The Plastics Recycling Show Europe (PRSE) has kicked off in Amsterdam. The world’s largest recycling show is taking place on 19-20 June, for the first time across four halls (Halls 9-12) at the RAI in Amsterdam.
During the conference opening session, Werner Bosmans, Team Leader on Plastics, DG Environment, at the European Commission discussed the ‘burning issues’ around EU plastic policy.
The potential adoption of the mass balance fuel-exempt method for recycled content allocation in single-use plastic beverage bottles is one of them.
This February, the European Comission discussed a draft document that recognises mass balance accounting as a way to calculate the weight of recycled plastic. If approved, it could prove transformational for the chemical recycling industry.
At PRSE, Bosmans revealed that ‘a vast majority of member states is in favour of this in broad lines’.
Single Use Plastics Directive
The legislation at the heart of this discussion is the Single Use Plastics Directive (SUPD). It sets recycled content targets for PET bottles of at least 25% recycled pet by 2025, and of 30% for all bottles by 2030.
The Commission Implementing Decision (EU) 2023/2683 of November 2023 implements rules for the application of the SUPD. That decision only recognises mechanically recycled material as counting towards the targets.
That has so far worked for PET bottles, Bosmans explained, however ‘for bottles beyond PET, we have been struggling’, he said.
Public consultation
“At the moment we are considering an amendment that introduces controlled blending and mass balance accounting, fuel-exempted with third-party verification. There should be a public consultation soon, I hope in summer.”
Bosmans further said the view of the Commission is that ‘mechanical recycling is better than chemical recycling, but chemical recycling is better than incineration’. Chemical recycling should complement mechanical recycling if it causes less environmental burden than incineration and virgin plastic production, he argued.
After revealing that the ‘vast majority’ of EU member states are in favour of such an amendment, Bosmans added he does not however have a ‘crystal ball’ to predict how capitals will vote in the end. The PPWR legislation is a good example of how countries can change their stands until the very last minute.
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 draft document under discussion 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.