Recycling | Recycling Policy ·
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Strong standards can distinguish proven solutions from promising ideas by setting clear expectations, creating accountability, and ensuring environmental claims are supported by evidence. When developed with rigor and independence, they can protect communities, inform decision-making, and build public trust.
But voluntary, privately developed certification standards are not public policy and cannot substitute for laws, regulations, or government oversight. Decisions about what qualifies as recycling and what environmental and public health protections facilities must meet have significant public consequences and should be established through transparent, accountable public processes.
Voluntary certification can provide an additional layer of accountability—but only if it sets a meaningful bar above basic legal compliance and requires clear evidence that certified facilities meet it.
That is why the release of the Responsible Chemical Recycling Standard from SCS Standards deserves careful attention.
The standard says it establishes a voluntary framework for certifying “responsible chemical recycling” operations by bringing greater transparency and consistency to an industry that has long faced questions about its environmental and economic performance.
But after reviewing the standard, we believe it raises a two fundamental question:
First, has chemical recycling demonstrated that it can consistently function as recycling—turning discarded plastic into usable material that becomes new products at meaningful commercial scale? And second, if it can, has it demonstrated that it can do so responsibly?
For AMBR, certification should require clear evidence of both.
Responsibility Should Be Demonstrated, Not Assumed
Chemical recycling has been promoted for decades as a solution for plastics that cannot be mechanically recycled. It has been presented as a way to expand recycling, reduce waste, and create a more circular economy.
Yet all of their claims remain largely unproven at commercial scale. Questions persist about operating reliability, material yields, environmental performance, energy consumption, economic viability, product destinations, public health, worker and community impacts, and whether chemical recycling complements or actually competes with existing mechanical recycling systems.
Numerous announced projects have been delayed, scaled back, or ceased operations, while others continue to rely on significant public subsidies or preferential policy treatment to remain operational. Claims of recycled content frequently depend on mass balance accounting rather than physically traceable material flows; greenhouse gas benefits often rely on lifecycle assumptions that remain contested; and economic viability is commonly tied to tax credits, grants, or producer-funded incentives rather than revenues generated through the sale of recycled materials alone. These realities make it difficult to conclude that chemical recycling has demonstrated the environmental or economic performance necessary to justify certification as a “responsible” recycling solution, or even recycling.
Despite these unresolved issues, the SCS standards begin with the assumption that chemical recycling is an appropriate and effective recycling solution. It establishes baselines for management systems, emissions reporting, chain of custody, community engagement, and continuous improvement, but it does not require facilities to demonstrate that they consistently return recovered materials to new products, achieve minimum material recovery rates, or deliver superior environmental outcomes compared with existing recycling systems.
Management systems are important.
Reporting is important.
Continuous improvement is important.
But none of those alone demonstrate that a technology is solving the problem it was designed to solve.
A facility should not be considered “responsible” simply because it documents its work and records whether it has impact, both good and the bad. Responsibility should be demonstrated through measurable outcomes.
The Standard Focuses on Process Instead of Performance
Throughout the standard, facilities are required to develop plans, establish management systems, measure impacts, create improvement programs, and report various operational metrics. These are all reasonable components of responsible facility management. But that is precisely our point: this is largely a facility management standard, not a performance standard. It focuses on whether a company has systems in place to manage its operations, rather than whether the technology itself meets clear standards for responsible recycling performance.
For example, the Management System requirements (Section 4.1) focus on documented procedures for legal compliance, stakeholder engagement, risk management, process control, emergency response, supplier management, corrective actions, and management review. These are important business management practices. They demonstrate that a company has systems in place, but they do not demonstrate that chemical recycling delivers meaningful recycling or environmental outcomes—or that it does so in a particularly “responsible” manner.
The same pattern appears throughout the environmental requirements. Facilities must establish environmental commitments and measure energy use, emissions, water consumption, waste generation, and greenhouse gas emissions. Under the “Plus” criteria, facilities are required to demonstrate improvement relative to their own baseline over time. Continuous improvement is important, but improvement from a self-established baseline is not the same as meeting an objective standard of environmental performance. The standard does not establish minimum performance thresholds or specify how much improvement is necessary to demonstrate responsible performance.
Most notably, the standard does not establish minimum requirements for demonstrating that chemical recycling is actually achieving recycling outcomes. It does not set minimum recycling yields or require facilities to demonstrate that recovered materials are consistently transformed into new products. It does not clearly distinguish between materials that remain in the material economy and those ultimately used as fuels or other non-circular outputs. Nor does it require facilities to demonstrate measurable environmental benefits compared with existing recycling systems or virgin plastic production.
That distinction matters. A facility with relatively poor environmental performance could potentially achieve certification by documenting its impacts, establishing management systems and improvement plans, and demonstrating progress from its own starting point. Responsibility, however, should not be defined primarily by improvement relative to a facility’s previous performance. It should be measured against objective standards that demonstrate the technology is actually recycling materials, protecting people and communities, and delivering meaningful environmental benefits.
Follow the Material, Not the Accounting Scheme
The central purpose of recycling is to conserve natural resources by turning recovered materials into new products. That process should be transparent and verifiable.
The standard allows different ways of demonstrating that recycled materials end up in new products. Some approaches physically track the material from one step in the supply chain to the next. Others rely on accounting methods rather than following the material itself.
This distinction is especially important for chemical recycling. Unlike mechanical recycling, where recovered materials can be physically tracked into new products, chemical recycling frequently relies on accounting methodologies to support recycled content claims after recovered materials enter large, integrated petrochemical manufacturing systems. As a result, a product may be marketed as containing recycled content even when the recycled material itself cannot be physically traced to that product.
A responsible recycling standard should clearly distinguish between material that can be physically traced into new products and claims that rely on accounting methodologies.
For consumers, policymakers, and brands, recycling should represent a physical outcome, not simply an accounting exercise.
If a product carries a recycling-related claim, that claim should be supported by transparent, physically traceable material flows.
The Standard Assumes Complementarity Without Requiring It
The standard repeatedly positions chemical recycling as complementary to mechanical recycling, but the standard does not require facilities to demonstrate that they strengthen existing recycling systems.
For example, facilities are only required to demonstrate that at least one recovered material stream would otherwise have been landfilled, incinerated, leaked into the environment, or remained unrecyclable within a geographic region.
That leaves several important questions unanswered.
- Are facilities processing only residual materials that truly lack viable mechanical recycling pathways?
- Are they competing with existing mechanical recyclers for valuable feedstocks?
- Could materials that are mechanically recyclable instead be diverted toward chemical processes?
Any new technology claiming to complement that system should be required to demonstrate that it strengthens, not competes with, existing recycling infrastructure.
Transparency Should Be the Baseline, Not an Optional Achievement
Transparency is one of the stated goals of the standard. Yet many of the disclosures most important for evaluating chemical recycling performance are reserved for optional “Trailblazer” recognition rather than required for Core certification.
For example, public reporting of conversion rates, total recovered material processed, product carbon footprints, and life cycle assessment summaries are treated as optional achievements rather than basic certification requirements.
These are not peripheral metrics. They provide critical information for evaluating how much recovered material a facility actually processes, what happens to that material, and what environmental impacts result.
Research increasingly demonstrates that assessments of chemical recycling can fail to account for its full environmental and health impacts, including emissions, hazardous byproducts, waste streams, and downstream impacts. These limitations are compounded by a lack of transparency from chemical recycling companies about their operations, material flows, and final outputs, making independent evaluation difficult. A certification standard should help close these information gaps, not allow critical performance information to remain optional.
Transparency should be the baseline for a standard claiming to certify “responsible” chemical recycling, not an advanced level of achievement.
Community Protection Requires More Than Facility Management
Chemical recycling facilities are frequently proposed in communities already experiencing disproportionate industrial pollution.
While the standard includes requirements for community engagement, grievance mechanisms, and environmental management systems, it does not require evaluation of cumulative environmental burdens experienced by surrounding communities.
Communities experience pollution cumulatively. They do not experience emissions one permit at a time or one facility at a time. A standard seeking to define “responsibility” must account for cumulative impacts, not simply individual facility performance.
Responsibility Must Be Earned
Voluntary standards can play a role in improving industrial practices, but they should not be used to establish credibility for technologies that have yet to demonstrate they can consistently deliver the outcomes they promise.
Until chemical recycling can consistently show that it protects human health, complements proven recycling systems, operates transparently, delivers meaningful environmental benefits, and creates genuinely circular material flows at commercial scale, labeling it “recycling” or “responsible” risks creating confidence that has not yet been earned.
Strong standards should be mandatory and challenge technologies to meet that bar.
They should not lower the bar to accommodate them.