Joint statement calling for a transparent and reliable policy framework defining recycled content in plastic

Co-signing letter

We, the signatories of this letter – civil society organisations and responsible companies operating in relevant sectors – are writing to you 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. […]

The decision on the methodology for defining single-use plastic recycled content will create a precedent with far-reaching implications […] It is crucial that the right decisions are taken to reduce the environmental impact of plastic, enhance plastic circularity, ensure consumer protection, respect the level playing field between recycling technologies, and avoid creating disadvantages for less environmentally harmful recycling processes. […]

Therefore, we recommend that the implementing decision prioritises the utilisation of segregation and controlled-blending models, whenever they are applicable. These models allow for the highest level of physical and chemical traceability. Additionally, when segregation and controlled-blending are not applicable, we suggest to proportionally allocate recycled content to all output products and the assessment of the content on a rolling average basis.

1. The implementing decision should not create unfair advantages for technologies with higher environmental impacts and lower yield rates. […]
2. The implementing decision should account for the likelihood that decisions taken regarding what types of chain of custody models are permissible will have knock-on implications for claims made to consumers on the proportion of recycled content in individual products. […]