Letter to Governor Newsom: Recycling Definition Under SB 54
December 16, 2024
Dear Governor Newsom,
On behalf of American Circular Textiles (ACT), I’m writing to address a significant issue related to the treatment of recycling technologies under the rules being developed for California’s Plastic Pollution Prevention and Packaging Producer Act (SB 54).
ACT has been heavily engaged in the amendment process and ultimate passage of California’s Responsible Textile Recovery Act (SB 707), actively participating in a year of direct feedback to the sponsors and author of the bill, along with working groups held by the sponsor, shaping the bill into a more effective and balanced framework. While we have several outstanding concerns about SB 707, for the purposes of this letter, we are focusing on SB 54, as SB 707 will inevitably follow SB 54’s lead given that they share recycling definitions.
It’s deeply concerning that certain interest groups appear intent on influencing the state to exclude specific recycling technologies or to oversimplify the conversation by treating all technologies as one and the same. By sidelining essential innovations, we risk not only stalling progress but also rendering any Extended Producer Responsibility (EPR) regulation completely ineffective. These technologies have the potential to significantly improve recycling rates and environmental outcomes. This approach demonstrates a lack of understanding of both the opportunities these technologies offer and the potential consequences of excluding them, including: the environmental impact of more waste, reduction of the quality of recycled content on the market, and the overall reduction of availability for recycled fibers overall which will stop brands and retailers from adopting recycled content.
Textile recycling, in particular, will be virtually impossible without the inclusion of some advanced recycling technologies. Mechanical recycling, while useful in a narrow set of cases, produces an inferior product and is ineffective for the majority of textiles, due to the complexity of blended fabrics, synthetic fibers, and quality degradation during processing. Advanced recycling technologies are essential to recover high-quality materials, close the loop, and achieve true circularity in the textile industry. To dismiss them would be to undermine the very progress we aim to achieve in building a more sustainable and circular future for textiles.
For further context, other advanced economies with more stringent environmental policies than the U.S., including those in the European Union, have not encountered similar challenges. Instead, they have embraced these technologies, as part of a comprehensive strategy to reduce, reuse and recycle products effectively. As a result, the EU is on track to achieve its recycling goals while fostering innovation. Their categorization approach supports a range of recycling technologies, enabling both current advancements and future innovations. Rather than limiting recycling processes to 1 or 2 specific methods, the EU's approach ensures opportunities remain open for the adoption of higher-quality recycling solutions, both now and in the future as innovations advance. Adopting a similar framework in California and categorizing technologies by environmental viability, availability and scalability, would create a balanced pathway to address immediate needs while fostering ongoing innovation in the textile recycling space.
Without inclusive recycling options, California risks several harmful outcomes. First, narrowly designed recycling policies could impose unintended and avoidable compliance costs on brands, which will likely be passed on to consumers, burdening taxpayers and hindering economic progress within the state. Second, California could transfer its waste burden to other nations, leading to two significant risks: recipient nations may leverage this waste as a resource, gaining a competitive economic advantage over California by adopting advanced technologies and systems that transform waste into value. Alternatively, nations lacking adequate infrastructure may struggle to manage the influx, resulting in environmental harm and reputational damage to participating producers. This not only risks tarnishing their brands but also exacerbates environmental degradation. Failing to address these issues responsibly would jeopardize domestic economic opportunities, such as leveraging innovative technologies that provide superior environmental alternatives to virgin materials, ultimately limiting California’s potential for leadership in the circular economy.
California has the opportunity to lead with reuse, repair, along with a potential path forward with an informed approach to recycling technologies. This is essential to meeting its ambitious reuse, recycling, and source reduction goals and setting a precedent for other states and federal initiatives.
We urge careful consideration of these issues and stand ready to collaborate and provide input to ensure that these regulations reflect practical realities and maximize environmental and economic benefits.
Thank you for your attention to this critical matter.
Best regards,
Rachel Kibbe
CEO, American Circular Textiles
About ACT (American Circular Textiles)
American Circular Textiles (ACT) is a leading industry association dedicated to advancing circularity and sustainability within the U.S. textile and fashion sectors. Our mission is to promote policies and initiatives that reduce waste, increase textile recycling, and support domestic manufacturing, all while fostering collaboration across the supply chain. With a rapidly growing membership of industry leaders, ACT provides valuable resources, advocacy, and networking opportunities to its members, ensuring they are at the forefront of legislative and market developments. By driving meaningful change in both policy and practice, ACT is committed to shaping a more sustainable future for the textile industry.
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www.americancirculartextiles.com