Instead, they urge the EC to establish a transparent, ambitious, and circular ‘chain of custody’ method. Signed by several civil society organisations 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’. 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’.
The joint letter recommends that 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 towards 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 last week by Zero Waste Europe, ECOS, and the Rethink Plastic alliance (RPa).
Shanar Tabrizi, Chemical Recycling and Plastic to Fuel Officer at Zero Waste Europe, said: “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. What we call for is plastic transparency, fair and square.”
Mathilde Crépy, Senior Programme Manager at ECOS, said: “The Single-Use Plastic Directive 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. 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.”
