We need to get toxic chemicals out of plastic packaging, not abandon recycling 

Using mechanically-recycled plastics in some applications to make new plastic products can offer significant benefits over virgin plastic, including reducing fossil fuel extraction and impacts of disposal. However, there are problems with mechanically recycling plastics, not the least of which is the presence of toxic chemicals in the recovered material due to harmful chemicals added when it was originally manufactured. To protect human and environmental health and facilitate recycling to decrease waste and fossil fuel extraction, we must eliminate toxic chemicals from all materials at the point of production. 

Some alarming reports released in the past year raise serious concerns about toxic chemicals found in recycled plastics. Unfortunately, a dangerous misinterpretation of these reports points to plastics recycling as the problem, rather than targeting the actual source—the vast amount of harmful chemicals applied during manufacturing of the original plastic products. We urgently need to eliminate toxic chemicals from all products, including plastics, to address the sobering health risks caused by these toxic substances.

No matter what happens to these products at the end of their life—whether they’re burned, buried, or recycled—the toxic chemicals will outlive the product and continue to cause harm. The manufacturing, recycling, and disposal of these additives leave a noxious trail of air and water pollution and human health risks around the globe. Problematic chemicals like those found in mechanically-recycled plastic are in ALL plastic packaging—far more than the 9% currently recycled. To create the real change needed, we must focus upstream by reducing the use of toxic chemicals and production of problematic and unnecessary plastics in the first place. Targeting end-of-use tactics, such as mechanical recycling, distracts from the source of the problems and necessary solutions. 

Though we cannot recycle our way out of the plastic pollution crisis, recycling plays a critical role in addressing the problem. Like electric cars and solar panels, mechanical recycling is a positive environmental solution with environmental trade-offs that must be addressed. We can work to reduce those impacts while promoting the full suite of solutions needed to reduce plastic production and waste. 

AMBR has conditional support for, and concerns with, the use of recycled plastic content:

• Plastics cause harm at all stages of its life cycle. Plastic production imposes inequitable harm on fence-line communities during extraction and production, including acute and long-term health and reproductive harm and even death. Many of the chemicals in plastic packaging can leach into food or migrate through close contact (especially true for liquids like beverages and oils), affecting consumers, particularly vulnerable populations like children and the elderly. Burning, burying, or recycling these plastic products won’t make those toxics “disappear.” Further, throughout its production and use, plastic sheds microplastics into the air, water, soil, and our bodies, the impacts of which are largely unknown, creating a high-risk experiment for future generations. 
• Unfortunately, plastic is here now. Regardless of the science, risks, and how we feel about it, plastic is present in ever-increasing quantities and likely here to stay for some time. The exponential growth of plastic production is daunting, and we can’t transition to fully reusable and refillable systems fast enough. As we transition, transparent and authentic recycling is part of the answer to mitigating harm now while we work toward the true solutions of reduction.

• Mechanically recycling some plastics decreases harm. At AMBR-member Eureka Recycling’s Minneapolis facility (one of the more than 350 recycling facilities across the country), more than 500,000 PET bottles are sorted and shipped to be turned back into new bottles every day. Sending those bottles to be burned or buried would increase the harm and toxic load on the overburdened communities living near waste facilities.
  
• Mechanical recycling of plastics can reduce fossil fuel extraction. Plastic is cheap and, from the perspective of manufacturers, outperforms other materials in many ways. Most companies will simply buy more virgin plastic if we stop all recycling, increasing extraction of fossil fuels.
  
• Mechanical recycling of plastics can reduce energy use and GHG emissions. Increasing the recycled content of any product reduces its environmental impact, from energy and water use to the effects of extraction. Recycling PET and HDPE plastics can save 75-88% of the energy used to make virgin plastics and reduce GHG emissions by 70%.
  

There are critical steps we should take to improve the safety of mechanically recycling plastics: 

1. Determine how toxic chemicals end up in recycled products through additional study. We need more real-world empirical data on how these chemicals are getting into plastic products and how to address this through product design or improvements in plastics sorting, washing, grinding, extrusion, and more. 
2. Acknowledge that all recycled plastics are not the same and craft solutions accordingly. For decades, we have known that computer plastic contains highly toxic flame retardants and other toxic chemicals. If mixed with HDPE shampoo and detergent bottles, it will still be toxic and should thus never be used to make toys. Toxic computer plastic should be eliminated from production, and legacy plastic should be disposed of safely. This is a very different set of issues from food-grade rPET, which needs different and specifically-targeted solutions, such as addressing the PFAS used as a mold release agent that accumulates on plastic beverage bottles. We need to make sure to look at each plastic recycling stream appropriately to craft the right solutions.
3. Focus resources and policies on scaling-up non-toxic reuse and refill solutions: Recycling is a place to start, not the end goal. “Closing the loop” on the current (and projected) volume and toxicity of the plastic packaging stream is not nearly enough. We must make the “circle” of the circular economy we are working toward increasingly and exponentially smaller if we are to build toward more just, healthy, and resilient communities. 
4. Eliminate problematic and unnecessary plastics: Stopping the use of the most problematic plastics not only reduces the health impacts from the use of that material, but improves the safety of more recyclable plastics as well. For example, it is known that if PVC gets into PET recycling streams (either through PVC labels or imperfect sorting where PVC gets into a PET bale), it can create benzene in the rPET. 
5. Prohibit claims of recyclability on ANY type of plastic container that has held hazardous substances: Plastics absorb toxic chemicals, and things like pesticide containers, for example, should never be labeled with a recycling symbol. Even better, known poisons should not be packaged in plastic, which can absorb toxic chemicals (unlike metal or glass), to reduce the chance that recycled plastic itself will be contaminated. 

AMBR is committed to working with our allies and colleagues across the supply chain to sharpen focus on the elimination of toxic chemicals from plastic packaging before they become a problem in the recycling stream. We cannot rebuild credible, transparent recycling systems for packaging without changing the way we design the packaging from the start.