A spanner in the recyclability works? NGOs raise concerns over plastic waste-to-fuel

18 Jun 2020 --- Could converting fossil plastics to fuels be part of the solution to the plastic industry’s environmental and waste management issues? Not according to Zero Waste Europe (ZWE) and the Rethink Plastic Alliance, who have warned ahead of today’s EU stakeholder meeting on the Renewable Energy Directive (REDII) that fuels derived from fossil waste will never be low-carbon and are therefore at odds with efforts to bring Europe’s carbon footprint to zero. ZWE also stresses that converting plastic waste-to-fuel could disincentivize the development of packaging that is recyclable by design and redirect existing recyclable plastics from mechanical recycling facilities.

“The current crisis is creating an opportunity for real change. Yet, plastic-to-fuel is encouraging reliance on our current linear system, convincing consumers that this waste can be ‘recycled’ when in fact it is getting burned. That's not the idea of a cycle,” Janek Vahk, Zero Waste Europe's Climate, Energy and Air Pollution Programme Coordinator tells PackagingInsights.

Countries including the UK, Netherlands and Belgium are reportedly considering converting hard-to-recycle plastics, including flexible packaging made of multi-material or multi-polymer compositions, to fuel as part of their carbon reduction strategies. This is largely motivated by the desire to find solutions for sectors that are relatively hard to decarbonize, like aviation, shipping, and heavy vehicles. However, ZWE points to research determining that CO2 emissions from waste-to-fuels with a high plastics content are actually higher than the CO2 emissions produced from fossil fuels.

At this stage, the EU environmental sustainability rules for Recycled Carbon Fuels (RCFs) have not been completely finalized. The rules have been largely left to delegated acts, the last of which are due by the end of 2021. Even though Member States have the option to include RCFs in their national frameworks, this decision would be based on unknown criteria, and should not be made before the last delegated act is published, ZWE advises. The Brussels-based NGO therefore recommends that Member States do not include RCFs in their national targets until proper evaluation of their environmental impact is made by 2021.

Zero Waste Europe highlights research suggesting that CO2 emissions from waste-to-fuels are higher than the CO2 emissions produced from fossil fuels.The issue for Vahk is how the Greenhouse Gas (GHG) savings are calculated. “Some say that plastic waste should be counted as zero-carbon as it's waste. This would exclude all the embodied carbon in plastics from the calculations. For example, ART Fuels Forum in its position paper suggests allocating the CO2 emissions to the final product rather than the waste. They also want to have waste incineration as the baseline because they claim that RCFs would be more efficient, but there’s no metric or anything that they use, so it’s hard to say how they think that’s not just another form of waste incineration,” he explains.

Unwanted competition for mechanical recycling
The definition of RCFs intends to guarantee that what can be recycled mechanically will not be used for waste to fuel applications, in line with the waste hierarchy in the waste framework directive. However, ZWE highlights that, as there is no definition of mechanical recycling, authorities have no way of determining which wastes are mechanically recyclable. “Therefore, the REDII prescribes that anything that can be recycled mechanically is recycled in that fashion, but it offers insufficient guarantee that this waste will not actually be turned into fuel,” ZWE states.

“For instance, only a couple of plastics are more or less successfully recycled right now, such as HDPE and PET bottles and flasks through selective collection. These plastics and other possibly recyclable plastics, could still very well end up in mixed waste streams (except for beverage bottles), which would be considered economically ‘unrecyclable’ and there is no basis for an authority to contest it. Several reports and composition analyses indicate that a clear majority of ‘residual waste’ is readily recyclable, and doing so would result in carbon savings and other environmental benefits,” the NGO explains.

Disincentivizing recyclable-by-design
An important element in transitioning to a circular economy is to make plastics easier to recycle. As acknowledged by the European Strategy for Plastics in a Circular Economy, the goal is to have plastic products designed for greater durability, reuse and high-quality recycling. The REDII aims to offer a solution for waste that cannot be mechanically recycled, but these types of waste will decrease in volume as increasing levels of plastics are recycled, according to ZWE.

Zero Waste Europe warns that plastic waste-to-fuel adoption could disincentivize the development of recyclable packaging and disadvantage mechanical recycling.The NGO points out that plastics that are difficult to recycle now could be redesigned to make them easier to recycle in the future. The phasing out of certain additives, the use of mono-materials and bans on specific plastics for specific product groups could help to change plastic products and make them suitable for mechanical recycling, it says.

“If these plastics are turned into fuel, the incentive to redesign plastic products will be lost. Instead, there will be a lock-in of an inferior technology that produces energy from fossil fuels,” ZWE stresses. 

Increased collection and design for reuse remain the priorities
ZWE's position is that increased collection of high-quality waste and design for reuse and recycling should remain the two priorities to increase recycling rates for plastics and ensure no plastic escapes the material loop via plastic-to-fuels.

“At the same time, chemical recycling technologies could be a complementary solution to mechanical recycling in dealing with waste streams that are too problematic, for example, due to their hazardous substances. Nevertheless, there is a risk of putting too much expectation on a solution whose potential is yet to be proven and this could delay the necessary efforts in the field of rethinking business models and material redesign,” ZWE tells PackagingInsights.

In conclusion, ZWE urges the European Commission to develop a set of robust environmental criteria that ensure the impacts of these fuels are accounted for properly.

By Joshua Poole