ACC comments on EPA's proposed significant new use rules under Toxic Substances Control Act; proposal would hinder advancement of innovative technologies including pyrolysis-based advanced recycling, group says

Sample article from our Government & Public Policy

August 21, 2023 (press release) –

WASHINGTON (Aug. 18, 2023) - The American Chemistry Council’s Plastics Division submitted comments to EPA regarding its proposing significant new use rules (SNURs) under the Toxic Substances Control Act. The following is a statement from Lee Salamone, Senior Director, Plastics Division of ACC:  

“Pyrolysis-based advanced recycling is a critical part of the solution to a circular plastics economy. As written, the SNUR proposal would create an unworkable impediment that could hinder the advancement of innovative technologies to increase this circularity. ACC and our members remain eager to inform the EPA and other decision-makers about advanced recycling and clarify misconceptions being spread by its opponents and foster a more constructive path forward for this important manufacturing process.  

“Progress towards a circular economy can only be achieved with smart, cohesive approaches that avoid inconsistent and conflicting approaches by regulators. To put it plainly, pyrolysis is not incineration. But it makes no sense and is counterproductive for one EPA office to explore the regulation of pyrolysis as incineration of solid waste while another office, EPA’s Office of Pollution Prevention and Toxics, considers pyrolysis to be chemical manufacturing under TSCA.  

“Across its offices and programs, as multiple statutory programs and regulations are implemented, it is imperative that EPA have a consistent, cohesive approach to the materials and processes to be regulated. Anything less will add regulatory burden, cost and delays, and impede progress to a circular economy. EPA offices must find a path forward expeditiously to remove impediments and begin working together to achieve the Administration’s plastic pollution prevention policy goals.” 

American Chemistry Council

The American Chemistry Council (ACC) represents the leading companies engaged in the multibillion-dollar business of chemistry. ACC members apply the science of chemistry to make innovative products, technologies and services that make people's lives better, healthier and safer. ACC is committed to improved environmental, health, safety and security performance through Responsible Care®; common sense advocacy addressing major public policy issues; and health and environmental research and product testing. ACC members and chemistry companies are among the largest investors in research and development, and are advancing products, processes and technologies to address climate change, enhance air and water quality, and progress toward a more sustainable, circular economy.



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