The UK government is seeking views on whether to adopt a mass balance approach for chemically recycled plastic in the Plastic Packaging Tax (PPT).
The consultation document seeks views on allowing a mass balance approach for the allocation of chemically recycled plastic to plastic packaging and the controls and standards that would maintain the integrity of the PPT.
The document also explores views on the mass balance approach, mass balance models and the use of certification schemes to track recycled content through the plastics value chain.
When the government announced the consultation earlier this year, HM Treasury said a “mass balance approach” for PPT is a way to calculate the recycled content in packaging made from chemically recycled plastic, so it can contribute to the 30% recycled content threshold above which no tax is due.
Chemical recycling breaks down plastic waste to a molecular level to produce feedstock which can be used to produce new plastic.
Mass balance methodology is the only chain of custody method that will enable the chemical recycling industry to grow.
The consultation also seeks views on if chemically recycled plastic using a mass balance approach is likely to meet the regulatory requirements for the immediate packaging of human medicines.
Currently, the immediate packaging of licensed human medicines is exempt from the PPT because, the HMRC says, regulatory requirements and necessary testing make it “very difficult” for manufacturers to use recycled plastic.
The government says its seeking views on the immediate packaging of human medicines as chemical recycling can produce recycled plastic that is “indistinguishable from virgin plastic”. It continues that this means the justification for the exemption may be diminished over time.
The level of mass balance is the system boundary or geographical area a mass balance approach calculation can be applied to. This can be at batch level, site level and group level (also known as company level).
In the document, the HMRC says the batch level calculation provides the “strongest possible physical link” between the recycled feedstock inputs and outputs and potentially reduces both the risk of false claims of relief from the tax and greenwashing.
The lack of clarity to date has prevented companies from investing in the UK and some have looked elsewhere to build facilities.
Among the questions in the document are if respondents agree it’s possible to determine actual recycled content in products using the outputs of chemical recycling processes which produce a polymer. As well as how should chemical recycling be defined to use a mass balance approach for PPT.
In response to the consultation’s announcement, the British Plastics Federation (BPF), said: “Mass balance methodology is the only chain of custody method that will enable the chemical recycling industry to grow, which will in turn maximise the amount of plastic the UK is able to recycle.
“The lack of clarity to date has prevented companies from investing in the UK and some have looked elsewhere to build facilities. To increase the UK’s recycling rate, reduce the country’s reliance on exporting waste and achieve net zero carbon by 2050, it is vital that there is significant investment in recycling infrastructure.”
