Is recycling creating a toxic chemical problem?

Research just published by the US Environment Protection Agency has found that recycled paper and construction materials “contained greater numbers of chemicals than virgin products”. Some 733 identified chemicals, including flame retardants, solvents and dyes, “had greater occurrence in recycled compared to virgin materials”. The authors of the paper, published in Environmental science and technology, warned that “the circular nature of the recycling economy may have the potential to introduce additional chemicals into products”.

Chemicals building up in recycled materials could cause a problem for the circular economy. Photograph: Massimo Borchi/Getty Images

So, is the circular economy creating a chemical problem? Are targets to increase recycling and the use of recycled materials within products and packaging actually storing up potential health and environmental problems?

Quite possibly. “The issue of additives in plastics is a real one for circularity,” says Colin Church, chief executive at the Institute for Materials, Minerals and Mining. “Circularity is building up before we have that framework for chemical management,” adds Kerry Dinsmore, from Fidra, an environmental charity. “People are not talking about this.”

This is perhaps understandable. Stories about chemicals concentrating in unknown quantities in recycled food packaging, toys or textiles could derail progress at a time when consumers, companies and politicians are all serious about reducing waste. 

Indeed, the UK and the EU have fast-tracked regulations that encourage more recycling, in particular of plastics. The UK’s plastics tax, set to come into force in April 2022, is designed to accelerate the use of recycled content in plastic packaging. “The importance of the circular economy is paramount and anything that undermines [it] puts at risk a system that has the potential to make enormous in-roads into the reductions in carbon we must make globally,” explains one waste industry source. 

But NGOs claim it is high time to pause, take a breath and think about chemicals in the context of the circular economy. Toxic chemicals in the circular economy are “nearly impossible” to extract once materials, most particularly plastics with chemical additives, have been re-circulated, explains Björn Beeler from the International Pollutants Elimination Network (IPEN). “We do not see a clean and safe plastic circular economy,” he notes. “We see a massive burden on the public to address the plastic and chemical producers’ toxic liabilities.” 

That chemicals are a concern is nothing new – the fact that recycling in the name of environmental protection could be creating more problems certainly is. In the EPA study, the samples with the fewest confirmed and probable chemicals were virgin plastic food contact items – the recycled samples had double that (22). “Recycling processes may increase the levels of chemicals found in, and therefore migrating from, food packaging,” said Olwenn Martin, a lecturer in Global Challenges at Brunel University, London, recently. 

Martin, together with 33 other scientists, had published a ‘consensus statement’ in the journal Environmental Health. The experts looked at 1,200 peer reviewed papers relating to food contact chemicals and found that chemical safety is “often ignored” in solutions to reuse or recycle plastic, or to switch to other materials.

Jane Muncke, another of the authors and managing director at the Food Packaging Forum, a non-profit foundation based in Switzerland, says there is “a lot of awareness about plastic pollution and people are working really hard to try and fight it, but they realise that the solutions they’ve come up with don’t work if you start talking about chemicals”.

The international and national agreements to recycle more plastic packaging, like the UK Plastics Pact, include ambitious targets to make all packaging recyclable and ensure higher levels of recycled content. Environmentally that makes sense, but these commitments are made “without specifying how to address chemicals in recycled plastics”, warned the International Chemical Secretariat (ChemSec) in a 2020 report. “Circularity must be a holistic approach,” notes the organisation’s Peter Pierrou, “which means toxic chemicals must be tackled as well”.

ChemSec’s report, entitled ‘What goes around’, also warned that chemicals of concern are being locked into circular recycling loops and “preventing the growth of the circular economy”. Many brands are stuck: they don’t want to buy recycled packaging material with unknown, and potentially toxic, content, but they have stretching targets to increase recycled content in their plastic packaging. Something has to give.

The easy option, surely, is to switch materials. Many have ditched plastic (seen as bad) and are using paper, board and compostable packaging (seen as good). If only it were that simple. PFAS are also being added in “really high” quantities to rigid compostable packaging, like clam shells for fish and chips, says Fidra’s Dinsmore. “That's a really direct source back into something that would be used for growing crops (compost).”

Fidra last year found PFAS on packaging used by eight of nine major UK supermarkets and all the takeaway packaging they assessed. Further research this year by NGOs in the UK and Europe showed the so-called ‘forever chemicals’ in bakery, fries and sandwich bags from McDonald’s, Subway, Greggs and the Coop, as well as pizza boxes from Papa John’s, Domino’s and Pizza Hut.

“Tracking chemicals through the production, use and the disposal and recovery chain is without doubt the conundrum we must [all] solve,” says the waste industry source. “Chemical analysis combined with other tools can help, but I feel much more work is needed in this area.”

Campaigners want to see stronger regulation and greater transparency. They are calling for bans on PFAS (Denmark has had a ban on their use in paper and board packaging for a year) and for chemicals of concern to be designed out as manufacturers and brands rethink their packaging. 

In a report published last week, Marcos Orellana, the UN Human Rights Council Special Rapporteur on the implications for human rights of the environmentally sound management and disposal of hazardous substances and wastes, wrote that “consumers do not have adequate information regarding the chemical additives in the plastic products they buy”. He said businesses should be required to disclose “the full chemical composition of plastic products, including additives”. This echoes the recommendations of an Environmental Audit Committee report in 2019.

Better enforcement of the regulations wouldn’t go amiss, either. There is strict EU legislation (that the UK still currently abides by) governing the use of recycled plastic in food contact materials, for example, but campaigners argue that many chemicals are still not comprehensively assessed. Food packaging made of paper or cardboard is not actually regulated at the EU level. FPF’s Muncke says the current regulations leave vast room for improvement. “They are not terrible,” she adds, “but what we are doing in terms of enforcement is subterranean. If we were really to enforce the regulations […] we would be clearing out the shelves in the supermarket.”

NGOs have thus far been reluctant to create scare stories that would undermine the circular economy. Their patience appears to be running out though; a more public-facing push is on the way. 

Only this week, the Health and Environment Alliance, Zero Waste Europe, CHEM Trust and ClientEarth launched a new campaign. “Harmful chemicals in recycled #FoodContactMaterials can put the #CircularEconomy and our health at risk,” they tweeted, with an infographic entitled ‘Misconceptions about food contact materials’. Their use of the phrase “toxic recycling” is deliberately emotive.

More transparency could certainly increase trust in the circular economy, but politicians and businesses remain wary of putting this invisible issue in the spotlight. DEFRA has said it is “working to improve our understanding of the emissions and risks of PFAS in the UK” as it develops a new chemicals strategy set for consultation later this year.

Some firms are applying stricter standards in their own supply chains, which may well limit their progress towards any packaging targets. Others say they are keeping an “open mind” on the issue. Michael Warhurst, executive director at the CHEM Trust, says the focus should be on creating a clean circular economy because “anything else will risk undermining public confidence in the whole circular economy concept”.