‘Chemical Recycling’ and Plastic Burning FAQ
Many so-called “chemical recycling” facilities–also called “advanced” or “molecular recycling” facilities–produce and release hazardous air pollutants and large amounts of hazardous waste that cause cancer, birth defects, reproductive problems, and damage to the brain, liver, and lungs. They are often located in communities where low income families and people of color live.1 These facilities, which convert plastic to fuels or other chemicals, actually recycle very little if any plastic and require continuous inputs of virgin plastic. The plastics industry wants people to think processes like pyrolysis, gasification, solvolysis and depolymerization are the solution to the plastic crisis, but “chemical recycling” is really just greenwashing to allow expansion of plastic production. Here we answer your questions about the problems of so-called “chemical recycling,” and provide information about real solutions to the plastics crisis.
The Basics
What is “chemical recycling”?
So-called “chemical recycling” (also referred to as “advanced recycling,” “molecular recycling,” “chemical conversion,” and “plastics renewal”) is an umbrella term for processes that convert plastics into either fuel, other chemicals, or other plastics. These toxic technologies include pyrolysis, gasification, solvolysis, and depolymerization.2
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Pyrolysis uses high temperatures and low-oxygen conditions to degrade plastic into a liquid/oil that is then refined into fuels or used to create other chemicals or plastics. Pyrolysis plants are regulated as incinerators under the federal Clean Air Act.
Gasification uses high temperatures with air or steam to degrade plastic into a gas called “synthesis gas” or “syngas” that can then be made into fuels or other chemicals. Gasification plants are regulated as incinerators under the federal Clean Air Act.
Solvolysis uses solvents and other chemicals to dissolve plastics and separate polymers so they can be used to create new plastics.
Chemical depolymerization uses thermal and chemical reactions to break polymers down into individual units (monomers) that can be made into new plastics.
Is “chemical recycling” actually recycling much plastic?
No. The products that result from “chemical recycling” are often not turned into plastic again, as the term recycling implies.3,4 A recent US Department of Energy study found that pyrolysis and gasification had very low yields, with only 0.1% to 14% of the inputs turned into outputs that are suitable for reuse as plastic.5 An analysis conducted by the Natural Resources Defense Council shows that most of the eight so-called “chemical recycling” facilities in the US are not actually recycling any plastic.
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In theory, both plastic-to-fuel and plastic-to-plastic processes could make new plastic from the liquid or gasses they produce.6 But plastic-to-plastic processes are currently not technically, economically, or commercially available.7,8 Therefore, in reality most of the so-called “chemical recycling” that is happening is largely just burning plastic.
For instance, Agilyx, a polystyrene pyrolysis plant in Oregon, is held up by the plastics industry as a prime example of commercial-scale “chemical recycling.” Agilyx takes waste polystyrene and uses pyrolysis to turn it back into styrene, which in theory would be used to make new polystyrene. However, this facility ships hundreds of thousands of pounds of styrene across the country to be burned instead of being converted into new plastic.9
What kinds of toxic emissions does “chemical recycling” release?
“Chemical recycling” generates hazardous air pollution and large amounts of hazardous waste.10 As noted in a July, 2022 letter signed by 35 members of Congress, “Chemical recycling facilities emit highly toxic chemicals, including benzene, toluene, ethyl benzene, xylenes, and dioxins, many of which are linked to cancer, nervous system damage, and negative effects on reproduction and development.”11
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Data from the Environmental Protection Agency analyzed by NRDC shows that in 2019 one facility alone generated nearly 500,000 pounds of hazardous waste that was then burned in six communities in the US.12 The main component of this waste was benzene, a known carcinogen which harms reproduction and the developing fetus, as well as other harmful chemicals such as lead, cadmium and chromium.13,14
How is it possible to burn plastic (during pyrolysis/gasification) without a flame or oxygen?
Combustion does not require a visible flame (according to the Clean Air Act an incinerator is any facility that combusts solid waste material, regardless of a flame). Combustion is a chemical reaction in which carbon and oxygen combine, creating carbon dioxide and releasing energy. As for the notion that there is no oxygen present in pyrolysis and gasification units, it is simply false.
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In the first stage of pyrolysis and gasification, where plastic wastes are heated to high temperatures in a low oxygen environment, it is impossible to exclude oxygen entirely, and thus some combustion occurs at this stage. The waste gasses created in the first stage of the pyrolysis/gasification process are vented to a second chamber, where they are burned in a normally oxygenated environment. For this reason, the U.S. EPA has recognized pyrolysis and gasification units to be incinerators since 1995.15
Are pyrolysis and gasification units considered incinerators?
Yes. As the name “pyro” implies, pyrolysis is combustion and the Clean Air Act defines an incinerator as any facility that combusts any solid waste material, regardless of whether it is part of a manufacturing process. Because pyrolysis and gasification units combust at least some of the waste that is fed into them, they are incinerators under the Clean Air Act. In fact, the EPA has already recognized that pyrolysis and gasification units are “two chamber incinerators,” as the first chamber heats waste to high temperatures and the second completes the combustion process.
Alternatives
What about “chemical recycling” that doesn’t require pyrolysis or gasification or generate fuels–for example, solvent-based methods?
Unfortunately, while plastic-to-plastic “chemical recycling” like solvent-based methods sound promising and are not generating fuels, they are actually extremely inefficient and not being performed by most facilities. They also still have significant health and environmental concerns. The solvents used are hazardous petrochemicals and these types of processes can generate harmful air pollution and large amounts of hazardous waste.
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For example, the PureCycle facility in Ohio is registered as a large-quantity hazardous waste generator with EPA, meaning it plans to generate 2,200 pounds or more of hazardous waste every month.16 This facility also is permitted to release volatile organic chemicals (VOCs) which are health-harming and contribute to smog formation. The facility burns some VOC emissions off in a flare, which releases greenhouse gasses and harmful combustion related air pollution like particulate matter.17
What about “molecular recycling”? Is that a promising new technology?
No. Molecular recycling is just the newest term created by the chemical industry to obscure plastic incineration and other toxic technologies that recycle little if any plastic, while generating large amounts of hazardous waste, air pollution and carbon emissions. It is essentially a synonym for other misleading terms such as “chemical recycling” and “advanced recycling.”
Is “chemical recycling” better than regular (mechanical) recycling in terms of the climate crisis?
No. To be a sustainable and equitable solution, any new recycling technology must not use hazardous chemicals, generate hazardous waste, or pollute communities who are low income, people of color, indigenous, or otherwise marginalized. “Chemical recycling” technologies do not meet these criteria. Several studies demonstrate that “chemical recycling” is not better than other forms of recycling.
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According to a recent study by the US Department of Energy (DOE), “mechanical recycling offers energy use and GHG emissions an order of magnitude lower than the other recycling technologies for all plastics,” as well as low waste generation, land use, toxicity, and water use.18
Other reports have also shown that mechanical recycling has lower GHG emissions than “chemical recycling,” landfilling, or incineration.19,20 The DOE report found that the “the economic and environmental metrics of pyrolysis and gasification are currently 10–100 times higher than virgin polymers due to low yields of monomers suitable for repolymerization and high energy requirements for the conversion and subsequent upgrading processes.”21
There is too much plastic for mechanical recycling to handle. Are there other solutions to address the plastic waste crisis?
Yes! The best solution to address the plastic waste crisis is to simply produce less plastic.22 There are other solutions as well, including through effective policies. The Break Free from Plastic Pollution Act is a federal bill that outlines practical plastic reduction strategies, providing a comprehensive template for policy solutions.23
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State and federal policies can also be leveraged to eliminate plastic waste. For example, unnecessary packaging can be eliminated through Accessories on Request laws, bills that promote using refillable bottles, and enforcing producers’ responsibility for transitioning their products to become reusable.24 In addition, local zero-waste initiatives can target waste reduction in communities.25
Phasing out problematic types of plastic that can’t be recycled, like polyvinyl chloride (PVC) and banning toxic additives will improve mechanical recycling by easing sorting and contamination issues. Another solution includes eliminating the use of certain plastics, such as single-use ones.26 Instead of using single-use plastic, transitioning products to becoming reusable can reduce negative impacts on health and the environment and increase prospects for economic benefits, including jobs.27
Are you saying we should eliminate all plastic, including the plastic that is used for life-saving medical devices, or essential products we all can’t live without, like our cell phones?
Plastic has a toxic lifecycle and the ultimate goal should be elimination. That said, some uses of plastic will be very challenging to phase out over the short to medium term. We should start by eliminating the most toxic, problematic and most easily substituted forms of plastic, as well as regulating and preventing the use of toxic additives in all plastics. For some uses (such as cell phones, which constitute a tiny proportion of all plastic use) we may need to continue to use plastic for the time being, but should promote efforts to redesign products to reduce plastic use, eliminate toxic additives, and identify safer materials. One approach that is beginning to be used by governments and companies wanting a better way to manage chemicals of concern is the Essential Use Approach, which could be expanded to address plastics.28
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Under the Essential Use Approach, uses of chemicals of concern (or in this case plastics) that are not essential for health, safety, or the function of society can be discontinued immediately. Uses of plastic that are essential and have no safer alternatives can remain in use temporarily, until a safer option is developed (better design of the materials, products, or processes).29 This approach would drastically and quickly reduce plastic production and use.
Policy
Isn’t “chemical recycling” a step toward a circular economy?
No. A true circular economy is based within a zero waste society, where everything produced and consumed can return safely to nature or society (non-toxic materials cycles). The most common “chemical recycling” processes lose so much of their feedstock’s volume (in the form of greenhouse gasses, toxic emissions, ash, and other fossil gasses and oils), that they do not return materials to the production cycle and thus are not circular. Other “chemical recycling” processes use and generate toxic chemicals and thus are not safe, and can’t be part of non-toxic materials cycles.
Where are “chemical recycling” facilities in the U.S.?
As of 2021, a review of publicly available data identified eight “chemical recycling” facilities in the U.S. located in Oregon, Ohio, Arizona, North Carolina, Indiana, Texas, and Georgia.30 According to the report, these facilities generate large quantities of hazardous waste, are permitted to release hazardous air pollutants, and are sited in communities that are disproportionately low income, people of color, or both.31,32,33
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These communities are often referred to as “fenceline communities,” and are largely excluded from the decision-making processes that lead to “chemical recycling” and plastic production facilities being built and operated in their communities.34 Further, fenceline communities often are already saddled with other types of dirty, polluting, toxic infrastructure and the dangerous health impacts they cause.
How big is the plastic waste crisis, and what’s the U.S.’s role in that?
Globally, an estimated 242 million metric tons of plastic waste is produced each year.35 The US is a top contributor to this global waste, producing an estimated 42 million metric tons of plastic waste in a single year. In fact, the US per capita plastic waste generation at 130 kg per year can be up to eight times higher than that of other countries.36 Despite these high numbers, the US only recycles about 8.7% of its plastic waste.37 Further, plastic production is increasing.
Plastic production is projected to increase 200% by 2035 and 350% by 2050.38 Because it is directly related to the amount of plastic that is produced and used, under current conditions plastic waste is expected to almost triple by 2060.39
Is “chemical recycling” a good use of taxpayer dollars – to invest in developing these innovative technologies?
No. Many “chemical recycling” projects that use taxpayer funds are not considered viable or likely to be built, according to a report by Greenpeace.40 The report also finds that $270,312,564 in taxpayer funds was spent on such nonviable projects. In other words, an incredibly large amount of taxpayer money is spent on technologies that will not necessarily work and are destructive to the environment, climate, and our health.
Should “chemical recycling” technologies be exempted from Clean Air Act emission standards to help solve the plastic problem?
No. Exempting “chemical recycling” technologies such as pyrolysis, gasification, and solvolysis allows them to emit toxic pollution without any control or monitoring requirements. This is not the right way to deal with the plastic waste crisis. A far less dangerous and destructive approach is to make less plastic.
Why shouldn’t “chemical recycling” be regulated under Section 112 of the Clean Air Act?
Incinerators such as those used for pyrolysis and gasification are currently regulated under section 129 of the Clean Air Act, which requires “maximum achievable control technology” (MACT) standards for all incinerators. In contrast, Section 112 only requires MACT for certain source categories,41 and gasification and pyrolysis units are not among them. The chemical industry has been lobbying for plastic disposal in pyrolysis or gasification incinerators to be regulated under Section 112 to avoid having to use the best control technologies available.
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Source categories under Section 112 include major sources of hazardous air pollutants – those with the potential to emit at least 10 tons or more of any single hazardous air pollutants or 25 tons of any combination of hazardous air pollutants per year. Chemical recycling incinerators emit smaller volumes of pollution – below the threshold that triggers regulation under section 112 – but that pollution is still highly toxic in very small amounts, containing things like benzene, cadmium, mercury, lead, PCBs and dioxin. Even if EPA created a new category for “chemical recycling” incinerators – an extremely unlikely scenario that would not happen for at least a decade if ever – getting EPA to impose meaningful limits on their toxic pollution would be uncertain and difficult.
Because gasification and pyrolysis incinerators are not major sources, EPA would have discretion to instead set do-nothing “generally available control technology” (GACT) standards for them. In the past, EPA’s GACT standards have, for example, required sources to do nothing more than conduct occasional tuneups of their equipment or follow the manufacturers’ instructions. Moving incinerators from Section 129 to 112 is the chemical industry’s clever way of getting out of pollution controls under the Clean Air Act. The EPA must continue to regulate these incinerators under section 129 of the Clean Air Act.
Plastic waste is currently defined as “waste” under the Resource Conservation and Recovery Act (RCRA). Isn’t it really a manufacturing feedstock that should be exempted from a definition as waste?
No. Wastes are used as manufacturing feedstocks in all kinds of industries -they are still wastes under the RCRA definition, which is any material that has been “discarded.” Treating plastic waste as something other than waste would mean effectively deregulating the dangerous processes, such as pyrolysis and gasification, that burn it to make fuel and other products. These facilities would then be allowed to emit highly toxic pollution into neighboring communities without monitoring or controlling their emissions and without accountability to the people who live in those communities.
There are now many state and federal bills that include a requirement that a significant percentage of plastic packaging be made from recycled plastic. Is that a good idea?
No. Supporting a recycled content mandate is a terrible idea. Scientific studies prove that the vast majority of household plastic waste cannot be safely recycled into food grade plastic due insurmountable toxicity barriers. The American Chemistry Council is pushing this requirement because pyrolysis of commercial film scrap can be made into oil which is fed into huge new plastic production plants and then the industry claims their products have recycled content. But household plastic waste can’t be used as feedstock because it is a mixed mess of many plastics with thousands of additives.
What should Congress do?
Congress should pass the Break Free From Plastic Pollution Act, the Protecting Communities From Plastics Act, and the Environmental Justice For All Act. They should reject any legislative proposal to weaken environmental protections from plastic waste, including in the Clean Air Act, Solid Waste Disposal Act, and Toxic Substances Control Act. Congress should also discontinue all direct and de facto subsidies including via the Department of Energy, and tax breaks and funding through the Inflation Reduction Act, and government purchase of most single use plastics. Instead, they should support funding for renewables and refillables.
Why does it seem like there is so much support for “chemical recycling” at the state level?
As of July, 2023 twenty-four states have adopted legislation to support “chemical recycling” and a few other states have introduced it, often from strong environmental state legislators. Many people want to find a solution for the plastic waste crisis and are hoping for an easy technical fix to the problem. The fossil fuel/plastic/chemical industry has been very effective at greenwashing processes they call “chemical recycling” and obscuring their toxic impacts.
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Because the industry was operating below the radar for a long time, many legislators never heard the truth about these practices and why they should not be supported or subsidized. Organizations fighting against plastics, toxics, and fossil fuels have since been trying to play catch-up on this issue and in the meantime industry has quietly gotten bad legislation passed in many conservative states.