Treasury chemical recycling ruling condemned in open letter

MPs and Peers from four major parties have called for the Treasury to reconsider its decision to classify the products of chemical processes as ‘recycled content’ in the Plastic Packaging Tax.

Written by A Plastic Planet, the open letter criticises the Treasury’s decision to treat the outputs of pyrolysis and gasification (two key chemical recycling processes) as being recycled, pointing to claims that the processes are unsustainable, energy-intensive, and carbon-heavy.

Recent parliamentary answers revealed that Treasury Ministers will classify the carbon intensive chemical processes as recycling under the tax, but A Plastic Planet’s open letter illustrates cross-party calls to close the ‘tax loophole’.

The open letter warns that big industry players are using chemical recycling as a ‘quick win’ to achieve plastic recycling targets and conform with the tax, with the Treasury’s classification facilitating this. However, in a separate parliamentary answer, the Department for Environment, Food and Rural Affairs (Defra) classified pyrolysis and gasification processes as ‘incineration’.

The letter goes on to assert that if plastic producers claim to reach the recycled content threshold for plastic packaging by using a process as carbon-intensive as chemical recycling, then the tax will fail to have the impact intended. These processes, A Plastic Planet notes, release ‘around 50 per cent of the carbon from plastics as greenhouse gases, and yield less than 10 per cent of [the material’s] original value in new content’.

Matthew Offord, Conservative MP for Hendon said: “The plastic packaging tax is a welcome development, which will see the UK lead the world on this subject. Nonetheless it is critical to ensure there are no get-outs or loopholes for plastic manufacturers. I urge the Treasury to carry out a detailed impact assessment of chemical recycling, and to recognise it as a form of incineration, in line with international standards.”

Caroline Lucas, Green Party MP for Brighton, Pavilion added, “This is a pivotal moment for the Treasury to defend the integrity of its own Plastics Tax. If major plastic producers are allowed to use chemical recycling as a way of avoiding paying tax on plastic items, then the whole system fails. The Treasury has made grandiose claims about this Plastics Tax – hailing it as world leading in the fight against plastic pollution.

“If Sunak really wants this to be the case then he must stop pandering to major plastic producers and acknowledge the harmful environmental impacts of chemical recycling. This starts by recognising it as incineration – not recycling.”

Sian Sutherland, Co-Founder of A Plastic Planet also commented: “Plastic producers and the retailers they rely on must stop focusing on protecting the industry’s profit margin at the expense of saving the planet. The Treasury’s decision to include these products under the definition of recycled is both illogical and hugely damaging. Environmental campaigners fought long and hard for the UK to introduce a plastics packaging tax: it is heart-breaking to see the Treasury introduce it on a flawed basis from the start.”

What is chemical recycling?

In the plastics context, chemical recycling – also known as advanced or molecular recycling – refers to chemical, thermochemical, and combustion processes whereby a proportion of the treated plastic waste is turned into chemical building blocks. This material is then able to be recycled into other plastics, including plastic that can be used for food-grade applications.

Proponents of chemical recycling technologies highlight their potential to address the dual issues of fossil fuel dependence and global plastic pollution, pointing to their ability to ‘fill the gap’ in current recycling by providing an alternative waste management option for items not currently recycled, and recycle material back to virgin-like quality.

However, chemical recycling has attracted criticism over a ‘lack of transparency’ in available evidence of environmental performance. These contrasting positions have provoked debate over the environmental viability of chemical recycling.

‘Essential’ technology

Trade association PlasticsEurope is amongst those advocating for the implementation of chemical recycling technologies. In a statement last year, the association claimed that scaling up such technology was ‘essential’ in achieving EU targets on recycled content for plastics packaging, affirming that members were ‘already working towards’ the target by investing in ‘new technology solutions’.

‘Significant concerns’

In a recent report by the Natural Resources Defence Council (NRDC), it was found that the majority of chemical facilities studied are not recycling any plastic, but are instead creating fuels and releasing hazardous pollutants into communities and the environment. The US analysis urges regulation for chemical recycling.

Reviewing eight facilities in the US, the study found that the majority of facilities are failing to recycle any plastic whilst simultaneously generating a large amount of hazardous waste and releasing hazardous pollutants. The study also noted that facilities are often situated nearby or within communities that are disproportionately low income, people of colour, or both, resulting in ‘significant environmental justice concerns’.

NRDC’s report found that Agilyx, an Oregon-based processing plant labelled as the ‘gold standard of chemical recycling’, had in fact sent a significant amount of material for incineration and generated a large amount of hazardous waste.

This followed a report published by the Worldwide Fund for Nature (WWF), wherein the NGO outlined its position on the implementation of chemical recycling technologies. The report urged that chemical recycling techniques should be applied in line with circular economy principles, noting that they are surrounded by ‘significant concerns’.

The report recommended that, if applied, such technologies should be ‘complementary’ to existing waste management systems, and not compete for feedstocks with mechanical recycling. Plastic waste streams should also be matched to the ‘most environmentally efficient technology available’, which the NGO asserts would ‘ensure the whole system operates with the smallest environmental footprint possible’.