The waste that wasn’t there

Pollution prevention guidelines have always put a premium on source reduction. The design phase is where source reduction costs the least, yet it is where product designers spend the least time.

A low ceiling for design-based prevention

The Pollution Prevention Act of 1990 established source reduction as national policy and placed it above recycling, treatment, and disposal. Congress explicitly indicated that opportunities often go unrealized because existing regulations, and the compliance resources they consume, are oriented toward treatment and disposal rather than toward preventing waste in the first place.

More than three decades later, that statement still describes the working conditions of most pollution prevention practice. By the time a practitioner meets a manufacturer, the questions that determine how much waste their operation generates have already been answered: What is the product made of? How many parts does it have? Can those parts be separated? How long is it expected to last? Can a given housing component be opened without destroying the whole unit? Are any components proprietary, or can a repair shop easily source them?

The European Commission indicated that up to 80 percent of a product's environmental impact is determined at the design phase. While this figure is an estimate, the impact is not. Design sets the ceiling on what any downstream improvement can amend, and most pollution prevention work necessarily happens under that ceiling.

In the U.S., healthcare generates roughly 5 million tons of waste per year, and about 95 percent of the environmental impact of a single-use medical product comes from production. So, the impact is set the moment someone decides the product will be disposable. Everything after that is bookkeeping—keeping tabs on waste for management and reporting.

The cost of changing your mind later

Getting a repairable design for a product already in production means the manufacturer must retool, requalify, renegotiate supplier contracts, sometimes recertify, and begin a round of explaining to customers why the part number changed. An environmental argument has to survive every one of those conversations before it gets anywhere. By contrast, at a company that has not yet ordered tooling or frozen its bill of materials, the same change takes a revised drawing and a design review, and nobody outside the building ever has to know it happened.

Waste that never gets designed into a product does not have to be addressed later because a product specification decision outlives the moment it gets made. The founder who picks standardized fasteners over adhesive bonding has settled the repairability question for every unit the company will ever ship, and the decision costs the same whether the product sells a hundred units or a hundred thousand.

None of this matters, however, if founders at that stage are not convinced of the necessity. A team that works on pre-revenue and sometimes pre-prototype decision-making has problems that feel far more urgent than end-of-life recovery, so a common assumption has been that circularity should wait until the company is up and running. Until recently, there was not much evidence either way.

What it looks like when founders design waste out

A cohort of hardware startups at the NextCorps Manufacturing Accelerator in Rochester went through a circular economy curriculum and was surveyed at the end. Nineteen of 44 teams answered.

Fifteen of the eighteen teams who answered the question regarding actions they have taken in relation to circularity indicated they had taken at least one concrete step, not just planned one. Five had written circular metrics like recycled content, repairability, or designed lifespan into their product requirements. Four had reconsidered a material or a supplier. Three had changed a design for disassembly, repair, or standardization. And on the self-rated confidence questions, the biggest gain reported across the cohort was in writing circular requirements into the product specifications, which is the skill that determines what actually gets built.

One team walked through a particularly robust set of design decisions they had made for their product, including flat-package design; diagnostics that run while the product is in use; compatibility with components available anywhere in the world; wear-tracking capability tied to automated alerts and replacement part logistics; and color-coded containers for the reusable parts. All of these design decisions contribute directly or indirectly to the elimination of several sources of waste. Flat-packing, for instance, cuts shipping volume and packaging material. Wear tracking catches failures before they turn products into disposed waste, and a product built from globally-available components is one that offers greater access to repair and service by providers in addition to the manufacturer.

Another team, building an industrial energy management platform, is now putting modular hardware architecture, serviceability, and end-of-life planning into its product roadmap. The timing is right because a joint projection by the International Renewable Energy Agency (IRENA) and the International Energy Agency (IEA) estimates that there will be up to 78 million metric tons of global solar panel waste by 2050. As a result, IRENA's standing advice is to lay the design and policy groundwork before that waste shows up, not afterward.

The changes made by these teams did not require any capital investment in retrofitting and retooling because all of them happened before there was anything to retool.

Why design belongs in pollution prevention

Designing waste out of new products makes sense in theory, but why should it become a standard practice?

Three reasons.

First, this is source reduction by the letter of the law. The U.S. Pollution Prevention Act's definition of source reduction includes reformulation and redesign as the number one source of reduction, and a single-use device that never reaches the market leaves nothing behind to divert, treat, or dispose. Nearly all of a single-use medical product's impact is locked in at production, so taking the disposability out of the design solves most of the problem in a single decision.

Second, the regulatory side of this is already enacted in New York State (NYS). The Electronic Equipment Recycling and Reuse Act puts end-of-life responsibility for covered electronics on manufacturers, who have to register with NYS Department of Environmental Conservation (DEC) before selling electronic products in the state and then report every year. Seven states now run Extended Producer Responsibility (EPR) packaging programs, which require compliance by any New York company shipping products to them. New York's own EPR packaging bill stalled in the Assembly again in 2026 after clearing the Senate, so nobody knows what the in-state rules will eventually be. However, a founder in the NextCorps accelerator program who has already sketched out take-back operations and reverse logistics is ready, and six teams in the cohort had started that homework.

Third, the material spreads on its own. Eight teams said they had raised circularity with a supplier, a partner, or an investor, which means that the ideas are walking into supply chains and pitch meetings without anyone from a pollution prevention program in the room.

This evidence comes with limits, since it is based on the experience of one cohort in one accelerator program that is self-reporting answers. This initiative shows that the approach can work, but not necessarily that it always does. The larger point, however, doesn't hang on one program. Accelerators, incubators, and university venture programs put dozens of companies in a room at the one moment in their growth when design decisions are still cheap to change. That window closes the day the tooling order goes out.

A medical device planned as fully disposable going to containing only four disposable pieces is a small story on the day it happens. But carry this change across every unit that company ships over the next decade, then imagine similar changes across all the hardware ventures moving through New York State's early-stage programs in a given year, and it becomes one of the cheapest forms of prevention available to startups and new manufacturers.

The leverage for pollution prevention, we know, always lives upstream. Design is as far upstream as it goes.

Funding provided by the Environmental Protection Fund as administered by the New York State Department of Environmental Conservation. The opinions, results, findings and/or interpretations of data contained herein are the responsibility of Rochester Institute of Technology and do not necessarily represent the opinions, interpretations or policy of New York State.