Comment by pfdietz
15 hours ago
What is considered recycling? Is convert the clothing into fuel pellets considered recycling? What about thermal decomposition for feedstocks for chemical manufacture (and what if 75% of the mass isn't useful for that and is instead burned in turbines for cogeneration)?
Down-cycling is a thing. Even aluminum and steel get down-cycled.
I have no sympathy for recycling fetishism.
From previously linked text:
> The concept of destruction as outlined in this Regulation should cover the last three activities on the waste hierarchy, namely recycling, other recovery and disposal. Preparation for reuse, including refurbishment and remanufacturing, should not be considered destruction. Preventing destruction will reduce the environmental impact of those products by reducing the generation of waste and by disincentivising overproduction.
Basically, does it end up as waste or does it end up being repurposed in some good way? If the former, we should find a way of getting rid of it, if it's the latter, it's A-OK!
To clarify without using the word ‘waste’ into two simple bullets:
1. Destruction is conversion of any usable product X to any non-X form (even if the new form is usable).
2. Destruction is prohibited (for large businesses, right now).
Usable is not perfectly defined and will be a judgment call, but one can construct a common sense set of ‘what is unusable?’ definitions that an inspector or judge would accept — so long as sellers have not explicitly caused such outcomes:
- Product lacks structural integrity (a loose thread doesn’t count, a missing sleeve does count)
- Product is contaminated (tried on and didn’t fit doesn’t count, motor oil stains does count)
- Product is unsafe (tried on and didn’t fit doesn’t count, underwear returned with safety liner removed may count, product has been worn for more than try-on period may count)
Note that, for example, the EU is likely to say ‘launder it first, then donate it’ for products that are worn and returned but can be safely donated after laundering; so they are specifically aware of some of the loopholes that corps will aim for first.
> Note that, for example, the EU is likely to say ‘launder it first, then donate it’
That's great because it will put pressure on manufacturers to build launderable clothing.