The European Commission has opened a public consultation on chemical recycling, specifically related to a proposed update to the implementing decision for the Single-Use Plastics Directive (SUPD).
The draft update includes rules for mass-balance accounting of chemically-recycled content towards the SUPD's recycled content targets, and would allow recyclates produced from non-EU post-consumer waste to count towards EU targets.
The commission is seeking feedback on a proposed fuel use-excluded approach to mass balance accounting. In this, the amount of circular feedstock eligible to be assigned as recycled content to polymers would be calculated by taking the amount fed into a steam cracker and assigning it to one of four output groups — non-fuels, fuels, losses and dual-use outputs — based on the proportion of each that the cracker produces.
Cracker operators could then allocate an amount of recycled content — sometimes termed by market participants as recycled credits — to their products, equal to the amount of eligible feedstock assigned to the non-fuels output group, or to any dual-use outputs that can be provably shown to be retained in the chemical/polymer chain rather than entering the fuels chain.
The draft document also lays out rules for allocating recycled content to cracker feedstock where mass balance accounting is required before the steam cracker stage of the polymer production process, which Argus understands to be a reference to refining or pre-treatment of pyrolysis oil. This would be based on the amount of recycled feedstock input into the refining or pre-treatment plant that evaporates below the maximum feedstock boiling point the intended steam cracker customer can accept, as a ratio to the total amount of material input into the former plant.
The same ratio of recycled content could then be applied to materials supplied to the steam cracker customer.
Basing allocation of recycled content on input before the steam cracker stage, rather than output, would appear to open the door to processing of pyrolysis oil in refineries that produce mainly fuels, without a large proportion of credits being lost to the fuels pool under fuel use-exempt rules. Argus is seeking clarification on this.
In addition to the mass balance rules, the draft extends the definition of post-consumer plastic waste to include that produced from products placed on the market outside the EU. This would align the definition with that used in the recently-adopted Packaging and Packaging Waste Regulation, and mean recyclates based on non-EU waste could count towards the 25pc recycled content for polyethylene terephthalate (PET) beverage bottles contained in the SUPD.
The consultation will run until 19 August.
