Editor's note: This article has been updated with comments from the Institute of Scrap Recycling Industries.
Is anyone on board with the draft National Strategy to Prevent Plastic Pollution proposed by the Environmental Protection Agency (EPA)? It was released on April 26, 2023, for public comment, which ended on July 31. The consensus? There isn’t one.
To summarize, the EPA outlined three primary objectives in its proposed strategy:
- Objective A: Reduce pollution during plastic production.
- Objective B: Improve post-use materials management.
- Objective C: Prevent trash and micro/nanoplastics from entering waterways and remove escaped trash from the environment.
To state the obvious, the devil is in the details, and you can immerse yourself in them by reading EPA’s draft strategy. For their part, industry advocates and anti-plastics groups surprisingly agree that the draft falls short on solutions. Of course, they come to that conclusion from very different perspectives.
EPA should prioritize circularity, say industry associations
The Plastics Industry Association (PLASTICS) expressed disappointment with the draft strategy. “The EPA was directed by Congress in an overwhelmingly bi-partisan way to focus on post-consumer materials management and infrastructure, and instead the agency’s first stated objective in this strategy is to reduce the production of essential materials rather than address plastic waste,” said PLASTICS President and CEO Matt Seaholm. Lamenting a lack of focus on improving recycling infrastructure, Seaholm stressed that the plastics industry is investing billions of dollars to expand recycling capacity. “Understanding and addressing the essential nature of plastics and tackling environmental challenges should not be mutually exclusive,” he added.
The American Chemistry Council (ACC) also stressed that the national strategy should acknowledge the diversity of recycling technologies that provide “pathways to circularity for plastics.” It noted, in particular, in its comments that “one of the most promising areas of innovation to help achieve that goal and that the EPA should recognize is advanced recycling, which could enable the United States to recycle significantly more types of plastics." The ACC also cautioned the EPA against pursuing alternative materials that may have unintended consequences in terms of the environment, a point we have repeatedly made in PlasticsToday.
The Institute of Scrap Recycling Industries (ISRI) was more supportive of the EPA's objectives in its comments. “Given the complexity of the recycling system and plastics, in particular, there simply is no one single answer to the challenges facing plastics materials management in the United States," said ISRI President Robin Wiener. "We applaud EPA for a proposed strategy that recognizes there are many solutions that, taken together, can make a significant difference in keeping plastic out of the environment and, instead, circulate these valuable material resources into the manufacturing supply chain."
ISRI submitted a number of recommendations in its comments to EPA, including improving markets for plastics recycling through innovation, incentives, and other efforts; encouraging design for recycling initiatives; and excluding processes that convert materials to fuel or energy from being considered as a recycling practice.
Break Free from Plastics demands "blueprint for action"
The other side of the proverbial aisle will have none of it. More than 100 organizations in the Break Free From Plastic movement submitted a letter to the EPA on Aug. 1 insisting that it “transform its so far largely aspirational [strategy] into an effective blueprint for action.” In particular, it calls out “false solutions pushed by the plastics industry, including so-called ‘chemical recycling,’ an industry greenwashing term for harmful processes like pyrolysis and gasification.” (Chemical recycling is largely synonymous with advanced recycling.)
Break Free from Plastics also calls upon the EPA to:
- Include a cap on plastic production, eliminating unnecessary single-use applications;
- measure and reveal all the toxic chemicals in plastics;
- ban the most toxic polymers and plastic chemicals;
- strengthen and enforce laws protecting people who endure the detrimental impacts of living and working near plastic production and incineration facilities;
- address the role of plastics in exacerbating the climate crisis.
Trying to find common ground between the two camps is a seemingly impossible task. We’ll see where this all lands, but I suspect that the outcome of the 2024 election will give us the final answer.