your company for products delivered
to the UC.
9. If your company is approved to receive an exemption, you will be required to provide quarterly reports estimating
the weight and volume of packaging foam materials distributed to the UC, inclusive of all manufacturers. If this
reporting poses an undue burden on your company, detail the obstacles/hardships preventing you from being able
to provide this information.
Supplier Survey Results on Exemption Process
Step Supplier Exemption Requirement Readily
Will require resources
1 Description of non-compliant foam packaging material(s) for
which an exemption is being requested
2 Explanation for required use of each material
3 Duration of exemption being requested
4 Supporting explanation for determination that there is no
suitable compliant alternative
5 Strategy for eliminating the use of all foam packaging materials
listed, including phase out date for each foam material listed
6 Approach to achieving each phase out
7 Potential marketplace obstacles that might prevent you from
achieving stated phase out
8 Description of take-back programs available to UC
9 Quarterly reporting on estimated weight and volume of
packaging foam materials distributed to UC, inclusive of all
manufacturers, or description of obstacles/hardships preventing
ability to provide the information
• Finalizing the exemption procedures for suppliers,
anticipated to be published Summer 2019
• Developing guidance on how to implement/enforce
through contract provisions
• Developing guidance on how to implement/enforce for
non-contract suppliers, as well as distributors
• Continue collaborating with suppliers