In November 2020, the Environmental Protection Agency (EPA) announced a national goal of increasing the U.S. recycling rate to 50% by 2030. As part of this process, Great Forest submitted comments to the EPA on recycling rate measurement methodology, drawing on our extensive work over 30 years of waste data collection and analysis.
“Overall, we want to avoid the problem of double-counting, and to ensure all recycling processes are verified and not generating environmental problems. We recommend following the circular economy as a guide: the processes included should be eliminating waste and pollution and keeping products and materials in use. Contamination in the recycling stream should be reported,” says Anna Dengler, Senior Sustainability Advisor at Great Forest.
Here is a summary of our recommendations on recycling rate measurement for the National Recycling Goal.
Great Forest believes that all materials listed should be included, with the possible exception of construction and demolition (C&D) waste. The reason to potentially exclude C&D materials is due more to the recycling process of those materials, than the materials themselves. C&D recycling does not usually go back into the construction process for continual use/reuse. If C&D recycling is included, the best way to ensure materials are recycled are to use data from certified recyclers.
Material Management Pathways:
Although we would hope that there would be data available on all waste diversion pathways, the goal of recycling is to create a circular economy. For the purposes of the National Recycling Rate, beneficial uses of materials should not be considered recycling if they do not incorporate recycled materials back into industry and back to consumers.
For example, in recycling a plastic bottle, the plastic is recycled if it becomes a new plastic item staying within the consumer marketplace. That plastic bottle is not recycled if combusted for energy production, a separate industry from consumer plastics. Furthermore, once the plastic bottle is combusted, that is the end of the plastic’s life, and there is no further possibility of recycling that plastic.
Our hope is that the National Recycling Goal will help in efforts to increase domestic markets. However, we don’t want to cut ourselves off from the global economy. The main issue has been in shifting the U.S.’s responsibilities to other countries. In that regard, international recycling data should be subject to verification, alongside tracking contamination and landfilled or burned material of the recyclables accepted.
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