16 December 2020

100% recycled? Only truthful claims will get people to trust recycled plastics

The European Commission is developing a new method to calculate, verify and report on the share of recycled content in plastic products. If not done carefully, it could lead to massive greenwashing by manufacturers. We spell out the two main pitfalls EU officials must watch out for - and how to avoid them.

10 million tonnes of recycled plastics reused per year by 2025: this is the target the industry has set for itself in the wake of the 2018 European Plastics Strategy[1]. This means 2.5 times more than 2016 levels. For this to happen, the Single Use Plastics Directive (‘SUP Directive’) sets minimum levels of recycled content for new plastic beverage bottles.

The European Commission will now decide how recycled content should be counted and traced down through the supply chain. A proposal is expected by 1 January 2022. Once adopted, this calculation method could be used in other sectors, such as batteries, packaging, construction products and vehicles.

This new method will determine how to calculate the figures on recycled plastic claims people find on millions of beverage bottles sold across the continent – such claims have the power to draw consumers towards more sustainable alternatives even when virgin plastic packaging is often cheaper. However, this method will only be effective if the EU avoids a number of caveats from some industry players to artificially swell the numbers.

‘Pre-‘ or ‘post-consumer’ waste – we mustn’t count industrial plastic waste

The European Commission must clearly state that the term ‘plastic waste’ only includes plastics which passed through the hands of consumers (or ‘post-consumer waste’) – leaving all industrial plastic waste out of the calculation.

The SUP Directive revolves around so-called ‘post-consumer’ plastic waste, i.e. bottles already placed on the EU market and discarded after a single use. Legislation aims to support the proper collection and sorting of plastic waste and prevent recyclable plastics from ending up in landfills.

Well-known international brands like Coca-Cola, Danone, Nestlé and PepsiCo have committed to switch some of their plastic bottles to 100% recycled content by 2025. This could definitely help EU member states meet the targets SUP Directive: at least 25% in PET beverage bottles as of 2025, and 30% recycled plastic in all listed beverage bottles as of 2030.

However, most plastic ‘waste’ collected by recyclers in Europe comes from industrial sources. This so-called ‘pre-consumer’ waste, or ‘post-industrial’ waste, includes all plastic material discarded during manufacturing processes. Some examples are defective bottles and stocks of previous models no longer on the market. These waste streams should be collected and recycled but should not count towards the EU target. If they do, they will create the perverse effect of incentivising the production of such industrial waste.

To remain in line with EU law, this calculation principle should also apply to other key products for which similar rules are to be proposed soon by the European Commission: packaging, construction materials and vehicles, including their batteries. It should also be at the core of the Commission’s EU-wide pledging campaign for the uptake of recycled plastics and the work of the Circular Plastics Alliance.

Separating the wheat from the chaff – tracking the life of plastic recyclates

Plastic recyclates must be tracked down the supply chain to avoid deceptive claims. Labels telling consumers that a product ‘contains 100% of recycled plastic’ must be verified before they reach the market.

But how to make the plastic recyclates truly traceable? Only a batch level mass balance method allows to continuously know the proportion of recycled material fed into the process, at the batch level. This can ensure a good estimate of the actual recycled content contained in final products placed on the market.

As a general rule, when both virgin and secondary raw materials have to be integrated into the production process, this system is easier to check, more credible, and more transparent towards consumers than other ‘creative accounting’ methods. And the latter, unfortunately, have been put forward by industry. The most recent one would allow manufacturers to allocate recycled material to a site other than the one actually producing the product in question, in another country even, not connected in any way to the supply chain (the so-called ‘multi-site’ mass balance). This method allows ‘recycled content credits’ to be transferred between sites, resulting in the physical flow of secondary raw materials being completely disconnected from its ‘paper trail’.

When following the trace of recycled plastics, the devil is in the detail: claims on plastic recyclates, for example, should only replace their own part or share of the product. For instance, for a product made of 50% wood, and 50% plastic, claims on the share of recycled plastic content must only go up to 50%.

We call on the European Commission to:

  1. Not include industrial plastic waste in the calculation on the share of recycled plastic content – only post-consumer plastics must be counted.
  2. Introduce a batch level mass balance method to track the proportion of plastic recyclates in products.

Only this way will claims on the recycled content of plastics be transparent and reliable. This will, in turn, significantly increase the trust and uptake of recycled plastics, driving millions of consumers to choose more sustainable solutions.

Follow ECOS for further detailed explanations on mass balance in an upcoming position paper.


[1] Set as a follow-up of the EU 2018 Plastics Strategy that showed the potential for plastic recyclates was untapped, especially as compared to paper, glass or metal as recycled plastics only accounted for about 6% of plastics demand in Europe.

ECOS is co-funded by the European Commission and EFTA

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