EU’s fuel-exempt chemical recycling rules set PET packaging content calculation framework for single-use bottles

EUROPE – The European Commission has adopted a new Implementing Decision under the Single-Use Plastics Directive that establishes fuel-exempt mass-balance accounting rules for chemically recycled PET content in beverage bottles, aiming to enhance transparency and investment certainty in the packaging sector.

The Implementing Act introduces a standardized methodology for calculating chemically recycled content, requiring economic operators to apply “fuel-use excluded” mass balance accounting, which mandates that eligible material processed into fuels or lost during production be deducted from any recycled content claims. 

The rules aim to improve transparency in calculating chemically recycled PET, level the playing field, and secure the plastic recycling industry, which faces mounting pressures from cheap virgin plastic imports and high energy costs. 

Mass-Balance Accounting, Chemical Traceability and Fuel-Excluded Approach Define Compliance Framework

The Implementing Decision establishes rules for mass balance accounting, tracking recycled materials through production processes, and dictates how eligible input material can be allocated to outputs in multi-output processes. 

A central principle is the “fuel-use excluded” allocation rule, meaning waste used to produce fuels or energy recovery cannot be counted as recycled content, in line with the definition of “recycling” in the Waste Framework Directive. 

To ensure transparency, the rules require chemical traceability to verify that attributed recycled material does not exceed what could theoretically be present in a product. Annual third-party verification will be required for the most complex stages, such as chemical recycling, with lighter requirements for SMEs every three years. 

Jessika Roswall, Commissioner for Environment, Water Resilience and a Competitive Circular Economy, stated that the new rules on chemical recycling are part of the answer to the challenges facing Europe’s plastic recycling sector, giving industry the certainty needed to invest and innovate.

Phased Implementation and Geographical Qualification of Recycled Material

In the first phase, only chemically recycled plastics produced within EU member states and EEA countries will count towards targets. 

Beginning 21 November 2027, material from OECD countries will also be eligible unless excluded under the Waste Shipment Regulation. 

Recycled materials from non-OECD countries may qualify if they establish agreements demonstrating equivalent environmental and human health standards. 

The Commission noted it counted recycled content toward EU targets based on “credible, traceable, and environmentally sound standards.” 

While some environmental NGOs, including Zero Waste Europe, have criticized the legitimization of chemical recycling, the European Commission views the rules as part of a broader strategy to strengthen the recycling sector and advance circular economy objectives. 

The Implementing Act will enter into force 20 days after its publication in the Official Journal.

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