ACC letter urges the EPA to encourage the growth of advanced recycling

The association says technical and legal analysis demonstrates advanced recycling is not waste incineration.

plastics feedstock for pyrolysis

Dec. 16, America’s plastic makers submitted comments to the Environmental Protection Agency (EPA) regarding its advanced notice of proposed rulemaking on gasification and pyrolysis, also known as advanced recycling.

Regulating these technologies as incineration would contradict the very definition and established EPA interpretations of “incineration” and hinder progress toward increasing plastics recycling and achieving a circular economy, the American Chemistry Council (ACC), Washington, says.

“Advanced recycling is critical to realizing sustainability and recycling goals, including the EPA’s goal of recycling 50 percent of postuse materials by 2030 and America’s plastic makers’ goal of reusing, recycling or recovering all U.S. plastic packaging by 2040,” says Joshua Baca, ACC vice president of plastics. “EPA’s National Recycling Strategy, released last month, recognizes the potential of advanced recycling technologies to transform plastic recycling rates in the U.S. Regulating these technologies as solid waste incineration would be a step backwards.”

Businesses are using advanced recycling to create innovative new products made with recycled plastics, and incorrectly regulating advanced recycling as solid waste incineration would stifle similar innovations in sustainability, the ACC says.

Many states are regulating these facilities as manufacturing sites, and 14 states have reinforced this by enacting laws that ensure advanced recycling is regulated as a manufacturing process as opposed to solid waste disposal or incineration since 2017. More than $7.5 billion in advanced recycling projects have been announced or are operating in the United States, with the potential to divert 11.7 billion pounds of waste from landfills, the ACC says. Regulating advanced recycling as solid waste incineration would hinder these investments and create significant uncertainty in the market.

The ACC notes that advanced recycling facilities do not dispose of or incinerate the used plastics they receive. Rather, they convert them in the absence of oxygen into raw materials for new products, including virgin-quality plastics for food- and pharma-contact applications. 

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