Zero Waste Europe urges policymakers to regulate chemical recycling with proportional allocation

12 May 2023 --- Zero Waste Europe (ZWE) has published a study examining the consequences of different approaches to allocating recycled content in plastic. The study finds that proportional allocation has the greatest potential for measuring environmental impact. 

National and European policymakers should implement regulation ensuring that mechanical methods remain the primary recycling option for maximum CO2 reduction and circularity score, stresses ZWE’s Chemical Recycling and Plastic-to-Fuels policy officer Lauriane Veillard. 

PackagingInsights discusses the report findings and its possible policy and industry implementations with Veillard. 

“The aim of introducing recycled content in the EU legislation is to foster the shift toward a more circular and sustainable society. Current developments are made to build trust, reflect reality and achieve real sustainability. Therefore, any environmental claims should be transparent and trustworthy,” says Veillard.

“This is an obligation we have toward consumers, but also to highlight differences between inherent recyclability potential of different materials,” she adds.

The study finds that recycled content claims based on proportional allocation lead to greater transparency in the plastic recycling market.Maximizing recycling rates
Launched and presented during a Zero Waste Live! Webinar installment, the “Impacts of allocation rules on chemical recycling – Consequences on the environment and maximum circularity of plastics” study calculated the impact of the different allocation rules regarding the environment, material circularity and level-playing field in the recycling landscape.

The study finds that recycled content claims based on proportional allocation lead to greater transparency in the plastic recycling market, as it reduces ambiguity about recycled content in plastic outputs. 

“It acts as a tool to ensure complementarity between different recycling pathways and reduces the risk of scenarios where long-loop chemical recycling dominates,” explains Veillard.

“If the European Commission (EC) chooses a method for recycled content based on a polymers-only or a fuel-exempt allocation model, a cap on thermo-chemical technologies (pyrolysis and gasification) may be necessary to prevent it from outcompeting mechanical recycling. The cap suggested in the study is 12.5-25% on chemical recovery, as proposed in the Dutch Transition Agenda,” she asserts.

Furthermore, the study finds that in the recycling landscape, a larger share of thermo-chemical technologies results in lower environmental benefits and reduced maximum recycling rates.

Capping pyrolysis and gasification 
When the methodology defining recycled content based is on a polymers-only or a fuel-exempt allocation model, policymakers should consider introducing a cap on pyrolysis and gasification to prevent multi-outputs technologies, i.e., pyrolysis and gasification, from outcompeting and overtaking mechanical recycling, stresses Veillard.

Veillard recommends claims made at the product level should be based on an assessment done at each batch, where mixing of input occurs. “Any claims at the product level shall be done at the batch-level level to ensure transparency and traceability along the value chain.”

“When considering the use of mass-balance chain of custody to assess recycled content from multi-output technologies, the allocation shall be proportional (instead of arbitrarily allocating recycled content),” she adds.

For the packaging industry, Veillard recommends any claims made at the product level should be based on an assessment done at each batch, where mixing of input occurs. The final mix shall be allocated proportionally to all outputs, “otherwise, any of these claims would lead to greenwashing practices and undermine consumers’ trust in environmental claims.”

“A larger share of thermo-chemical technologies results in lower environmental benefits and reduced maximum recycling rates,” continues Veillard.

EC recommendations 
ZWE urges the EC to consider the study’s findings on allocation rules and recycled content targets for plastics in their upcoming files. The European network calls on the EC to use “batch level” mass balance (instead of allocating it arbitrarily) to determine recycled content so it is clear how much recycled material is in the final product.

It also suggests the EC should consider capping chemical recovery to avoid overtaking mechanical recycling if polymers-only or fuel-exempt models are used and implement regulation to ensure that mechanical remains the primary recycling option for maximum CO2 reduction and circularity score.

“We see a lot of emphasis on improving the end-of-life treatment of plastic. However, to ensure a scaling-up of an efficient recycling system, changes should also happen at the production phase with an effective design for recycling. Study says that around 80% of GHG related to end-of-life treatment of plastic could be avoided with a right design in the first place,” concludes Veillard. 

By Natalie Schwertheim

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