For decades, one of the most important questions in recycling has also been one of the simplest:
When does waste stop being waste?
The answer matters more than it might seem.
Materials classified as waste can be subject to very different regulatory requirements from materials considered fuels, manufacturing feedstocks or commercial products. Those distinctions can affect everything from permitting and transportation to investment decisions and whether emerging recycling technologies can operate economically at commercial scale.
The U.S. Environmental Protection Agency is now taking several actions that suggest a broader emphasis on resource recovery—finding productive uses for materials that might otherwise be discarded.
Some recent reporting has characterized these actions as a sweeping change in how EPA views plastic waste. The reality is more nuanced. Several of the most important actions are still proposals, and EPA has not simply declared that plastic waste is no longer waste.
But the direction is significant.
EPA is increasingly recognizing that materials traditionally viewed as waste may, under the right circumstances, become legitimate manufacturing feedstocks, fuels or other valuable products.
For anyone interested in recycling and the circular economy, that distinction deserves attention.
Recycling Is Becoming More Than Mechanical Recycling
Traditional mechanical recycling remains the dominant method for recycling plastics in the United States. Plastics are collected, sorted, cleaned, shredded and remelted without fundamentally changing their underlying chemical structure.
When the material is clean and relatively uniform, this can work very well.
But not every plastic waste stream looks like a clean PET bottle or HDPE container.
Plastic can be contaminated with food, oils or other materials. It can contain multiple polymer types, adhesives, coatings or additives. Modern packaging can combine several layers of materials engineered to provide strength, flexibility or barriers against air and moisture.
Those properties may make a product highly useful during its life while making it considerably harder to recycle afterward.
EPA now explicitly recognizes this limitation.
On its current Advanced Recycling of Plastics webpage, the agency says advanced recycling technologies have the potential to complement mechanical recycling by processing plastic materials that may not be suitable for traditional recycling and diverting materials that might otherwise be landfilled.
That is an important distinction.
The objective does not have to be choosing between mechanical recycling and advanced recycling.
Different materials may require different recovery pathways.
That is the same principle we discussed in Resource Recovery: Why Recycling Alone Will Never Be Enough: a successful circular economy ultimately depends on matching materials with practical end uses rather than expecting every discarded material to pass through the same recycling process.
What Is Advanced Recycling?
“Advanced recycling” is a broad term covering several technologies that use chemical or thermal processes to transform plastics.
EPA identifies technologies including pyrolysis, gasification, hydrothermal treatment, depolymerization and purification.
Pyrolysis, for example, heats plastic at high temperatures in the absence of oxygen. Depending on the process and feedstock, the resulting products can include hydrocarbon liquids, gases and char.
Those outputs may then become chemical feedstocks, fuels or raw materials for additional manufacturing.
EPA specifically notes that these technologies can sometimes process plastics that are too contaminated, too complex or otherwise unsuitable for conventional mechanical recycling.
This distinction is important because advanced recycling is sometimes casually described as simply another form of waste incineration.
Technically, that is inaccurate.
EPA itself distinguishes pyrolysis and similar conversion technologies from conventional waste-to-energy combustion. In pyrolysis, the material undergoes thermal decomposition under little or no oxygen. Conventional waste-to-energy facilities directly combust material with excess oxygen to generate heat, which can then be used to produce steam and electricity.
Both may recover value from materials.
But they do so differently.
EPA Is Reconsidering How Pyrolysis Should Be Regulated
One of the most important current EPA actions involves the Clean Air Act regulations governing Other Solid Waste Incinerators, commonly referred to as OSWI.
In March 2026, EPA proposed revising the regulatory definition of a “municipal waste combustion unit” by removing a reference to “pyrolysis/combustion units.”
According to EPA, the proposed change would clarify that the OSWI rule does not regulate pyrolysis units used in advanced recycling operations.
That could be significant for advanced recycling developers because the regulatory classification of a facility can affect permitting requirements, project costs and development schedules.
But an important qualification is necessary:
This is not yet a final rule.
EPA accepted public comments on the proposal through May 4, 2026 and has stated that those comments will help inform development of its policy toward advanced recycling.
In other words, EPA is reconsidering how these facilities should be classified.
It has not eliminated environmental regulation of advanced recycling facilities, nor has it declared that every pyrolysis operation automatically qualifies as manufacturing rather than waste management.
Facilities remain subject to applicable federal, state and local environmental requirements.
The Larger Question: Is the Material a Waste or a Resource?
The current debate over plastics is actually part of a much older regulatory question.
Under the Resource Conservation and Recovery Act, EPA has long maintained rules determining when certain non-hazardous secondary materials used in industrial processes should be treated as solid wastes and when they can instead qualify as legitimate fuels or ingredients.
The governing regulations are found in 40 CFR Part 241.
EPA explains that non-hazardous secondary materials can include post-consumer materials, post-industrial materials and scrap, many of which retain useful energy or material value.
That framework dates to EPA’s 2011 Non-Hazardous Secondary Materials rule.
Among other pathways, the regulations recognize that a discarded material can sometimes be sufficiently processed to produce a legitimate fuel or ingredient rather than remaining a solid waste.
The distinction depends on factors including how the material is managed, whether it provides meaningful value and whether it satisfies EPA’s legitimacy requirements.
That concept is fundamental to resource recovery:
A material’s history does not necessarily determine its future.
Something can begin as an industrial residual, scrap material or discarded product and, after appropriate recovery and processing, become a useful commodity again.
EPA’s Scrap-Tire Proposal May Be Even More Important Than It Appears
Another 2026 EPA proposal illustrates this concept particularly well.
EPA estimates that approximately 48 million abandoned scrap tires remain in piles across at least 23 states and Tribal lands.
Historically, abandoned tires recovered from old tire piles have been considered discarded materials. Under existing rules, substantial processing may therefore be required before those tires can qualify as non-waste fuel.
EPA is proposing to change that treatment for certain applications.
Under the March 2026 proposal, whole abandoned scrap tires could be recovered and used as non-waste fuel in cement kilns, provided they are properly managed as valuable commodities from recovery through use.
Again, this remains a proposal rather than a final rule.
But the reasoning behind it is notable.
Instead of seeing an abandoned tire solely as something requiring disposal, EPA is asking whether its remaining energy and material value can be responsibly recovered.
That principle extends well beyond tires.
Industrial society produces enormous quantities of secondary materials that may no longer serve their original purpose but still contain usable material or energy.
The question becomes:
What is the highest practical second use for them?
Recycling Should Be a Hierarchy of Solutions, Not a Competition
This is where discussions about recycling sometimes become unnecessarily polarized.
Mechanical recycling advocates may criticize advanced recycling.
Advanced recycling companies may emphasize the limitations of mechanical recycling.
Energy-recovery advocates may argue that materials unsuitable for either pathway should not simply be buried.
In reality, all three observations can be correct.
Clean materials capable of being economically recycled into new products should generally be recovered that way.
Materials unsuitable for traditional recycling may sometimes be candidates for advanced chemical or thermal recycling.
Other residual materials may retain meaningful energy value and can potentially be processed into engineered fuels for appropriate industrial applications.
And some materials ultimately may have no technically or economically viable recovery pathway and will still require responsible disposal.
The objective should not be to force every material into a preferred technology.
The objective should be to recover as much practical value as possible before disposal becomes the final option.
This complementary approach has also been explored by FlexOnyx in its discussion of Why Advanced Recycling and Engineered Fuels Work Better Together. The underlying idea is straightforward: resource recovery works best when technologies are matched to the materials they can actually process rather than being treated as competing universal solutions.
The energy side of this equation also matters. PowerGen Insights has examined how modern engineered fuels can recover value from suitable secondary materials while utilizing existing boilers and industrial energy infrastructure.
That intersection between recycling, manufacturing and energy will likely become increasingly important as resource-recovery systems develop.
Regulation Still Matters
Recognizing waste as a potential resource should not mean abandoning environmental safeguards.
Quite the opposite.
As more economic value is attached to recycled materials, recovered feedstocks, carbon attributes and claims of landfill diversion, it becomes increasingly important to know what is actually happening to the material.
EPA itself says advanced recycling companies should clearly communicate information including feedstocks, processing capabilities, product yields and environmental impacts, and that regulators should ensure facilities meet applicable requirements.
Transparency becomes especially important when companies describe products or processes as “recycled,” “circular,” “sustainable” or “landfill diverted.”
As we discussed recently in When Recycling Claims Become Fraud: Greenwashing, Misrepresentation and the Need for Transparency, environmental claims become more valuable when governments, consumers and investors begin attaching economic value to them.
That inevitably creates incentives for exaggeration.
A credible resource-recovery system therefore needs both innovation and verification.
Track the material.
Understand the process.
Measure what comes out.
Verify the environmental claims.
The goal should not merely be changing the terminology surrounding waste.
It should be creating demonstrably better outcomes.
This Does Not Mean Everything Is Now “Recycling”
There is an important danger in taking EPA’s recent direction too far.
Not every use of a discarded material should automatically be called recycling.
Not every fuel produced from waste is equivalent to manufacturing a new plastic product.
Not every thermal process produces the same environmental outcome.
And not every material should be diverted from mechanical recycling simply because another process can accept it.
The environmental and economic performance of individual technologies still matters.
So do emissions, transportation distances, energy consumption, product quality, feedstock availability and what ultimately happens to the outputs.
Real resource recovery should be judged by measurable outcomes rather than labels.
That is also why the distinction between recyclable and actually recycled remains so important, as discussed in Real Cycle’s The Truth About Recycling: Breaking Down the Myths.
Putting something into a blue bin does not guarantee that it becomes another product.
Likewise, calling something advanced recycling does not automatically establish that it represents the best possible use of the material.
The entire chain has to be examined.
The Important Change May Be How We Think About Waste
The most interesting aspect of EPA’s recent actions may ultimately be philosophical rather than regulatory.
For much of modern history, waste policy focused primarily on controlling disposal.
That made sense when society’s principal challenge was preventing uncontrolled dumping and protecting human health and the environment.
Those responsibilities remain essential.
But modern waste systems face another challenge:
We discard enormous quantities of materials that still contain useful molecules, minerals, metals, carbon and energy.
Increasingly, environmental policy is being asked not simply how those materials should be disposed of—but whether they need to be disposed of at all.
EPA’s current resource-recovery initiatives suggest that question is receiving more attention.
The agency has described the challenge itself as an opportunity to transform waste into valuable materials while reducing environmental impacts and supporting a more circular economy.
That does not mean every discarded material has suddenly become valuable.
Nor does it mean every recycling technology will succeed.
But it reflects an important principle:
Waste should be the end of the process, not the beginning of our thinking.
Before material is buried, we should ask whether it can be reused.
Can it be mechanically recycled?
Can its molecules be recovered through advanced recycling?
Can it serve as an industrial feedstock?
Can appropriate residual material be converted into a legitimate engineered fuel?
Only after practical recovery options have been considered should permanent disposal become the answer.
That is not an argument for one technology.
It is an argument for using all of the tools available to us intelligently.
And if America’s recycling system is going to improve substantially, that broader definition of resource recovery may prove to be one of the most important changes of all.
About the Author
Gregory Merle (Greg Merle) is President of FlexOnyx and a director and advisor to Real Cycle as well as a regular contributor to PowerGen Insights. His work focuses on advanced recycling, resource recovery, energy and energy infrastructure, and practical solutions for reducing waste. Read Gregory Merle’s full bio.
Sources
U.S. Environmental Protection Agency — Advanced Recycling of Plastics.