Position Paper: Recycled Content


On the background of environmental discussions on waste and limited resources, being able to claim having recycled content in products has become more and more important. In certification schemes of building products for example, the percentage of recycled content has a big influence on the achievable level.

Although there are meanwhile even certificates for recycled content on the market, the chemical composition of used recycled contents is often largely undefined. The base material is recognizable but the nature and constancy of certain components like analytically identified heavy metals cannot be guaranteed when the prehistory is not defined. Furthermore, there is not as much recycled content available as the market driven by certification schemes demands. For this reason companies are “hunting” for recycled content.


There are recycled materials out on the market that tend to be absurd. In the frame of EPEA’s work, for instance a recycled filler was met that was so contaminated that a direct use as 100% recycled content was not considered. Instead, the recycled filler was diluted with 50% virgin material which had previously been declared as mining waste for not meeting the aesthetic requirements for traditional industrial uses. After having been declared as waste, the material could be declared as recycled content without having ever been used before.

So, too contaminated recycled content was diluted with pseudo recycled content. We see this as a combined case of 1.) dilution of pollution and 2.) questionable labeling for the benefit of a favorable market perception. Other cases of questionable labeling as recycled content are given with the recycling of post production waste in the same application as it came from, for example reprocessing of alloys or plastic resins.

Our Proposal

Incorporating as much recycled content as possible just for the sake of recycled content needs to be changed in certification schemes as well as in people’s heads. Instead of thinking about recycling only after a product’s use phase, emphasis needs to be put on defined and claimed recyclability while designing a product.

For the use of recycled content, it is necessary to define reasonable quality criteria for recycled content considering:

  • that the content to be recycled needs to be extracted from its context first
  • that byproducts of this extraction could also be specified for next uses on other routes
  • the product context in which the recycled content will be used

In addition, the wording itself needs adaptation. Recycled Content appears to be an outdated wording reminding of the former linear thinking from cradle to grave.

The term “nutrients” suggests product quality encompassing defined right materials occurring at the defined right place at the defined right time.

Published by EPEA Internationale Umweltforschung, October 2015