In December 2019, the European Federation for Waste Management (FEAD), the representative body of the private waste management and resource industry, published the results of its analysis of chemical recycling. Chemical Recycling Europe (ChemRecEurope) recently released a statement clarifying some observations from the FEAD document.
First and foremost, ChemRecEurope emphasized that chemical recycling complements other recycling processes and is one of the solutions for tackling the plastic waste issue. When mechanical recycling is unable to treat the polymer waste (or cannot do so in an economically viable manner), chemical recycling provides a unique opportunity to convert difficult-to-recycle waste streams into high-quality secondary raw materials. Unlike mechanical recycling, chemical recycling comprises different technologies, which makes it necessary to build a common understanding of the chemical recycling concept — including its definition — across the plastic value chain. ChemRecEurope supports any initiative to reach this common understanding.
At one time during the recycling discussion as it relates to the “circular economy,” there was a question as to whether converting plastic from its original product form to anything other than another similar product would qualify as “recycling.” I posed that question to Mohammad Hayatifar, PhD, Secretary General of ChemRecEurope.
Hayatifar wrote back that the EU Waste Framework Directive defines recycling as “any recovery operation by which waste materials are reprocessed into products, materials, or substances, whether for the original or other purposes. It includes the reprocessing of organic material but does not include energy recovery and the reprocessing into materials that are to be used as fuel for backfilling operations . . . .”
This definition, said Hayatifar, is “technology neutral and includes both mechanical and chemical recycling. Output of chemical recycling might be a chemical product and a substance or chemical mixture that can be used as secondary raw material for the production of new products. This does not necessarily mean that it is not circular,” said Hayatifar.
Hayatifar drew the following example:
He then emphatically stated, “Please note that energy recovery is not recycling.”
ChemRecEurope welcomes the FEAD’s conclusion on the definition of recycling in the Waste Framework Directive, which confirms that the current technology-neutral definition appropriately addresses “chemical recycling.” In line with the definition, use of the output as fuel automatically falls under the energy recovery level in the waste hierarchy.
As an industry, ChemRecEurope said that it is committed to provide, as soon as the development of the industry enables it, an independent life cycle assessment (LCA) to ensure that chemical recycling creates value for the environment. However, the organization highlights two main points:
- The CO2 footprint is not enough to assess the full impact of chemical recycling, and ChemRecEurope would run a more holistic LCA looking at a broader range of indicators, as well as understanding the quality and value of the recyclate produced (by mechanical and chemical recycling).
- The comparison with mechanical recycling is often complicated, given that it is a different feedstock going in and a different (higher-quality) product coming out, generally used for food-grade or other than plastic production applications. Chemical recycling is tackling issues such as contamination, removal of chemical and mineral additives, colors, multi-layered or mixed plastics that mechanical recycling cannot address without additional cleaning/washing steps and a thorough separation by polymer types, which is often not possible or too costly. The LCAs, therefore, are not directly comparable as they address different waste streams (input) and different demands (output).
ChemRecEurope commented that it regrets the use of unjustified statements regarding the impact of chemical recycling and its feasibility at industrial scale. Regarding the economic feasibility of chemical recycling, many large industrial plants have been announced and are in the pipeline in Europe with global partners, which would not have associated their names nor put chemical recycling as a key strategic direction if they did not believe in the feasibility at industrial scale.
Protecting consumer health and the environment is one of ChemRecEurope’s key strategic goals, and to ensure this it affirms that “secondary raw materials leaving the recycling plant should be in compliance with the relevant legal provisions such as REACH or waste legislation.”
“It is worth mentioning that chemical recycling is more tolerant toward contaminants and, thus, can treat low-quality feedstocks and produce high-quality secondary raw materials to be used even in food-contact applications,” the statement continued. “However, there is a lack of alignment between waste and product legislation that needs to be clarified.”
The growing demand for chemical recycling output from global brands and the chemical industry in order to reach the ambitious recycling targets for plastics set by the EU will require a strong collaboration with the whole plastic value chain. ChemRecEurope noted that the waste management sector has a “key role” to play in this chain: “We, therefore, call for a constructive collaboration to enable the development of new solutions, such as chemical recycling, to reach these goals.”