An industry letter, some scribbles on mass balance accounting, and some notes on facility siting

27 March 2023

 Silke Einschuetz

Scribbles by Silke Einschuetz, Senior Consultant,
Recycling & Sustainability

During AMI’s Chemical Recycling North America conference in Houston last week mass balance accounting was one of the topics that attracted the most interest and discussion. Not surprising given its great relevance not only for the chemical recycling industry but also for packaging converters and brand owners who, in Europe in particular, face increasingly higher recycled content targets as well as EU-level and national levies and taxes. Standardisation and clarity of how recycled content is to be calculated will be crucial for assessing progress towards recycling targets and is a prerequisite for attracting additional investments to the chemical recycling industry.

My approach has always been to map things out on paper, so I’ve shared my scribbles with you in the picture, providing a simplified picture of recycled content allocation. From that, you can see that the fuel-exempt model the associations ask for is, from an industry perspective, a compromise between the preferred model of free allocation and stricter allocation rules such as ‘polymers-only’. In terms of the recycled content that can be counted in the polymer fraction of the process output it ranks above ‘polymers-only’ but presents a significantly lower attributable share than free allocation, which is widely considered not acceptable in terms of traceability and reflecting reality. In its letter, the associations consider that this model would provide for a robust system that would allow producers and users of recycled content to reach targets expected by the market and required by EU legislation in a timely manner.

More detail on mass balance and the global status of the chemical recycling industry is, of course, available in our report Chemical Recycling Global Status, which will be updated with brand new data in April 2023. Please don’t hesitate to get in touch with any questions or comments at silke.einschuetz@amiplastics.com

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