Recycled Plastic Content - Workshop covering the general methodology and application to various sectors - Amaplast
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Recycled Plastic Content Workshop covering the general methodology and application to various sectors. 14th September 2021
Workshop Agenda
Morning Session (CET) Afternoon Session (CET)
11:00 Welcome and speaker introductions 14:00 Packaging followed by Q&A
11:05 Introduction from the Commission 14:30 Construction followed by Q&A
11:10 Introduction to formula and definitions 14:55 Automotive followed by Q&A
Measurement point calculations followed
11:25 15:20 EEE followed by Q&A
by Q&A
Specific Aspects: moisture, additives, 15:45 Ecolabel and GPP followed by Q&A
11:55 contaminants, food contact, biobased and
compostable plastics followed by Q&A 16:05 Conclusions and next steps
Chain of custody and verification followed 16:10 Conclusions from the Commission
12:30
by Q&A
16:15 Workshop close
13:00 Break for lunch
Welcome
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ID: 155-688-369
Workshop Aims
1. Presenting the general methodology for the calculation, verification
and reporting of the recycled plastic content in products
2. Identifying how the specific elements of this general method may be
adapted and what sector specific obstacles may exist in developing
mandatory recycled plastic content obligations in key sectors and
policy areas, these being:
• Packaging
• Construction
• Electronics
• Automotive
• Ecolabel / green public procurement (GPP) product policies
Recycled Plastic Content - Formula and Definitions
Formula Losses in numerator (that do
not make their way into the
final product) must be
Percentage by mass*: accounted for
Percentage mass of recycled plastic used for the product
of recycled
= X 100
plastic in total mass of final product or total mass of
product plastic in final product
Non-plastic elements in final product
*Based on formula for the calculation of recycled
content presented in section 6 of EN 15343:2007 and
section 7.8.4.1 in ISO 14021:201
Formula Recommendations • Use of a percentage by mass formula is suitable • Any material that does not make its way into the final product (e.g. production losses) must be deducted from the numerator to ensure comparability with the denominator • The scope of the denominator must be clear (e.g. plastic elements only or entire product/ product group)
Definition of Recycled Plastic Content
Percentage by mass*:
Percentage mass of recycled plastic used for the product
of recycled
= X 100
plastic in total mass of final product or total mass of
product plastic in final product
*Based on formula for the calculation of recycled content
presented in section 6 of EN 15343:2007 and section 7.8.4.1 in
ISO 14021:201
Definition of Recycled Plastic Content
Three interpretations:
• Plastic input material that is subsequently recycled into plastic
• Any material (plastic or non-plastic) that is recycled into
plastic
• Plastic input material that is recycled into any output
material (plastic or non-plastic)
Depends on the legislation that is introducing the recycled content target
Definition of Plastic
SUP Directive Article (3)1:
“…a material consisting of a polymer as defined in point
5 of Article 3 of Regulation (EC) No 1907/2006, to which
additives or other substances may have been added,
and which can function as a main structural
component of final products, with the exception of
natural polymers that have not been chemically
modified”Definition of Recycled WFD Article 3(17) & Article 5: • It must have been a waste (excludes by-products of the production process) • It must have entered a recycling operation (by which waste materials are reprocessed into products, materials or substances whether for the original or other purposes, not be used as a fuel, for energy or for backfilling operations)
Definition of Recycled Plastic Content
Recommendations
• Key criteria for defining “recycled plastic content”:
• Source material must have been classified as waste (excludes by-products)
• Source material must have entered a recycling operation (excludes recovery
and fuel products)
• Either or both the source material and outputs must be plastic (as per
associated legislation)Measurement Point Calculations
Calculation Point • At which the proportion of recycled plastic content (by mass) in a product can be estimated, based on the wording/ intent of the relevant legislation • Scope of products • Point in supply chain • Physical/ location point
Measurement Point • At present there are no reliable technologies for an analytical determination of the recycled content in a material or product (CEN)* *EN 15343, [CEN 15343, 2007], Plastics - Recycled plastics - Plastics recycling traceability and assessment of conformity and recycled content.
Measurement Point - Denominator
Recommendations
• Point which most clearly reflects the requirements of the legislation
• Inputs to conversion process?
• Outputs of specific conversion processes?
• Final products placed on the market?Denominator Measurement Point Example, SUP Bottles:
Placed on the market 4Measurement Point - Numerator
Recommendations
• Prior to input into final conversion process or at the point in which recycled
plastic is mixed with virgin plastic; whichever comes first
• Proportion of recycled plastics in compounds/ masterbatch
• When secondary plastic materials are of sufficient quality to undergo conversion
comparable to the processing of primary materials
• Outputs of previous steps (e.g., output of a recycling process) may be used as
proxy so long as any subsequent losses prior to conversion are deductedMeasurement Point - Numerator Example, SUP Bottles:
Q&A on Formula,
Definitions and
Measurement
Points
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155-688-369Specific Aspects of a Recycled Plastic Content Calculation Methodology
Pre/ Post Consumer Waste
Recommendations
• Pre/ post consumer waste are not terms defined in EU law – no basis for exclusions at present
• EU law does make distinction between waste and by-product (production residues may be
either of these) – this must be accounted for
• Should exclusions be necessary on the basis of the source of waste, this needs to be clearly
defined in legislation
• In these cases, the calculation rules would need to provide further product-specific guidance
on which materials are classified as within and out of scope of “recycled plastic” in the
numerator.
Image: https://jacandsharpholdings.net/product/pet-flakes/Additives and Fillers • Widely used in varying proportions for different polymers and products • The exclusion of these additives and fillers from the numerator of the calculation will need to be supported by the definitions of recycled plastic and plastic within the relevant legislation
Additives recycled within plastic waste
Recommendations
Additives and fillers within the
polymer matrix of plastic
waste that is recycled into
plastic products, can be
counted as recycled plastic
(therefore included in both the
numerator and denominator).
Image: https://jacandsharpholdings.net/product/pet-flakes/Virgin additives in recycled plastics
Recommendation
Additives and fillers
produced from virgin
material and input to plastic
products, (including in the
form of masterbatch/
compounds) shall not be
counted as recycled plastic
(therefore included in the
denominator only).
Image: http://oxygreenplastics.com/blogs/advantages-of-plastic-additives-to-the-plastic-industry-part-1/Other considerations…
Additives recycled from plastic waste
Additives and fillers which have been
extracted from the polymer matrix of
plastic waste and are subsequently
recycled into plastic products (noting that
this is currently a theoretical discussion
and instances of this are very limited, this
may be subject to further revision if
technology develops so that their use
increases).
Recycled additives from non-plastic waste
Additives and fillers which have
themselves been recycled from non-
plastic waste and are subsequently input
Image: https://www.reade.com/products/metal-alloy-non-metallic-minerals-ceramic-composite-polymer-powder-sheet-foil-rod-
natural-fiber-metal-fiber-nanowire-nanoparticle-nanotube-coatings-aerogel-metal-foam-ceramic-foam-enzymes-magnetic-
to plastic products
conductive-abrasives-additives/abrasives-powders-inorganic-grit-media/glass-abrasive-powder-recycledMoisture Content
Recommendations
• Numerator/ denominator should be
comparable
• Moisture that ends up in the product (based
on accepted tolerance levels for conversion
process) is inherent and should not be
deducted
• Need for case by case approach to
deductions
• Where moisture is very lowImpurities and Contaminants
Recommendations
• Legislation must clarify what contamination
is
• Contamination that ends up in the product
(based on accepted tolerance levels for
conversion process) is inherent and should
not be deducted
• Need for case by case approach to
deductions
• Where contamination is very lowBiobased Plastics
Recommendations
• It is important when determining recycled
content targets and calculations for a
particular product group, that
consideration should be given to whether
recycled content is allowed to come from
sources other than plastic waste.
• Specific recycled content targets for
product groups should consider the
benefits of novel bio-based plastics and
their relative maturity to determine
whether a short-term exemption is
necessary to prevent the suppression of
such technologies.Biodegradable and Compostable
Plastics
Recommendations
• Compostable products are designed to be
single use and put on a one-way trip, they are
therefore unlikely to contain any recycled
content of their own (excepting PLA, which can
be both mechanically recycled or composted).
• Compostable plastics are still considered to be
plastics and are therefore subject to the same
requirements.
• Exemption might also be considered from the
product perspective on a case-by-case basis
for products that confer benefits such as
reducing plastic contamination in organic
waste (e.g. biowaste bags).Q&A on Specific
Aspects
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155-688-369Chain of Custody and Verification
Chain of Custody (CoC) According to ISO 22095
Traceability, strength of claim, physical
presence
Segregation Controlled Blending Mass Balance
Unknown proportions
Known proportions
C C
C C
No physical separation of material means no guarantee
Physical separation of material to ensure that recycled content is physically present in the output
of recycled content physically present in the output
Recycled Virgin Mixed C CertifiedNon-Mechanical Recycling – Application of Mass Balance
Physical Chemical
CoC Mechanical Dissolution Hydrolysis Pyrolysis
Segregation Partly Partly Partly
Controlled Blending
Mass BalanceMass Balance System Boundaries
Traceability, strength of claim, physical
presence
Practicality, business case
Rolling Average Credit Method Restricted Credit
Transfers*
Actual Sold
Actual/ Credit Actual Sold
Sold
10
10 10/90 85 15
10 10
90
10/90
10/90 Linked
5
90 5/95 100
90 90
95
Credit Transferred
* Restricted Credit Transfers are not defined in ISO 22095Allocation
Traceability, strength of claim, physical
presence
Practicality, business
case
Proportional Free
Product 1
10 9 1 Product 1 10 10 (100% rc)
(10% rc)
10 10
Product 2 36 Product 2
40 36 4 40
(10% rc) (0% rc)
90 90 Product 3
50 45 5 Product 3 50 45
(10% rc) (0% rc)Allocation - Fuels Exempt
Recycling definition in the Waste
Framework Directive (WFD) Art 3(17):
Product 1
“… does not include energy 10 5 5 (50% rc)
10
recovery and the 40
Product 2
40
reprocessing into materials (0% rc)
that are to be used as 90
50 45 5
Product 3 - fuel
(0% rc)
fuels…”
Clarity needed on interpretation of “recycling
operation” and “preliminary treatment”
Care is needed to makes sure recycled content = recycling“Mass Balance” in Existing EU Law
2019/665* Art 6c 1(i)
“Where packaging waste materials enter recovery operations whereby those materials
are not principally used either as a fuel or other means to generate energy, or for
material recovery, but result in output that includes recycled materials, fuels or
backfilling materials in significant proportions, the amount of recycled waste shall be
determined by a mass balance approach which results in taking account only of
waste materials that are subject to recycling.”
• Not to be confused with CoC Mass Balance where ‘balancing’ happens to a
product, not a waste.
• “mass balance” is not further defined
*amending Decision 2005/270/EC establishing the formats relating to the database system pursuant to European Parliament and Council Directive 94/62/EC on
packaging and packaging wasteRecommendations
• In accordance with ISO 22095 (Chain of custody — General terminology and models), the following chain
of custody models relevant to recycling are presented in order of preference:
• Segregated
• Controlled blending
• Mass balance
• These form a hierarchy that can be applied to recycled content targets and provides a flexible
framework that can be applied differently depending upon the desired outcome.
• Mass balancing requires further rules in order to implement – the variability of these rules is a balance
between transparency and freedom of business practices
• A free allocation approach results in recycled content in fuels being allocated to plastic products,
which runs counter to the WFD, but further clarity is required.
• Some thermal depolymerisation technologies may require the ability to use multi-site restricted
credit transfers (RCT) to be able to aggregate recycled content. However, there are credibility issues
with this approach.
• Creating several definitions and methods of mass balance calculations/system boundaries could
create confusion and complexity.
• Care must be taken to be consistent with existing definitions of recycling.
• Third party verification and direct auditing of self-declarations is an important aspect to maintain
credibility.Q&A Session on
Chain of Custody
and Verification
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155-688-369Break for lunch – see you back here at 14:00 CET
Afternoon Session (CET)
14:00 Packaging followed by Q&A Reminder that Q&A
today is via
14:30 Construction followed by Q&A
14:55 Automotive followed by Q&A
15:20 EEE followed by Q&A
15:45 Ecolabel and GPP followed by Q&A
Join at:
16:05 Conclusions and next steps vevox.app
16:10 Conclusions from the Commission ID:
155-688-369
16:15 Workshop closeAdaptability of General Method for Other Products/Sectors
Packaging
Current Recycled Content Targets • Only targets for RC in packaging set at EU level are those in the SUPD for SUP beverage bottles • The Commission is assessing the feasibility of recycled content targets for other types of packaging in the future
Formula
Percentage by mass:
Percentage mass of recycled plastic used for the product
of recycled
= X 100
plastic in total mass of final product or total mass of
product plastic in final productFormula
Percentage by mass:
Percentage mass of recycled plastic used for the product
of recycled
= X 100
plastic in total mass of final product or total mass of
product plastic in final productNumerator / Denominator
• Broad product category
• “plastic packaging”
• Polymer level
• “all plastic packaging items made of PP”
• Specific plastic packaging format
• “SUP beverage bottles” or “flexible food packaging films”Formula
Percentage by mass:
Percentage mass of recycled plastic used for the product
of recycled
= X 100
plastic in total mass of final product or total mass of
product plastic in final productRecycled Plastic
• Main principles in general methodology likely to also apply to the
packaging sector
• Possible interpretations:
• Plastic waste subsequently recycled into plastic:
• Closed loop: Plastic tray→ plastic tray
• Open loop: Plastic tray → plastic crate; plastic pipe → plastic crate
• Any waste (plastic or non-plastic) that is recycled into plastic:
• Glass bottle → filler in plastic packaging productDenominator
Percentage by mass:
Percentage mass of recycled plastic used for the product
of recycled
= X 100
plastic in total mass of final product or total mass of
product plastic in final productCalculation Point
• Calculation point will be based on wording in relevant
legislation
• E.g. placed on market, sold to final consumer, exits manufacturing
process
• Be mindful of unintended consequencesCalculation Timeframe • PPWD requires member states to report information on quantities of packaging placed on their markets by mass calendar year • Reduce administrative burden if the same timeframe and calculation point could be applied for calculation and reporting of recycled content in packaging
Pre-Consumer / Post-Consumer
• Currently no grounds for
excluding recycled content based
on its source
• If desired, would need to be
clarified in legislation
• Packaging sector-specific
guidance on “waste” and “by-
product” may be required
https://crawfordpackaging.com/automation-and-innovations/tray-sealing-101Additives & fillers
In general low concentration in
packaging application, but could be
exceptions
• E.g. plastic crates with
bulking/strengthening fillers
For these applications, or where there
is a risk of recycled additives/fillers
being inflated to achieve targets, a
threshold mechanism may need to be
consideredMoisture & contamination Any moisture / contamination acceptable to the conversion process is considered inherent to the material and need not be deducted from the calculation
Reporting & Verification • Only a mere reference to “mass balance approach” in Implementing Decision (EY) 2019/665 is not adequate to base CoC verification rules • Does not define mass balance • Further clarity will be required in future updates to the PPWD
Packaging Sector Summary Recommendations
• The only existing EU level targets for RC in packaging are in the SUPD for SUP beverage bottles
• The Commission is assessing the feasibility of other recycled content targets for packaging in the
future – how this target (or targets) are formulated with influence the calculation methodology
• Both the numerator and denominator depend on the scope of the target (i.e. the products it
applies to)
• The legislation should also clarify:
• How “recycled plastic content” should be interpreted
• The calculation point
• Acceptable approaches for reporting & verification, including definition of mass balance
• Possible need for packaging sector specific guidance on distinction between “waste” and “by-
product”
• Additive/filler content likely to be low for most packaging products. For exceptions, a threshold
approach may be necessary
• Moisture/contamination acceptable in conversion process need not be deducted from the
calculationQ&A on Packaging Sector
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155-688-369Construction
Construction Sector
• Second largest user of plastic in
Europe (after packaging). • insulation
• Consuming 10 million tonnes of • windows and doors
plastics annually - 20% of total
Construction
European consumption. • pipes and plumbing
plastic
• Significant user of recycled applications
• cabling
plastic content can include: • carpets
• PVC is the most common • shower fittings
polymer used in construction.
• light fittings
• Definition and scope of
construction products is vital.Construction: Recommendations & Considerations Product Variation • High variation in plastic product types • Product value chains range from relatively simple to hugely complex • Complexity of pre and post-consumer definitions Additives & Fillers • Complex range of products, some may have high additive and filler content • How / if to include additives and fillers in the Numerator Mass of Products • Whole mass or only plastic components included in the Denominator • Proportion of a product which is typically plastic vs non-plastic
Construction: Recommendations & Considerations
Scope of Targets
• Two possible options considered:
• Product / group level – Target is set for a particular product/ product group
• Building level – More flexibility, but may add administrative burden
Calculation Point
• Various options considered:
• Product / group level
• Building level
• Member State levelQ&A on
Construction Sector
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155-688-369Automotive
Automotive Sector
• Use of plastics in the sector is growing
Applications include:
• Improved techniques to produce high
• dashboards
quality recyclate for use in new vehicles
• bumpers
• ELV Directive contains weight-based
• buttons
recovery targets
• casings
• ELV Directive includes 85% material
• containers
recovery target
• clamps
• Recycled plastic content is already used in
• sockets
some new vehicles
• fluid tanks
• Many companies have voluntary
• handles
commitments for recycled plastic content
inclusionAutomotive: Recommendation & Considerations
Scope of Target
• In establishing the formula for calculation, there are two possible options that must be
considered in the scope of any target:
• An average level of recycled plastic material (% by mass) across the whole car – allows for
complete flexibility on where the recycled plastic content is incorporated into a vehicle.
• A specific level of recycled plastic material (% by mass) to be incorporated in a specific car
part/ component – This option allows for targets to focus on specific car parts.
Mass of Products
• A decision will need to be made on whether the whole mass of the automotive product should be
included in the denominator or only the plastic components.
Scope of Plastics
• The definition of plastics within the scope of any recycled plastic targets will be significant (e.g.,
whether or not to include composite plastic materials like FRPs, tyres, etc.), whether plastic waste
from any source, or specifically from ELVs should count if recycled into new vehicles, etc.Automotive: Recommendation & Considerations
Calculation Point
• Three possible options for the calculation point are considered:
• Member state level – this allows for flexibility as to how targets are met within a member
state;
• Car part level – this approach will only apply if the scope of a target is also at the car part
level and it would require every part of that type to meet the level;
• Whole car level – this approach would mean that every new car would need to meet the
target.
Additives
• Several car parts include a high proportion of additives/ fillers. An exclusion on non-recycled
(virgin) additives/ fillers may be required to ensure no unintended incentive to increase
proportion of such additives/fillers to meet the target with lower content of genuine recycled
plastics.
• Inclusion of non-plastic waste recycled into materials that are used in plastic products as fillers/
additives will need to be considered depending on the objectives of any underpinning legislation
(i.e. to encourage recycling of plastic waste specifically, or any waste into plastic products).Q&A on
Automotive Sector
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155-688-369Electrical and Electronic Equipment (EEE)
EEE Sector • High technical, aesthetic and requirements for EEE plastics and products • WEEE Directive places a number of requirements on Member States for management of WEEE • A proportion of WEEE goes through unknown treatment routes
EEE Sector • Regulatory framework for EEE and WEEE is complex • Recycling of WEEE plastics is expensive • Certification and verification of recycled content carried out at product level, but there is no common standard
EEE : Recommendation & Considerations
Definition of Recycled Plastic
• Only plastic recycled into new EEE should count as “recycled plastic”
• For WEEE, it must have been:
• a plastic;
• a waste and entered a recycling operations.
• reprocessed into sufficient quality outputs to substitute virgin plastic use in EEE
Products & Components in Scope
• Calculation should be based on total mass of plastic components within EEE placed on the
market
• Exclusions from calculation need to be considered on product basis
• The inclusion of additional components or spares for EEE products, that are not placed on the
market as EE, within the calculation will need to be considered.
Calculation Timeframe
• Could be per calendar year, in accordance with annual reporting requirements of WEEE Directive.EEE : Recommendation & Considerations Measurement Point & Calculation Point • Measurement point could be at product, product group or polymer type level • Calculation point could be at member state or product level • Both must consider recyclability of plastics required and quantity of recycled material available Verification and Reporting • Complexity of EEE manufacturing supply chain will make reporting and independent verification of recycled content difficult Pre-/ Post-Consumer Waste • Definitions for pre-consumer waste classification will be required • Size of content target could be different if pre-consumer waste included within the calculation • Targets must consider complexity of recycling post-consumer waste and limits on quantity of recyclate available Additives & Fillers • Consideration must be given to whether maximum thresholds for additives are required.
Q&A on Electrical
and electronic
equipment Sector
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155-688-369Ecolabel and GPP
Ecolabelling
• Plastic recycled content requirements in
ecolabeling are generally inconsistently applied
• ISO 14021 should be used as a starting point for Product Packaging
Product Minimum Minimum
definitions of pre/post consumer. Requirement Requirement
• Verification requirements are typically
inconsistently worded. Computers 10% -
• EN 15343 already provides a set of requirements Electronic Displays (tvs) 10% -
that can be referenced to provide more Furniture 30% -
consistency for such claims. Textiles 70% -
Detergents* 80%
• Application of CoC terminology developed in ISO
Lubricants - 25%
22095 should also be used in future revisions.
Footwear - 80%
• The cosmetics revision draft references ISO
22095 but applies the terminology incorrectly *Includes six labels introduced on 23rd June 2016 covering household and
industrial detergents for laundry and dishwashing
currently.
• If a mass balance CoC is allowable, further
definition of rules are required beyond current
ISO/EN StandardsGreen Public Procurement
• Plastic recycled content requirements in GPP are not widely adopted.
• Textiles: 20% recycled content for Polyester, but can come from pre or post
consumer
• Computers and furniture: discussed by rejected.
• keep criteria to a minimum
• focus on those that have the most impact.
• lack of a common method for calculation and verification.
• EN 45557 for energy-related products (including some EEE) may help to
improve this but;
• has yet to be fully considered in GPP criteria for such product groups
• Is inconsistent with ISO 22095 terminology and treats all CoC models
equally.Q&A on Ecolabel and
GPP
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155-688-369Next Steps - Stakeholder Engagement
Today
Nov 2020 Workshop 3
Workshop 1 General
Initial Methodology & Spring 2022
Webinar Other Sectors Final Report
Spring 2021 Autumn 2021
Workshop 2 Workshop 4
Specific Method Specific
for SUP Method for SUP
Beverage Beverage
Bottles Bottles
Study email address: RC_Measurement@eunomia.co.ukConclusions from the Commission
www.eunomia.co.uk
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