February 27, 2024

NGO-business coalition calls on the decision-makers to consider a real compromise by voting for a “polymer-only” allocation method to account for recycled content in the implementing decision of the Single-Use Plastic Directive (SUPD)

The undersigned organisations – civil society organisations and companies operating along the value chain in relevant sectors – are writing to you to express their concerns and to highlight the importance of prioritising robust and transparent chain of custody models for calculating recycled content in the European Commission’s implementing decision that establishes rules for the application of Directive (EU) 2019/904.

We believe it is important to consider amending the proposal’s allocation rules where it pertains to the ‘fuel-use excluded’ for mass balance accounting. Just like in 2019 with the SUPD, our current decisions will shape future legislation such as the Packaging and Packaging Waste Regulation, the Ecodesign for Sustainable Product Regulation (ESPR) and the End-of-life Vehicles Regulation. The rules adopted will play a significant role in either facilitating genuine circularity or retaining the status quo of relying on virgin feedstock.

The decisions made regarding the EU methodology in this implementing act will have implications beyond its immediate scope. Failing to establish a suitable chain of custody now will hinder Europe’s ambitions for carbon neutrality by 2050 and slow down progress towards a circular economy. It is thus crucial to maintain ambitious goals and oppose opaque and distorting rules which run against environmental objectives.

It is worth noting that mass balance accounting shall only be used as a last resort when other models providing greater transparency and traceability (i.e. segregation and controlled blending) are not feasible to fully maximise the benefits of recycling.

When mass balance accounting is needed, the allocation rules should be stringent, aim to prevent greenwashing, ensure a level playing field among technologies, and promote genuine innovative solutions that do not require dilution with virgin feedstock and high energy demand. The ‘fuel-use excluded’ allocation rule does not meet these criteria and represents nothing more than an additional economic incentive.

We recommend that the implementing decision prioritise the use of segregation and controlled-blending models, whenever applicable. These methods provide excellent traceability of materials both physically and chemically. If segregation and controlled blending are not feasible, we propose considering a mass balance with polymer-only allocation as a compromise. Indeed, we initially supported proportional allocation rules at the batch level.

We thank you in advance for your attention and call on you to maintain the initial ambitions of the Single-Use Plastic Directive and remain at your disposal for further information and conversation.

Signatories (in alphabetical order):


Environmental Coalition on Standards (ECOS)

European Environmental Bureau (EEB)

European Recycling Industries’ Confederation (EuRIC)

European Waste Management Association (FEAD)

Minderoo Foundation

Zero Waste Europe (ZWE)