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Recycling is a key component of modern waste management and is the third component of the "Reduce, Reuse, Recycle" waste hierarchy. Recyclable materials include many kinds of glass, paper, metal, plastic, textiles, and electronics. Although similar in effect, the composting or other reuse of biodegradable waste – such as food or garden waste – is not typically considered recycling. Materials to be recycled are either brought to a collection center or picked up from the curbside, then sorted, cleaned, and reprocessed into new materials bound for manufacturing. In a strict sense, recycling of a material would produce a fresh supply of the same material, for example used office paper to more office paper, or used foamed polystyrene to more polystyrene. However, this is often difficult or too expensive (compared with producing the same product from raw materials or other sources), so "recycling" of many products or materials involves their reuse in producing different materials (e.g., cardboard) instead. Another form of recycling is the salvage of certain materials from complex products, either due to their intrinsic value (e.g., lead from car batteries, or gold from computer components), or due to their hazardous nature (e.g., removal and reuse of mercury from various items). Critics dispute the net economic and environmental benefits of recycling over its costs, and suggest that proponents of recycling often make matters worse and suffer from confirmation bias. Specifically, critics argue that the costs and energy used in collection and transportation detract from (and outweigh) the costs and energy saved in the production process; also that the jobs produced by the recycling industry can be a poor trade for the jobs lost in logging, mining, and other industries associated with virgin production; and that materials such as paper pulp can only be recycled a few times before material degradation prevents further recycling. Proponents of recycling dispute each of these claims, and the validity of arguments from both sides has led to enduring controversy. Recycling has been a common practice for most of human history, with recorded advocates as far back as Plato in 400 BC. During periods when resources were scarce, archaeological studies of ancient waste dumps show less household waste (such as ash, broken tools and pottery)—implying more waste was being recycled in the absence of new material. In pre-industrial times, there is evidence of scrap bronze and other metals being collected in Europe and melted down for perpetual reuse. In Britain dust and ash from wood and coal fires was collected by 'dustmen' and downcycled as a base material used in brick making. The main driver for these types of recycling was the economic advantage of obtaining recycled feedstock instead of acquiring virgin material, as well as a lack of public waste removal in ever more densely populated areas. In 1813, Benjamin Law developed the process of turning rags into 'shoddy' and 'mungo' wool in Batley, Yorkshire. This material combined recycled fibres with virgin wool. The West Yorkshire shoddy industry in towns such as Batley and Dewsbury, lasted from the early 19c to at least the First World War. In 1987, the Mobro 4000 barge hauled garbage from New York to North Carolina; where it was denied. It was then sent to Belize; where it was denied as well. Finally, the barge returned to New York and the garbage was incinerated. The incident led to heated discussions in the media about waste disposal and recycling. The incident is often referred to as igniting the recycling "hysteria" of the 1990s. Economist Steven Landsburg has claimed that paper recycling actually reduces tree populations. He argues that because paper companies have incentives to replenish the forests they own, large demands for paper lead to large forests. Conversely, reduced demand for paper leads to fewer "farmed" forests. Similar arguments were expressed in a 1995 article for The Free Market. When foresting companies cut down trees, more are planted in their place. Most paper comes from pulp forests grown specifically for paper production. Many environmentalists point out, however, that "farmed" forests are inferior to virgin forests in several ways. Farmed forests are not able to fix the soil as quickly as virgin forests, causing widespread soil erosion and often requiring large amounts of fertilizer to maintain while containing little tree and wild-life biodiversity compared to virgin forests. Also, the new trees planted are not as big as the trees that were cut down, and the argument that there will be "more trees" is not compelling to forestry advocates when they are counting saplings. The recycling of paper should not be confused with saving the tropical forest. Many people have the misconception that paper-making is what's causing deforestation of tropical rain forests but rarely any tropical wood is harvested for paper. Deforestation is mainly caused by population pressure such as demand of more land for agriculture or construction use. Therefore, the recycling paper, although reduces demand of trees, doesn't greatly benefit the tropical rain forests.