FEAD contribution to the Call for Evidence on sustainability criteria for plastic recycling technologies under Article 7(9) of the PPWR

FEAD welcomes the European Commission’s intentions on the sustainability criteria for plastic recycling technologies under Article 7(9) of the Packaging and Packaging Waste Regulation. This contribution focuses exclusively on the future delegated act establishing those criteria.

The sustainability criteria will determine whether recycled plastic produced through a particular recycling pathway may be counted towards the recycled-content targets. They should ensure that the production and use of recycled content deliver a genuine environmental benefit, while remaining proportionate and enforceable for recycling operators and their customers.

FEAD supports a performance-based approach: the criteria should not be used to favour or exclude technologies based on political preferences or broad technology labels. However, technology neutrality should not mean treating processes with materially different environmental impacts as equivalent. The assessment methodology should be neutral, while the resulting criteria should evaluate the sustainability performance of a recycling pathway based on scientific evidence.

Key aspects for an efficient and enforceable sustainability criteria

FEAD recommends that the Commission:

• Establish separate assessment categories defined by the combination of the ‘type of waste input’ and the ‘required quality of the recyclate’.
• Assess the entire relevant process chain, including transport between sorting, recycling, upgrading and conversion sites.
• Establish, for every assessment category, a sustainability threshold based on the representative environmental performance of EU recycling operations, as assessed in the work of the JRC.
• Implement an additional prioritisation of the most sustainable recycling pathway for a combination ‘type of waste input’ x ‘required quality of the recyclate’.
• Minimise administrative burdens through a common and simple assessment tool.

Compare processes treating same inputs and producing same outputs quality

A single sustainability threshold covering all plastic recycling processes would result in comparisons between fundamentally different situations. A process treating PET bottles waste stream cannot be meaningfully compared with a process treating PET films waste stream. Similarly, a process producing recyclate for a non-contact-sensitive application should not be assessed against one required to produce material meeting specific contact-sensitive requirements.

The basic unit of assessment should therefore be a clearly defined combination of:

‘Type of waste input’ × ‘Quality of recyclate’

The waste-input category should be based on the categories of packaging as defined under Annex II – Table 1 – Rows 8 to 19 of the PPWR, with possible refinement needed if identified by the JRC.

The output category should be based on the categories defined for the recycled content targets under Article 7 of the PPWR, e.g. single-use plastic beverage bottles, contact-sensitive packaging made from PET, contact-sensitive packaging made from plastic other than PET and other plastic packaging.

The functional unit should be one tonne of recyclate meeting the defined specification at the same point in the value chain.

Assess the full recycling pathway, including transport

The sustainability assessment should not be limited to the core operations taking place within the recycling installation. Since recycling technologies operate within value chains, the environmental performance of a recycling pathway can only be properly understood by considering the stages required to transform a defined waste input into a quality of recyclate.

Depending on the recycling pathway in question, the system boundary should therefore encompass sorting and pre-treatment, washing, decontamination, recycling and any necessary upgrading steps. Key parameters must be defined for each step in order to capture its main environmental impact. Yield and material losses must be reflected in the sustainable performance of a recycling pathway.

Transport must be a full component of the assessment

Transport can represent a material part of the environmental impact of a recycling chain, particularly where waste, intermediate outputs or recyclates are moved through several countries or over long distances. Excluding transport would systematically underestimate the impact of long-distance supply chains and could place shorter European recycling chains at a structural disadvantage.

The JRC is developing the technical basis for the sustainability assessment using life-cycle assessment of plastic recycling technologies. This work should be used to determine the key sustainability parameters to be assessed for each step of the process and to establish a general sustainable score for an entire recycling pathway. A list of potential key parameters per processing step is proposed in the table below.

Establish sustainable criteria thresholds based on EU performance standards

For each combination of waste input and recyclate quality, the Commission should establish a specific sustainability threshold based on EU reference processes developed through the JRC study.

The reference process should represent the environmental performance of mature recycling operations functioning under normal European industrial conditions. It should be derived from a sufficiently broad and quality-controlled dataset. This threshold aim is to distinguish normal, environmentally sound operations from pathways whose impacts are materially worse than the representative EU process.

For each category ‘Type of waste input’ x ‘Quality of recyclate’, a sustainable criteria threshold must be established, and for each recycling pathway tested against this threshold, a total sustainable score must be measured:

• A total sustainable score at or below the applicable threshold would be considered sustainable.
• Recycled content produced through a recycling pathway exceeding that threshold would not be eligible to count towards the Article 7 recycled-content targets.

The thresholds and reference datasets should be reviewed on a sufficiently regular basis to reflect technological development, changes in the European energy system and improved industrial data.

Provide a user-friendly interface to perform the sustainability assessment

Once the evaluation framework and the category-specific thresholds have been validated, the Commission, supported by the JRC, should develop and maintain a single harmonised EU interface through which the sustainability assessment can be performed.

The interface should translate the methodology into a practical tool requiring no specific life-cycle assessment expertise from recyclers, converters or other users. Economic operators should only be required to enter a limited set of parameters identified by the JRC and normally available through operational records, such as the relevant type of waste input and quality of recyclate categories, material yield, sorting and process losses, energy, heat and water consumption, and the distance between the relevant stages of the recycling pathway.

All complex elements of the calculation, including environmental impact factors, normalisation and the applicable sustainability threshold, should be embedded in the interface and applied automatically.

The interface should generate an assessment report indicating the pathway assessed, the data and default values used, the resulting score and whether the applicable threshold has been met. This report, or a unique reference linked to it, should be transmitted along the value chain and retained as part of the technical documentation accompanying the packaging. The plastic converter or recyclate user is required to perform the assessment and establish this report, based on the relevant data received from the recycling operator, as the transport distance between the recycling site and the converting site must be known.

Introduce a prioritisation of the most sustainable recycling pathway

A sustainability threshold is necessary, but it is not sufficient to ensure that recycled content delivers the greatest achievable environmental benefit. Several processes may remain below the threshold even where one process has a clearly and consistently lower environmental impact than another for the same input and output category.

FEAD therefore recommends complementing the eligibility threshold with a prioritisation of the most sustainable pathway principle: subject to availability of the recyclate and for a given category of input waste and output quality, an operator must source recycled content from the recycling pathway demonstrating the lowest overall life-cycle impact.

Recycled content produced through a less sustainable but authorised pathway should remain eligible only where the economic operator relying on it demonstrates that adequate capacity using the most sustainable pathway is not reasonably available for the relevant waste stream. The burden of providing this justification should rest with the operator claiming recycled content produced through the alternative pathway.

In order to help the operators in identifying what are the most sustainable recycling pathways for their situation, the Commission and the JRC should provide comparative examples of what could be considered as the most sustainable recycling pathway for a category of waste input and quality output.

Ensure proportionate implementation and simple pathway for EU recyclers

As explained in ‘Provide a user-friendly interface to perform the sustainability assessment’, recyclers should only need to provide a limited set of operational information that is generally available from existing plant records.

In addition, for facilities located in the EU, standard default data should be made available for existing recycling technologies for a given category of waste input and quality output. Therefore, for EU facilities, the operators will have the choice to use standard default data or facility-specific data. Such facility-specific data should be required principally where an operator seeks to demonstrate performance better than the default value.

Conclusion – In practice, how does it work?

1. For each category ‘Type of waste input’ × ‘Quality of recyclate’, the Commission develops a sustainability criteria evaluation framework, based on key parameters identified by the JRC for each step of the recycling pathway, including transport.
2. For each category, the Commission establishes sustainability criteria threshold, based on an EU reference process tested against the sustainability criteria evaluation framework. Such thresholds should be established so mature recycling operations functioning under normal European industrial conditions pass the assessment.
3. Once such framework and thresholds are validated, the Commission must develop a simple interface with minimal data input for the user to evaluate a recycling pathway against the established sustainability criteria threshold for each category.
4. For recyclate to count toward the recycled content target, sufficient and verifiable information must be provided to the converter or recyclate user to proceed with the evaluation of the recycling pathway through the simple interface. If the sustainable score obtained by a recycling pathway is under the sustainability criteria threshold, then it can count towards the recycled content targets.
5. For a given category of input and quality of recyclates, the converter must use in priority recyclates stemming from the recycling pathway with the lowest sustainable score.   
6. Faster sustainability assessment based on standard default data should be made available for EU recycling operators to limit administrative burden.
7. The sustainability assessment performed by the converter or the recyclate user must be documented under the technical documentation accompanying the packaging.

FEAD, the European Waste Management Association, represents the entire waste management value chain, from collection and sorting to recycling, energy recovery, and final disposal. It brings together the private waste and resource management industry across Europe through its 21 national member associations, which collectively represent over 3,000 companies. Together, the sector provides more than 500,000 local jobs and fuels €5 billion in investments into the economy every year. For more information, please contact: info@fead.be