Chemical recycling has become one of the more debated topics in textile circularity. For those of you in the plastics recycling industry, the story may be familiar: new technologies, questions around environmental performance, disagreements over the definition of recycling, and broad regulatory uncertainty.
Chemical recycling processes like pyrolysis and gasification have been around since the 1970’s as a solution for hard-to-recycle plastics, converting it into new plastics, fuels and chemical feedstocks. However, decades later, chemical recycling still accounts for a small portion of US plastics recycling and few facilities produce chemically recycled plastics at scale.
Environmental and public health orgs have also raised concerns about energy demand, hazardous byproducts, local impacts, and whether fuel and chemical outputs should count as recycling. Since fuel production has historically been one of the main outputs, pyrolysis and gasification has become associated with energy recovery and incineration.
From plastics to textiles
This backdrop now influences textile circularity. Supporters of chemical recycling see it as one of the only ways to recover fiber from complex textiles. But critics question whether the technologies can consistently produce recycled fiber at scale and have concerns over energy intensity, transparency, end-markets and continued reliance on synthetic fibers.
With textile EPR advancing in California and legislation introduced in New York, Washington and Minnesota, policymakers are faced with deciding how to classify these technologies and whether they count as recycling.
Not all recycling is created equal
Over the past decade, a growing number of companies have developed technologies to recycle postconsumer textiles. These are not pyrolysis or gasification, but dissolution, depolymerization, solvolysis and enzymatic recycling — and each is genuinely distinct. Even within a single category like solvolysis, no two companies’ processes are the same; they vary in reagents, feedstock requirements, operating conditions, energy demands, outputs and byproducts.
That complexity is exactly what makes policymaking so hard. Technologies can’t simply be lumped under the singular “chemical recycling” term, because the differences between them are legitimate and material.
The regulatory challenge is compounded by the fact that many companies do not release technoeconomic, environmental or lifecycle data in order to protect process details. And, in fact, performance claims are often based on pilot or demonstration-scale operations that may change as facilities scale up, improve efficiency or expand feedstock acceptance.
Legislative approaches in CA and NY
Despite this complexity, lawmakers still have to make decisions, and California and New York have thus far taken different approaches.
California’s SB 707 (Newman, 2024), borrows the definition of “recycling” from SB 54’s packaging EPR law. The definition does not explicitly prohibit chemical recycling but does not grant blanket approval either. To count as recycling, a process must convert covered products into recovered material for use in new, reused or reconstituted products that are sent to a responsible end market, and the definition explicitly excludes combustion, incineration, energy generation and fuel production.
CalRecycle’s regulations go even further, requiring technologies to demonstrate that they do not generate significant hazardous waste and align with ISO 59014:2024’s sustainability and traceability requirements — with compliance responsibility falling to recyclers and PROs, meaning these technologies aren’t prohibited but must be evaluated individually.
In New York, the conversation is highly polarized. Rather than evaluating technologies case by case, one of the proposed textile EPR laws pairs ambitious recycled content requirements with an explicit prohibition on chemical recycling, which is a position that reflects the plastics recycling legacy. Groups like Beyond Plastics and NRDC support that approach, arguing that some chemical processes function as energy recovery or fuel production rather than true recycling. They also warn that carving out exceptions for chemical processing could divert attention and investment away from prevention, reuse, repair and mechanical recycling, while extending the industry’s reliance on virgin plastics.
Supporters of emerging technologies see it differently. They argue this framing oversimplifies a rapidly evolving field, and that newer, textile-to-textile approaches merit individual evaluation based on inputs, outputs, environmental performance and end markets rather than a blanket label and a blanket ban.
Education and transparency are key
The debate is leading to a need for industry to align on a path forward and that requires closing the information gap.
Earlier this year, CPSC convened legislators, regulators and stakeholders in Sacramento to discuss chemical processing and textile recovery pathways, noting classification depends on evidence about inputs, outputs, environmental performance and end uses. It was a successful gathering.
Building on that, NYSAR3 is organizing a similar discussion in New York, with NYS legislators and regulators invited to learn alongside recyclers, operators, academics and NGOs.
Where does that leave us? As textile EPR policy develops, decisions about recycling will depend less on broad technology categories and more on demonstrated outcomes and alignment with policy objectives.
