The European Union clarifies mass balance accounting rules within the Single-Use Plastics Directive (SUPD), providing guidance for recycled content compliance.
LONDON — The European Commission has released detailed guidance on how the mass-balance methodology will be applied under the Single-Use Plastics Directive (SUPD), following approval of the implementing act on 6 February.
The newly adopted Implementing Decision confirms that recycled polyethylene terephthalate (rPET) imported from countries outside the European Union will only be eligible to contribute toward the 25% recycled content requirement for beverage bottles starting 21 November 2027. After receiving member state support, the implementing act is expected to enter into force as law.
As anticipated, the regulation adopts a “fuel-use excluded” mass-balance framework. Under this approach, any material diverted into fuel applications or lost during processing cannot be counted toward recycled content targets. However, free allocation of the remaining eligible recycled material across outputs will be allowed, provided specific conditions are met.
These conditions include demonstrating that a realistic chemical process exists to convert eligible inputs into the claimed outputs, ensuring allocated quantities do not exceed the portion of output that could originate from the recycled feedstock, and avoiding allocation where both the input and output are polymers.
Although the implementing act applies specifically to recycled PET within the SUPD, the Commission has previously indicated that the methodology could serve as a model for broader EU recycling regulations. Several calculation elements appear particularly relevant to chemical recycling technologies such as pyrolysis, even though PET itself is not commonly processed using pyrolysis methods.
Industry participants involved in pyrolysis oil production have suggested that clearer regulatory direction may support future investment and improve market confidence over time. Nevertheless, uncertainties remain, including questions around end-of-waste classification beyond the scope of this act.
The rules also address materials with dual uses, requiring that any portion expected to become fuel must be excluded from recycled content calculations. Solid by-products with mixed applications, such as char, are similarly excluded.
Different calculation methodologies are outlined depending on whether recycled feedstocks enter steam crackers directly or undergo additional processing steps beforehand. Mass-balance accounting must be completed within a three-month period, calculated individually for each production facility, and cannot be transferred between sites or companies.
The SUPD, which came into force in 2019, includes several major measures aimed at reducing plastic waste and increasing recycling. These include a mandatory 25% recycled content requirement for PET beverage bottles by 2025, with future targets now covered under the Packaging and Packaging Waste Regulation (PPWR). The directive also sets separate collection goals of 77% for plastic bottles by 2025 and 90% by 2029.
In addition, the legislation bans certain single-use plastic products such as cotton buds, cutlery, plates, straws, stirrers, balloon sticks, and food or beverage containers made from expanded polystyrene or oxo-degradable plastics. It also introduces extended producer responsibility schemes that require manufacturers to contribute to waste management and clean-up costs for products including fishing gear and tobacco filters.