This is how that hypothetical ISCC-certified plastic cup we introduced at the beginning of this blog can say “30% recycled plastic” but physically contain 0 percent recycled plastic. See the section above (What are the problems with the plastics industry’s efforts to use mass balance for “chemically recycled” content?) and an in-depth article from ProPublica for many more concerns with this approach.
The plastics industry’s nonproportional (“free”) allocation credit scheme is highly problematic, not accurate, not transparent, misleading, and should be avoided at all costs.
The plastics industry claims that mass balance is already an established practice in use and accepted in other sectors such as for certified fair-trade products, but this is not a relevant comparison. First, the international Fairtrade guidelines conform to the ISO 22095 standard, which does not allow nonproportional allocation. In fact, the guidelines do not allow credit schemes at all and use the rolling average percent method for mass balance; further, actual average percentage must be included in the claim. The Fairtrade guidelines state that the term certified may not be used for claims about ingredients: “The word certified, when used in relation to an ingredient, implies physical traceability so it must not be used.” Note that the ISCC mass balance logo includes the word certified, which Fairtrade considers misleading for mass balance ingredients. The way Fairtrade applies mass balance is entirely different from the nonproportional credit schemes the plastics industry is proposing.
Second, there is no transformation of a Fairtrade product, such as cocoa, into fuels or other materials. If a label claims that “mass balance is used to match Fairtrade sourcing, total 30 percent,” then there would physically be that amount of Fairtrade cocoa existing in the supply chain; you couldn’t have this cocoa being burned to power the factory that makes chocolate. This is not the case with the processing of pyrolysis oil—some plastic is burned as fuel, so with nonproportional allocation, you can’t be sure that the amount of recycled feedstock even exists in the world, much less in a particular product.
In addition, while it is physically possible to have 100 percent Fairtrade cocoa, it is not possible to have plastic made from 100 percent pyrolysis oil. There is no physical limit on the percentage of Fairtrade cocoa that can be in a product, up to 100 percent, but it is not possible to increase the percentage of pyrolysis oil that goes into a refinery above 10 percent because of the contamination problems.
Finally, despite plastics industry claims of mass balance credit schemes contributing to a “circular economy,” “circular feedstocks,” or other such terms, this is not actually the case. While there are different definitions for a circular economy or circularity, all generally include one fundamental principle: There must be circular material loops (see the EPA definition). A circular material loop means that materials entering the market remain in their best and highest uses as long as possible through pathways such as reuse, remanufacturing, and recycling. Both proportional and nonproportional mass balances are inconsistent with circularity because they allow burning of recovered materials as fuels, removing them from the manufacturing cycle. Further, since there is no requirement with mass balance that the nonfuel products (such as chemicals, or even other types of plastic) made from waste plastic be recyclable or even be likely to be recycled themselves, these products would also exit the manufacturing cycle.
So, to be clear: The way the plastics industry is proposing to use mass balance is very different from the way it is currently used in other sectors. As stated earlier, the plastics industry’s credit schemes are effectively trying to turn the decades-old practice of mass balance accounting into mass imbalance, twisting the practice in ways that were never intended and deceiving the public in the process.
The bottom line is, if you are buying a product and see a logo like this (or something similar), what you see is not really what you get; it is likely tied to a highly polluting form of plastic waste disposal; and this is a product to avoid.
