Some uncertainty remains over the correct interpretation of the draft of rules governing the inclusion of chemically-recycled plastics towards EU recycled content targets, BlueAlp chief executive Valentijn De Neve told Argus, but he said that an initial reading threw up some encouraging signs and some concerns.
The European Commission opened a public consultation on a draft update of the implementing decision for the Single-Use Plastic Directive (SUPD) — which would provide details on how the 25pc recycled content requirement for PET beverage bottles can be met — on 8 July. It includes proposed rules around the use of mass-balance accounting to allocate chemically-recycled content. It is seen by many in the industry as a likely precedent for the rules that will apply to the EU's Packaging and Packaging Waste Regulation (PPWR), which will become the primary legislation governing recycled content targets for plastic packaging from 2030.
De Neve said that he is still looking to understand the full connotations of the draft document put forward by the commission. At first reading he is encouraged that it appears to open up the possibility of plastic-derived pyrolysis oil (PPO) being processed in existing assets — refineries — as well as on-purpose upgrading facilities.
This is "key in getting [the PPO market] to a realistic and larger market, and to fulfil the sustainability criteria that we've jointly set", he said.
De Neve expressed some possible reservations on whether recognition of what share of input "really translates into circular plastics versus what becomes fuel" when the supply chain includes a refinery step has been "sufficiently captured" in the draft. But he said that he would discuss this within the Chemical Recycling Europe industry association, which would co-ordinate a response to the consultation.
De Neve also said that the proposed extension of the definition of post-consumer plastic waste to include waste from products placed in non-EU markets — which would enable recyclates based on non-EU waste to count towards the recycled content targets — risks attracting import pressure from producers in lower-cost regions without sufficient additional controls.
"We need to make sure… whether you're operating inside or outside the EU, that the same rules apply and it's a level playing field", he said.
PPWR contains a so-called "mirror clause" stating that recyclers from outside the EU should be held to the same environmental standards as domestic operators. But no such clause exists in the SUPD, or elsewhere in the draft implementing decision released under consultation.
