PLASTIC POLLUTION & PRODUCER RESPONSIBILITY

PLASTIC-TO-FUEL: A FALSE SOLUTION

[vcnva-agenda-items]

Plastic production is increasing globally and in Virginia, resulting in the state’s waterways being inundated by single-use plastic pollution. However, “advanced” or “chemical” recycling, also known as plastics-to-fuel, pyrolysis, gasification, chemical conversion, and chemical depolymerization, is not a solution to this plastic pollution crisis. These processes use chemicals and heat to incinerate plastic waste to create fossil fuels (see graphic below).¹  As such, the U.S. Environmental Protection Agency has classified these processes as “incineration.”² In addition, “chemical recycling” produces more greenhouse gases and hazardous waste than the production of virgin plastic,³ while also incentivizing the production of more plastic. The resulting air pollution and hazardous waste put Virginia’s communities and environmental health at risk.

Many of these facilities do not test, record, or report the environmental impacts of their incineration. For example, a 2018 report found that an Oregon facility released over 49,000 tons of waste styrene, a highly toxic chemical, into our air.⁴ Pollution disproportionately burdens communities of color,^5,6, and, as a result of this environmental injustice, Black people are three times more likely to die from exposure to air pollutants than white people.⁷ Seven of the eight U.S. “chemical recycling” facilities are located in environmental justice communities.⁸ This, combined with the fact that these facilities are often out of compliance with EPA hazardous waste regulations,⁹ further demonstrates that “chemical recycling” is a false, inequitable solution.

Chemical Recycling. Image Credit: Clean Fairfax

Twenty-four states,¹⁰ including Virginia, effectively exempt “chemical recycling” facilities from important waste regulations required of other waste industries because they are regulated as manufacturing facilities. This carveout was awarded based on promises from the American Chemistry Council, highlighting the operations of a Tigard, Oregon polystyrene “chemical recycling” facility. However, this facility lost $4.5 million between 2021 and 2023 and ultimately closed in early 2024 after failing  to produce a marketable product, but not before generating more than 200 tons of styrene waste between 2018 and 2022–all of which was burned off-site.¹¹

Likewise, the short history of “chemical recycling” facilities in Virginia suggests “chemical recycling” is a false solution that depends on taxpayer dollars while delivering little to no public benefit. For example, Braven Environmental LLC received approval for a $1.2 million incentive grant from the Virginia Tobacco Region Revitalization Commission to build a chemical recycling facility in Cumberland County. The project was touted as a solution to Virginia’s plastic waste challenges, but the company ultimately withdrew from the project, leaving the facility unbuilt and the grant unpaid.¹² 

The “chemical recycling” industry has failed for decades due to issues of technology scalability, high volumes of hazardous waste production, energy consumption, and overall inability to turn a profit.^13,14,15 To truly tackle Virginia’s plastic pollution crisis, the Commonwealth should look towards producer responsibility and proven solutions that reduce our reliance on single-use plastic (see PLASTIC POLLUTION & PRODUCER RESPONSIBILITY) to protect human health, our waterways, the ocean, aquatic animals, and the economy.

State solid waste management policy follows a clear hierarchy designed to minimize community and environmental impacts: source reduction, reuse, recycling, resource recovery (waste-to-energy), incineration, and landfilling.¹⁶ This hierarchy can guide discussions on  “chemical recycling,” as the process is considered incineration according to EPA regulations. Effective solid waste management focuses on reducing single-use plastics in the waste stream and as litter, reusing products where possible, and, when recycling is necessary, prioritizing solutions that reduce the manufacture of virgin plastics. Technologies that convert plastic into fuel are distinct from recycling and do not align with the goals of extended producer responsibility and recycling development programs. This position is also reflected by national recycling organizations, including the National Recycling Coalition, which has stated that any process using heat or chemicals to transform plastic waste into fossil fuels, fossil fuel additives, substitutes, or waxes does not meet their “definition of recycling.”¹⁷

Technologies with limited demonstrated performance, such as “chemical recycling”, warrant robust evaluation for safety, scalability, and economic viability before being allowed in Virginia. Technologies that contribute to Virginians’ quality of life—through outcomes such as litter reduction, plastic waste management, and environmental equity—demonstrate measurable benefits and economic sustainability independent of ongoing taxpayer support. Public investments, including loans, grants, and subsidies, are best directed toward solutions with a demonstrated track record of achieving these goals.

¹ Recycling lies: “chemical recycling” of plastic is just greenwashing incineration. (2022, February). Natural Resources Defense Council. https://www.nrdc.org/sites/default/files/chemical-recycling-greenwashing-incineration-ib.pdf

² Pyrolysis proposed provision withdrawal notice. (2023, May). Environmental Protection Agency. https://www.epa.gov/system/files/documents/2023-05/Pyrolysis%20Proposed%20Provision%20Withdrawal%20Notice_%20ADMIN%2BDISC.pdf

³ Uekert, T., Singh, A., DesVeaux, J. S., Ghosh, T., Bhatt, A., Yadav, G., Afzal, S., Walzberg, J., Knauer, K. M., Nicholson, S. R., Beckham, G. T., & Carpenter, A. C. (2023). Technical, economic, and environmental comparison of closed-loop recycling technologies for common plastics. ACS Sustainable Chemistry & Engineering, 11(3), 3075–3084. https://doi.org/10.1021/acssuschemeng.2c05497

⁴ Patel, D., Moon, D., Tangri, N., & Wilson, M. (2020). All talk and no recycling: An investigation of the U.S. “chemical recycling” industry. Global Alliance for Incinerator Alternatives. https://doi.org/10.46556/WMSM7198

⁵ Bullard, R. D., & Wright, B. H. (1986). The politics of pollution: Implications for the Black community. Phylon, 47(1), 71–78. https://doi.org/10.2307/274696

⁶ Bullard, R. D., & Wright, B. H. (1986). The politics of pollution: Implications for the Black community. Phylon, 47(1), 71–78. https://doi.org/10.2307/274696

⁷ Tessum, C. W., Paolella, D. A., Chambliss, S. E., Apte, J. S., Hill, J. D., & Marshall, J. D. (2021). PM  < 2.5>  polluters disproportionately and systemically affect people of color in the United States. Science Advances, 7(18). https://doi.org/10.1126/sciadv.abf4491

⁸ Chemical recycling: A dangerous deception. (June 13, 2025). Beyond Plastics. https://www.beyondplastics.org/fact-sheets/chemical-recycling

⁹ Recycling lies: “chemical recycling” of plastic is just greenwashing incineration. (2022, February). Natural Resources Defense Council. https://www.nrdc.org/sites/default/files/chemical-recycling-greenwashing-incineration-ib.pdf

¹⁰ Heffernan, M. (2023). 2023 sees growing chemical recycling lawmaking activity. Resource Recycling Inc. https://resource-recycling.com/plastics/2023/07/18/2023-sees-growing-chemical-recycling-lawmaking-activity

¹¹ Oregon chemical recycling facility closes 3-6-24. (2024, March 6). Beyond Plastics. https://www.beyondplastics.org/press-releases/oregon-chemical-recycling-facility-closes-3-6-24

¹² Virginia Economic Development incentives. (n.d.). Virginia Economic Development Partnership. https://www.virginiaincentives.org/

¹³ Bertolini, G. E. & Fontaine, J. (1987). Value recovery from plastics waste by pyrolysis in molten salts. Conservation & Recycling, 10(4), 331-343. https://doi.org/10.1016/0361-3658(87)90064-6

¹⁴ Brightmark $260m facility sells for $14M following Green Bond Default. (2026, March). Klean Industries | Market News. https://kleanindustries.com/insights/market-analysis-reports/brightmark-260m-plastics-pyrolysis-facility-sale-green-bond-default/

¹⁵ Quin, M. (2025, March 18). Brightmark retains Indiana Chemical Recycling facility through bankruptcy auction | waste dive. Brightmark retains Indiana chemical recycling facility through bankruptcy auction. https://www.wastedive.com/news/brightmark-bankruptcy-ashley-indiana-sale-process/742791/

¹⁶ Local, state and regional solid waste planning. Virginia Department of Environmental Quality (DEQ). https://www.deq.virginia.gov/our-programs/land-waste/solid-hazardous-waste/solid-waste/local-state-and-regional-solid-waste-planning

¹⁷ Freeman, A. L. (2025, May 19). NRC Policy Position on Chemical Recycling (Advanced Recycling). National Recycling Coalition. https://nrcrecycles.org/nrc-policy-position-on-chemical-recycling-advanced-recycling-5-19-2025