29 October 2021

Cooking the plastic books: EU must avoid opening the door to widespread use of creative accounting in recycled plastic content

By Fanny Rateau

ECOS and the Rethink Plastic alliance ask the EU Commission and its consultants to set limits to the use of the ‘mass balance’ method when measuring recycled content in plastic products.

 New requirements for minimum recycled content rates in plastic products will enter into force in the coming years as part of the EU Single Use Plastic (SUP) Directive 2019/904.

PET bottles, for example, will have recycled content thresholds. As of 2025, all PET beverage bottles allowed on the EU market will need to have a minimum amount of 25% recycled content. By 2030, the bar will rise to 30%.

However, small details will determine whether such requirements will result in a true breakthrough. Methods to calculate the rate of recycled content will be essential for that. In fact, the European Commission has been looking into ways of calculating, verifying and reporting recycled content from beverage bottles since 2020.

In support of the Commission, the consulting firm Eunomia has been undertaking the technical preparatory work supporting the requirements set in the SUP Directive.

The latest proposal by Eunomia has raised the alarms. At a workshop held on 12 October, consultants suggested that companies would be free to allocate their recycled plastic content inputs to any production outputs from chemical recycling processes, such as bottles. Only fuels are left out of this system.

The ‘mass balance’ approach is an accounting method that would allow companies to claim artificially swollen rates of recycled content to products of their choosing – especially those for which the EU will require minimum levels of recycled content.

On 26 October, ECOS and the Rethink Plastic alliance sent a letter to European Commission’s DG ENV, the Joint Research Centre, and consultancy firm Eunomia, raising their concerns about the dangers that an unlimited use of the ‘mass balance’ approach.

Instead, campaigners say that recycled plastic calculation, and associated claims, should be based on proportional allocations, should discount process efficiency losses and consider only recycled materials that have passed through the hands of consumers (technically called ‘post-consumer plastic waste’).


A massively unbalanced accounting method

This ‘mass balance’ method can be explained through an analogy with a cookie factory. This producer mixes regular sugar with some ‘sustainably produced sugar’ to make cakes, cookies, bread, and croissants. In truth, only around 5% of the sugar used in the cookies is ‘sustainable’. However, the producer can artificially allocate all the good sugar to the cookies only – selling them as containing ‘100% sustainable sugar’!

A second major problem comes from the inclusion of pre-consumer plastics waste in the accounting method for recycled content. This has a perverse effect as it gives incentives to wasteful and inefficient production processes, since waste plastics can then be considered as recycled even if they have never reached consumers. Instead, the EU methodology should target recyclates from post-consumer plastic waste only, in line with the EU circular economy policies.

Setting this methodology right today is all the more important since the European Commission will use it as a base for setting new European recycled content requirements in other sectors, such as packaging, construction products, vehicles and batteries.

The full letter can be read here.

ECOS is co-funded by the European Commission and EFTA

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