NGOs warn “loose” EU SUPD recycled plastic calculation method could lead to “massive greenwashing”

05 Nov 2021 --- Rethink Plastic and the Environmental Coalition on Standards (ECOS) are advocating for stricter accounting systems to calculate recycled plastic content in beverage bottles to avoid potential greenwashing.

In a letter sent to Eunomia last week, the two organizations expressed concerns that the consultancy firm’s alleged suggestions to allow companies to freely allocate recycled content to their production outputs could undermine circularity goals.

New recycled content requirements are entering into force as part of the EU Single Use Plastics Directive (SUPD). As of 2025, all PET beverage bottles sold on the EU market must have a minimum of 25% recycled content. By 2030, the bar will rise to 30%.

According to Rethink Plastic, it will be crucial to finetune these legislative details, as these rules will form the backbone of the upcoming mandatory requirements on recycled plastic content and plastic waste reduction measures throughout Europe.

Responding to the criticism, a Eunomia spokesperson tells PackagingInsights: “This is an ongoing project and our role is to lay out some of the potential options for the [European] Commission to consider in the development of the SUPD implementing act.” 

“It wouldn’t be appropriate to respond to speculation about the outcome in advance of our research being completed.” 

Cooking the books?
Rethink Plastic and ECOS allege Eunomia consultants have suggested companies would “be free” to allocate their recycled plastic content inputs to any production outputs from chemical recycling processes, such as bottles. Only fuels would be left out of this system.

“Such a loose accounting system would mean a blank check for plastic producers to allocate all their recycled content to a few products to be promoted as 100% recycled – even though in truth they contain only very small fractions of actual recycled content,” Fanny Rateau, program manager at ECOS, tells PackagingInsights.

“That is what we call ‘cooking the books.’ The system should zoom in to the ‘batch level’ so claims on recycled content are closer to reality, avoiding potentially massive greenwashing.”

Rethink Plastic compares the mass balance method to baking a cake (Image credit: Rethink Plastic).Setting a legal precedent
The mass balance approach is a set of rules determining the use of recycled content in products, such as plastic packaging, allowing manufacturers to market products as “recycled.”

The mass balance approach is already well-established for ensuring “sustainably harvested wood” in furniture, or “organic cotton” in textiles. 

“If the rules for mass balance are developed too loosely, this method could become a major tool for greenwashing and would allow companies to claim and market products as made from recycled materials regardless of their true content,” underscores Rethink Plastic.

“Ultimately, this could block incentives to improve plastic recyclability and increase the amount of recycled content in products, while harming the credibility of the recycling industry.”

If the mass balance approach is employed to manage supply chains where recycled feedstock, such as plastic, is mixed with virgin fossil feedstock to manufacture products, Rethink Plastic and ECOS recommend:

• Aiming for the highest possible amount of recycled content.
• Prohibiting recycled content trade as part of a credit system.
• Ensuring strong physical and chemical traceability of recycled content.
• Accounting for the full life-cycle of products in the chain of custody model.

The advent of chemical recycling
The concept of “chemical recycling” will be key to understanding the future of plastics recycling, according to Rateau. Chemical recycling converts used plastics back into monomers, then transformers them into fuel or feedstock for the petrochemical industry, sometimes for producing new plastic. 

Rethink Plastic maintains key chemical recycling players are calling for a mass balance method allowing for “very flexible rules,” such as a liberal allocation of recycled feedstock to the chosen final product, regardless of its true content. 

Meanwhile, Rabobank has documented huge investment in advanced recycling globally, estimating the number of plants will more than double by 2025.

“The catch is chemical recycling is a polluting and inefficient process. That is why, together with the Rethink Plastic Alliance, we ask policymakers to set strict eligibility criteria for plastic waste used for ‘chemical recycling’ to avoid competition with mechanical recycling feedstock,” says Rateau. 

“No mechanically recyclable waste input, such as PET beverage bottles, should be allowed to be fed as input materials in chemical recycling.” 

While Eunomia acts as a consultancy group, the European Commission is ultimately the sole drafter of EU legislation.Post-consumer only
ECOS and Rethink Plastic claim Eunomia proposes including pre-consumer plastic waste in the accounting method for recycled content. “We believe the methodology should instead target recyclates from post-consumer plastic waste only,” the duo state in the letter. 

“[Pre-consumer plastic waste] would have a perverse effect as it gives incentives to wasteful and inefficient production processes, since waste plastics can then be considered as recycled even if they have never reached consumers.” 

“If you need to reach a target, maybe it is easier to artificially create more scrap plastic in the production process, so then it can be reused and counted toward recycling targets. The only plastic that should count toward EU goals is that which has gone through consumers´ hands,” argues Rateau.

Issues abound
Just this week, the trade association European Plastics Converters flagged some EU member states are failing to uniformly implement the SUPD and “undermining the integrity of the single market.”

Earlier issues centered on concerns over the SUPD’s definitions of “plastics.” In January, Symphony Environmental Technologies took legal action against the EU over the definition of “oxo-biodegradable.” 

More recently, BFG Packaging questioned the definition of “expanded polystyrene” while Sulapac scrutinized what constitutes “chemically modified polymers.”

By Anni Schleicher