Constituent policy

What is the place of chemical recycling in EPR policy? Experts say it’s complicated.

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Although companies are more interested than ever in chemical recycling projects, clear guidelines for assessing a project’s potential impacts on the environment, health and economy are lacking, according to speakers at the a Nov. 17 webinar from the Product Stewardship Institute.

Further research could help solve the problem, but the waste and recycling industry must also recognize that chemical recycling is not a monolith, the speakers said. The term encompasses a collection of diverse technologies creating a variety of outputs.

Conversations about specific technologies and their impacts could help states make more informed policy decisions when considering how or whether chemical recycling fits into extended producer responsibility legislation, the panellists said. Here are some takeaways from the event:

More specific language could lead to more specific policies

According a report by Closed Loop Partnersmore than 40 companies are working on chemical recycling projects in the United States as of late 2021.

The chemical recycling industry “is incredibly diverse, not just from a technology perspective, but also from a business operations perspective and the different business decisions that operators will make in the marketplace,” said Paula Luu, Director senior project manager at the CLP Circular Center. Economy.

Each of these different approaches may have different economic viability and, depending on the technique used, may require varying policy measures, she said. As chemical recycling continues to evolve, policies should also evolve, she said.

One area where the industry needs to be more specific is the choice of terminology for different chemical recycling approaches. The plastics industry calls the technologies “advanced recycling”, while some experts prefer to refer to the specific technique used, such as pyrolysis, gasification or chemical depolymerization.

The Institute of Scrap Recycling Industries’ catch-all term for the variety of chemical recycling processes is “non-mechanical recycling”, but this term only applies when the process creates a new plastic as an end product, and not fuels or other non-plastic products. results,” said Cheryl Coleman, senior vice president of sustainability. ISRI’s position is that plastics-to-fuel projects should not be considered recycling. During the webinar, speakers from Closed Loop, PSI, and state governments agreed.

Embracing chemical recycling considerations in legislation

States are already devoting time and research to chemical recycling and its implications for legislation and policy. It’s an essential part of the EPR for the packaging conversation in Connecticut, said Tom Metzner, environmental analyst for the Connecticut Department of Energy and Environmental Protection. The state failed to pass an EPR bill for packaging last year, but it is confident the legislation could return next year.

“Clearly chemical recycling is one of the issues that we are going to have to address in our legislation,” he said. If an EPR bill for packaging is passed in the state, regulators will need to be prepared to consider whether chemical recycling techniques could play a role in managing end-of-life packaging.

“If the stewardship organization wants to offer chemical recycling, it will have to prove that it is the best environmental result. But we don’t have any standards to conform to,” he said.

DEEP has made it clear that it does not take into account the manufacture of recycled chemicals, a classification that 20 states have adopted through laws backed by the American Chemistry Council. laws in general to classify chemical recycling facilities as manufacturing facilities instead of disposal facilities.

PSI says the reclassification is “antithetical” to its EPR model for packaging legislation. Incineration and “waste-to-fuel” or “waste-to-energy” technologies should be considered disposal, not recycling, the report says.

Oregon’s chemical recycling policy is more about how the technologies fit into available methods of processing or disposing of plastics and other materials, said David Allaway, senior policy analyst for the Department of environmental quality of Oregon. Oregon spent a REP for packaging law in 2021, and “one of the elements of it is that producer organizations have an obligation to ensure that all materials collected for recycling are managed responsibly,” he said. Oregon’s policy is that mechanical recycling is “preferred” to chemical recycling, “but there are cases where both will be better than landfilling,” he said.

Further research could help quantify the total impacts of chemical recycling

Oregon’s chemical recycling policy is based in part on data from a recent life cycle assessment, though it’s only one piece of the puzzle when it comes down to it. It’s about creating a good policy, Alloway said.

Oregon DEQ life cycle analysis for expanded polystyrene, for example, shows that mechanical recycling requires less processing overall than chemical recycling, and that mechanical recycling uses less energy, he said.

Closed Loop also analyzed different chemical recycling strategies, and “mechanical recycling in all cases we evaluated has a smaller footprint,” Luu said.

Ongoing research and data collection must also consider the impact chemical recycling could have on nearby communities, said Vena Single, senior scientist at the Natural Resources Defense Council. This is especially true for communities that already experience overlapping health or environmental impacts with other industrial facilities that may be built in the same areas as chemical recycling plants, she said.

Polluting industries are concentrated in structurally disadvantaged communities,” she said. The NRDC generally considers many chemical recycling projects in the United States greenwashand Singla said more evidence is needed to show that new or expanded facilities will not create environmental and health issues such as air pollution.

“From a public health perspective, we really welcome any technology that contributes to a more circular, non-toxic materials cycle and doesn’t impact environmental justice communities,” she said. . “But the information we have indicates that current chemical recycling technologies do not meet these goals.”

Environmental impact assessment will likely be a big part of Connecticut’s EPR conversation, Metzner said.

“We’re trying to assess the information we’re getting from all stakeholders, assess the political landscape, and figure out what type of bill is best for human health and the environment that we can actually push through” , did he declare.