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  • ChemRecEurope
    Nov 5

Mass-Balance for chemical recycling

The Mass-Balance approach:

  • is a proven chain of custody approach used in many areas bringing innovations to the market such as fair-trade practices in the food industry and the adoption of “green energy” where the Mass-Balance approach enables its flow through the same grid as for fossil energy and the significant development of the industry,

  • is essential in meeting recycling targets for plastics in Europe,

  • brings transparency and audited traceability process.


This paper is in response to the revision of the Packaging and Packaging Waste Directive from DG ENV, as supported by consultants Eunomia, focusing on how hydrocarbon products from chemical recycling of plastics can be accounted for within a recycling system that encompasses petrochemical processing infrastructure.

Read more here.

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10 Questions and Answers to Better Understand Chemical Recycling

CRE publishes the first series of Questions & Answers (Q&As) on Chemical Recycling. This Q&As document helps better understand the role of chemical recycling technologies in boosting circular economy and protecting the environment as well as clarify issues and concerns related to those innovative processes.

You can find it here.

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Restrictions & misunderstanding about Chemical Recycling misguide transformation of EU Waste Policy



Although the “10 priorities to transform EU Waste Policy” developed by various European Union (EU) NGOs and associations points at ambitious directions for the waste policy that Chemical Recycling Europe generally supports, restrictions mentioned in Priority 9 represent missed opportunities to improve the current waste and recycling system, leading to some inconsistencies between priorities. We would like to provide some clarification on chemical recycling to refine Priority 9.


Chemical Recycling Europe supports many of the priorities mentioned in the NGO’s joint statement:

  • Priority to favour waste prevention and reduction as well as reuse in full alignment with the EU Waste Hierarchy.

  • Priority to prevent shipping of plastic waste to non-EU countries, especially if they do not have the necessary infrastructure, to stimulate recycling and recycling infrastructure in the EU and to avoid pollution elsewhere.

  • Priority to encourage the creation of plastic products that follows the principle of the waste hierarchy. This implies support for eco-modulation and measures to incentivize increased amount of recycled content in plastic products, and more generally, in a circular design. The purpose of which is to stimulate the demand for recycled content and circular materials. On this basis, we support an Extended Producer Responsibility (EPR) expanded to other groups beyond packaging and WEEE.

  • Priority to clarify the definition and framework for chemical recycling.

We would, however, like to bring some elements of clarification related to Priority 9 regarding chemical recycling:


I. Chemical Recycling is circular by definition: Chemical recycling represents an overarching category composed of different technologies that aims to close the material loop by converting plastic waste currently not recycled into high-quality products. These recycling techniques (sometimes described as Upcycling or Advanced Recycling) reflects the essence of what circularity is by enabling the direct replacement of virgin material with its identical quality and properties. They, for instance, enable the inclusion of recycled content in food-grade applications. These various technologies convert polymeric waste in different value-added materials like monomers, naphtha, syngas, waxes and etc.

Chemical recycling takes on a clear circular approach as the definition of chemical recycling excludes energy recovery: “Chemical Recycling is defined as any reprocessing technology that directly affects either the formulation of the polymeric waste or the polymer itself and converts them into chemical substances and/or products whether for the original or other purposes, excluding energy recovery”.


II. Input characteristics should not be restricted: The input of chemical recycling has very little value compared to the input of mechanical recycling. Therefore, chemical recycling input naturally falls into a category that tends to be contaminated and/or degraded. We, however, fail to see the reason for restricting chemical recycling to contaminated and degraded plastics. Some plastics are more complex and some do not represent a stream economically viable for mechanical recyclers and therefore this restriction prevents the possibility for these plastics to be recycled. Opening broader plastic waste streams to chemical recycling would enable more plastics, that are currently not being recycled, to be recycled and would therefore complement current efforts made by mechanical recyclers.


III. Input origin should not be restricted: Saying that the input should not come from a separate collection, would mean that chemical recycling would not be able to capture the rejects from mechanical recyclers, which represent a significant amount of plastic waste. In addition, mechanical recycling is also not able to recycle some separate collected waste streams e.g. EPS, LDPE,… Therefore, we ask what the best recycling alternative would be for those separate collected waste streams rather than chemical recycling? On the other hand, in addition to new plastics, the output of chemical recycling can be used in the production of a variety of materials which might bring more value than plastics and therefore the output should not be limited to new plastics. Furthermore, unwanted plastic waste of a larger variety can be transformed into alternative oils, waxes, and solvents. This also results in a reduction of crude oil as a raw material and creation of necessary and useful materials for various industries.


IV. Restrictions lead to inconsistencies with Priority 10: Restricting the input characteristics and origins for chemical recycling would be inconsistent with Priority 10 phasing out waste incineration. Given that the plastic waste going to chemical recycling would otherwise be sent to Energy-from-Waste, the restrictions above imply that you implicitly favour this waste going to Energy-from-Waste. This represents a missed opportunity to recycle the plastic waste coming from the rejections of mechanical recycling (and therefore from separate collection) or a waste stream technically or economically difficult to recycle by mechanical recyclers.


V. Chemical recycling targets a new demand: Chemical recycling specifically targets the demand for virgin-quality recycled content that mechanical recycling can fulfil only for PET and HDPE for a few cycles under strict conditions (for now, and we hope that innovation will enable more!). It targets a circular product and demand that currently cannot be fulfilled.

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Call for faster recognition & legislation review to unlock the potential of chemical recycling

In a position paper published on the 2nd of June 2020, Chemical Recycling Europe calls for a faster recognition and legislation review to unlock the potential of chemical recycling.



The recycling industry plays an important role in the transition to a more circular economy by turning polymeric waste into new value-added materials.


The sustainable management of waste and use of resources is at the heart of the European Green Deal. While the new Circular Economy Action Plan aims at accelerating transformational change required by the EU Green Deal, in order to meet its ambitions and to reach EU recycling targets laid down in the EU Plastics Strategy, there is an urgent need to develop and implement new technologies for the recycling of polymeric waste, going beyond the limitations of traditional mechanical recycling.


Chemical Recycling complements the current recycling approaches and has the potential to be an environmental game-changer by processing polymeric wastes which are currently difficult to recycle. Investment in developing chemical recycling technologies and infrastructure will lead to the creation of new jobs and the protection of our environment by curbing CO2 emissions and increasing EU recycling capacity.


To access the full position paper, please click HERE.


ChemRecEU calls for constructive collaboration with waste management industry to increase recycling



In December 2019, FEAD the representative body of the private waste management and resource industry published the results of its analysis of chemical recycling. Chemical Recycling Europe supports constructive dialogues with regard to chemical recycling and would like to clarify some observations issued in the FEAD’s analysis:


1. Chemical Recycling Europe would emphasize that chemical recycling complements other recycling processes and it’s one of the solutions to tackle the plastic waste issue. When mechanical recycling is unable to treat the polymer waste (or not in an economically viable manner), chemical recycling provides a unique opportunity to recycle those difficult-to-recycle waste streams and convert them to high-quality secondary raw materials. Unlike mechanical recycling, chemical recycling provides different technologies for the recycling of different polymer types which makes it necessary to build a common understanding of the chemical recycling concept – including its definition – across the plastic value chain. ChemRecEurope supports any initiative to reach this common understanding.


2. ChemRecEurope welcomes the FEAD’s conclusion on the definition of recycling in the Waste Framework Directive which confirms that the current technology neutral definition appropriately addresses “chemical recycling”. In line with the definition, use of the output as fuels automatically falls under the energy recovery level in the waste hierarchy.


3. As an industry, we are committed to provide, as soon as the development of the industry enables us, an independent Life Cycle Assessment (LCA) to ensure that chemical recycling creates a value for the environment. We would however like to highlight two main points:

  • CO2 footprint is not enough to assess the full impact of chemical recycling. We would therefore run a more holistic LCA looking at a broader range of indicators, as well as understanding the quality and value of the recyclate produced (by mechanical and chemical recycling). 

  • The comparison with mechanical recycling is often complicated given that it is a different feedstock in and a different (higher-quality) product out, generally used for food-grade or other than plastic production applications. Chemical recycling is tackling issues such as contamination, removal of chemical and mineral additives, colours, multilayered (ML) or mixed plastics that mechanical recycling cannot address without additional cleaning/washing steps and a thorough separation by polymer types which is often not possible or too costly. Their LCA are therefore not directly comparable as they address different problem waste streams (input) and different demands (output), that are very much complementary.


4. We regret the use of unjustified statements regarding the impact of chemical recycling and its feasibility at industrial scale. Regarding economic feasibility of chemical recycling, many large industrial plants have been announced and are in the pipeline in Europe with global partners, which would not have associated their names nor put chemical recycling as key to their strategic direction if they did not believe in the feasibility at industrial scale.


5. Protecting consumer health and the environment is one of our key strategic goals. To ensure this, we believe that secondary raw materials leaving the recycling plant should be in compliance with the relevant legal provisions such as REACH or waste legislations. It is worth mentioning that chemical recycling is more tolerant towards contaminants and thus can treat low quality feedstocks and produce high-quality secondary raw materials to be used even at food contact applications. However, there is lack of alignment between waste and product legislations that needs to be clarified.


The growing demand for chemical recycling output from the global brands and the chemical industry in order to reach the ambitious recycling targets for plastics set by the EU, will require a strong collaboration with the whole plastic value chain to make it a reality. The waste management sector has a key role to play in this chain and we therefore call for a constructive collaboration to enable the development of new solutions, such as chemical recycling, to reach these goals.

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Chemical Recycling is part of the solution!

Updated: Jun 2, 2020

There is now a growing movement recognizing chemical recycling as part of the solution to reduce plastic waste, decrease CO2 footprint and contribute to the creation of a circular economy for plastics. See how Chemical Recycling Europe (ChemRecEurope) members are supporting circularity of polymers by providing innovative solutions to tackle plastic pollution, to conserve natural resources and protect the environment.


Read more here.


"Chemical Recycling: welcomed step in the right direction"

Chemical Recycling Europe (ChemRecEurope) welcomes Zero Waste Europe (ZWE) assessment of the potential of chemical recycling to complement mechanical recycling and to overcome its limitations, as much in the plastic waste treated as well as in the high-quality of the output.

ChemRecEurope also welcomes the recognition from ZWE that the plastic to plastic (P2P) process counts as ‘Recycling’ according to the EU definition of ‘Recycling’.

Although ChemRecEurope agrees that the environmental impact plays an important role, we regret the suggested hierarchy set between mechanical recycling and chemical recycling given that it is in the same way a recycling process, not competing but instead targeting different plastics (easier-to-recycle vs more difficult-to-recycle) and creating a different output. We therefore support a non-differentiation between the two recycling methods.

On the other hand, we believe that some competitiveness is key for innovation and technology growth. Building barriers and promoting anti-competitive practices would neither necessarily help maturing chemical recycling nor improving current mechanical recycling processes.

We urge policymakers, the value-chain, and NGOs to agree on a definition for chemical recycling to lift further confusion. Our goal is to educate, communicate, and clarify.

ChemRecEurope understands and supports the aim of ZWE to prioritize reduce, reuse, and re-design, along the principle of the EU waste hierarchy. We however highlight that funding and investments also need to go towards new recycling innovations that also aim at reducing pollution, improving waste management, and increasing recycling and recycled content when the three previous options were not possible in the first place, and/or when plastics have already been created.

While developing a legislative support to P2P is a welcomed step, we disagree with the direct association of plastic to fuel (P2F) with incineration. Although being a less preferable option, P2F has some benefits compared to incineration that should not be discarded including its lower environmental

impact, its reduction in oil extraction, as well as the transformation of waste into a valuable resource and the fact that it does not burn the plastic waste/resource. In addition, with chemical recycling, fossil resources for high value-added chemical production can be replaced with recycled material from plastic waste.

We are committed to provide, as soon as the development of the industry enables us, an LCA to ensure that the chemical recycling process creates a value for the environment. We, in addition, commit to improving energy efficiency of the technologies. Given the industry infancy, the LCA opinion should account for the gradual improvement of the technologies.

Contact: John Sewell –

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  • ChemRecEurope

Position Paper on Chemical Recycling

Updated: Jun 2, 2020

Chemical Recycling: a complementary recycling solution to boost plastics circularity and reduce the carbon footprint


The European Commission with its Circular Economy Action Plan has set ambitious targets for the EU member states. It aims to overcome traditional linear patterns of production and consumption, to keep resources in use for as long as possible, and to recover and regenerate product and materials at the end of their service life.


As part of its Circular Economy Package, the Commission depicts its 'vision for Europe's new plastics strategy' by setting clear goals to curb plastic waste, increase resource efficiency, and create value and job growth in Europe. However, by focusing its strategy on mechanical recycling, it falls short of presenting a comprehensive approach. Concrete steps towards increasing plastic waste recyclability and reducing landfilling and incineration involves supporting innovative recycling solutions such as “Chemical Recycling”.


Chemical Recycling of polymer waste is defined as any reprocessing technology that directly affects either the formulation of the polymeric material or the polymer itself and converts them into useful products like monomers, basic-chemicals, alternative fuels and other value-added materials.


Targets set up in the EU plastic strategy (10 million tonnes) will not be achievable without implementing of chemical recycling. As the collection and recycling system is not (yet) cost-effective and the quality of the recyclate is not sufficient to replace virgin plastic on a large scale, current mechanical recycling has limitations. Chemical recycling is a complementary solution to overcome the current challenges of mechanical processes to increase overall recycling rates.


To this end, chemical recycling is of high importance as it targets heterogeneous and contaminated plastic waste material when separation is neither economical nor completely technically feasible. Chemical recycling plastics is important to conserve natural resources and protect the environment, as it can reduce the amount of virgin oil needed to produce commodity plastics and reduce landfilling or incineration of plastic waste, thus contributing to the creation of a circular plastics economy and cleaner environment.


However, the race to develop the technology that can provide a solution to recycle hard-to-recycle plastic waste is outpacing the regulation and policy around it. Lack of structured and harmonized approach to waste collection and recycling causes constraints on companies that can create new value-added products from this waste.


Therefore, Chemical Recycling Europe welcomes any opportunity to work together with the whole plastics value chain and EU and National policymakers to develop new EU regulatory and policy measures to boost the circular plastic economy by finding sustainable solutions for the following critical policy areas:


1. Recognition of chemical recycling: create a supportive framework to fully exploit the potential of chemical recycling technologies.


2. A level playing field for recycling technologies: Implementation of the same EPR systems for mechanical and chemical recycling and recognition of chemical recycling as recycling in the waste hierarchy, to support collection and ensure it counts towards EU recycling targets.


3. Efficient collecting and sorting processes: high performance sorting of the input materials needs to be performed to ensure that plastic types are separated to high levels of purity.


4. Redefining the plastic waste segregation and identifying the most sustainable option for the individual treatment of specific waste streams across Europe.


5. Developing common EU standards of chemical recycling for different polymers.


6. A need for the further development of end markets for each recycled polymer stream.


7. Reducing landfilling and incineration of plastic waste: chemical recycling is a more sustainable and environmentally friendly alternative to incineration and landfill, this can be demonstrated by life-cycle analysis.


8. Clarifying the alignment between the end-of-waste status and REACH and ensuring harmonization across EU member-states.



Click here to download the PDF version.

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