No One Can Specify What "Recycled Plastic" Means — And That's Why the Circular Economy Can't Scale

There are no published ASTM material specifications for post-consumer recycled (PCR) plastics. ASTM D20.95 committee chair Mark Lavach stated directly that there has been "a dearth of standards for post-consumer recycled plastics and PCR suppliers." Existing resin identification codes (ASTM D7611) "do not add much value in defining performance of a specific recycle stream." Recycled plastics exhibit significant compositional variation across batches — seasonal fluctuations in waste streams, foreign polymer contamination, additive packages — and buyers have no standardized way to specify, evaluate, or compare what they're purchasing. Manufacturing equipment requires consistent feedstock, but "equipment likes consistency — it doesn't like variability."

Without material specifications, the entire recycled plastics value chain operates on ad hoc supplier-buyer relationships rather than standardized procurement. Manufacturers wanting to meet voluntary or mandatory recycled content commitments cannot reliably source PCR at consistent quality. The EU's Packaging and Packaging Waste Regulation (PPWR, effective August 2026) mandates specific recycled content targets that U.S. producers and exporters will need to meet. U.S.-EU terminology misalignment (definitions of "recyclate," "post-consumer," "post-industrial") creates trade barriers estimated at EUR 120 million/year in additional costs. FDA compliance for food-contact recycled plastics is "the biggest hurdle," and no ASTM standard addresses food-grade PCR. The previous ASTM guide for recycled plastics standards development (D5033) was withdrawn in 2007 and never replaced.

ASTM D20.95 is currently drafting three new PCR specifications (WK74657 for recycled PE, WK89382 for recycled vinyl, and one additional). The Association of Plastic Recyclers (APR) published its own Certification Scheme in November 2024, bypassing ASTM's consensus process. NIST published a comprehensive economic analysis (AMS 100-64) documenting the market failure. A U.S.-EU workshop in October 2024 identified alignment needs. However, the fundamental challenge is feedstock variability: recycled plastics are heterogeneous by nature, and the compositional variation that makes standardization difficult is the same reason standardization is needed. The D5033 guide was withdrawn in 2007, leaving a 19-year gap in ASTM's standards framework for recycled plastics. The new work items are in early drafting stages and face the typical 2-4 year ASTM development timeline, putting them past the EU PPWR compliance deadline.

A classification system for recycled plastics based on measurable material properties (melt flow index, contaminant levels, color, mechanical properties) rather than origin or process history. This would enable specification-based procurement regardless of feedstock source. Near-infrared (NIR) spectroscopy for rapid incoming material characterization is technically mature but lacks a corresponding ASTM standard for recycled plastic classification. A harmonized U.S.-EU definition set for key terms (recyclate, post-consumer, post-industrial) would eliminate trade barriers.

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 exactly the pre-standardization data ASTM D20.95 needs. A complementary project could use NIR spectroscopy to develop a rapid QC screening method for incoming PCR feedstock. Relevant disciplines: materials science, polymer engineering, analytical chemistry, industrial engineering.