The term “chemical recycling” refers to a wide range of technologies that process recovered plastic products (including packaging) into new plastic, as well as energy and/or fuel. These technologies have become a lightning rod: Producers claim they leapfrog mechanical recycling by enabling infinite processing, while environmental groups allege that they undermine efforts to reduce plastic through upstream redesign and are simply another form of greenwashing. Yet as of 2021, more than 40 companies are working to develop or manage chemical recycling projects in the United States, and 20 states — including, most recently, Missouri and New Hampshire — have enacted laws that allow chemical recycling facilities to be permitted as manufacturing facilities.

This is antithetical to the Product Stewardship Institute’s Extended Producer Responsibility (EPR) model legislation for packaging, which informedlaws enacted in Maine, Oregon, Colorado, and California and specifies that incineration and “waste to fuel” or “waste to energy” technologies, which burn material for energy, should be considered disposal, not recycling. Meanwhile, government policy makers tasked with passing legislation or issuing permits for chemical recycling projects lack criteria to assess their economic, environmental, and human health impacts.

A new PSI report, “Making Sense of Chemical Recycling,” aims to fill that gap. It will launch on November 17th, when PSI will also host an EPR Masterclass: Chemical Recycling presented by the Extended Producer Responsibility Alliance (EXPRA). The free webinar will feature a multi-stakeholder panel of experts from the United States and Europe, who will discuss the wide range of technologies that fall under the chemical recycling umbrella and consider criteria to determine which, if any, can support a sustainable economy, prevent waste and pollution, and curb greenhouse gas emissions.

Since 2000, PSI has helped enact 130 EPR laws across 16 product categories in 33 states — and all of them began with a background paper, which established the foundation for dialogue. As such, the purpose of “Making Sense of Chemical Recycling” report is to provide baseline information for a robust multi-stakeholder dialogue that PSI seeks to facilitate with governments, NGOs, and companies running or planning chemical recycling facilities. “Our chemical recycling report is a first step in a desperately needed dialogue so that all stakeholders can present their interests and perspectives,” said Scott Cassel, CEO and Founder of PSI. “Only then can we jointly develop specific recommendations for how EPR can be applied to emerging chemical recycling technologies.”

Concerns about chemical recycling are increasingly high-profile. In July 2022, U.S. Senator Cory Booker of New Jersey, along with U.S. Representatives Jared Huffman and Alan Lowenthal of California, published a letter to the Environmental Protection Agency (EPA) requesting that pyrolysis and gasification continue to be regulated as “municipal waste combustion units” under the Clean Air Act. The letter was signed by 35 other members of Congress and endorsed by over 45 environmental organizations.

Critics of chemical recycling point out that projects are typically situated in low-income communities of color and that they do not yet operate “at scale,” i.e., at the required size to solve the problem. However, waste management facilities, including mechanical recycling plants, are also typically situated in low-income communities of color and are also not operating at a scale to solve the problem: In the United States, only about 30% of the nearly 300 million tons of municipal solid waste generated each year is mechanically recycled.

“America has failed to address the plastic pollution crisis: The majority of plastics are currently landfilled, incinerated, exported, or leaked into the environment,” Cassel continued. “While the best way to address this crisis – as well as the linked climate emergency – is to eliminate the overproduction of plastics by ramping up waste prevention systems such as reuse and refill, we must acknowledge that production might not stop in the near- or mid-term. Strong recycling and waste management policies are also necessary to achieve a sustainable circular economy.”

For more information, visit www.productstewardship.us.

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