While this report represents the latest publication found on taxonomy implications on recycling activities, it should be noted that the document does not have policy implications and is not an official EU Commission document.

### 4) Regulation in Japan

According to the Basic Law for Establishing the Recycling-based Society, the following order of priority was specified for the processing of recyclable resources in 2000: (1) generation control, (2) reuse, (3) recycling, (4) thermal recovery, and (5) appropriate disposal.<fnref n="305" />

This is complemented by the amendment to the Waste Disposal Law on May 2005 which states that "first, emission of waste plastic should be reduced, after which recycling should be promoted; any remaining waste plastic should not go to landfill as it is suitable for use in thermal recovery".<fnref n="306" />

The Law for Promotion of Sorted Collection and Recycling of Containers and Packaging (known as the Containers and Packaging Recycling Law) was put in force in April 2000 and was amended in 2006. It aims to promote recycling and reduce the amount of container and packaging waste produced by households. Businesses, consumers, and municipalities are required to contribute to reducing emissions and recycling waste. Under the amendment in 2006, the emission reductions are promoted as well as high quality sorted collections, the PET bottle category was modified to include containers such as noodle broth bottles.

The Containers and Packaging Recycling Law recognizes the following recycling processes:

* Material (mechanical) recycling

* Chemical (feedstock) recycling (which includes monomerization, liquefaction, use as a blast furnace reducing agent, coke even chemical feedstock recycling, conversion to chemical feedstock by gasification)

* Energy recovery (thermal recycling) (liquefaction, gasification)

Refuse Derived Fuels<fnref n="307" /> (RDF) and other forms of energy recovery were also included with some limitations in the amendment in 2006.<fnref n="308" />

#### a. Main regulatory and fiscal situations applicable to recycling plants

*Please note there is a lack of available information on this topic.*

Based on the article 15-8 of the Waste management and Public Cleansing Law in 1970, "In each fiscal year, a center shall prepare an operational plan and a budgetary statement of income and expenditure and submit them to the Minister of the Environment in accordance with the Ordinance of the Ministry of the Environment. To revise its operational plan, the center shall prepare a revised operational plan and a revised income and expenditure budget and submit them to the Minister of the Environment. After the end of each fiscal year, a center shall prepare an operation report and a year-end income and expenditure report and submit them to the Minister of the Environment in accordance with the Ordinance of the Ministry of the Environment."<fnref n="309" />

A "Waste Treatment Facility Development Plan" (FY 2018-22) which aims at establishing waste treatment facilities that include measures to prevent global warming and promote energy production was also approved by the Japanese cabinet in June 2016.<fnref n="310" />

<footnote n="305">³⁰⁵ http://www.env.go.jp/recycle/low-e.html</footnote>

<footnote n="306">³⁰⁶ https://www.pwmi.or.jp/ei/plastic_recycling_2019.pdf</footnote>

<footnote n="307">³⁰⁷ Refuse Derived Fuels (RDF): solid fuel made from burnable waste, plastic waste, etc.</footnote>

<footnote n="308">³⁰⁸ https://www.pwmi.or.jp/ei/plastic_recycling_2019.pdf</footnote>

<footnote n="309">³⁰⁹ https://www.env.go.jp/en/recycle/basel conv/files/Waste Management and Public Cleansing.pdf</footnote>

<footnote n="310">³¹⁰ https://www.pwmi.or.jp/ei/plastic_recycling_2019.pdf</footnote>
### b. Opportunity to use recycled resins for food-contact applications after approval by competent authorities

The food grade regulatory framework for recycled plastics in food packaging is based on the Food Sanitation Act of 1947, the positive list system for food packaging materials developed by the Ministry of Health, Labor and Welfare (MHLW) and the voluntary standards to ensure the baseline for safety of food-contact materials from industrial hygienic associations (e.g., Japan Hygienic Olefin and Styrene Plastics Association - JHOSPA).

Some guidelines for use of recycled plastics in food contact articles were published by MHLW in May 2012 and specified that:

* post-consumer plastic should be from the food contact use in principle and be collected separately

* this plastic could be recycled via chemical, physical reprocessing or via a new technology (no further detail was provided)

* the recycled plastics have to be verified for safety including validation for material and barrier as well as material and/or migration testing for example.<fnref n="311" />

Simultaneously, the Food Safety Commission of Japan (FSCJ), established as a part of Japan's Cabinet Office in July 2003, has implemented science-based risk assessment of food and risk communication about the results of the assessments. This is independent from risk management organizations (Ministry of Agriculture, Forestry and Fisheries (MAFF), Ministry of Health, Labor and Welfare (MHLW), Ministry of Environment (MOE), Consumer Affairs Agency (CAA)).<fnref n="312" />

Some recycled materials have already been approved for food-contact applications such as the following examples:

* Teijin Ltd. technology developed a process which used ethylene glycol and methanol to break PET down into DMT. After improvement, the technology allowed to break PET bottles down from DMT to PTA. The main goal was the production of textiles and films. Teijin started operation of a facility in 2003. The Japanese Food Safety Commission considered the resin produced was suitable for use in food containers in 2004. With the approval of the Ministry of Health, Labor and Welfare, the B-to-B production started in April but was withdrawn by Teijin Fibre due to a shortage in raw materials (i.e., significant increase in the export of waste PET bottles).<fnref n="313" />

* The chemically recycled PET from JEPLAN BRING Technology™ will be used by Kao Corporation for their cosmetic bottle containers starting in June 2021. The high-quality r-PET has received the certification by the Food Safety Commission of Japan, which is part of the Cabinet Office, for use in food containers.<fnref n="314" />

### c. Acceptability of the implementation of a mass balance approach

Please note there is a lack of available information on this topic.

In June 2021, BASF and Mitsui Chemicals announced the launch of a study to promote chemical recycling in Japan. Via its ChemCycling™ project, BASF will convert post-consumer plastic waste into pyrolysis oil thanks to their technology partners. This oil will serve as a feedstock for the production recycled materials via a mass balance approach. In Europe, products developed under this approach are already available in the market. Through their collaboration, BASF and Mitsui Chemicals will assess collaborative business models and options for the commercialization of chemical recycling in Japan.

Several measures have been developed by the Japanese government, notably its "Green Growth Strategy Through Achieving Carbon Neutrality" in December 2020 to reach sustainability goals by 2050. In this context, chemical recycling could be an option. Through their collaboration, BASF and Mitsui

<footnote n="311">³¹¹ https://www.worldpackaging.org/Uploads/SaveTheFood/Japan.pdf</footnote>

<footnote n="312">³¹² https://www.fsc.go.jp/english/what_we_do.html</footnote>

<footnote n="313">³¹³ https://www.pwmi.or.jp/ei/plastic_recycling_2019.pdf</footnote>

<footnote n="314">³¹⁴ https://www.kao.com/global/en/news/sustainability/2021/20210602-001/</footnote>
Chemicals will promote the development of chemical recycling in Japan and the efficient use of recycled materials and would like to accelerate the discussions on this topic with ministries, agencies, and industry groups.<fnref n="315" />

### d. Departure from the status of waste

Please note there is a lack of available information on this topic.

Below is presented the definition of "waste":

Based on the Article 2 from the Waste management and Public Cleansing Law in 1970, "the "waste" refers to refuse, bulky refuse, ashes, sludge, excreta, waste oil, waste acid and alkali, carcasses and other filthy and unnecessary matter, which are in solid or liquid state (excluding radioactive waste and waste polluted by radioactivity)" and ""municipal solid waste" refers to waste other than industrial waste".<fnref n="316" />

Based on the Act on the Promotion of Sorted Collection and Recycling of Containers and Packaging (Act No. 102 of June 16, 1995), "the term "waste containers and packaging" as used in this Act shall mean containers and packaging which have become municipal solid waste (meaning municipal solid waste prescribed in Article 2, paragraph 2 of the Waste Management and Public Cleaning Act (Act No. 137 of 1970; hereinafter referred to as the "Waste Management Act"); the same shall apply hereafter)."<fnref n="317" />

### e. Qualification of a recycled state

Please note there is a lack of available information on this topic.

#### Qualification of production tools and qualification of products

Based on the definition from the 3R (Reduce, Reuse, Recycle) initiative launch in 2000, "Recycle" refers to material recycling and "recyclable resources" should be used as raw materials to develop new products.<fnref n="318" /> This definition is in line with the Act on the Promotion of Effective Utilization of Resources in 1991, which states: "the term "Recycling" as used in this Act shall mean to change the condition of the whole or part of such Used Products, etc. that are useful, so as to make them available as Recyclable Resources or Reusable Parts" and "the term "Recyclable Resources" as used in this Act shall mean such Used Products, etc. or By-products that are useful and are available or can be made available as raw materials."<fnref n="319" />

Toray Group developed recycled PET/ABS and PC/ABS alloy compounds made from plastic waste (process not detailed, probably reformulation and compounding). The group applied for the ISO 14021 and EU EN15343 recycled plastics verification, and US EPEAT standards under the IEEE 1680 and UL 110, for the post-consumer recycled PET/ABS and PC/ABS alloy compounds. Inspections and on-site inspections of Toray's factories and its recycled-materials suppliers were conducted by TÜV Rheinland Japan, Shenzhen, and Taiwan to ensure that the product complies with the standards in terms of percentage of recycled materials and limits on hazardous substances. Toray Group products were granted the TÜV Rheinland New Test Mark: Recycled Materials in December 2015.<fnref n="320" />

However, no further information was found on the certification of chemically recycled materials.

<footnote n="315">³¹⁵ basf mitsui chemicals chemcycling.html</footnote>

<footnote n="316">³¹⁶ WASTE MANAGEMENT AND PUBLIC CLEANSING LAW (env.go.jp)</footnote>

<footnote n="317">³¹⁷ <5461726F31332D97658AED95EF9195838A83548343834E838B964081698970> (meti.go.jp)</footnote>

<footnote n="318">³¹⁸ waste management recycling japan.pdf (eu-japan.eu) ; METI Ministry of Economy, Trade and Industry</footnote>

<footnote n="319">³¹⁹ <5461726F31332D8E918CB9974C8CF89798977091A390699640816989708CEA> (meti.go.jp)</footnote>

<footnote n="320">³²⁰ Staying On the Move: Toray Group Receives TÜV Rheinland's First Post-consumer Recycled Materials Verification | id | TÜV Rheinland (tuv.com)</footnote>
Based on our understanding, the material produced via pyrolysis/gasification is almost always used for energy applications in Japan (mentioned on the JCPRA website). In general, the potential use of the generated oil for plastic production is not mentioned. Only Nippon Steel indicated that the produced oil can be used as raw material for the manufacturing of plastics.<fnref n="321" />

Acknowledgement of pyrolysis oil as a recycled material when used to produce new polymers

Please note there is a lack of available information on this topic

## 5) Regulations in Europe, the USA and Japan - Key learnings

<table><thead><tr><th></th><th>Europe</th><th>USA</th><th>Japan</th></tr></thead><tbody><tr><th>Main regulatory and fiscal situations applicable to recycling plants</th><td><ul><li>Recycling plants are subjected to laws and taxations that traditionally apply to the general category of producers/manufacturers</li><li>Legislations on chemical and physico-chemical recycling are still being drafted on a European level</li><li>Numerous discussions ongoing on chemical and physico-chemical recycling (definition and applicability)</li></ul></td><td><ul><li>EPA counts several laws that every waste management facility must comply with (including the Resource Conservation and Recovery Act (RCRA)).</li><li>Dozens of American states have passed bills to support chemical recycling facilities</li></ul></td><td><ul><li>Facilities are subjected to the Waste management and Public Cleansing Law and Waste Treatment Facility Development Plan</li><li>Lack of information</li></ul></td></tr><tr><th>Opportunity to use recycled resins for food-contact applications</th><td><ul><li>Monomers and oligomers resulting from chemical depolymerization are subject to the same criteria as monomers manufactured by chemical synthesis, which are set by Regulation (EU) No 10/2011 on plastic materials and articles intended to come into contact with food</li><li>EFSA approval needed</li><li>Some hydrocarbon oils obtained from pyrolysis have been approved to be used in food-grade packaging</li></ul></td><td><ul><li>Recycling materials must comply with the requirements of Chapter 21 of the Code of Federal Regulations, which is reserved for rules of the FDA</li><li>Chemically recycled PET and PEN approved by FDA</li></ul></td><td><ul><li>Chemically recycled PET already approved by the Japanese Food Safety Commission and the Ministry of Health, Labor and Welfare</li></ul></td></tr><tr><th>Acceptability of the implementation of a mass balance approach</th><td><ul><li>No legal framework</li><li>Numerous discussions are ongoing on this topic</li><li>This approach is not accepted by the current regulation in France.</li></ul></td><td><ul><li>Mass balance approach not mentioned in the legislation, it seems not to be accepted</li></ul></td><td><ul><li>Lack of information</li></ul></td></tr></tbody></table>

<footnote n="321">³²¹ https://www.nipponsteel.com/en/csr/env/circulation/waste.html</footnote>
<table><caption>Table 23: Comparative table of the regulations in Europe, the USA and Japan (RECORD, 2022)</caption><tr><td>Departure from the status of waste</td><td><ul><li>Definition from the Waste Framework Directive 2008/98/EC</li><li>The adaptation of the EoW regulation to chemical and physico-chemical recycling is assumed to either be on hold (not progressing) or still under discussion</li></ul></td><td><ul><li>Post-consumer plastics reclassified in 17 states to consider the pyrolysis and gasification facilities as manufacturing facilities</li><li>Definitions of post-consumer waste may differ from one state to another</li></ul></td><td><ul><li>Definition of waste from Waste management and Public Cleansing Law</li><li>Lack of information on the departure from the status of waste</li></ul></td></tr><tr><td>Qualification of production tools and qualification of products</td><td><ul><li>Multiple certifications exist at a EU level to verify the production of tools and qualification products (Recycled Plastics Traceability Certification, EuCertPlast, REDcert, LNE / IPC, ...).</li></ul></td><td><ul><li>Post-consumer (PCR) resin certification (includes the mass balance approach)</li></ul></td><td><ul><li>TÜV Rheinland Japan certification</li></ul></td></tr><tr><td>Acknowledgement of pyrolysis oil as a recycled material when used to produce new polymers</td><td><ul><li>No official statement identified on this specific topic</li><li>Based on the definitions, it seems that pyrolysis oil could be considered as a recycled material only if it used for new polymers production (not for fuel applications)</li></ul></td><td><ul><li>The EPA is currently exploring the definition of recycling – no final decision has been made public</li><li>Numerous discussions ongoing on the acknowledgment of pyrolysis oils as recycled material when used to produce new polymers.</li></ul></td><td><ul><li>Lack of information</li></ul></td></tr></table>

## 6) Global Standards and Certifications

Aside from regional initiatives, global standards exist which can be used to certify recycling operations and outputs. The following paragraphs present some relevant standards that are applicable to recycled materials.

### a. ISCC PLUS 322 323

The International Sustainability & Carbon Certification (ISCC) system has created the ISCC PLUS certification. This type of standard can be used to certify bio (e.g., cotton, corn, etc.), bio-circular (e.g., forestry residues, tall oil, etc.), and circular economy materials (e.g., mixed plastic waste, end-of-life tires, etc.) and is applicable to all markets which are not regulated by the EU renewable energy or by fuel quality directive (for which a different certification named is ISCC EU used) (45). The ISCC PLUS can certify feedstock either through the mass balance approach or through physical segregation. In the first case, the standard ensures that the mass balance accounting respects a series of pre-established requirements. The second case consists of a chain of custody option (43). This standard is well aligned with relevant initiatives including: the Ellen McArthur's White Paper on the mass balance approach, Plastics Europe industry view paper on the mass balance approach, the American Chemistry Council principles for mass balance, and Cefics' position paper on chemical recycling. It additionally has validity

<footnote n="322">322 https://www.iscc-system.org/about/circular-economy/</footnote>

<footnote n="323">323 https://www.iscc-system.org/wp-content/uploads/2021/06/ISCC-for-Industrial-Applications_June.pdf</footnote>
on a global level (45). To certify the mass balance approach, the ISCC PLUS analyses the inputs, outputs, and losses of certified feedstock that occur during the process. Several organizations use this certification, some examples are presented below:

* Since 2019 this certificate is being used by SABIC to certify its circular polymers (PE and PP) produced with the Plastic Energy's TACOIL (pyrolysis oil)<fnref n="324" />. Eastman's glycolysis processing site is also ISCC PLUS certified, and so is its processing site for methanolysis which is expected to become operational by 2022³²⁵.

* The same certification has been accredited to RECENSO's chemical recycling technology Carboliq (catalytic pyrolysis)<fnref n="326" /> and to INEOS Olefins and Polymers USA (technology used/technology partner not specified)<fnref n="327" />.

The following claims on a product developed via a mass balance approach and ISCC PLUS certified can be done: "An equivalent amount of ISCC compliant material has been sourced", or "product from certified sources on a mass balance basis", or again "committing to". However, it is forbidden for these claims to refer to the physical characteristics of the product.

### b. RSB<fnref n="328" />

The RSB Global Advanced Products Certification is a worldwide certificate released by the Roundtable on Sustainable Biomaterials (RSB). The RSB is a member organization formed by multiple stakeholders who share the objective of achieving the UN's Sustainable Development Goals. The RSB Global Advanced Products Certification can be used to certify non-energy products within the chemicals and polymers industry. These products can fall within Category I - Bio-based products; Category II - Recycled content products; Category III - Bio-based or recycled fossil carbon mixed with fossil carbon products (this last category refers to the utilization of the mass balance approach)<fnref n="329" />. RSB openly supports chemical recycling (technology not specified) as a circular way to overcome the barriers of mechanical recycling<fnref n="330" />. Yet, to be certified, at least 25% of the virgin fossil feedstock over a 3 months-period needed to produce the certified product batch must be replaced by alternative feedstock<fnref n="331" />. After having been certified, recyclers can use the RSB certification logo on their products, stating that "This RSB compliant product leads to a x% substitution of fossil resources through waste recycling in the production system" or again that "Over its production lifecycle, this material provides x% greenhouse gas savings compared to a fossil fuel equivalent" <fnref n="332" />.

Several organizations use this certification, some examples are presented below:

* In December 2020, Plastic Energy received the RSB certification for their facility in Sevilla (processing plastic waste into pyrolysis oil via non-catalytic pyrolysis)<fnref n="333" />.

* Lactel's Montauban plant for the production of UHT milk bottles also received the RSB certification in April 2021. The bottles are produced in partnership with INEOS and integrating its circular polyethylene (HDPE) obtained from post-consumer recycled material. According to available information, a trial production of 140,000 milk bottles was conducted. These bottles proved to be compliant with food safety regulations and fully recyclable<fnref n="334" />.

<footnote n="324">³²⁴ https://www.iscc-system.org/cracking-the-problem-of-waste-plastics/</footnote>

<footnote n="325">³²⁵ https://www.iscc-system.org/wp-content/uploads/2020/06/Enabling-world-scale-advanced-circular-recycling-of-plastics-with-ISCC-PLUS.pdf</footnote>

<footnote n="326">³²⁶ https://www.openpr.com/news/2268254/sustainability-certificate-for-chemical-recycling</footnote>

<footnote n="327">³²⁷ https://www.cosmeticsandtoiletries.com/networking/news/company/INEOS-Receive-ISCC-PLUS-Certification-for-Advanced-Plastic-Recycling-574259841.html</footnote>

<footnote n="328">³²⁸ https://rsb.org/about/</footnote>

<footnote n="329">³²⁹ https://rsb.org/wp-content/uploads/2020/08/RSB-Guide-to-Certification-for-Advanced-Products.pdf</footnote>

<footnote n="330">³³⁰ https://rsb.org/wp-content/uploads/2020/07/Chemicals-and-Polymers-Report-WEB2.pdf</footnote>

<footnote n="331">³³¹ https://rsb.org/wp-content/uploads/2018/12/18-12-11_RSB-STD-02-001-v2.0-RSB-Standard-for-Advanced-Products.pdf</footnote>

<footnote n="332">³³² https://rsb.org/wp-content/uploads/2020/08/RSB-Guide-to-Certification-for-Advanced-Products.pdf</footnote>

<footnote n="333">³³³ https://plasticenergy.com/rsb_certification_sevilla/</footnote>

<footnote n="334">³³⁴ https://rsb.org/2021/06/01/ineos-and-lactel-partner-to-produce-the-worlds-first-hdpe-milk-bottles-from-advanced-recycling/</footnote>
### c. UL LCC

Through its UL 2809 - Environmental Claim Validation Procedure (ECVP) for Recycled Content certification, UL LCC certifies products based on the amount of recycled content in it. Recycled materials may include post-consumer and post-industrial recycled content, closed loop recycled content, and total recycled content<fnref n="335" />. The UL LCC has incorporated a mass balance approach which can be applied to both mechanical and chemical recycling<fnref n="336" />. By receiving this certification, companies can prove their environmental claims and protect themselves against greenwashing allegations. Being a global safety leader, UL LCC can certify companies worldwide<fnref n="337" />. In 2021, BASF received a UL certification for their chemically recycled Ultramid Cycled polymers (ChemCycling's non-catalytic pyrolysis output)<fnref n="338" />. No further details were found about other certified chemical recycling technologies.

### d. Recycled Claim Standard (RCS)<fnref n="339" /> and Global Recycled Standard (GRS)<fnref n="340" />

The Recycled Claim Standard and the Global Recycled Standard were created by Textile Exchange<fnref n="341" /> with the goal of increasing the amount of recycled materials used in products. Although initially meant to be used within the textile industry, the scope of these global standards has been widened to actors operating outside of this sector (no further information available specifying relevant sectors). The RCS is used for products that contain at least 5% certified recycled material free from any pollutant. The GRS is used to certify recycled content within products that contain a minimum of 20% of recycled material<fnref n="342" />. The GRS additionally includes a set of social and environmental requirements and chemical restrictions.<fnref n="343" /> To be certified through either standard, recycled materials must meet pre-established requirements across the whole supply chain. Yet, no further information has been found concerning the applicability of these standards to certify chemical recycling outputs. No examples of chemical technology developers that have obtained this certificate have been identified.

<footnote n="335">³³⁵ https://www.ul.com/services/recycled-content-validation</footnote>

<footnote n="336">³³⁶ https://www.ul.com/news/mass-balance-new-approach-calculating-recycled-content</footnote>

<footnote n="337">³³⁷ https://www.ul.com/services/recycled-content-validation</footnote>

<footnote n="338">³³⁸ https://chemengonline.com/basf-advances-chemical-recycling-portfolio-with-new-ul-validation/?printmode=1</footnote>

<footnote n="339">³³⁹ https://textileexchange.org/wp-content/uploads/2017/06/Recycled-Claim-Standard-v2.0.pdf</footnote>

<footnote n="340">³⁴⁰ https://cdn.scsglobalservices.com/files/program_documents/Global%20Recycled%20Standard%20%20FINAL.pdf</footnote>

<footnote n="341">³⁴¹ Global non-profit multi-stakeholder organisation (brands, retailers, suppliers, etc.) supporting the transition towards a more sustainable textile industry: https://textileexchange.org/.</footnote>

<footnote n="342">³⁴² https://textileexchange.org/standards/development-hub/grs-rcs-revision/</footnote>

<footnote n="343">³⁴³ http://www.cuc-china.net/uploadfile/infoPic/20131015114849409.pdf</footnote>
# XI. Synthesis of experts' opinion

## 1) Experts' point of view

### a. What are the main opportunities and constraints to chemical and physico-chemical recycling technologies and to their scaling up?

### Introduction (based on the literature review)

The bibliography review highlighted the different opportunities and discrepancies between the different chemical and physico-chemical recycling technologies.

Indeed, all **solvolysis technologies** are usually designed to handle mono-material waste streams, which necessary requires pretreatment steps to be implemented. The need for such pre-treatment steps is heightened by the fact that these processes demonstrate a relatively low tolerance for contaminants, which are thus to be removed beforehand. The nature of these steps highly depends on the feedstock, whose composition is key. Underestimating the importance of pre-sorting could be detrimental to the scaling-up of the technology. Nevertheless, **technology developers rarely elaborate on this subject and often claim that their technology does not necessitate any pre-sorting or pre-treatment step.**

These technologies produce monomers or chemical intermediaries that would have to be reintegrated in an existing polymerization chain and would thus require adapting conventional production processes to ensure that the waste is effectively recycled into a new polymer. Downstream steps are thus necessary to ensure the repolymerization of the material to its initial chemical form. However, **there are a lack of information and uncertainties about the nature and extent of such steps in the literature.**

The maturity level of solvolysis technologies is evaluated at the **development phase**, with some very specific methanolysis developers at a higher TRL (around 8 in the best cases).

On the contrary, **thermal treatment technologies** can usually handle multi-material waste streams, as long as they don't contain non-processable materials, such as PVC, PET or PU. Limited levels of contamination (with PVC, PET, etc.) could be tolerated depending on the considered technology developer process. These technologies are usually applied on polyolefins mix or specific polymers such as PS or PMMA. Pre-treatment steps would also be required in order to remove these components, but the feedstock concentration requirements would however be less stringent than solvolysis. Controversy, multiple downstream steps seem to be required to produce a recycled polymer from these technologies. Information about the nature and extent of these steps are however scarce in the literature. Issues arise in the case of pyrolysis oil, which has to be mixed with virgin oil. Indeed, the low level of available feedstock compared to the virgin amount of materials implies that the recycled material would be a small portion of the recycled material, with traceability issues. This would not be as problematic for other technologies, as the outcome does not need to be mixed with virgin material and thus can be differentiated in distinct polymerization lines. It would seem that, in PS or PMMA's cases, thermal processes going back to the monomer would need similar pretreatment and posttreatment steps as in solvolysis' case. The maturity level of thermal treatment technologies is higher compared to other chemical and physico-chemical recycling technologies, as the majority of the technologies studied have a TRL ranging from 5 to 8, with some having industrial capacities.

Similarly, **dissolution** is practically **suited to all types of thermoplastics**, even if it is mainly applied to PS, PVC, and polyolefins. This process can **treat mono-material contaminated streams**, and sometimes mixed plastics. Pre-sorting or pre-treatment are however often necessary, even if there is little information disclosed by developers or by literature on the subject. This chemical process has the advantage of almost not altering the chemical structure of the recovered polymer and targets either the polymer of choice or the impurities. It can thus be used as pre-treatment to dissolve impurities contained in a specific feedstock. The maturity level of dissolution technologies is evaluated at the **development phase**, with an average TRL of 5.

### Volumes of available feedstocks

#### POINTS OF AGREEMENT BETWEEN EXPERTS

Experts agree on the fact that a major challenge for chemical recyclers is to access **feedstock with sufficient volume**. Indeed, the feedstock targeted might be scarce and/or diffuse. The ease of accessing the feedstock will highly depend on the resin and on the requirements. Accessing a feedstock of specialty polymers in sufficient quantity might be challenging due to the geographical dissemination
of this resource. Yet the demand for such feedstock in the different industries will be less important than for commodity polymers.

Accessing enough commodity polymers feedstock is difficult due to different factors such as purity levels or concentration in the polymer of interest.

### Box 1: Specific examples raised by some experts on the quantity of feedstock available

In **specialty performance polymers' case, lower volumes are produced** than for commodity polymers. As a consequence, this means that:

- Collecting these materials at their end-of-life can be challenging.

- This aspect requires recycling processes to be more efficient while treating lower volumes. It may therefore be necessary to put an intermediate plant which will additionally sort sorting refusals containing specialty plastics.

- In order to increase waste volumes, there could be long-distance transport to reach the recycling plant.

Indeed, **feedstock volumes** is an issue as chemical recyclers are looking for a specific type of waste, meeting criteria such as **concentration in the targeted polymers**.

## Feedstock type

### POINTS OF AGREEMENT BETWEEN EXPERTS

Chemical and physico-chemical recycling technologies give more or less promising results depending on the feedstock that they treat. Indeed, most of the experts agree on the fact that, **to target a specific application, a suitable match between a specific process and a specific polymer is more likely to give adequate results.** Thus, depending on the polymers at hand, the chemical and physico-chemical recycling technology should be adapted.

Hence, knowing the exact composition of the feedstock is essential to evaluate what type of technology could be used, as no technology can treat all types of input. Additionally, some products cannot be mechanically recycled, such as multi-layered products, or printed and colored packaging, which means **there is a need for chemical and physico-chemical recycling technologies to be tolerant towards these products.** The case is similar for non-carbonaceous polymers for which depolymerization might result technically less challenging than incineration.

### Box 2: Specific examples shared by some experts on feedstock type

The following examples have been tackled by some experts:

- A stream of **PET** would give better results through a **depolymerization** reaction,

- A **PS** stream would be suited for **dissolution**. A more **contaminated** stream of PS could be treated through **high temperature** - catalytic or not - pyrolysis,

- A **polyolefin mix** will be better treated by **liquefaction** or **gasification**,

- **PE/PP flexible multilayer packaging**, which cannot currently be mechanically recycled, is a good feedstock for **pyrolysis** followed by **steam cracking**. Some experts agree on the fact that pyrolysis would however represent a small volume when compared to the steam cracker total capacity in Europe. Having such a low amount of recycled content in products could represent an issue when trying to sell the recycled material.

Thus, having a **homogeneous feedstock** is key in being able to feed a technology and meet the desired application characteristics. Yet, its **purity** might also be an issue as to the intended output quality.

## Purity of the feedstock

### POINTS OF AGREEMENT BETWEEN EXPERTS

A main well-known constraint of the chemical and physico-chemical recycling technologies lies in the purity of the feedstock. Indeed, most experts agree that **the prerequisite condition for a successful recycling process is the access to a feedstock with sufficient volumes and quality.** The recycler will then be influenced by the latter. Thus, the building of an entire value chain is key.
Indeed, depending on the feedstock contamination level, it can be recycled either via **mechanical recycling technologies** or through **chemical processes**. Contaminated plastics would have to be very well sorted and washed for the feedstock to be eligible for mechanical recycling. Not implementing these throughout steps would raise concerns on the quality of the recyclates that would be produced. They however come with non-negligible environmental impacts.

There are moreover consequent risks to be taken into account when recycling a contaminated stream. Firstly, the **economic viability is key**. A process that is efficient at pilot or demonstration scale might not be efficient at industrial scale. From an economic point of view, it might not make sense to process mixed and contaminated plastic waste if multiple costly purification steps are required.

Then, **the desired output has to be taken into account**. The type of output the recycler is aiming for should be adapted to the feedstock it can access, and the potential impurities incorporated in it.

Finally, treating contaminated plastics could lead to **corrosion of the equipment**, especially when halogenated compounds are present within the feedstock. Subsequently, either halogenated compounds should be removed before entering the recycling process or the unit should have been purposely built for treating waste containing these additives. The presence of halogenated compounds only represents an issue when the operating temperature is not high enough. In this case, options to treat contaminated waste are either gasification or incineration.

### Box 3: Specific examples shared by some experts on feedstock purity

The following examples on purity requirements by technology type have been tackled by some experts:

- Thermal treatment conversion processes are suitable to handle plastics, even if they are **mixed with other materials**, such as biomass for instance. However high levels of PVC in a feedstock dedicated to gasification would require minimizing chlorine at less than 10%,

- Dissolution, if applied to a PS feedstock, would typically require a **minimum of 90-95%** of PS in the feedstock,

- Depolymerization, when used on PET feedstock, would require a **minimum of 85% of PET**, except for enzymatic depolymerization. Indeed, enzymes are more selective than chemical catalysts. Even when treating mixed materials, they demonstrate a high selectivity and target a specific polymer. According to an expert, **enzymatic depolymerization could process about 80% of PET and 20% of impurities**. This would be an advantage when recycling textiles, for instance, as enzymes will be able to target PET despite the presence of multiple other materials, such as cotton or metal. However, this technology still requires prior removal of contaminating substances, due to CAPEX considerations, and to ensure that the recycled polymers will meet the technical requirements,

- **Enzymatic processes** can be highly selective in terms of feedstock composition. In the case of PET, these processes need a preparation step to turn PET from the crystallized to the amorphous form, as enzymes react to amorphous PET. This would not be required for solvolysis processes that do not involve the use of enzymes,

- Technologies such as plasma-based gasifiers can be used to treat **refractory waste**.

Moreover, it should be considered that buyers of specialty polymers use these materials because their **properties are superior to those of other plastics**. In the case of PMMA, buyers are looking for transparency and optical quality. In some cases, such high purity is not achievable through recycling processes or requires high energy consumption. These factors could represent a hindrance for chemical and physico-chemical recycling.

Thus, depending on the **level of impurities the feedstock contains**, in depth pre-processing might be needed to ensure it meets the technology requirements.
## Pre-treatment and preparation of the feedstock

### POINTS OF AGREEMENT BETWEEN EXPERTS

Numerous start-ups claim that their process does not require feedstock preparation (or limited pre-treatment). However, the experts agreed on the fact that **feedstock has to be prepared and impurities have to be removed**, for economic and quality reasons. The alternative would be to undergo a series of purification steps after the chemical reaction, which is likely to be more costly and may have a higher impact from an LCA perspective.

Once again, the pre-treatment steps highly depend on the chemical and physico-chemical recycling technology chosen.

The first pre-treatment step usually needed consists in **pre-sorting**. Indeed, as mentioned previously, depolymerization and purification processes require a high concentration of the targeted polymer. Consequently, upstream value chain players are entailed to **previously sort feedstocks by resin**.

Afterwards, chemical and physico-chemical recycling technologies would require the **removal of contraindicated contaminants**. The selection of the appropriate preparation steps highly depends on the initial composition of the waste and the recycling technology to be used afterwards. This implies that **better feedstock characterization is needed** to determine which components could be a burden to the selected recycling technology.

Preparation steps may involve **size reduction** (such as crushing), sometimes **washing, cleaning**, and low temperature treatment or adsorption to remove halides<fnref n="344" /> from the feedstock.

When evaluating the need for feedstock preparation steps, **geography** should also be considered. Some countries have already been putting in place programs for improving plastics' collection, enhanced sorting or the separation of bags for the collection of hard to recycle waste. This aspect has an impact on feedstock's quality.

Several players in the waste management and mechanical recycling industries already own **sorting equipment**. Many chemical and physico-chemical recycling technology developers have either invested in their own sorting equipment or have already created partnerships with companies that do. The most appropriate actor to carry out these steps depends on the type of preparation required and the desired target products. In general, from a logistics and regulatory perspective, it is **often preferable to conduct feedstock preparation phases on the waste site**. Some chemical recyclers who use dissolution or solvolysis, usually carry out additional sorting and pre-treatment of waste on their own site to make sure the feedstock meets their specific requirements.

### Box 4: Specific examples shared by some experts on feedstock contaminants removal

The following examples on feedstock contaminants removal have been tackled by some experts:

- **Solvolysis** has the advantage of allowing for specific separation of a targeted polymer, as long as the contaminants are not impacted the same way as the polymer. In theory they could thus be removed.

- As for **pyrolysis**, removal or separation of contaminants is necessary when these compounds would lead to an undesired output composition. For instance, the presence of aromatics in the feedstock could lead to high level of aromatics in the output, which is unwanted in a cracker feedstock. Even if higher feedstock flexibility could be allowed in the case the process used is catalytic or high temperature pyrolysis, pre-treatment of feedstock is systematically necessary to remove contaminants such as Cl, Br, etc.

- To an expert's mind, **dissolution** could also be considered as a pre-treatment for both mechanical and chemical and physico-chemical recycling and could be used to make the waste more suited for a specific recycling technology.

<footnote n="344">³⁴⁴ Chemical compound consisting of a bond between a halogen atom and a less electronic atom (of the general formula X = F, Cl, Br or I)</footnote>
Thus, the different pre-treatment applied to the feedstock will consequently affect the **output and its quality**.

## Outputs

### POINTS OF AGREEMENT BETWEEN EXPERTS

The **pre-treatment steps and the level of residual contaminants** are key factors in the yield and quality of the output obtained. Indeed, the output can usually be produced in different grades: the monomer grade and the chemical grade. The **presence of impurities in the output could affect the molecular weight** and the **properties of the polymer** and consequently highly impact the final application.

The outputs produced are also dependent on the **operating conditions** (e.g., temperature, use of a catalyst).

### Box 5: Specific examples shared by some experts on the output produced

According to an expert, more forgiving pyrolysis technologies, which are not producing steam cracking feedstock, are a **preferable solution** than solely focusing on naphtha production. Indeed, they entail less restrictions on the initial feedstock composition, as the main issues could be solved either via a catalytic step or through pyrolysis and specific separation conditions. Thus, the output produced would be more homogenous and less sensitive to impurities and contaminants. This product **could afterwards be mixed with the steam crackers' output**. These technologies would avoid too stringent specifications on the feedstock (which are necessary in order to produce a cracker's feed). Indeed, these specifications usually are similar to those of mechanical recycling, which should be preferred to pyrolysis in an environmental point of view.

An expert believes that efficiency and yields of pyrolysis oils processed into a cracker are completely different from those of naphtha. A key parameter to avoid variability is **the homogeneity of the waste feedstock** as upgrading of the final product is more troublesome. A cracker could theoretically contain from 1 to 10% of pyrolysis oil. This would require the use of a mass balance approach.

An example mentioned regarding operating conditions was the maximization of the **production of monomers**, in the case of pyrolysis using **high temperature**. The addition of a catalyst to a high temperature pyrolysis process will generally produce a high concentration of aromatics mixed with olefins. Hence, the higher the operating temperature is, **the more the product will resemble the steam cracker output**.

Similarly, in enzymatic depolymerization, factors such as **temperature range, solubility and concentration effect on the presence of organic and metal inhibitors**, could have an impact on enzymes' activity and thus on the final yield of the reaction.

## Output conversion

### POINTS OF AGREEMENT BETWEEN EXPERTS

Outputs of chemical and physico-chemical recycling processes might need **further processing**, depending on the requirements for the final product. Indeed, impurities can represent an issue for downstream applications, especially if a high-quality material is required. Yet, it seems the easiest way to deal with impurities would be to remove them during upstream steps. Otherwise, downstream steps can include separation of gases, distillation, selective aromatics removal by distillation or adsorption in pyrolysis' case. In many cases, existing facilities could be adapted so that they could carry out downstream steps.

To avoid these steps, there **may be a need to adjust operating conditions**, either via the use of a catalyst that would steer the output composition towards the targeted products, or by applying specific temperature and pressure conditions.

Another aspect to consider before converting the output is its **chemical composition**.
### Box 6: Specific examples shared by some experts on the output conversion

Adjusting the operating conditions in pyrolysis' case could mean using high temperature that would maximize the production of monomers. These techniques could avoid going through a steam cracker, as the composition of the final oil would be similar to a cracker's output.

In the case of pyrolysis, the oil produced needs to undergo several transformation steps before reinterring a virgin value chain. Indeed, to an expert's opinion, the **output of standard pyrolysis is not suited as steam cracker feedstock**. Any substances other than carbon and hydrogen can be detrimental to the equipment or the output through corrosion, unexpected reactions, and catalyst poisoning. As an example, unsaturated compounds are not allowed in crackers and, on the other hand, having a pyrolysis oil containing a wide range of hydrocarbons is not optimal. Hence, there is a need to ensure that the **chemical composition of oils**, including chains length, matches the **steam cracker requirements**. Usually, these requirements include high content in olefins, which means an initial feedstock rich in polyolefins and the previous removal of chlorine and bromine. A way to improve the quality of the pyrolysis oil would be through a series of intermediate refining steps.

## Operating risks

### POINTS OF AGREEMENT BETWEEN EXPERTS

Handling hydrocarbons involves a series of risks. Developers have to be cautious enough to take all possible risks into account and adopt preventive measures.

Indeed, the variability of the feedstock mentioned earlier leads consequently to variability in operations. The more the plastic is contaminated, the more **sanitary risks** are involved in its treatment. This risk would be affected by whether the pretreatment of waste is carried out on the recycling site or not. Moreover, unwanted materials in the feedstock (e.g., undesired polymer, glass, metal, or stone) would lead to the disruption of the process, which would have to be **continuously adapted** if the feedstock composition changes from batch to batch. This might be a source of inefficiency in operations.

Another major risk of thermal treatments lies in the **volume of the produced gas and the storage of flammable materials**. Safety precautions should be taken to avoid any incident.

Treatment of wastewater and disposal of by-products to avoid soil contamination should be implemented to avoid any **pollution of the surrounding environment**. The developers should also be prepared to manage unforeseen emissions from hazardous gases and liquids.

The way all of these risks are managed depends on the materials and the technology used. Hazard and Operability Studies (HAZOPs) are required throughout different steps of the value chain.

### Box 7: Specific points raised by some experts on operating risks

One expert believed that there is **often a fear of chemical and physico-chemical recycling processes being polluting or toxic from a consumer perspective**. However, it should be reminded that these plants are regulated under the same industrial directives as other processes (the Industrial Emissions Directive) and thus mitigation measures have to be implemented to comply with the regulation.

The presence of **odors and aromatics in pyrolysis oils** could also represent a risk in the utilization of this oil. The composition of the oil has to be monitored closely and steered towards an acceptable composition.

## Technology readiness level

### POINTS OF AGREEMENT BETWEEN EXPERTS

Most of the experts agree on the limitations of the TRL indicator. Indeed, a **specific TRL should not be generalized to a family of technologies**, as there are significant differences from one technology
developer to another. The TRL should be assessed for each technology. Moreover, the **TRL should not necessarily be linked to capacity**. For solvolysis processes, the capacity required to achieve commercial scale will be much lower than that for gasification. Finally, it would be **more appropriate to consider the maturity of the technology**, which includes TRL, but also the size and number of units operated by a technology developer.

The experts evaluate the TRL of the different technologies, as represented on Figure 22 below. These figures are given as an **indication**. They have been **estimated by some experts** and thus **are not necessarily totally aligned with other studies**. For informative and comparability purposes, they have been compared with Closed Loop's Partners' indications. The ranges indicated below depend on each technology.

<figure><img src="image_50.png" /></figure>

*CLP: Closed Loop Partners

**Few pyrolysis and gasification plants are ready for treating only mixed plastic waste (for plastic-to-plastic applications). As an example, many gasification plants operate using biomass or a mixture of biomass and plastics waste. Therefore, gasification should not be considered as TRL 9 (except for Enerkem). The actual TRL of the whole value chain for gasification, from plastic-to-plastic, is estimated around 6.

<caption>Figure 18: Evaluation of chemical and physico-chemical recycling technologies' TRL by some experts (RECORD, 2022)</caption>

The experts also evaluate the TRL of the chemical and physico-chemical recycling of different polymers, as represented on Figure 19.
<figure><img src="image_51.png" /></figure>

<caption>Figure 19: Evaluation of the chemical and physico-chemical recycling technologies' TRL depending on the treated polymer by some experts (RECORD, 2022)</caption>

### Box 8: Specific examples raised by some experts on technology development by polymer

The following examples on the chemical recycling of specific polymers have been tackled by some experts:

- There are currently numerous PET chemical recycling technologies operated at a **demonstration scale**. Examples include Carbios, Loop Industries, Ioniqa. JEPLAN, Eastman and Polygenta Technologies are at commercial scale.

- Commercial scale plants for the recycling of PMMA via gasification and pyrolysis already exist.

- Aquafil already has a PA commercial plant and has been selling its recycled products for a few years.

## Perspectives of evolution

### POINTS OF AGREEMENT BETWEEN EXPERTS

The experts anticipated the evolution of chemical and physico-chemical recycling technologies to be fueled or, at the opposite, constrained by different factors such as regulations, eco-design trends, collection models improvements and sorting or recycling progress.

Indeed, on the **regulatory** side, future legislations on plastics will impact the composition of waste and its available volumes. This trend can already be observed nowadays. Indeed, due to China ban on waste imports, some of the waste that used to be exported now remains in the EU.

It is also likely that **sorting and mechanical recycling technologies will improve** in the future. This progress is expected to impact the volumes of available waste for chemical recyclers.

Moreover, **eco-design efforts** are currently being made to facilitate recycling of plastic products put on the market. The strong push from the packaging industry (flexible and rigid) to go towards PE, PP, and PET, will increase the share of these materials found in waste. The industry is already evolving to ensure better sorting and recycling of materials put on the market. Thus, it is increasingly **moving away from multi-layered multi-material packaging**. Having access to better quality feedstocks will not only favor mechanical recyclers, but it will also be an advantage for chemical recyclers. The economic viability of their processes will indeed be improved by reducing the need for additional sorting and purification.

Additionally, to this temporal variability, experts find it very likely that a geographical variability will emerge. Indeed, due to the **geographical variability** of the feedstock mentioned earlier, it can be expected that, in the future, **aggregation models** depending on existing collection infrastructure, which also depends on location, will be developed.

<footnote>*Deloitte deduction from the expert's affirmation of existing plants at a commercial scale via gasification and pyrolysis.</footnote>
## b. What is the current and future regulatory context in the USA, EU, and Japan?

### Introduction (based on the literature review)

It can be observed that the regulatory framework on chemical and physico-chemical recycling differs between the considered geographical areas. Indeed, in the USA, as of January 2022, there are **no federal laws** that specifically refer to chemical and physico-chemical recycling and **bills are passed on a state-level**, either to promote or hinder chemical recycling technologies. As for food-grade applications, the FDA has already issued a non-objection on the **suitability of chemical recycling processes for producing post-consumer recycled plastic** to be used in the manufacturing of food-contact articles for several companies. Several states in the US are also considering implementing recycled contents requirements. There is however **no mention if a mass balance approach would be accepted**. Some states have also requalified the waste status, using terminologies such as "non-solid waste", "recovered materials" or "raw materials for manufacturing".

In the European Union, although chemical and physico-chemical recycling seems in some cases to fall under the legal definition of "recycling" on a European level (excluding plastic-to-fuel applications), no regulations nor amendments specific to these technologies have been published yet. Waste management legislation includes directives related to the **classification of waste, to trans-boundary transfers of waste, and to transitions from waste to product status**. Moreover, **food-contact regulation only applies to mechanical recycling** technologies and there are uncertainties about whether or not chemical and physico-chemical recycling technologies' outputs could be certified as food-grade materials. Moreover, **no legislation nor harmonized standard regulating the mass balance approach** has yet been approved on a European level.

As for Japanese regulations, there are a lack of information and **uncertainties on the topics' studied and regulations on the subject of mass balance**, chemical and physico-chemical recycling facilities, the qualification of a "recycled state", the end of waste status. It has to be noted that several chemically recycled products have already been approved for food-contact applications (chemically recycled PET from JEPLAN technology for example).

### New legislations and amendments of current regulations expected

#### POINTS OF AGREEMENT BETWEEN EXPERTS

In the regions of interest, **regulations are not yet operational on the subject of chemical and physico-chemical recycling**. Indeed, they have usually been developed for mechanical recycling and are **not yet up to date on chemical and physico-chemical recycling technologies**. There are also discrepancies between the different regions.

Thus, a clear regulatory framework is needed, with harmonized definitions (if possible). Indeed, strong regulations and financial incentives for chemical and physico-chemical recycling routes will be necessary to support the industry. It has to be noted that the lack of clear regulations presents a significant risk for technology developers.

<figure><img src="image_52.png" /><figcaption>Box 9: Specific examples for the EU</figcaption></figure>

Within the EU, legislation on chemical and physico-chemical recycling is likely to consist of an **adaptation of existing regulations** rather than on the development of new rules. Regulations and Directives that might be subject to

<figure><img src="image_53.png" /><figcaption>Box 10: Specific examples for the USA</figcaption></figure>

As for the USA, fourteen states have passed a legislation defining advanced (chemical) recycling technologies as manufacturing technologies. They are therefore not

<figure><img src="image_54.png" /><figcaption>Box 11: Specific examples for Japan</figcaption></figure>

In Japan, household waste sorting is much more advanced than in the EU and the USA. Already 20 years ago, consumers were required to operate a thorough pre-sorting of their waste. In this condition, it is much easier to develop recycling
modification are represented on Figure 20 below.

Regarding the REACH regulation, the experts believe that mechanical recycling products are exempted from this legislation. The exemption was made at a time when this type of recycling was dominating. As for chemical and physico-chemical recycling, the REACH regulation only exempts the recycled monomers that comply with very strict criteria. These criteria require for the virgin material to be already REACH registered, for the recycling operation to have been done in Europe (or at least the paperwork to have been drafted in the EU), and for a high-quality output product (the toxicity level has to be proven as identical to the virgin one). It has to be noted that certain chemical intermediaries (such as BHET) are currently not REACH registered. According to experts, some adjustments should be made to the REACH legislation application for chemical and physico-chemical recycling, especially due to the high costs associated with the registration process. Moreover, having a product that is REACH registered does not guarantee it has passed the end of waste regulation requirements. A connection should therefore be made between the End-of-Waste and the REACH regulations.

Moreover, Zero Waste Europe is building a case for making a distinction between chemical recycling and recovery from a regulatory perspective. For instance, pre-treatment processes should not be considered as recycling but as recovery.

regulated as waste disposal. As a consequence, this regulation excludes the feedstock used for these processes from the definition of solid waste. Two states (Maryland and Oregon) have taken the opposite path by proposing a **ban on chemical recycling**, which was however defeated.

The American Chemistry Council has advanced a proposal to **define terms** such as advanced recycling processes, products, feedstocks, or mass balance, on a federal rather than on a state level, as part of the “5 Actions for Sustainable Change”<fnref n="345" />. The lack of **definitions currently makes the industry vulnerable**. As an example, the Environmental Protection Agency has put forward an advanced notice of proposed rulemaking to perhaps classify the chemical recycling technologies as solid waste incineration under the Clean Air Act<fnref n="346" />.

technologies. This shows that **easy implementations could be done from a legislative point of view**. As an example, colored PET bottles could be prohibited to facilitate recycling given that the product's color only has a marketing value but has no value for consumers.

<footnote n="345">³⁴⁵ 5 actions for sustainable change, American Chemistry Council, Action #2</footnote>

<footnote n="346">³⁴⁶ U.S. EPA weighs regulation of chemical recycling | Reuters</footnote>
<figure><img src="image_55.png" /><figcaption>Figure 20: European regulations and directives expected to be reviewed according to some experts (RECORD, 2022)</figcaption></figure>

## Mass balance approach

### POINTS OF AGREEMENT BETWEEN EXPERTS

The experts all share certain perspectives, notably the fact that the lack of regulation on mass balance represents an issue for big brands' credibility and for the value their products delivered to customers. Whenever there is a disconnection between the input and the output of the process (for instance pyrolysis oil obtained on one site but turned into products at a different site), traceability becomes a challenge. To their minds, improved physical traceability methods would be preferable to a mass balance approach. As there are no such methodologies currently, the use of mass balance is debatable. However, if mass balance is necessary to develop chemical recycling, then its application has to be regulated and made understandable for customers. Moreover, the implementation of a mass balance approach should only be considered as a transition phase, given this is the main available solution today.

The experts also agree on the fact that the mass balance approach can be misleading and confuse consumers when it comes to communication claims. Clear communication is needed to avoid creating disappointment among customers regarding the recycled content of the material they purchase.

### Box 12: Specific examples raised by some experts on mass balance

Caution should be applied when **treating output of pyrolysis processes**. Indeed, in such processes, approximately 70% of the output is liquid. Of the liquid portion, 70% will consist in a naphtha-like material which, when fed into a stream cracker, achieves a yield of approximately 35% of ethylene and 17% propylene. As a result, the process only truly recycles one quarter (by weight) of the original plastic waste into plastic. Hence, it is clear that **mass balance approach could open the door to confusion**, as companies could claim that significant recycled materials are integrated in the value chain and a high premium price could be considered for the end-product.

Finally, accepting to transfer mass balance certificates from the EU to countries outside of the EU would go against the efforts made to create a circular economy. **Circular economy should be localized**, exporting products would mean taking materials to another country which perhaps has not made the same efforts to achieve circularity.

It also has to be noted that the use of mass balance approach may not be necessary for the chemical recycling of all polymers. Indeed, for some specialty polymers, small commercial chemical recycling
facilities already exist and produce recycled products. In this context, the mass balance approach is not needed.

It has to be noted that the share of "recycled" material should be allocated to all end-products and not only to the production of new polymers. This approach is more appropriate, although less favorable for technology providers.

## DISAGREEMENTS BETWEEN EXPERTS ON THE TOPIC OF MASS BALANCE

The experts express divergent views on the subject. The different arguments are presented on Table 24 below.

<table><caption>Table 24: Arguments in favor or against mass balance approach (RECORD, 2022)</caption><thead><tr><td>Arguments in favor of a mass balance approach</td><td>Arguments against a mass balance approach</td></tr></thead><tbody><tr><td><ul><li>One expert believes that the use of a mass balance approach is new for chemical recycling but can be replicated on the basis of what has already been applied across various other industries (such as cocoa, sugar, etc.). As an example, a customer purchasing its energy from renewable sources will inevitably consume a portion of electrons from non-renewable sources that is present in the grid. Many American manufacturers are already using the ISCC standard to certify their products (e.g., ice-cream tubs, cups, etc.).</li><li>In order to ensure that the chemical recycling industry will grow, there is a need to be slightly more flexible on the use of the mass balance approach and focus on the benefits they can generate. Indeed, credits transfer is acceptable within an integrated company.</li><li>An expert believes that regulation on mass balance has to be flexible to boost the development of chemical recycling technologies.</li></ul></td><td><ul><li>Other experts consider that accepting mass balance to support certain technologies would create a disadvantage for other new technologies that could be more promising but that would also require additional investments.</li><li>The use of mass balance in the chemical recycling industry may not be compared with its use into other sectors. When it comes to renewable energy, the electrons cannot be stored. Therefore, the number of electrons generated from renewable sources has to be measured at the moment it enters the system or, in other words, before it gets lost in the energy flow. That is why mass balance becomes an appropriate measurement tool for this sector. Plastic does not have the same characteristics and it cannot be compared to energy.</li><li>Mass balance has proven not to work well for certain industries (such as palm oil for instance).</li><li>Some experts insist on the need for a regulation limiting mass balance applications.</li></ul></td></tr></tbody></table>

## Food grade applications

### POINTS OF AGREEMENT BETWEEN EXPERTS

As previously mentioned, legislation varies in the different regions, specific examples are presented on the different geographies in Box 13 below. The regulation in the USA is more open than in the EU towards new chemical and physico-chemical recycling technologies. Indeed, in Europe, for resins to be approved for food-contact applications, there is a need to prove that materials do not contain any toxins. This process can be time consuming. In the USA, there is a need for the FDA to better understand what chemical and physico-chemical recycling is.

### Box 13: Specific examples raised by some experts on food grade applications

In the USA, PureCycle recently announced they will be **bringing to market food grade r-PP**. In Europe, it is very complex to obtain an approval from EFSA to allow the use of chemically recycled resin in food applications. One participant provided the example of its organization having identified **specific feedstocks** that could be used for dissolution and would allow to produce high quality recyclates. These materials have been passing compatibility tests for food-grade materials.
An expert believes that **dissolution could also be considered as a pre-treatment** for both mechanical and chemical recycling and could be used to make the waste more suited for a specific recycling technology. Therefore, the **output of dissolution would not be considered as a food-grade material** given it will require further treatment and purification.

## Legacy substances

*POINTS OF AGREEMENT BETWEEN EXPERTS*

Legacy substances are additives put on purpose in the virgin material for it to feature some specific properties. There are different types of legacy substances such as flame retardants, plasticizers, lubricants, pigments, etc.

Legacy substances can be **contained within products with long lifecycles**. Changing regulations imply that substances that were authorized in products 10 years ago might be prohibited today. When products containing these substances reach their end-of-life, lack of traceability could make it challenging to identify the exact composition of this waste, which **additives were used** during the manufacturing of the product and when it was put on the market. Yet, from the moment these substances are prohibited on the market, mechanical recycling is no longer an option as this technology cannot remove them. Chemical and physico-chemical recycling technologies can be useful in this situation. The little amount of research conducted on the topic shows there is a lack of clarity on how to deal with these substances both from a technological and a regulatory perspective. From a business perspective, legacy substances affect chemical recyclers in three different ways:

* Firstly, the recyclers are affected in the **selection of feedstocks**. Indeed, the legacy substances could both stimulate or hinder the chemical and physico-chemical recycling market.

* Then, regardless of the process, there is also a concern of **where the legacy substances end up in the outputs produced**.

* Else, chemical and physico-chemical recycling processes would also have to be **able to treat legacy substances**. Indeed, challenges encountered on legacy substances depend on the processes that is being used.

Finally, the **legacy substances could hinder the catalysts' activity**. It is thus important to better understand these substances in order to be able to switch to a non-catalytic process when necessary.

**Box 14: Specific examples raised by some experts on legacy substances**

The legacy substances could stimulate the chemical and physico-chemical recycling market, especially in **selecting the feedstock**. As an example, **EPS waste containing HBCD** is currently sent to incineration and is subject to a gate-fee. **Selective dissolution** of EPS containing HBCD could therefore benefit from an economic value due to the presence of a gate-fee.

An expert believes that, in the case of a **pyrolysis** process, if legacy substances, such as mercury, were to be concentrated within the solid residue burnt for energy recovery, the recycling plant would no longer be carrying out only recycling, it could be considered as an incineration plant as well. It is therefore key to trace how these substances move across the value chain.

According to an expert, for pyrolysis and steam cracking, legacy substances do not really represent an issue as pyrolysis oils undergo purification. When it comes to selective dissolution, it is much harder to **ensure that all substances have been properly handled**.

## DISAGREEMENTS BETWEEN EXPERTS ON THE TOPIC OF LEGACY SUBSTANCES

Two experts disagree on the ability of high temperature processes to get rid of all legacy substances.
## Departure from the status of waste

### POINTS OF AGREEMENT BETWEEN EXPERTS

Experts agree on the fact that current regulation is unclear about the end of waste status and this could represent a threat for chemical and physico-chemical recycling technologies.

The steps of the depolymerization process designated in Europe by the status of waste are represented on Figure 21: Status of waste in the chemical recycling value chain and expert's suggestions below.

<figure><img src="image_56.png" /><figcaption>Figure 21: Status of waste in the chemical recycling value chain and expert's suggestions (RECORD, 2022)</figcaption></figure>

### Box 15: Specific examples raised by some experts on the departure from the waste status

An expert's suggestions on **new regulation development** to determine with more clarity at which step of the value chain the status of waste ceases is also represented on **Figure 21** above.

Another expert considers that the lack of clarity on this subject is **not only generated by the lack of regulation but also from the fact that regulation in the EU is not harmonized across all European countries** and that Member States have the room to pass their own waste regulation.

## Qualification of a "recycled state"

### POINTS OF AGREEMENT BETWEEN EXPERTS

This qualification should differ between post-consumer and post-industrial waste. Most experts agree on the fact that the focus of plastic recycling should be on **post-consumer waste**, and the term "recycled" should only be dedicated to materials that have completed a full cycle within the economy, that is to say post-consumer materials.

During products manufacturing, the waste which is produced at the beginning or at the end of the extrusion step can be used again in the process. Similarly, some companies already shred their post-production waste, such as spare parts, reintegrate the material in their process and then claim that these products have been recycled. In this case, **production waste cannot be qualified as recycling given it is normal practice to either valorize, reprocess, or reuse it**. An additional distinction should be made between easy to recycle post-production or pre-consumption plastics and hard to recycle post-industrial waste, for instance multi-material packaging, which, due to its complexity, could be considered a post-consumption product (proposal from some experts).

For brand-owners, another challenge regarding the "recycled state" of materials is generated by the fact that **many companies wish to integrate recycled materials into their products**.

Moreover, there is a lack of clarity on whether the definition of "recycled" could apply to the output of chemical and physico-chemical recycling. Indeed, most regulations on the "recycling state" at the EU
level were developed for mechanical recycling. The Waste Framework Directive defines "recycling" as the reprocessing of organic material, **excluding energy recovery and fuel applications**. Thus, when it comes to thermochemical processes, the part of the output that is to be used as fuel should not count as recycled material but be deducted instead. When it comes to pyrolysis oil or syngas, this output still requires **further downstream steps**, therefore the product is not considered as a recycled material. As for gasification, there are already many developers using mixed streams of biomass and mixed plastic waste as feedstock. The syngas obtained from these processes can be transformed into ammonia and CO2 or hydrocarbons including a naphtha fraction or ethanol and methanol (such as the technology developer Enerkem). When using gasification processes that use both plastics and biomass as input, **it would not necessarily be possible to calculate the exact recycled plastic content** given that it would get mixed with materials originated from biomass. Since regulations similar to the Single-Use Plastics Directive are expected to be enacted in the future for materials other than plastics, **separating the notion of recycled content from recycled plastic content** will become even more relevant.

For other processes, such as solvolysis, this issue does not arise as the end-of-waste criteria is met and because it is unlikely that fuel will be produced from it.

Box 16: Specific examples raised by some experts on the qualification of a recycled state

An expert believes that, in Europe, many mechanical recyclers are not aware of the existence of REACH regulations and requirements for recycled materials.<fnref n="347" /> If **regulation is too complex** for chemical recyclers, who are sometimes small players, there is a good chance that these actors will not comply with it. Hence, chemical recyclers may decide to **focus on the recycling of post-production materials instead**, as they usually would not contain legacy substances. In this case, the challenge is that post-production or pre-consumption waste may not be accounted for as recycled content given it has not completed a full lifecycle. This point was not approved nor denied by other experts and represents solely one stakeholder's point of view.

In the USA, post-consumer and post-industrial waste are differentiated in the same way as the EU.

An expert mentioned the example of the integration of PET recyclates by brands in their final product. Two main issues will arise:

- First of all, **available supplies** of r-PET will be **too limited** compared to demand.

- Then, it should be considered that **some recyclates' applications are less circular** than others. As an example, transforming PET bottles into textiles reduces the quantity of materials that could be used for recycled bottles applications. Given that PET contained in textiles is more challenging to recover than that in bottles, this increases the risk that the material will not be recovered at its end-of-life.

**Thermal depolymerization** is recognized in different ways in the USA and in the EU. In the EU, when plastics are recycled, the component that goes to energy recovery would not be accounted for as recycled plastics, whereas in the USA, the definition of recycling includes both streams. Therefore, **when American products are imported into the EU, they create an unfair competition for European recyclers.**

<footnote n="347">³⁴⁷ Information about REACH is available on the internet. At French level, recyclers are members of SRP (Syndicat national des Régénérateurs de matières Plastiques). On its website, information about REACH is available http://www.srp-recyclage-plastiques.org/images/pdf-documents/mars-2019/srp-mrp-reach-v-finale-2-05-2019.pdf</footnote>
c. What are the strengths and weaknesses of the different environmental assessments and their comparisons?

## Introduction (based on the literature review)

The bibliography review highlighted that the results of different assessments conducted by technology developers are **often communicated in favor of the chemical and physico-chemical recycling technologies**, that are allegedly **more environmentally friendly than virgin production** or other **end of life treatments, but less virtuous than mechanical recycling**. Yet, the different analysis conducted lack transparency on the methodology, hypothesis chosen, and datasets used. Often, only the result of the lifecycle assessments is made public.

Some LCA are also made in the literature but they often rely on technology developer's data, which are, once again, kept private. It is thus arduous to link the main environmental impacts with specific steps of the chemical and physico-chemical recycling process.

Currently different methodologies are used to evaluate the impact of chemical and physico-chemical recycling technologies and they can sometimes encompass negative emissions. Indeed, the **cut-off** approach is assessing the environmental impact from the feedstock (which means that the waste comes without any burden). On the contrary, the **substitution** methodology is applied to treat the double functionality of recycling (waste treatment and new material production). In this case, they consider that the recycling process (e.g., pyrolysis) allows waste to be diverted from incineration or landfilling and thus deduct these associated impacts from the environmental impacts of the recycled polymer (e.g., produced from pyrolysis oil).

## Comparison of chemical and physico-chemical recycling technologies with end-of-life and production processes

### POINTS OF AGREEMENT BETWEEN EXPERTS

From a methodological point of view, chemical and physico-chemical recycling processes, could be compared to either end of life processes, such as landfilling or incineration, or virgin production processes.

Given that recycling processes are multifunctional processes, the lifecycle analysis could be conducted through a **comparison using a double functional unit**. This means considering the waste treatment function and the material production function of a recycling process, and to then compare the results obtained to a system which would be an adjunction of an end-of-life process and a virgin material production process. This would mean extending the framework of the system considering both functions.

The other option is to **focus solely on one of the two functions** (either waste treatment or material production).

### DIVERGENT VIEWS ON THE COMPARISON WITH END-OF-LIFE OR PRODUCTION PROCESSES

The experts had divergent views on this subject, which are presented on Table 25 below.
<table><caption>Table 25: Arguments on the different assessment comparison (RECORD, 2022)</caption><thead><tr><th></th><th>Comparison with production processes</th><th>Comparison with end-of-life processes</th><th>Comparison with both options</th></tr></thead><tbody><tr><th>Arguments in favor</th><td><ul><li>Recycling processes lead to the <strong>production of new polymers</strong>.</li></ul></td><td><ul><li>The volume of plastics destined to chemical and physico-chemical recycling is limited, which means <strong>there will be a need to cannibalize other waste streams</strong>, such as waste currently sent to energy recovery.</li></ul></td><td><ul><li>One expert considers that the objective of the transition to circular models is to <strong>enhance the value of recycling operations</strong> compared to the use of virgin polymer, to <strong>appreciate a change of end-of-life treatments</strong>, and, overall, to acknowledge the environmental impact of the product that is being sold and put on the market. The dynamics of change and the effort put in transitioning from a linear to a circular economy must be valued. In this sense, <strong>both approaches should be used</strong> in the perspective of trying to achieve a circular economy. In fact, the combination of the two approaches is interesting because it <strong>provides a complete overview</strong> on the technology used by considering the double function of the process.</li></ul></td></tr><tr><th>Arguments against</th><td><ul><li>No arguments were raised against this approach</li></ul></td><td><ul><li>Landfilling and incineration are ideally <strong>meant to disappear one day</strong>, which means it is not relevant to compare their end-of-life performances with those of chemical and physico-chemical recycling technologies.</li><li>Some studies' methodology consider that pyrolysis allows waste to be diverted from incineration or landfilling and thus <strong>deduct these associated impacts from the environmental impacts of recycled polymer</strong> produced from pyrolysis oil. An expert disagrees with this approach as he/she considered there is a bias.</li></ul></td><td></td></tr></tbody></table>

### Comparison of chemical and physico-chemical recycling with mechanical recycling

#### POINTS OF AGREEMENT BETWEEN EXPERTS

Studies analyzing chemical and physico-chemical recycling technologies, especially pyrolysis, sometimes do not make such comparison saying that mechanical and chemical and physico-chemical recycling processes are complementary given they use different types of feedstock.

The experts agree that two main aspects should be considered when comparing environmental impacts of chemical and mechanical recycling.

Firstly, the environmental impact of pre-treatment and post-treatment processes (including purification) should be taken into account when evaluating recycling technologies. Pre-treatment and post-treatment processes are rarely accounted for within LCAs of chemical and physico-chemical recycling technologies, although most of the time they are necessary (e.g., turning pyrolysis oil back into polymers).

Then, comparing the LCA results of mechanical and chemical and physico-chemical recycling is only relevant when the two processes produce the same outputs (with the same quality).
Box 17: Specific examples raised by some experts on the comparison with mechanical recycling

An expert pointed out the example of **bottles**. Indeed, they **have considerably shorter life cycles**. This implies that r-PET can undergo more than one recycling loop per year and thus determining the concentration of recycled material compared to virgin material in the waste would be more arduous.

Moreover, it **seems irrelevant to use the number of cycles as a moderating factor** as it is not necessarily interesting to calculate the number of recycling loops a material goes through. At the end-of-life of a recycled product, it will be most probably found in a waste stream amongst a majority of virgin plastics.

DIVERGENT VIEWS ON THE COMPARISON WITH MECHANICAL RECYCLING

The experts disagree on whether the comparison with mechanical recycling is relevant. The main arguments in favor and against are presented in Table 26 below.

<table><thead><tr><td>Arguments in favor of comparison with mechanical recycling</td><td>Arguments against the comparison with mechanical recycling</td></tr></thead><tbody><tr><td><ul><li>Making the comparison is relevant as long as the quality of the output produced by different recycling technologies is the same. LCA results are not a determining factor in the choice between recycled and virgin product. The relevant criterion lies in the properties expected of the polymer. Mechanical recycling often leads to the loss of properties and quality of polymers which results from mixing different grades of polymers. This aspect must be considered when evaluating the impact of different technologies. A coefficient should be developed to allow the comparison of these technologies. Today, Plastics Europe only qualifies one generic grade per polymer. However, ranking quality and properties will be increasingly important in the future.</li><li>When it comes to food-grade applications of recycled polymers, chemical and physico-chemical recycling could become an alternative to mechanical recycling (as only PET can currently be both mechanically recycled and used for food-grade applications).</li></ul></td><td><ul><li>The type of recycling to be used is directly determined by the nature of the waste, the desired properties of the output, and the recycles' application. Hence, the comparison between these two forms of recycling has limited relevance.</li><li>Regarding EEE or automotive applications, mechanically recycled materials already perform efficiently. Thus, it is not necessarily needed to compare mechanical and chemical recycling as the end-product applications will naturally drive the choice of the technology. These technologies are thus complementary and virgin or chemically recycled material should not be used when the mechanically recycled material is sufficient and meets the required specifications.</li><li>Depending on the market they operate in, mechanical recyclers will not have the same economic viability. Indeed, some markets are very accessible for mechanical recycling and others, particularly for food-applications, where it is extremely complicated to be able to address another polymer than PET if we only consider mechanical recycling. For all plastics that are easily accessible to mechanical recyclers, chemical and physico-chemical recycling will struggle to become economically competitive. The economics will thus naturally make the two technologies complementary.</li><li>There is no need to compare chemical and mechanical products because they do not deal with the same feedstocks.</li><li>Comparing a mechanical and a chemical and physico-chemical recycling unit would not be possible due to the different size of the units and the geographical area on which the feedstock must be collected. For a mechanical recycling unit, there is the need to locally source a specific amount of waste to justify the operations of the unit*. A chemical and physico-</li></ul></td></tr></tbody></table>
chemical recycling unit for the same polymer may require **much larger waste quantities as the capacity may be larger than that of mechanical recycling units**. In this sense, capacity factors have an impact on all logistic aspects (transport, energy consumed in transport, etc.). In general, higher volumes of feedstocks are to be sent to a chemical and physico-chemical recycling unit to recover the investment initially made. Additionally, there may come a time when **both processes will compete for the same resource in the collection area**, and it will be easier to fill a small unit (mechanical) than a large one (chemical). Moreover, scattered chemical and physico-chemical recycling units would raise logistic issues and questioning on the quality of the sorting done to divide waste between mechanical and chemical recycling centers. It can be risky to answer environmental questions now that chemical and physico-chemical recycling units are not yet fully mature.

* The materials treated by the two processes will tend to diverge more and more. Indeed, mechanical recycling can involve **adding additives** when the product is passed in the extruder. By adding these materials to the mechanically recycled product, the **end-product becomes more complex**. Eventually, chemical and physico-chemical recycling of such products is more challenging.

<table><caption>Table 26: Arguments in favor and against the comparison with mechanical recycling (RECORD, 2022)</caption><tr><td></td><td>chemical recycling unit for the same polymer may require much larger waste quantities as the capacity may be larger than that of mechanical recycling units. In this sense, capacity factors have an impact on all logistic aspects (transport, energy consumed in transport, etc.). In general, higher volumes of feedstocks are to be sent to a chemical and physico-chemical recycling unit to recover the investment initially made. Additionally, there may come a time when both processes will compete for the same resource in the collection area, and it will be easier to fill a small unit (mechanical) than a large one (chemical). Moreover, scattered chemical and physico-chemical recycling units would raise logistic issues and questioning on the quality of the sorting done to divide waste between mechanical and chemical recycling centers. It can be risky to answer environmental questions now that chemical and physico-chemical recycling units are not yet fully mature.<br/>• The materials treated by the two processes will tend to diverge more and more. Indeed, mechanical recycling can involve adding additives when the product is passed in the extruder. By adding these materials to the mechanically recycled product, the end-product becomes more complex. Eventually, chemical and physico-chemical recycling of such products is more challenging.</td></tr></table>

* Note: This argument is **not considered relevant by some experts** since **the usage of large units is not necessarily a pattern that will last in the long term** (for instance for pyrolysis processes). There is an ongoing logic of wanting to obtain **moderate size units** so that transports would have a lower impact and feedstock could be more accessible. This is the strategy used by Polyloop, which is approaching selective dissolution using small, distributed units.

## Comparison of the different chemical and physico-chemical recycling technologies

### POINTS OF AGREEMENT BETWEEN EXPERTS

It is challenging to compare chemical and physico-chemical recycling technologies with one another as there is **no polymer that can be recycled by all technologies**.

### Box 18: Specific points raised by some experts on the comparison between technologies

Manufacturers are interested in creating a ranking based on the environmental impact of different processes that produce plastics, whether it is virgin, mechanically or chemically recycled. Such classification needs to be simple and clear, to be **understandable by people who know less about existing technologies**. It will not be possible to clarify the environmental impact of products' content if results are only accessible to specialists.

## Comparison of chemically recycled material with virgin material

### POINTS OF AGREEMENT BETWEEN EXPERTS

The relevance of this comparison highly depends on the **nature of the targeted polymer**. The comparison might be uneven for commodity polymers compared to specialty polymers. **Specific examples have been tackled by experts and listed in Box 19 below.**
Again, the **end-product application should be considered**. Indeed, producing food-grade material through chemical and physico-chemical recycling could be environmentally impactful, due to the number of additional steps necessary to ensure its quality. It should thus be ensured that CO₂ emissions related to the production of a food-grade chemically recycled polymer are not higher than their virgin counterpart.

Box 19: Specific examples raised by some experts on the comparison with virgin polymers

In **specialty performance polymers' case**, there are **significant gains in terms of GHG emission reduction** for chemically recycled PMMA, PA6, and any technical or specialty performance polymer compared to their virgin counterpart. Some studies on PMMA have recorded a reduction of 70% GHG emissions of the produced chemically recycled monomer compared to the virgin monomer (without accounting for avoided emissions, based solely on the comparison of energy consumption and CO₂ emissions of recycling vs. virgin production). Indeed, virgin specialty polymers consume a lot of energy to be produced. For example, PA6 has an environmental footprint of at least 7 kg of CO₂/kg of polymer<fnref n="348" />. Most of these emissions are generated while adding nitrogen into the molecule during the production process. As a consequence, chemical and physico-chemical recycling processes have a limited environmental footprint compared to the production of the virgin material.

Another consideration to make about specialty polymers is **that lower volumes are produced** than for commodity polymers. This means that collecting these materials at their end-of-life can be challenging. In order to increase waste volumes, there could be long-distance transport to reach the recycling plant.

Finally, it should be considered that buyers of specialty polymers use these materials because their **properties are superior to those of other plastics**. In the case of PMMA, buyers are looking for transparency and optical quality. In some cases, such high purity is not achievable through recycling processes or requires high energy consumption. These factors could represent a hindrance for chemical and physico-chemical recycling.

The reasoning is different on **commodity polymers**. Indeed, when it comes to polyolefins, it can be challenging to show positive environmental results as energy consumption and CO₂ emissions remain low during manufacturing of virgin fossil-based resins. However, **GHG emissions are not the only environmental indicator that should be considered** in an environmental assessment. Even if GHG emissions indicators may detect a poor environmental performance, other sustainability indicators may still support the relevance of using a certain chemical and physico-chemical recycling process.

Some studies consider that **pyrolysis allows waste to be diverted from incineration or landfilling** and thus deduct these associated impacts from the environmental impacts of recycled polymer produced from pyrolysis oil. An expert disagrees with this approach as considered there is a **bias**.

Cut-off and substitution approaches

POINTS OF AGREEMENT BETWEEN EXPERTS

There are two main ways to assess the environmental impact of technologies: the “cut-off” approach and the “substitution” methodology. The **cut-off** approach is relying on the hypothesis that, from the moment a material becomes waste, it has no environmental impact attached to it. This means that, in this approach, waste intended for recycling is not attributed the benefits of the treatment channels that are avoided (such as incineration for instance). Collection, logistics, and other treatments’ environmental impacts are allocated to the product using the secondary raw material. On the contrary, a **substitution** methodology is applied to treat the multifunctionality of recycling, which are waste treatment and new material production functions. This approach integrates emissions that have been avoided by preventing conventional end-of-life treatment processes, such as landfill or energy recovery.

DIVERGENT VIEWS ON THE METHODOLOGICAL APPROACHES

Experts disagree on the relevance of these methodologies. Their main arguments and concerns are presented in Table 27 below.

<footnote n="348">³⁴⁸ Data from Plastics Europe
Study RECORD n°21-0919/1A</footnote>
<table><caption>Table 27: Arguments on the different assessment methodologies raised by experts (RECORD, 2022)</caption><thead><tr><th></th><th>Cut-off approach</th><th>Substitution approach</th></tr></thead><tbody><tr><th>Arguments in favor</th><td><ul><li>Several experts argue that cut-off is a better approach than substitution because it allows to restart the count of emissions from the moment the product has reached its end of life.</li></ul></td><td><ul><li>Some experts view substitution approaches as justifiable. Indeed, if a given amount of waste had not been chemically recycled, it would still have been treated through other end-of-life processes.</li><li>From a theoretical point of view, the ability of a recycling process to produce an output that can be reused in plastics' manufacturing has to be considered into the LCA equation. From this perspective, the substitution approach is methodologically required and can favor the sector's transition towards a more circular economy.</li><li>It is inaccurate to assume that all waste would be incinerated without energy recovery if it was not recycled. Some of it may be incinerated with energy recovery. This is why, it would be relevant to compare the environmental impacts of recycling with that of incineration with energy recovery to better represent the reality.</li></ul></td></tr><tr><th>Arguments against</th><td><ul><li>No arguments were raised against the cut-off approach</li></ul></td><td>Other experts disagree with this perspective and suggested there are three reasons for which substitution approaches should be discarded:<ul><li>When it comes to the understanding and accounting for environmental impacts, considering avoided emissions biases the system. As an example, if different plastics of the same bale undergo different methods of recycling or incineration, how would CO2 emissions be compatibilized and which ones should be deducted?</li><li>As for future perspectives, incineration and landfilling are not virtuous solutions and these end-of-life pathways should be limited. It is therefore not relevant to prove that a technology has environmental benefits if it is compared to inefficient and non-environmentally friendly incineration processes.</li><li>Additionally, this notion leads to a delay in the implementation of better technologies and can become a way finding justifications to maintain/implement solutions that are not the most efficient ones available. In fact, such perspective can lead to a misinterpretation of LCA results as new recycling technologies would be selected only because they are slightly better than incineration (whilst overall they might still perform less efficiently than other recycling solutions).</li></ul></td></tr></tbody></table>

## Pre-treatment and purification impacts

### POINTS OF AGREEMENT BETWEEN EXPERTS

Sorting is not the first step which has an impact on the total environmental performance of a recycling process yet is often deemed as such. Today, recycling challenges are linked to the **design of the initial product**. The design of the product may lead to higher complexity and additional challenges within the sorting and pre-treatment phases. As a consequence, the whole recycling process will end-up having a
higher overall environmental footprint. Hence, **recycling constraints should be brought up to the design phase.**

Using different polymers in the same product is not necessarily an obstacle to chemical and physico-chemical recycling and its environmental performance, as long as **they can be easily separated during sorting or pre-treatment phases** (e.g., separation of some polymers based on their density,...).

Considering current feedstocks, preparation steps are needed both for mechanical and chemical and physico-chemical recycling. These steps have to be considered as they have an environmental impact. Indeed, **pre-treatment steps and post-treatments steps are poorly defined in current LCAs.**

### Box 20: Specific examples raised by some experts on pre-treatment and purification

An expert agrees that, in the automotive sector, a rear light made of PMMA, ABS, PC can be easily recycled. However, the recycling of a front light containing PP shells with 40% talc glued with polycarbonate, would be more challenging, and the product design should thus be revised.

One expert believes that, in some industries, such as the automotive one, the plastics that are collected today were put on the market fifteen years ago. The **new eco-design regulations that are put in place today will ease recycling processes** in twenty years' time.

## Environmental performance assessment improvements

### POINTS OF AGREEMENT BETWEEN EXPERTS

Multiple aspects must be considered to improve environmental assessments. These include the **availability of data**, the existence or absence of **common methodological rules**, the extent to which **differences in data robustness and process maturity** are to be considered, etc.

Regardless of the approach used to conduct a LCA, the methodology, hypotheses and references should **always be clearly stated in the study**.

On top of capacity and output purity, other factors that should be considered when evaluating recycling processes are the following:

* **Water consumption:** water consumption is a key indicator, especially when it comes to specialty polymers which consume a lot of water during production processes compared to recycling processes.

* **Energy consumption:** energy can be produced by burning oil, gas, plastic waste, heavy or light products of pyrolysis.

* **Geographical area:** global comparisons should not be made. Indeed, the energy mix may differ from one country to another. Moreover, processes can vary between regions.

**Presence of additives:** it is important to ask the question of where all additives that were contained within plastics end up during the recycling process. As of today, this aspect is not sufficiently addressed in environmental analysis. In Asia, toxic additives are usually burnt together with plastics for the purpose of energy production.

### Box 21: Specific examples raised by some experts on environmental performance assessments improvements

When it comes to the comparison of depolymerization units for PMMA, the following difficulties arise even when data is available:

* Different plants do not operate at the same **capacity** (varies from a few hundred tons to a few thousand tons).

* Different plants do not have the same level of **output purity**. Asian countries (India, China, Vietnam, etc.) accept products coming from depolymerization units which qualities are too low to be accepted in Europe.

Therefore, even when actual plant data is available, **comparison of LCAs should be done carefully**. There may be a need to make comparisons of products with the same purity level. For instance, 3 different grades could be defined for chemically recycled PMMA: purity below 95%, purity
between 95% and 98% and purity above 99%. The review of existing LCA studies showed that the PMMA depolymerization units that performed worst in terms of product quality were better than virgin PMMA production in terms of CO₂ emissions/kg of monomers.

Other factors, such as **water consumption**, are relevant when conducting a LCA of PMMA. Indeed, PMMA is recycled via pyrolysis, which does not consume a lot of water. The geographical area is also important as there are three radically different processes to manufacture PMMA monomers. Not all of these processes have the same relevance everywhere. Indeed, different technologies for virgin fossil based PMMA production are used in Europe and in Japan. The data selected to make comparisons has to be applicable to the geographical area discussed. Therefore, making comparisons requires selecting the technology that is predominant in a given region as that is the one that would be substituted by recycling.

Moreover, environmental impacts of liquefaction processes are **based on the quantity of liquid produced during recycling**. In Asian countries for instance, the calculation does not take into account the amount of gas or solids produced (making the calculation inappropriate). This generates interest in having an available material balance.

According to an expert, the minimum criteria to be considered is for the technology to have a certain **TRL** (at least TRL=6-7) and a track record of output **volumes produced** (at least 100 tons of material produced and ideally 1000 tons of material produced). Making an environmental performance assessment additionally requires disclosing a **material balance** and an **energy balance of the process**. In Asian countries, it seems the calculation of yields is not methodical.

## Additional methodological aspects

### POINTS OF AGREEMENT BETWEEN EXPERTS

Quality comparison between the different technologies' outputs should be included in the methodologies, to most of the experts' minds. This comparison depends both on the **output produced** and the **end-application**. The produced output can either display the functional properties expected of a recycled material or do not meet the technical specifications for a given application - which would require adding virgin material to recycled materials to obtain an end-product with the proper specifications. In that case, a specific criterion should be developed to take this point into account.

Another way of evaluating recycling processes is whether they lead to **closed-loop** or **open-loop** recycling. Both approaches are perfectly legitimate and must be considered in relation to a reference, which would be the final application.

The experts also agree that processes should be compared taking into account the same output specifications (including purity).

Moreover, GHG emissions are mainly considered in LCAs. Other LCA indicators should also be studied such as resources scarcity, water use and sanitary risks. The energy mix could vary from one country to another, this should be taken into account. The efficiency of the processes should also be considered. The presence of additives should be further studied.

Eventually, there is a lack of available data and transparency. This is why, it may be relevant to disaggregate LCA inventories.

Several experts believe that the virgin fossil-based resin used for a specific application may be overqualified compared to the actual need. The use of a mechanically recycled resin may be sufficient, there may be no need to use a virgin grade resin or a chemically recycled resin.
Box 22: Specific examples raised by some experts on additional methodologies

Examples used to illustrate quality comparison include:

- In the **automotive industry**, recycled products that are to be used in certain parts of the vehicle (such as handles) must display specific characteristics. In this case, the focus of the industry is on the properties of the recycled polymer, little relevance is given to whether the plastic waste used to produce that recyclate was derived from an application of superior quality.

- Another example is provided by the **recycling of PET bottles**. PET bottles can either be recycled into other bottles or into textiles. Using r-PET from bottles for textile applications is simple, and the textile market has a demand that is twice that of the PET bottle market. From a technical, economic, and environmental perspective it would be better to turn bottles into textiles. However, the current legislation requires to integrate recycled plastic into bottles. This is why, we can observe a "bottle-to-bottle" approach is promoted on the market.

### d. What are the main costs of the different recycling technologies?

#### Introduction (based on the literature review)

The bibliography review highlighted the vagueness around the economic data, considered sensitive by the chemical and physico-chemical recycling actors. **Very few technology developers have disclosed detailed information about the competitivity, price or cost of their final product.**

Public literature however underlines some contributing factors to the potential costs associated with these technologies, such as the need to invest in equipment made from noble metals, in order to resist corrosion, the potential additional costs linked with specific parts of the value chain (e.g., pre-processing, purification, or reprocessing of solvent) or the economic value associated with specialty polymers production.

However, **no figures are available on the final cost** of a recycled material. The only figures made public are investment in chemical and physico-chemical recycling plants, and highly varies depending on the location and technology targeted.

This is why, theoretical economic models have been developed, based on public information. Experts were invited to comment on these economic models presented in Appendix I. The models were afterwards enriched with their inputs. Some experts however expressed some concerns, as they consider these models as only theoretical and therefore potentially not representative of reality.

Discussions were focused on specific examples, corresponding to the economic models developed: hydrolysis of a PET, pyrolysis of polyolefins and PS dissolution.

Experts mostly highlight two parameters as being critical. The first one being the **feedstock**, due to its purchase price and its purity, which influences the yield. The second parameter lies in the **investments**. Indeed, they are considerable and must thus be optimized, accenting the need to have a **very pure feedstock** to reduce the size of equipment and reactors.

#### Feedstock costs

##### POINTS OF AGREEMENT BETWEEN EXPERTS

When considering feedstock costs, sometimes non-usable materials in the feedstock can still be economically valorized. Indeed, when sorting is conducted, at least two fluxes are generated. Hence, the question becomes whether the second flux generated is to be considered as **waste or as credit**.

Gate fees seem an **unrealistic assumption** for most of the feedstock meeting the requirements of chemical and physico-chemical recycling technologies. An exception to this lies in the case of PS containing flame retardants, dedicated to dissolution processes.

The **quality of the feedstock** used is moreover key in the process economics. Indeed, a contaminated feedstock will inevitably lead to additional costly pre-treatment steps.
Box 23: Specific examples raised by some experts on feedstock costs

Examples discussed by some experts:

- For **PET hydrolysis**, sorted cotton from textiles can be sold and produce an economic value for the technology developer.

When considering the feedstock type, the textile industry accounts for two-thirds of the PET production. It is interesting to evaluate **PET from textile as a feedstock** because the main interest of depolymerization technologies is to recover PET when it is mixed with other products. If PET was already well-sorted and clean, then it would be eligible for mechanical recycling. When it comes to PET, this material would not necessarily be predominantly present in the residuals of household plastic waste. Bottles are sent to different sorting centers for mechanical recycling, so the chances of finding over 70% of PET within residuals are low. Therefore, the feedstock considered should perhaps be sorted PET plastic waste.
Regarding the prices of such feedstock, the following estimates were shared by an expert:

o Colorless PET bottles in 2017 had a price of about 300-400€ per ton<fnref n="349" />.

o PET bottles with mixed color had a price of about 100-300€ per ton<fnref n="350" /> (containing 5%-20% humidity that would need to be dried).

o Hot washed colorless PET flakes had a price of approximately 850€-900€ a ton in Europe (pre-covid), while colored ones had a price of around 650€ per ton<fnref n="351" />.

If this feedstock is further purified (for example, by removing remaining impurities or volatile organic compounds), then price levels would further raise to 1 100€ - 1 200€. At the same time, the price of virgin PET was around 1 000€ per ton. This means that in this scenario, recycled PET would be more valuable than virgin PET. Considering these values and the state of polymers during different phases, the best possible input for depolymerization to this expert's mind, would be dried hot washed colored PET flakes with a 650€ price per ton. In this case, 2% of input containing pigments and other impurities would still have to be discarded through additional sorting. This would then lead to some costs related to getting rid of this generated waste through incineration (in Scandinavian countries it costs about 60€ per ton, in Western Europe gate-fees can go up to 210€ per ton).

The fact that low proportions of PET are contained in textiles (compared to packaging for example) combined with the presence of contaminants and unwanted materials in textile waste alter the mass yield of the process and thus its rentability. For this type of waste, options become to either only target the limited quantities of PET or to also economically valorize other materials:

o **Option 1**: Targeting only the limited quantities of PET. Some technologies work with enzymes that only target PET and should therefore allow to treat PET contained in textiles. Input streams for hydrolysis should contain around 90% of PET, for which a gate-fee will probably not be applicable. At the same time, if the waste that is being treated consists of dirty clothing or rusty zippers, these impurities might affect the effectiveness of enzymes. Some technologies seem to operate using extremely stable enzymes which, combined with the fact their process operates at low temperatures, makes the technology very interesting. Their real advantage is the ability to treat mixed streams without a catalyst that reacts on everything but using a selective enzyme instead. One expert considers that, even in such a very selective process, the type of supply chains and the quality of the input remain important. Currently, it is still better to sort upstream than to treat these impurities in the reactor or during the purification steps. These aspects have an impact on the economic viability of the model.

<footnote n="349">³⁴⁹ 2017 price, Google image search.</footnote>

<footnote n="350">³⁵⁰ ICIS reference, before Covid.</footnote>

<footnote n="351">³⁵¹ Specific dates and data sources have not systematically been shared by experts</footnote>
* **Option 2:** Economically valorize other materials. JEPLAN's technology can separate the cotton contained in waste from the PET to then resell both the recovered cotton and the recycled plastic<fnref n="352" />.

- For **pyrolysis of polyolefins**, when considering feedstock costs, gate fees are only available for certain types of waste. Residual fractions from sorting facilities would probably not be compatible with pyrolysis reactors. That is mainly because the fractions would contain PVC. There are fractions of waste containing primarily polyolefins. However, these fractions would contain 5-20% of humidity and pyrolysis reactors are unlikely to work with water in it. Consequently, recyclers will have to shred it up, clean it, etc.

Due to the mentioned feedstock requirements, the waste considered would probably have a **positively strong market value**. At the same time, claims on the technologies being able to process oxygen and nitrogen contained in waste would have to be verified. The lowest quality of polyolefins feedstock would already be marketed around at least 400-600€ a ton<fnref n="353" />. This makes the idea to have a pure hydrocarbon feedstock going into a reactor and with a gate-fee very unlikely.

Oxygen and nitrogen are acceptable within the feedstock if the pyrolysis process is followed by a hydrogenation post-treatment. This would however have a cost associated with it which would have to be considered.

- In the case of **PS dissolution** there might be the opportunity to obtain a gate-fee depending on the type of waste (e.g., waste containing HBCDD which would be incinerated). Polystyreneloop's dissolution process is designed to remove contaminants (example of HBCDD<fnref n="354" />). This way, bromine found in waste can be recovered and used to make new bromine (which is expensive).

## Operational conditions

### POINTS OF AGREEMENT BETWEEN EXPERTS

Once assumptions on feedstock have been defined, understanding the economics of the different technologies requires determining how the input is prepared, and the costs associated to these operations. It is also likely that further upgrading will be necessary (e.g., hydrotreatment, etc.) to ensure the output will reach the required specifications. All of these specific steps make it very complicated to fully capture the economics of the processes.

**Box 24: Specific examples raised by some experts on operating conditions**

Examples used to illustrate quality comparison include:

- In the **PET Hydrolysis**, hydrolysis being a polycondensation reaction, the process is equilibrium limited. Hence, an excess of water is needed to shift the reaction and reach the final monomer product (which would otherwise remain a mixture).

An expert also trusts that the **PTA produced would probably be purified by crystallization** due to its high melting point and low solubility in water. In a neutral environment the terephthalic acid is actually a salt. Being a salt, there will be a need to use another acid (usually acetic acid) or another technology to revert it to the acid form (the monomer is the acid form), which can come with additional costs.

Precipitating PTA requires getting rid of all other solvents. The PTA is precipitated in the reaction medium (or just after). What is left afterwards is a mixture of ethylene glycol and water. Therefore, there is still a need to evaporate a large excess of water, get rid of residues, and extract the ethylene glycol.

According to experts, **wastewater can be recycled and reused in the process**. Water boils at 100°C, while acetic acid (one of the first organic acids) boils well above that temperature. This means that evaporated water will not contain acids. There will be some water losses in the process, yet a majority of the water could be recycled in the process. The ability to recycle the acetic acid however depends on the characteristics of the recycling process used.

<footnote n="352">³⁵² https://www.jeplan.co.jp/en/service/bring/</footnote>

<footnote n="353">³⁵³ Specific dates and data sources have not systematically been shared by experts</footnote>

<footnote n="354">³⁵⁴ https://polystyreneloop.eu/</footnote>
- In pyrolysis, there is not much public data available on the subject of refining of pyrolysis oils according to experts. **The selection of the refining process depends on the quality of the pyrolysis oil and the type of steam cracker used** (as an example some crackers may be more suitable for light feedstocks, others for heavy ones).

One expert asserts being skeptical about the ability of pyrolysis processes to reuse secondary outputs such chars to heat up the recycling process. These outputs are mainly waste products and thus can contain VOCs that could be released through the fumes. However, it seems that conventional fumes treatment (for instance dry process removal of fumes with sodium bicarbonate) could be installed at the exit of the plants. This would however require additional installation costs.

Another expert believes that chars could have a value in certain industries.

Gently heating up polymers leads to a heavy output (waxes, etc.). Shorter chains and naphtha require higher temperatures, which generates more gas. This gas could have a value by being purified and sold. Yet is can also be used to generate energy in the process. The chars obtained through this process will contain a lot of contaminants (metals, etc.). Moreover, when operating temperatures are high (such as for gasification), it is possible that Persistent Organic Pollutant (POP) waste will be produced.

It is often likely that **further upgrading of pyrolysis oils will be necessary** (hydrotreatment, etc.) to ensure the output will have the required specifications to enter a steam cracker and thus produce olefins. These steps are highly dependent on the process and the feedstock chosen and are thus very complicated to generalize. According to an expert, it is also not possible to mix pyrolysis oil with virgin naphtha to remove the need for purification steps afterwards. This process is called dilution. Applying this technique would require ensuring that all contaminants do not affect the output yet, as of now, it is not possible to do so.

- As for **PS dissolution**, solvents have a high cost for many developers that decide not to use cheaper solvents due to their negative environmental impact (example Polystyreneloop and CreaSolv<fnref n="355" />). Moreover, energy costs associated with this process are usually high (due to the evaporation of the solvent).

## Depreciation costs

### POINTS OF AGREEMENT BETWEEN EXPERTS

There are high uncertainties on the investment costs according to some experts. These uncertainties are weighting on the costs and the sizing of the unit should thus be appropriate in regard to the feedstock at hand. The purer the feedstock will be the less investment in additional equipment will be needed.

**Box 25: Specific examples raised by some experts on depreciation costs**

The points below were discussed:

- Regarding **hydrolysis**, a chemical depolymerization plant for flexible PU was being built in the Netherlands for 55 million €. In Europe plants are built for **20 years**, depreciated in 10 years (equipment included). CAPEX would be significantly impacted by the fact that some of the pieces in these plants are completely new due to the **strong innovation change** leading chemical and physico-chemical recycling.

- Moreover, **start-up costs** and working capital would also influence the investment costs. These aspects refer to the extra costs that may be involved due to the construction of a first-of-a-kind plant and to the need to store materials, solvents, etc.

### e. What are the perspectives of development of the different chemical and physico-chemical recycling technologies?

## Introduction (based on the literature review)

The literature review highlighted the **variability between technology advancements** and plans for expansion from a developer to another.

<footnote n="355">³⁵⁵ https://polystyreneloop.eu/faq/
Study RECORD n°21-0919/1A</footnote>
Indeed, within the **solvolysis** category, planned capacities ranges from 4 kt to 100 kt, depending on the developer. The facilities are mostly planned for the coming years. The majority of the advanced developers are focusing on PET recycling.

Regarding **dissolution**, several technology developers claimed that they would have started operating their demonstration plant or commercial facilities in 2021/22. However, no further details have been found concerning the advancement of these operations so far. There is thus a **lack of clarity on whether these plants** will be operational. The majority of the advanced developers are focusing on PS recycling.

As for **thermal treatment** technologies, the same variability in announcements can be observed, as planned capacities range from 15 ktons per year to 350 ktons per year in a time horizon from 2021 to 2025. These developers are usually focusing on mixed plastic waste.

Thus, information publicly available usually focuses on the plants to be built and operated. However, very little is known about the **way to technically run these plants and their positioning in the value chain** of such actors.

## Challenges and opportunities for scaling-up

### POINTS OF AGREEMENT BETWEEN EXPERTS

First of all, it can be noted that the demand for recycled materials is very high (especially food-grade recycled polymers). **The demand for recyclates often does not match the supply available.**

The experts agree that building of the whole **value chain** is key when considering the scale-up of a technology. Deploying recycling at a commercial scale requires **access to meaningful volumes of waste with the appropriate feedstock specifications**. Further technical progress is required on the phases that come prior to chemical and physico-chemical recycling (design for recycling, collection, sorting, traceability of waste).

In this sense, it should be established beforehand whether the aim is to process mixed waste or to treat resins one-by-one. These technologies could reach commercial scale by 2030 as long as there is a **proper match between the technology and the feedstock**. This is why **feedstock needs to be selected based on the desired outputs**. Such approach implies reversing the value chain by determining the desired products, establishing the volumes of waste needed after sorting and cleaning, and, in some cases, adapting the technology to the available waste. Indeed, there will be the need to ensure that the right technologies are applied to the right quality feedstocks (high quality feedstocks to be treated via mechanical recycling and solvolysis, lower quality feedstocks to be treated via pyrolysis, the lowest quality feedstocks to be sent to gasification facilities).

In addition, the learning curve of operating such recycling technologies is important as time is needed to understand what the requirements are to reach acceptable yields, quality, and price.

Experts assume that, in all cases, the amount of chemicals produced via chemical and physico-chemical recycling will be a **very small part of the total demand of polymer chemicals**.

Moreover, there is a need to develop **better traceability systems**. There is currently a lack of monitoring during the transformation of waste into products. So far, the chemical and physico-chemical recycling industry has mainly considered non-physical traceability of waste, as the mass balance approach. For mechanical recycling, traceability standards are in place and oblige recyclers to disclose information from the origin of waste until its use under the form of recyclates. Efficient traceability systems should be used both for mechanical and chemical and physico-chemical recycling. For this purpose, these technologies additionally need improved and harmonized collection systems, digitalization, improved sorting, etc.

Additionally, many brands demand specific requirements for recycled materials. **Numerous brands do not accept materials developed under a mass balance approach** as they wish to know the exact recycled content in their products.

Policy aspects are also relevant to the progress of chemical and physico-chemical recycling. The regulation on waste is currently under review within the Circular Economy Action Plan and will either be updated or revised. **Evolving regulation makes business models uncertain.** At first, strong regulations and financial incentives for chemical and physico-chemical recycling routes will be necessary to support the industry. These points have been discussed in more detail in part XI.1)b of this report.
Additionally, the experts believe the terminology “commercial scale” cannot be generalized. In many cases (such as for pyrolysis), **scaling-up takes place through modularization**, namely by multiplication of modules for certain processes. In this case, the development of the technology mostly lies in the required learning curve of each developer.

It should also be considered that **different technologies reach commercial scale at different capacities**. It is not possible to assume that all categories of technology will reach commercial scale at a 50 kilotons capacity (for example).

Many projects have been announced and are in the pipeline to reach industrial scale by 2025-2030. The question remains on whether these plants will start-up successfully. Most technologies still need to be de-risked and optimized. Plastics Europe recently announced that **investments in chemical and physico-chemical recycling technologies will go from 2.6 € billion by 2025 up to 7.2 € billion by 2030 in the EU and UK**<fnref n="356" />.

**Box 26: Specific examples raised by some experts on scaling-up**

One expert believes that although pyrolysis plants could be scaled-up by multiplying the number of recycling modules, some developers are **facing scaling-up issues**. Moreover, the pyrolysis oils produced will still need to be turned into plastics and **the ability to introduce large volumes of pyrolysis oils into crackers has not yet been proven**.

Some experts also believe that solvolysis is the technology that is closest to commercial scale currently, followed by high temperature pyrolysis and gasification.

**DISAGREEMENTS BETWEEN EXPERTS ON THE TOPIC OF SCALING-UP**

Experts disagree on the technical feasibility of the scaling-up process. Indeed, an expert feels **skeptical towards the easiness to scale-up**. As of today, few developers are actually delivering at scale and some of them encounter issues in scaling-up. There are usually high expectations and ambitions related to chemical and physico-chemical recycling. However, **proof of concept is still missing** when it comes to scalability. Yet, another expert considers that most of the existing challenges **do not depend on the ability to up-scale technologies**, but on the ability to build a complete value chain (access to feedstock, collection, and sorting steps to be improved, etc.).

One expert believes that, although it will be possible to produce higher volumes of chemically recycled materials (thanks to regulations and technology developments), **pyrolysis oil production suited for stream crackers will still be low in the coming years** (due to the low quality of the oil and subsequently a low efficiency towards the targeted products' quality). From the expert's point of view, a significant fraction of pyrolysis oil produced through current technologies will go to incineration or fuel, which is obviously not desired. Significant progress on high temperature pyrolysis or catalytic pyrolysis is however expected.

**Design for recycling**

**POINTS OF AGREEMENT BETWEEN EXPERTS**

Several experts agree that transitioning to a circular economy will require a portfolio of different solutions (eco-design, reusability, recycling, etc.). The principle of design for recycling has to be a tool of such portfolio, together with chemical and physico-chemical recycling. Design for recyclability can then lead to a better balance between waste quality and products volumes.

**Box 27: Specific points raised by some experts on design for recycling**

An expert believes that design for recycling **will not directly favor chemical and physico-chemical recycling**, which is only one angle of a much wider topic: design for sustainability.

<footnote n="356">³⁵⁶https://plasticseurope.org/sustainability/circularity/recycling/recycling-technologies/chemical-recycling/</footnote>
Competition with mechanical recycling

DISAGREEMENTS BETWEEN EXPERTS ON THE TOPIC OF COMPETITION WITH MECHANICAL RECYCLING

Most of the experts agree that there will be some competition between the two forms of recycling, but some experts express different opinions. Arguments are summarized on Table 28.

<table><thead><tr><td>There will be competition with mechanical recycling</td><td>There will not be competition with mechanical recycling</td></tr></thead><tbody><tr><td><ul><li>Mechanical and chemical and physico-chemical recycling are competing through an uneven regulatory context. Indeed, European legislation on mechanical recycling is currently very strict. Some mechanical recyclers are demanding to make changes in regulation that will favor circular economy. For competition to be fair, chemical, and mechanical recyclers should be subjected to the same laws in order to create a level playing field. Additionally, there is a lack of definition within existing regulation on recycling. When it comes to chemical and physico-chemical recycling, it is not clear where waste ceases to be waste and becomes a product.</li><li>Mechanical and chemical recycling are competing whenever chemical recycling would be substituting downcycling via mechanical recycling. Indeed, if chemical recycling allows to produce higher quality recyclates, this option could be favored depending on the specifications required for the end-products.</li><li>Currently, there are already examples of some low-quality materials produced via mechanical recycling being purchased to be turned into higher quality monomers by chemical recyclers. Thus, either the output of mechanical recycling would qualify as a waste or the chemical recycling process would qualify as post-treatment. This type of activity further increases existing competition between recyclers.</li><li>If a company could meet all its materials' requirements using mechanically recycled materials, it would privilege this solution as it would be cheaper to do so. Consequently, chemical and physico-chemical recycling will mainly be considered whenever customers have specific requirements for their recyclates (e.g., food-grade, etc.).</li><li>The demand for chemically recycled products is higher than the demand for mechanically recycled materials. Current forecasts already highlight that pyrolysis plants would use too much high-quality polymer waste, which would also be suited for mechanical recycling. In this context, clear incentives, regulations, and specifications are needed to regulate the overall stream distribution to the high added value, low</li></ul></td><td><ul><li>Ideally, higher quality feedstocks would be redirected towards mechanical recycling (it would be too expensive to treat them through chemical and physico-chemical recycling), while lower quality feedstocks would be sent to chemical and physico-chemical recycling (quality would be too low for mechanical recyclers). If it is possible to recycle mechanically a specific feedstock, this route will be favored as it would be less expensive than chemical and physico-chemical recycling technologies.</li></ul></td></tr></tbody></table>
environmental impact, and high techno-economic impact solutions.

<caption>Table 28: Arguments in favor and against the competition between mechanical and chemical and physico-chemical recycling (RECORD, 2022)</caption>

## Competition between “plastic to plastic” and “plastic to fuel”

### POINTS OF AGREEMENT BETWEEN EXPERTS

As of today, in the EU, the Waste Framework Directive specifies that **recycling does not include plastic-to-fuel nor energy recovery applications**. Recycling means taking waste and transforming it into a material.

<caption>Box 28: Specific examples raised by some experts on the competition between “plastic to plastic” and “plastic to fuel”</caption>

An expert believes that **fuel targeted routes should only be needed to accelerate technology development** (i.e., used to develop specific parts of the technology). At the end, each recycling technology should lead to products (including plastics) with the maximum circularity. **Fuels are only intermediate solutions.** The biggest challenge will be jet fuel as there is no circular alternative yet, and the aviation lobby is very strong. Again, clear regulations are required.

It has to be clear that plastic-to-materials, plastic-to-chemicals, and plastic-to-fuel solutions should not compete but complement each other instead. **The portion of waste dedicated to each of these applications will be the determined by market demand, net-zero ambitions, and regulations.** Hence, the subject of competition between plastic-to-plastic and plastic-to-fuel has to be regulated beforehand. Requirements have to be set for both end-of-life options and there is the need to properly trace waste to understand where the materials will end up. Perhaps, in the future, a difference will be made between high-quality recycling and low-quality recycling. In this case, plastic-to-plastic would be qualified as high-quality recycling.

## Levers to accelerate the development of chemical and physico-chemical recycling technologies

### POINTS OF AGREEMENT BETWEEN EXPERTS

According to most experts, the focus should be on factors facilitating **structuring of the upstream part of the value chain.** This would mainly involve improving collection and sorting systems, as well as avoiding dumping of waste into the environment. Once the upstream of the value chain will have been restructured, the rest of the value chain will be able to adapt at relatively fast and low investment costs. The transformation of the value chain with the aim of reaching circularity will be required. In addition, we should go beyond 1-to-1 collaborations.

Moreover, there is a need for **further transparency regarding technologies** (e.g., LCAs data including GHG emissions, etc.) to understand what can actually be achieved by these processes. It is expected that, in the upcoming months, the JRC will provide a draft report containing an LCA study of different recycling pathways. This document will probably present the common reference and basis on how environmental footprints of different technologies should be calculated.

Finally, from a **regulatory perspective**, it should be ensured that different directives (such as climate, health, waste, etc.) are clear, stable, coherent, and that they do not contradict one another. Sometimes, existing legislation classifies chemical and physico-chemical recycling technologies under incineration due to the presence of thermal treatments. This has an impact on the public acceptance of these recycling methods (notably in France and Spain, Germany is more open).

There is also a need to **harmonize European regulation.** The existing European waste regulation does not ensure that legislation will be harmonized across all Member States. The countries within the EU have the possibility to adapt EU Directives in a slightly different way from one another. This factor generates complexity.

**Clear incentives and recycling targets** for both end-products and chemicals are needed. It should also be key to consider the “true pricing” of chemical and physico-chemical recycling technologies. Less favorable conditions should be created for non-circular solutions, by using taxes for instance. In this way, the industry will know what the future targets will be and will move to develop strategies, partnerships, value chains and technologies accordingly.
Box 29: Specific examples raised by some experts on the levers to accelerate chemical and physico-chemical recycling technologies development

An expert considers the need to develop comprehensive scenario models (including techno-economic aspects and impact perspective) to allow for **technology decision and overall strategic investments**.

## Value chain stakeholders' actions in favor of chemical and physico-chemical recycling development

### POINTS OF AGREEMENT BETWEEN EXPERTS

The stakeholders of the value chain should be **clearer about their future roadmaps**. Defining and working towards long-term objectives would help the stakeholders align with other players within the same value chain. Each player can have its own roadmap, yet, if such roadmap does not match with the upstream and downstream steps of the value chain, it will not be deployed.

Also, they should set higher priority for sustainability targets in companies' roadmaps. The credibility of the whole value chain could be increased by **putting more efforts in achieving the milestones** that have been disclosed as part of future roadmaps.

Stakeholders across the value chain should also align on **feedstock specifications and volumes** using backwards integration and thinking (for instance from products and impact perspective).

Box 30: Specific examples raised by some experts on value chain stakeholders

Value chain's actors could also **help governments and other stakeholders** to better understand the overall industry picture by taking all stakeholders' perspectives into account.

## 2) Limitations of the exercise

The experts' consultation however holds limitations among which:

- **The geographical representativeness of the panel:** Although 16 Japan based organizations were contacted, no Japan experts have accepted to participate in the working sessions. A few American organizations joined the experts' consultation. However, most experts were European. Thus, there is a lack of geographical representativeness.

- **Information sharing:** As the working sessions with experts were not covered by NDA, no confidential information should be shared. This may have limited relevant information sharing that would have allowed us to complement our study.

- **Publicly available information:** Some questions could not have been fully answered as there is still a lack of available information around chemical and physico-chemical recycling, notably on the economic and environmental performances of the processes. This data has not been made public by technology developers. More techno-economic studies should be conducted to better understand the performance of these technologies.

- **Panel constitution on specific topics:** for some topics, the panel was quite heterogeneous in terms of experts and, especially during the economic session, the floor was shared between only a handful of experts (one or two people). Specific information could not be obtained in this case.
## XII. Authors' point of view

Based on the outcomes from the literature review and the experts' consultation, the authors of the study highlighted the following key messages on the relevance of chemical and physico-chemical recycling technologies and their perspectives of development to help reaching plastics circularity.

It has to be noted that classification of chemical and physico-chemical recycling technologies in different overarching categories systematically generates debates. This study on "chemical and physico-chemical" recycling mainly focuses on solvolysis, thermal treatment and dissolution. However, the wording could be adjusted to better reflect reality using for example the terminology "physical and chemical" recycling technologies. For more information, please refer to the paragraph XII.3) below. Moreover, we invite readers to have a look at the sections III and XI.2) of this report to have a better understanding of the limitations of this study.

Please also note the plastic recycling sector is a fast-moving field. In this context, the key messages presented below should be refined relatively quickly based on current and future work progress around recycling technologies.

### 1) "Chemical and physico-chemical" recycling technologies are key to help reaching plastics circularity

If it succeeds to reach industrial and commercial scale, chemical and physico-chemical recycling will help overcoming the limitations of mechanical recycling. Mechanical recycling has limits that narrow the range of solutions to reach a true circular economy. As a matter of fact, the available feedstock to produce food-grade recycled material through this technology is scarce. Hence, only some mechanical recycling plants are currently producing recycled PET (and HDPE to a lesser extent) eligible for food-contact and their capacity is very inferior to the market demand. More generally in mechanical recycling, the end-product's quality limits the end market applications due to the variety of input materials, which have different grades, color, or that might contain legacy substances. Mechanical recycling processes may lack the technical ability to remove all these contaminants, which inevitably alters the final output's quality. Ongoing developments (including R&D) on increasing purity of the outputs of mechanical recycling processes might be able to close some of these gaps but the recycling costs would necessarily increase and the approval by the authorities of the food contact nature of the products still required.

In addition to the quality and feedstock issues, the end of life of products that use mechanically recycled plastics raises question about the true circularity of these technologies' output. Indeed, due to the downcycling effect<fnref n="357" /> of mechanical recycling technologies, the end-product might not meet the market requirements in terms of quality and purity. Its number of recycling cycles might thus be limited, and the plastic produced might not thus become truly circular.

A wide range of chemical and physico-chemical recycling technologies that individually aim at tackling these issues is developing. Indeed, they could lessen the feedstock requirements to produce high-quality and/or food-grade plastics, due to their ability to remove some contaminants or sometimes problematic legacy substances that mechanical technologies cannot handle properly. This would allow to enlarge the eligible feedstock volume and therefore increase recycled high quality material production. The quality of the plastic produced through chemical and physico-chemical recycling could also meet more demanding purity standards. Such products could hence loop through relatively more recycling cycles than mechanically recycled material.

The recycling ability of these technologies aims at broadening recycling horizons and potentially contribute to achieving a circular economy for plastics.

<footnote n="357">³⁵⁷ Product quality lowering by mechanical recycling. Indeed, a part of pollution remains in the end product due to the additives originally present in the feedstock, that were not removed. The final product might therefore an average standard that no longer meets the quality requirements of some markets.</footnote>
**However, like any process, it has its own limits.** As an example, it has been observed that additional sorting and pretreatment steps are often required as a considered chemical and physico-chemical recycling technology cannot treat all types of plastics. In addition, depending on the considered technology, some legacy substances may not be totally removed. Indeed, some studies' results mentioned in the last ECHA report have highlighted the presence of bromine substances in pyrolysis oils. Additionally, it is still not clear to which amount pyrolysis oil can be reused in a steam cracker. Hence, the limitations and uncertainties around chemical and physico-chemical recycling are to be taken into account. These aspects are further detailed in the sections below (in terms of regulatory context, environmental and economic performances, etc.).

**Chemical and physico-chemical recycling is complementary to mechanical recycling.** In situations where mechanical recycling offers a product of sufficient quality for applications driven by a sophisticated market, mechanical recycling will be more environmentally friendly and cost competitive. It will consequently and naturally be the preferred option of the market. It is however key that a level playing field is ensured between all technologies, especially on regulatory and feedstock access aspects (see Error! Reference source not found. and Error! Reference source not found.).

**Generally, chemical and physico-chemical recycling should be seen as one instrument within a wider range of relevant circular solutions.** It is important to acknowledge that chemical and physico-chemical recycling technologies are one of the solutions to a bigger challenge that encompasses resource preservation and climate change mitigation. These processes are dedicated to solving specific issues and such solution should not limit actions that focus on circularity beyond recycling: eco-design, better collection and sorting, reuse, new business models, etc.

2) Dynamism around the development of "chemical and physico-chemical" recycling technologies is massive. However, only a few plants are at industrial scale

**The market of chemical and physico-chemical recycling is actively developing.** The news is currently flooded with announcements of projects in construction or planned. The recycling capacities are **expected to tenfold** in the next five years if all these announcements are met (see Figure 13). Production volumes should follow the trend and reach unseen levels. There is undoubtedly an infatuation around these technologies on the current recycling market.

**To this end, numerous stakeholders of the whole value chain are taking part in this development.** Brands are providing support for chemical and physico-chemical recycling technologies as the latter could help them meet their recycled content targets. They are offering financial support in different forms (offtake agreements, joint ventures...). Petrochemical industries are also either developing their own technologies or collaborating with developers themselves to expand on the chemical and physico-chemical recycling market. Waste management companies are as well supporting the growth of chemical and physico-chemical recycling technologies by investing in the upcoming plants or financially contributing to their progress. However, the interest that stakeholders are sharing for these technologies can be modulated. There is an urgent need to structure the value chain and to reorganize several industrial assets to adapt to chemical and physico-chemical recycling's issues and needs (e.g., refining steps usually used by the petrochemical industry to be fully adapted to the treatment of pyrolysis oils). The current craze around chemical and physico-chemical recycling technologies is not yet driving this change. Please note that further details on the structure of the entire value chain are presented at the end of this section.

**The potential of these technologies to reach commercial scale however remains to be proven.** Numerous stakeholders of the value chain have significantly invested in chemical and physico-chemical recycling technologies. However, a large share of these technologies is currently at pilot or demonstration scale and there are some examples of failures to scaling up (Vinyloop for instance). Very few industrial scale plants are in operation nowadays. Indeed, scaling-up a technology is a long process. Generally, around 10 years are necessary to reach commercial scale from lab scale. This development should be carefully planned. Numerous factors must be taken into account to properly attain commercial scale such as technical, regulatory, economic, or environmental considerations. There may be hence a
gap between the interpretation that one can have of the technologies and their real progress, often less optimistic. The bibliography and technology developers' announcements can be misleading on this point. The promises of such announcements should thus be handled with caution.

### 3) "Chemical and physico-chemical" recycling technologies are very diverse, and each must be considered individually

**Classification of chemical and physico-chemical recycling technologies in different overarching categories systematically generates debates.** Classifying these technologies might be an arduous process and there is currently no consensus on the terminologies used. Indeed, dissolution processes might not be considered as "chemical" technologies in the sense that they do not usually alter the polymer structure. However, it is arguable that depending on the solvent chosen, there can be a reaction with the polymer. This technology can thus either be considered as physical or chemical and physico-chemical recycling.

This study on "chemical" recycling mainly focuses on solvolysis, thermal treatment and dissolution. However, the wording could be adjusted to better reflect reality using for example the terminology "physical and chemical" recycling technologies.

**The nature and number of steps needed to go back to plastics, with the proper specifications, might be very different from one technology to another.** The different outputs produced by chemical and physico-chemical recycling technologies are more or less easily reprocessed. Indeed, some technologies are producing monomers that can be directly repolymerized while others need additional steps to transform the output back into plastics.

* For example, pyrolysis processes can either produce monomers (when applied to PMMA or PS feedstock for instance) or a hydrocarbon mix (such as pyrolysis oil). The latter requires several downstream steps before it can be reinjected into a cracker (or be polymerized again if the process applied allows for high content of aromatics in the output oil). Some specific steps usually used by the petrochemical industry can be applied to reprocess pyrolysis oils (such as refining). However, these petrochemical processes are not fully developed for this application yet. This could represent a brake on the development of pyrolysis processes.

* Regarding gasification, the main output is syngas which has to undergo multiple conversion steps to allow for the production of chemical intermediates that could eventually be used again for the production of polymers.

* On the contrary, when producing monomers, the downstream steps are less stringent. However, some depolymerization processes produce a chemical intermediate that would require the addition of the monomer to complete the repolymerization. This monomer is currently a virgin polymer, which calls into question the circularity of the process. Indeed, it is not usually possible to go back to polymers without the addition of some virgin monomers.

* Other recycling technologies, such as dissolution, directly produce purified polymers. These technologies would require less downstream steps.

In general, it has to be noted that the number of pretreatment and purification steps required will depend on the feedstock, the technology, and the desired end-product specifications.

**Each technology is specific in terms of feedstock targeted, output produced and operational conditions.** Technologies also differ in terms of scale of operations and their ability to handle different feedstocks. Indeed, the challenges associated to the recycling of specialty polymers and commodity polymers are very different. The first category would need a technology able to efficiently treat low quantities of material in a cost-effective manner. The latter on the contrary would need bigger reactors able to handle high volumes of contaminated waste. Dynamics of the market are thus guiding the choice of technology and feedstock.
4) Based on available information, chemical and physico-chemical recycling appears as a solution that could bring environmental benefits. However, the environmental performance of chemically recycled products still needs to be fully demonstrated.

Available information on the environmental performance of chemical and physico-chemical recycling processes demonstrates benefits (notably taking into account the climate change indicator). Benefits of chemical and physico-chemical recycling technologies against conventional virgin production or usual end of life processes (e.g., incineration) are highlighted by technology developers. Indeed, numerous results disclosed show that the processes are less emissive than virgin production (even if more impactful than mechanical recycling).

These benefits also depend on several critical parameters such as:

* The **availability of the feedstock near the plant**. Indeed, the need to source feedstock further away necessitates transportation of the waste, which can deteriorate the environmental performance.

* The **composition of the feedstock**. Purification and pretreatment steps would need to be more thorough and thus more impactful in case of a contaminated feedstock.

* The **technology type**. The further the technology goes back into the polymer production steps, the higher the environmental impacts will become. As an example, pyrolysis breaks down polymer chains to come back to the monomers or initial components. Thus, this process may be energy intensive and have higher environmental impacts.

* The **gap with virgin material environmental performance**. Indeed, some polymers (such as specialty polymers) require lots of energy to be manufactured. Chemical and physico-chemical recycling gains could thus more easily be achieved than for commodity chemicals, whose virgin production process consumes less energy.

* The used **methodology and studied indicators**.

* Most communications focus on GHG emissions only while circular economy is in the first place about resource preservation. It is key to focus on other indicators such as resources preservation instead of solely on GHG emissions.

* Taking into account the climate change indicator, the chemical route may be assessed as more impactful than virgin material depending on the end-of-life reference scenario chosen, especially if a landfill reference scenario is chosen. Mechanical recycling can be less impactful; however it produces lower grade applications (the functional unit is then different).

* The lack of consensus on the methodology to be used contributes to the multiplication of impact assessments that are not comparable to one another, as they are elaborated using different methodologies. Other factors can have an impact on the environmental performance of the process such as the data used, the geographical area considered and the associated energy mix, etc.

**Due to a lack of publicly available data, environmental benefits of chemical and physico-chemical recycling technologies still have to be largely demonstrated.** Although the LCA figures shared by the technology developers and the public reports usually highlight the environmental benefits of chemical and physico-chemical recycling technologies at first sight, there is currently a lack of publicly available data. This missing information usually includes methodology and assumptions used, which are essential in understanding the presented results. The figures shared by technology providers are often unverifiable. It is thus difficult to prove the environmental benefits of chemical and physico-chemical recycling technologies. Very few developers are indeed publishing a critical review of their environmental data.

**Environmental assessment methodologies should evolve to better assess the reality of the value chains and markets.** The objective of the transition to circular models is to enhance the value of recycling operations compared to the use of virgin polymer, to appreciate a change of end-of-life treatments, and, overall, to acknowledge the environmental impact of the product that is being sold and put on the market. Current environmental assessment methodologies do not allow a fair comparison between mechanical and chemical and physico-chemical recycling as the differences in terms of output quality and the number of lifecycles of the recycled materials are not accounted for. It is thus necessary to implement a factor rationalizing these differences into the environmental impact assessments. Other
aspects should be taken into account such as the expected economy of scale once the technology reaches commercial scale.

**The comparison of chemical and physico-chemical recycling impacts with alternative end-of-life treatments reflects the current reality of the market but should evolve over time.** The dynamics of change and the effort put in transitioning from a linear to a circular economy must be valued. In this sense, the comparison of chemical and physico-chemical recycling with other end-of-life treatments, such as incineration and landfilling, could be considered at a first step. The environmental assessments of technologies and the associated methodologies will be evolving.

5) **In the current context, regulations should not hinder the development of chemical and physico-chemical recycling. Clarification of the current and future regulatory context is expected to ease investment decision making processes**

**There is currently a lack of harmonized definition.** Existing recycling regulations mostly apply to mechanical technologies, leaving a doubt on their application to chemical and physico-chemical recycling technologies. These technologies are not clearly defined nor classified. The application of existing regulations is thus unclear when it comes to chemical and physico-chemical recycling. Among the three geographies studied (Japan, Europe, and USA), not one clearly states its position on chemical and physico-chemical recycling and if these technologies could be qualified as "recycling". There is thus an urgent need for alignment from policy makers on this topic.

**There are differences between geographical areas, which do not allow for a level playing field regarding chemical and physico-chemical recycling.** The different definitions of a recycled material between the US, Japan and EU may add complexity. Indeed, some states in the United States are promoting several chemical recycling technologies whereas the European regulation is unclear.

**A clear legal framework is necessary.** In order to be developed, chemical and physico-chemical recycling technologies would need clarity on current and future regulations, uncertainties should be lifted. For example, explicit guidelines should be defined regarding the implementation of the mass balance approach. This approach indeed has the potential to boost the development of recycling technologies during a transition phase. Stable material traceability should however be implemented on the longer term. Regulations should also be clearer regarding the end of waste status and harmonized around the different geographies.

**Regulations should ensure a level playing field between all recycling technologies.** While regulations should not hinder the development of chemical and physico-chemical recycling it should not bring a competitive advantage to these technologies compared to mechanical recycling or other circular economy solutions such as prevention or reuse. Access to feedstock for both chemical and mechanical recycling, proven environmental benefits for the market and possible associated economic instruments are among the critical aspects to be considered.

6) **Feedstock appears as the critical aspect of chemical and physico-chemical recycling development**

**Policies and programs should ensure that feedstock is available (with sufficient volumes and quality) for all recycling activities.** Due to the low volumes of available plastics collected for recycling compared to the recycled material demand, a competition between recyclers is likely to occur for feedstock access. It is thus key to secure sufficient volumes of waste with the proper specifications to ensure the development of chemical and physico-chemical recycling technologies.

**The feedstock specifications are of consequent importance for the development of a technology.** Although some technology developers claim that preparation of feedstocks is not required, it seems that pretreatment steps (such as the removal of contaminants, crushing, washing, etc.) are nonetheless
necessary before entering the recycling process. The higher the quality of the feedstock will be, the less
thorough the pretreatment steps will have to be. Access to proper feedstock, in terms of quality and
volumes, is therefore key in the technological development of chemical and physico-chemical recycling.
A tremendous challenge faces the collection and sorting systems to meet these criteria. This challenge
should be addressed country by country due to the significant variety of schemes across geographies.

**The ability to meet feedstock specifications is one of the criteria that most impact the economic equation.** The feedstock volumes and quality play a tremendous role on the economics of a plant. First, quality and price of the feedstock directly and largely impact the operational costs. Especially the impact of quality on the yield is critical as it lowers the revenues (by lowering the volumes sold compared to the volume purchased), grows the amount of waste produced and the associated costs and increases the needed quantity of resources, such as energy or solvent, per unit produced. In addition, the plant structures are dimensioned on these criteria. Low quality feedstock will lead to the necessity of buying higher volumes to reach the necessary amount of polymer of interest. Taking into account the massive impact of CAPEX on the cost structure of chemical and physico-chemical recycling, any oversize of the process and equipment (e.g., reactor) would harm the economics of chemical and physico-chemical recycling.

7) More broadly, the building of the whole value chain is necessary from feedstock supply to the production of the end product

**It is necessary to ensure a proper match between the feedstock used, the technology applied and the end-product application.** One single technology is not able to treat all types of feedstocks and their specificities. The best match between feedstock composition (including the polymers' type), technology and the desired end-product specifications should be found. It has to be highlighted that the challenges for the chemical and physico-chemical recycling of plastic waste differ from one polymer to another, especially between commodity and specialty polymers. Indeed, volumes of specialty polymers might be scarce and scattered, which would require recycling processes that are efficient in treating lower volumes. As for commodity polymers, the purity of the feedstock might be an issue and the technology used would thus have to be able to handle contaminants.

**Partnerships and cooperation along the whole value chain should be implemented.** For each technology, a specific value chain should be built suiting the characteristics needed. The following requirements would have to be met to ensure proper scaling up of the technologies:

- Secure feedstock supply with waste management companies should be ensured.

- Agreements with petrochemical companies or polymer manufacturers to ensure purification steps (such as refining steps for instance) should be completed when needed.

- **Partnerships with polymer manufacturers** that could conduct the repolymerization step should be made.

- **Partnerships with academics** for analyses of the recycled materials should be established.

- **Partnerships with brand-owners** for the purchase of recycled end-products

- **Financing of the plant** should be secured. Diverse sources of funding could be considered (including grants, investments from brand-owners, polymer manufacturers, etc.)
### XIII. Conclusion

The aim of this report was to assess current chemical and physico-chemical recycling technologies and their future perspectives of development, focusing on plastic-to-plastic applications.

The solvolysis technologies assessed demonstrated the opportunity of producing a high-purity, virgin-like material that could be suitable for food-grade applications. With projects currently at a relatively advanced development stage, these technologies seem to be the most promising chemical and physico-chemical recycling processes despite a lack of transparency on potential pretreatments and purification steps needed. Their complementarity to mechanical recycling makes their potential market and applications sustainable, as long as the two technologies don't compete for feedstock access. This implies that progress has to be made on existing collection and sorting systems to ensure an appropriate feedstock distribution between recycling processes.

It is also important to ensure that the output of these processes comply with the existing regulations in place (for instance that the monomers can be REACH registered).

The economic viability of this process is however unsure, with potential high costs of pretreatment steps and high investments needed.

Similarly, the environmental benefits of such technologies are difficult to assess and very few technology developers have shared their LCA methodology to this point.

Dissolution technologies are mostly developing towards contaminated stream applications or plastic containing additives, such as plastics containing flame retardants. Indeed, these technologies can, in some cases, treat separately the plastic from its additives and are thus among the only technologies capable of recycling WEEE plastics. However, the opportunity of using the recycled product for food-grade applications still has to be proven. In addition, the use of solvent and its potential environmental and economic impacts is still a point lacking clarity for now.

The thermal treatment technologies have demonstrated their ability to handle relatively mixed waste streams, even though some non-processable inputs have to be removed beforehand. However, these technologies are used both for plastic-to-plastic and plastic-to-fuel applications. Numerous downstream steps are needed to produce a recycled polymer (purification of the hydrocarbon mix, integration in virgin value chains, etc.). This is also the case, although to a lower extent, for technologies focused on PS and PMMA depolymerization. There are thus few examples of advanced plastic-to-plastic facilities.

Moreover, the economic viability of such installations has not been proven, due to the lack of communication from the developers on the costs of feedstock pre-treatment and purification steps.

The environmental benefits of such technologies are also unsure due to a lack of public LCA on these processes and the particularly high energy demand of the different processes.

The main obstacle to the development of these technologies comes from the lack of structure of the entire value chains. Waste resources do not seem to be secured and are mostly directed to incineration or landfill. Partnerships with stakeholders need to be put in place in order to ensure access to feedstock (with sufficient volumes and quality).

Finally, there is generally a regulatory uncertainty on chemical and physico-chemical recycling across the world. Regulatory ambiguity on the topic of chemical and physico-chemical recycling can be found across the three regions studied (Europe, United States and Japan). Exceptions exist. As an example, in some parts of the United States dozens of American states have passed bills to support chemical recycling facilities. No geography has yet ruled on the definition of "recycled material" and the technologies that are eligible for such denomination.

Moreover, the implementation of a mass balance approach currently generates debates among various stakeholders (public authorities, petrochemical industries, NGOs, etc.) and seems not to be accepted in any of the regions studied.

These technologies development can be impacted by several factors. Indeed, the evolution of regulations can help chemical processes to expand to commercial stage by removing some uncertainties. The evolution of eco-design trends will lead to the transformation of feedstock composition. This change in waste composition can be beneficial for recyclers, by avoiding additional costly and environmentally impactful steps of the processes. Simplification of the processes can also be levered by the evolution of collection and sorting techniques sorting. These trends should boost the
numerous projects in progress. Indeed, current plans are involving all the actors of the value chain and
include ambitious objectives of plant construction in the future years that could be met if the
aforementioned criteria are reconciled.

Thanks to the literature review and the authors' point of view, this study can regroup the highlights of chemical and physico-chemical recycling technologies and of their development perspectives. Some uncertainties however remain as these processes are still under development and not all questions can be answered. There is thus a need for more technical-economic data and LCA studies, among others, to fully capture the challenges of chemical and physico-chemical recycling technologies and answer potential concerns from brand owners, recyclers, legislators, and the other stakeholders of the value chain.
# Appendix I. Theoretical economic reference models

**Please read this note first:** To highlight the main factors influencing the price of recycled material, some theoretical economic models were developed. The core objective of this work was to determine the main critical parameters that can impact the cost of chemically recycled material and potentially contribute to its economic competitiveness. The models have been computed based on publicly available information or, when not available, estimated data. The figures thus lack in robustness and precision, especially when estimated.
The results are thus to be interpreted as orders of magnitude of figures. They aim at giving an estimation of the potential costs associated with the different recycling technologies and are not to be interpreted as exact actual figures.

## Appendix I.1. Introduction

Three models have been established, each taking into account a different technology:

* **Dissolution of PS:** the cost of the recycled materials has been computed from the purchase of plastic waste to the production of the recycled resin by the technology developer.

* **Hydrolysis of PET:** the cost of the different materials has been computed from the purchase of plastic waste to the production of the monomers – Monomers produced should be ideally comparable to virgin petrol-based monomers in terms of quality.

* **Pyrolysis of polyolefins:** the cost of the different materials has been computed from the purchase of plastic waste to pyrolysis oil production. The oil produced has been compared to the production of naphtha from the petrol-based industry, even though the composition is different.

The scope chosen for the data collection is European.

In all models, similar hypotheses regarding the size of the installation, the energy costs, the efficiency of the different equipment were chosen, in order to ensure the comparability of the three models to one another. The base installation characteristics are:

- An output capacity of 18 000 tons per year of recycled product.

- Load hours of 8 000 hours per year.

- Fixed operating costs (personnel costs, insurance costs, tax...) were not modeled into detail but it was ensured that they were approximately similar as the size of the installation is considered to be the main factor in its end value.

**No catalysts were considered in any of the 3 models** due to the diversity of options available. Indeed, including a catalyst may significantly change the results and thus harm the comparability of the subsequent data. Similarly, no dangerous waste was considered in any of the 3 models. It was thus assumed that the feedstock bought either does not contain any dangerous components or has been presorted before the process to remove such components.

The following costs **were excluded of our analysis:** patent costs, interests costs linked with capital debt, exchange rate costs and inflation (all costs considered are in €2020 without any inflation rate).

The aim of the models is to compare the costs of chemically and physico-chemically recycled materials with the market price of virgin-based alternatives. The analysis has been conducted by defining two scenarios: a "worst-case" scenario, taking the upper end of each hypothesis, and a "best-case scenario", which assumes the most favorable hypothesis. These two scenarios have afterwards been averaged to define a final cost of the recycled material, which **does not take into account any commercial margin**, contrary to the prices of the virgin equivalents that they are compared to.

## Appendix I.2. PET hydrolysis

The Hydrolysis of PET, as stated in section V.4), produces PTA and MEG as outputs.

Different steps were considered for the cost analysis that was conducted. These steps are represented on Figure 22 below. The perimeter considered starts from the purchase of the waste by the technology
developer (and thus from the pretreatment done in the chemical recycling plant) to the purification of the monomers produced (MEG and PTA). The repolymerization step is thus excluded. In the following paragraphs, the terminology “PET equivalent” designates the quantities of PTA and MEG necessary to produce 18 000 tons of PET, without taking into account any repolymerization losses. The process of **neutral Hydrolysis** was considered in the thereafter study.

<figure><img src="image_57.png" /><figcaption>Figure 22: Steps considered for the PET Hydrolysis process (RECORD, 2022)</figcaption></figure>

Depending on the scenario considered, more or less material and energy are needed. The **mass and energy balance** of this process are presented thereafter in Figure 23, for the best case and worst-case scenario.

<figure><img src="image_58.png" /><figcaption>Figure 23: Mass and energy balance of the PET hydrolysis process (RECORD, 2022)</figcaption></figure>

The results of this analysis are presented in Figure 24 below. According to this study, the production of recycled PET equivalent by Hydrolysis costs about **300% more than the price of virgin PTA and MEG** (average value of a minimum and a maximum scenario). The price of the virgin monomers however includes a commercial margin contrary to the costs computed.

<figure><img src="image_59.png" /><figcaption>Figure 24: costs of chemically recycled PET equivalent compared with its virgin alternative (left) and breakdown by scenario (right) (RECORD, 2022)</figcaption></figure>

The costs repartition by category and the main hypotheses are presented in Table 29 below.
$$ \sum costs = $$

Pretreatment costs

<figure><img src="image_60.png" /></figure>

Energy and solvent costs

<figure><img src="image_61.png" /></figure>

Purification costs

<figure><img src="image_62.png" /></figure>

Other operational costs

<figure><img src="image_63.png" /></figure>

Depreciation costs

<figure><img src="image_64.png" /></figure>

<figure><img src="image_65.png" /></figure>

<figure><img src="image_66.png" /></figure>

<figure><img src="image_67.png" /></figure>

<figure><img src="image_68.png" /></figure>

The pretreatment costs are divided between the **cost of buying the feedstock** for the process and the **costs of the additional sorting necessary** to ensure that the input complies with the process requirements.

Two cases were considered:

* In the "best case" scenario, the feedstock is assumed to be composed of sorting refusals and **purchased at 400€/t of feedstock**. Due to the relatively bad quality of the feedstock, it was considered **that additional sorting costs were about 300 €/t of feedstock**, as it contains impurities (about 30% of the feedstock weight is assumed).

* In the "worst case" scenario, the feedstock is assumed to be cleaner and contains less impurities (about 5%). It was thus considered that it was bought at **600€/t and additional sorting costs of 150 €/t of feedstock** were applied.

The energy costs are divided between the **use of electricity for compression and the use of steam to heat up the reaction media**. The major cost is **electricity**, representing in each scenario more than half of the total costs. Indeed, less electricity than steam is needed but the **cost of electricity in Europe is higher than the cost of natural gas** (used in the boilers to produce steam).

The **solvent cost** represents the **lesser fraction** of the total costs, as the hydrolysis process uses only water. The weight of water needed ranges from 5 to 12 times the weight of PET respectively in the minimum or maximum scenario.

The costs of purification considered were the **costs of distillation of the solvent**, the **purification of PTA** (through crystallization) and the **distillation of MEG**. The costs of mechanical purification operations, such as filtering or mechanical separation, are included in the equipment costs, as they do not require significant variable costs.

The most important cost is the **distillation of water, due to the relatively high amount of water** used in the maximum scenario.

The other operational costs (some operational costs have been covered in the recycling or purification costs) are divided between **waste management costs** and **other fixed costs**.

**Other fixed costs** include operational labor costs, costs of managers and supervisors, staff overheads, fixed annual maintenance costs, property tax and insurance, building allowance/lease, general overheads, laboratory costs, research & development (R&D), environmental taxes and fixed costs for heat and/or electricity consumption (grid management costs).

**Waste management costs** represent the costs needed to eliminate the impurities extracted from the feedstock during the presorting step and the reaction losses.

**Water used as a solvent must then be treated** as it might be polluted after the process.

The depreciation costs are divided between **equipment depreciation costs** (92%) and **building depreciation costs** (8%).

The equipment lifespan was assumed to be **10 years** whereas the building lifespan is assumed to be **20 years**. The residual value of both is assumed to be null.

The investment costs were **computed using different announcements of the technology developers' facilities** and thus include all costs needed to build a chemical recycling plant (i.e., environmental taxes, equipment costs, electricity, and water network costs, building costs...).

<caption>Table 29: Hydrolysis cost repartition (RECORD, 2022)</caption>
## Appendix I.3. PS dissolution

The dissolution of PS, as stated in section VI, produces purified PS as an output. Different steps were considered for the cost analysis that was conducted. These steps are represented on Figure 25 below. The perimeter considered starts from the purchase of the waste by the technology developer (and thus from the pretreatment done in the physico-chemical recycling plant) to the purification of the PS produced.

<figure><img src="image_69.png" /><figcaption>Figure 25: Steps considered for the PS Dissolution process (RECORD, 2022)</figcaption></figure>

Depending on the scenario considered, more or less material and energy are needed. The **mass and energy balance** of this process are presented thereafter on Figure 26, for the best-case and worst-case scenario.

<figure><img src="image_70.png" /><figcaption>Figure 26: Mass and energy balance of the PS dissolution process (RECORD, 2022)</figcaption></figure>

The results of this analysis are presented in Figure 27 below. According to this study, the production of recycled PS equivalent by dissolution **costs about 80% more than the price of virgin PS**. The price of virgin PS however includes a commercial margin contrary to the costs computed.

<figure><img src="image_71.png" /><figcaption>Figure 27: costs of chemically recycled PS compared with its virgin alternative (left) and breakdown by scenario and type of cost (right) (RECORD, 2022)</figcaption></figure>

The variations between the two scenarios are mostly due to the purification steps. Indeed, hypotheses made about the solvent (p-xylene in the best-case scenario and cymene in the worst-case scenario) are contributing to higher purification costs.

Purification costs are the most important costs with 35% of the total costs in the average value.

The costs repartition by category and the main hypotheses are presented in Table 30 below.
$$ \sum costs = $$

<table><caption>Table 30: Dissolution cost repartition (RECORD, 2022)</caption><thead><tr><th>Pretreatment costs</th><th>Energy and solvent costs</th><th>Purification costs</th><th>Other operational costs</th><th>Depreciation costs</th></tr></thead><tbody><tr><td><p>240 €/t<br>of chemically recycled PS</p><p>260 €/t<br>of chemically recycled PS</p><p>250 €/t<br>of chemically recycled PS</p><p>Minimum scenario</p><p>Maximum scenario</p><p>Average value</p></td><td><p>1 €/t<br>of chemically recycled PS</p><p>13 €/t<br>of chemically recycled PS</p><p>7 €/t<br>of chemically recycled PS</p><p>Solvent cost</p><p>Electricity cost</p><p>Minimum scenario</p><p>Maximum scenario</p><p>Average value</p></td><td><p>600 €/t<br>of chemically recycled PS</p><p>700 €/t<br>of chemically recycled PS</p><p>650 €/t<br>of chemically recycled PS</p><p>Solvent elimination cost</p><p>Other operations (such as drying, extrusion costs)</p><p>Other operations (such as drying, extrusion costs)</p><p>Solvent elimination cost</p><p>Minimum scenario</p><p>Maximum scenario</p><p>Average value</p></td><td><p>320 €/t<br>of chemically recycled PS</p><p>280 €/t<br>of chemically recycled PS</p><p>300 €/t<br>of chemically recycled PS</p><p>Waste management cost</p><p>Other fixed operational costs</p><p>Other fixed operational costs</p><p>Other fixed operational costs</p><p>Minimum scenario</p><p>Maximum scenario</p><p>Average value</p></td><td><p>120 €/t<br>of chemically recycled PS</p><p>700 €/t<br>of chemically recycled PS</p><p>410 €/t<br>of chemically recycled PS</p><p>Equipment depreciation cost</p><p>Equipment depreciation cost</p><p>Building cost</p><p>Building depreciation cost</p><p>Minimum scenario</p><p>Maximum scenario</p><p>Average value</p></td></tr></tbody></table>
## Appendix I.4. Pyrolysis of polyolefins

The pyrolysis of polyolefins, as stated in section 1), produces a purified oil as an output, that can be used as a substitute for virgin naphtha. The following economic assessment is centered on fast pyrolysis, as it is the most favorable option to maximize oil yield, and thus to produce plastic.

Different steps were considered for the cost analysis that was conducted. These steps are represented on Figure 28 below. The perimeter considered starts from the purchase of the waste by the technology developer (and thus from the pretreatment done in the chemical recycling plant) to the refining of the pyrolysis oil produced. Steam cracking operations are thus not taken into account in the subsequent model.

<figure><img src="image_72.png" /><figcaption>Figure 28: Steps considered for the pyrolysis process (RECORD, 2022)</figcaption></figure>

Depending on the scenario considered, more or less material and energy are needed. The **mass and energy balance** of this process are presented thereafter in Figure 29, for the best-case and worst-case scenario.

<figure><img src="image_73.png" /><figcaption>Figure 29: Mass and energy balance of the polyolefin's pyrolysis process (RECORD, 2022)</figcaption></figure>

The results of this analysis are presented in Figure 30 below. According to our analysis, the production of recycled naphtha by pyrolysis costs about 400% more than the price of virgin naphtha. The price of virgin naphtha however includes a commercial margin contrary to the costs computed.

<figure><img src="image_74.png" /><figcaption>Figure 30: costs of pyrolysis oil compared with its virgin alternative (left) and breakdown by scenario and type of cost (right) (RECORD, 2022)</figcaption></figure>

Depreciation costs are the most important costs with 47 % of the total costs in the average value.

The costs repartition by category and the main hypotheses are presented in Table 31 below.
$$ \sum costs = $$

Pretreatment costs

<figure><img src="image_75.png" /></figure>

Energy and solvent costs

<figure><img src="image_76.png" /></figure>

Functionning costs

<figure><img src="image_77.png" /></figure>

Other operational costs

<figure><img src="image_78.png" /></figure>

Depreciation costs

<figure><img src="image_79.png" /></figure>

<figure><img src="image_80.png" /></figure>

<figure><img src="image_81.png" /></figure>

<figure><img src="image_82.png" /></figure>

<figure><img src="image_83.png" /></figure>

The pretreatment costs are divided between the **cost of buying the feedstock** for the process and the **costs of the additional sorting necessary** to ensure that the input complies with the process requirements.

Two cases were considered:

* In the "best case" scenario, a **feedstock price of 400 €/t of feedstock** was applied. It was moreover considered that **additional sorting costs were about 300 €/t of feedstock**, as the feedstock purity is low (about 70%).

* In the "worst case" scenario, the **feedstock** is cleaner and contains less impurities (about 10%). It was thus considered that it was **bought at 600 €/t and additional sorting costs of 150 €/t of feedstock** were applied.

The energy costs to heat up the reaction media and to purify the oil produced **are considered to be null** as they are covered by the **combustion of char and gases produced**.

Thus, the only energy costs considered represents the **use of electricity** to start up and fuel the different equipment.

The main difference between the two scenario lies in the **valorization of char**, which is burnt for **energy recovery in the minimum scenario** and dealt as **waste in the maximum scenario**.

It is however important to note that if the **feedstock** contains **dangerous compounds**, burning char and gases produces might liberate these compounds in the atmosphere. Thus, a **treatment of fumes should be added at the chimney** (e.g., dry slaughtering with sodium bicarbonate).

The functioning costs of the recycling process represent the **use of electricity** to start up and fuel the different equipment.

The major costs in the minimum scenario are **electricity** as the pyrolysis reactor is considered to be self-heating (the high reaction temperatures are reached by burning gases and char). Electricity is thus only needed to startup the installation and provide for the different equipment needs.

The other operational costs (some operational costs have been covered in the recycling or purification costs) are divided between **waste management costs** and **other fixed costs**.

Other fixed costs include operational labor costs, costs of managers and supervisors, staff overheads, fixed annual maintenance costs, property tax and insurance, building allowance/lease, general overheads, laboratory costs, research & development (R&D), environmental taxes and fixed costs for heat and/or electricity consumption (grid management costs).

Waste management costs represent the costs needed to **eliminate the impurities** extracted from the feedstock during the presorting step and the reaction losses. They were calculated assuming a **140 €/t fee** (cost of landfill).

The depreciation costs are divided between **equipment depreciation costs** (93%) and **building depreciation costs** (7%).

The equipment lifespan was assumed to **be 10 years** whereas the building lifespan is assumed to be **20 years**. The residual value of both is assumed to be null.

**Start-up costs** that may be incurred by the construction of a unique plant and the need to store materials, solvents, etc. **are not considered in this analysis**.

<caption>Table 31: Pyrolysis cost repartition (RECORD, 2022)</caption>
Appendix II. Glossary of abbreviations and units & English-French lexicon

<table><thead><tr><td>Abbreviation</td><td>Definition</td></tr></thead><tbody><tr><td>ABS</td><td>Acrylonitrile Butadiene Styrene</td></tr><tr><td>ACC</td><td>American Chemistry Council</td></tr><tr><td>ADEME</td><td>Agence de l'Environnement et de la Maîtrise de l'Énergie</td></tr><tr><td>Alu</td><td>Aluminium</td></tr><tr><td>APR</td><td>Association of Plastic Recyclers</td></tr><tr><td>ASR</td><td>Automotive Shredder Residue</td></tr><tr><td>BHET</td><td>Bis(2-hydroxyethyl) terephthalate</td></tr><tr><td>BOPET</td><td>Biaxially-oriented polyethylene terephthalate</td></tr><tr><td>CHDM</td><td>Cyclohexanedimethanol</td></tr><tr><td>CO</td><td>Carbon monoxide</td></tr><tr><td>CO<sub>2</sub></td><td>Carbon dioxide</td></tr><tr><td>C5/C10/C20/C50</td><td>5/10/20/50 carbon building blocks</td></tr><tr><td>ECHA</td><td>The European Chemicals Agency</td></tr><tr><td>EFSA</td><td>European Food Safety Authority</td></tr><tr><td>DMT</td><td>DiMethylTerephtalate</td></tr><tr><td>EMF</td><td>Ellen MacArthur Foundation</td></tr><tr><td>EPA</td><td>Environmental Protection Agency</td></tr><tr><td>EPR</td><td>Extended Producer Responsibility</td></tr><tr><td>(E)PS</td><td>Expanded polystyrene</td></tr><tr><td>EU</td><td>European Union</td></tr><tr><td>FDA</td><td>Food and Drug Administration</td></tr><tr><td>GHG</td><td>Greenhouse gas</td></tr><tr><td>H<sub>2</sub></td><td>Hydrogen</td></tr><tr><td>HBCD</td><td>Hexabromocyclododecane</td></tr><tr><td>HDPE</td><td>High density polyethylene</td></tr><tr><td>Hydr. mix</td><td>Hydrocarbon mix</td></tr><tr><td>HIPS</td><td>High Impact Polystyrene</td></tr><tr><td>H<sub>2</sub>S</td><td>Hydrogen sulfide</td></tr><tr><td>HVC</td><td>High-Value Chemicals</td></tr><tr><td>JRC</td><td>Joint Research Centre</td></tr><tr><td>LCA</td><td>Lifecycle Analysis</td></tr><tr><td>LDPE</td><td>Low density polyethylene</td></tr><tr><td>MEG</td><td>MonoEthylene Glycol</td></tr><tr><td>NDA</td><td>Non-Disclosure Agreement</td></tr><tr><td>NGO</td><td>Non-governmental organization</td></tr><tr><td>NH<sub>3</sub></td><td>Ammonia</td></tr><tr><td>NO<sub>x</sub></td><td>Nitrogen oxides</td></tr><tr><td>PA/PA.6</td><td>Polyamide/Nylon 6</td></tr><tr><td>PB</td><td>Polybutylene</td></tr><tr><td>PBT (or PBTP)</td><td>Polybutylene téréphtalate</td></tr><tr><td>PC</td><td>Polycarbonate</td></tr><tr><td>PCR</td><td>Post-consumer resin</td></tr><tr><td>PDMS</td><td>Polydimethylsiloxane</td></tr><tr><td>PE</td><td>Polyethylene</td></tr><tr><td>PEN</td><td>Poly(oxy-1,2-ethanediyloxycarbonyl-2,6-naphthalenediylcarbonyl</td></tr><tr><td>PET</td><td>Polytéréphtalate d'éthylène</td></tr><tr><td>PIP</td><td>Polyisoprene</td></tr><tr><td>PMMA</td><td>Poly(methyl methacrylate)</td></tr><tr><td>PMP</td><td>Polymethylpentene</td></tr><tr><td>PP</td><td>Polypropylene</td></tr><tr><td>PRE</td><td>Plastic Recyclers Europe</td></tr></tbody></table>
<table><tr><td>PS</td><td>Polystyrene</td></tr><tr><td>PTA</td><td>Purified terephthalic acid</td></tr><tr><td>PTMP</td><td>Polytétraméthylène</td></tr><tr><td>PU</td><td>Polyurethane</td></tr><tr><td>PVC</td><td>Polyvinyl chloride</td></tr><tr><td>r-</td><td>Recycled</td></tr><tr><td>REACH</td><td>Registration, Evaluation, Authorization and Restriction of Chemicals</td></tr><tr><td>R&amp;D</td><td>Research &amp; Development</td></tr><tr><td>WEEE</td><td>Waste Electrical and Electronic Equipment Directive</td></tr><tr><td>Zn</td><td>Zinc</td></tr></table>

<table><thead><tr><td>Unit of measure</td><td>Definition</td></tr></thead><tbody><tr><td>°C</td><td>Degrees Celsius</td></tr><tr><td>cm</td><td>Centimeters</td></tr><tr><td>g/cm<sup>3</sup></td><td>Grams per cube centimeter</td></tr><tr><td>g PM<sub>2.5</sub></td><td>Grams of particulate matter with volume &lt;2.5 micrometers</td></tr><tr><td>GJ</td><td>Gigajoules</td></tr><tr><td>Kg/h</td><td>Kilograms/hour</td></tr><tr><td>KJ/mol</td><td>Kilojoules per mole</td></tr><tr><td>Km</td><td>Kilometers</td></tr><tr><td>Kt/y</td><td>Kilotons a year</td></tr><tr><td>KWh</td><td>Kilowatt-hour</td></tr><tr><td>L</td><td>Liters</td></tr><tr><td>mm</td><td>Millimeters</td></tr><tr><td>MJ</td><td>Megajoule</td></tr><tr><td>Mt</td><td>Million metric tons</td></tr><tr><td>t</td><td>Tons</td></tr><tr><td>tCO<sub>2</sub>e</td><td>Tons of CO<sub>2</sub> equivalent</td></tr><tr><td>t/hr</td><td>Tons per hour</td></tr><tr><td>t/d</td><td>Tons per day</td></tr><tr><td>t/y</td><td>Tons per year</td></tr><tr><td>ug</td><td>micrograms</td></tr><tr><td>wt.%</td><td>Percentage by weight</td></tr><tr><td>w/w</td><td>Weight for/by weight</td></tr><tr><td>2D/3D</td><td>2 Dimensional / 3 Dimensional</td></tr></tbody></table>

<table><thead><tr><td>English terminology</td><td>French</td></tr></thead><tbody><tr><td>Aminolysis</td><td>Amminolyse</td></tr><tr><td>Catalyst</td><td>Catalyseur</td></tr><tr><td>Chemical recycling</td><td>Recyclage chimique</td></tr><tr><td>Dissolution</td><td>Dissolution</td></tr><tr><td>Feedstock</td><td>Intrant</td></tr><tr><td>Hydrolysis</td><td>Hydrolyse</td></tr><tr><td>Hydrothermal cracking</td><td>Craquage hydrothermique</td></tr><tr><td>Gasification</td><td>Gazéification</td></tr><tr><td>Glycolysis</td><td>Glycolyse</td></tr><tr><td>Granulates</td><td>Granulés</td></tr><tr><td>Methanolysis</td><td>Méthanolyse</td></tr><tr><td>Pellets</td><td>Granulés</td></tr><tr><td>Physico-chemical recycling</td><td>Recyclage physico-chimique</td></tr><tr><td>Pyrolysis</td><td>Pyrolyse</td></tr><tr><td>Pyrolysis oil</td><td>Huile de pyrolyse</td></tr><tr><td>Solvolysis</td><td>Solvolyse</td></tr><tr><td>Steam cracker</td><td>Vapocraqueur</td></tr></tbody></table>