Earlier this week, organisations from across the value chain called on the EU to adopt mass balance as a means of developing EU-harmonised calculating rules for recycled content in plastics applications in order to meet revised environmental targets.

In this article, Nigel Davis, Insight Editor at ICIS, discusses why tracking of recycled content is a major issue, especially with the industry pressing for the legal acknowledgement of a mass balance approach that excludes fuel use.


There is obvious urgency behind the recent meeting of 31 trade associations for the EU to be clear on how it legally views chemical recycling and how recycled content is tracked in plastic products.

It is the tracking of recycled content that is a major issue with industry pressing for the legal acknowledgement of a mass balance approach that excludes fuel use.

“Mass balance is a transparent and auditable method to trace a defined material characteristic along the value-chain from material suppliers to consumers,” the trade associations, which represent chemical producers, plastics converters, recyclers and end-use industries, claim.

“A mass balance chain of custody is already used and accepted in other domains such as sustainable forestry products and fair-trade cocoa and chocolate,” they said.

Essentially, this is push for policy support from the European Commission and EU member states for chemical recycling that could help speed investment and add more overall plastic recycling capability.

“The rules currently being developed for the Single-Use Plastics Directive (SUPD) implementing act will have a key impact on both mechanical and chemical recycling investments in Europe,” the associations said.

The timelines for targets set out in frameworks such as the proposed Packaging and Packaging Waste directive, which set out goals for chemical recycling capacity by 2030 and 2040, will require the sector to begin work on commercial-scale production facilities immediately, according to the associations.

“It is therefore key that policymakers set a precedent as to when and how a mass balance chain of custody in recycled plastics will be applied in the EU sooner rather than later,” the trade groups said

“This precedent should also set the direction of policy in non-packaging sectors such as automotive or construction, where recycled plastics targets are currently under discussion or may arise in the future.”

There are clear concerns over the mass balance approach to approximating the recycled content of individual plastic items and customer acceptance is critical. If recycling capacity is to grow however, and the move towards greater plastics circularity accelerated, then clearer policy support is required.

The industry view is that the mass balance model can be based on credible third-party verification and certification. Chemicals trade group Cefic says that process losses and outputs, consumed as energy, should not count towards the recycled content targets.

“We need all up- and down-stream levers to be deployed, including both mechanical and chemical recycling, to create a circular plastics economy,” added Plastics Europe Managing Director Virginia Janssens on Friday, noting that chemical recycling is the only avenue for reusing certain kinds of plastic waste and to reach quality levels needed for some end markets.

“However, the complexity of the European plastics system, and long-investment cycles, mean investment decisions taken now will determine what the industry looks like in 2050,” she said.

Janssens added: “To accelerate the growth of chemical recycling, investors need the confidence provided by a full recognition of chemical recycling and acceptance of the mass balance model by EU policy makers. The window of opportunity to make investment decisions is rapidly closing.”

According to Helen McGeough, senior analyst for plastic recycling at ICIS, the open letter is the latest call from the recycling value chain for greater legal certainty from regulators.

“The chain is set to invest or seek investment to expand capabilities which will ultimately improve supply of recycled materials and move higher volumes of plastic waste away from the lower echelons of the waste hierarchy and requires this certainty to support those investment decisions,” she said.

“The supply chain wants and needs to have clarity on how to prove recycled content, for reporting purposes both legally required and expected from consumers,” she added.

At present the sector lacks a standardised approach, according to McGeough, with the commonly-used methodology behind mass balance remaining contentious.

“The open letter suggests the use of mass balance for recycling, but it remains unclear from the letter whether the mass balance approach is suggestion application not only to chemical recycling, but to mechanical recycling as well where it is generally not adopted in the same way,” she said.

In mechanical recycling mass balance can also refer to the process of using a credit system to substitute the use of recycled material in one end-use for another in order to meet sustainability targets, according to McGeough.

“This can generate criticism for failing to fundamentally encourage tangible growth in recycling, increasing claims of greenwashing by the sector.” she said.

The concept of greenwashing is coming under increasing scrutiny in the EU, with regulators this week announcing a stronger push on eliminating the practice as deadlines to reach certain thresholds for recycling and carbon abatement draw closer.

At present, many of the systems for quantifying decarbonisation and waste-reduction remain fragmented, with McKinsey noting that the environmental, social and governance (ESG) space is currently similar to the state financial reporting was in a century ago.

Systems are likely to become more standardised over time, but the complexity of chemical – and even mechanical – makes the process a complex one, with few easy answers.

“Although harmonisation in the recycling sector is needed in many areas, in terms of standardising recycled content measurement this is challenging to resolve by a one size fits all approach for a complex industry, where the routes to recycle – and mechanisms involved in each – vary so much.” concluded McGeough.

Additional reporting by Helen McGeough.

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