For years the European Commission clung to the view that mechanical recycling was the answer to plastic waste and marine pollution. Then, when industry and safety experts pointed out the risks of using dirty plastic waste for food contact materials, reusable packaging became the remedy. Although these technologies are important, they will never be the complete solution. For a while now, industry and consumer brand owners have been making the case for chemical recycling, which decontaminates and processes most types of waste plastic into new, clean, high quality polymers. But although it is to be accepted by EU regulations as a bona-fide way of recycling, emerging rules around implementation could easily lead to unintended consequences.
Society is always going to need plastics for packaging medicines, food, and personal care products, and in a low carbon economy, they will be made from renewable materials or carbon dioxide from the air. But the polymers used for packaging are just not tough enough to withstand repeated cycles of use. Most degrade as they are melted or heated, cleaned, refilled, and transported. So, at some point, they become waste. A supplier of polypropylene milk bottles estimates that they can be reused 15-20 times before disposal. End of life comes even sooner for mechanical recyclate; typically, it is too degraded to be used after a few cycles. Chemical recycling can take most of these wastes and transform them into new polymers.
In chemical recycling, the process of breaking down the polymer molecules, and then rebuilding them, is not selective and the recycled content becomes distributed through different products, not just those that will be reprocessed back into plastics used for packaging. The rest of the recycled content ends up in fuel, chemicals or intermediates that are not subject to recycled content requirements, so it is of little use for compliance. Companies are trying to address the problem, and the MoReTec technology from Lyondell Basell aims to convert more of the fractions back to useful raw materials for plastics.
The laws of chemistry, however, don’t obey EU Directives, and there will always be some recycled content that ends up in other molecules. Regulators have decided that this recycled content cannot be allocated to plastics if it ends up in fuels and will probably be ‘discounted’ in products that can be ‘dual use’ (fuel or chemical). So, a significant proportion of the recycled content will effectively be lost. The waste hierarchy, enshrined in the Waste Framework Directive, apparently forbids the allocation of recycled content in fuels, back to polymers, as the Directive prioritises recycling over energy recovery. However, the waste hierarchy is not binding. Indeed, the Commission’s own website emphasises that it is an ‘order of preference’.
There is already a shortage of suitable recyclate, and this decision is likely to exacerbate the problem. So, what happens when ambitious targets come up against shortages in the marketplace? Look no further than the biofuels sector, where the push to get waste-based biofuel into both road and air transport has created a trend for fraudulently passing off virgin vegetable oil as used cooking oil. Could this happen in the plastics sector? One industry insider has recently publicly stated that unscrupulous operators are already selling virgin plastic that they have deliberately dirtied, as waste, so it can count as recycled content. Where there is a shortage, then bad actors will rush in.
It will be a few years before the implications of the current approach to recycled content become clear. In the meantime, brand owners and others who have to comply with these regulations should take steps to avoid fraud by investing in certified and traceable waste materials. Society has to get recycling right, as plastic will be with us for the foreseeable future. So, eventually something will have to change in Europe to make chemical recycling easier, and it won’t be the laws of chemistry.
Published: 19 March 25
