The US Environmental Protection Agency (EPA)recently proposed a rule that would weaken protections under the Clean Air Act by redefining pyrolysis as something other than incineration.
Let’s be clear: pyrolysis is incineration. The EPA is not having a scientific debate with this proposed rule—it’s a policy maneuver with real consequences for air quality, public health, and the future of recycling.
Today, thermal waste processes like pyrolysis are subject to stricter oversight when classified as incineration, including emissions standards, monitoring, and permitting requirements. The proposed reclassification puts those protections at risk.
What is Pyrolysis?
Pyrolysis is a thermal process that uses high heat to break down plastic in the absence of oxygen. It may sound different from traditional incineration, but it’s not where it matters most.
Pyrolysis:
- Requires high heat to process waste
- Breaks down materials into fuels, gases, and chemical byproducts
- Results in emissions and hazardous outputs
- Destroys the original material rather than recovering it
Whether oxygen is present or not does not change the fundamental reality. This is a burn-based system. It is waste-to-fuel. It is material destruction, not a circular solution.
Changing its classification doesn’t change those facts.
Why the Definition Matters
Keeping pyrolysis within the definition of incineration is not about semantics, it’s about preventing harm.
Changing the definition would:
- Open the door to public subsidies and incentives intended for real solutions like recycling
- Grant legitimacy in policy frameworks like Extended Producer Responsibility
- Expand facility siting in overburdened communities with fewer environmental protections
- Weaken air permitting and emissions oversight
- Allow facilities to bypass stricter incineration regulations
This is how false solutions scale.
The View From the Pile
For those of us doing the work of recycling every day, this isn’t abstract. We’re the ones sorting the materials. We know what is actually recyclable, what contaminates the system, and what has no viable end market.
The Risk to Real Recycling
Redefining pyrolysis misleads the public, and it actively undermines proven systems and policy solutions.
It diverts:
- Attention away from reduction and reuse
- Investment away from mechanical recycling
- Accountability from producers to design better materials
And it sends a dangerous signal that we can manage unlimited plastic production downstream when we absolutely cannot.
Recycling alone will not solve the plastic crisis. And pyrolysis is not recycling or manufacturing in any meaningful circular sense.
Health, Environmental, and Justice Implications
And the impacts don’t stop at the system level. Thermal processes like pyrolysis carry real risks:
- Air emissions and toxic byproducts
- Hazardous residuals that require disposal
- Siting in overburdened communities already facing disproportionate pollution
Communities are being forced to bear the cost of a system designed to justify continued plastic production. We should not redefine pollution as progress.
What Should Happen Instead
If we are serious about protecting communities and building systems that reduce extraction, the path forward is clear. Pyrolysis should remain classified as incineration.
That means that pyrolysis is:
- Regulated as a waste-to-energy or disposal technology
- Subject to strict air and environmental protections
- Excluded from recycling definitions and targets, as well as from any manufacturing incentives and green subsidies, including within EPR structures
- Evaluated transparently for its full environmental and health impacts
At the same time, policy should focus on what actually works:
- Reducing plastic production
- Eliminating toxic chemicals from materials
- Designing for reuse and recycling
- Scaling reuse systems
- Strengthening real recycling where it is proven and safe
The Bottom Line
This is a line we cannot afford to blur. If it burns waste and turns it into fuel, it is incineration.
Rewriting definitions will not fix a broken system. It only makes it intentionally harder to tell the truth about it.
Read AMBR’s full comments to the EPA on their proposed reclassification of pyrolysis.