The European Commission is considering adopting the mass balance fuel-exempt method for allocating recycled content in single-use plastic beverage bottles. A draft document implementing the decision, which could prove transformational for the chemical recycling industry, is being discussed today in a meeting of the Waste Technical Adaptation Committee.
The draft document seen by Sustainable Plastics is dated Feb. 13 and proposes repealing the Commission Implementing Decision (EU) 2023/2683 of November 2023. That decision does not recognise material allocated through the mass balance method in chemical recycling as recycled plastic but rather as ‘material stemming from post-consumer plastic waste’. Moreover, the decision does not consider technologies such as pyrolysis and gasification to be within the scope of the regulation.
Recognition for mass balance
In mass balance, a certified volume of renewable or recycled material is input across a production run but may not be evenly distributed across each individual product output. Using the mass balance method allows economic operators to state that they use a certain percentage of recycled or renewable material in their products, without having to prove that each individual product produced has that percentage of recycled or renewable material.
Given that pyrolysis oil is blended with virgin feedstocks in a cracker, and that the two feedstocks cannot be physically separated once co-fed, many argue that recognising mass balance is essential for allocating recycled content via this chemical recycling technology.
The new draft document recognises mass balance accounting as a way to calculate the weight of recycled plastic. Articles 5 and 6 say that calculation for recycled plastic which is not obtained through mechanical recycling or ‘any other recycling technology for which the proportion of material stemming from post-consumer consumption waste in the output is known and for which no other plastic waste than post-consumer plastic waste is used as input’ shall use mass balance accounting.
Mass balance accounting rules
Article 7 lays down the rules for mass balance accounting. In summary, the recycled content attributed within each fuel-exempt mass balancing period (maximum of 3 months) is calculated by multiplying the weight of recycled input material with a conversion factor. That conversion factor is calculated as the ratio between the weight of the process output and the weight of the process input. The fuel-exempt method deducts a certain proportion of the output weight to account for fuels and residues such as char.
“The conversion factor shall be based on representative process-specific operational data of the respective mass balancing period,” article 7 reads. “The economic operator may provide certified evidence that the distribution of the attributed amount to the outputs of the considered process is not uniform.”
Mass balance accounting may be applied at site-level, but attributed amounts cannot be transferred between different sites of a company or between different companies.
Next steps
The draft document is being discussed until 17:00 CET today. Sustainable Plastics will update this article when a summary record of the meeting is made public. For now, the draft document makes explicit that its text has not been adopted or endorsed by the European Commission and that any views expressed are the preliminary views of the Commission services and may not in any circumstances be regarded as stating an official position of the Commission.