After about two years of development, SCS Standards and Assurance Systems has published a Certification Standard for Responsible Chemical Recycling (SCS-004), informed by stakeholders of varying sizes and technologies.
The company’s for-profit arm, SCS Global Services, uses the new standard to underpin the certification program, which aims to provide transparency for non-mechanical recyclers in communicating with customers, legislators and industry itself, said Victoria Norman, executive director of SCS Standards and Assurance Systems.
With brands under pressure to deliver on PCR commitments, chemical recycling can help produce the necessary volumes and complement mechanical methods, Norman said. “But we need to have confidence that the recycling process is done in a responsible way,” Norman said.
The standard centers on three pillars – chain of custody/feedstocks, environmental impacts and social impact – to independently verify that chemically recycled materials come from operations that meet clear standards for environmental and social performance along with operational transparency, Norman told Plastics Recycling Update.
“If you’re doing something, you should be reporting it. Whether you shout it or make it a footnote, I don’t care,” Norman said. “Regardless of how loud you are, it needs to be truthful. And so that’s really the purpose of the standard, to back claims, provide assurance that things are being done and they’re being done correctly, and there is annual oversight.”
With a focus on transparency and disclosure, SCS-004 deliberately avoids a prescriptive approach to recycling technologies and processes, she said. Norman emphasized that the standard addresses production – processing feedstocks within the recycling operation – and not the chain of custody. As such, it’s complementary to ISCC Plus, which for chemical recycling focuses on the chain of custody from the recycler to the end user.
Defining ‘responsible’ operations
Norman framed the standard as a tool for businesses to engage with industry as well as legislators, designed to provide third-party determination as to what constitutes “responsible” operation of non-mechanical recycling processes.
That said, defining responsible operations can raise the uncomfortable question of whether past practices were in fact irresponsible, she said. The standard sidesteps that particular thorn by looking forward rather than in the rearview.
For example, a recycler may need to adjust operations to be certified as responsible, she said. “Does that mean that what I’m doing now is not responsible? And the answer isn’t obviously yes or no. We are setting a standard for what we think ‘responsible’ should be,” in the form of disclosures, transparency, monitoring, tracking and improving performance over time.
Answering that question “requires some soul searching, and that was probably the biggest roadblock” for companies that participated in the standards development phase. SCS said Eastman, Nexus Circular and Brightmark were among the contributors, with other stakeholders not publicly identified.
Norman added: “We’re talking about an industry that has never done this before. And because we did pilot audits, I know for a fact that this standard is moving the needle. Folks are having to change how they do things to meet the standard, and that to me is the most validating and encouraging thing.”
Genesis of the standard
Dave Ford, co-founder of Circle (formerly the Ocean Plastics Leadership Network), said his group began the effort about six years ago. As a “neutral secretariat,” Circle convened consumer brands, chemical companies and environmental experts to first agree on common principles and then to test whether the guidance they developed could become a standard.
“We’re not an advocate for these technologies, we’re an advocate for helping everyone learn about them, because they’re so complicated,” he said.
To shape what would become the standard, the group centered on three core areas: transparency about recycling technologies and outputs, environmental justice for residential communities near proposed plants, and environmental impact.
Feedback from the stakeholders ultimately became the published white paper “Responsible Production Guidelines for Advanced, Chemical and Molecular Recycling.” And later the participating companies voted to pursue a formal standard, shifting the initiative into the development phase led by SCS.
Norman said of Ford, “He likes to think he had a tiny role, but was really instrumental in bringing everyone to the table, which is a superpower.”
SCS worked for about two years with the group of recyclers to develop the standard, including seeking perspective from brands, NGOs and regulators, “to make sure that what we were doing was actually not what the chemical recyclers thought that they should do or wanted to do, but actually addressing the real concerns that exist, and also grounding it in reality.”
The certification employs a tiered system:
- Core: Foundational requirements covering management systems, operational permits, chain of custody transparency, and social and environmental reporting.
- Plus: Core, plus demonstrated continuous improvement in social and environmental performance.
- Trailblazer: Plus, as well as category-specific recognition for best-in-class performance across risk assurance, transparency and disclosure, water stewardship, zero waste and social impact.
Looking ahead, SCS hopes regulators will look to the standard to help streamline approval processes for technologies and sites, Norman said, as well as Circular Action Alliance (CAA), as the producer responsibility organization develops a responsible end market standard for the packaging EPR programs it manages. (A public comment period for the CAA draft standard is open until July 7.)
She said that as they are implemented, EPR laws will determine what is and is not acceptable operational practice. “And through the transparency that is required in this standard, we will be able, I believe, to meet the bar set by different regulators, different states, based on what they define as ‘recycling.'”
A living document with industry input
Although the standard is set to be reviewed every five years, Norman expects an earlier revision because the chemical recycling space is changing so rapidly, from both regulatory and technological perspectives.
She estimated that in about three years, the industry will have a much better understanding of the impact and implementation of EPR laws for packaging. The key is to maintain a living document that keeps pace with a nascent industry, but isn’t updated so often that it becomes unwieldy for either auditors or certified entities, she said.
Carla Toth, senior vice president of business development and feedstock sourcing strategy at Nexus Circular, echoed this point. “Many of these technologies were started 10 or 15 years ago. They’re not 100 years old, like the petrochemical industry, and they will grow and evolve and change over time.”
Toth said the group wanted to create a base-level certification to provide credibility and confidence, but also to allow companies to understand their impact from energy intensity or water management perspectives. Establishing such a baseline can enable companies to develop process improvement plans to achieve a higher certification over the course of several years, she added.
And while technologies vary widely, so do the companies employing them. As such, the standard was deliberately designed to scale with facility size.
Toth said accommodating “standalone” chemical recyclers was important particularly for social responsibility criteria. “Some of our facilities are quite small, and we wanted to ensure that we were engaging appropriately for the size of the company.”
For example, early drafts required a facility to hire a certain number of people from the local community. “For a small company of under 50 people, that could be almost an insurmountable barrier,” even if the company fully understands the need for such a requirement, she said. But when a plant scales to, say, several hundred people per plant, that’s when compliance is realistic, she said, adding that the three certification levels consider these scalability issues.
Bridging a credibility gap
The motivation for Nexus to participate in the process was that the terms covering non-mechanical recycling are broad and poorly understood, and at varying levels of commercial maturity. This added to a credibility gap with legislators, regulators, brands and consumers, Toth said.
Based in Georgia, Nexus operates commercial-scale pyrolysis recycling on hard-to-recycle plastics, particularly film and flexible packaging.
“We knew we had a bit of an industry challenge with trust and credibility, and that’s where this process started, driven by different parts of the plastics value chain, with a lot of input from the brands,” Toth said.
Brand involvement was key from the start of the process, given their direct line to what consumers, legislators, regulators and even NGOs needed to be more readily accepted as a credible, viable new innovation in the recycling ecosystem, Toth said.
“It’s difficult to accurately describe and then ensure that the industry truly understands what the process is, how it’s best utilized, how it complements mechanical recycling, and that we are operating responsibly and returning material to the value chain,” she added.
And to ease concerns over disclosing proprietary information – a rising concern with emerging EPR reporting requirements – the standard allows confidential disclosure to auditors rather than full public disclosure.
“There was a lot of conversation about how we ensure we’re being transparent to provide our goal, which is confidence and incredible operations, but also ensuring that confidential information is kept at an appropriate level, and what is the balance,” Toth said.
Another recycler that participated in the process, Brightmark, said in a statement that it hoped that more broadly, “the standards can help support informed, science-based discussions and contribute to the development of practical legislation and regulation. By increasing transparency and creating a common framework for evaluating projects, the standards can help stakeholders better understand where different solutions fit within the waste management hierarchy and how they can collectively contribute to improved circularity outcomes.”
Norman added: “We would not have engaged in this exercise if we did not think that it was possible to do chemical recycling responsibly, because we’re rooted in science, we have a reputation of being in the world of sustainability – that’s not worth the risk.”.
