NGOs to EU Commission: too much space for ‘cooking the books’ in current proposal for the method to count recycled plastic content

ECOS and Rethink Plastic alliance campaigners send a letter to European Commission and consultancy firm Eunomia asking for limits to ‘artificial’ mass balance accounting method to be used to count recycled plastic content in beverage bottles.

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, the devil is in the detail, and that 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 for over 20 years now.

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 important concerns. 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, expressing their concerns about the dangers of an unlimited use of the ‘mass balance’ approach.

Campaigners point out 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’).

The full letter can be read here.

Notes to editors:

How does the ‘mass balance’ method work?

The ‘mass balance’ method can be explained through an analogy with a cookie factory. A producer mixes a large volume of regular sugar with a small amount of ‘sustainably produced sugar’ to make a number of different products: cakes, cookies, bread, croissants… In truth, only around 5% of the sugar used in the cookies is ‘sustainable’. However, using this methodology, the producer can then artificially claim all the sugar is in the cookies is of the ‘good’ type – selling them as containing ‘100% sustainable sugar’!

A second major problem comes from the inclusion of pre-consumer plastic 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 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.

For more information, please access our recent report for further details and recommendations: ‘Determining recycled content with the ‘mass balance approach’”.

A set of infographics summarising our recommendations for the accounting of recycled plastic content can be seen here.

Fanny Rateau, Programme Manager at ECOS – Environmental Coalition on Standards

‘The EU stood up for the environment when introducing requirements for minimum plastic content in the Single Use Plastics Directive. It would be a pity if it resulted in a greenwashing exercise, with companies being allowed to cook their books thanks to a clear loophole in the small print of an implementing act. Fighting the environmental crisis will require real action – creative accounting will not help’.

Press contacts:

Fanny Rateau, Programme Manager at ECOS – [email protected] [KK1] 

Ivo Cabral, Press & Communications Manager at ECOS – [email protected]