While the US Environmental Protection Agency (EPA) considers how to improve the national recycling system, there has been a recent burst of recycling legislation at the state level. Many state legislatures passed bills in the last month to limit plastic usage, set minimum recycled content in plastic packaging, and expand recycling infrastructure (FPF reported). Oklahoma’s SB 448, Arizona’s SB 1156, and others specifically include significant support for chemical recycling facilities. While chemical recycling could potentially help keep non-mechanically recyclable plastic from entering a landfill, it is currently debated whether it should count as recycling when the output material is not the same as the input (true recycling), and the energy required and emissions are high.

Between November 2020 and March 2021, the EPA accepted comments pertaining to their 50% recycling rate by 2030 goal (FPF reported), including whether or not chemical recycling should be considered in the national recycling calculations. At the moment, plastic recycling rates are primarily from mechanical recycling processes, which has the most infrastructure in place for PET and HDPE plastics. Chemical recycling may use heat, pressure, or chemicals to break down plastics into fuels for combustion, or raw materials which can be used to synthesize new plastics.

According to comments from the American Chemistry Council, “advanced recycling processes that produce feedstock for new plastic, chemical products, waxes, and lubricants should count as ‘recycling,’ but feedstocks used for fuels should be classified ‘advanced recovery.'” However, the non-governmental alliance, Global Initiative for Incinerator Alternatives argues chemical recycling technology is too costly environmentally, because it releases toxic chemicals and GHG emissions, and “cannot economically compete with virgin plastics that would allow production to scale” (FPF reported). A joint statement released by a group of civil society organizations in July 2020 also proposed a set of steps for effectively regulating chemical recycling, including restricting the use of public funding only to chemical recycling projects that have lower carbon footprints than plastic production processes using virgin feedstock (FPF reported).


Jane Nishida (March 8, 2021). “Comment submitted by the American Chemistry Council (ACC).” Regulations.gov (pdf)

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Cole Rosengren (April 28, 2021). “State legislatures busy with plastics policy on shampoo bottles, chemical recycling and preemption.” Waste Dive

American Chemistry Council (April 19, 2021). “Oklahoma Becomes 11th State to Pass Legislation to Help Expand Plastics Recycling.”

Megan Quinn (April 19, 2021). “Minimum recycled content bill heads to Washington governor’s desk.” Waste Dive

Jared Paben (April 7, 2021). “EPA hears divergent opinions on chemical recycling.” Plastics Recycling Update

Public Commenters (November 2020 – March 2021). “Comments related to EPA-HQ-OLEM-2020-0443.” Regulations.gov

EPA (November 2020). “National Recycling Goal: Recycling Rate Measurement Comment Period.”