Recycled Content

My interpretation is that if a manufacturer does not have closed loop recycling, then the recycled content from their product cannot contribute to this portion of the credit. So only products with closed loop recycling programs will be able to contribute recycled content credit. Though there are no specific requirements for how much material must be actually closed loop recycled to qualify a manufacturer as having a program. Is 1,000 pounds enough? 1 million pounds? There needs to be some threshold. NSF 140 - Sustainable Carpet Assessment Standard has clear criteria for end-of-life management with specified reclamation rates. The manufacturer must document a reclamation rate of at least 1% or 40,000 lbs (whichever is smaller) where the reclamation rate = (lbs of all product reclaimed annually) divided by (lbs of annual production of product being certified)

I really like the idea of closed loop recycling, but the way I'm reading this now, it seems to ignore the tremendous number of cross-industry secondary markets for recycled content that have gained momentum over the years. I would like to see an alternative that offers credit for manufacturers with a closed loop process in combination with strong, time-tested recycling (not downcycling) opportunities between industries/product types.