Item B Public Comment — Palo Alto City Council, November 3, 2025

From: Cynthia Fan
To: Council, City
Subject: 11-3-25 agenda — Landfill city’s plastic recyclables. Reduce city’s plastic use.

Date: Monday, November 3, 2025 12:05:33 PM
Attachments: 2025 11 03 - Palo Alto - Landfill recyclables. Reduce citys plastic use.pdf CAUTION: This email originated from outside of the organization. Be cautious of opening attachments and clicking on links.

Hi City Council,
Today’s council meeting agenda includes an informational report that discusses the city’s plastic waste.

This report is “not listed for action or discussion during this meeting’s agenda.” However, I really think this subject necessitates discussion by the council.

See my attached letter.

Please agendize this subject for an upcoming meeting.
-Cynthia Fan

Re: 11-3-25 agenda item Info Report B — Landﬁll recyclables. Reduce city’s plastic use.

City Council Members,
I write in regards to Information Report B of the November 3, 2025 agenda.

Plastic’s lifecycle and its human and environmental health implications remain risky. Consider landﬁlling plastic recyclables for now, and increase efforts to reduce the city’s plastic use.

According to the “GWPA Traceability Report -2024” attached to the item in the agenda:
“At the end of 2018, Palo Alto City Council gave City staff direction to report on the intermediate and ﬁnal disposition of Palo Alto’s recovered… plastic. City staff and GWPA agreed that as a goal, GWPA would attempt to gather information on the environmental and social implications associated with the full life cycle of Palo Alto Recyclable Materials.” (Emphasis mine.) Seven years later, however, this most recent report suggests that, despite these efforts, the City hasn’t nailed down the “ﬁnal disposition” of our recovered plastics—or the “environmental and social implications” of plastic’s full lifecycle. Much of what we do know appears to come from companies with a ﬁnancial stake in portraying plastic recycling in a positive light.

Meanwhile, over these seven years, independent research increasingly indicates that plastic recycling may worsen negative impacts on the environment and humans rather than reduce them. Recent studies have found that:
● Recycling facilities release large quantities of microplastics into wastewater during grinding and washing.
● Recycled plastics often contain hundreds of toxic chemicals including endocrine disruptors. Compounds identiﬁed include pesticides, pharmaceuticals, industrial chemicals, plastic additives and other harmful substances. These chemicals can leach from products, contaminating humans and the environment. ● Microplastics have been detected in human organs, where they are linked to inﬂammation and oxidative stress.
● Policy reviews conclude that plastic recycling is inherently ﬂawed because of contamination and chemical additives.

In short, plastic recycling itself can be a major pollution source. I think we should seriously consider that certain plastics—or perhaps all of them—should be landﬁlled until the recycling of them and products produced with them are proven relatively safe.

Given all of the above, I encourage Council to explore the following actions:

1. Document the full life cycle of plastics, not just disposal.

Future annual reports should examine the environmental and social impacts of producing plastic, not just managing its end-of-life. As I highlighted in my introduction, the city’s intent was to examine the “full life cycle.” The city needs this information to comply with its own Environmentally Preferred Purchasing Policy (accessible from the city’s “Plans, Policies, Ordinances” page) which states that “Evaluation prices for goods and services shall factor in life-cycle costs.”

2. Reevaluate whether recycling is the best option for the plastics collected from residents and businesses.

Consider whether sending some or all plastics directly to landﬁll may be the more responsible interim strategy until independent science conﬁrms that recycling processes and recycled products are truly safe. This question is not about legality—it’s about prudence. An absence of regulatory violations does not equate to safety, especially when environmental laws are often shaped by industry lobbying. Besides, there are not yet even any federal or state requirements that recyclers must track or limit the number or amount of microplastics in their wastewater eﬄuent. Does the city really want to continue supporting this risky human and environmental health experiment? Landﬁlls might be the safest place for discarded plastic. Please rethink the city’s goal of 95% diversion from landﬁlls and goal of ﬁnding domestic businesses that will let us pay them to divert waste from landﬁlls. Landﬁll diversion does not consistently support our overarching goal of reducing the environmental and human health implications of Palo Alto’s consumerism.

3. Reduce the City’s demand for nonessential plastics.

Direct staff to review the City’s purchases of nonessential plastics and recommend concrete steps to phase them down over time, ensuring that the total amount used does not continue to grow. For example, Palo Alto’s four plastic turf athletic ﬁelds, if replaced on an appropriate schedule, likely require over 80 tons of plastic, for the carpet, backing, and shockpad, every eight years. For perspective, that’s as much as more than half the total plastic waste of types #2 through #7 that are annually hauled from all City residences and businesses (per page 10 of the 2024 traceability report). The City should prioritize piloting improvements to grass ﬁeld construction and maintenance to reduce the pressure to install more plastic turf and to potentially lower the city’s overall inventory of plastic ﬁelds.

Thank you for considering these points as you continue your important work on waste policy and environmental stewardship.

Sincerely,
Cynthia Fan

References
[1] Stapleton et al. (2023). Science of the Total Environment. “Evaluating the generation of microplastics from an unlikely source: The unintentional consequence of the current plastic recycling process” “Large amounts of microplastics are generated during the plastic recycling process.” https://opus.lib.uts.edu.au/bitstream/10453/178141/2/1-s2.0-S0048969723047150-main.pdf [2] Brown et al. (2023). Journal of Hazardous Materials Advances. “The potential for a plastic recycling facility to release microplastic pollution” “Microplastics <5 µm were generally not removed by the ﬁltration and subsequently discharged, with 59–1184 tonnes potentially discharged annually.” https://doi.org/10.1016/j.hazadv.2023.100309
[3] Umarie & Bagastyo (2024). Journal of Ecological Engineering “Microplastics Identiﬁcation in Plastic Recycling Facility – Removal Eﬃciencies of the Treatment Plants and Its Potential Release to the Environment” “Plastic recycling facilities are one of microplastic sources that may release into the environment.” https://www.jeeng.net/pdf-191506-112829
[4] University of Gothenburg (2023). “Hundreds of Toxic Chemicals in Recycled Plastics.” “scientists will urge delegates to heed the latest science showing that because toxic chemicals are used to make all plastics, and plastics will adsorb other chemicals during use, there are no plastics that can be deemed safe or circular.” https://www.gu.se/en/news/hundreds-of-toxic-chemicals-in-recycled-plastics [5] University of Gothenburg (2025). “Recycled Plastic Can Affect Hormone Systems.” “A single pellet of recycled plastic can contain over 80 different chemicals.” https://www.gu.se/en/news/recycled-plastic-can-affect-hormone-systems [6] Greenpeace USA (2023). “Forever Toxic: The science on health threats from plastic recycling plastics are inherently incompatible with a circular economy.” “While virgin plastics contain unknown and untested harmful chemicals, studies show that recycled plastics often contain higher levels of chemicals that can poison people and contaminate communities. Chemicals in recycled plastics have been linked to cancer, cardiovascular disease, obesity, and other health issues.” https://www.greenpeace.org/usa/forever-toxic/
[7] IPEN (2022). How Plastics Poison the Circular Economy “Toxic chemicals, that have been banned under international chemicals conventions, are being recycled from plastic waste into new consumer products, resulting in risks that are impossible to quantify because of lack of knowledge on material composition.” https://ipen.org/sites/default/ﬁles/documents/ipen-plastic-poison-circ-econ-v1_4w-en.pdf [8] European Parliament (2020). The Environmental Impacts of Plastics and Micro-Plastics Use, Waste and Pollution. “Recycling of plastic waste remains problematic because of the inherent diﬃculties with the collection and separation of the feedstocks used in the recycling process… Reducing toxic exposure to plastic waste, in all its forms, requires a plethora of solutions, both voluntary and legislative.” https://www.europarl.europa.eu/RegData/etudes/STUD/2020/658279/IPOL_STU%282020%29658279_E N.pdf
[9] Inside Climate News (2023). “Who Said Recycling Was Green? It Makes Microplastics by the Ton.” https://insideclimatenews.org/news/16052023/recycling-plastic-microplastics-waste/

Science Politics Justice & Health Fossil Fuels Clean Energy Pulitzer Prize-winning, nonpartisan reporting on thebiggest crisis facing our planet.Donate Science
Who Said Recycling Was Green? It MakesMicroplastics By the TonA study finds one plastics recycling plant in the U.K. produces asmuch as 3 million pounds of microplastics a year—and that’s withfiltering.

By James BruggersMay 16, 2023
Cubes of sorted compressed plastic bottles are seen at the recycling center at the Sile Integrated Waste Facility Center on March 12, 2018 in Istanbul, T urkey. Credit: ChrisMcGrath/Getty Images TRUMP 2.0: The Reckoning
Research out of Scotland suggests that the chopping, shredding and washing of plastic in recyclingfacilities may turn as much as six to 13 percent of incoming waste into microplastics—tiny, toxicparticles that are an emerging and ubiquitous environmental health concern for the planet andpeople.A team of four researchers measured and analyzed microplastics in wastewater before and afterﬁlters were installed at an anonymous recycling plant in the United Kingdom. The study, one of theﬁrst of its kind, was published in the May issue of in the peer-reviewed Journal of HazardousMaterial Advances.If the team’s calculations are ultimately found to be representative of the recycling industry as a Inside Climate News uses cookies. By continuing to use this site, you accept this policy. Learn More Accept https://insideclimatenews.org/news/16052023/recycling-plastic-microplastics-waste/ 11/3/25, 11:00 AMPage 1 of 6 If the team’s calculations are ultimately found to be representative of the recycling industry as awhole, the scale of microplastics created during recycling processes would be shocking—perhaps asmuch as 400,000 tons per year in the United States alone, or the equivalent of about 29,000 dumptrucks of microplastics. The study suggests that rather than helping to solve plastics’ contribution towhat the United Nations has described as a triple planetary crisis of pollution, climate change andbiodiversity loss, recycling could be exacerbating the problem by creating an even more vexingconundrum.Other scientists are ﬁnding microplastics in human blood, human placentas and in virtually allcorners of the planet, and the United Nations has warned that chemicals in microplastics areassociated with serious health impacts including changes to human genetics, brain developmentand reproduction.

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The paper was published as United Nations delegates prepare to hold their second meeting tonegotiate a potential global plastics treaty later this month in Paris, with one potential outcomebeing more plastics recycling as the chemical and plastics industry presses governments to keepplastic in the global economy.“It seems quite backward to me,” said plastics researcher Erena Brown, who led the research whileshe was a graduate student at the University of Strathclyde in Glasgow. “With plastic recycling, wehave designed and initiated it in order to start protecting our environment. I think this study hasshown that we have ended up creating a diﬀerent if potentially slightly worse problem.”The recycling plant allowed researchers to measure microplastics in wastewater before and after theplant installed ﬁlters, which Brown said deﬁnitely helped to reduce microplastics.But even with ﬁlters, the study found that the mechanical recycling process that produced plasticpellets to make new plastic products could still allow as much as 75 billion particles of microplasticsin a cubic meter of the plant’s wastewater.In all, they calculated the plant would annually release as much as 3 million pounds of microplasticswith ﬁltration, and up to 6.5 million pounds without ﬁltration. The study measured microplastics down to a size of 1.6 microns, which Brown said was smaller thantwo other similar studies that the researchers found. Still, she said, with the widespread prevalenceof even smaller micro and nano plastics, smaller than the study’s size limit, the researchers believetheir ﬁndings underestimate the problem.“We assume that there are many, many, many particles in sizes smaller than this,” she said.The researchers also detected microplastics in the air at the recycling facility and suggested thatsuch air emissions should be the focus of additional research since breathing microplastics is a riskto lung health.

Recycling Could Create a ‘Ridiculous’ Amount of Microplastics The plastics and packaging industries have pushed recycling and consumer responsibility fordecades. But plastics are made with thousands of chemicals including additives designed to give https://insideclimatenews.org/news/16052023/recycling-plastic-microplastics-waste/ 11/3/25, 11:00 AMPage 2 of 6 them special properties including clarity, strength, color and ﬂexibility. Many of those chemicals aretoxic, and increasingly, scientists and environmental advocates have been warning that thecomplicated chemical nature of so many diﬀerent types of plastic is what has helped make them sodiﬃcult to recycle.The world is making twice as much plastic waste as it did two decades ago, with most of thediscarded materials buried in landﬁlls, burned by incinerators or dumped into the environment,according to the Organization for Economic Co-operation and Development, a group that representsdeveloped nations. Production is expected to triple by 2060. Globally, only 9 percent of plastic wasteis successfully recycled, according to OECD.

In the United States, the recycling rate could be less than 6percent, according to a 2022 report by the environmental groupsBeyond Plastics and The Last Beach Cleanup.

Kara Pochiro, a spokesperson for the Association of PlasticRecyclers, a trade group representing the recycling industry, said“recycling is an industrial process regulated like any otherindustrial process in the U.S. Recyclers must conform withnational, state, and local regulations regarding all aspects of the business including environmentallaws.” However, Brown said she’s not aware of any requirements anywhere that recyclers must track orlimit the number or amount of microplastics in their wastewater eﬄuent. And in the United States,the Environmental Protection Agency does not speciﬁcally regulate microplastic discharges fromwastewater treatment plants, wastewater experts said this week.

The EPA did not respond to a request for comment.Environmental advocates expressed alarm at the research ﬁndings.The research suggests that recycling plants in the United States could be “creating ridiculousamounts of microplastics,” said Jan Dell, a chemical engineer who has worked as a consultant to theoil and gas industry and founded The Last Beach Cleanup, the nonproﬁt that ﬁghts plastic pollutionand waste.Dell said the study highlights a problem she said she has “been yelling about for years,” what shecalls the “material waste rate” for plastic recycling, “but no one pays attention.” Her owncalculations based on industry data she cited in her group’s report last year with Beyond Plasticsestimated a 30 percent material loss for recycling PET plastic bottles, commonly used by beveragecompanies. “To make 100 bottles out of recycled plastic, 143 bottles have to be collected andprocessed,” she said.The Association of Plastic Recyclers estimates there are more than 100 post-consumer plasticrecycling operations in the United States and Canada. Many are likely sending their wastewater tomunicipal wastewater treatment facilities.Generally, treatment plants are supposed to comply with rules that limit solid particles in theireﬄuent. So regulations would capture some, but not all, microplastics—and what gets throughwould be the smaller and more dangerous particles, Dell said.Microplastics captured in treatment end up in a plant’s biosolid byproduct, or sewage sludge, whichis often spread on land as a fertilizer, allowing microplastics to contaminate the soil and wash intowaterways during rain, according to a March report produced by the Minderoo-Monoco Commissionon Human Health, a body of scientists assembled by the Australian-based Minderoo Foundation,and published in the Annals of Global Health, a peer-reviewed scientiﬁc journal.In fact, more microplastics are estimated to enter the soil from the use of wastewater sludge foragricultural purposes each year than microplastics entering the ocean or freshwater sediments, thecommission study found. “The presence of (microplastics) in sewage sludge poses a threat to soil health and productivity andcould cause harm to soil-dwelling biota,” the Minderoo-Monoco group found.“Microplastic has to go somewhere,” Dell said. “It doesn’t disappear.” Study Adds to UN Plastics Debate
California is at the forefront of microplastics regulatory investigations and potential actions, and isweighing options to limit microplastics in water bodies, said Shelley Walther, an environmentalscientist at the Los Angeles County Sanitation Districts. She’s also leading a task force on https://insideclimatenews.org/news/16052023/recycling-plastic-microplastics-waste/ 11/3/25, 11:00 AMPage 3 of 6 microplastics with the Water Environment Federation, an industry group for wastewaterprofessionals.A 2016 study in Los Angeles found that wastewater treatment designed to collect “suspended solids”are more than 99 percent eﬀective at capturing microplastics, she said. But she also said that thestudy did not include the smallest of the particles.Walther said that among the challenges of curbing microplastics is that they are hard to measure.“There’s still not a lot of great technology,” Walther said.

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She also cited ongoing uncertainty over the health threats from microplastics, pointing to a WorldHealth Organization report from last year that called for more research to get to the bottom ofconcerns about microplastics. What’s needed, she said, are “data quality objectives and standardizedmethods” that will produce believable ﬁndings.The World Health Organization study found that there was limited data to prove that nano andmicroplastic particles have “adverse eﬀects in humans.” But, the WHO, which has called for a stop inthe increase of plastic pollution worldwide, said its ﬁndings do not imply that exposure tomicroplastics is safe. And, the health body concluded, “there is increasing public awareness and anoverwhelming consensus among all stakeholders that plastics do not belong in the environment,and measures should be taken to mitigate exposure” to them.The Minderoo-Monoco Commission on Human Health report, however, took a broader look atplastics throughout their lifecycle and found health and environmental impacts from production touse and disposal, including from microplastics. While acknowledging “gaps remain in knowledgeabout plastics’ harms to human health and the global environment,” the report identiﬁed many ofthe chemicals used in plastics as known toxicants. One of its lead authors, Dr. Philip J. Landrigan, a pediatrician, epidemiologist and director of BostonCollege’s Global Public Health Program and Global Observatory on Planetary Health, said hebelieves the health debate over plastics is largely resolved. “There are still details to be worked out about the exact magnitude, but there is no doubt whatsoeverthat plastic causes disease, disability, premature death, economic damage and damage toecosystems at every stage of its life cycle,” he said in March.At the United Nations, countries are working to develop a treaty or agreement aimed at endingplastic pollution by 2040. Some countries are pushing to reduce and cap plastic production, whichcould double over the next 20 years, while others are focusing on waste management solutions, suchas recycling.For their part, the authors of the recycling plant study on microplastics concluded their reportprovides insight into the potential for plastic recycling facilities to be signiﬁcant sources ofmicroplastic pollution and considerations for ways to reduce that pollution through ﬁltration. Moreresearch is needed to determine whether their ﬁndings are typical and can be extrapolated acrossthe industry, Brown said.But Brown said there could be another potential solution. It is clear, Brown said, that “we don’t know what to do with (microplastics) once we ﬁnd them.” Butthe recycling study “highlights to me that we just need to be making so much more eﬀort in reducingour plastic production and consumption, instead of focusing on recycling.” About This Story
Perhaps you noticed: This story, like all the news we publish, is free to read. That’s becauseInside Climate News is a 501c3 nonproﬁt organization. We do not charge a subscription fee,lock our news behind a paywall, or clutter our website with ads. We make our news on climateand the environment freely available to you and anyone who wants it. https://insideclimatenews.org/news/16052023/recycling-plastic-microplastics-waste/ 11/3/25, 11:00 AMPage 4 of 6

Without dramatically reducing plastic production,
it will be impossible to end plastic pollution
and eliminate the health threats
from chemicals in plastics.

Babies chew plastic toys. © pavla / Shutterstock
Waste sorting at a recycling plant, Sterlitamak, Russia.10 January 2019. © Shutterstock

CONTENTS
3 EXECUTIVE SUMMARY
4 DANGEROUS CHEMICALS IN
RECYCLED PLASTIC: THE THREE

POISONOUS

PATHWAYS
7 RECYCLING PLASTICS
= RECYCLING TOXIC CHEMICALS
8 THE SCIENCE ON CHEMICAL

THREATS FROM PLASTIC
RECYCLING:

ENVIRONMENT AND FOOD
10 POISONING WORKERS AND

COMMUNITIES
12 PRODUCTS POISONING

CONSUMERS
14 HEALTH THREATS FROM PLASTIC

RECYCLING INDUSTRY ACCIDENTS
17 ENDING THE LOVE AFFAIR WITH
PLASTIC “RECYCLED CONTENT”

AND FOCUSING ON REDUCING

PLASTIC PRODUCTION AND USE
18 REFERENCES
19 ENDNOTES
1FOREVER TOXIC

PLASTICS ARE

INHERENTLY

INCOMPATIBLE
WITH A

CIRCULAR

ECONOMY
© Les Stone / Greenpeace
Pumpjack in Colorado © Les Stone / Greenpeace
2 FOREVER TOXIC

EXECUTIVE SUMMARY
The global Greenpeace1 network is advocating for an
ambitious, legally binding Global Plastics Treaty that
accelerates and provides the conditions needed for a
just transition away from dependence on plastic. The
Treaty should promote safer, toxics-free materials and
reuse-based, zero-waste economies, creating new
jobs to support these practices, protecting human and
planetary health, minimizing resource use, and delivering a just transition for workers and affected communities
across the plastics supply and waste chains.

Without dramatically reducing plastic production, it
will be impossible to end plastic pollution and eliminate the health threats from chemicals in plastics. The Treaty must cap and reduce plastic production, and establish a pathway to end virgin plastic production.

A key obstacle is the plastics industry, including fossil fuel, petrochemical, and consumer goods companies,
which continues to put forward plastic recycling and
recycled content as central solutions to the plastic
pollution crisis. The reality is that fewer than 10% of all plastics ever produced have been recycled.2 This
revelation leads many to promote higher recycling targets as the best way to resolve the global plastic crisis. For example, the members of the U.S. Plastics Pact lobby for the recycling and “circular use” of plastics, distracting attention from the need for massive reductions in global plastic production and shifting the burden of dealing with plastic waste away from themselves as the producers
and onto the public.

Many consumer goods companies, including Nestlé,
Unilever, and Coca-Cola, tout the use of recycled plastic in their packaging as an important part of the solution, while failing to achieve significant reductions of overall plastic use, and in some cases increasing plastic use, or meaningful gains in reuse. But the reality is that most plastics collected for recycling are never recycled – and when plastics are recycled, they contain a toxic cocktail of chemicals that makes them unfit for food-grade and other consumer
uses. In fact, plastics are inherently incompatible with a circular economy.

Coca-Cola bottles© Paul Hamilton© Fairfax Media / Getty Images 3FOREVER TOXIC

DANGEROUS

CHEMICALS

IN RECYCLED
PLASTIC:

THE THREE

POISONOUS

PATHWAYS
Dangerous chemicals make their way into recycled
plastic materials from a variety of sources. Since
nearly all plastics are made from a combination of
carbon (mainly oil/gas) and toxic chemicals, the
most obvious pathway is direct contamination, as
chemicals from the original plastic products simply
transfer into recycled plastic. But chemicals can
also enter recycled plastics in other ways, due to
contamination in the plastic waste stream and the
recycling process itself.

The three uncontrollable poisonous pathways of
plastic recycling are:

1. Toxic chemicals in new virgin plastic materials:

When plastics are made with toxic chemicals and
then recycled, the toxic chemicals can transfer into
the recycled plastics.

2. Leaching of toxic substances into plastic waste:

Numerous studies show that plastics can absorb
contaminants via direct contact and through
the absorption of volatile compounds.3 When
plastics are tainted by toxins in the waste stream
and the environment and are then recycled, they
produce recycled plastics that contain a stew of
toxic chemicals. For example, plastic containers
for pesticides, cleaning solvents, and other toxic
chemicals that enter the recycling chain can result in
contamination of recycled plastic.

3. New toxic chemicals created by the recycling
process: When plastics are heated in the
recycling process, this can generate new toxic
chemicals that make their way into the recycled
plastics. For example, brominated dioxins are
created when plastics containing brominated
flame retardants are recycled,4 and a stabilizer
used in plastic recycling can degrade to a highly
toxic substance found in recycled plastics.5
Sorting challenges and the presence of certain
packaging components in sorted materials can
also lead to toxicity in recycled plastic. Studies
have shown that benzene (a carcinogen) can be
created by mechanical recycling of PET#1 plastic,
even with very low rates of contamination by
PVC#3 plastic, resulting in the cancer-causing
chemical being found in recycled plastics.6
4 FOREVER TOXIC

PLASTIC

RECYCLING'S

UNCONTROLABLE

POISONOUS

PATHWAY
1 23

1. Rubber Duck © Roman Gorielov / Shutterstock, 2. Inudstrial plastic storage containers © Leitenberger Photography / Shutterstock, 3. Melted plastic. © wittaya photo / Shutterstock TOXIC

CHEMICALS
IN NEW
VIRGIN

PLASTIC

MATERIALS

LEACHING

OF TOXIC

SUBSTANCES

INTO PLASTIC
WASTE

NEW TOXIC

CHEMICALS

CREATED BY

THE RECYCLING

PROCESS
5FOREVER TOXIC
Hypothalmus
Pituatary
Thyroid
Parathyroid
Cardiovascular
Mammary
Liver
Adrenal
Kidney
Adipose tissue
Pancreas
Ovary
Prostate
Testis
Bone
Pineal

THE HUMAN

ENDOCHRINE
SYSTEM
The hormones released by the
endocrine system control many
important functions in the body,
including growth and development,
metabolism, and reproduction.

Because of the endocrine system’s
critical role in so many important
biological and physiological functions,
impairments in any part of
the endocrine system can lead to
disease or even death.
6 FOREVER TOXIC

WHEN PLASTIC WASTE

IS HIGHLY TOXIC

POPS WASTE
Persistent organic pollutants (POPs) are among
the world’s most toxic chemicals, regulated
globally under the Stockholm Convention, as is
waste containing POPs. The Convention sets a
concentration limit for each POP, called the Low
POP Content Level (LPCL), and any plastic waste
that contains one or more POPs above the LPCL
threshold is defined as POPs waste. Common
plastics with intentionally added POPs include
electronics, vehicle and aircraft plastic interiors,
and synthetic textiles in furniture, carpets, and
other floor coverings, among other products.

Under the Convention, Parties must destroy
and must not recycle POPs waste (with some
exceptions if the POPs can be removed and
managed separately). But current LPCLs are not
strong enough to prevent recycling of plastic POPs
waste, so, as several studies below show, many
recycled plastic products have been found with
high levels of these highly toxic POPs.

RECYCLING

PLASTICS
Plastics are made with as many as 13,000 chemicals,
and researchers say 3,200 of these are chemicals of
concern (while many more have never been assessed
and may also be toxic).7 While virgin plastics contain
unknown and untested harmful chemicals, studies
show that recycled plastics often contain higher levels of chemicals that can poison people and contaminate
communities.8 Chemicals in recycled plastics have been
linked to cancer, cardiovascular disease, obesity, and
other health issues.9
It is important to understand that not only are people
exposed to toxic chemicals from the production and use of virgin plastic, they are also exposed to toxic chemicals by plastic recycling throughout the recycling stream:
• When plastics are exported under the guise of
recycling, they are often dumped or burned, leading to
environmental and food chain contamination.
• Workers and their communities are exposed to toxic
chemicals from plastics they collect, sort, and dismantle for recycling. Plastic recycling areas should be regulated as facilities that handle hazardous waste and like
contaminated sites that release hazardous chemicals.
• Recycled plastic products expose consumers to toxic
chemicals, including chemicals that have been globally
banned. Recycling can combine toxic chemicals from
different plastics and create new hazardous chemicals,
all of which end up in recycled plastic products.
= RECYCLING
TOXIC

CHEMICALS
Interior of airplane © Juan Manuel Aparicio Diez.Shtterstock 7FOREVER TOXIC

THE SCIENCE

ON CHEMICAL

THREATS

FROM PLASTIC
RECYCLING:

ENVIRONMENT

AND FOOD
A broad range of studies demonstrate how people and
the environment can be poisoned by plastic recycling.

RECYCLED PLASTICS CAN CONTAMINATE
THE ENVIRONMENT AND FOOD CHAINS:

A 2013 report10 in Nature recommended regulating
plastic waste as hazardous waste, including waste
presumably intended for recycling, noting threats to
the environment, food chains, and health. The article
noted that wildlife that consumes plastics can be
harmed by toxic chemicals in these products, with
previous research showing such threats to all sea turtle species, 45% of marine mammal species, and 21% of
seabird species. The authors state, “As plastic (waste) breaks into smaller pieces, it is more likely to infiltrate food webs.”
A 2013 study11 found harmful air-polluting chemicals
around and inside plastic recycling facilities in China, with potential health impacts on workers and local
residents. Concentrations of harmful chemicals near
the facilities were higher than those at a reference site.

Two studies12 from China found high levels of plastic
flame retardant chemicals in soils, sediment, and road
dust near plastic recycling facilities compared to low
levels in samples from areas where no plastic recycling takes place.

A 2021 study13 by the International Pollutants Elimination Network (IPEN) and Arnika analyzed 35 pooled free-
range chicken egg samples and 1 individual egg sample
from 25 locations worldwide for certain persistent
organic pollutants. Eggs produced around e-waste
and plastic waste recycling yards were among the most
contaminated samples in the study.
8 FOREVER TOXIC
1 1. Plastic wrapped apples in a Hong Kong supermarket
© Patrick Cho / Greenpeace 2. Municipal collection of
recycling © Dmitry Kalinovsky / Shutterstock 3.Plastic in a landfill in China © Greenpeace / Yat Yin 4. Fish that ingested microplastic © The 5 Gyres Institute 5. Garbage next to rice fields in China © Rumbo a lo desconocido / Shutterstock 6. Microplastics pollution from the river Rhine in Germany© Oliver Tjaden / Greenpeace 7. Cooking with eggs © fizkes / Shutterstock
9FOREVER TOXIC
2 4
6 5
7 3

RECYCLED PLASTICS CAN POISON
WORKERS AND COMMUNITIES:

A 2015 study14 found that workers in plastic recycling
workshops face health risks from volatile organic
compounds produced by recycling processes, with
some workers facing an increased cancer risk.

A 2020 study15 of plastic recycling workers (waste
pickers) in the Gaza Strip found that most had been
exposed to hazardous materials in the previous 12
months, and most reported occupational illnesses.

A 2021 study16 of Vietnamese recycling concluded
that “the typical processes for plastic recycling
in craft villages come along with health risks for
workers and neighbors and a high potential of
environmental pollution.”
A 2022 Human Rights Watch report17 documented
the health impacts of plastic recycling facilities in
Turkey, finding that recycling workers and nearby
residents can be exposed to harmful chemicals
when they inhale toxic dust or fumes. This poses risks
of life-long health conditions, including cancer and
reproductive harm.

A 2023 IPEN study18 found the plastic flame retardant
chemical Dechlorane Plus (DP) in the blood, food,
and surroundings of home-based recycling workers.

Blood testing of one plastic recycling worker in
Thailand found a level of DP nearly 280 times higher
than the trace levels found in farm workers who lived
15 km from the recycling operations.

THE SCIENCE

ON CHEMICAL

THREATS

FROM PLASTIC
RECYCLING:

POISONING

WORKERS AND

COMMUNITIES
10 FOREVER TOXIC
1 1. Recycled plastic in India ©
PradeepGaurs / Shutterstock 2. A trash
collector working in a waste collection
facility in Instanbul, Turkey.© Sahan
Nuhoglu / Shutterstock 3. Electronic
waste recycling plant in Turkey ©
OVKNHR / Shutterstock 4. Volunteer
wearing gloves to handle plastic
sorting work at a plastic recycling
plant. © Greenpeace
11FOREVER TOXIC
2 3
4 RECYCLED PLASTIC PRODUCTS
CAN POISON CONSUMERS:

A 2015 study19 by researchers from Czechia and Germany
found that recycled plastics used in food packaging
and other products contained toxic flame retardants,
including banned POPs, with potential health impacts on children and consumers.

A 2017 study20 found high levels of toxic flame retardants in toys and other recycled plastic products purchased in the EU, with one child’s toy containing levels of a regulated chemical nine times higher than EU safety limits.

A 2018 study by IPEN, Arnika, the Health and
Environment Alliance, and BUND21 found high levels
of dioxins in recycled plastic products, including toys, from seven countries on four continents. The levels were similar to those found in some hazardous wastes, such
as waste incineration ash, and in half of the products
exceeded proposed limits for chlorinated dioxin in
hazardous waste.

A 2021 IPEN study22 analyzed recycled plastic pellets
purchased from 24 recycling facilities in 23 countries.

Testing showed that all of the pellets contained at least one toxic chemical and 21 samples contained all three
types of chemicals tested for, including endocrine-
disrupting chemicals and chemicals with links to
neurotoxicity, cytotoxic effects, and cardiovascular
impacts. Noting that recycled pellets are often
made into toys and other products for children, the
report warned that its results “raise concerns about
potential health impacts and exposure of vulnerable
populations such as children.”
A 2020 study23 found high levels of highly toxic dioxins in recycled plastic toys, three of which were found to
be “as contaminated as hazardous waste” under the
Stockholm Convention’s limits. It also estimated daily
ingestion of toxic chemicals from children’s mouthing
habits, finding that the “contribution of the ingestion of contaminated black plastic to children’s dioxin
body burden is significant and often higher than the
recommended TDI [tolerable daily intake].”
A 2022 IPEN report24 summarized data on recycled plastic products from China, Indonesia, and Russia, finding that all of the products contained toxic chemicals, including substances banned under international conventions. All
73 products analyzed contained one or more globally
banned flame retardant chemicals.

A 2022 study25 found that recycled plastic bottles had
higher concentrations of toxic chemicals than bottles
made with new plastics, indicating that the recycling
process can intensify chemical threats.

A 2022 study26 by IPEN, Arnika, and partners in 11 African and Arabic countries found toxic chemicals in recycled
plastic toys, kitchen utensils, and other products. Out of 83 products analyzed, 61 had levels of POPs that would
define the products as POPs waste under limits proposed by African countries.

A 2023 study27 from the Fraunhofer Institute and IES Landau tested post-consumer plastic recyclates from different
European countries, finding 51 chemicals with intermediate to high toxicity risks and 30 that could not be identified (under EU law, only authorized substances can be used in food grade plastics28).

A 2023 IPEN study of recycled plastic products purchased in Kenya29 found that 14 of the 18 products contained high levels of toxic flame retardants, exceeding a definition of hazardous POPs waste proposed by African countries. One sample, a toy car, was tested for brominated dioxins and contained the toxic chemicals at higher concentrations than levels found in ash from waste incineration.

THE SCIENCE ON

CHEMICAL THREATS

FROM PLASTIC
RECYCLING:

PRODUCTS POISONING

CONSUMERS
12 FOREVER TOXIC

1. Plastic ffragments © Meaw_
stocker / Shutterstock 2.Electronic
waste recycling plant in Turkey ©
OVKNHR / Shutterstock 3. Fruit
in single use plastic packaging
© monticello / Shutterstock 4.

Product images of plastic bottles
made by Coca-Cola, Pepsi and
Nestle, three of the biggest plastic
polluters. © Tim Aubry / Greenpeace

HEALTH THREATS

FROM PLASTIC

RECYCLING

INDUSTRY

ACCIDENTS
As plastic stockpiles increase, the risk of large fires at recycling facilities is increasing, especially when facilities hold e-waste plastics with used batteries. A survey in
the U.S. and Canada in 2022 found a record 390 fires in plastic recycling and waste facilities.30 Another project has mapped fires at plastic recycling facilities globally since 2018.31 A report from Turkey noted that the number of fires at plastic recycling facilities in that country increased from 33 in 2019 to 121 in 2021, one every three days.32 Similarly, in Malaysia a 2020 report noted a
1 14 FOREVER TOXIC

1. A fire at a plastics recycling plant in Richmond,
Indiana, forced the evacuation of 2,000 nearby
residents. Credit: Kevin Shook/Global Media
Enterprise. 2. Fire at plastics factory, Hull, UK

3. Black smoke rises over an explosion at a plastic
factory in Thailand.© Varit Soponpis / Shutterstock
2 3
doubling in fires at plastic recycling facilities over the previous year, stating that environmental health experts had warned residents that the fumes from the fires could cause respiratory problems, trigger and aggravate
asthma, and cause rashes and eyesores.33 Two 2017
studies34 found that a 2015 fire at a plastic recycling facility in Greece released persistent carcinogenic
compounds (dioxins and furans) and concluded that
even short-duration releases could increase lifelong
cancer risks for nearby residents. After another Greek
plastic recycling facility fire in 2020, health experts warned residents to avoid or thoroughly wash local
produce due to the toxicity of chemicals released by
burning plastics.35 In the 12 months up to April 2023, large fires have been reported at plastic recycling facilities in Australia,36 Canada,37 Ghana,38 Russia,39 Southern
Taiwan,40 Thailand,41 and the United Kingdom,42 and in
the U.S. states of Florida,43 Indiana,44 North Carolina,45 and Nebraska46 (at a plant that was producing plastic
lumber from recycled plastics).]
15FOREVER TOXIC

PLASTIC

PRODUCTION

FORECAST

ENDING THE LOVE

AFFAIR WITH PLASTIC
“RECYCLED CONTENT”

AND FOCUSING ON

REDUCING PLASTIC

PRODUCTION AND USE
Without dramatically reducing plastic production, it
will be impossible to end plastic pollution. The existing discrepancy between the amount of plastic produced
and the amount recycled is vast, with the Organisation
for Economic Co-operation and Development (OECD)
estimating that only 9% of plastic waste is recycled
globally. The situation is only set to get worse as plastic production is forecast to triple by 2060, with only a
minimal increase in recycling predicted.47 The downstream impacts of overproduction of plastic are well documented, including harming the health of communities living near dumpsites and incinerators, evidence of prevalence of
plastic in the human body, and devastation to marine life.

According to UN statistics, in 2018 approximately 6 million tonnes of plastic waste were traded internationally, largely in the form of exports of unsorted mixed plastics from high- income to low-income countries, predominantly in South
and South East Asia.48 A 2023 report found that this number is likely a significant underestimation, and warned that “without global policies to reduce plastic production, there will continue to be an unequal exchange of plastic wastes from high-income countries to low- and middle-income
countries”49 – many of them with a lower GDP than the
revenue of major plastic producing companies.

Despite the devastating impacts of the overproduction of plastic and the need to accelerate refill- and reuse-based systems, the plastics industry continues to argue that the global plastic crisis can be addressed by raising national recycling targets and increasing the amount of recycled content in single-use plastic packaging. But in addition to the health concerns associated with the use of recycled plastics, increased plastic recycling means expanding
toxic health and environmental threats throughout the
recycling stream. These threats unequally impact the
most vulnerable communities.

Instead of encouraging more toxic plastic
recycling, the Global Plastics Treaty must:
1 Achieve immediate, significant reductions in
plastic production, establishing a pathway to
end virgin plastic production.
2 Promote a shift to refill- and reuse-based
economies, creating jobs and standards in new
reuse industries and supporting established
zero-waste practices.
3 Support a just transition for workers across the
plastics supply chain, prioritizing waste pickers
who collect approximately 60% of all plastic
that is collected for recycling globally.
4 Promote non-combustion technologies for
plastic stockpiles and waste disposal.
5 Institute the “polluter pays” principle for plastic
waste management and for addressing the
health and environmental costs throughout
the plastics life cycle.
6 Significantly improve regulation, oversight,
safety and worker protections for existing
recycling facilities.
7 Require transparency about chemicals in
plastics and eliminate all toxic additives and
chemicals used in the plastics life cycle.
17FOREVER TOXIC
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REFERENCES
18 FOREVER TOXIC
1 References to Greenpeace in this document refer to the program - matic work of the Plastic Free Future Campaign, a global campaign involving several offices across the global Greenpeace network of 26 independent organizations, including Greenpeace USA and Greenpeace International
2 UN Environment Programme (2021)
3 See e.g. Cook et al. (2023).
4 Petrlík et al. (2022)
5 Rung et al. (2023)
6 Alvarado Chacon et al. (2020), van Velzen et al. (2020) 7 UN Environment Programme & Secretariat of the Basel, Rotterdam and Stockholm Conventions (2023)
8 CHEM Trust (2022)
9 See e.g. Ahern et al. (2022), Callaghan et al. (2020), and Heindel et al. (2022).
10 Rochman et al. (2013)
11 Huang et al. (2013)
12 Tang et al. (2014), Tang et al. (2015)
13 Petrlík et al. (2021)
14 He et al. (2015)
15 Al-Khatib et al. (2020)
16 Salhofer et al. (2021)
17 Human Rights Watch (2022)
18 Dvorska et al. (2023)
19 Puype et al. (2015)
20 Guzzonato et al. (2017)
21 Petrlík et al. (2018)
22 Brosché et al. (2021)
23 Budin et al. (2020)
24 IPEN (2022)
25 Gerassimidou et al. (2022)
26 Petrlík et al. (2022)
27 Rung et al. (2023)
28 European Commission (2011)
29 CEJAD, IPEN & Arnika (2023)
30 Quinn (2023)
31 The Last Beach Cleanup, Fires at Plastic Recycling Facilities [Online]
32 Agence France Presse (2022)
33 Ayamany (2020)
34 Sarigiannis (2017), Sarigiannis et al. (2017)
35 ekathimerini.com (2020)
36 May (2023), Treasure (2022)
37 CTV News Edmonton (2022)
38 E.hope (2022)
39 Hromadske Int. [@Hromadske] (2023)
40 Everington (2022)
41 Newsflare (2023)
42 Elworthy (2022)
43 McLaughlin (2022)
44 Associated Press (2023)
45 Martin (2022)
46 6 News (2023)
47 OECD (2022). The OECD estimates that the share of plastic waste that is recycled will increase to approximately 17% by 2060. 48 Cook et al. (2023)
49 Karlsson et al. (2023)

ENDNOTES
Activists from Greenpeace Africa hold banners in support of a Global Plastics Treaty. Ngong Hills, Nairobi, Kenya, 02/24/2022 © Paul Basweti / Greenpeace 19FOREVER TOXIC
PUBLISHED MAY 2023
GREENPEACE, INC.
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Suite 1100 East
Washington, DC 20005
www.greenpeace.org/usa
Greenpeace is a network of
global, independent campaigning
organizations that use
peaceful protest and creative
communication to expose global
environmental problems and
promote solutions that are essential
to a green and peaceful future.

SPECIAL THANKS TO
Asia Arminio, Björn Beeler,
Tanya Brooks, Vito Buonsante, Jan
Dell, Graham Forbes, Rachel Head,
John Hocevar, Jamie Kalliongis,
Dr. Therese Karlsson, Charles Margulis,
and Kate Melges.

This report was developed in
collaboration with International
Pollutants Elimination Network (IPEN)
and The Last Beach Cleanup.

DESIGN
Paul Hamilton, weareoneanother.net
Greenpeace projects messages and plastic waste imagery in Uruguay as global leaders come together to discuss a Global Plastics Treaty in Punta del Este, Uruguay. © Greenpeace / Manuela Lourenço

Palo Alto City CouncilNovember 3, 2025

Palo Alto City Council
November 3, 2025