Repsol · Companies & groups · ES
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…1 April 24th, Madrid Repsol’s position on the revision of the Packaging and Packaging Waste Regulation (PPWR) Repsol welcomes the opportunity to provide feedback on the European Commission’s initiative to review the Packaging and Packaging Waste Regulation (PPWR) aiming to support the circular economy by boosting the use of recycled materials instead of primary raw materials, reducing our dependencies on raw materials and fossil fuels and contributing to achieving climate neutrality by 2050. However, we believe the following points should be taken into account in order to ensure the development and quick ramp up of all recycling technologies which will allow the achievement of the targets: • Chemical recycling and mass balance approach Chemical recycling technologies should be considered recycling at the same level as mechanical recycling in the measures that are implemented.
…should be considered recycling at the same level as mechanical recycling in the measures that are implemented. Chemical recycling allows the recovery of high-value streams from plastic waste that cannot be collected or treated by mechanical means. Those streams can be converted into feedstock for the petrochemical to produce new chemicals including plastics Chemical recycling technologies, in a complementary way to mechanical recycling technologies, will play a fundamental role in the transition towards the circular economy, since they reduce the amount of plastic waste, and improve the efficiency in the use of waste. With chemical recycling, it is possible to recover plastic waste where mechanical recycling is not technically or economically viable, avoiding its incineration or landfill.
…waste where mechanical recycling is not technically or economically viable, avoiding its incineration or landfill. In addition, it allows the production of quality plastics equivalent to those produced with virgin raw material, so they can be used in food contact or in Healthcare, it reduces the use of fossil raw materials and contributes to the reduction of CO2 emissions. One of the main barriers to scale-up chemical recycling technologies is uncertainty about the method for calculating the recycled content of plastics. The current PPWR proposal indicates that the calculation rules for recycled content will be set by an implementing act by 31 December 2026, as per Article 7 (7). However, it is imperative to have a clear methodology in place as soon as possible, in order to provide legal certainty for investments in new recycling facilities or working on scaling up.
…as possible, in order to provide legal certainty for investments in new recycling facilities or working on scaling up. The same goes for the economic providers to ensure compliance with the targets set in this legislation. To encourage chemical recycling development and scaling up, it is necessary to recognize this technology in the calculation of recycled plastic, for which compatible Ref. Ares(2023)2891031 - 24/04/2023 2 metrics must be applied for the calculation of recycled plastic with the acceptance of the Mass Balance approach, a trustworthy chain custody model (ISO 22095-20201) that allows fossil raw materials to be easily replaced in existing production infrastructures by recycled feedstocks, calculating and verifying the amount of recycled content allocated to products.
…infrastructures by recycled feedstocks, calculating and verifying the amount of recycled content allocated to products. It is important to be able to leverage existing infrastructure to allow co-feeding of the recycled feedstock, replacing part of the virgin fossil-sourced feedstock. This is also because it would not be feasible to build an entirely new stand-alone infrastructure for producing plastics solely from recycled waste since it would take years to construct new manufacturing plants with billions in costs and high climate footprint. • Design for recycling: technological neutrality for recyclability requirements It is important that the recyclability requirements remain technology-neutral.
…for recyclability requirements It is important that the recyclability requirements remain technology-neutral. While not yet specified in the proposal, the assessment of recyclability should consider the materials that can be recycled through all recycling pathways, including chemical recycling technologies. Recycling technologies are in continuous evolution and development, so that waste that is difficult to recycle today may have a technological solution in the near future. Therefore, it is convenient to contemplate in the proposal a continuous adaptation to technological progress. 1 ISO 22095:2020 “Chain of custody — General terminology and models”.