APR wants chemical recycling limited to plastics-to-plastics

The Association of Plastic Recyclers wants to see the definition of chemical recycling limited to circular loops that make new plastic from discarded waste polymers, a position at odds with some other industry groups.

In a policy statement released June 1, APR is pushing a narrow definition of chemical recycling, in contrast with other industry groups like the American Chemistry Council, which say broader rules will speed development of the new technologies.

The difference of opinion between the two plastics groups comes amid growing debate about how to regulate chemical recycling.

ACC, for example, organized a news conference in March to urge Congress not to restrict the technology. At the same time, ACC has led a nationwide push to pass pro-chemical recycling laws in states legislatures.

APR President and CEO Steve Alexander said his group, which primarily represents traditional mechanical recycling companies, felt that with the increasing attention it wanted to clearly state its position: it supports chemical recycling, but should only be called recycling if it goes back into new plastics.

"If it's not back to resin, it's not recycling in our opinion — it's a conversion technology or a diversion technology," he said.

A particular concern for the recycling group is that it believes chemical recycling that uses waste plastics to make fuels or oils should not be considered recycling.

"Feedstock to fuel or energy should not be considered recycling," APR's policy statement states. "Chemical recycling should only include processes converting resin feedstock to resin."

APR sees business implications for its members, both in laws and for recycling markets.

Too much focus on chemical recycling could lead to manufacturers "disregarding" design-for-recycling guidelines for their packaging, if they feel that new technologies can solve any packaging disposal problem, Alexander said.

As well, there's a political component — ACC and other industry groups have secured legislation in 13 states that ACC says is crucial to creating a level playing field for the technology, which it calls advanced recycling.

But Alexander said APR is concerned that legislation could count turning waste plastics into fuels as recycling.

"When you look at some of the legislative activity that's out there, which allows for under the definition of some sort of recycling, to go into fuels or oils, we oppose that," he said. "We don't consider that recycling."

Washington-based ACC, which includes a subgroup that advocates for the new technologies, argues that advanced recycling should be defined more broadly than simply waste plastic going back into new plastic.

Joshua Baca, ACC's vice president of plastics, said in a statement that a key benefit of the technologies is their ability to break waste plastic back down into monomers, overcoming technical limits of mechanical recycling and allowing it to be more widely reused.

He said ACC and its Advanced Recycling Alliance for Plastics (ARAP) do agree with APR that plastic-to-fuels should not be labeled recycling. But they believe other non-resin uses should be.

"ACC agrees that the production of fuels should be counted as recovery and not recycling," Baca said. "However, we disagree that advanced recycling should be limited to production of plastic resins. A major benefit of advanced recycling is the ability to produce a versatile mix of useful products including chemicals, additives, waxes, lubricants and coatings — in addition to new plastics."

The two groups even differ on terminology: APR refers to it as "chemical recycling" throughout its statement, while ACC calls it "advanced recycling."

Whatever it's called, the technologies are a key part of the plastics industry's strategy for increasing low recycling rates, making plastics more circular and pushing back on bans and other restrictive legislation.

ACC and industry executives including Dow Chairman and CEO Jim Fitterling held an online news conference in March to oppose any attempts in Congress to limit development of advanced recycling technologies through legislation.

Environmental groups have consistently opposed the technology in political debates, arguing it's not economically viable and that attention should be put on cutting back on fossil fuels and single-use packaging.

Industry groups, though, see it as crucial to recycling widely used packaging materials like multilayer plastic films, which can be economically and technically challenging to recycle.

ACC said its push in state legislatures is important for helping advanced recycling grow.

"Policymakers in 13 states have recognized that facilities that utilize an advanced recycling process should be regulated as manufacturing facilities that can remake used plastic into a variety of new and useful products — not just new plastics," Baca said. "We do not support legislation that limits advanced recycling to plastics only. Fuels produced from advanced recycling processes should be counted as recovery not recycling."

The website for ARAP does give prominent mention to the plastics-to-fuel option, however, as part of advanced recycling.

The first goal of the alliance listed on its main web page is to "grow awareness of the benefits of advanced plastics recycling technologies that convert post-use plastics into chemicals, fuels and other products."

A 2019 ACC study found that the United States could support 260 advanced recycling facilities making a variety of products, including feedstocks for new plastics and transportation fuels.

Alexander said APR is concerned that too much focus on chemical recycling could mean that big consumer product companies pay less attention to designing their plastic packaging to be more recyclable.

The APR policy statement called design for recycling "essential for a circular economy" and said that "chemical recycling should not result in packaging manufacturers disregarding design for recycling guidelines."

ACC said it supports those guidelines and said many brands are redesigning their packaging for greater recyclability.

"ACC is a long-time supporter of APR, and as an associate member we support broad adoption of APR's design for recycling guidelines," Baca said. "But the fact remains, if we want to create a circular economy for plastics, we need both advanced and mechanical recycling processes."

In an interview, Alexander several times expressed concern over what he called a narrative that chemical recycling is a "silver bullet" solution.

"I think it's creating the narrative that this definition is somehow the preferred pathway going forward and it's going to solve all the issues," Alexander said. "There's this concept that advanced recycling technologies are somehow better and it means that traditional recycling is not working, which is not the case in any way, shape or form."

He said there are key unresolved questions about whether enough of the proper feedstocks can be collected for chemical recycling.

"‘We know that chemical recycling works, but up to now the chemical recyclers that are part of APR have worked primarily with feedstock that is the byproduct  left over from processing postconsumer material," Alexander said.

APR's policy statement said chemical recycling can expand recovery of "materials that are not recycled by mechanical processes today."

As well, he contended that mechanical recycling has a lower environmental footprint than chemical recycling, given the energy needed to chemically break down polymers.

"I don't think there's any question that mechanical recycling has a much lower carbon footprint and a much lower energy utilization than in chemical recycling," Alexander said.

Some groups have supported that point. A 2016 report from the Ellen MacArthur Foundation said that mechanical recycling uses "significantly less energy" than chemical recycling.

EMF said the two technologies should not compete for feedstocks and that chemical recycling should be used for mixed, lower quality or multi-material plastics.

But ACC argued it's difficult to compare the greenhouse gas footprints of the different technologies and said they are complementary.

"Direct comparisons of GHG footprints are not useful," Baca said. "Mechanical processes convert homogeneous plastics like bottles into mainly durable applications such as railroad ties, plastic lumber and carpet."

"There are often limits to mechanical recycling solving the entire plastic waste challenge, which is why we believe both are needed," Baca said. "Advanced recycling processes convert heterogenous mixes of plastics back into virgin quality plastics that can go into any application, including food- and pharma-contact and medical-grade packaging."