Chemical recycling, greenwashing claims at play in mass balance discussions

Orlando, Fla. — For chemical recycling to work effectively, some plastics and consumer product companies say governments need to embrace very technical but important standards called mass balance.

They're pushing for the standards, used to track recycled content across complex supply chains, to be included in projects such as the rewrite of the U.S. government's Green Guides and in the United Kingdom's new tax on plastic packaging that lacks recycled content.

It's an idea that's controversial, though, especially with recyclers and environmental groups. They argue mass balance claims on packages confuse consumers and leave companies vulnerable to greenwashing charges.

The debate played out at a recent plastics industry conference, where executives said clearer mass balance rules for measuring plastics recycled content would help create a framework to scale up the chemical recycling industry.

An executive with Evansville, Ind.-based plastic packaging maker Berry Global Group Inc., for example, pointed to the Federal Trade Commission's plans to rewrite its Green Guides for environmental marketing.

"I think the Green Guides should recognize recycled material from mass balance, absolutely," said Diane Marret, Berry's sustainability director of consumer packaging for North America, speaking at the American Chemistry Council's Innovation and Circularity Summit: Advanced Recycling and the Future of Plastics, June 28-29 in Orlando.

Others agreed.

"I think one of the biggest opportunities in the updates to the Green Guides is to explicitly include mass balance accounting methodologies for advanced recycling," said Matt Rudolf, vice president for international business development with certification firm SCS Global Services.

The topic is showing up in European tax policy debates.

Barnaby Wallace, global commercial lead for packaging for Mars Petcare, said it has been talking with tax officials in the United Kingdom, urging them to accept mass balance when administering a new tax on plastics packaging with less than 30 percent recycled content.

"We're asking them if they can recognize mass balance as a bona fide methodology for reporting against their tax," Wallace told the conference. "That's a debate that's been going on for a year and a half. It's taking time for regulators to get comfortable."

Mars and other companies argue that mass balance chemical recycling will be critical to meeting recycled-content goals in plastic packaging because of limits around traditional mechanical recycling.

"We're going to use mass balance, and it's going to be a great tool for all of us," he said. "It's something which we hope is going to be accepted."

Rudolf and others at the event said mass balance standards have been used for years in industries like biofuels or electric power, where renewable and fossil-based fuels or power are mixed together, but consumers still want to be able to purchase green energy.

They suggested that while mass balance is newer for plastics, companies should work to make governments and the public more comfortable with the ideas.

"I think at some level if we point to existing systems that are in place and have been used in other sectors, we can create comfort for regulators," Rudolf said.

But there is still wariness about how mass balance would be used, with concerns that it could be deceptive for consumers.

A speaker at the ACC conference from toy maker Lego A/S, for example, said that while they support chemical recycling, they worry about being accused of greenwashing over mass balance claims.

"It's so far upstream in our supply chain that how do we say this is how much recycled content mass balance is included in our product," said Drew Felz, Lego's Washington-based director of government and public affairs. "We need to make sure that we can make that claim to the consumer in a clear way that they understand and we're not going to get labeled greenwashing."

Similarly, a plastics recycling group wants FTC and other regulators to be cautious.

The Association of Plastic Recyclers said in April comments to FTC that its public opinion research shows consumers have little understanding of mass balance. APR said consumers see a recycled-content claim on packaging as meaning that the package in their hand has recycled content. But the group said mass balance only means that a source material could have recycled content, not a specific package. It urged FTC to be cautious with mass balance advertising directly to consumers.

"Consumers purchase a product with recycled content with the implied understanding there are recycled materials in that actual product, and claims must conform to that understanding," APR said. "Making recycled-content claims in on-pack labeling, based on mass balance calculations, is deceptive to the consumer because there is little to no physical traceability to prove that there is any physical recycled content in the actual product, which is contrary to what the consumer believes to be true."

The mass balance debate features widely in FTC considerations, with the commission specifically inviting comment on whether it should be allowed.

Industry groups like ACC and the Plastics Industry Association urged FTC to recognize mass balance in recycled-content claims and said polling shows consumers support advanced recycling, while Greenpeace, Beyond Plastics and others called mass balance "blatantly deceptive to consumers" in their joint submission.

As well, others argue there's a risk to the industry if claims around mass balance are not clearly limited to plastic waste being made back into new plastic products, and instead include material made into fuels.

"It's a risk to the brands to be buying chemical recycled products because, with the stroke of a pen, legislation could change and you're not allowed to mass balance anymore," said Dustin Olson, CEO of recycler PureCycle Technologies Inc., speaking in a recent interview at a different industry event.

Olson said he supports chemical recycling, which uses heat to break chemical bonds in plastics, but he said marketing claims should be clear. PureCycle uses different solvent-based technology to clean and recycle polypropylene.

Governments are still working on details of their mass balance standards and figuring out what is workable to them, said Jan Henke, a director at Cologne, Germany-based International Sustainability and Carbon Certification, which developed the ISCC Plus mass balance certification system for plastics, chemicals, textiles and other materials.

European governments seem to be interested in a stricter mass balance standard than what the United States may adopt, although final decisions have yet to be made, he told the ACC conference.

"I believe that in the U.S., things are, luckily, a little bit more flexible; you are a bit more open still when it comes to mass balance and the free attribution approach, which is more industry-friendly at this point in time, but which definitely makes it easier to scale up," Henke said.

"From my perspective, the European Commission will not go for the strictest one but will find something somewhere in between, which hopefully everyone can still live with, but which is maybe a bit more strict than what everyone still accepts here in the United States," he said.

The U.S. government is considering mass balance standards.

A February 2022 report from the panel at the National Institute of Standards and Technology recommended that Washington develop national standards around mass balance to speed development of plastics recycling.

Rudolf said mass balance standards will be crucial to scaling up chemical recycling of plastics because at least at first, it will be hard to economically justify separate pipes, tanks and other infrastructure just for the pyrolysis oil or other feedstocks from scrap plastic.

"We have to have these mass balance systems to allow that scale-up of existing infrastructure," Rudolf said. "If we don't have mass balance, there's no way to set up a dedicated infrastructure just for these new systems."

He said building separate infrastructure over time for renewable feedstocks would have an advantage for companies. It would allow much stronger environmental marketing claims.

"Typically, [a strong claim] requires a dedicated infrastructure and large investments, and even if we ultimately do want to get to a segregated supply chain, the only way to get there is scale," he said. "The only way to get to scale is mass balance."