Werner Bosmans, team leader on plastics and DG Environment at the European Commission said at the opening of the Plastics Recycling Show Europe that most member states in the European Union favor a mass balance approach in recycling.
PRSE kicked off June 19 in Amsterdam. It is the world's largest recycling show.
Bosmans took advantage of his slot to discuss the "burning issues" around EU plastic policy, including the adoption of mass balance for recycled content in single-use plastic bottles.
In February, the EC discussed a draft document that recognizes mass balance accounting as a way to calculate the weight of recycled plastic. If approved, it could prove transformational for the chemical recycling industry.
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 percent recycled PET by 2025, and of 30 percent 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 recognizes 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.” he said.
Bosmans further said the view of commission members 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 favor 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 companies 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 recognizing mass balance is essential for allocating recycled content via this chemical recycling technology.
The draft document under discussion recognizes 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.