Article

More than 30 Years of PVC Recycling in Europe—A Critical

Inventory
Uwe Lahl * and Barbara Zeschmar-Lahl

BZL Kommunikation und Projektsteuerung GmbH, D-28876 Oyten, Germany; [email protected]

* Correspondence: [email protected]

Abstract: PVC has a special status, as chlorine is a component of the polymer molecule. The prop-
erties of chlorine are the reason why the polymer molecule needs additivation. PVC is the mass
plastic to which the most diverse and quantitatively largest number of additives are added. This
makes PVC difficult to recycle. More than three decades ago, the PVC industry announced its com-
mitment to improve the sustainability of the material through material recycling. We analysed the
latest figures from the European PVC industry, ensuring that the statistics included the quantities
that enter the market as recyclate. We also analysed the significance of replacing virgin PVC with
recyclates. We conclude from this that, after a good three decades, the recycling result is rather mea-
gre. The lion’s share of PVC waste in Europe is still going to waste-to-energy plants, where it tends
to be a nuisance. The many announcements to close the chlorine cycle via waste incineration have
not got very far either. And the announcements to expand chemical recycling in parallel have not
been successful. On the basis of this stocktaking, we have analysed, in a second separately published
part, which conclusions can be drawn for regulatory measures, building on a current ECHA inves-
tigation report.

Keywords: PVC; material recycling; chemical recycling; chlorine cycle; additives

1. Introduction
The history of the chemical industry over the last 150 years includes a large number
of pioneering developments such as the synthesis of dyes (fuchsine, alizarin, indigo), elec-
Citation: Lahl, U.; Zeschmar-Lahl, B.
trolysis (e.g., extraction of chlorine and caustic soda from water and common salt), the
More than 30 Years of PVC
Haber–Bosch process (production of ammonia from atmospheric nitrogen), or the
Recycling in Europe—A Critical
Fischer–Tropsch synthesis (production of hydrocarbons from carbon monoxide and hy-
Inventory. Sustainability 2024, 16,
drogen). However, it is also characterised by damage to humans and/or the environment,
3854.
https://doi.org/10.3390/su16093854
which in some cases has been recognised only many years after the actual event. This
particularly applies to chlorine chemicals. In the early 1970s, for example, a chemical
Academic Editor: Antonio Caggiano (DDT = Dichlorodiphenyltrichloroethane) was banned for the first time due to its recog-
Received: 14 April 2024 nised damage or risks (persistence, biomagnification, and toxicological effects). Following
Revised: 26 April 2024 an environmental disaster (dioxins) caused in 1976 by an accident at a chemical plant in
Accepted: 28 April 2024 Seveso, northern Italy, Germany responded in 1980 with the Hazardous Incident Ordi-
Published: 4 May 2024 nance, followed, in the EU in 1982, by the so-called Seveso Directive [1]. In the following
years, the production and use of certain persistent organic pollutants (POPs) have been
banned worldwide since the Stockholm Convention came into force.
Copyright: © 2024 by the authors. Li- At that time, the risks of chlorine chemistry were the subject of intense debate. The
censee MDPI, Basel, Switzerland. plastic PVC (polyvinyl chloride) was also part of this debate, e.g., in Germany [2], Austria
This article is an open access article [3], or in the US and Canada [4]. Parallel to the debate about a ban at federal level, there
distributed under the terms and con- were, in the 1980s, various municipal initiatives in Germany to stop PVC being used in
ditions of the Creative Commons At- construction projects because PVC was not considered sustainable. The main applications
tribution (CC BY) license (https://cre- of PVC in the construction sector are pipes, window profiles, rigid films (=rigid PVC
ativecommons.org/licenses/by/4.0/).

Sustainability 2024, 16, 3854. https://doi.org/10.3390/su16093854 www.mdpi.com/journal/sustainability

Sustainability 2024, 16, 3854 2 of 24

applications) and cables, floorings, and synthetic leather (=flexible applications). One of
the first cities to ban PVC in construction projects was Bielefeld [5], followed by further
cities such as Dusseldorf, Nuremberg, Munich, and Vienna. The main arguments and con-
cerns at the time were:
• In the event of fire, PVC serves as a precursor for the formation of toxic substances
such as dioxins, and the fire residues are hazardous waste [6–8].
• PVC interferes with waste disposal (chlorine and toxic additives) [6].
• PVC is not sustainable (because of, e.g., problematic additives (heavy metals,
phthalates), poor recyclability, mercury emissions from chlor-alkali electrolysis
(amalgam process)) [7,9].
Many cities and municipalities subsequently issued a “PVC ban” for public buildings
(i.e., products containing PVC were excluded from tenders for construction work). In Aus-
tria, for example, PVC-containing floor coverings, wall coverings, plastic pipes, and elec-
trical installations are excluded from the procurement of materials for the new construc-
tion and renovation of service buildings (office buildings, educational buildings, sports
and event venues, and healthcare buildings and hospitals) [10].
In order to counter the threat of government regulation of PVC, the manufacturing
and processing industry in Germany has launched its own initiative. Behind the PVC in-
dustry’s “Plastics Cycle”, “PVC cycle guarantee” and “Global Recycling” concepts of 1988
and the AGPU (Arbeitsgemeinschaft PVC und Umwelt e.V., i.e., Working Group on PVC
and Environment), which was founded for this purpose, lies the idea of recycling PVC
waste and the chlorine it contains, and thus solving the respective waste and sustainability
problem [11–13] (see also Section 2.4). Of course, an ideal circular economy entails much
more than only recycling, i.e., a cascading of material and energy use, starting with reuse,
refurbish, etc.
In 2000, the AgPU recycling promise was “europeanised”, probably driven by the
public consultation process initiated with the EU Commission’s PVC Green Paper [14].
With “Vinyl 2010”, the European PVC industry presented a ten-year program aimed at
moving towards sustainability [15]. The sustainability pledge also included a commitment
to promote recycling throughout Europe. The pledge was then given different names for
the following decade: “VinylPlus”, and most recently (2021) “VinylPlus 2030”. We will
stick with ‘Vinyl’ in the following Sections.
This article takes a closer look at the PVC industry’s recycling promises, critically
examines the reported successes of material recycling, and analyses the possible causes
for the achieved recycling rates. The status of chemical recycling to date is also discussed.
The article ends with an outlook for the second part of our review about PVC.

2. Materials, Methods, Definitions, and Target

2.1. PVC Polymers and PVC Compounds
The basic building block of PVC is chloroethene (H2C=CHCl), better known as vinyl
chloride monomer or VCM. In the United States and Europe, VCM is mainly produced
based on chlorination (+ Cl2) of ethylene followed by dehydrochlorination (− HCl) of the
produced ethylene dichloride (EDC):
Ethylene (H2C=CH2) + Chlorine (Cl2) → Ethylene dichloride/EDC (H2ClC−CClH2)
EDC (H2ClC−CClH2) → vinyl chloride monomer (H2C=CHCl) + hydrogen chloride
(HCl).
In industrialized countries, ethylene is mainly produced today by cracking natural
gas, crude oil, ethane (H3C−CH3), or higher hydrocarbons. It is possible to convert
ethane—which is cheaper than ethylene and nearly always available from natural gas—
directly to vinyl chloride, e.g., by high-temperature chlorination using chlorine (H3C−CH3
+ 2 Cl2 → H2C=CHCl + 3 HCl), or by high-temperature oxychlorination using oxygen and
hydrogen chloride instead of chlorine (H3C−CH3 + O2 + HCl → H2C=CHCl + 2 H2O). The
production of VCM from ethane has not yet become established. “Developing an ethane-
Sustainability 2024, 16, 3854 3 of 24

based technology would be a breakthrough for VCM manufacturing in the future. How-
ever, despite its great potential, an ethane-based technology is still under exploration”
[16].
In the next step, the vinyl chloride monomers are polymerized to polyvinyl chloride
(PVC), see Figure 1. In sum, PVC consists of chlorine and hydrocarbons (57% resp. 43%
by weight).

Figure 1. Scheme: Polymerization of vinyl chloride monomers (VCM) to polyvinyl chloride (PVC).

Currently, PVC is one of the most important polymers worldwide in terms of volume
(see Table 1). Behind polyethylene (PE; here as the sum of HDPE and LDPE, LLDPE) and
polypropylene (PP), PVC is in third place with a global production volume of a good 51
million tonnes per year. Global PVC production is forecast to increase to almost 60 million
tonnes per year after 2030 [17].

Table 1. Global polymer production 1990–2019, in million tonnes per year.

Polymer 1990 2000 2010 2015 2016 2017 2018 2019

PE (sum) 30.0 54.6 81.9 98.2 100.1 103.2 106.5 109.8
HDPE 14.4 26.6 40.7 49.8 50.8 52.3 53.9 55.5
LDPE, LLDPE 15.7 27.9 41.2 48.4 49.3 50.9 52.6 54.3
PP 20.8 37.2 55.4 65.4 66.6 68.5 70.7 72.8
PVC 14.7 26.2 38.6 45.3 46.1 47.8 49.8 51.4
PS 6.4 11.2 16.3 18.9 19.2 19.8 20.5 21.1
PET 6.6 12.2 18.5 22.5 23.0 23.6 24.2 24.9
PUR 5.4 9.5 13.9 16.1 16.4 16.9 17.5 18.0
Total 129.9 234.0 348.9 412.8 420.0 432.2 446.2 459.7
Source: Global Plastics Outlook—plastics use by polymer [18].

As the data in Table 1 only relate to pure polymers, the volume of plastic products
made from PVC is likely to be higher than the data stated. The PVC polymer is mixed
(compounded) with additives for the respective area of application. As pure PVC is hard,
becomes brittle at low temperatures, and begins to decompose at temperatures above 160
°C, which impairs processability (extrusion or injection moulding), various additives are
added to the polymer to eliminate these weaknesses, such as plasticizers, stabilizers, and
other additives. The weight proportion of additives in the compound is between four and
just under 20% by weight for rigid PVC products (PVC-U, U = unplasticized), and up to
50% by weight for soft PVC products (PVC-P, P = plasticized) [19]. Table 2 gives a survey
on applications of PVC and the typical composition of PVC compounds.

Table 2. Applications of PVC and typical composition of PVC compounds (in weight-%) [20].

Application PVC polymer Plasticizer Stabilizer Filler Others

Rigid PVC applications (PVC-U)
Pipes 98 - 1–2 - -
Sustainability 2024, 16, 3854 4 of 24

Window profiles (lead stabilized) 85 - 3 4 8

Other profiles 90 - 3 6 1
Rigid films 95 - - - 5 (1)
Flexible PVC applications (PVC-P)
Cable insulation 42 23 2 33 -
Flooring (calendar) 42 15 2 41 -
Flooring (paste, upper layer) 65 32 1 - 2
Flooring (paste, inside material) 35 25 1 40 -
Synthetic leather 53 40 1 5 1
(1) incl. approx. 0.5% stabilizer.

The sales volume of uncompounded PVC in the EU amounted to 5.2 million tonnes
in 2021 (Eurostat, 2023b, cited in [19]), which (according to the European Chemicals
Agency ECHA) corresponds to around 6.8 million tonnes of PVC compounds. In addition,
0.5 million tonnes of unmixed PVC are imported into the EU each year, and 1.2 million
tonnes are exported to countries outside the EU (Eurostat 2023b, cited in [19]). Adjusted
for these import and export quantities, 4.5 million tonnes of unmixed PVC-polymers were
therefore used in Europe, corresponding to 5.9 million tonnes of PVC compounds. Almost
70% of this was used in the construction sector, mainly for pipes, floor coverings, cables,
and window/door frames [21]. A good 50 to 85% of this quantity is used in rigid, and 35
to just under 50% in flexible PVC applications (based on data in [19]).

2.2. Methods for Recording the Volumes of Recycled Material

As mentioned above, to become sustainable, the PVC industry promised recycling.
Figure 2 shows the calculation points used for the statistical records of material recycling.
For lightweight packaging, the calculation point (1) was used for many years in Europe.
This resulted in the known high recycling rates, but failed to record all recycling losses
along the processing chain. Commission Implementing Decision (EU) 2019/665 from
17 April 2019 [22] prescribed calculation point (2) for statistics from 2020 onwards.

Figure 2. Calculation points for recording recycling quantities in the recycling process when recov-
ering packaging waste (based on Conversio [23], modified).

However, in our opinion, calculation point (3) in Figure 3 would be more suitable
because it also takes into account the losses during the production of recyclates, and thus
statistically reflects the actual quantities of recyclates produced at the end of the chain.
But calculation point (3) will not display the quality of recycling (share of downcycling).
The central ecological reason for propagating material recycling is the replacement of vir-
gin material (in this case, virgin PVC). This would correspond to calculation point (4),
Sustainability 2024, 16, 3854 5 of 24

which we consider to display the share of closed loop recycling, what would have, in gen-
eral, better ecological results.

Figure 3. Calculation point for recording “real” quantities in the recycling process of PVC.

As part of the auditing of recycling data in Europe, the converter output has recently
also been recorded, which would come closer to calculation point (4), as this would ex-
clude unusable recyclates, for example [24,25]. However, calculation point (4) would also
subtract products that do not contribute to closing the PVC loop (Figure 3: Open Loop
box: PVC recyclates replace wood or concrete, for example). In the final state, the circular
economy means that there is no longer any need for new material (in this case, virgin PVC)
or that only the unavoidable loss of material is replaced by virgin PVC. On the way there,
the amount of virgin PVC used must gradually decrease each year. The volume of the
virgin market would have to become smaller and smaller. The extent to which this takes
place is methodically recorded via calculation point (4).

2.3. Definitions: Recycling

There are different definitions for the recycling of plastics, particularly with regard
to the distinction between chemical recycling and feedstock recycling/recovery [26,27]. In
this article, we use the following definitions:
• Physical recycling, which includes:
o Mechanical recycling: processing without dismantling the compound; the bond
of PVC polymer and additive is retained; and the output are flakes or granulate,
which are converted to new products.
o Solvent-based recycling (purification, dissolution): use of chemicals (e.g., or-
ganic solvents) to dissolve the compounded plastic, whereby the polymer chain
remains intact and can be reused for the fabrication of new products.
• Chemical recycling:
o Depolymerization: This includes, e.g., thermal depolymerisation, chemolysis,
and solvolysis. Here, the plastics are broken down into their building blocks—
oligomers (partial depolymerization) and monomers (full depolymerization).
o Thermolysis: Decomposition of the polymers by thermal processes (e.g., pyrol-
ysis, gasification); the resulting fragments (monomers, hydrocarbons, CO, etc.)
can be used as feedstock for the synthesis of other substances or as a raw mate-
rial in other processes. Following this logic, waste-to-energy (WtE) with carbon
capture and utilization (CCU) in the chemical industry) is also part of chemical
recycling.
Sustainability 2024, 16, 3854 6 of 24

• Energy recovery (thermal recycling): Use of the energy content of the plastic in incin-
eration plants (waste-to-energy), cement plants, or power plants fired with solid re-
covered fuels (SRF).
Within circular economy thinking, material recycling is often categorized based on
the product which is manufactured from the secondary raw materials [28]:
• “Closed loop is a recycling process whereby the recycled material is reused for the
same market application as that of its previous life cycle (system-wide concept).”
• “Open loop is a recycling process whereby the recycled material is used for a differ-
ent market application than that of the previous life cycle (system-wide concept)”
[29].
Open loop recycling is often equated with downcycling. There is also no legal or of-
ficial definition of “downcycling”. Experts define downcycling as “a recycling process
whereby the recycled material is used for a lower-quality market application than that of
the previous life cycle, normally defined by a lower market value, as opposite to upcycling
(system-wide concept), defined for plastics as: “the use of plastic waste, post-industrial or
postconsumer, as a feedstock for the synthesis of value-added products, being polymers,
molecules, or materials’” ([30], cited by [29]). Other experts propose, based on a stake-
holder process [31], that: “Downcycling is the phenomenon of quality reduction of mate-
rials reprocessed from waste relative to their original quality, where waste means any
substance or object which the holder discards or intends or is required to discard.
Downcycled materials count as recycled materials.….”
Open loop recycling does not necessarily mean downcycling. “In fact, there might be
cases where open-loop recycling produce recyclates of adequate quality for another ap-
plication, rather than unnecessarily pushing closed-loop recycling processes to increase
the technical properties of recyclates to meet the standards of their virgin counterpart.
Open-loop recycling can still contribute to meet demand of the virgin resource while in-
curring environmental benefits as long as there is an unsaturated market application for
that secondary material which is ready to absorb it (…). However, one should also bear in
mind that these substitutions would not occur when such outlet markets suddenly be-
come saturated (e.g., because of closed-loop recycling initiatives taking place within that
sector or bans in export)” [29].
If recycled PVC (rPVC) replaces virgin plastic 1:1, this is undoubtedly recycling.
However, the technically possible recyclate admixture is limited: pipes 25%, cable sheath-
ing 30%, floor coverings 30%, window profiles 60%, and other profiles 25% (AgPU, cited
in [32]). In most cases, a formerly high-quality primary product becomes an intermediate
layer, sub-layer, or a low-grade product. “Even if downcycling is not entirely avoidable,
we can still foster high-quality recycling and implement a cascade of slowly and gradually
downcycled materials” [31]. But downcycling entails the risk that it will only have minor
environmental benefits. Mixing without any relevant contribution to the product proper-
ties is not recycling, it is dumping in products.
The circular economy means that we need to organize more than just a material cycle.
It is true that this issue is very forward-looking in the construction sector. However, it
must be stated that the compounds of virgin PVC and recyclates will move further down
the cascade of downcycling in the next future cycle.

2.4. Target: Sustainability through Recycling

2.4.1. Germany (1988)
Behind the sustainability promise of the AgPU (Working Group on PVC and Envi-
ronment) in 1988 was the plan to recycle PVC waste as far as possible to substitute virgin
PVC and thus eliminate the waste problem [13]. The plan was based on an industry con-
cept, which ideally meant, for example, that a new window frame would be made from a
used PVC window frame. Virgin PVC would not be essential any more. Old PVC goods
(post-consumer) therefore had to be collected and recycled in a sector-specific manner.
Sustainability 2024, 16, 3854 7 of 24

AgPR (Arbeitsgemeinschaft PVC-Bodenbelag Recycling, https://agpr.de/en/, accessed on

31 March 2024) was founded for the recycling of floor coverings, AfDR (Arbeitsgemein-
schaft für PVC-Dachbahnen-Recycling [33]) for roofing membranes, the Wavin subsidiary
Replast for pipes [34], and the companies Fenster Recycling Initiative (FREI, now: RE-
WINDO www.rewindo.de, accessed on 31 March 2024) and VEKA-Umwelttechnik
(https://www.veka.com/divisions-brands/veka-recycling, accessed on 31 March 2024) for
window and other profiles. As a rule, the leading producers and processors were involved
in these projects as shareholders [35].
This approach naturally meant that the respective product manufacturers could be
held more accountable. However, it also meant that chemically similar waste (e.g., win-
dow profiles) was collected separately, which ultimately promised higher-quality recy-
cling. In 1997, the situation was as follows [36]:
• The manufacturers of PVC flooring had built a recycling plant for around 2.6 million
Deutsche Mark (DM) (about 1.3 million EUR), but only 10% of the plant was utilised
with post-consumer PVC flooring waste. The recycled material was used as a back
coating.
• The manufacturers of roofing sheets had built a recycling plant for a good 2 million
DM (about 1 million EUR). The plant was 20% utilised with PVC roofing membranes.
The recycled material was used as a centre layer in new products [37–39].
• Only just under 5% post-consumer PVC was used in the pipe recycling plant (mainly
PE was recycled). Low-quality products such as support pipes or winding cores for
carpeting were produced.
• The window manufacturers had set up two recycling plants. One was built in Beh-
ringen for just under 18 million DM (about 9.2 million EUR). The plant was well uti-
lised, but mainly processed pre-consumer offcuts. Only just under 5% of post-con-
sumer PVC was recycled at the time. The second plant in Rahden processed off-cuts
and post-consumer PVC separately and had a slightly better capacity utilization of
30%.
For the question of whether this has been recycling or downcycling in individual
cases, see Section 2.3. Overall, the balance at that time was rather poor [40,41]. So, the
question arises: How has the recycling of PVC compounds developed since then?

2.4.2. Europe (since 2000)

In 2018, ‘Vinyl’ has committed to recycle 900,000 tonnes of PVC by 2025 and 1 million
tonnes by 2030 as part of the European Commission’s Circular Plastics Alliance (CPA) [42].
The Alliance endorses the ambitious target that by 2025 at least 10 million tonnes of recy-
cled plastics should find their way into products and packaging in Europe each year (here-
after referred to as “the 10 million tonnes target”), helping to deliver the circular economy
with a life cycle approach. ‘Vinyl’ points out: “Over the last two decades, reporting annu-
ally and overseen by an independent Monitoring Committee, Vinyl 2010 and VinylPlus
succeeded in meeting their targets” [15]. Figure 4 shows the current recycling balance—a
considerable increase.
‘Vinyl’ states that 813,266 tonnes of PVC waste have been recycled in 2022 (“PVC
recycled within the VinylPlus framework”). “Taking into account also PVC waste streams
that do not have formally established collection schemes (…) and rPVC volumes not yet
traced and certified through the Recovinyl® system, Conversio data estimates that 35% of
PVC waste is currently being recycled in Europe [43]”.
Sustainability 2024, 16, 3854 8 of 24

Figure 4. Material recycling of PVC (“recycled within the VinylPlus framework”) 2002 to 2022 (based
on data published by VinylPlus [44]).

3. Results: 35% Recycling Rate in Europe—An Analysis

Although a material recycling rate of 35% is not quite at the target of a closed loop, it
would still be progress, and it is for the entire European Union. But is this figure reliable?

3.1. Reference Value

The layers in Figure 4 contain both pre- and post-consumer recyclates. However, if
the recycling volumes from post-consumer material (305,594 tonnes ([43], p. 44)) are re-
lated to the total volume of post-consumer PVC waste (around 2.5 million tonnes of PVC
waste), the recycling rate for 2022 is 12% (also according to the ECHA ([21], p. 60)). ‘Vinyl’
states [45]: “PVC post-consumer recycling rate was not 12% but 24% according to Conver-
sio 2021. This is a factual error from the ECHA report. See … [46]. The amount quoted by
ECHA corresponds to the amounts that have been certified in the Recovinyl system, i.e
290 kT, which does not catch all post-consumer recycling. However, a Conversio study
from 2020 estimates that 599 kT of post-consumer waste is recycled”.
The Conversio study of 2021 has not been published so far. Therefore, in this article,
we will stick to use the certified recycling data of ‘Vinyl’, respectively, ‘Recovinyl’, also
because these data were not extrapolated.
Looking back, it can be seen that a good 260,000 tonnes of post-consumer waste were
already recycled in 2010 [47,48]. In 2021, the figure was a good 290,000 tonnes [49]. The
increase in Figure 4 was therefore primarily achieved by increasing the collection of pre-
consumer recycling volumes. For post-consumer waste, there was only a slight increase
(from 260,000 to 305,000 tonnes, i.e., by 45,000 tonnes, which corresponds to around 17%)
in this period. ‘Vinyl’ points out: “If one considers post-consumer recycling only the in-
crease is actually quite dramatic from 2000 until 2020: from 100 kT to 599 kT, this is a 9,3%
Sustainability 2024, 16, 3854 9 of 24

growth rate, much more than ‘virgin resin’ [45]”. However, this statement shows two
problems: 1. With a low initial value, even a small upward changes lead to high percentage
increases. 2. These new Vinyl figures for post-consumer waste recycling cannot be recon-
ciled with the previous figures for Vinyl that we have reproduced in Figure 4. These new
figures are significantly higher than what Figure 4 contains. The data in Figure 4 is certi-
fied according to Vinyl. The new figures are based on extrapolations of data from surveys
of recycling companies and extrapolations made using the expertise of plastics associa-
tions. They have not been certified, and are therefore not reliable in our view. We will
therefore not base our analysis on these new figures, but we will not conceal them either.
‘Vinyl’ confirms that the increase of post-consumer recycling in the second decade of
the Voluntary Commitment has slowed down. “Several factors explain this:
(1) The new VinylPlus 2030 commitment focused on all waste streams including pre-
consumer as it was acknowledged that the full recycling potential had not yet been
achieved there in part because of the strong focus of previous VinylPlus commit-
ments on post-consumer waste.
(2) New restrictions have been put in place decreasing the number of potential outlets
for recyclates and limiting the ability to recycle certain products (e.g., decrease in
recycling in sheets following the restriction of DEHP (Di(2-ethylhexyl) phthalate),
lead in PVC restriction). This is probably a trend that will be reinforced short term
until new projects enable to unblock recycling potential (e.g., sorting of legacy addi-
tives, chemical recycling, dissolution technologies…).
The assessment of how to tackle those challenges is part of the foreseen VinylPlus
2030 commitment mid-term target review (in 2025)” [45].
Recycling of pre-consumer waste is laudable and has always been practised, where
economically advantageous. However, contributions from post-consumer recycling are
more crucial for closing material cycles. This is another reason why the current voluntary
commitment of the plastics industry within the Circular Plastics Alliance (CPA) (see Sec-
tion 2.4.2) [50] only includes material from post-consumer recycling [25]. However, the
PVC industry and ‘Vinyl’ have been able to obtain special treatment from the Commis-
sion; they are allowed to include the quantities from pre-consumer recycling in their vol-
untary commitment [25]. The argument in favour of this special treatment is that, for PVC,
better recyclate qualities can be achieved with the mixture of pre- and post-consumer
waste [51].
Figure 5 based on data from ‘Vinyl‘ [43] shows the volumes of PVC compounds re-
cycled in the EU in 2022 (813,266 tonnes in total), broken down by product and origin and
separated for pre- and post-consumer waste. It is clear that post-consumer recycling re-
sults are mainly achieved through the recycling of window frames (56%). This has already
been the flagship in 1997 [36,40].
For recycling of PVC cables, ECHA sees a need for clarification [19]: “This rate seems
to contradict the information received from plastic recyclers which suggests that PVC in
electrical and electronic equipment mostly ends up in the heavy fraction of the shredder
light fraction which is subsequently incinerated”. Following ‘Vinyl’ [45], PVC cable recy-
cling is well established and “verified as part of the Recovinyl network. Cable recyclers
are mostly not members of Plastics Recyclers Europe”. We are not convinced by this ex-
planation. For this, we also see the need for clarification.
Sustainability 2024, 16, 3854 10 of 24

Figure 5. PVC compounds recycled in the EU in 2022 (813,266 tonnes) (based on data according to
VinylPlus [43]).

3.2. Recycling or Downcycling

Let us analyse the bars in Figure 5 in more detail. What method respective to the
calculation point is used for the statistic of post-consumer recycling? Is there, following
calculation point 4 in Figure 3, a replacement of virgin PVC?
For plastics such as PVC, this poses a particular difficulty in the assessment, because
recycling of post-consumer waste—as experience from the 1990s has already shown—
was, in our opinion, generally downcycling, even if collected separately (see Section 2.3).
Overall, we have not been able to find reliable data on the extent recyclates are produced
out of post-consumer PVC (calculation point 3) or to which extent PVC recyclates replace
virgin PVC (calculation point 4). In our opinion, this is where the greatest need for action
lies in order to achieve greater data transparency.
In terms of the life cycle assessment (LCA), material recycling in general is only su-
perior to waste-to-energy options if credits for the substitution of virgin plastic can be
taken into account. If recyclates replace lower-quality materials (downcycling, see Section
2.3), then the eco-balance credits are rather low. This must be checked in each individual
case. The question is at what stage of the “downcycling cascade” these new products are.
For recycling, ‘Vinyl’ gave the following definition: “Recycled PVC is a discarded PVC
product, or semi-finished product, that is diverted from waste for use within a new prod-
uct; processing waste is included provided it cannot be reused in the same process that
generated the waste” [52]. The term “use within a new product” is of importance, as it is
not identical with substitution of “virgin” PVC (→ open instead of closed loop). ‘Vinyl’
states that “one of the main issues of recycled product is their colour (the mix will often
be greyish), not making it suitable for certain application. The solution is to find new ap-
plications where colour is not fundamental, or to use the recyclate in inner layers (co-
extrusion)” [45].
For 2022, ‘Vinyl’ gives the following data: 562,000 tonnes recyclate uptake at plastic
converters (corresponds to calculation point 3 in Figure 3) was registered in the Recovinyl
system. However, it should be noted with regard to this figure that the survey both relied
on recyclers output and the new registration system for recyclate uptake at plastics
converters. ‘Vinyl’ points out that “the picture is still incomplete as this is a new
registration system, and many convertors have not yet joined (the number of converters
is bigger than the number of recyclers)”.
Sustainability 2024, 16, 3854 11 of 24

The end-application of converting output as products was almost 468,000 tonnes

(=83%) [45]. The difference of about 94,000 tonnes (17%) went elsewhere, presumably to
energy recovery. The end-applications were:
• Windows and profiles: ...................................39%
• Floor coverings: ...............................................25%
• Traffic management: .......................................18%
• Pipes: .................................................................10%
• Building & construction—other: ....................6%
• Horticultural and stable equipment: .............1%
• Coils and mandrels: ..........................................0.18%
• Packaging: ..........................................................0.16%
‘Vinyl’ points out, that “traffic management covers a range of products and should
not be understood as downcycling. There are indeed some bases for holding fences in
replacement of concrete, but this is a minority. Typical applications would be traffic cones,
cable bridges, and structures for drainage” [45]. We follow this argument partly.
Figure 5 and the data provided by ‘Vinyl’ show that window profiles (and doors, etc.)
are by far the most important contributors to post-consumer recycling. Historically, this
certainly also has to do with the fact that this waste is very easy to recognize and to grab
from construction waste. Today, post-consumer material may only be used for the internal
profiles due to the contamination with meanwhile banned hazardous substances and reg-
ulatory requirements. The contact surfaces on the outside must be made from virgin PVC
as part of a co-extrusion process. E.g., at REHAU, in the last decade, about 15% of the
tonnage required for the inner core of PVC windows consisted of recyclate [53]. In 2020,
new window products from REHAU already had a recycling share of 54%. By 2025, this
proportion is set to increase to 65% [54].
The situation will become even more complicated in the future. Glass fibre reinforced
window profiles (GRP) have been increasingly available for a good five years. This pro-
vides greater rigidity so that triple glazing can also be manufactured from plastic. Thermal
insulation is also improved because the thermally conductive steel core of the frame can
be dispensed with. However, there are very different GRP techniques on the market (con-
nective sleeves with glass fibres, pultruded profiles, plastics with glass fibres in the matrix,
etc.). There are also market participants that use other GRP-reinforced plastics, such as
polybutylene terephthalate, which would further complicate the situation if market
growth were to occur here.
These windows are expected to be increasingly found in waste from 2030 and be-
yond. It will then be necessary to separate the GRP-PVC material from the shredded and
ground other PVC [53]. According to a market participant, this requires the GRP-PVC in
the window frame to be provided with a fluorescent marker so that this PVC can be de-
tected afterwards. For this, the technical infrastructure has to be established throughout
Europe. Another market participant is sceptical here and considers PVC windows with
GRP components to be only theoretically, but not practically recyclable [55]. For his own
recycling practice, GRP windows are regarded as “impurities”. As long as there is no con-
sensus in the industry on the GFR complex, future material recycling (replacement of vir-
gin PVC) is unclear.
The example of the dominance of window recycling also indirectly shows the diffi-
culties of further expanding post-consumer PVC recycling. While windows, as the pro-
verbial low-hanging fruit, are easy to separate from bulky and construction waste, this is
much more difficult for the smaller types of waste. In addition, window recycling is again
dominated by German companies. The market here is very centralized, which has made
it easier for the players to reach an understanding. It is questionable whether this can be
achieved for the other areas of PVC use in the construction sector, which tend to be dom-
inated by SMEs, and whether companies can be won over on a voluntary basis for the
recycling of materials whose formulation is unknown and where the former
Sustainability 2024, 16, 3854 12 of 24

manufacturers may no longer even exist. This is also because the strategy to “hide” the
recyclate inside the window frames (or pipes) is more difficult for other applications. We
therefore expect post-consumer recycling in the EU to stagnate, perhaps even decline, over
the next few years.

3.3. Recycling Rates in Germany

As shown above, PVC recycling has been practised in Germany for some time. There-
fore, higher recycling rates should be expected here than for Europe as a whole. In fact,
more detailed analyses show that the high recycling rates acclaimed by ‘Vinyl’ are
achieved in Germany in particular. The most recent publicly available data for Germany
is from 2021 and was collected by Conversio. The full report has not been published, and
only an abridged version is publicly available [23]. Conversio shows figures for post-con-
sumer recycling (previous calculation point (1): input into the recycling process), accord-
ing to which, the recycling rate for material recycling of PVC from post-consumer origin
in Germany in 2021 was 29% (189,000 of 658,000 tonnes). In relation to all PVC waste in
total (the sum of post-consumer and pre-consumer waste) and calculation point (1), the
share of PVC waste going to energy recovery in 2021 was around 57%; 42% of PVC waste
was directed to material recycling (including a very small proportion chemically recy-
cled). Around 7000 tons of PVC waste (1%) was disposed of in landfills.
With its 658,000 tonnes, Germany accounted for the lion’s share (81%) of the total of
PVC compounds recycled within the VinylPlus framework in 2021 (about 810,000 tonnes).
Regarding solely post-consumer PVC waste, Germany’s share was 64% (189,000 of 295,273
tonnes).
In relation to calculation point (2), the breakdown shifts to 62% energy recovery and
38% material recovery. A good two thirds (27,000 tonnes) of the losses from the recycling
process (Figure 3, pink box), totalling 40,000 tonnes, were used as substitute fuel (cement
plants, power plants, etc.), and one third was used for energy recovery in waste incinera-
tion plants. These 40,000 tonnes correspond to just under 5% of the total PVC waste mass
collected in 2021 (861,000 tonnes). The material recycling of post-consumer PVC according
to calculation point (2) in Germany is then 23% (see Section 3.1: Conversio data are not
certified).
We have not been able to obtain data on recycling calculated according to calculation
point 3 or 4. It can therefore only be assumed that these data will be below 23%.
The PVC industry and ‘Vinyl’ certainly do not share our low statistics (23% for Ger-
many vs. 24% (Conversio) to date in Europe, see Section 3.1) and our pessimistic assess-
ment of future PVC material recycling. For this reason, we suggest that industry’s current
voluntary commitment to the EU Commission could be conceptually developed further
after 2025 to provide for a gradual replacement of virgin PVC with recyclates over several
years. The cycle should then be closed by 2040 at the latest, except for the unavoidable loss
of material. If one were to follow the general climate protection targets, a target for the
closed loop would be 2040. We consider it highly questionable whether such a target can
be realized for PVC, a plastic that is difficult to recycle. But it would be interesting to dis-
cuss this issue with the industry.

3.4. VINYLOOP®—A Review

Recycling of PVC by using solvents—VINYLOOP®—is often attributed to chemical
recycling, but is a solvent-based (= physical) recycling process (see Section 2.3). It was first
tested on a semi-industrial scale in a plant in northern Italy in 2002 [56]. In this process,
old post-consumer PVC products, such as cable sheathing, were dissolved in a solvent,
and the PVC contained was then precipitated out again. The advantage of the process was
that PVC composites with other materials could also be processed. However, the mean-
while banned phthalate plasticisers contained, such as DEHP, proved to be an unsolvable
problem. According to REACH, these plasticisers could no longer be placed on the market
in the EU as of 21 February 2015. The Commission had granted a derogation with a limit
Sustainability 2024, 16, 3854 13 of 24

value of 20% DEHP in the recyclate. However, due to the high concentration of phthalates
in the soft PVC compounds, it was not possible to produce a recyclate that complied with
this limit [57]. This is the main reason why the plant in question was closed in 2018 [58].
‘Vinyl’, on the other hand, emphasizes that “the closure of Vinyloop was not due to the
fact that the DEHP limit was not met. Actually, DEHP levels were considerably reduced,
and a review report by ECHA allowed the process to continue with a reduced limit of 5%
[59]. The decision to stop activities was related to financial reasons and a smaller customer
base. It remains that the removal of those additives should be considered in the develop-
ment of new solvolysis processes” [45].

3.5. Chemical Recycling—A Review

3.5.1. Recycling Options
The PVC industry’s narrative has always included “feedstock recycling” or chemical
recycling, which would open up completely new horizons. ‘Vinyl’ points out [45] that “in
the case of PVC, both parts of the PVC molecule can be chemically recycled: the hydrocar-
bon part (43%) can be recycled by processes suitable for hydrocarbon polymers, such as
pyrolysis or gasification [60], while the chlorine part (57%) can be recycled and used in
the production of rPVC as well as other raw materials and substances” (Vinyl cites
Z. Hruska, Public Affairs Director at VinylPlus®): Chemical Recycling of Specific Plastics
Waste Streams—Case PVC, in Conference Proceedings of the 10th International Sympo-
sium on Feedstock Recycling of Polymeric Materials, Budapest, 2019).
It is undoubtable that these recycling options exist. But theory is one thing, practice
is another. The question is what really works in practice on an industrial scale and can
therefore make a significant contribution to PVC recycling.

3.5.2. Hydrocarbon Recycling

‘Vinyl’ points out [44]: “There are different chemical recycling technologies suitable
for plastics waste containing hydrocarbon polymers, such as pyrolysis, gasification, hy-
dro-cracking and depolymerization. If the plastics waste streams contain heteroatoms
such as, e.g., halogens, then these must be removed either before (via pre-treatment) or
directly during chemical recycling process. … Some pyrolysis processes can tolerate high
concentration of chlorine in the feedstock. For example, ARCUS Greencycling Technolo-
gies GmbH provides a chemical recycling solution for otherwise non-recyclable mixed
plastic waste [61] streams that have undergone minimal pre-sorting or pre-cleaning. Their
process is claimed to successfully handle a wide range of polymers, from PP, PE and PS
to difficult-to-process PVC, ABS or PET”.
Thermal processes (pyrolysis or gasification) could theoretically overcome the prob-
lem of legacy additives, because the hazardous additives are either broken down (organic
substances) or eliminated for example via ashes (heavy metals). Small amounts of PVC
within a plastic mixture will only result in operational challenges in thermal processes.
For pure PVC or waste with high share of PVC, special technologies are needed. One of
the most promising is de-hydrochlorination, which has the concept of “evaporating” the
chlorine in the form of HCl from the polymer matrix. There exist different options when
increasing the temperature above 300 °C.
The history of PVC recycling by ‘Vinyl’ is linked to many pilot projects for chemical
recycling, all of which were put on display at their time: the Rotary kiln project with off-
gas scrubbing (DOW and later SUEZ in Schkopau (GE)), pyrolysis (NKT-Watech (DK)),
de-hydrochlorination (REDOP (NL)), the Stigsnaes process (DK), the Alzchem project
(GE), which eliminates chlorine with a heated extruder before entering the process, or the
KU Leuven project (BE) with the de-hydrochlorination in a ionic liquid media [52,62–66].
None of these projects was scaled up to an industrial plant. To date, not a single plant
exists that can chemically recycle relevant quantities of PVC waste. The pyrolysis plant of
ARCUS mentioned above (having started operation in 2022) is a commercial-scale pilot
Sustainability 2024, 16, 3854 14 of 24

plant with a capacity of 4000 t/a (output: 2500 t/a), no large-scale industrial plant [67]. We
will see what experiences ARCUS will gain concerning PVC.

3.5.3. Chlorine Recycling

The field of HCl recovery from waste incineration has been similarly unsuccessful to
date. It was already clear to the experts in the 1990s: hydrochloric acid recovery from
waste incineration plants is—from an economic point of view—the best way to recycle the
chlorine content of PVC, as hydrogen chloride from flue gas scrubbing does not have to
be neutralized, but can be returned to the economic cycle as hydrochloric acid (HCl) [7].
Similar to chemical recycling, a lot has been tried out here and put on display (MVR
Rugenberger Damm, Halosep, The SOLVAir® Solution, etc.), but to date, nearly nothing is
running in Europe in the operation of a waste incineration plant (for Switzerland, see be-
low).
New ideas from ‘Vinyl’ take up the chlorine cycle again [68]: “In the VinylPlus® Reco-
Chlor chemical recycling programme, the selected PVC wastes are thermally decomposed
in modern waste-to-energy plants, which enables to recover chlorine either in the form of
sodium chloride (RecoSalt, dry process) or as diluted hydrochloric acid (RecoAcid, wet
process). … Both RecoSalt and RecoAcid processes lead at the end to the production of
new chemicals and/or metals which can be sold on the market”. The polymeric (hydro-
carbon) part, on the other hand, is used for energy recovery.
In Switzerland, metal recovery from filter ash produced during the treatment of mu-
nicipal waste is obligatory from 1 January 2026 [69]. In 2018, already “more than 60% of
fly ashes in Switzerland were treated according to the FLUWA process, which represents
a state-of-the-art technology” [70]. In ‘Vinyl’s RecoAcid project at the waste incineration
plant in Thun, HCl is separated from the flue gas and used to treat the flue gas dust (acid
fly ash washing). This allows for heavy metals to be extracted from the fly ash as chlorides
and recycled. The trial (that has meanwhile ended) has confirmed that wet flue gas scrub-
bing in municipal solid waste incineration (MSWI) plants “is a valid option for the recy-
cling of PVC wastes which cannot be mechanically recycled” [43]. But this recommenda-
tion only applies to plants with wet flue gas cleaning (FGC). In Europe, however, many
MSWI plants are equipped with a dry FGC system. A report for 2011 on 455 waste-to-
energy (WtE) plants in 18 European countries (Austria, Belgium, Czech Republic, Den-
mark, Finland, France, Germany, Hungary, Ireland, Italy, Netherlands, Norway, Portugal,
Slovakia, Spain, Sweden, Switzerland, and the United Kingdom) showed that dry FGC
processes dominated in the three countries with the highest number of waste incineration
plants (France, Germany, and Italy, see Table 3) [71].

Table 3. WtE systems with dry or semi-dry flue gas cleaning (FCG) (at least one combustion line),
2011, based on ISWA [71].

Plants with Wet FGC Share of plants

Total WtE Semi-dry Dry + SD Sum
Country data Dry FGC + dry or with data
plants FCG FCG Dry+ SD
available + SD available
France 127 124 47 24 2 2 75 60%
Germany 55 47 6 19 0 6 31 66%
Italy 51 49 22 10 1 3 36 73%

For these plants, an extensive conversion of the flue gas cleaning system would be
required. In Switzerland, the Netherlands, Austria, and Sweden, wet or so-called hybrid
processes—the combination of a wet and conditioned dry process—dominated. In these
countries, however, there was no requirement for wastewater-free plant operation, mean-
ing that the wastewater can be discharged into the receiving water after wastewater treat-
ment. This plant operation naturally has certain economic advantages in terms of residual
waste disposal costs [72].
Sustainability 2024, 16, 3854 15 of 24

Apart from that, there is another problem: “The municipal waste-to-energy plants do
not generate enough raw acid by treatment of household wastes, and the supply gap can
be covered either by technical grade hydrochloric acid bought on the market or by in situ
generated hydrochloric acid from mechanically non-recyclable PVC wastes” [46]. But a
significant increase in PVC throughput volumes poses problems for many of the plants
currently in operation, like, e.g., chlorine corrosion on the evaporator heating surfaces by
hydrogen chloride. “The operator of plant must ensure that the HCI is separated during
waste gas purification to such an extent that the limit values specified in the plant licence
are complied with. On the one hand, he must not exceed the maximum HCI concentration
in the raw gas before it enters the waste gas purification system, which is the basis for the
design of the waste gas purification system, in order not to “overrun” the system. On the
other hand, he naturally endeavours to minimise the use of neutralising agents for cost
reasons. For this reason alone, he keeps the HCI raw gas concentration within the specified
limits by carefully mixing the waste in the bunker” [73]. As early as the 1990s, it was crit-
icised that an increasing proportion of PVC in the MSWI input would result in a higher
demand for neutralisation agents [9]. For this reason, PVC is also especially regulated in
the acceptance conditions of some waste incineration plants (e.g., exclusion from ac-
ceptance or delivery of PVC waste only after prior agreement [74–76]).
A regulation requiring the conversion of the flue gas cleaning of all waste incineration
plants in a state to such technologies is politically feasible, as the example of Switzerland
shows. But it would be politically and economically challenging for Europe (2020: 504
[77]), as many incineration plants are equipped with dry or semi-dry flue gas cleaning
[71]. Notwithstanding, metal recovery from MSWI filter ash is a good idea, also because
some of these metals contained in the filter ash are strategically important for the EU (cop-
per, nickel) or even critical (antimony) [78]. In PVC, antimony is used in form of antimony
trioxide (ATO, antimony(III) oxide, Sb2O3) as a flame-retardant [79]. Antimony, further-
more, is not recovered during the FLUWA process, but remains in the fly ash. The imple-
mentation of a sequential extraction with different acids (HCl followed by phosphoric acid
followed by citric acid) showed high potential for the future to achieve high antimony
recovery rates [80], but this is currently not feasible in incineration practice.

4. Discussion: No Sustainability—Attempts of an Explanation

4.1. Starting point
More than 30 years have passed since the introduction of the “Plastics Cycle”, “PVC
cycle guarantee”, and “Global Recycling” concepts. However, the post-consumer material
recycling rate, as documented above, is meagre. And specific information on the extent of
the closed loop respective to the replacement of virgin PVC is not available.
The balance of chemical PVC recycling is currently even worse than that of material
recycling. In 2021, around 400 tons of PVC waste (400 t/658,000 t following Conversio ([23],
p. 60–63)) were sent to chemical recycling (presumably use of the mixed plastics in the
blast furnace process) in Germany, which is 0.06 percent. In Europe, the figures are likely
to be even lower. This result is difficult to understand, as chemical recycling promises
good results, at least in chemical theory (virgin plastic) [60,81]. The ecological analysis
also shows that—depending on the boundary conditions—chemical recycling of PVC can
be advantageous [82,83].
Can this result for Germany (or Europe) be explained by a lack of money or a lack of
state support? It was certainly also due to money. However, the call for the state leads to
a dilemma: the chemical industry—like all other sectors—actually wants less, not more
governmental involvement. And the recycling promise for PVC was positioned from the
outset as a voluntary activity by industry. So, what could the reasons be for so little pro-
gress?

4.2. First Reason: The Quantity and Variety of Additives

Sustainability 2024, 16, 3854 16 of 24

PVC is chemically very complex. PVC itself has, as described above, properties that
do not make it a favourable polymer, with the key weakness being chlorine. From 100 °C
to 120 °C, the polymer begins to decompose and hydrogen chloride (HCl) is released (de-
hydrochlorination [84]). This decomposition, in turn, leads to chain reactions. As temper-
atures in the range of 160 to 200 °C are required for, e.g., extruding, this polymer could
not be processed at all without considerable damage. The polymer would therefore
simply be unusable as a plastic, especially for a second or third processing at elevated
temperatures in the context of recycling. This is where additives (stabilizers) come into
play [84]. These are added to the polymer before the first “melting” (in the sense of “mak-
ing malleable”). Although they cannot completely prevent HCl decomposition, the addi-
tives do stop the chain reaction.
Solar radiation (heating, UV) also leads to the described de-hydrochlorination and
chain reaction [84]. This also causes the polymer to age quickly, and should be considered
unsuitable for most applications. Stabilisers—mostly metal soaps, metal salts (cal-
cium/zinc), or organometallic compounds (organotin)—are usually combined with or-
ganic co-stabilisers (polyols or epoxidized esters) [84]. The stabilisers are used up in full
or in part during the lifetime of a product (through the protective reaction). Strictly speak-
ing, therefore, the stabilisation status would have to be determined by chemical analysis
before re-processing. This is an enormous amount of work that cannot be carried out in
practice by small- and medium-sized companies. You can expect larger companies to be
able to make this effort.
Another disadvantage of the PVC polymer poses the intra-molecular forces caused
by the chlorine (dipole forces and size of the chlorine atom). The polymer is brittle and
stiff, and is therefore unusable. It has to be made flexible. Other additives (plasticisers) are
used for this purpose. Over 85% of the plasticisers used in plastics in Europe end up in
PVC [21]. The weaknesses of the polymer therefore mean that PVC is one of the plastics
with the highest and most complex additive content, which would make high-quality re-
cycling of mixed post-consumer waste impossible. There are 470 different PVC additives
in use today [21]. Therefore, even if the waste is collected by product type, the diversity is
still so high that often only downcycling or more often disposal (today mostly incinera-
tion) are the only options.
It can also be assumed that the plastic is damaged during the second or further melt-
ing during the recycling process (high temperature, shear forces, presence of oxygen, car-
bonyl, and peroxide compounds). Processing therefore leads to changes in the polymer
molecule, which in turn causes an increase in the mobility of the additive molecules ([85],
cited by [86]). We therefore do not believe in the narrative of infinite cycles (circular econ-
omy), especially for PVC. ‘Vinyl’, in contrast, refers to experiments that have shown that
PVC can withstand 10 thermal cycles without addition of further stabilisers or process
aids. In [87], the experiments were performed with two PVC-U (rigid-PVC) suspension
resins, the one containing a tin stabilizer (2%), the other containing a lead stabilizer (8%),
plus further additives (e.g., pigmentation). Both additives are meanwhile banned (see Sec-
tion 4.3). “The study has confirmed that the physical properties of recycled PVC-U are
very similar to virgin material even after several passes”. It should be noted that this was
a material that was not subject to any further changes in the course of the investigation
and was not mixed with other PVC materials that were additivated differently. The au-
thors themselves limit the significance of their test results with regard to the first point:
“The process did not allow normal ageing between the cycles which according to some
researchers may be expected to somewhat reduce the thermal stability of the material (…).
… Clearly such modifications could be utilised in practice whereby the recycled material
may not necessarily be 100% recycled but blended with virgin material”. The other study
[88] cited by ‘Vinyl’, using one dry blend (pipe formulation) stabilized with Ca/Zn (2.8%),
confirmed the findings of the first [87].
It therefore remains an open question, whether we can reach in reality one cycle, two
cycles, or more with PVC. But this is not “circular economy”.
Sustainability 2024, 16, 3854 17 of 24

4.3. Second Reason: Legacy Chemicals (Legacy Additives)

There is another chemical reason, which is related to the first reason and which makes
it even more difficult for the processing industry (converters) to achieve a good quality of
the recyclates. Particularly for toxicological reasons, many of the additives previously
used as stabilisers and plasticisers in PVC products have since been banned. Due to the
long product lifetimes of some PVC articles, they are still in circulation [89]. PVC recycling
today leads to products that still contain these banned additives through the recyclates in
them [53,90]. The long list of banned PVC additives [91] includes phthalates, short-chain
chlorinated paraffins, hexabromocyclododecane (HBCDD), organotin compounds, arse-
nic, lead, cadmium, nickel, and chromium.
The group of phthalates alone comprises around a dozen individual substances, and
the above list of regulated additives is not final [92]. And the discussion about further bans
is not over, on the contrary [21]. For some additives that are banned, there are increased
limit values for substance concentrations in recyclates (e.g., DEHP, Cd, Pb) or other re-
quirements to not hamper too much the efforts towards recycling targets. Therefore, it is
very difficult for recyclers and converters to maintain an overview, let alone determine
what banned pollutants (and candidate substances [93]) are contained in the PVC waste
they receive. Also, a glance at the EU database SCIP (Substances of Concern In Products),
which was put in place to better inform actors at the end-of-life treatment stage about
harmful chemicals in waste, cannot solve this problem [94]. A solution for ending this
vicious circle needs to be found.
‘Vinyl’ states: “However, it is true that the growth rate of recycling has slowed down
in the last decade …. In some cases, uncertainty regarding upcoming restrictions of legacy
additives, and whether recycling would still be possible (with appropriate limit values)
has led to postponed investment. This is the case for the restriction on lead in PVC, which
was adopted last year and now foresees a 10-year derogation for recycling lead-containing
PVC that meets specific conditions [95]. Future restrictions, such as on MCCPs [96], also
have an impact. VinylPlus will consider those impacts in view of the Voluntary Commit-
ment target review in 2025”. However, this argument for the decline in recycling must
also include the argument that the ban on an additive was preceded by the decision to
have used this additive at all without sufficient safety tests.

4.4. Third Reason: Economic Interests?

Apparently small and medium-sized plastics processors (converters) have no eco-
nomic problem with an increasing use of recyclates, if (simplified) the recyclates are of
sufficient quality and at good prices. One step before in the supply chain, the situation is
different for PVC manufacturers (especially for polymer producers). Even a temporary
drop in demand triggers concern [97]: “The European—and in particular the German—
PVC market is staggering at the brink of destruction. At least that is what a look at the
current production figures and the results of a recent survey of the most important PVC
producers in Europe suggest” (“Der europäische—und insbesondere der deutsche—PVC-
Markt taumelt am Rand des Abgrunds. Das jedenfalls legen der Blick auf die aktuellen
Produktionszahlen sowie die Ergebnisse einer aktuellen Umfrage unter den wichtigsten
PVC-Erzeugern in Europa nahe.”). A permanent reduction in the sale of virgin PVC
through the expansion of recycling would significantly reduce plant capacity utilisation,
which would lead to significant financial losses for PVC manufacturers. It is unlikely that
PVC manufacturers will voluntarily bring about and finance this development.
Today, it is no longer disputed that PVC has a central function in chlorine removal.
A PVC ban would lead to a chlorine surplus in the chemical industry, which would then
become a waste problem. The Vinyl Environmental Council (VEC), for example, argues
this to the European Chemicals Agency [21].
Sustainability 2024, 16, 3854 18 of 24

But how do these serious negative economic consequences of a ban fit in with the
communication of “Vinyl”, which propagates the circular economy, which would have
the same consequences as a ban?
Unfortunately, we were not able to find a complete data set on the production of PVC
polymers or PVC plastics (compounds) at European level. But for single years, data are
available. According to PlasticsEurope [98] (there: page 16), the demand for (not: “produc-
tion of”) PVC plastics was around 4.9 million tonnes in 2012. Using the ECHA conversion
factor for PVC polymers to PVC compounds in [21], the 4.9 million tonnes of PVC plastics
should correspond to around 4 million tonnes of PVC polymer.
Ciacci et al. [99], who were allowed to evaluate the European PVC statistics of
PlasticsEurope almost ten years ago, also put the flow of PVC polymers in Europe in 2012
at 4 million tonnes. So, we have two sources for 2012. For a rough estimate of the
development, the data for demand for, and the flow of PVC polymers in the EU in 2012
should be equated with sales volumes. The sales volume of PVC polymers in 2021
amounted to 5.2 million tonnes (Eurostat, 2023b, cited in [19]). This means that the increase
in sales of PVC polymers over ten years (2012–2021) totalled (5.2 minus 4.0) 1.2 million
tonnes, an average increase of 3% or 135,000 tonnes of polymer per year. For PVC
compounds, the corresponding sales volumes are 4.9 million tonnes for 2012 and
6.8 million tonnes for 2021 [21], which corresponds to an average increase of 3.7% or
210,000 tonnes of PVC compounds per year.
In the same period (2012–2021), the increase in recyclate volumes from PVC com-
pounds in Europe averaged only around 50,000 tonnes per year (pre- and post-consumer)
according to Figure 4; this corresponds to around a quarter of the average growth in pro-
duction. The quantities of recyclates are even lower if the quantities from post-consumer
recycling (at calculation point (2)) are taken into account (less than 4000 tonnes a year).
And the volume of tonnes that have replaced virgin PVC (calculation point (4)) is surely
even lower. But only the latter would affect the PVC industry’s sales.
The production of PVC polymers (or PVC compounds) in the EU has de facto in-
creased far more than the quantities of substitution of virgin PVC from recycled waste
PVC in the period 2012–2021.

5. Conclusions
The PVC industry has been promising a sustainable PVC cycle for over 30 years. The
current level of certified material recycling of post-consumer waste in Europe is a meagre
12%. Vinyl has also informed us that post-consumer recycling volumes will amount to
599,000 tons in 2020. However, these figures are extrapolated and not certified. And we
do not know if there is a substantial reduction of virgin PVC with recyclates. And some
of the resulting products are of low quality and are frequently contaminated with banned
pollutants (legacy additives).
‘Vinyl’s’ current annual reports show significantly higher figures (see above), mainly
because pre-consumer recyclates are also included. The EU Commission has allowed this
practice exclusively for the PVC industry so that it can fulfil its voluntary commitments.
However, the main contributions to closing a material cycle can only be made through
post-consumer recycling. We therefore propose that only post-consumer recyclates should
be counted for successful material recycling.
As early as 1995, experts came to the following conclusion regarding the recycling of
PVC [100]:
“For individual product groups, a real material and product cycle would have to be
established by the manufacturers concerned, leading to a reduction in new production in
line with the quantities of recyclate produced. This would require a new industrial policy
in the respective sectors. New production and recyclate production should no longer take
place separately in terms of organization and business management, but only in a fully
integrated process”. (“Für einzelne Produktgruppen müsste von den jeweils betroffenen
Herstellern ein wirklicher Stoff- und Produktkreislauf aufgebaut werden, der zu einer
Sustainability 2024, 16, 3854 19 of 24

entsprechend den erzeugten Rezyklatmengen verringerten Neuproduktion führt. Dies

würde eine neue Industriepolitik in den jeweiligen Branchen voraussetzen.
Neuproduktion und Rezyklatproduktion dürften organisatorisch und
betriebswirtschaftlich nicht mehr getrennt ablaufen, sondern nur in einem
vollintegrierten Prozess.”)
On the road to a circular economy, the market for virgin PVC was supposed to grad-
ually shrink in order to be sustainable. This has not happened. The sale of PVC (com-
pounds) in Europe has risen steadily—with dips since the 1990s—by around 210,000 tons
per year in the last ten years alone. The annual increase in PVC recyclates (total post- and
pre-consumer) over the same period was only around 50,000 tons per year (see Section
4.4), and the increase in the post-consumer recycling alone was not even 4000 tons per
year. The substitution of virgin PVC can only be a share of these 4000 tons. We therefore
also suggest that the substitution of virgin PVC with post-consumer recyclates should be
collected statistically.
At the beginning of the 2000s, optimism still prevailed with regard to chemical recy-
cling: “It is assumed that, by the end of 2002, most of this information will be made avail-
able to form a basis from which industry can select and take investment decisions” [101].
But in the last 30 years, not a single industrial plant for chemical recycling has been built
and successfully operated. And there has also been no practical recycling solution for chlo-
rine, which accounts for 57% of pure PVC polymer by weight. Despite the promise of
recycling, the lion’s share of PVC waste in Europe is still being incinerated in waste-to-
energy-plants, where it tends to be a nuisance [75–77].
At the end of 2023, the European Chemicals Agency ECHA presented an “Investiga-
tion Report” following a request of the EU Commission [21]. In the second part, we will
therefore analyse what regulatory consequences need to be drawn.

Author Contributions: Conceptualization, writing—original draft preparation, U.L.; writing—re-

view and editing, B.Z.-L. All authors have read and agreed to the published version of the manu-
script.
Funding: This research received no external funding.
Institutional Review Board Statement: Not applicable.
Informed Consent Statement: Not applicable.
Data Availability Statement: The original contributions presented in the study are included in the
article, further inquiries can be directed to the corresponding author.
Acknowledgments: The authors would like to sincerely thank Christine Herrmann (European Envi-
ronmental Bureau (EEB)), Klaus Günter Steinhäuser (Arbeitskreis Umweltchemikalien/Toxikologie
beim Bund für Umwelt und Naturschutz Deutschland e.V. (BUND)), Vincent Stone (European
Council of Vinyl Manufacturers/VinylPlus) and Geoffroy Tillieux (European Plastics Converters
(EuPC)) for their valuable feedback.
Conflicts of Interest: The authors declare no conflict of interest.

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