ChemRecEurope also welcomes the recognition from ZWE that the plastic to plastic (P2P) process counts as ‘Recycling’ according to the EU definition of ‘Recycling’.
Although ChemRecEurope agrees that the environmental impact plays an important role, we regret the suggested hierarchy set between mechanical recycling and chemical recycling given that it is in the same way a recycling process, not competing but instead targeting different plastics (easier-to-recycle vs more difficult-to-recycle) and creating a different output. We therefore support a non-differentiation between the two recycling methods.
On the other hand, we believe that some competitiveness is key for innovation and technology growth. Building barriers and promoting anti-competitive practices would neither necessarily help maturing chemical recycling nor improving current mechanical recycling processes.
We urge policymakers, the value-chain, and NGOs to agree on a definition for chemical recycling to lift further confusion. Our goal is to educate, communicate, and clarify.
ChemRecEurope understands and supports the aim of ZWE to prioritize reduce, reuse, and re-design, along the principle of the EU waste hierarchy. We however highlight that funding and investments also need to go towards new recycling innovations that also aim at reducing pollution, improving waste management, and increasing recycling and recycled content when the three previous options were not possible in the first place, and/or when plastics have already been created.
While developing a legislative support to P2P is a welcomed step, we disagree with the direct association of plastic to fuel (P2F) with incineration. Although being a less preferable option, P2F has some benefits compared to incineration that should not be discarded including its lower environmental
impact, its reduction in oil extraction, as well as the transformation of waste into a valuable resource and the fact that it does not burn the plastic waste/resource. In addition, with chemical recycling, fossil resources for high value-added chemical production can be replaced with recycled material from plastic waste.
We are committed to provide, as soon as the development of the industry enables us, an LCA to ensure that the chemical recycling process creates a value for the environment. We, in addition, commit to improving energy efficiency of the technologies. Given the industry infancy, the LCA opinion should account for the gradual improvement of the technologies.
