February 2005

Volume 14, Number 2

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Article Contents

Recycled Content: What is it and What is it Worth?

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Recycled content is the most widely cited attribute of green building products. Numerous federal, state, and local government agencies have “buy recycled” programs aimed at increasing markets for recycled materials—these programs typically have an explicit goal of supporting recycling programs to reduce solid-waste disposal. A handful of programs claim to target environmentally preferable purchasing in a broader sense, yet in practice they focus almost exclusively on recycled content because that attribute is ostensibly easy to define and measure. But even this relatively quantifiable attribute can be tricky to document, and its presumed environmental benefits have rarely been tested.


Recovered-Material Levels for the Comprehensive Procurement Guidelines (CPG)


The recycled-content ranges in this table represent most of the construction and other building-related items from the U.S. EPA’s Consolidated Recovered Materials Advisory Notice, last revised in April 2004. These notices implement the Comprehensive Procurement Guidelines (CPG). See www.epa.gov/cpg/ for details. Federal agencies and others using federal dollars for large purchases are required by regulation and executive order to implement programs that provide preference for materials meeting these guidelines, as long as performance, availability, and price are not unduly compromised. “EAF” refers to electric arc furnace, and “BOF” refers to basic oxygen furnace.

Table compiled by Mark Piepkorn

In the 1970s, the U.S. public began expressing concerns about litter, overflowing landfills, and a proliferation of waste-to-energy incinerators. The far-reaching federal Resource Conservation and Recovery Act of 1976 (RCRA) addresses many aspects of solid- and hazardous-waste management. Tucked away in Section 6002(e) of RCRA is a mandate that requires anyone spending federal dollars to give preference to items made with materials that have been recovered from the waste stream. The same mandate directed the U.S. Environmental Protection Agency (EPA) to designate items that are or can be made with recovered materials, and to help others procure these products—resulting in the Comprehensive Procurement Guidelines program from EPA’s Office of Solid Waste (see chart).

In mandating this recycled-content procurement, the authors of RCRA were ahead of their time. The federal government wasn’t really prepared to implement that mandate—it took a 1987 lawsuit against the EPA administrator by the Environmental Defense Fund, the National Recycling Coalition (NRC), and others to get the program rolling. In fact, NRC was founded largely to encourage the government to fulfill its mandate. Even in the culture at large, recycling didn’t really take off as a social phenomenon until the early 1980s.

When recycling did start to catch on, it immediately became clear that markets had to be developed for the recovered materials, because a glut of material would cause prices to nosedive, which would make the recycling programs less cost-effective. This market development had to be carefully managed, however, because if there were not enough recovered materials to meet demand, the new ventures would not be profitable. Throughout the 1980s, many states, counties, and municipalities joined the federal government in encouraging or mandating the use of recycled-content products in order to create outlets for materials collected in recycling programs.

Quite early in the process, according to recycled products consultant Nancy VandenBerg, building materials were identified as a potential outlet for recovered materials. “Paper was a problem,” recalls VandenBerg, who was researching markets for EPA. “We had run into serious difficulties with the newsprint industry—they didn’t want to touch recycled newsprint. Hence we started to look at cellulose insulation. But in order to research one type of insulation, we had to look across the board, at everybody’s insulation products.” Concrete made with flyash was the other building material designated by EPA for agency use in the early stages of the program.

Recycled Material Definitions


Definitions of recycled content and all the related terms vary by agency, source, and program (see sidebar), but they are increasingly consistent, at least in intent. In general terms, recovered or reclaimed materials are those that have been extracted from a waste stream but not yet turned into a new product. Post-consumer reclaimed materials are those that have reached their end-user before being discarded, while pre-consumer reclaimed materials have been recovered from a waste stream somewhere in the manufacturing process prior to reaching their end-user. Post-industrial, a term that is synonymous with pre-consumer, is used less widely. Once they are incorporated into a new item, materials from all of these categories become recycled materials.

Salvaged, refurbished, and reused materials are recognized by most recycling incentive programs as equivalent to, if not better than, recycled-content materials. These are products that can be reused without needing to be remanufactured. In this sense, salvaged materials are a subset of reclaimed materials—all salvaged materials can be considered reclaimed, but not all reclaimed materials are salvaged. But there is no hard-and-fast line dividing reuse from recycling, and the terminology varies by industry. Salvaged wood timbers that are remilled into flooring are generally considered salvaged, for example, even though they have been reprocessed much like they would have been if they had come from

virgin timber.

Some definitional issues can be resolved with just a little common sense. Edge trimmings from a roll of paper in a paper mill are not considered reclaimed if they can be repulped and turned into new paper within the same mill, for example. But if the original roll was made from post-consumer material, then those same edge trimmings can still be considered post-consumer when they go into another roll.

Recycled Content in LEED

Projects seeking certification under the U.S. Green Building Council’s LEED® for New Construction (LEED-NC) Rating System often pursue the two points in Materials & Resources credit 4 for using recycled-content materials, and an additional innovation point for significantly exceeding the credit requirements. Of the first 148 projects certified under LEED-NC version 2.0/2.1, 87% achieved the first point and 68% the second point. In LEED 2.1, the first point is achieved if the “recycled-content value” of materials used in a building represents at least 5% of the total materials cost, and the second point is achieved if that value reaches 10%. The recycled-content value of a product or material is the percentage (by weight) of the material that is post-consumer recycled plus one-half of the percentage that is pre-consumer recycled, multiplied by the cost of the material:

(post-consumer recycled content


1/2 pre-consumer recycled content)


material cost

The decision, in LEED, to devalue pre-consumer recycled content by half compared to post-consumer content is an outgrowth of the credit’s origins in the pilot (version 1) LEED Rating System. In version 1, points were achieved for using a certain fraction of materials (on a cost basis) that had at least 20% post-consumer or 40% pre-consumer content. Using this method, materials that had some recycled content, but not more than 20% post-consumer or 40% pre-consumer, were not counted at all, and materials that had more recycled content than the 20% or 40% didn’t get any extra credit. That approach was replaced in LEED 2.0 with a complicated formula that included dividing post-consumer recycled content by 20% and dividing pre-consumer recycled content by 40%, in effect giving post-consumer content twice the value of pre-consumer.

Perhaps inadvertently, when this new formula was introduced, the effective thresholds for the two recycled-content points were lowered dramatically. That formula was simplified, while providing the same results, to end up with the LEED-NC 2.1 calculation described above. The newly released LEED for Commercial Interiors retains the same formula but doubles the thresholds to 10% for the first point and 20% for the second. The same change has been proposed in the draft version of LEED-NC 2.2. LEED-Canada, meanwhile, opted to split the difference, with thresholds of 7.5% and 15%.

LEED for Existing Buildings (LEED-EB) has returned to an approach more like that used in LEED-NC version 1, in which materials must contain at least 10% post-consumer or 20% pre-consumer to count, and higher levels don’t make them count for more. This simplification was adopted because, in LEED-EB, recycled content is combined with several other green material attributes that are all added together to determine the number of points achieved, and factoring in varying “recycled-content values” for each material was deemed too complicated.

Benefits and Costs

Recycling “is a means to an end, but it has become an objective in its own right,” says Wayne Trusty, director of the ATHENA™ Sustainable Materials Institute. “It always has a positive landfill implication,” he notes. But in terms of other environmental concerns, such as global warming, energy use, and ozone depletion, it may not always be beneficial, according to Trusty. “Sometimes it may take more energy and resources to collect, transport, process, and recycle something into a usable product than you save. So there may be cases where we’re better off if we incinerate and capture the energy than if we recycle the product,” he explains.

There is also a risk that using materials with high recycled content will compromise other important goals, such as energy efficiency or indoor air quality. A 2003 study by the California Department of Health Services (see EBN Vol. 13, No. 2) concluded that, overall, using recycled-content materials does not tend to adversely affect indoor air, but it did find some notable exceptions. Flooring materials derived from used tires, in particular, raised air-quality concerns.

Comparing Virgin and Recycled Materials


Adapted from an analysis performed by Sylvatica, Inc. of North Berwick, Maine, based on the Franklin Associates 1998 database in SimaPro software, characterized using the EcoIndicator 99 method. The comparisons are on a straight mass basis, which is valid only if the recycled and virgin materials are perfectly interchangeable. For these two materials, in almost all impact categories, the recycled-content material has a lower environmental burden.

A comparison of recycled to virgin materials over a range of environmental impact categories shows that, at least for the materials sampled, using recycled content does consistently reduce environmental impacts (see bar charts). The degree of benefit varies significantly by material, however.

Following Recycled Content in a Life-Cycle Assessment

Environmental life-cycle assessment (LCA) is an attempt to quantify and characterize all the significant environmental inputs and outputs associated with a product over its entire life cycle (see EBN Vol. 11, No. 3). Recycling and the use of recycled content is a thorny issue for LCA practitioners. But if a material goes through one life as one product and then has a second life as recycled content in another product, how should the resources used to produce that material be allocated between those two products?

In the case of a material that is recovered from a post-consumer waste stream, there is consensus that none of the resources or pollution from its original manufacturing should count towards its second (or future) incarnation. These materials are still not free of environmental burdens, however, because resources are used and pollution is emitted to collect, transport, and prepare them as inputs to a new manufacturing process. The only objections to this convention come from some in the metals industry, who argue that, since much of their material will inevitably be recycled, not all of the environmental burdens from the extraction and processing of the virgin materials should be counted against the first product to use those materials.

When dealing with pre-consumer material, the life-cycle assessment protocols are not as clear-cut. In LCA terms, the outputs of a process are considered to be products, co-products, byproducts, and waste products. Exact definitions of each of these outputs vary, but, in general terms, products and co-products are the principle items that the process was set up to create. Byproducts are materials that are not the intended outputs, but may nevertheless have economic value. And waste products are unwanted outputs that must be disposed of. This is where the definitions get tricky, however, because most definitions of pre-consumer recycled content require that it come from a “waste material,” but as soon as a market is created for that waste material, it might be considered a byproduct rather than a waste product.

How to allocate the environmental burdens among the byproducts and waste products is even less clear. Practices in LCA range from allocating a full share of resources and pollution to pre-consumer recovered materials, to allocating none at all to them. When a share is allocated, it may be prorated based on the mass of the material, or based on its economic value. “Economic allocation works well for waste or near-waste,” notes Trusty. The cleanest solution in terms of LCA methodology is to expand the boundaries of the system that is being modeled to the point where the pre-consumer recycling is all happening within a defined system, in effect treating it like scrap that is reused within a factory and therefore not considered recycled. If no material is moving from one system to another, there is no need to figure out how much of the environmental burden from one system should be transferred. In this scenario, any recycling that happens within a system just contributes to reducing the amount of resources needed and pollution produced per unit of end product.

Certifying Recycled Content

Most governmental buy-recycled programs expect their participating agencies to obtain some type of certification from the supplier regarding the recycled-content levels in the purchased products. In most cases, these figures are simply declared by the manufacturer with no independent verification. One of the key uncertainties that has to be resolved in determining a product’s minimum recycled content is how to deal with variability in the mix. EPA’s instructions to federal agencies give them a lot of latitude to work with manufacturers on this issue. Actual batch-by-batch recycled-content levels are preferred (these provide the closest approximation of the actual amount of recycled material in any given item), but recycled content averaged over three months “or some other appropriate averaging period” is also considered acceptable.

This question regarding the best

averaging period is one of the reasons some companies have hired an independent agent to audit their manufacturing process and certify their recycled content. This third-party certification is “a good idea,” opines Trusty. “Not that anybody is cheating, but there are so many definitional problems,” he notes. The only organization providing that service for building products in North America is Scientific Certification Systems, Inc. (SCS) of Emeryville, California. “Recycled-content certification is a unique environmental certification because it is a combination of accounting and manufacturing-process auditing, overlaid by environmental definitions,” notes Kirsten Ritchie, director of environmental claims at SCS. SCS has recently updated its “Environmental Certification Program: Material Content” standard (now SCS-EC11-2004). Among the changes in this version are recycled-material definitions based on those from the International Organization for Standardization (ISO).

SCS is also an accredited certifier of forest management and chain-of-custody practices for the Forest Stewardship Council (FSC), so SCS now actively certifies FSC’s new recycled-content labeling program (see “Forest Stewardship Council’s New Labeling Rules” in this issue).

Recycled Steel

Steel calls itself “North America’s number one recycled material.” The Steel Recycling Institute (SRI) estimates that almost 69 million tons (63 million tonnes) of steel were recycled or exported for recycling in 2003. In steel-industry jargon, there are three types of scrap steel, based on their origin:

Home scrap is internal to a steel mill or operation and is recycled within that operation. This definition implies that home scrap is not what most industries would consider reclaimed material, although SRI claims that 80% is pre-consumer or post-industrial reclaimed.

Prompt scrap is waste generated by manufacturing processes for products made from steel—this is classic pre-consumer material.

Obsolete scrap is material that has been used (as a car, beam, or appliance) before being recycled, and is consistent with most definitions of post-consumer reclaimed material.

Steel is manufactured in one of two types of factories. A basic oxygen furnace is the traditional manufacturing facility, which is typically part of a large integrated mill that also makes iron from ore and can cold-roll high-quality sheet steel for cars and appliances. SRI estimates that basic oxygen furnaces use about 30% recycled steel, of which most (about 23%) is post-consumer.


Steel scrap is fed into an electric arc furnace using an overhead hopper.

Source: Steel Recycling Institute

The other type of steel factory is the electric arc furnace, which is more likely to stand alone as a “minimill” rather than as part of an integrated operation. Electric arc furnaces rely entirely on scrap steel and iron. SRI estimates that, on average, they use about 59% post-consumer and 32% post-industrial scrap. Because most minimills lack the post-processing equipment needed to make high-grade sheet steel, they tend to produce more heavy-gauge items, such as steel plates, beams, and rebar.

The steel industry argues that there is little point in specifying high recycled-content levels in steel products because so much steel is recycled as a matter of course, and all the scrap steel that it is economically feasible to recycle is already recycled. Others counter that some steel still ends up in landfills, and, if a clear demand is established for steel with high recycled content, it might prove economically viable to recover a bit more of that material.

Recycled Wood

Wood is not as inherently recyclable as metal—with the exception of remanufactured salvaged timbers, it is nearly always “downcycled” into a lower-grade material such as particleboard or mulch. There have been several attempts to create businesses that reclaim post-consumer waste wood and convert it into particleboard and medium-density fiberboard panel products. The largest such effort was by The CanFibre Group, Ltd., which built factories in Riverside, California, and Lackawanna, New York. These plants were not profitable, though, and the use of “urban wood waste” has been largely discontinued.

The question of whether sawmill waste, including sawdust, planer shavings, and edge slabs, can be consider pre-consumer reclaimed material has been hotly debated for some time. While the material is not reused within the same manufacturing operation, there is some question as to whether it is truly recovered from a waste stream, since at least marginally economical uses have long existed for these materials. EPA began classifying it as a recycled material only recently, when the fourth Recovered Materials Advisory Notice (RMAN) for the Comprehensive Procurement Guidelines came out listing particleboard for office furniture applications as 80 to 100% pre-consumer recycled.

This listing was added in response to lobbying by the Composite Panel Association, which classifies sawmill waste as a “recycled fiber” in its Environmentally Preferable Products Specification. That specification also has a “recovered fiber” category, which includes material that is not considered recycled by other programs. Examples of recovered fiber include pre-commercial forest thinnings and salvage operations. Scientific Certification Systems has also accepted sawmill waste, but not commercial thinnings, as a reclaimed material in its latest Material Content Standard.


As recycled content is used more and more widely in preferential purchasing programs and building rating systems, it is important to ensure that all manufacturers are using consistent protocols to report their data. Clear, consistent definitions will help in this regard, but audited, third-party certification is even better. While no programs that EBN is aware of currently require third-party certification of recycled content, designers may feel more comfortable specifying products that have that endorsement as a way of minimizing the likelihood that their recycled content claims will be challenged.

From its origins as a strategy to support the efforts of the recycling industry to divert waste from landfills, to its establishment as a proxy for environmental preferability in materials, recycled content has become a key part of all green-building initiatives. While encouraging recycled content in materials is overall a good thing, it should be done sensibly. If using a material with high recycled content is likely to compromise other performance issues, such as energy efficiency or indoor air quality, then it may not be the right choice from a broad environmental standpoint. Someday, recycled content will just be one aspect of a material’s flow that is analyzed using a comprehensive, reliable, LCA protocol, but until we get there (and even after we do!) we should be sure to keep an eye out for the broader context in all material choices.

– Nadav Malin

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February 1, 2005