manufacturing · environment · circular-economy · family: the missing yardstick
recycled plastic means whatever you want
No one can specify what "recycled plastic" means — and that's why the circular economy can't scale
Problem statement
The ASTM subcommittee on recycled plastics lists only one published material classification for post-consumer recycled (PCR) plastics. A 2021 ASTM Standardization News feature on the plastics committee (D20) and its recycled-plastics subcommittee (D20.95) said that historically there has been "a dearth of standards for post-consumer recycled plastics (PCR) and PCR suppliers." The subcommittee's list today shows seven active standards: five on separating, washing or identifying contaminants, the resin identification code, and one material classification, for recycled rigid PVC and CPVC (D8655). The same article reports a subcommittee officer's view that the resin identification codes (ASTM D7611) "do not add much value in defining performance of a specific recycle stream." Recycled plastic streams are less consistent than virgin material — the article's example of a property that varies is the level of polypropylene contamination in polyethylene, and it says recycled materials may be made up of several materials or contain additives — and D20 committee chair Mark Lavach said that unless a recycled material's properties are adequately categorized, "it sometimes makes it difficult for the buyer of this stream to use it." Manufacturing equipment requires consistent feedstock; in Lavach's words, "Equipment likes consistency. It doesn’t like variability."
Why this matters
Lavach said the committee has to create "usable standards that enable consistency of supply that both the buyer and seller can agree to and utilize." NIST's economic analysis says "the supply of recycled plastic is more variable, creating uncertainty in supply quality and availability." Participants in the October 2024 U.S.-EU workshop said the EU has specific targets for recycled plastics while the U.S. lacks national ones, and the workstream behind the workshop named upcoming EU circular economy regulations as a focus area. That workstream concluded that "there is a lack of alignment around standards and terminology, including around topics such as recyclates, resin types, and post-consumer waste," and the workshop discussed differing definitions (recyclate, post-consumer, post-industrial, pre-consumer) as potential trade barriers. A D20.95 officer said in 2021 that, other than performance, "the biggest hurdle" for the new specifications will be a product that is FDA compliant for direct food contact; the workshop heard that packaging producers are uncertain how to comply with the differing FDA and EFSA rules for food-grade packaging. The ASTM guide for developing standards on recycled plastics (D5033) was withdrawn in 2007; ASTM's record shows it replaced by D7209, which was itself withdrawn in 2015 with no replacement.
What’s been tried and why it hasn’t worked
In 2021 ASTM D20.95 was drafting three new PCR specifications: WK74657 for recycled polyethylene, and two more for polypropylene and PET. The subcommittee's list today shows a published cell classification for recycled rigid PVC and CPVC (D8655) and three proposed work items, for rigid vinyl recycled content (WK89382), flexible PVC materials (WK98310) and "Circular Plastics" (WK87117); it shows no published classification for recycled polyethylene, polypropylene or PET. NIST published an economic analysis of U.S. plastics recycling (AMS 100-64), which says there is likely a need for material-related standards and standards to track plastic materials. A U.S.-EU workshop in October 2024 identified alignment needs. The difficulty the ASTM article describes is variability: recycled material does not come from the consistent raw material stream that earlier plastics standards assumed, and that variability is the reason buyers want standards. The D5033 guide was withdrawn in 2007 and its replacement, D7209, in 2015, and the subcommittee's list shows no active guide of this kind.
What would unlock progress
A classification system for recycled plastics based on measurable material properties (the ASTM article's examples are tensile strength and the level of polypropylene contamination in polyethylene). This would enable procurement by specified properties. Near-infrared (NIR) spectroscopy is one candidate for rapid characterization of incoming material; the sources read for this write-up do not discuss it. A harmonized U.S.-EU definition set for key terms (recyclate, post-consumer, post-industrial) would, in the workshop's words, "support trade."
Entry points for student teams
A team could collect PCR plastic samples from multiple commercial recyclers, characterize their material properties (melt flow index, tensile strength, contaminant levels via FTIR/DSC), and develop a classification system that groups recycled plastics into performance tiers. This is the kind of property data a cell classification like the ones D20.95 has described would rest on. A complementary project could use NIR spectroscopy to develop a rapid QC screening method for incoming PCR feedstock. A third project needs no laboratory: the workshop report says its table of standards "is not comprehensive" and proposes an online repository of U.S., EU and international standards, so a team could compare how the terminology standards it lists (ISO 472, EN 17615, ASTM D883, ISO 14021) define recyclate and post-consumer, pre-consumer and post-industrial material. Relevant disciplines: materials science, polymer engineering, analytical chemistry, industrial engineering.
Genes
Structural cousins: stuck the same way, in other fields
Sources
ASTM D20.95 Subcommittee on Recycled Plastics (Hunt, K., "Plastics and the Circular Economy," ASTM Standardization News, May/June 2021, subcommittee standards list, ); Thomas, D.S., Kneifel, J.D., and Butry, D.T., "The U.S. Plastics Recycling Economy: Current State, Challenges, and Opportunities," NIST AMS 100-64, October 2024, Last, N. and Baillargeon, L., "Report: U.S.-EU Virtual Workshop on Plastics Recycling Standards and Definitions to Support Transatlantic Trade," October 31, 2024, go to source 1 ↗ go to source 2 ↗ go to source 3 ↗ go to source 4 ↗
Working notes
Notes made while writing and checking this brief, shown as written. They use working shorthand.
- Related to existing briefs on circular economy (`manufacturing-sme-circular-economy-barriers`, `manufacturing-reuse-quality-standardization`) but distinct: this is specifically about the absence of material specifications for recycled feedstock, not the broader circular economy transition challenges.
- The October 2024 workshop report says the EU has specific targets for recycled plastics and the U.S. lacks national ones; the sources give no compliance date.
- ASTM D5033 was withdrawn in 2007 and replaced by D7209, which was withdrawn in 2015 with no replacement.
- The workshop report names work going on outside ASTM: design-for-recycling guidelines from CEN and APR, and the collaboration between APR in the U.S. and RecyClass in the EU.
- FDA food-contact compliance for PCR is a separate, compounding barrier; the workshop report says FDA and EFSA have different requirements for food-grade packaging.
Reconciliation 2026-10-01: Fact repair after reading the whole write-up against the sources it names. All were fetched on 2026-10-01. Read in full: the NIST report AMS 100-64 (https://nvlpubs.nist.gov/nistpubs/ams/NIST.AMS.100-64.pdf, 117 pages; the whole text was searched and the passages on standards, contamination, supply variability and post-consumer recycling were read); the report of the U.S.-EU workshop held on October 1, 2024 (https://tsapps.nist.gov/publication/get_pdf.cfm?pub_id=958975, 7 pages); and the ASTM Standardization News feature that carries the quotations, "Plastics and the Circular Economy" by Kathy Hunt, May/June 2021 (https://www.astm.org/news/plastics-and-circular-economy-mj21). Also read, on astm.org: the list of standards under subcommittee D20.95, the catalogue records for D5033, D7209, D7611 and D8655, and the work item page for WK89382. The Source line named the subcommittee and the workshop without links; it now carries the article, the subcommittee list and the workshop report, with authors and titles copied from those pages. (1) The text said there are "no published ASTM material specifications" for post-consumer recycled plastics. The subcommittee's list shows one, D8655, a cell classification for recycled rigid PVC and CPVC; the sentence now says the subcommittee lists only one and names it. (2) The "dearth of standards" sentence was quoted as the words of "ASTM D20.95 committee chair Mark Lavach." The words are the article writer's, not a quotation from anyone; the quotation had also dropped "(PCR)"; and Lavach chairs the parent committee D20, while the article names Jeffrey Biesenberger as chair of D20.95. The sentence is now attributed to the article and quoted exactly. (3) The quotation "equipment likes consistency — it doesn't like variability" had been joined into one sentence; the article has two sentences, now quoted as printed and attributed to Lavach. (4) Seasonal fluctuation in waste streams, and the statement that buyers have "no standardized way" to specify or compare material, are not in the sources; the sentence now gives the article's examples and Lavach's remark about buyers. (5) Removed because no source contains them: the value chain running on "ad hoc" supplier relationships; the EU Packaging and Packaging Waste Regulation and its August 2026 date; trade barriers "estimated at EUR 120 million/year"; "no ASTM standard addresses food-grade PCR"; the Association of Plastic Recyclers certification scheme of November 2024 "bypassing" ASTM; the "2-4 year" ASTM timeline; and NIST "documenting the market failure" (the report does not use that phrase). In their place the text gives what the NIST report and the workshop report say about supply variability, EU targets, terminology and food-contact rules, and Lavach's sentence on standards that buyer and seller can agree to, quoted in full. (6) "The biggest hurdle" was said of FDA compliance without the article's qualifier; the speaker said "other than performance," and was speaking of the new specifications. The sentence now says so. (7) The text said D5033 was withdrawn in 2007 "and never replaced," leaving "a 19-year gap." ASTM's record for D5033 says it was replaced by D7209, which was withdrawn in 2015 with no replacement. The text and the Source Notes bullet now say that. (8) The text said D20.95 "is currently drafting" three specifications, WK74657 for polyethylene, WK89382 for vinyl "and one additional." The 2021 article names WK74657 for polyethylene and says the other two cover polypropylene and PET. WK89382 is a separate, later work item on rigid vinyl. The paragraph now reports the 2021 plan and what the subcommittee's list shows today, including its three proposed work items. The sentence calling feedstock variability "the fundamental challenge" now reports what the article says about variable recycled streams. (9) NIR spectroscopy being "technically mature" and lacking an ASTM standard is not in the sources; the sentence now says the sources do not discuss it. The examples of measurable properties are now the article's own. "Would eliminate trade barriers" now reads as the workshop report puts it, that aligned definitions will support trade. (10) "This is exactly the pre-standardization data ASTM D20.95 needs" is not in the sources and was softened. An entry point that needs no laboratory was added, drawn from the workshop report's list of terminology standards. Four Source Notes bullets were corrected to match. Confirmed and left as written: the D7611 quotation; the October 2024 workshop; the misalignment over recyclate and post-consumer terms; D5033 withdrawn in 2007. Could not be checked: the current status of WK74657, whose ASTM page returned "not found"; an Internet Archive copy of the work item page from September 2021 (web.archive.org/web/20210921120908/www.astm.org/DATABASE.CART/WORKITEMS/WK74657.htm) shows it as a draft under development in D20.95 for recycled polyethylene, and the subcommittee list no longer shows it. Only the D20.95 list was read, so whether another ASTM subcommittee has published a classification for recycled polyethylene, polypropylene or PET was not checked. The titles were not changed; the long title's "No One Can Specify" is broader than the sources, which show one published classification (for PVC) and none for polyethylene, polypropylene or PET. A second reader went over these repairs against the same sources on the same day (including the Internet Archive copy of the WK74657 page and a clean download of the NIST report) and tightened three sentences: the examples of variability in the Problem Statement now follow the article's own wording (polypropylene contamination in polyethylene; materials made up of several materials or containing additives); the NIST sentence on supply now quotes the report without adding a comparison to primary resin; and "regardless of feedstock source" was dropped from the unlock, since the proposed polyethylene standard indicates material origin. Genes untouched.