Zero Waste Europe and ECOS tell EU “mass balance approach” is damaging plastics circular economy

18 Feb 2021 --- Zero Waste Europe (ZWE), the European Environmental Citizen’s Organisation for Standardisation (ECOS), and nine other organizations are urging the European Commission (EC) to avoid a flexible “mass balance approach” method in determining recycled content in plastic products. 

The signatories delivered a joint letter yesterday evening to the EC advising it to establish a “transparent, ambitious, and circular ‘chain of custody’” method instead.

Signed by several civil society organizations and recycling industry members, the letter is a “direct objection” to the recent calls of key industry players, including chemical recycling actors, for a “mass balance approach,” ZWE explains.

“This method could allow for the liberal allocation of recycled feedstock to the final product of their choosing, regardless of its true content.”

“In practice, a plastic product could be sold as ‘fully recycled’ while containing only very small fractions of actual recycled content under the ‘mass balance approach.’”

According to the Ellen MacArthur Foundation’s Mass Balance White Paper, “mass balance accounting” is designed to trace the flow of materials through a complex value chain. The mass balance approach provides a set of rules for allocating recycled content to different products to claim and market the content as “recycled-based.”

Criteria to avoid greenwashing
The joint letter recommends the EC base its method on ten specific criteria to avoid greenwashing practices and regulate how recycled content is determined, guaranteeing a circular chain of custody:

• Aim for the highest possible amount of recycled content and segregate recycled feedstock from virgin feedstock in the supply chain.
• Use “batch level” mass balance to determine recycled content when segregation is not feasible.
• Do not allow for the trading of recycled content as part of a credit system.
• Evenly allocate the recycled content to output products where mass balance is used.
• Ensure strong physical and chemical traceability of recycled content.
• Avoid converting recycled content into theoretical “currencies.”
• When determining recycled content, only include post-consumer waste and not pre-consumer waste.
• Set strict eligibility criteria for plastic waste used for “chemical recycling.”
• Account for the full life cycle of products in the chain of custody model.
• Ensure full transparency toward consumers.

These criteria are further explained in the “Determining recycled content with the ‘mass balance approach’ – 10 recommendations for development of methods and standards” joint policy briefing, published in February by ZWE, ECOS, and the Rethink Plastic alliance.

Ensuring recycling transparency
The EU is targeting a minimum packaging recycling rate by weight of 65 percent by the end of 2025 and 70 percent by 2030. Moreover, the EU Plastics Strategy requires all packaging to be recyclable in an economically viable way by 2030.

The signatories’ letter is a “direct objection” to the recent calls for a “mass balance approach” to recycled plastics transparency.Meanwhile, the EU’s SUPD requires at least 25 percent recycled plastic in PET bottles by 2025 and 30 percent in all beverage bottles from 2030. Its recently introduced plastics tax also imposes a €0.80/kg (US$0.97/kg) levy on non-recycled plastic packaging waste.

“The EU targets for recycled content could be a huge driver for recycling – that is, unless we introduce loose methods for reporting the share of recycled content in plastics which remove such incentives, mislead consumers and risk damaging the credibility of the recycling industry,” comments Shanar Tabrizi, chemical recycling and plastic to fuel officer at ZWE.

“What we call for is plastic transparency, fair and square.”

Toward this end, the EC awarded blockchain transparency platform Circularise a €1.5 million (US$1.2 million) grant in 2020. Blockchain technology can be particularly effective in monitoring Extended Producer Responsibility (EPR) schemes.

“The Single-Use Plastic Directive (SUPD) was a true breakthrough for environmental policy. But with the ‘mass balance approach,’ we open the door to the creative accounting of recycled plastic content,” adds Mathilde Crépy, senior programme manager at ECOS.

“If we allow manufacturers to play with the numbers in their recycled content claims, our planet will suffer the consequence. We can’t afford it being watered down by a flexible chain of custody allowing for creative accounting of recycled content.”

The European Parliament recently voted in favor of the EC’s Circular Economy Action Plan, demonstrating support for permanent materials, recyclable without loss of quality.

By Joshua Poole