Adoption of the fuel-exempt mass balance allocation method for chemically recycled content is closer to reality than ever before. An expert committee of the European Commission met earlier this week to discuss a draft document implementing the decision.
Now, a group of seven non-governmental organisations (NGOs) has responded with calls for a more restrictive, ‘polymer-only’, mass balance allocation method.
Fuel-exempt vs. ‘polymer-only’ 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.
Many argue that recognising mass balance is essential for allocating recycled content via chemical recycling technologies like pyrolysis or gasification. During the pyrolysis process, for example, pyrolysis oil is blended with virgin feedstocks in a cracker and the two feedstocks cannot be physically separated once co-fed. That means the amount of recycled material in the output of the process, usually a mix of residues and hydrocarbons suitable to produce fuel, plastics, or other chemicals, may not be individually distributed in each individual product output.
The recycled content attributed within the mass balance method 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.
In October 2023, industry associations called for an ‘urgent’ adopting of the fuel-exempt mass balance method as the standardised approach for allocating recycled content through chemical recycling.
The fuel-exempt method deducts a certain proportion of the output weight to account for fuels and residues such as char. That means, for example, that outputs of the pyrolysis process used to make chemicals rather than plastics would still count as ‘credits’ towards recycled content allocations in the Single-Use Plastics Directive.
The NGOs, including the Environmental Coalition on Standards (ECOS) the European Environmental Bureau (EEB), European Recycling Industries’ Confederation (EuRIC), and Zero Waste Europe (ZWE), are calling the European Commission to adopt a ‘polymer-only’ mass balance method instead.
The ‘polymer-only’ method deducts the weight of the process outputs used to make chemicals other than plastics in addition to fuels and residues, thereby further reducing the proportion of allocated recycled content.
This approach was also consideration, but the European Commission now seems more likely to side with the method supported by the plastics and chemical industries.
Accusations of greenwashing
The NGOs claim that using ‘recycled content credits’ from material used to produce chemicals to allocate 100% recycled content to, for example, a PET bottle amounts to ‘greenwashing’.
“It is worth noting that mass balance accounting shall only be used as a last resort when other models providing greater transparency and traceability (i.e. segregation and controlled blending) are not feasible to fully maximise the benefits of recycling,” they said in a statement. “When mass balance accounting is needed, the allocation rules should be stringent, aim to prevent greenwashing, ensure a level playing field among technologies, and promote genuine innovative solutions that do not require dilution with virgin feedstock and high energy demand. The ‘fuel-use excluded’ allocation rule does not meet these criteria and represents nothing more than an additional economic incentive.”
The environmental groups call for a mass balance allocation method restricted to polymers as a ‘compromise’, whenever segregation and controlled blending are not feasible.
Next steps
Following this week’s meeting, there should be a public consultation of the draft implementation, followed by formal adoption before the European Parliament’s last scheduled plenary session at the end of April. The Single-Use Plastics Directive requires 55% of EU member states to vote in favour of the decision for it to be approved.