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Calculating recycled content in SUP beverage bottles. Ensuring a level playing field with the mass balance approach

06 November 2023


Following the introduction of requirements for a mandatory minimum content of recycled plastic in beverage bottles under the SUP Directive[i], the European Commission will set new rules for the calculation and verification of those targets through the adoption of an implementing act.

EuRIC – the European Recycling Industries’ Confederation- strongly supports the development of calculation and verification methods at EU level that ensures the highest level of traceability and strength of claim when counting recycled plastic content. Strict and transparent rules are needed to ensure a higher circular use of plastics that drives positive environmental change while respecting the level playing field between recycling technologies.

In this position paper, EuRIC exposes different accounting systems to calculate recycled plastic content, with a focus on the development of mass balance methodologies for chemical recycling. In addition, EuRIC highlights some key elements that cannot be forgotten when it comes to achieving the recycled plastic content targets.

EuRIC represents the European recycling industry at an EU level. Gathering the vast majority of national recycling federations from EU/EEA Member States, the Confederation represents about 5.500+ recycling companies – from market leaders to SMEs – generating an aggregated annual turnover of about 95 billion € by treating various waste streams (e.g., metals, plastics, textiles, e-waste including batteries, tyres, paper etc.,).

EuRIC’s position in a nutshell

Call for the development of clear and transparent rules to calculate and verify the recycled plastic content in beverages bottles. Mass balance requires further rules to be implemented.

  • EuRIC supports a waste stream specific approach to ensure the highest level of traceability without breaking technology neutrality. Rolling average mass balance method shall apply for PET waste recycling and proportional credit method, with a review clause, shall apply for other plastic waste recycling under the scope of this regulation, in particular polyolefins.
  • Strong opposition to fuel exempt accounting method as there is too much discrepancy between claims and real recycled content in article as well as a non-technology neutral approach. Polymer-only would be the “least bad option” as it still induces a significant deviation in claim and recycled content.
  • Strong opposition to the credit transfer between different sites recycling polymers. Recycled Content should be calculated at facility level.
  • Strong support to third-party verification, essential to maintain the credibility and transparency of the recycling industry.