by Scott Cassel, CEO and Founder of PSI
As of last year, more than 40 companies are working to develop or manage “chemical recycling” projects in the United States. This month, ExxonMobil announced 13 projects in the pipeline with the capacity to recycle 1.1 billion pounds of plastic by 2026. And as many as 20 states have enacted laws that allow chemical recycling plants to be permitted as manufacturing facilities. Yet 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.
Our new report, “Making Sense of Chemical Recycling,” aims to fill that gap. The report will publish on November 17th, the same day that we will 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 which, if any, of these technologies can support a sustainable economy, prevent waste and pollution, and curb greenhouse gas emissions.
PSI works with state, local, and tribal government Members in 40 states; to write the report, we called on our Members to help draft a set of criteria through which governments might assess chemical recycling technology permits and legislation. The report also includes an overview of the types of technologies currently considered under the chemical recycling umbrella.
We recognize that this conversation is controversial. Producers claim that these projects leapfrog mechanical recycling by enabling infinite processing, while environmental groups allege that they undermine efforts to reduce plastic through upstream design and are simply another form of greenwashing. 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” rather than as a manufacturing plant under less stringent regulations. 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, many acknowledge that 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. 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.
In the four existing packaging EPR laws, the point is already decided: PSI’s model legislation for packaging EPR, which informed laws enacted in California, Colorado, Maine, and Oregon, specifies that incineration and “waste to fuel” or “waste to energy” technologies, which burn material for energy, should be considered disposal.
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 we hope to facilitate with governments, NGOs, and companies running or planning chemical recycling facilities. It is a first step in a desperately needed dialogue where all stakeholders can present their interests and perspectives. Only then can PSI develop specific recommendations for how EPR can be applied to emerging chemical recycling technologies.