WASHINGTON (JULY 31, 2023) — In comments submitted to the Environmental Protection Agency, the American Chemistry Council outlined opportunities where greater collaboration could turn the Draft National Strategy into a more comprehensive approach to eliminate plastic pollution and called out sections of the draft where unintended consequences could mean significant negative impacts for American consumers and our environment.
The United States could be the leader in developing a circular economy of plastics. One of the most promising areas of innovation to help achieve that goal and that EPA should recognize is advanced recycling, which could enable the United States to recycle significantly more types of plastics.
To facilitate recycled content goals and mandates, the National Strategy should acknowledge the diversity of recycling technologies and programs that provide pathways to circularity for plastics. In its comments, ACC highlights opportunities EPA can use to engage stakeholders and learn more about industry innovations and investments, including with advanced recycling, bio-plastics, enhanced plastic management, and ACC’s “5 Actions for Sustainable Change” policy framework.
ACC is concerned that many parts of the draft strategy are inconsistent with the direction and intention of Congress. In addition, there are aspects of the Draft National Strategy that would stall the transition to a circular economy and increase carbon emissions in the U.S. Our biggest concerns lie with the agency’s call for material substitution without considering the impacts of alternatives that may ultimately increase our environmental footprint. Taking this proposed approach without science-based analysis could increase resource utilization, greenhouse gas emissions and waste sent to landfills.
As the National Strategy to Prevent Plastic Pollution is linked to the EPA’s National Recycling Strategy – a strong first step in creating a circular economy in the United States – there should be an emphasis put on fulfilling the objectives laid out in that strategy. America’s plastic makers look forward to working with EPA to enact sensible practices that keep plastics out of the environment.
