jointly on a process transforming TACOIL into food grade r-PP<fnref n="155" />. Unilever, Tupperware and Mondelez are also already integrating TACOIL in the production of some of their products (including some food-grade applications).

OMV produces gas, synthetic crude oil (Syncrude) and petrochemical feedstock which are used for virgin plastics production at Borealis (OMV's partner).

Recycling Technologies UK's output consists of a hydrocarbon mix called Plaxx. Targeted final applications are plastic production (70%) and waxes (30%).

It is known that in 2020 the developer Fuenix Ecogy Group has completed the REACH registration for its Premium Circular Feedstock (naphtha, paraffin, LPG)<fnref n="156" />.

## b. Technology scaling-up

### Average Technology Readiness Level

Most of the technology developers studied are at demonstration stage and thus their TRL range from 5 to 7.

Some particularly well-developed technologies are Plastic Energy, Enval and Splainex, which are close from industrial phase and whose TRL range from 7 to 9.

### Current and future capacities

Current plants are able to produce from a few thousand tons a year to 35 000 tons per year (Splainex) of oil or monomers.

Planned capacities for the non-catalytic pyrolysis processes ranges from 15 ktons per year to 350 ktons per year in a time horizon from 2021 to 2025.

Plastic Energy is currently operating two plants in Sevilla and Almeria (first plant in the European Union having obtained a REACH certification) with a capacity of 7,000 tons/year input each, operating respectively since 2014 and 2017. They aim at expanding the production of their Sevilla plant by 2022 and of start building 10 chemical recycling plants by 2021 (across Europe and Asia). There is no news on whether this target has been reached. However, several projects are ongoing:

- Plastic Energy has contracted a partnership with ExxonMobil to build a plant in France (announced in 2021). The companies finalized the investment decision at the end of 2021 with start-up anticipated in 2023. The initial capacity of the plant is about 25,000 t/y of plastics waste, to be scaled up to 33,000 t/y in the future<fnref n="157" />.

- A first large-scale plant was planned to start operations in 2021 on Sabic's Netherlands-based project in Geleen but it is now expected for 2022. The input capacity of this plant would be about 20,000 t/year. It is known that Sabic has invested approximately €30 million in the development of the facility.

- A plant with Ineos is expected to reach completion towards the end of 2023, although the companies have not announced a location for the plant. This plant would be able to process up to 30,000 tons of input per year.

- A plant in Pengerang, Malaysia is expected with Petronas. The agreement was signed in 2019, the plant is scheduled to operate in 2024 and to reach a capacity of 33kt/y (it is not specified whether it refers to input or output capacity). The facility will process municipal solid waste (MSW), rejects of mechanical recycling centers and other collected recyclables (composition not specified).

<footnote n="155">¹⁵⁵ https://www.icis.com/explore/resources/news/2020/09/17/10553991/first-commercially-available-chemically-recycled-food-grade-r-pp-pellets-enter-market</footnote>

<footnote n="156">¹⁵⁶ https://echa.europa.eu/registration-dossier/-/registered-dossier/31769</footnote>

<footnote n="157">¹⁵⁷ https://plasticenergy.com/plastic-energy-announces_fid_and_start_of_construction_works_for_advanced_recycling_plant_in_france/
Study RECORD n°21-0919/1A</footnote>
- A plant is expected with Total Energies which construction agreement was signed in 2020¹⁵⁸. The plant will have a capacity of 15,000 t/y and will be located at Total's zero crude facility in Grandpuits, France. In January 2022, the two companies also announced the construction of a second plant in Sevilla, Spain. The recycling plant is expected to be completed by 2025 and to reach a final input capacity of 33,000 t/y<fnref n="159" />.

- The developer signed a Memorandum of Understanding (MoU) in Indonesia with West Java for the construction of 5 plants with an average capacity of 20-33kt/y.<fnref n="160" />

- In October 2020, Nestlé additionally declared its intention to assess the opportunity of building a plant with Plastic Energy in the UK (no additional information provided).

In December 2021, Plastic Energy and INEOS Olefins & Polymers Europe announced a partnership to develop a solution to turn hard-to-recycle plastics into recycled resins suitable for food-grade and hygiene applications<fnref n="161" />. A strategic collaboration to increase the rate of plastics' recycling had also been signed in November of the same year with Axens<fnref n="162" />.

Recycling Technologies UK currently owns a lab-scale demonstration facility (capacity 100kg/h), and it is in the building phase of their first pilot plant (no further details available). The construction of this facility is partly funded through a €10 million investment from Neste and Mirova (investment company specialized in sustainability) and a grant from Zero Waste Scotland (non-profit environmental organization). The developer plans to install 1300 machines by 2027, producing 7 million tons of Plaxx, which is their proprietary output of the oil fraction, annually. This is a rather ambitious goal.

In October 2020, the developer announced a joint project in collaboration with Neste and Unilever for the development of a recycling process able to produce virgin quality plastics<fnref n="163" />.

Other Recycling Technologies' strategic partners include: Kerax (supply agreement), ecosurety (EPR scheme), Binn Group (waste management company), Innovate UK (funding). Research partners include: Wood Research and Development (testing and certification lab), University of Brimingham, Cranfield University, University of West of England, University of Surrey. It is known that INEOS Styrolution and Trinseo are working with Recycling Technologies UK to build multiple plants for the recycling of PS. To begin with, a pilot plant will be built it the UK in 2022. INEOS Styrolution plans to build a 15kt/y (input) commercial facility in Wingles, France ( timeline not disclosed). Trinseo also announced they will build a plant with the same capacity in Tessenderlo, Belgium, which will be completed in 2023¹⁶⁴.

Enval uses modules that can be accumulated to plants and to each other's. A typical Enval module operates at a feed rate of up to 350 kg per hour, which equates to a nominal capacity of 2,000 tons per year⁴². Enval partnerships include The Kraft Heinz Co. and Sonoco (to explore the deployment of plastic recycling solutions in the United States), Little Freddie, SAIREM, (supplier of microwave generators that power the recycling process), Resource Association, CIWM, and Cambridge Cleantech.

Fuenix Ecogy Group owns a pilot plant and is in its scaling-up phase. In 2020, the developer had received a € 4 million investment from Brightlands Venture Partners (with the participation of Koobra Invest, Bolsius and Fimavest as investors)<fnref n="165" />. Together with Dow Chemicals, the developer established

<footnote n="158">¹⁵⁸ https://plasticenergy.com/total-and-plastic-energy-announce-a-strategic-partnership-and-the-construction-of-the-first-chemical-recycling-plant-in-france/#:~:text=Paris%20%E2%80%93%20Total%20and%20Plastic%20Energy%20announce%20the,%20Total%20platform%20z%C3%A9ro%20crude%20in%20Grandpuits%2C%20France.</footnote>

<footnote n="159">¹⁵⁹ https://www.packaging-gateway.com/news/plastic-energy-totalenergies-spain-recycling/</footnote>

<footnote n="160">¹⁶⁰ Chemical Recycling in Asia Pacific conference, 14/09/2021</footnote>

<footnote n="161">¹⁶¹ https://plasticenergy.com/ineos-and-petroineos-at-grangemouth-partner-with-plastic-energy-in-an-important-breakthrough-in-the-recycling-of-plastic/</footnote>

<footnote n="162">¹⁶² https://plasticenergy.com/plastic-energy-axens-strategic-collaboration/</footnote>

<footnote n="163">¹⁶³ https://recyclingtechnologies.co.uk/2020/10/recycling-technologies-neste-and-unilever-combined expertise-to-test-and-validate-systems-to-chemically-recycle-waste-plastics/</footnote>

<footnote n="164">¹⁶⁴ https://recyclingtechnologies.co.uk/2021/04/ineos-styrolution-recycling-technologies-and-trinseop progress-plans-for-the-first-polystyrene-recycling-plants-in-europe/</footnote>

<footnote n="165">¹⁶⁵ https://brightlandsventurepartners.com/nieuws/fuenix-raises-e-4-million-to-scale-up-its-technology-to-recycle-mixed-plastic-waste/</footnote>
a partnership for the supply of pyrolysis oil to Dow's production facilities in Terneuzen, Netherlands (partnership ongoing since 2019). In 2021, the two partners extended their agreement with the goal of building a second plant in Weert, the Netherlands plant (20 kt/y input capacity, date of completion unavailable)<fnref n="166" />.

ITERO owns a pilot plant in the UK and has a first commercial plant under construction. The R&D pilot plant is located in the UK (unknown capacity). The commercial plant is due in 2023 and will be located in Brightlands Chemelot Campus, Geleen, Netherlands and will require an investment of about 25 € million. The plant will consist of a single-module 27 kt/a facility (input)¹⁶⁷. In February 2021, ITERO signed an agreement with COUNT Energy Trading. The agreement established that COUNT Energy Trading will purchase an annual share of the produced liquid output (up to 19kt/y). In June 2021, another partnership was initiated with Kerax (wax manufacturer) to increase the recycling of plastic waste. As part of the collaboration, Kerax will purchase up to 5kt/y of recycled wax produced by the commercial plant in the Netherlands.

OMV owns a pilot plant located in Schwechat, Austria which is planned to start operating by the end of 2022 (capacity of 16kt/y). The aim is to reach final industrial-scale capacity (200kt/y) by 2025 at the latest. OMV has invested approximately 10€ million in the project as a whole, 10% of which has been subsidized by FFG (Austrian Research Promotion Agency) (as of 2018). OMV also holds 75% interests in Borealis, which is currently working on a project (Borecycle C) to develop circular polymers derived from chemical recycling.

Of the MMATwo project, it is known that they aim to secure a supply of minimum 12.2kt of recycled materials from the input of 27kt of PMMA and other types of end-of life waste (not specified)<fnref n="168" />.

The technology developer Indaver announced in 2021 that they had received permits to build a 15 kt/y plant in Antwerp, Belgium. Since 2017, the company had been working on a lab scale to develop the technology with Ghent University and the University of Antwerp. The announced facility is meant to bring Indaver from lab to pilot scale, yet, as of January 2022 no news on the subject were found<fnref n="169" />.

Arcus Greencycling currently has an input capacity of 250 kg - 800 kg plastic waste per hour. While no details were found on this developer's recycling facilities, it is known that the North Channel Bank financed the construction of a first pilot system. The company has also partnered with Infraserv höchst (infrastructure partner, first prototype installed in their facilities), KIT (technology partner), Sphera (with whom they conducted a LCA assessment), and Sulzle (engineering partner).

Agilyx currently operates a 50-100 t/day (it is not specified whether it refers to input or output capacity) facility in Tigard, USA, under a joined venture with AmSty. As of July 2019, Agilyx was planning to build a commercial recycling facility in Europe with an input capacity up to 50t/day. No updates have however been found on the subject. The developer additionally has strategic partnerships with General Electric (development of an artificial intelligence technology), Go Beyond Racing (partnership to recycle single-use PS generated during events), Styrenics Circular Solutions (joint industry initiative), Technip Energies (to market and license Agilyx's depolymerization and Technip Energies' purification technologies), NextChem (technology and EPC partners to develop advanced chemical recycling facilities globally), ExxonMobil (established together Cyclyx Joint Venture to supply the plastics recycling industry), Braskem (deploy advanced recycling for PP in North America), Mitsubishi Chemical Methacrylates (developing solutions for the recycling of PMMA). In December 2021, Agilyx announced a partnership with Toyo Styrene for the building of a recycling plant (10t/d capacity) in Japan<fnref n="170" />.

<footnote n="166">166 https://www.itero-tech.com/projects</footnote>

<footnote n="168">168 https://www perspectivemarketresearch.com/market-research/methyl-methacrylate-market.asp</footnote>

<footnote n="169">¹⁶⁹ https://www.indaver.com/en/news-media/news-detail/press-release-indaver-receives-permit-to-build-a-new-plant-for-the-chemical-recycling-of-end-of-lif/</footnote>

<footnote n="170">¹⁷⁰ https://news.cision.com/agilyx/r/toyo-styrene-enters-into-the-construction-phase-of-chemical-recycling-facility-in-japan-utilizing-ag,c3483797</footnote>
### c. Economic performance

An economic analysis of rapid pyrolysis conducted by Gerard Antonini concluded that the technology could provide a positive return on investment after approximately 6 years (12). The following paragraph is a translation of his work. Please note this is a theoretical analysis.

This analysis focused on a Dense Fluidized Bed (DFB) installation allowing the rapid pyrolysis of plastic waste. This unit operates 8 000 h/year and can treat an incoming flow of used plastics of: 6,000 t/year.

### d. Environmental performance

#### LCA data (or similar studies), notably carbon footprint

Among the technologies studied, some have undergone a study of their environmental impacts. However, as these evaluations have not been made public, the hypothesis and the methodology chosen are undisclosed and thus not confirmable.

Indeed, Fuenix Ecogy Group asserts that plastic made from their feedstock reduces CO₂ emissions by 65% compared to virgin plastic.

BASF conducted an LCA of their ChemCycling process. They compared CO₂ emissions of plastic production from pyrolysis oil and naphtha, using a mass balance approach. The process chosen was the production of ethylene in steam cracker and the polymerization to LDPE (low-density polyethylene). The feedstock either comes from naphtha from crude oil or from oil from pyrolysis of mixed plastic waste from German yellow bag. It was found that:

- "Conventional production of 1t LDPE emits, in total, 1894 kg CO₂e.

- For the production of 1t LDPE via pyrolysis a negative number of -477 can be accounted for the overall CO₂ emissions."

- BASF thus concludes that "1 ton of LDPE produced from pyrolysis oil under a mass balance approach, emits 2.3 t less CO₂ than 1 ton LDPE produced from fossil naphtha"

This study relies on several hypothesis which are:

- The fact that the study is based on projections of future development if the waste sector in Germany (carbon footprint of electricity, etc.)

- The previous result is calculated using a mass balance approach.

- Negative emissions are taken into account in the calculation using a reference scenario for plastic waste treatment which is incineration.

Some methodological choices regarding this study are also debatable. Indeed, lower yields on the recycling process give out better environmental benefits. This is due to the fact that more feedstock is needed to produce the same quantity of recycled plastics. As the study takes into account avoided emissions of the end of life of plastics (incineration assumption in this case), if the quantity of material used increases, the environmental benefits also increase. Moreover, deducing end of life emissions is particularly decisive for the results obtained, even though it can be difficult to compute. Without deducing end-of-life emissions, the GHG impacts of the production of one kilogram of chemically recycled LDPE is greater than that of a kilogram of virgin LDPE<fnref n="171" />.

In September 2020, Plastic Energy published a report in partnership with Quantis focusing on the life-cycle assessment of chemical recycling (pyrolysis) of plastic waste<fnref n="172" />. The study analyses chemical recycling using two different approaches:

- Approach 1 – Waste perspective: Comparison of different end-of-life options (landfilling, incineration, and chemical recycling) for 1kg of sorted mixed plastic waste (composition not specified)

- Approach 2 – Product perspective: Comparison of the production of 1kg of virgin LDPE with production of virgin-like LDPE via both mechanical recycling and chemical recycling

<footnote n="171">¹⁷¹ Approche « Mass balance » et recyclage chimique des plastiques, ADEME</footnote>

<footnote n="172">¹⁷² https://plasticenergy.com/sustainability/lca-report/#:~:text=Plastic%20Energy%20contracted%20independent%20sustainability%20consultancy%2C%20Quantis%2C%20to, is%20available%20to%20download%20on%20the%20link%20below.</footnote>
The analysis was conducted within a European scope both for waste perspective and product perspective calculations. The waste perspective scenario considers an average European energy mix as baseline. The efficiency considered in the incineration with energy recovery plant are respectively 10.1% for electricity and 31% for heat. No further details are available on the data used to conduct calculations nor concerning the limits of the study.

Regarding the Approach 1, the results highlight that, in terms of climate change impact (kg CO₂-eq), chemical recycling is the second-best option after landfilling. In terms of resources use, chemically recycled LDPE proved to be the best option due to the prevented production of virgin naphtha. The study concludes that incineration is the scenario with highest climate change impacts (GHG emissions from incineration are not entirely compensated by energy recovery). Although landfilling has relatively low climate change impacts, the risk of materials being dispersed in the environment is not considered within the applied LCA calculations. Moreover, this end-of-life options hinders circularity as it does not allow to recover any materials in the process. Consequently, the report suggests that, in the long-term, chemical recycling will become a preferable solution to incineration with energy recovery from a waste management perspective.

<table><caption>Table 10: LCA results for 1 kg of sorted mixed plastic waste</caption><thead><tr><td>Indicator (Units)</td><td>Chemically recycled LDPE (pyrolysis)</td><td>Incineration with energy recovery</td><td>Landfill</td></tr></thead><tbody><tr><td>Climate change (kg CO₂-eq)</td><td>0.55</td><td>1.60</td><td>0.15</td></tr><tr><td>Resources use, fossil (MJ)</td><td>-31.10</td><td>-26.54</td><td>0.36</td></tr></tbody></table>

Regarding the Approach 2, the results highlight that mechanically recycled LDPE performs better in terms of climate change impact (kg CO₂-eq) than chemically recycled LDPE and virgin (fossil) LDPE. The results of this section take into consideration the prevented impacts of alternative end-of-life waste treatments. The results show that mechanical recycling performs better than chemical recycling, which however remains a better option that virgin LDPE production.

<table><caption>Table 11: LCA results for 1 kg of produced virgin and virgin-like LDPE</caption><thead><tr><td>Indicator (Units)</td><td>Chemically recycled virgin-like LDPE (pyrolysis)</td><td>Virgin (fossil) LDPE</td><td>Mechanically recycled virgin-like LDPE</td></tr></thead><tbody><tr><td>Climate change (kg CO₂-eq)</td><td>0.86</td><td>1.90</td><td>-0.45</td></tr><tr><td>Resources use, fossil (MJ)</td><td>39.54</td><td>80.08</td><td>22.14</td></tr></tbody></table>

In order to validate the reliability of the study's calculations, Plastic Energy and Quantis run a series of sensitivity tests. The following parameters were varied to verify the sensitivity of the obtained conclusions:

* Electricity mix used in the chemical recycling facility, for both the product and waste perspective approaches (i.e., EU mix vs 100% renewable one).

* Assuming, instead, that the entire plastic waste used in the chemical recycling process, alternatively, would have been incinerated (product perspective approach).

* Assuming, instead, that the entire plastic waste used in the chemical recycling process, alternatively, would have been sent to landfill (product perspective approach).

* Different distances travelled by truck (100 km, 500 km, 1000 km) to transport plastic waste to sorting facility for chemical recycling scenario (product and waste perspective approach).

* Electricity utilization for pyrolysis (± 20% compared to the baseline) at the chemical recycling facility.

* Different amounts of naphtha needed to produce 1 kg of LPDE (baseline: 1.6 kg Naphtha /kg LDPE; additional amounts tested include 1.4, 1.2 and 2.0 kg Naphtha / kg LDP).

* Efficiency of chemical recycling process in terms of the ratio of TACOIL produced and feedstock processed (baseline: 69.6%; additional efficiencies of 65% and 75% assessed).
* Amount of energy (i.e., electricity and heat) recovered from waste plastic in the incineration process (baseline: average EU energy recovery rate; other scenarios assessed include no energy recovery, and high energy efficiency).

* Mechanical recycling quality ratio from the Product Environmental Footprint (PEF) guidance has been tested to integrate the quality of the plastic as a parameter in the study.

Specific findings of the sensibility analysis have not been included within the public version of the report. However, the results of the study point out that, to achieve higher efficiency from an LCA perspective, chemical recycling technologies should decrease their energy consumption while increasing output yields. Renewable energy sources are suggested as a mean to further reduce carbon emissions.

### Comparative analysis between end-of-life processes

The emissions calculated by Arcus Gre recycling amount to 140 kg CO₂eq./t mixed plastic waste.

Recycling technologies UK asserts that their technology could save 1.4tCO₂e per ton of plastic processed compared to an incineration facility.

The BASF LCA gives out favorable environmental performances for pyrolysis compared to incineration. The pyrolysis process taken into account is the production of oil as feedstock for the chemical industry (with a material yield of 70%, and almost no need of external energy due to internal energy recovery). It was compared to the incineration process, generating electricity and steam that substitutes electricity from national grid and steam from national average. The feedstock used is one ton of mixed plastic waste from packaging (German yellow bag) in both cases. It should be noted that "*the study is based on an assumed future development of pyrolysis and the waste sector in Germany in 2030*"<fnref n="173" />. It was found that:

- "Pyrolysis of 1t mixed plastic waste emits, in total, 739 kg CO₂e.

- Incineration of 1t mixed plastic waste emits, in total, 1777 kg CO₂e."

In conclusion, pyrolysis of mixed plastic waste emits 50 percent less CO₂ (or 1t less CO₂) than the incineration of mixed plastic waste.

Gerard Antonini conducted a similar analysis on a flash pyrolysis installation (12). This installation can treat about 6 000 tons of waste plastic by year and can function continuously for 8 000 hours/year. His conclusions were that:

- The rapid pyrolysis process (including sorting, electric consumption, and indirect emissions) emits about 1 039,7 t CO₂/year. These emissions only relate to the treatment of the plastic waste and not the latter steps from pyrolysis oil.

- Incineration of this quantity of plastics would emit 15 553,5 t CO₂/year.

The results of the different analyses should be considered carefully as they are very variable depending on the methodology chosen and the assumptions for the calculation. Gerard Antonini's assessment was conducted for a French facility using thus the French electricity emission factor and waste composition.

### Energy costs

Pyrolysis is a very energy intensive process compared to other recycling technologies, but some technology developers assert that by incinerating the gas fraction produced during the process, it can be self-sustaining. A case study of a pyrolysis plant confirmed this analysis by revealing that the process was autothermal (12). However, the process still needs an external energy supply to function at a certain moment. Plastic Energy uses produced tars and gas to power the recycling process.

In November 2021, Agilyx announced that its Tigard, Oregon facility has transition to an energy supply sourced entirely from renewable sources<fnref n="174" />.

<footnote n="173">¹⁷³ Critical review statement LCA for Chemcycling</footnote>

<footnote n="174">¹⁷⁴ https://news.cision.com/agilyx/r/agilyx-and-amsty-joint-venture-transitions-to-100--renewable-energy-at-its-tigard--oregon-facility,c3454985</footnote>
NON-CATALYTIC PYROLYSIS

<table><tr><td rowspan="5">Technology</td><td>Input</td></tr><tr><td><ul><li>More suited for polymers from polyaddition (polyolefins, PS, ABS and PMMA).</li><li>Treats relatively mixed plastics waste streams but acceptable polymers ratio is very high</li><li>Usually, a first sorting step is necessary to remove non-processable inputs (PVC, PET, PU...) and mechanically recyclable materials.</li></ul></td></tr><tr><td>Process</td></tr><tr><td><ul><li>Pyrolysis processes occur in an atmosphere without oxygen (the concentration of O<sub>2</sub> is inferior to 1%).</li><li>They are carried out between 350 and 650°C. Some technologies (such as Enval) use microwaves to bring the energy needed.</li><li>Yields obtained range from 70% to 85%* (mass yield from plastic waste to oil). Additional purification steps would result in further losses (approximately 3%).</li><li>When going back to the monomer, the theoretical yield in styrene can go up to 85%* (depolymerization of PS) and in MMA up to 90%* (PMMA depolymerization).</li></ul></td></tr><tr><td>Output and Downstream steps</td></tr><tr><td><ul><li>Pyrolysis processes, under certain conditions, can produce monomers of polymers input, for example for PS, PMMA and Polyamide 6.</li><li>In the case of other polymers as feedstocks, such as polyolefins (PE, PP), it will lead to three different fractions: an oil fraction, a gas mixture and coke or char.</li><li>The oil fraction can be reprocessed into naphtha or polyolefins and be separated in a petroleum-type steam cracker.</li><li>The gas mixture is usually used to supply heat for the process.</li></ul></td></tr><tr><td rowspan="3">Technology scaling-up</td><td>Average Technology Readiness Level</td></tr><tr><td><ul><li>Estimated TRL = 5-8.</li><li>Most technology developers are still in the development phase of their technology.</li></ul></td></tr><tr><td><ul><li>Enval and Splainex are close from industrial phase. Plastic Energy is at commercial scale.</li></ul></td></tr><tr><td rowspan="2">Economic performance</td><td>Current and future capacities</td></tr><tr><td><ul><li>Current plants are able to produce from a few thousand tons a year to 35 000 tons per year (Splainex) of oil or monomers.</li><li>Planned capacities for the non-catalytic pyrolysis processes ranges from 15 ktons per year to 350 ktons per year in a time horizon from 2021 to 2025.</li></ul></td></tr><tr><td rowspan="2">Environmental performance</td><td>An economic analysis of rapid pyrolysis as conducted by Gerard Antonini concluded that the technology could provide a positive return on investment after less 3 years.</td></tr><tr><td><ul><li>Lack of public data available</li></ul></td></tr><tr><td></td><td>LCA data (or similar studies), notably carbon footprint</td></tr><tr><td></td><td><ul><li>BASF found that 1 ton of LDPE produced from pyrolysis oil under a mass balance approach, emits 2.3 t less CO<sub>2</sub> than 1 ton LDPE produced from fossil naphtha. These figures are only indicative.</li><li>The BASF LCA gives out favorable environmental performances for pyrolysis compared to incineration (even though it is computed with strong methodological choices, see VII.d).</li></ul></td></tr><tr><td></td><td>Energy costs</td></tr><tr><td></td><td><ul><li>Pyrolysis is an energy intensive process compared to other recycling technologies, but some technology developers assert that by incinerating the gas fraction produced during the process, it can be self-sustaining. A case study of a pyrolysis plant confirmed this analysis by revealing that the process was autothermal. This</li></ul></td></tr></table>
means that a part of the output is used for the energy of the site. However, the process still needs an external energy supply to function at a certain moment.

* Lack of public data available on the environmental performance of the process

## STUDIED TECHNOLOGY DEVELOPERS

<figure><img src="image_20.png" /></figure>

<figure><img src="image_21.png" /></figure>

<figure><img src="image_22.png" /></figure>

<figure><img src="image_23.png" /></figure>

<figure><img src="image_24.png" /></figure>

PLASTIC*
ENERGY

<figure><img src="image_25.png" /></figure>

Recycling
Technologies™

<figure><img src="image_26.png" /></figure>

<figure><img src="image_27.png" /></figure>

ETIA
ECOTECHNOLOGIES

agilyx

<figure><img src="image_28.png" /></figure>

<figure><img src="image_29.png" /></figure>

BOREALIS
Keep Discovering

<figure><img src="image_30.png" /></figure>

ARKEMA

<figure><img src="image_31.png" /></figure>

Splainex Ecosystems

<caption>Table 12 : Non-catalytic pyrolysis recapitulative table (RECORD, 2022)</caption>

*Yields can vary depending on the feedstock type and operating conditions. These yields are likely to be overestimated as they have been calculated by technology developers on a lab scale.

## 2) Catalytic pyrolysis

### a. Technology

#### Input

Catalytic pyrolysis is able to treat waste that is rejected by centers treating household waste for recycling, light automotive shredder residue (ASR) (plastic films, foams, etc.), and mixed waste resulting from the production/transformation of plastics. The source of the feedstock can be post-consumer or post-industrial depending on the requirements of the technology developer.

Some technology developers favor the use of homogeneous feedstocks (GreenMantra Technologies<fnref n="175" /> or Pyrowave<fnref n="176" /> relying on PS input streams), while others process mixed plastic waste (24). It should be noted that the term “mixed plastic waste” may not refer to all type of polymers. Most technologies are not capable of treating all types of plastics, which is why developers only accept a mix of selected polymers as input. As an example, Quantafuel<fnref n="177" /> and Pryme<fnref n="178" /> only process mixed plastic waste composed of PE, PP and PS. GreenMantra Technologies<fnref n="179" /> owns a technology capable of treating post-consumer and post-industrial waste (either PP & PE, or PS mixed waste).

In October 2021, BioBTX announced its involvement in the Circular Foam project together with Covestro, RWTH Aachen University, ETH Zürich and Rijksuniversiteit Groningen. The project aims at the design and demonstration of chemical recycling solutions for PU rigid foams into high quality products suitable for closed-loop applications (it was not yet disclosed whether Bio BTX's technology is the one that will be used within the project)<fnref n="180" />.

PVC feedstocks are frequently avoided as there is evidence of this material reducing the process performance due to a strong decrease in the activity of the catalysts in the presence of sulphur and acid vapors, with a subsequent decrease in the yield of the reactions (5). Cassandra Oil<fnref n="181" /> and Anellotech are able to treat different types of waste (e.g., end of life tires, oil contaminated soil and oil sludge, electronic scrap). These developers however do not accept PVC in their feedstock. In general, PET

<footnote n="175">¹⁷⁵ http://greenmantra.com/</footnote>

<footnote n="176">¹⁷⁶ https://www.pyrowave.com/en/</footnote>

<footnote n="177">¹⁷⁷ https://quantafuel.com/</footnote>

<footnote n="178">¹⁷⁸ http://www.pryme-cleantech.com/about-us/</footnote>

<footnote n="179">¹⁷⁹ Please not that Greenmantra Technologies treats both PS and a mixture of PP and PE. Although processed by the same technology developers, these two feedstocks are recycled separately.</footnote>

<footnote n="180">¹⁸⁰ https://biobtx.com/making-pur-foam-circular/</footnote>

<footnote n="181">¹⁸¹ http://cassandraoil.com/en/</footnote>
waste is not accepted either by the technology providers. Yet, some of them tolerate a certain PET fraction in the feedstock.

Feedstocks containing a high level of contaminants (such as paper, chlorinated products, heavy metals) may lead to a significant reduction of the reaction yields or, in some cases, even to the deactivation of the catalyst (such as in the presence of certain metals). That is why pre-treatment steps might be required (8, 9). As an example, the benefits of adding a catalyst in the pyrolysis process may rapidly decline also due to the presence of chlorine or nitrogen in the carbon residues. That is why catalytic pyrolysis may require the pre-sorting or the pre-treatment (e.g., pre-pyrolysis) of waste (12). Pyrowave and GreenMantra Technologies both include a step of input's preparation at the beginning of their recycling process. Pyrowave removes contaminants and impurities from its feedstock during a phase of preparation and shredding of feedstock (details not disclosed)<fnref n="182" />, GreenMantra Technologies removes impurities by extrusion (12).

Of the developer Carboliq, it is known that the size of its input feedstock should not exceed the following measures: 40mm for 2D, and 5mm for 3D. Metals, stones, glass, ceramics, and porcelain also have to be removed, while humidity should be kept below 18%. Yet, Carboliq's process was also designed to handle significant quantities (not specified) of PVC and brominated ABS waste contamination<fnref n="183" />.

For some actors such as Quantafuel, Carboliq, and KIT, which only treat specific resins, it remains unclear whether the technology developers are responsible for the sorting and purification of their own input.

## Process

Catalytic pyrolysis features the presence of a catalyst (e.g., metal oxides, cobalt complexes, silicate zeolites, etc.), which is added to achieve results such as increased reactivity of the reaction, lower operating temperatures, better selectivity, and reduction of by-products (24). Catalytic pyrolysis can take place either in a liquid (melted) or in a solid form (12). The first case consists of a one-level approach in which the catalyzer and the polymer are directly in contact with each other while the polymer is in its liquid form. The other option is to use a two-step system beginning with the thermal degradation of the polymer, followed by a catalytic processing of the produced vapors (5). In the second scenario, the catalyst is in contact with the formed vapors in its gaseous form (12). The two-step approach can be used to prevent a deactivation (poisoning) of the catalyst due to the presence of impurities such as certain metallic traces. This treatment can be carried out in line or decoupled (pyrolysis then condensation of the vapors then catalytic treatment) (24). Information concerning the type, quantity, and recovery of the catalysts used by each technology developer is usually not publicly disclosed (16).

Regarding operating conditions, the presence of a catalyst reduces processing temperatures to around 300°C compared to approximately 400-450°C for non-catalytic pyrolysis (24). As an example, using a catalyst (MgO, CaO, ...) to depolymerize PS can reduce the reaction temperatures from 550-600°C to 380-400°C (12). Catalytic pyrolysis conducted at temperatures as low as 200°C is often referred to as slow catalytic pyrolysis (5). Another variant of catalytic pyrolysis is catalytic microwave pyrolysis. In this case, plastic waste is mixed with a highly microwave-absorbent dielectric material to improve plastics' naturally poor dielectric strength. The choice of the added material determines the resulting magnitude of heating and heating efficiency. Once the dielectric material has been added to the plastics mix, the heat absorbed from the microwaves is transferred to the plastics by conduction. Advantages of using this treatment include even heat distribution, higher heating rates, increased control over the process and improved production speed when compared to conventional pyrolysis (10). The Canadian developer Pyrowave bases its chemical recycling operations on this process.

GreenMantra Technologies process uses a thermochemical process in which PP (with less than 10% of PE) is preheated and fed into a pyrolysis reactor where it is depolymerized. This step can include catalysts to target specific end products.

Carboliq (subsidiary of Recenso GmbH, Germany) developed a Catalytic Tribochemical Conversion (CTC), which is a one-stage liquefaction process. This process uses a mechanical shear imposed on

<footnote n="182">¹⁸² https://www.pyrowave.com/medias/iw/pyrowave-process-ENG.pdf</footnote>

<footnote n="183">¹⁸³ http://www.carboliq.com/pdf/1910_CARBOLIQ-flyer-K-2019.pdf</footnote>
the reaction medium to overcome the limitations of heat and mass transfer. The shear also lowers the required reaction temperature, bringing it below 400°C while operating under atmospheric pressure levels. The catalyst used by the developer is not disclosed. Carboliq claims that the only source of energy used within the process is generated through friction<fnref n="184" />.

Quantafuel has developed a unique two-stage catalytic process (type of catalyst not disclosed). Following pyrolysis, the developer purifies the gas from impurities (ash, chlorine, sulphur, etc.), then condenses it and separates oil fractions through distillation<fnref n="185" />. This two-stage process is used to maximize the valorization of plastic waste and increase the quality of desirable hydrocarbons.

The Karlsruhe Institute of Technology (KIT) and LyondellBasell have been cooperating on a joint research venture since 2018. The goal of the agreement is to develop a new catalytic thermal depolymerization technology. KIT contributes to the partnership through its expertise in thermal conversion processes, while LyondellBasell focuses mainly on the development of the catalyst. This collaboration led to the development of the MoReTec technology (no further details provided).

## Output and downstream steps

Composition of the feedstock, selected catalyst and processing techniques have therefore direct implications on the outputs of catalytic pyrolysis (12). Plastic waste recycled via this reaction leads to outputs which nature is similar to those of non-catalytic pyrolysis. These include:

- **A liquid fraction:** the reaction leads to the production of a pyrolysis oil. In general, the presence of a catalyst favors the production of oligomers with chains containing between 5 and 10 carbon atoms (fuel compounds like diesel or gasoline) (12). Very selective catalysts can lead to the production of specific hydrocarbons with high commercial value and prevent the formation of chlorinated hydrocarbons (in the case of waste containing PVC). Depending on the nature of the process and feedstock used, the refining of pyrolysis oils can either lead to monomers (depolymerization, possible with PA6, PS, PET, or PMMA) or to a hydrocarbon mix (cracking, necessary for polyolefins) (12). Following post-treatment steps (such as purification) the final outputs obtained by developers consist of products such as crude oil (Cassandra Oil), olefins (Anellotech), naphtha (Pryme), kerosene (Pryme), BTX (Bio-BTX, Anellotech), styrene (Pyrowave; Greenmantra produces both a primary up-cycled low molecular weight polystyrene and a secondary recycled styrene monomer)<fnref n="186" />, waxes (GreenMantra Technologies, Pyowave) and hydrocarbon mixes suitable for fuel applications (Carboliq).

- **A gaseous fraction:** another product is syngas, which can be composed of a mixture of hydrogen, methane, and various hydrocarbons. Further catalytic treatment of syngas also allows to obtain ammonia, ethanol, or methanol.

- **Solid residues:** a mixture of organic compounds and recycled fibers. Coke (or char), that can be used for energy recovery, fuel production, or gasified (12).

Different catalysts can be used to direct the products, improve the outputs' quality, and yields of this process compared with non-catalytic pyrolysis (24). Using a catalyst to depolymerize PS allows to reach a yield close to 79% in styrene (Pyrowave's yield reaches up to 95% in monomer production) (7,8). The conversion of polymers into monomers is more significant when the catalyst is added to the polymer in its liquid form (the polymer direct contact with the catalyst favors the reaction compared to when the vapors formed are put in contact with the catalyst in its gaseous form) (12). Examples of technology developers' liquid output yields include Quantafuel – 84%<fnref n="187" />, Pryme – over 90% liquid output, 10% non-condensable gases. No further information was provided concerning how these yields were calculated.

<footnote n="184">¹⁸⁴ http://www.carboliq.com/en/technology-en.html</footnote>

<footnote n="185">¹⁸⁵ https://www.quantafuel.com/our-solution/technology/</footnote>

<footnote n="186">¹⁸⁶ https://www.ineos.com/businesses/ineos-styrolution/news/ineos-styrolution-and-greenmantra-sign-jda-to-advance-polystyrene-chemical-recycling/#:~:text=GreenMantra%20utilizes%20its%20existing%20proprietary%20and%20patented%20catalytic,molecular%20weight%20polystyrene%20and%20secondary%20recycled%20styrene%20monomer.</footnote>

<footnote n="187">¹⁸⁷ https://www.basf.com/global/en/who-we-are/sustainability/we-drive-sustainable-solutions/circular-economy/mass-balance-approach/chemcycling/FAQ_ChemCycling.html</footnote>
Specific studies conducted on PE proved that the larger the polymer's pore size, the higher the yield of PE conversion to liquid hydrocarbons. In this case, less acidic catalysts would yield lighter gas and liquid fractions, thus facilitating an easier return to the associated monomers or oligomers after steam cracking (12).

In the case of KIT and Lyondell Basell, the oil obtained through pyrolysis is cracked into C2 and C3 gas, which are used to produce respectively transparent PE and PS<fnref n="188" />. The technology developers produce multiple output products (e.g., Quantafuel's output consists of 10% ash, 16% light fraction, 56% diesel fraction, 8% heavy fraction). Low temperature and microwave catalytic pyrolysis can lead to good quality output materials (e.g., recycled fibers with good mechanical and surface characteristics) (5). Catalysts can also be used to address the presence of brominated flame retardants in plastic waste. However, while some catalysts can reduce bromine levels in the oil, they can also significantly reduce the amount of oil or alter its composition (24).

Anellotech's technology, known as Plas-TCat™ process, can be controlled to either generate an output with a high yield of BTX or a high yield of olefins. Other minor components found within the output include paraffins, H₂, other C5+ liquids, and wax. The desired output products (BTX, ethylene, propylene, paraffins) are produced directly within the reactor and are ready to undergo the purification step. The amount of CO and CO₂ produced depends on the oxygen content of the feedstock.

In cases where a hydrocarbon mix is produced, the latter can be further purified/distilled to become eligible for integration into higher value applications (Quantafuel, GreenMantra Technologies, Anellotech). GreenMantra's final output consists of PE and PP polymer additives, waxes, styrene polymers, which can be used in asphalt, polymer reprocessing, and plastic composites.

As a general comment, it is relevant to mention that although it might be possible to obtain virgin-quality equivalent recyclates (including feedstock suitable for food-grade applications), significant losses (details currently unavailable) might occur during each recycling loop aiming to achieve this high-quality output (16).

## b. Technology scaling-up

### Average Technology Readiness Level

Most of the reviewed technology developers had an estimated TRL of 6-7. An exception is represented by low temperature catalytic pyrolysis as this process has a lower maturity level.

### Current and future capacities

The current production capacities of the reviewed technologies significantly vary from one developer to another. Most of the technology developers already possess a pilot (Anellotech, Bio-BTX) or a demo plant (Carboliq - output of 2500 tons/year; Cassandra Oil demo plant - One Cassandra 1500kW-reactor is expected to produce approximately 300 000 barrels of oil per year).

Some players have already begun construction for their commercial recycling facility. Developers such as Pryme, Carboliq, Bio-BTX have announced that their new plants are expected to begin production within the next 2 to 3 years (2022-2023). Pryme has a planned input capacity of 40,000t/year for their future commercial plant located in Rotterdam, Netherlands (commissioning expected Q2 2022) which is expected to be increased of 50% by 2023¹⁸⁹. Pryme additionally claimed that they will select five European locations and start the permitting process to build more plants by the end of 2021. As of 2021, Pryme established a feedstock supply agreement with Suez and signed a Letter of Intent (LOI) with Shell Chemicals for off-take and downstream development. In the same year, the developer secured a NOK 287 million investment through private placement which will be used to develop its plant in Rotterdam.

<footnote n="188">¹⁸⁸ https://cefic.org/a-solution-provider-for-sustainability/chemical-recycling-making-plastics-circular/chemical-recycling-via-conversion-to-feedstock/start-up-of-lyondellbasells-moretec-plant-underlines-ambitious-plastic-waste-targets</footnote>

<footnote n="189">¹⁸⁹ https://pryme-cleantech.com/
Study RECORD n°21-0919/1A</footnote>
Pyrowave owns a small-scale unit in Canada processing 400-1200t/y (news as of 2019). The developer works in partnership with Ineos (buyer of its output) and ReVital Polymers (recycling partner). Furthermore, in November 2020, Michelin and Pyrowave agreed to work together to fast-track the industrialization of Pyrowave's technology (focus on certification and international commercial roll-out). The joint development agreement will ultimately account for an investment of more than €20 million<fnref n="190" />.

GreenMantra Technologies started the construction of a 1100 t/y demonstration plant in 2018. As of end 2019, GreenMantra owned a commercial facility containing 3 production lines. A fourth production line was announced by the end of 2019 - no additional information is however available on the status nor the capacity of the plant. The facilities that are currently run and operated by GreenMantra focus on the processing of PE and PP. In 2019, the developer announced its intention to start building a demonstration plant for PS recycling, keep expanding its existing facilities, and further deploy its technology on a global level (no additional information available). GreenMantra's strategic partners include INEOS Styrolution (joint development agreement), HARKE GROUP (distribution partnership), Western Technologies and Innovation LLC (aiming to expand its presence into Middle East and Africa, and in the Indian subcontinent), Crayola (the company will supply discarded plastic markers which will be turned into high-value polymers for industrial applications). In 2021, the company additionally received a funding of $1 million from Bioindustrial Innovation Canada and of $1 million from the Canadian government.

In September 2020, KIT and LyondellBasell announced the successful start-up of the first MoReTec molecular recycling facility in Ferrara, Italy. The facility has a capacity of 5-10 kilograms of household plastic waste per hour, which is equivalent to an output of approximately 17 t/y. While no further information was found as of January 2022, it is known that the deployment of MoReTec's technology is part of LyondellBasell goal of producing 2 million metric tons of recycled and renewable-based polymers annually by 2030.<fnref n="191" />

In 2020, Anellotech partnered with R Plus Japan, a new joint venture of 16 Japanese cross-industry partners aiming at developing Plas-TCat™ to commercialize an eco-efficient recycling technology by 2027 (end of a 4-year development program being run by Anellotech). Two plants are under construction. The engineering phase for the first plant began in June 2019, the plant will have an input capacity of 500 tpd, producing 40 kt/y of BTXN (benzene, toluene, xylene, and naphthalene) & 30 kt/y of CO. The second commercial plant (planning under way) will have an input capacity of 2,500-3,000 tpd, producing 200-250 kt/y of BTXN & 150 kt/y of CO. Its research and development partners are Johnson Matthey and Intercat (specialized in catalyst technologies), IFP Energies Nouvelles (IFPEN) (process development and scaling-up), Axens (process and plant design, licensing). The developer is also partnered with Toyota Tsusho Corporation (strategic equity investor and corporate partner for the supply chain of renewable aromatic chemicals).

Quantafuel is amongst the developers with highest capacity thanks to its commercial plant in Skive (Denmark), which was recently scaled-up and has now an input capacity of 20 000 t/y<fnref n="192" />. The developer has also another plant in Kristiansund (pilot plant developed with BASF used to test commercial scalability)<fnref n="193" />, and other plants planned in Esbjerg in 2022 (80,000 ton per year), Antwerpen w/VITOL & VTTI in 2022-2023 (100,000 ton per year), Amsterdam with VITOL & VTTI in 2022-2023 (100,000 ton per year), and a first plant with BASF in 2023 (100,000 ton per year)<fnref n="194" />. In 2021, the company purchased

<footnote n="190">¹⁹⁰ https://www.michelin.com/en/press-releases/michelin-and-pyrowave-join-forces-to-industrialize-an-innovative-plastic-waste-recycling-technology/</footnote>

<footnote n="191">¹⁹¹ https://cefic.org/a-solution-provider-for-sustainability/chemical-recycling-making-plastics-circular/chemical-recycling-via-conversion-to-feedstock/start-up-of-lyondellbasells-moretec-plant-underlines-ambitious-plastic-waste-targets</footnote>

<footnote n="192">¹⁹² https://www.quantafuel.com/skive</footnote>

<footnote n="193">¹⁹³ https://www.quantafuel.com/Kristiansund</footnote>

<footnote n="194">¹⁹⁴ https://www.quantafuel.com/plants-and-projects#:~:text=Quantafuel%E2%80%99s%20pilot%20plant%20in%20Kristiansund%20is%20part%20of,plant%20to%20be%20built%20on%20the%20same%20premises.</footnote>
a site to build the Esbjerg plant, which will become one of the biggest plastic waste sorting plants in Europe as well as their future chemical recycling plant. As of June 2021, Quantafuel invested in a plastic pre-sorting line in Aalborg. The sorting line is being built in cooperation with Geminor and it will increase control over feedstock quality for the Skive and Esbjerg plants<fnref n="195" />.

Quantafuel has additionally established partnerships with VTTI (energy partner), Grønt Punkt Norge AS (partnership to increase the material recycling rate in Norway), Plastpiratene (organization involved in plastic collection activities which will send waste to Quantafuel), Vitol (funding of its first plants), and BASF (invested 20 million € to secure the pyrolysis oil for the ChemCycling project)<fnref n="196" />.

The capacities of other developers (such as Bio-BTX) were not disclosed. The first pilot plant of BioBTX was opened in partnership with Zeton, Tebodin-Bilfinger, University of Groningen, KNN Advies B.V., and Syncom B.V. It is known that Bio-BTX has secured funding from multiple investors (Carduso Capital, Vries Beheer, Lynnovation, Groeifonds, NOM) which will be used mainly for the construction of the first commercial plant. The technology developer is also part of the iCarePlast project which aims to turn plastic into aromatics using BioBTX's technology. Other than BioBTX, the iCarePlast consortium is composed of the Agencia Estatal Consejo Superior de Investigaciones Científicas (CSIC), the Universitat Politècnica de València, the Technische Universität Braunschweig, iPoint-Systems gmbh, the National Laboratory of Energy and Geology (LNEG), University of Twente, Imperial College London, KERIONICS S.L., URBASER, S.A.<fnref n="197" />.

### c. Economic performance

Although little information is available, it is relevant to point out that the profitability of these processes is directly impacted by the cost, type, quantity, and lifespan of the catalyst used (24).

Quantafuel has developed a financial model which allows the company to receive a payment both for accepting waste plastic and for the final output sold. This technology developer is receiving a payment around 50-80$ for each ton of plastic collected for recycling. Moreover, the developer has established a partnership with BASF, which has committed to buying all of their output <fnref n="198" /> <fnref n="199" />. The estimated market price of their output is of 1000$ per ton (24).

Pryme has a projected CAPEX of 700€ per ton of output (oil).

The technology developer Carboliq published the following financial information on its website<fnref n="200" />:

* Targeted sales price > 550€/to oil, > 50€/to fuel

* Negative cost (gate fee) for feedstock delivery: -50€/to

* Cost of production <400€/to oil

Additional information on economic performances is currently unavailable as these details are usually not publicly disclosed by developers.

<footnote n="195">¹⁹⁵ https://www.marketscreener.com/quote/stock/QUANTAFUEL-ASA-103374361/news/Q3-21-36981840/</footnote>

<footnote n="196">¹⁹⁶ https://www.quantafuel.com/our-solution/our-partners#:~:text=Quantafuel%20and%20Plastpiratene%20aim%20to%20establish%20an%20environment,tonnes%20of%20plastic%20waste%20from%20the%20marine%20environment.</footnote>

<footnote n="197">¹⁹⁷ https://www.icareplast.eu/consortium/</footnote>

<footnote n="198">¹⁹⁸ https://seekingalpha.com/article/4378135-quantafuel-global-leader-in-chemical-recycling-of-plastic-backed-bASF-and-vitol-potential-to</footnote>

<footnote n="199">¹⁹⁹ https://d1kc1xo119v43s.cloudfront.net/1613912399/qfuel-annual-report-2019.pdf</footnote>

<footnote n="200">²⁰⁰ https://carboliq.com/en/contributions-en.html</footnote>
d. Environmental performance

LCA data (or similar studies), notably carbon footprint

In terms of environmental impact, Pryme claims for its process to present the opportunity to reduce CO₂ emissions up to 100% when compared to traditional forms of crude oil extraction<fnref n="201" /> (no further information was provided concerning the methodology and context that were used to estimate this number). As for Pyrowave, each ton of processed plastics is estimated to prevent the release of more than 2 tons of greenhouse gases<fnref n="202" /> (no further information was provided concerning the methodology and context that were used to estimate this number). Little information is available assessing the reusability or recyclability of catalysts. Additional details concerning the means by which these numbers have been calculated is currently unavailable as this information is usually not publicly disclosed by developers.

Comparative analysis between end-of-life processes

No information found on this subject

Energy costs

By reducing the temperatures required for depolymerization to occur, the presence of a catalyst has the potential to reduce the energy required for catalytic pyrolysis compared to non-catalytic pyrolysis (16). As an example, using a catalyzer in the processing of PP and PE can reduce the activation energy respectively from 276 kJ/mol to 106 kJ/mol and from 394 kJ/mol to 178 kJ/mol (12).

Pyrowave claims for its process to have a (low) energy consumption of roughly 1 to 1.5 kWh/kg of processed materials), which is approximately 10 times less energy than making styrene from virgin resources<fnref n="203" />.

Pryme claimed that they intend to source 100% of their energy from renewable sources (no further details provided).

CATALYTIC PYROLYSIS

<table><tr><td></td><td>Input</td></tr><tr><td>Technology</td><td><ul><li>Input can consist of homogeneous feedstocks (GreenMantra Technologies or Pyrowave relying on PS input streams) or of mixed plastic waste (Quantafuel, Pryme, Cassandra Oil).</li><li>Pre-sorting/pre-treatment may be required to remove contaminants that may lead to a significant reduction of the reaction yields or, in some cases, even to the deactivation of the catalyst (Pyrowave, GreenMantra Technologies, Anellotech).</li></ul></td></tr><tr><td></td><td>Process</td></tr><tr><td></td><td><ul><li>The presence of a catalyst leads to an increased reactivity of the reaction, lower operating temperatures, better selectivity, and reduction of by-products.</li><li>Information concerning type, quantity, and recovery of the catalysts used is usually not publicly disclosed.</li><li>Option A: one-level approach in which the catalyzer and the polymer are directly in contact with each other while the polymer is in its liquid form (Carboliq).</li><li>Option B: two-step system beginning with the thermal degradation of the polymer, followed by a catalytic processing of the produced vapors (option often used to prevent the deactivation of the catalyst) (Quantafuel).</li><li>Processing temperatures to around 300°C.</li></ul></td></tr></table>

<footnote n="201">²⁰¹ https://www.pryme-cleantech.com/solutions/</footnote>

<footnote n="202">²⁰² https://www.pyrowave.com/medias/iw/Brochure-PYROWAVE_2020_ENG_PDF.pdf</footnote>

<footnote n="203">²⁰³ https://www.pyrowave.com/medias/iw/Brochure-PYROWAVE_2020_ENG_PDF.pdf</footnote>
<table><tr><td></td><td><ul><li>Variants of this process: low temperature catalytic pyrolysis; and catalytic microwave pyrolysis (Pyrowave).</li></ul>Output and Downstream steps<ul><li>Like in non-catalytic pyrolysis, output is composed of a liquid fraction, a gas fraction, and solid residues.</li><li>Different catalysts can be used to direct the products, improve the outputs' quality, and yields of this process compared with non-catalytic pyrolysis.</li><li>Depending on the selected process, catalytic pyrolysis can lead to the formation of monomers (depolymerization) or to a hydrocarbon mix (cracking).</li><li>The presence of a catalyst favors the production of oligomers with chains containing between 5 and 10 carbon atoms (with the exception of developers such as Clariter who also targets wax production, i.e., product with more than 10 carbons).</li><li>Further processing (purification/distillation) of the obtained hydrocarbon mix can make this output eligible for integration into higher value applications (Quantafuel, GreenMantra Technologies, Anellotech).</li><li>Examples of technology developers' liquid output yields include Quantafuel - 84%, Pryme - over 90%.</li></ul></td></tr><tr><td>Technology scaling-up</td><td><p><strong>Average Technology Readiness Level</strong></p><ul><li>Estimated TRL: 6-7.</li><li>Low temperature catalytic pyrolysis (approximately 200°C) represents an exception as it has a lower maturity level.</li></ul><p><strong>Current and future capacities</strong></p><ul><li>Current capacities significantly vary from one developer to another.</li><li>Quantafuel is the developer that currently has the highest capacity thanks to its commercial plant (20,000 tons of plastic processed per year).</li><li>Several technology developers (Pryme, Carboliq, Bio-BTX, Quantafuel) claimed that by 2022/23 they will begin production in a commercial facility. No further details have so far been found concerning the advancement of these operations.</li></ul></td></tr><tr><td>Economic performance</td><td><ul><li>Cost significantly impacted by the price, type, quantity, and lifespan of the catalyst used.</li><li>Lack of public data available</li></ul></td></tr><tr><td>Environmental performance</td><td><p><strong>LCA data (or similar studies), notably carbon footprint</strong></p><ul><li>Pyrowave claims that for each ton of processed plastic they prevent the release of over 2 tons of greenhouse gases. This figure is only indicative.</li><li>Little information available concerning the reusability/recyclability of catalysts.</li></ul><p><strong>Comparative analysis between end-of-life processes</strong></p><ul><li>Lack of public data available</li></ul><p><strong>Energy costs</strong></p><ul><li>As the catalyst reduces operating temperatures, energy consumption should be lower than for traditional non-catalytic pyrolysis.</li><li>Lack of public data available on the environmental impact of the process</li></ul></td></tr></table>

STUDIED TECHNOLOGY DEVELOPERS

<figure><img src="image_32.png" /></figure>

CASSANDRA OIL

<figure><img src="image_33.png" /></figure>

<figure><img src="image_34.png" /></figure>

GREENMANTRA™
TECHNOLOGIES

<figure><img src="image_35.png" /></figure>

BioBTX

carboliq

PYROWAVE

Anellotech

<figure><img src="image_36.png" /><figcaption>Table 13: Catalytic pyrolysis recapitulative table (RECORD, 2022)</figcaption></figure>
### 3) Hydrothermal cracking

Note: This section presents the hydrothermal cracking technology Cat-HTR™ developed by Licella Holdings. As of today, Licella Holdings mainly operates via a series of partnerships and subsidiaries (including Mura Technology and Renew ELP).

#### a. Technology

##### Input

In terms of feedstock, Cat-HTR™ uses mixed plastics as input, including certain types of multi-layered plastics (composition not specified). It should however be noted that the quality of the output is directly affected by the input. As an example, the quantity of aromatics found within the feedstock directly impacts the output's quality (no further details provided). That is why, Licella Holdings is currently working with refineries (using their infrastructure) to test how to best extract impurities from their input.<fnref n="204" /> It is also known that Mura Technology is already cleaning and shredding plastic waste before processing it.

##### Process

Mura Technology and ReNew ELP processes operate using Licella Holdings' Cat-HTR™ technology. This process uses supercritical water (water above 374°C and 218 bars), heat and pressure via hydrothermal liquefaction to break long-chain hydrocarbons, donating hydrogen to produce shorter-chain, stable hydrocarbon products. First, the raw material is prepared by being crushed to produce a mixture which also contains water and oil (paraffinic oil, crude oil, bio-oil, etc.). In this phase, non-plastic contaminants are removed. Plastic waste is then melted, pressurized, and mixed with supercritical water. The mixed plastics and water mixture are then inserted into the Cat-HTR™ reactors for approximately 20 minutes at high temperatures (around 450°C) and high pressure (not specified) <fnref n="205" />. Depending on the feedstock used, catalysts can be added to the process. Finally, the products obtained are cooled under atmospheric pressure and the outputs are separated and stored (no further details provided on these last steps).

##### Output and downstream steps

Liquid yields are estimated at approximately 80-85%<fnref n="206" />. Mura Technology and ReNew ELP produce the following output fractions:

* Naphtha

* Distillate Gas Oil

* Heavy Gas Oil

* Heavy Wax Residue

However, they do not carry out additional repolymerization steps. Indeed, these steps should thus be conducted by downstream partners.

After being used in the process and following a depressurization phase, supercritical water goes back to being normal water. The water used in the process can be collected and recycled through a purification stage allowing to remove contaminants that were acquired throughout the recycling process. The rest of the output products (non-liquid fraction) are made up by methane and other gases, which are used within the process to produce a calorific effect. The remaining collected contaminants (such as inks) are also considered as reusable (no further details on how these materials are reused). Hence, no output of the Cat-HTR™ process is labelled as waste.

<footnote n="204">²⁰⁴ Chemical Recycling in Asia Pacific conference, 14/09/2021</footnote>

<footnote n="205">²⁰⁵ https://www.licella.com/wp-content/uploads/2021/11/2021_Licella_Report_FINAL_1Nov_spreads EMAIL.pdf</footnote>

<footnote n="206">²⁰⁶ Chemical Recycling in Asia Pacific conference, 14/09/2021</footnote>
## b. Technology scaling-up

### Average Technology Readiness Level

With regards plastic waste recycling, the technology developers studied, ReNew ELP and Mura Technology, are at demonstration stage with a TRL of 6-7.

### Current and future capacities

The standard Licella module has an initial capacity of 20kt/y (it is not specified whether it refers to input or output capacity). Licella Holdings currently has multiple plants in the pipeline through its partnerships and subsidiaries. Information was found on the following plants<fnref n="207" />:

* Project development in the UK: ReNew ELP is in the final stages of development on the first of four chemical recycling processing lines, with each line processing 20kt of plastic waste a year. The Northeast England plant in Teesside, which will be the first, is planned to start operating by end 2022. Once completed (deadline unknown), the plant is expected to reach a capacity of 80kt/y<fnref n="208" />.

* Under iQRenew Pty, Licella Holdings also owns a pilot plant located on the NSW Central Coast in Australia. No further details found on the capacity and opening date of this plant.

* Licella has proposed the construction of a Cat-HTR™ site at an under-utilized manufacturing site which belongs to Dow Chemicals. The site, located in Australia, would be powered by 100% renewable electricity. Supported by Amcor, Coles, iQ Renew, LyondellBasell, and Nestlé, Licella conducted a feasibility study for the construction of a new plant<fnref n="209" />. The status of advancement of this project remains unknown for the time being.

* One plant in the USA planned for 2024 (no further details available).

* One plant in MCC's Ibaraki Plant, Japan to be completed by 2023: This plant will have an input capacity of 20kt/y and will be deployed by Mura Technologies in partnership with KBR (exclusive licensing partner of Mura, providing engineering and technical services and equipment) and Mitsubishi Chemicals. Mura Technologies and KBR are exploring multiple projects across Asia, Europe, and the USA to meet Mura's target of 1,000,000 tons of annual recycling capacity in operation or development by 2025. This seems rather ambitious when compared to their current capacity<fnref n="210" />.

Mura has been operating in a partnership with Dow Chemicals, which provide financial support and materials science expertise (no further details available)<fnref n="211" />.

## c. Economic performance

According to Mura Technology, the prices of the recycled fraction are comparable to fossil oil. No additional information was found concerning the price of Renew ELP's output. Licella claimed that the costs of this technology compared to other forms of chemical recycling are low and that the company aims to offer cheaper solutions than its competitors (prices and names of competitors not specified).<fnref n="212" /> It has to be noted that this information could not be checked.

<footnote n="207">²⁰⁷ Chemical Recycling in Asia Pacific conference, 14/09/2021</footnote>

<footnote n="208">²⁰⁸ https://muratechnology.com/sites-projects/renew-elp/</footnote>

<footnote n="209">²⁰⁹ https://www.licella.com/wp-content/uploads/2021/11/2021_Licella_Report_FINAL_1Nov_spreads EMAIL.pdf</footnote>

<footnote n="210">²¹⁰ https://www.bioplasticsmagazine.com/en/news/meldungen/20210813-Mura-Technology-KBR-and-Mitsubishi-Chemical-Corporation-announce-innovative-new-plastics-recycling-project-a-first-for-Japan.php</footnote>

<footnote n="211">²¹¹ https://investors.dow.com/en/news/news-details/2021/Dow-and-Mura-Technology-announce-partnership-to-scale-game-changing-new-advanced-recycling-solution-for-plastics/default.aspx</footnote>

<footnote n="212">²¹² Chemical Recycling in Asia Pacific conference, 14/09/2021</footnote>
d. Environmental performance

LCA data (or similar studies), notably carbon footprint

ReNew ELP has conducted an independent LCA study that shows a +70% reduction in GHG emissions compared to a traditional fossil resource⁴¹. However, the methodology and hypothesis taken by this LCA have not been made public and are thus unverifiable.

Licella Holdings has also conducted an LCA study (geographic scope: Australia) to compare the Cat-HTR™ process with the production of virgin oil and to evaluate its environmental benefits. Disclosed results reported on a reduction of particulate emissions (air pollution) and water usage compared to landfilling and energy recovery. The methodology and hypothesis considered in this LCA have not been made public and are thus unverifiable.

<table><caption>Table 14: Benefits of Cat-HTR™ vs. landfill and waste-to-energy<fnref n="213" /></caption><thead><tr><th></th><th>Particulate Matter<br>(g PM<sub>2.5</sub> equivalent)</th><th>Consumptive Water Use<br>(L)</th></tr></thead><tbody><tr><td>Cat-HTR™</td><td>-90.0</td><td>0.13</td></tr><tr><td>Landfill</td><td>2.74</td><td>0.29</td></tr><tr><td>Waste-to-energy</td><td>2.48</td><td>2.36</td></tr></tbody></table>

Comparative analysis between end-of-life processes

Mura Technology mentions that this technology could save approximately 1.5 tCO₂/t of plastic processed when compared to incineration. However, there is no further indication on the source of this information⁴².

The LCA study conducted by Licella Holdings in Australia reported on a 64% reduction of GHG emissions during the production of 1 ton of Cat-HTR™ oil vs fossil crude oil (kg CO₂e) (with the GHG emissions of Cat-HTR™ being estimated at 203 kg CO₂e per ton of oil)<fnref n="214" />.

Energy costs

The technology developers have not made public the quantity of energy required for this process though they claim that the use of supercritical water allows to heat the feedstock rapidly and thus avoids excessive cracking⁴³. Licella additionally supports the statement by which the presence of water helps better control the process and, by doing so, it makes the process more energy efficient due to the lower operating temperatures<fnref n="215" />.

<footnote n="213">²¹³ https://www.licella.com/wp-content/uploads/2021/11/2021_Licella_Report_FINAL_1Nov_spreads EMAIL.pdf</footnote>

<footnote n="214">²¹⁴ https://www.licella.com/wp-content/uploads/2021/11/2021_Licella_Report_FINAL_1Nov_spreads EMAIL.pdf</footnote>

<footnote n="215">²¹⁵ https://www.licella.com/wp-content/uploads/2021/11/2021_Licella_Report_FINAL_1Nov_spreads EMAIL.pdf</footnote>
<table><caption>Table 15: Hydrothermal treatment recapitulative table (RECORD, 2022)</caption><thead><tr><th colspan="2">HYDROTHERMAL CRACKING</th></tr></thead><tbody><tr><td>Technology</td><td><p>Input<br/>• Mixed plastic waste</p><p>Process<br/>• Supercritical water, heat, and pressure via hydrothermal liquefaction to break long-chain hydrocarbons, donating hydrogen to produce short-chain, stable hydrocarbon products.</p><p>Output and Downstream steps<br/>• Naphtha<br/>• Distillate Gas Oil<br/>• Heavy Gas Oil<br/>• Heavy Wax Residue</p></td></tr><tr><td>Technology scaling-up</td><td><p>Average Technology Readiness Level<br/>• Estimated TRL = 6-7 (for the developer studied).</p><p>Current and future capacities<br/>• ReNew ELP is in the final stages of development on the first of four chemical recycling processing lines, with each line processing 20,000 tons of plastic waste a year. The Northeast England plant in Teesside, which will be the first, is slated to launch mid- to end 2021.</p><p>Licella has several other projects in the pipeline, details on the advancement on these projects are however unavailable for the time being.</p></td></tr><tr><td>Economic performance</td><td>According to Mura Technology, the price of the recycled material is comparable to fossil oil.</td></tr><tr><td>Environmental performance</td><td><p>LCA data (or similar studies), notably carbon footprint<br/>• ReNew ELP has conducted an independent LCA study that shows a +70% reduction in GHG emissions compared to a traditional fossil resource*.</p><p>A LCA conducted by Licella Holdings shows that in Australia Cat-HTR™ would lead to a 64% GHG emissions reduction compared to the production of virgin oil. The technology would produce less particulate matter and consume less water than landfilling and energy recovery.</p><p>Mura Technology mentions that this technology could save approximately 1.5 tCO₂/t of plastic processed when compared to incineration*.</p><p>Please note the above figures are only indicative.</p><p>Energy costs<br/>• The use of supercritical water would allow to heat the feedstock rapidly and thus avoids excessive cracking<br/>• The presence of water within the process reduces operating temperature and, subsequently, energy consumption<br/>• Lack of public data available on the environmental performance of the process</p></td></tr><tr><td colspan="2">STUDIED TECHNOLOGY DEVELOPERS</td></tr><tr><td colspan="2">Licella™ MURA ReNew ELP</td></tr></tbody></table>

<footnote>*Unverifiable statements from technology developers.</footnote>
4) Hydrocracking (or catalytic depolymerization through hydrocracking – in the presence of hydrogen)

Note: The information contained in this section has been sourced from scientific papers reviewing hydrocracking technologies in general. These papers do not always specify whether the information provided refers to plastic-to-fuel or plastic-to-plastic applications. Given that most of the existing research on this topic has been conducted on hydrocracking for plastic-to-fuel applications, it is likely that some of the documents used to write this report may have been built on literature referred to plastic-to-fuel experiments.

The ECHA refers to this technology also using the term hydrogenation.

a. Technology

Input

Research has proven that different resins react in diverse manners to hydrocracking. The estimated hierarchy of feedstocks' suitability for the degradation of plastic materials via hydrocracking is as follows: PIP<sup>216</sup>>PS>PET>PP~PBD>LDPE>HDPE<sup>217</sup> (23). PVC resins are not included in the ranking as they are usually excluded from selected feedstocks due to their poisoning effects (10). Although little information is available on the topic, this technology is considered to be capable of treating both mono-streams and mixed plastics (12). The absence of developers deploying this recycling process<sup>218</sup>, together with limited publicly available information, does not allow to determine which type of polymers are most often used, nor whether pre-sorting or pre-treatment of plastic waste is common practice for this technology. It is however known that hydrocracking processes have proven highly sensitive to impurities and contamination of input resins (10). Pre-treatment steps may therefore be required to achieve an optimal output.

Process

The term “hydrocracking” refers to a specific type of catalytic cracking, one that is realized under a
hydrogen (H₂) atmosphere. Hydrocracking processes are used to shorten the length of polymer chains
(23). In hydrocracking, plastic waste is first subjected to a low temperature pyrolysis. Then, the core
reaction takes place and turns plastics into a liquid stage free from non-distillable matter. The liquid
obtained is then moved to the catalyst bed (10). During the core reaction, C-C bonds are split to then
be hydrogenated on a monofunctional acid catalyst or on a bifunctional catalyst (bifunctional
hydrocracking) (12). Whether monofunctional or bifunctional, any catalyst used in this process must
have both hydrogenation-dehydrogenation and cracking abilities. A typical hydrocracking catalyst is
composed of a metal site and an acid site. The acidic support within the catalyst (e.g., silica-alumina,
crystalline zeolite, a strong solid acid, etc.) activates cracking and isomerization reactions, while the
metal (noble metal, non-noble metal of group VI-A or group VIII-A of the periodic table) performs the
hydrogenation-dehydrogenation function. Bifunctional catalysts are generally considered the best option
for the hydrocracking of plastics. Catalysts with a hydrotreating ability or with low sensitivity to the
presence of impurities are preferred for the treatment of plastic waste (23).

As for other technologies, one of the reasons why catalysts are used in hydrocracking is to reduce processing temperatures. Hydrocracking generally occurs at temperatures between 375°C and 500°C. When hydrocracking is conducted at low temperatures, catalysts with weak acidic properties (e.g., alumina/silica) or weak hydrogenation-dehydrogenation functions (e.g., Fe) should be avoided as they have proven unable to crack plastics in the presence of limited heat. Increasing reaction temperatures may lead both to an increase in plastics' conversion and to a decrease in the output's quality (23). In general, temperatures over 400°C are not recommended for hydrocracking as more gases and coke

<footnote n="216">216 PIP = polyisoprene</footnote>

<footnote n="217">217 Resins are ranked based on the highest liquid conversion yields obtained (please refer to the following paragraphs for further details)</footnote>

<footnote n="218">218 This statement refers to the findings of the background research that was conducted for this study.
Technology developers may exist although they have not been considered within this analysis.</footnote>
may result due to higher temperatures (23). It should additionally be noted that the type and presence of a catalyst does not have a significant impact if the process is conducted at high temperatures (10).

In terms of other operating requirements, hydrocracking usually requires hydrogenated pressures reaching up to 70 bars (10). The effects of different hydrogen pressures in the process have however not been thoroughly explored by researchers. As for reaction times, increasing the length of the reaction may both favor the reaction by increasing plastics' conversion rates and lead to an increased production of gas. Optimal times to achieve the maximum oil yield should be determined based on the type of polymer treated and the other reaction conditions. A reaction time of more than 60 minutes is usually not advised for an active catalyst at moderate temperatures (23).

## Output and downstream steps

Other than reducing operating temperatures, adding a catalyst in the process leads to an increased oil quality and improved conversion yields (10). Similarly, the presence of hydrogen allows to obtain higher quality outputs compared to conventional catalytic pyrolysis. Compared with conventional and catalytic pyrolysis, hydrocracking can reduce the formation of olefins, aromatics, and coke in the reaction products. Moreover, the presence of hydrogen allows for the removal of heteroatoms such as chlorine, bromine, and fluorine that may be found in waste plastic (23). As previously mentioned, the estimated order of ease for the degradation of various individual plastic materials is the following: PIP>PS>PET>PP=PBD>LDPE>HDPE. This ranking should be interpreted as PIP giving the highest liquid yield and the lowest yield of gas, while HDPE gives the lowest liquid yield and the highest yield of gas. A desired quality of oil may be produced by selecting a specific composition of the plastic feed. Although hydrocracking has been studied for the production of recycled feedstock, most of the information available of this process and the majority of its current applications are related to the production of high quality and ready-to-use fuels (12, 13). This process produces in fact highly saturated liquid products which do not need further upgrading if used for transportation fuel or energy production (23).

## b. Technology scaling-up

### Average Technology Readiness Level

The technology has an estimated TRL of 7 for plastic-to-fuel applications. However, when it comes to plastics-to-plastics applications, the technology is still at a research/pilot scale. No evidence was found of the technology being applied at a commercial scale or of industry players having publicly invested in the development of this technology. Thus, the estimated TRL could be 2-3.

### Current and future capacities

Hydrocracking has not yet been tested on an industrial scale for waste management purposes. While several scientific studies have been conducted to assess the efficiency of hydrocracking processes to treat plastic waste, further research is required to better understand under which conditions (temperature, pressure, feedstock, catalyst, reaction time) the process achieves highest efficiency. As of now, hydrocracking remains more popular in plastic-to-fuel applications (12, 13).

## c. Economic performance

Hydrocracking is usually expensive due to the investments needed to generate high pressures (12) and elevated operating costs associated for example with the consumption of hydrogen (which costs around €2500 per tons when electrically produced) (14). The hydrocracking of some types of waste (such as PVC) may produce hazardous substances. Dealing with such materials has an impact on the process' cost as it requires additional control operations and removal of impurities from the end products. Applying very high pressure might additionally fail to provide added benefits when considering the cost associated with a high-pressure process. Significant investments in research and development are required due to the technology still being in its early stages. Operating costs will also have to be optimized for hydrocracking to become a more attractive recycling solution (10).

## d. Environmental performance

*No information found on this subject*
<table><caption>Table 16: Hydrocracking recapitulative table (RECORD, 2022)</caption><thead><tr><th colspan="2">HYDROCRACKING</th></tr></thead><tbody><tr><td>Technology</td><td><p>Input<ul><li>Estimated hierarchy for feedstock suitability: PIP>PS>PET>PP~PBD>LDPE>HDPE.</li><li>PVC is usually avoided as input due to its poisonous effects.</li><li>Technology considered as capable of treating both mono-streams and mixed plastics.</li><li>Pre-treatment/pre-sorting may be required due to the high sensitivity to impurities of these processes.</li></ul><p>Process<ul><li>Specific type of catalytic cracking realized under a hydrogen atmosphere.</li><li>The presence of a catalyst reduces the required operating temperatures which, for hydrocracking, descend between 375°C and 500°C. Temperatures above 400°C are however not recommended (more gases and coke may result due to higher temperatures).</li><li>The catalyst used can either be a monofunctional acid catalyst or a bifunctional catalyst. The type of catalyst should be selected based on other operating conditions (e.g., temperature, desired output, etc.).</li><li>Further research is necessary to determine optimal operating temperatures, pressure, catalyst, and reaction time.</li></ul><p>Output and Downstream steps<ul><li>Outputs are comparable with those of catalytic pyrolysis but with a reduced formation of olefins, aromatics, and coke.</li><li>Reaction used to reduce the length of polymer chains.</li><li>Adding a catalyst to the reaction increases oil quality and improves conversion yields.</li></ul></td></tr><tr><td>Technology scaling-up</td><td><p>Average Technology Readiness Level<ul><li>Estimated TRL: 2-3.</li></ul>Current and future capacities<ul><li>Not yet deployed on a commercial scale for plastic-to-plastic applications.</li><li>Further research required to determine optimal conditions for hydrocracking.</li></ul></td></tr><tr><td>Economic performance</td><td><ul><li>High investments needed to generate high pressures.</li><li>Elevated costs of electrically produced hydrogen (€2500 per tons).</li><li>Significant investments still required to further develop this technology.</li><li>Lack of public data available</li></ul></td></tr><tr><td>Environmental performance</td><td><ul><li>Lack of public data available</li></ul></td></tr></tbody><thead><tr><th colspan="2">STUDIED TECHNOLOGY DEVELOPERS</th></tr></thead><tbody><tr><td colspan="2">No technology developer identified</td></tr></tbody></table>

## 5) Gasification

Note: Some experts consider gasification as indirect recycling of plastic waste. That is because the syngas produced using this process is an intermediary product which requires further conversion steps. The building blocks produced in this process could be used both for plastics and for fuel applications. For the purpose of this study, chemical recycling through gasification only refers to plastic-to-plastic applications.

Variants of gasification processes already exist (such as plasma gasification); however, they are still undergoing a research and development phase.
a. Technology

Input

One of the main advantages of gasification is its ability to treat all type of polymers and almost all feeds composed of organic materials (2,3). Although this technology can treat mixed and soiled plastics, gasification still requires stable waste composition. It is generally preferable to free the input from metals, fermentable composites, and moisture (2,3). This makes the pre-processing of the feedstock often necessary. Pre-treatment steps for gasification can involve waste screening, shredding, and classification (no further details provided on any of the pre-treatment steps).

The technology developer Enerkem treats mixed plastics, woody biomass, textiles, agricultural granulates, and material recovery facility residues. Their input comes from industrial, commercial, or municipal sources<fnref n="219" />. Enerkem prepares its feedstock through sorting to remove recyclable materials and inert materials, then they are shredded, and dried (if needed)<fnref n="220" />.

Synova Tech treats waste composed of biomass, ash, moisture, and plastics that are not suitable for mechanical recycling<fnref n="221" />. The developer claims that there is no need to separate nor to wash the feedstock (mixed plastic municipal solid waste). Yet, their recycling process begins with a preparation step consisting of sizing of the feedstock and dosing the input via the feed bin to ensure a consistent throughput (no further details are available concerning this process). Materials which are excluded from the selected feedstock are sent to incineration<fnref n="222" />.

Process

Gasification is a thermal treatment cracking process that is conducted in the presence of limited quantities of oxygen (6). This process works by partially oxidating the waste that is inserted in the reactor. There are different types of gasification which happen at different temperatures and under different operating conditions (such as the use of different gasifying agents). Medium temperature gasification features temperatures ranging between 900°C-1650°C, while low temperature gasification takes place at 700°C-900°C (6). The main gasifying agents used are air, steam, and oxygen. Different gasifying agents determine the final composition of the output produced and its suitability for different applications (10). Following the production of syngas, many recycling processes include a syngas cleaning phase.

Enerkem is the most well-known technology developer operating via gasification mainly for waste-to-fuel, but also for plastic-to-plastic applications<fnref n="223" />. Following pre-sorting and pre-treatment, waste is fed into the gasification vessels. Here, the input is broken down in the presence of steam and under specific operating conditions (no further details provided). To improve the purity and quality of its output, the developer has implemented a unique bubbling fluidized bed gasification reactor. To be eligible for chemical-grade applications, the produced syngas also has to undergo a further cleaning and conditioning treatment. This process is conducted directly by Enerkem (details not provided). After having been processed, the syngas is subjected to catalytic conversion, which produces liquid methanol and possibly fuel-grade ethanol as final output<fnref n="224" />.

Synova Tech's technology MILENA-OLGA (developed through a joint venture with TNO), works by inserting feedstock, steam, and combustion air into a MILENA gasifier, which converts the input into

<footnote n="219">219 https://enerkem.com/feedstock/flexibility/</footnote>

<footnote n="220">220 https://enerkem.com/process-technology/carbon-recycling/</footnote>

<footnote n="221">221 https://synovatech.com/our-technology-platform/</footnote>

<footnote n="222">222 https://synovatech.com/wp-content/uploads/2021/11/CE_Delft_200456_Carbon Footprint Synova-T_FINAL-public-version-2.pdf</footnote>

<footnote n="223">223 Although Enerkem produces more waste-to-fuel outputs, some of its outputs (e.g. syngas) can be used to make new plastics.</footnote>

<footnote n="224">224 https://enerkem.com/process-technology/carbon-recycling/</footnote>
solids (char and tars<sup>225</sup>) and product gas. The solids formed are then transported to a combustion chamber, where their latent energy is captured and used to drive the production process. At the same time, gas and tars are transported into a product gas cooler. The heat energy recovered within the gas cooler is used in the production of process steam. The cooled gas is then moved into a cyclone where it is spun to remove particulate matter. The spun gas is inserted into OLGA. OLGA is a clean-up train which cleans the product gas by removing up to 99.9% unwanted tars using a cooled collecting oil, an electrostatic precipitator, and a cooled absorbing oil<sup>226</sup>. The OLGA process is able to clean the gas of residual heavy tars through the use of a cooled collecting oil (collected tars are sent back to the MILENA reactor). Other fine particles as aerosols are removed through the use of an electrostatic precipitator. Finally, a cooled absorbing oil is used to further filter the gas and remove remaining light tars (which are also sent back to the MILENA reactor together with the heavy tars). All tars that are collected by OLGA, are broken down and used as fuel to power up the whole process.

A gasification technology known as Ebara Ube Process (EUP) is being deployed in Japan. The process was developed by Ebara Corporation and Ube Industries in 2000. It uses a mixture of oxygen and steam as agents to produce syngas from plastic waste. No further details were found concerning the operating conditions of this technology<sup>227</sup>. It is however known that the process is currently being used by Showa Denko within their chemical recycling facility.

## Output and downstream steps

Gasification converts inputs into a synthesis gas (syngas), which is a gaseous mixture of carbon dioxide, carbon monoxide, hydrogen, methane, water, and other light hydrocarbons (16). The output of this process often contains impurities such as char, NH<sub>3</sub>, H<sub>2</sub>S, NOx, alkali metals and tars (6). The quantity of impurities and by-products produced depends on the input used and operating conditions (such as the operating temperature or the selected gasifying agent). High-volatility feedstocks such as PS, PVC, and PET, lead to low char yields but high tar formation. Higher amounts of char are found in waste containing materials such as biomass and fibers (10).

Different types of syngas are suitable for diverse purposes (e.g., energy, fuels, chemicals, plastics). Output obtained via low temperature gasification is only suitable for energy applications, while that obtained via medium temperature gasification can be used for plastic applications. Turning syngas into final products requires a phase of catalytic conversion and distillation. There are at least 4 different paths to close the loop with plastic production: 1. Direct conversion of syngas to produce olefins; 2. Syngas used to produce methanol which is converted into olefins (Methanol-to-Olefins process, MTO); 3. Syngas used to produce ethanol which is converted into ethylene; 4. Syngas used to produce hydrocarbons (obtained via Fischer Tropsch) which are converted into olefins in a steam cracker.

The crude syngas that is produced by Enerkem consists of carbon monoxide, carbon dioxide, water, and hydrogen. As previously described, transforming syngas into building blocks suitable for plastic applications requires additional purifications steps meant to improve its quality (6) and downstream conversion steps. After having been processed, Enerkem's syngas is subjected to catalytic conversion, which produces liquid methanol and possibly fuel-grade ethanol as final output<sup>228</sup>.

The process developed by Synova Tech is capable of directly producing olefins. Once the syngas has been processed through OLGA, Technip Energies (strategic partner) carries out an additional step of

<footnote n="225"><sup>225</sup> Chars are carbonized products produced during pyrolysis or gasification processes. Tar is a dark brown or black dense liquid made of hydrocarbons and free carbon. Tar is obtained from organic materials.</footnote>

<footnote n="226"><sup>226</sup> https://synovatech.com/our-technology-platform/</footnote>

<footnote n="227"><sup>227</sup> https://www.ube-ind.co.jp/ube/en/news/2019/20190828_01.html</footnote>

<footnote n="228"><sup>228</sup> https://enerkem.com/process-technology/carbon-recycling/</footnote>
hydrocarbon treatment and purification of the output produced using a steam cracker unit<fnref n="229" />. The olefins produced through this process can be used to in plastics, renewable fuels, and for utilization in turbines. The following data are an example of the outputs produced by Synova Tech starting from a plastic rich feedstock<fnref n="230" />:

Synova/Technip Energies (later as T.En) feedstock composition (input):

* Plastic 590 kg (pure, dry materials excluding inert material and moisture)

* Biomass 291 kg (pure, dry materials excluding inert material and moisture)

* Ash 109 kg

* Moisture 10 kg

High Value Chemicals (HVCs) and fuel gas production (valuable outputs):

* Ethylene 198 kg

* Propylene 70 kg

* 1,3-Butadiene 26 kg

* Benzene 67 kg

* Toluene 16 kg

* Fuel gas 189 kg

## b. Technology scaling-up

### Average Technology Readiness Level

Gasification has an estimated overall TRL of 6. The technology is well-developed for waste-to-fuel applications (TRL 9); yet plastic-to-plastic value chain is still under development.

Developers owning advanced gasification technologies include:

* Enerkem, a Canadian company currently close to commercial scale, with an overall TRL of about 8 (including both waste-to-plastics and waste-to-fuels applications).

* Synova Tech, a Dutch company currently running a pilot plant and has an estimated TRL of about 5-6 for its waste-to-plastics applications.

* Showa Denko, a Japanese company using the EUP technology and running a commercial plant since 2003. Their estimated TRL is 9 (output's applications not specified).

### Current and future capacities

Enerkem is currently operating a plant in Edmonton (Canada) able to process 100,000 dry tons of waste per year and produce 38 million liters of methanol per year (not specified to what extent the output is used for plastic applications). In the long-term, Enerkem aims to license its technology and start deploying prefabricated modular systems internationally. Its investors include Chinese Sinobioway Group and BlackRock. Other partners for the development of recycling plants include Alberta Innovates, Government of Alberta, Air Liquide, Nouryon, Suez, Port of Rotterdam, Waste Management of Canada, Investissement Quebec, Cycle Capital. Disclosed upcoming projects include:

- A plant in Rotterdam (Netherlands) to process 360 000 tons of waste per year and produce 220 000 tons of jet fuel per year.

- A plant in Varennes (Canada), which is currently under construction and scheduled for 2023. The planned capacity is about 125M liters of biofuels and renewable chemicals (input 200k metric tons of waste). This plant, which is worth C$875 million, is being built with strategic partners including Shell (lead investor), Suncor (investor), Proman (investor), Hydro-Québec

<footnote n="229">²²⁹ https://synovatech.com/synova-and-technip-energies-announce-strategic-partnership-in-advanced-plastic-recycling-technology/#:~:text=Synova%E2%80%99s%20patented%20thermochemical%20recycling%20technology%20closes%20the%20gap,olefin%20monomers%20and%20co-products%2C%20to%20produce%20circular%20plastics.</footnote>

<footnote n="230">²³⁰ https://synovatech.com/wp-content/uploads/2021/11/CE_Delft_200456_Carbon Footprint Synova-T_FINAL-public-version-2.pdf</footnote>
(renewable hydrogen and oxygen supplier) and with the support of the governments of Quebec and Canada.

- A plant in Tarragona (Spain), which is in development and pending final investment decision. The input would amount to 400kt of waste per year and the output to 270M liters per year of methanol

Synova Tech operates a joint venture with TNO and has a strategic partnership with Technip Energies. The developer installed its first lab-scale unit in 2004 (unknown capacity). A pilot unit (unknown capacity) followed in 2008 in the Netherlands. However, their full integrated technology (MILENA-OLGA) started being tested in 2009 when OLGA was coupled with MILENA in their pilot plant. The technology developer additionally built two small scale plants in India and Portugal, each of which has a capacity of 25 tons per day (approximately 7.5 kt/y, it is not specified whether it refers to input or output capacity). The developer has not yet disclosed future plans for the upscaling of its technology.

Showa Denko owns a plant with a capacity of 70kt/y plastic waste, which has been operating since 2003. The plant is based in Japan and runs using the EUP technology. In 2019, Showa Denko, JGC, Ebara Environmental Plant, Ube Industries, started drafting a licensing contract for the deployment of the EUP technology in Japan as well as other countries (geographic scope not specified). No recent updates were found on the advancement of their joint operations<fnref n="231" />.

### c. Economic performance

Feedstock's pre-treatment, large amounts of input required, use of pure oxygen, high energy consumption, and need for final purification steps of syngas, significantly increase operational costs associated with gasification.

### d. Environmental performance

#### LCA data (or similar studies), notably carbon footprint

In a Delft study (25), the impacts of gasification were studied. The inputs of this data were various publications and insights from confidential projects as well as TNO's publications.

It was found that gasification of 1 ton of plastic waste emits about -0,2 tCO₂e/t input of DKR350²³² or waste refused by mechanical recyclers, taking into account avoided products and energy. However, due to the screening nature of the studies and the differences in processed waste streams, the results should be considered indicative. Moreover, data from industrial-scale processes are not available and thus these results are only estimated.

#### Comparative analysis between end-of-life processes

In the same study, it was found that:

- Incineration emits about 1.5 tons of CO₂e./ton of input of DKR 350 (mixed plastic stream) or recycling failures.

- Mechanical recycling of DKR 350 to plastic recyclate for thick-walled applications ('dkr 350') provides a climate impact of approximately -0.5 tons of CO₂e./ton of input material. This is the case, among other things, because the application of the recyclate prevents the production of steel and virgin plastic. Indeed, in this assessment, the following scenario for processing DKR 350 has been retained: "The mixed plastic flow (DKR 350) produced from household plastic is currently mainly processed in Germany. It is washed and converted into recycled plastic, which is mainly used in thick-walled applications. This is for example garden furniture, tiles, and roadside bollards. According to research conducted by TNO, this recyclate replaces 1/4 concrete, 1/4 plastic, 1/4 steel, 1/8 tropical hardwood, and 1/8 impregnated wood (TNO, 2017)." (Translated from Dutch).

<footnote n="231">²³¹ https://www.nsenergybusiness.com/news/jgc-ube-industries-showa-denko-begin-study-on-gasification-chemical-recycling-of-plastic-waste/</footnote>

<footnote n="232">²³² DKR 350 specification in Netherlands is a category of waste where various types of plastics end up together. This stream makes up circa 35% of the total volume of sorted plastic packaging materials and is difficult to recycle mechanically. Source: Netherlands institute for sustainable packaging.</footnote>
- Pyrolysis emits about 0 tons of CO2e./ton of input of DKR350 or recycling failures.

- Gasification emits about -0.2 tons of CO2e./ton of input of DKR350 or recycling failures.

In August 2021, Synova Tech published the results of a LCA study conducted by CE Delft. The analysis was conducted in the Netherlands using a feedstock containing 560 kg of plastics and 291 kg of (dry) biomass per tons of waste (with the remaining 119 kg composed of ash and moisture). A plant with a capacity of 50kt/y (input/output not specified) was used as a reference. The study considered both the production and the waste management functionality of the Synova process<fnref n="233" />:

* From a production perspective, the process was compared with virgin production of High-Value Chemicals (HVCs). The total virgin production of HVCs was estimated at 1.5 tons CO2e./ton HVCs (European average). While the Synova's process itself has a higher footprint than virgin production, it was considered that the process involves co-production of fuel gas, avoids waste incineration credits, and that biogenic carbon is present in the products. Adding these factors into the calculation as saved emissions resulted in a footprint net reduction of 2.5 kg CO2e./ton HVCs compared to virgin production.

* From a waste perspective, Synova Tech's technology was compared to incineration with energy recovery (Dutch Municipal Solid Waste Incinerator). Waste incineration results in a footprint of 0.8 tons CO2e./ton waste. By taking into account emissions avoided from virgin fossil based HVCs production, the process results in a net 0.9 tons CO2e./ton waste saving compared to incineration.

## Energy costs

This technology is known for having the disadvantage of requiring high energy consumption compared to other recycling processes (further details currently unavailable) (6). However, it should be noted that non condensable light fractions could be used to have an autothermal process<fnref n="234" />.

Synova Tech is able to power its process by transforming unwanted tars into fuels and by recovering the heat produced by solid flows and by gas in the cooling process.

<footnote n="233">²³³ https://synovatech.com/wp-content/uploads/2021/11/CE_Delft_200456_Carbon footprint_Synova-T_FINAL-public-version-2.pdf</footnote>

<footnote n="234">²³⁴ An autothermal process refers to a system in which some of the output produced are used to heat up the process itself. However, the process still needs an external energy supply to function at a certain moment.</footnote>
<table><thead><tr><th colspan="2">GASIFICATION</th></tr></thead><tbody><tr><td>Technology</td><td><strong>Input</strong><ul><li>Input can consist of all types of polymer and almost all feeds composed of organic materials.</li><li>Gasification can treat mixed and soiled plastics. It is however preferable to free the input from metals, fermentable composites, and moisture using pre-sorting or pre-treatment processes.</li></ul><strong>Process</strong><ul><li>Process conducted in the presence of limited flow of oxygen.</li><li>Medium temperature gasification 900°C-1650°C.</li><li>Low temperature gasification: 700°C-900°C.</li><li>Enerkem is the most well-known technology developer operating via gasification for notably waste-to-fuel but also for plastic-to-plastic applications.</li></ul><strong>Output and Downstream steps</strong><ul><li>The output consists of synthesis gas (syngas) that can be transformed into energy, plastics, fuels, and chemicals through further treatment.</li><li>Syngas often contains impurities and by-products such as char, NH<sub>3</sub>, H<sub>2</sub>S, NOx, alkali metals and tars.</li><li>Plastic-to-plastic applications require medium temperature gasification.</li><li>Synova Tech's process include a purification phase run by Technip Energies.</li></ul></td></tr><tr><td>Technology scaling-up</td><td><strong>Average Technology Readiness Level</strong><ul><li>Estimated TRL: 6 (as plastic-to-plastic value chain is not fully mature)</li></ul><strong>Current and future capacities</strong><ul><li>Enerkem is currently processes 100,000 dry tons of waste per year and produces 38 million liters of methanol per year. The developer has multiple additional projects in the pipeline for the upcoming years.</li><li>Showa Denko owns a plant with a capacity of 70kt/y plastic waste,</li></ul></td></tr><tr><td>Economic performance</td><td><ul><li>High costs of feedstock pre-treatment, energy, and final purification steps of syngas. Downstream steps are also needed to convert syngas into chemicals and subsequently into polymers.</li><li>Lack of public data available</li></ul></td></tr><tr><td>Environmental performance</td><td><strong>LCA data (or similar studies), notably carbon footprint</strong><ul><li>Process was found less impactful than incineration and pyrolysis but more emissive than mechanical recycling.</li><li>Synova Tech's LCA showed emission saving compared to virgin production of HVCs and to incineration with energy recovery.</li></ul><strong>Energy costs</strong><ul><li>High energy consumption compared to other recycling processes. However, non-condensable light fractions could be used to have an autothermal process.</li><li>Lack of public data available on the environmental performance of the process</li></ul></td></tr></tbody></table>

STUDIED TECHNOLOGY DEVELOPERS

<figure><img src="image_37.png" /></figure>

Enerkem

SYNOVA

SHOWA DENKO

<caption>Table 17: Gasification recapitulative table (RECORD, 2022)</caption>
# VIII. Downstream steps

## 1) Introduction on downstream steps

Downstream steps are usually required after chemical recycling to remove residual impurities, contaminants and perform one or several conversion steps to produce recycled polymers with the proper specifications. These downstream steps depend on the technology, the output's quality, and the targeted end-application.

Impurities can represent an issue for downstream applications, especially if a high-quality material is required. 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.

A few examples are presented below:

* In the case of the production of monomers via solvolysis, purification and repolymerization steps are needed.

* Regarding pyrolysis, oil purification and further treatment is needed to make it suitable to enter a steam cracker, as would a virgin feedstock. Steam cracking represents the last step to having a virgin-like product.

## 2) Example of downstream step: vapocracking (Steam cracking)

### a. Technology

#### Input

This process takes as an input the condensable fraction originating from pyrolysis and gasification processes. Indeed, the input is thus comparable to these processes and consists in plastics that are left in the waste stream after mechanical recycling and that otherwise would end up in landfill (such as flexible, multi-layer films).

#### Process

<figure><img src="image_38.png" /><figcaption>Figure 6: Steam cracking process (RECORD, 2022)</figcaption></figure>
Steam cracking or vapocracking is a petrochemical process that consists in obtaining, from petroleum fractions (such as ethane, propane, butane, gas oil or naphtha) alkenes (ethylene, propylene) that are better valorized. These alkenes are mainly used in the plastics industry to produce polymers (polyethylene, polypropylene, etc.). The fractions used can be replaced by the oil produced in pyrolysis or gasification processes, which is similar to naphtha in its composition.

These naphtha cuts, resulting from the thermal treatment of plastics, are introduced into the steam cracker under high temperature (around 700°C), and in the presence of steam (around 30 to 100% by weight). The steam allows to reduce the "residence time" and to prevent the formation of coke.

Under these conditions, the hydrocarbon molecules in the naphtha split into several fractions (gases, raffinate and olefins) giving rise to different outputs (12).

## Output and downstream steps

Steam cracking gives out several products:

* Olefins, such as ethylene, propylene, butadiene, isobutene, and other unsaturated products. These components will need to undergo additional treatments (chlorination, oxidation, polymerization, etc.) to recuperate ethylene ($C_2H_4$) and propylene ($C_3H_6$). These two molecules are the origin of many plastics and can be repolymerized afterwards to create other components such as Polyethylene, Polypropylene, PET, PVC (12).

* Gases (dihydrogen, methane, ethane, etc.) (12). The process gases are reused in the process to generate supercritical steam40.

* A fraction called "raffinate", which is used for fuel applications.

## b. Technology scaling-up

### Average Technology Readiness Level

As previously mentioned, steam cracking is already used at commercial scale in the petrochemical industry.

### Current and future capacities

No information found on this subject

## c. Economic performance

No information found on this subject

## d. Environmental performance

### LCA data (or similar studies), notably carbon footprint

No information found on this subject

### Comparative analysis between end-of-life processes

No information found on this subject

### Energy costs

No information found on this subject
<table><thead><tr><th colspan="2">STEAM CRACKING</th></tr></thead><tbody><tr><td>Technology</td><td><p>Input<br/>• Condensable fraction originating from pyrolysis and gasification.</p><p>Process<br/>• Naphtha cuts, resulting from the thermal treatment of plastics, are introduced into the steam cracker under high temperature (around 700°C), and in the presence of steam (around 30 to 100% by weight)</p><p>Output and Downstream steps<br/>• Three types of output produced:<br/>○ Olefins and other unsaturated products - These components will need to undergo additional treatments (chlorination, oxidation, polymerization, etc.) to recuperate ethylene (C<sub>2</sub>H<sub>4</sub>) and propylene (C<sub>3</sub>H<sub>6</sub>).<br/>○ Gases: The process gases are reused in the process to generate supercritical steam.<br/>○ A fraction called "raffinate", which is used for fuel applications.</p></td></tr><tr><td>Technology scaling-up</td><td><p>Average Technology Readiness Level<br/>• Steam cracking is already used at commercial scale in the petrochemical industry.</p><p>Current and future capacities<br/>• Lack of publicly available data</p></td></tr><tr><td>Economic performance</td><td>Lack of publicly available data</td></tr><tr><td>Environmental performance</td><td>Lack of publicly available data</td></tr></tbody></table>

STUDIED TECHNOLOGY DEVELOPERS

No technology developer - Steam crackers are already operated by petrochemical industries at commercial scale.

<caption>Table 18 : Steam cracking recapitulative table (RECORD, 2022)</caption>
# IX. Key learnings

A table of the main advantages and drawbacks of the studied technologies is presented below.

<table><thead><tr><td>Recycling process</td><td>Input<sup>235</sup></td><td>Main advantages</td><td>Drawbacks</td></tr></thead><tbody><tr><td>Glycolysis</td><td>PET, PA, PU</td><td><ul><li>Production of high-purity, virgin-like material.</li><li>Suitable for food-grade applications (EFSA, FDA approval needed)</li><li>Solvent limits the environmental impact compared to other solvolysis processes.</li></ul></td><td><ul><li>Mono-material waste streams required (presorting necessary).</li><li>Low level of contaminants required (pretreatment necessary).</li><li>The use of corrosive chemicals in the process might necessitate noble materials for equipment.</li><li>Production of monomers that need to be reintegrated into an existing polymerization value chain.</li></ul></td></tr><tr><td>Methanolysis</td><td>PET</td><td><ul><li>Production of high-purity, virgin-like material</li><li>Suitable for food-grade applications (EFSA, FDA approval needed)</li></ul></td><td><ul><li>Mono-material waste streams required (presorting necessary).</li><li>Low level of contaminants required (pretreatment necessary).</li><li>The use of corrosive chemicals in the process might necessitate noble materials for equipment.</li><li>Production of monomers that either need to be reintegrated into an existing polymerization value chain or to be repolymerized on site by the addition of a dedicated polymerization unit.</li><li>Methanol used in the methanolysis process can have a consequent environmental impact.</li></ul></td></tr><tr><td>Aminolysis</td><td>PET</td><td><ul><li>No high pressure and relatively low temperature range compared to other chemical recycling technologies.</li></ul></td><td><ul><li>Not a very developed process.</li><li>High costs of amines.</li><li>Possible toxicity of amines.</li><li>Production of monomers that need to be reintegrated into an existing polymerization value chain.</li></ul></td></tr></tbody></table>

<footnote n="235">235 Note: The list of resins presented in this table is based on the inputs used by the technology developers which have been analysed within this study. Therefore, this table does not include all the resins that could potentially be processed using a given technology.</footnote>
<table><tr><td>Hydrolysis</td><td>PET, PA</td><td><ul><li>Production of high-purity, virgin-like material</li><li>Suitable for food-grade applications (EFSA, FDA approval needed)</li><li>In the absence of catalyst, the only chemical used is water for neutral and sub/supercritical hydrolysis.</li><li>Unique solvolysis method that leads directly to the production of terephthalic acid (TPA) and ethylene glycol (EG). This route is then the fastest and PET can be directly reconstituted from these species.</li></ul></td><td><ul><li>Mono-material waste streams required (presorting necessary).</li><li>Low level of contaminants required (pretreatment necessary).</li><li>Significant cost to purify PTA</li><li>Strong bases required for alkaline hydrolysis.</li><li>Strong acids required for acid hydrolysis.</li><li>Production of monomers that need to be reintegrated into an existing polymerization value chain.</li></ul></td></tr><tr><td>Hydrolysis catalyzed with enzymes</td><td>PET</td><td><ul><li>Production of high-purity, virgin-like material.</li><li>Suitable for food-grade applications (EFSA, FDA approval needed)</li><li>Less stringent conditions than other chemical recycling processes due to the use of enzymes (atmospheric pressure and low temperature claimed).</li><li>No sophisticated sorting necessary claimed as the enzyme targets PET feedstock only.</li></ul></td><td><ul><li>Mono-material waste streams required from various sources (textiles included).</li><li>Low level of contaminants required (pretreatment necessary).</li><li>Production of monomers that need to be reintegrated into an existing polymerization value chain.</li></ul></td></tr><tr><td>Dissolution</td><td>PS, PP, PVC, PE</td><td><ul><li>Production of high-purity materials</li><li>Can treat contaminated streams and mixed plastics.</li><li>Low alteration of the structure of the polymer.</li><li>Can usually treat plastics containing additives. However, it may be difficult to separate them (for instance phthalates in plasticized PVC).</li><li>Direct production of polymer, no repolymerization needed.</li><li>Lower environmental impacts than depolymerization (if the solvent is recovered).</li></ul></td><td><ul><li>Pre-sorting or pre-treatment are often necessary (e.g., sorting, washing, grinding, etc.).</li><li>Use of solvents to be recycled</li><li>No food grade approval at the moment</li></ul></td></tr><tr><td>Non catalytic and catalytic pyrolysis</td><td>PS, PE, PP, PMMA, Mixed plastics</td><td><ul><li>High-purity, virgin-like recycled resin using pyrolysis oil</li><li>Suitable for food-grade applications.</li><li>Treats relatively mixed waste streams</li><li>Process could be autothermal</li><li>Process seems to be able to remove contaminants and additives.</li></ul></td><td><ul><li>Additional sorting steps necessary to remove non- processable inputs (PVC, PET, PU...)</li><li>For catalytic pyrolysis: potential poisoning effects on the catalyst to be considered</li><li>High energy consumption compared to other recycling processes</li></ul></td></tr></table>
<table><tr><td></td><td></td><td><ul><li>For catalytic pyrolysis: catalyst leads to an increased reactivity of the reaction, lower operating temperatures, better selectivity of the end-products, and reduction of by-products.</li></ul></td><td><ul><li>Numerous downstream steps needed to produce a recycled polymer (purification of the hydrocarbon mix, integration in virgin value chains). PS and PMMA produce monomers that need to be repolymerized.</li><li>Purification of the output necessary before it can be reintegrated in a steam cracker.</li><li>Liquid fraction obtained needs to be mixed with virgin feedstock in a steam cracker (via a mass balance approach).</li><li>Significant losses in each recycling loop.</li><li>No direct link between wastes and recyclates</li></ul></td></tr><tr><td>Hydrothermal cracking</td><td>Mixed plastics</td><td><ul><li>High feedstock flexibility compared to other technologies</li><li>Supercritical water allows to heat the feedstock rapidly and thus avoids excessive cracking</li></ul></td><td><ul><li>Numerous downstream steps needed to produce a recycled polymer (purification of the hydrocarbon mix, integration in virgin value chains).</li><li>Liquid fraction obtained needs to be mixed with virgin feedstock in a steam cracker (via a mass balance approach).</li></ul></td></tr><tr><td>Hydrocracking</td><td>Mixed plastics</td><td><ul><li>Production of high-purity, virgin-like material.</li><li>Suitable for food-grade applications.</li><li>Can treat both monomaterial waste streams and mixed plastics.</li><li>Process removes contaminants and additives.</li><li>Limited formation of coke.</li></ul></td><td><ul><li>Low level of development</li><li>Pre-treatment/pre-sorting may be required due to the high sensitivity to impurities of these processes.</li><li>High investments needed to generate high pressures</li><li>Numerous downstream steps required to produce a recycled polymer (purification of the hydrocarbon mix, integration in virgin materials value chains)</li><li>Significant losses in each recycling loop</li></ul></td></tr><tr><td>Gasification</td><td>Mixed waste</td><td><ul><li>Production of high-purity, virgin-like recycled resin</li><li>Suitable for food-grade applications.</li><li>Can treat all type of polymers and almost all feeds composed of organic materials.</li><li>Can treat mixed and soiled plastics.</li></ul></td><td><ul><li>Pre-sorting required to free the input from metals, fermentable composites, and moisture</li><li>High temperatures needed</li><li>The process releases impurities such as coal, alkali metals and tars, or NH3, H2S, NOx from the syngas.</li></ul></td></tr></table>
<table><caption>Table 19: Advantages and drawbacks of steam cracking (RECORD, 2022)</caption><tr><td></td><td><ul><li>Process removes contaminants and additives.</li><li>Syngas is a valuable intermediate product suitable for different applications.</li></ul></td><td><ul><li>Numerous downstream steps required to produce a recycled polymer (purification of the hydrocarbon mix, integration in virgin value chains).</li><li>Significant losses in each recycling loop.</li></ul></td></tr></table>

<table><caption>Table 20 : Recapitulative table on technologies (RECORD, 2022)</caption><thead><tr><td>Downstream process</td><td>Input</td><td>Main advantages</td><td>Drawbacks</td></tr></thead><tbody><tr><td>Vapocracking (steam cracking)</td><td>Mixed plastics</td><td><ul><li>Production of high-purity, virgin-like material.</li><li>Suitable for food-grade applications.</li><li>Vapocracking step is necessary for the conversion of pyrolysis and gasification output.</li></ul></td><td><ul><li>Valuable fraction from pyrolysis and gasification needs to be mixed with virgin feedstock in a steam cracker (via a mass balance approach)</li></ul></td></tr></tbody></table>

The current output capacities of the studied technology developers (as of January 2022) are presented below as well as the additional capacities announced by the start-up companies by 2025. Please note there may be a high level of uncertainties as the technology developers have announced ambitious capacities in the coming years.

<figure><img src="image_39.png" /><figcaption>Figure 7 : Capacities of chemical depolymerization technologies in 2021 (RECORD, 2022)</figcaption></figure>
<figure><img src="image_40.png" /><figcaption>**Figure 8 :** Additional capacities of chemical depolymerization processes announced by the technology developers by 2025 (RECORD, 2022)</figcaption></figure>

<figure><img src="image_41.png" /><figcaption>**Figure 9 :** Capacities of dissolution technologies in 2021 (RECORD, 2022)</figcaption></figure>
<figure><img src="image_42.png" /><figcaption>Figure 10 : Additional capacities of dissolution processes announced by the technology developers by 2025
(RECORD, 2022)</figcaption></figure>

<figure><img src="image_43.png" /><figcaption>Figure 11 : Capacities of thermal treatment technologies in 2021 (RECORD, 2022)</figcaption></figure>
<figure><img src="image_44.png" /><figcaption>Figure 12: Additional capacities of thermal treatment processes announced by the technology developers by 2025 (RECORD, 2022)</figcaption></figure>

The total current and estimated future output capacities (2021 vs. 2025) of the studied technology developers (as of January 2022) are presented below.

<figure><img src="image_45.png" /><figcaption>Figure 13: Total capacities in 2021 vs. 2025 (RECORD, 2022)</figcaption></figure>
<figure><img src="image_46.png" /><figcaption>Figure 14: Solvolysis PET and PA capacities in 2021 vs. 2025 (RECORD, 2022)</figcaption></figure>

<figure><img src="image_47.png" /><figcaption>Figure 15: Dissolution capacities in 2021 vs. 2025 (RECORD, 2022)</figcaption></figure>

<figure><img src="image_48.png" /><figcaption>Figure 16: Thermal Treatment PS, PMMA, Mixed Plastics capacities in 2021 vs. 2025 (RECORD, 2022)</figcaption></figure>
# X. Focus on regulations and certifications

This section focuses on the definition of the mass balance approach as well as on the following regulatory aspects in Europe, the United States and Japan:

* Main regulatory and fiscal situations applicable to recycling plants

* Opportunity to use recycled resins for food-contact applications after approval by competent authorities

* Acceptability of the implementation of a mass balance approach

* Departure from the status of waste

* Qualification of a recycled state

Please note that within the following section the generic term “chemical and physico-chemical recycling” was used whenever it was not clear if the regulation discussed also applied to dissolution technologies.

## 1) Introduction to the mass balance approach

As manufacturers take their first steps towards producing bio-based drop-in chemicals or chemically recycled materials, there will often be the need to use existing facilities, which currently process petroleum derived/fossil materials, somewhere in the supply chain. Since there is generally a significant gap between the capacity of existing industrial assets and the initial volumes of bio-based materials/recycled material, batch conversion of 100% bio-based/chemically recycled materials is technically and economically challenging, if possible, at all in some situations. This will lead to the “dilution” of the recycled (or bio-based) material with fossil material.

The term “Mass-balance” refers to a type of chain of custody model. Chain of custody models are methods used to transfer, follow, and control information about materials that are entering and those that are leaving a system. The main types of chain of custody models used are: Identity preservation, Segregation, Mass balance, Controlled blending, and Book & claim (26, 27). The ISEAL Alliance states that “In the mass balance model the volume of certified product entering the operation is controlled and an equivalent volume of product leaving the operations can be sold as certified. The physical mixing of certified and non-certified product is allowed, but not required (i.e., does not define the model to have physical blending) at any stage in the production process provided that the quantities are controlled in documentation”<fnref n="236" />.

The mass balance approach can be used in the absence of a physical traceability system whenever certain products/materials with defined characteristics are mixed with other materials that do not possess those same features (26). Using an auditable bookkeeping system, the mass balance approach determines how the products/materials of interest are allocated within the output that is produced (27). While already used in sectors such as furniture or textiles, the application of the mass balance approach to the plastic recycling industry is still new and, therefore, under investigation. Several organizations (including Plastics Europe – 2020, and the Ellen MacArthur Foundation – 2019) have already published position papers and recommendations on the use of the mass balance approach in the plastics industry. The following paragraphs focus on the most recent report that was found on this topic. The document was published by the ADEME in 2021 under the title “Approche « Mass balance » et recyclage chimique des plastiques” (Mass balance approach and chemical recycling of plastics).

It is relevant to specify that the ADEME makes a clear distinction between two types of mass balance.

* Rolling average: Materials with specific characteristics are mixed with other materials. The quantity of a given input material is not constant within the products produced, however, content can be allocated in the form of an average.

<footnote n="236">²³⁶ ISEAL Chain of Custody Models Guidance September 2016.pdf (isealalliance.org)</footnote>
* Credit method: Materials with specific characteristics are mixed with other materials. The content of a given material is allocated freely to the different products produced (independently from the actual physical characteristics of those final products).

The report published by the ADEME focuses mainly on the application of the mass balance approach to pyrolysis and vapocracking. As discussed on the report, the quantity of pyrolysis oils that are produced today are not sufficient for them to be the only material entering a vapocracker. Pyrolysis oils derived from recycled plastics constitute therefore a very limited portion of a vapocracker's input when compared with conventional naphtha. Hence, plastic producers are driven towards the use of the mass balance approach.

While the ISO certification 22095:2020 (Chain of custody — General terminology and models) provides some general guidelines on mass balance, there is yet no internationally recognized standard specifying which conditions are to be respected to use this approach. In the absence of such norm, private certification schemes have been created, to certify a product developed under a mass balance approach (e.g., ISCC, RED Cert GmbH, UL, etc.). In this context, one of the main issues point out by the ADEME is the fact that each of individual certification system establishes its own mass balance set of requirements. The analysis of such systems has identified three topics that may become a subject of discussion if an official ISO norm will be created (26):

1) "The understanding of the input/output balances of steam crackers and the possible issues of coherence between the technical data and, in particular, the concrete methods of calculating the conversion factors".

2) "Regulatory texts, especially the new European rules on calculating recycling rates".

3) "The points of view expressed by various stakeholders on the implementation of a mass balance model".

All these subjects are discussed in detail within the ADEME's report. Overall, this document provides a complete overview of the multiple challenges associated with the use of the mass balance approach when using pyrolysis oils. Upcoming regulations and standards on mass balance will inevitably have a direct impact on chemical recyclers. Further updates on this subject are expected in the years to come.

## 2) Regulation in the United States

Note: regulation in the United States sometimes uses the term “advanced recycling” to refer to chemical recycling technologies. Within these paragraphs, the two terms have been used interchangeably.

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

In the United states, plants are subjected to environmental regulations on air, water, and land use. Indeed, the United States Environmental Protection Agency (EPA) counts several laws that every waste management facility must comply with. The main regulation is the Resource Conservation and Recovery Act (RCRA), aiming at managing the hazards of waste disposal<fnref n="237" />; conserving energy and natural resources by recycling and recovery; reducing or eliminating waste; and cleaning up waste that which may have spilled, leaked, or been improperly disposed of. Recycling facilities usually falls under the category of solid waste management facilities. As of January 2022, there are no federal laws that specifically refer to chemical recycling. In 2021, the EPA issued an Advanced Notice of Proposed Rulemaking to regulate pyrolysis and gasification on USA territory. Indeed, the EPA has been working on the collection of informative material on pyrolysis and gasification to establish whether there is the need to enhance the regulation of these technologies. The questionnaire aims to collect data such as construction date, startup date, air emissions, pollution control equipment and project design. The results of this assessment will determine if and how the EPA will decide to enhance regulation on

<footnote n="237">²³⁷ https://www.epa.gov/regulatory-information-topic/regulatory-and-guidance-information-topic-waste
Study RECORD n°21-0919/1A</footnote>
chemical<sup>238</sup>. One possible scenario is to make pyrolysis and gasification facilities subject to article 129 of Clean Air Act (this act is currently regulating waste incineration units). On a state-level, approximately 14 states (Louisiana, Arkansas, Florida, Wisconsin, Georgia, Iowa, Tennessee, Texas, Illinois, Ohio, Pennsylvania, Virginia, Oklahoma, and Arizona) have already exempted advanced (chemical) recycling facilities from general solid waste and recycling laws<sup>239</sup>.

Some states are defining more granularly recycling plants regulations (these states are represented on the Figure 17 below). Indeed, in the last years, a dozen of American states has passed bills to expand recycling infrastructure and support chemical recycling facilities. Among these states, Oklahoma's SB 448<sup>240</sup>, passed on April 19<sup>th</sup>, 2021, defines regulatory aspects with which a chemical recycling plant must comply:

"Advanced plastic recycling facility" means a manufacturing facility that receives, stores, and converts post-use polymers and recovered feedstocks it receives using advanced recycling<sup>241</sup>. An advanced recycling facility shall be subject to applicable Department of Environmental Quality regulations for air, water, waste, and land use. Advanced recycling facilities shall not be considered disposal sites, solid waste management systems, transfer stations as defined in this section or incineration. Advanced recycling facilities shall be subject to inspections by the Department to ensure compliance with applicable laws and regulations. If an advanced recycling facility does not comply with the requirements of this definition it shall not be considered an advanced recycling facility and is subject to all applicable solid waste laws and regulations as determined by the Department"

Arizona has passed a similar bill (SB 1156<sup>242</sup>) in March 2021, subjecting recycling facilities to the same regulations. It has additionally created a recycling fund:

"A recycling fund is established to be administered by the director. The fund consists of monies appropriated by the legislature, gifts, grants, donations, and monies derived from the landfill disposal fees in section 49-836. Monies derived from landfill disposal fees are subject to legislative appropriation. Monies in the fund are exempt from lapsing under section 35-190. On notice from the director, the state treasurer shall invest and divest monies in the fund as provided by section 35-313, and monies earned from investment shall be credited to the fund. B. Monies from the recycling fund shall be used for the following purposes:

1. Grants to or contracts with political subdivisions, nonprofit organizations or private enterprise for research, demonstration projects, NEW TECHNOLOGIES, market development and source reduction studies and implementation of the recommendations or reports prepared pursuant to this article.

2. Public information, public education and technical assistance programs concerning litter control, recycling, and source reduction.

3. The collection and administration of monies in the fund.

4. The administration of this article.

5. The administration of the Arizona commerce authority's recycled market development program.

<footnote n="238"><sup>238</sup> https://www.reuters.com/business/environment/us-epa-weighs-regulation-chemical-recycling-2021-09-22/</footnote>

<footnote n="239"><sup>239</sup> https://www.americanchemistry.com/chemistry-in-america/news-trends/press-release/2021/louisiana-becomes-14th-state-to-support-reduction-of-plastic-waste-through-advanced-recycling</footnote>

<footnote n="240"><sup>240</sup> http://webserver1.lsb.state.ok.us/cf_pdf/2021-22%20FLOOR%20AMENDMENTS/Senate/SB448%20(3-09-21)%20(TAYLOR)%20FS%20FA1.PDF</footnote>

<footnote n="241"><sup>241</sup> According to the bill, ""Advanced plastic recycling"" means a manufacturing process for the conversion of post-use polymers and recovered feedstocks into basic hydrocarbon raw materials, feedstocks, chemicals, liquid Req. No. 1970 Page 2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 fuels and other products like waxes and lubricants through processes that include pyrolysis, gasification, depolymerization, catalytic cracking, reforming, hydrogenation, solvolysis and other similar technologies. The recycled products produced at advanced recycling facilities include, but are not limited to, monomers, oligomers, plastics, plastics and chemical feedstocks, basic and unfinished chemicals, crude oil, naphtha, liquid transportation fuels, waxes, lubricants, coatings and other basic hydrocarbons."</footnote>

<footnote n="242"><sup>242</sup> https://legiscan.com/AZ/text/SB1156/id/2331769/Arizona-2021-SB1156-Engrossed.html</footnote>
At the end of each fiscal year, any funds not spent by the authority for this purpose shall be returned to the fund. "

Other states are lightening the regulations to which chemical plants are subjected. For instance, in Ohio, the HB166 regulation, passed in July 2019, is excluding pyrolysis and gasification facilities from solid waste facility regulations. Indeed, it is stating that "Disposal" does not include the process of converting post-use polymers and recoverable feedstocks using gasification or pyrolysis."

Indeed, in these states, pyrolysis and gasification facilities are reclassified as manufacturing facilities and thus subjected to the state's air, water, and waste regulations applicable to manufacturing facilities, which are usually weaker than solid waste facility regulations.

Similarly, Louisiana has passed its SB97²⁴³ bill in June 2021 that excludes advanced recycling facilities from the categories "resource recovery and management facility" and "Solid waste disposal facility": "Advanced recycling shall not be considered solid waste disposal, processing, incineration, combustion, or storage."

In other states, certain types of manufacturing or alternative fuel production facilities may qualify for current or future renewable energy credits<fnref n="244" /> <fnref n="245" />.

<figure><img src="image_49.png" /><figcaption>Figure 17: States exempting pyrolysis and gasification facilities from being regulated as solid waste facilities (update of Gaia map110)</figcaption></figure>

<footnote n="243">²⁴³ https://legiscan.com/LA/text/SB97/id/2421666/Louisiana-2021-SB97-Chaptered.pdf</footnote>

<footnote n="244">²⁴⁴ According to the Environmental Protection Agency (EPA), "A renewable energy certificate, or REC, is a market-based instrument that represents the property rights to the environmental, social and other non-power attributes of renewable electricity generation. RECs are issued when one megawatt-hour (MWh) of electricity is generated and delivered to the electricity grid from a renewable energy resource".
Source: Renewable Energy Certificates (RECs) | Green Power Partnership | US EPA</footnote>

<footnote n="245">²⁴⁵ https://www.no-burn.org/wp-content/uploads/US-ACC-State-Legislation-Alert_updated-July-2020.pdf.pdf</footnote>
On the other hand, Maryland has tried to pass its HB 21<sup>246</sup> bill in January 2021 that forbids the building of a chemical recycling facility in the State. The ban however died in committee. The definition of chemical facilities in this bill is a facility "that converts plastic to fuel or feedstock through those [...] chemical conversion processes" (which are: pyrolysis, hydro pyrolysis, methanolysis, gasification, enzymatic breakdown, or a similar process). It has to be noted that, the state of Maryland has also redefined the term "recycling" to exclude "pyrolysis, hydro pyrolysis, methanolysis, gasification, enzymatic breakdown, or a similar process"<sup>247</sup>.

As for fiscal situations, the United States does not discriminate chemical recycling plants from other recycling plants.

### b. Opportunity to use recycled resins for food-contact applications after approval by competent authorities

When used for food-contact applications, recycling materials must comply with the requirements of Chapter 21 of the Code of Federal Regulations, which is reserved for rules of the Food and Drug Administration (FDA).

Indeed, the FDA has set requirements on recycled plastics such as maximum acceptable level(s) of residual contaminants in the recycled material that are represented in the table below:

<table><caption>Table 21: acceptable level of residual contaminant by polymer type<sup>248</sup></caption><thead><tr><td>Recycled Polymer</td><td>Density, g/cm³</td><td>Maximum residual contaminants to maintain an estimated daily intake of consumer inferior to 1,5 microgram/person</td></tr></thead><tbody><tr><td>PET</td><td>1.4</td><td>220 µg/kg</td></tr><tr><td>Polystyrene</td><td>1.05</td><td>300 µg/kg</td></tr><tr><td>PVC</td><td>1.58</td><td>200 µg/kg</td></tr><tr><td>Polyolefins</td><td>0.965</td><td>320 µg/kg</td></tr></tbody></table>

In the case of the use of a non-food container as a feedstock for the recycled resin, to be used in a food-contact application, this resin should respect current adjuvants and contaminants levels set by the FDA. The recycled resin should also comply with FDA's regulations regarding barriers to stop contaminants migration into food. The recycler should thus conduct additional migration test.

Recycled plastics that are approved by the FDA receive a Letter of No Objection specifying that the material has been deemed as suitable for food-contact applications<sup>249</sup>.

FDA issued a favorable opinion 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

<footnote n="246"><sup>246</sup> https://trackbill.com/bill/maryland-house-bill-21-environment-recycling-prohibition-on-the-chemical-conversion-of-plastic/1957979/</footnote>

<footnote n="247"><sup>247</sup> Bill HB21: https://trackbill.com/bill/maryland-house-bill-21-environment-recycling-prohibition-on-the-chemical-conversion-of-plastic/1957979/</footnote>

<footnote n="248"><sup>248</sup> https://www.fda.gov/regulatory-information/search-fda-guidance-documents/guidance-industry-use-recycled-plastics-food-packaging-chemistry-considerations</footnote>

<footnote n="249"><sup>249</sup> https://resource-recycling.com/plastics/wp-content/uploads/sites/4/2019/10/PNC-2372.FNL_signed-1.pdf</footnote>
companies, which are listed below. Only PET and PEN (Poly(oxy-1,2-ethanediyloxycarbonyl-2,6-naphthalenediylcarbonyl)) resin have been approved for now<fnref n="250" />.

<table><caption>Table 22 : Recycled materials non objected by the FDA for food-contact applications</caption><thead><tr><th>Company</th><th>Polymer</th><th>Recycling type</th></tr></thead><tbody><tr><td>Hoechst Celanese</td><td>PET</td><td>Chemical - Regenerated dimethyl terephthalate from depolymerized PET bottles</td></tr><tr><td>Eastman Chemical Co.</td><td>PET</td><td>Chemical - Regenerated ethylene glycol and dimethyl terephthalate from depolymerized PET bottles</td></tr><tr><td>Far Eastern New Century Corporation APG Polytech LLC Corpus Christi Polymers, LLC</td><td>PET</td><td>Chemical - PET oligomers from depolymerized PET bottles</td></tr><tr><td>DuPont Co.</td><td>PET</td><td>Chemical - Regenerated ethylene glycol and dimethyl terephthalate from depolymerized post-consumer PET.</td></tr><tr><td>Hoechst Celanese</td><td>PET</td><td>Chemical (glycolysis)</td></tr><tr><td>Wellman, Inc.</td><td>PET</td><td>Chemical (glycolysis)</td></tr><tr><td>Innovations in PET Pty Ltd.</td><td>PET</td><td>Chemical (glycolysis)</td></tr><tr><td>Eastman Chemical Co.</td><td>PEN</td><td>Chemical - Regenerated dimethylnaphthalene dicarboxylate and ethylene glycol from depolymerized PCR poly(oxy-1,2-ethanediyloxycarbonyl-2,6-naphthalenediylcarbonyl (PEN) resins using a methanolysis process.</td></tr><tr><td>Eastman Chemical Co.</td><td>PET</td><td>Chemical (glycolysis)</td></tr><tr><td>Eastman Chemical Co.</td><td>PET</td><td>Chemical (glycolysis/methanolysis)</td></tr><tr><td>JEPLAN, INC</td><td>PET</td><td>Chemical (glycolysis)</td></tr><tr><td>NanYa Plastics Corp.</td><td>PET</td><td>Chemical (glycolysis)</td></tr><tr><td>Teijin Limited</td><td>PET</td><td>Chemical (methanolysis)</td></tr><tr><td>Mitsubishi</td><td>PET</td><td>Chemical (methanolysis)</td></tr><tr><td>Futura Polymers</td><td>PET</td><td>Chemical (glycolysis)</td></tr><tr><td>Roychem</td><td>PET</td><td>Chemical (glycolysis)</td></tr><tr><td>Eastman Chemical Co.</td><td>PET</td><td>Chemical (glycolysis)</td></tr><tr><td>Selenis Canada, Inc.</td><td>PET</td><td>Chemical (glycolysis)</td></tr><tr><td>DAK Americas LLC</td><td>PET</td><td>Chemical (glycolysis)</td></tr><tr><td>Indorama Ventures</td><td>PET</td><td>Chemical (glycolysis)</td></tr><tr><td>M&G Polímeros México</td><td>PET</td><td>Chemical (glycolysis)</td></tr><tr><td>Loop Industries Inc.</td><td>PET</td><td>Chemical (process not specified)</td></tr><tr><td>OCTAL SAOC FZC</td><td>PET</td><td>Chemical (process not specified)</td></tr></tbody></table>

<footnote n="250">²⁵⁰https://www.cfsanappsexternal.fda.gov/scripts/fdcc/index.cfm?set=RecycledPlastics&sort=RecycleNumber&order=DESC&startrow=1&type=column&search=Recycling%20Process%C2%A4VARCHAR%C2%A4chemical</footnote>
As for the use of recycled content in cosmetics applications, there is no legal regulations in the USA for now, as complementary safety assessments of products are not mandatory and only considered as a best practice<fnref n="251" />.

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

Several states in the US are nowadays considering implementing recycled contents requirements. California was the first state to constrain the integration of recycled plastics in beverage bottles through its bill AB-793, which passed on August 2020. The bill sets a recycled plastic target of 50% postconsumer recycled plastic per year by 2030 and defines these targets on the percentage of recycled plastic content on the total plastic bottles sold in the state<fnref n="252" />.

Washington's bill SB 5022, passed on April 2021, has a similar definition of the recycled content to be integrated into bottles, in the aim of reaching a 50% postconsumer recycled content plastic by weight by 2031:

> "A producer of a beverage in a plastic beverage container must meet the following annual minimum postconsumer recycled content percentage on average for the total quantity of plastic beverage containers, by weight, that are sold, offered for sale, or distributed in or into Washington by the producer"<fnref n="253" />

The state has introduced an additional bill in January 2021, SB 5219²⁵⁴, to implement targets on plastic packaging as well. These targets have been defined on the same indicator, which is the minimum postconsumer recycled content on average for the total amount of plastic packaging sold, offered for sale, or distributed.

Oregon's HB 2065, which was introduced in February 2021, is more explicit in its definition of the recycled content to be taken into account in reaching these targets. It clearly states that the recycled content is measured compared to a packaging total weight. The mass balance approach seems thus non accepted:

> ""Recycled content" means the portion of a package's total weight that is composed of recycled material, as determined by a material balance approach that calculates total recycled material in the package as a percentage of the total weight of the package<fnref n="255" />."

In conclusion, several states are requiring a certain amount of recycled plastic content to be integrated into products sold, offered for sale, or distributed. There is however no mention if a mass balance approach would be accepted.

### d. Departure from the status of waste

In order to reclassify the pyrolysis and gasification facilities as manufacturing facilities, the 17 states evoked in the first part of this chapter (see X.2)a above) have reclassified post-consumer plastic. Indeed, their status has been reclassified into "non-solid waste" (in Massachusetts<fnref n="256" /> for instance in an introduced bill), "recovered materials" (in Virginia<fnref n="257" /> in an introduced bill) or "raw materials for manufacturing"<fnref n="258" />.

In Illinois, the very definition of "waste" was modified in the bill HB2941, passed on May 16, 2021, to exclude post-use polymers or non-recycled feedstocks processed through pyrolysis or gasification<fnref n="259" />.

<footnote n="251">²⁵¹ http://www.foodlaw.rdg.ac.uk/pdf/2020-FDF-Recycled-Plastics-Guidance.pdf</footnote>

<footnote n="252">²⁵² https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=201920200AB793</footnote>

<footnote n="253">²⁵³ http://lawfilesext.leg.wa.gov/biennium/2021-22/Pdf/Bills/Senate%20Passed%20Legislature/5022-S2.PL.pdf?q=20210625023553</footnote>

<footnote n="254">²⁵⁴ http://lawfilesext.leg.wa.gov/biennium/2021-22/Pdf/Bills/Senate%20Bills/5219.pdf?q=20210625021636</footnote>

<footnote n="255">²⁵⁵ https://www.njleg.state.nj.us/2020/Bills/S3000/2515_I1.HTM</footnote>

<footnote n="256">²⁵⁶ https://legiscan.com/MA/text/H829/2019</footnote>

<footnote n="257">²⁵⁷ http://lis.virginia.gov/cgi-bin/legp604.exe?201+sum+SB591</footnote>

<footnote n="258">²⁵⁸ http://www.legis.ga.gov/legislation/en-US/Display/20172018/HB/785</footnote>

<footnote n="259">²⁵⁹ http://www.ilga.gov/legislation/BillStatus.asp?DocNum=2491&GAID=15&DocTypeID=HB&LegID=118521&SessionID=108&GA=101&SpecSess=0#actions</footnote>
The same phenomenon occurred in Wisconsin<fnref n="260" /> and Pennsylvania<fnref n="261" /> (the bill has been introduced), where “post-use plastics” were excluded from the solid waste or municipal waste category if processed in pyrolysis or gasification facilities.

For instance, the state of Oklahoma in its SB448 bill, passed on April 19th, 2021, redefines post-consumer plastics as follows:

"Post-use polymer shall not be considered solid waste as defined in this section, unless the post-use polymer is improperly managed, abandoned or disposed of"<fnref n="262" />.

No specific information has been found on the departure from the status of waste.

### e. Qualification of a recycled state

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

The association of plastic recyclers (APR), an international trade association, has implemented a post-consumer (PCR) resin certification program to certify PCR pellet or flake.

The certification guarantees that the product certified complies with APR's definition of PCR, aligning with the ISO 14021:2016 definition: "Postconsumer Recycled Content means material generated by households or by commercial, industrial and institutional facilities in their role as end-users of the product which has been used for its intended use or can no longer be used for its intended purpose. This includes return of material from the distribution chain"<fnref n="263" />.

The certification ensures, via a material balance analysis, that the recycled content claims are accurate and evaluate the source of the recycled material to determine the final percentage (by weight) of PCR in the product<fnref n="264" />.

This certification does not seem to require producing PCR in the United-States, as some companies listed on their website are located in Canada, Malaysia, or Mexico.

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

The EPA (Environmental Protection Agency) is currently exploring the definition of recycling and consulting on whether to include certain streams. This definition is used to afterwards calculate the national recycling rates.

The consultation covers five aspects: Sources of Recyclable Material, Material Streams, Material Management Pathways, Material Destination and Other Considerations. In the material management category, the agency wonders if pyrolysis should be included and if so, what products should it include (purified polymers, chemicals, fuels...)<fnref n="265" />. 108 comments were made from recycling industry stakeholders and opinions are diverging.

Indeed, the American Chemistry Council (ACC) stated that "advanced recycling processes that produce feedstock for new plastic, chemical products, waxes, and lubricants should count as 'recycling,' but feedstocks used for fuels should be classified 'advanced recovery.'"<fnref n="266" />

As for Brightmark (a global waste solutions company), pyrolysis processes should be defined as recycling: "All products should be considered as recycling in recycling rate calculations including fuels, fuel blend stocks and waxes"<fnref n="267" />.

Gaia, an alliance of groups, NGOs, and individuals, has emitted a strong opinion of not including any chemical recycling technology in the definition of a recycled product:

<footnote n="260">²⁶⁰ http://docs.legis.wisconsin.gov/2017/proposals/reg/asm/bill/ab789</footnote>

<footnote n="261">²⁶¹ https://legiscan.com/PA/bill/HB1808/2019</footnote>

<footnote n="262">²⁶² http://webserver1.lsb.state.ok.us/cf_pdf/2021-22%20FLOOR%20AMENDMENTS/Senate/SB448%20(3-09-21)%20(TAYLOR)%20FS%20FA1.PDF</footnote>

<footnote n="263">²⁶³ ISO 14021:2016 Section 7.8.1.1</footnote>

<footnote n="264">²⁶⁴ https://plasticsrecycling.org/images/PCR_Certification/APR-Endorsed-PCR-Certifier-Application.pdf</footnote>

<footnote n="265">²⁶⁵ https://www.epa.gov/americarecycles/national-recycling-goal-recycling-rate-measurement-comment-period#comments</footnote>

<footnote n="266">²⁶⁶ https://www.regulations.gov/comment/EPA-HQ-OLEM-2020-0443-0101</footnote>

<footnote n="267">²⁶⁷ https://www.regulations.gov/comment/EPA-HQ-OLEM-2020-0443-0133</footnote>
"Among the material management pathways which could potentially be considered as recycling in recycling rate calculations, EPA lists various forms of incineration, including pyrolysis, solvolysis, depolymerization, gasification, and combustion with energy recovery; all of which not only fall short of tackling the waste crisis at the source but also have negative environmental, climate, and financial impacts. Burning things is not recycling them at all, regardless of what technology is used and whether it generates energy or a byproduct. EPA must in no way count these methods toward national recycling goals"<fnref n="268" />.

No final decision has been made public yet, but the limit date for submitting comments has been reached on March 8, 2021.

It has to be noted that, the state of Maryland has redefined the term "recycling" to exclude "pyrolysis, hydro pyrolysis, methanolysis, gasification, enzymatic breakdown, or a similar process"<fnref n="269" />

### 3) Regulation in the European Union

Note: The term "chemical depolymerization" within European regulation refers to technologies that break down plastics into monomers and other starting substances. It is however not specified which specific types of chemical recycling technologies this term refers to<fnref n="270" />.

The following sections briefly discuss some of the regulations and standards in the field of recycling that are most relevant for the purpose of this report. Many more directives that have not been mentioned exist in relation to subjects such as plastics, recycling, waste management, and materials' production processes.

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

In the European Union, recycling plants are subjected to laws and taxations that traditionally apply to the general category of producers/manufacturers as well as those of waste management companies. 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. Relevant regulations include:

* the Waste Framework Directive 2008/98/EC

* the European List of Waste (Commission Decisions: 2000/532/EC, 2014/955/EU)

* the Waste Shipment Regulation (EC) (No. 1013/2006)

* the POP Regulation (EC) (No. 850/2004)

* the Seveso III Directive (2012/18/EU)

The Waste Framework Directive 2008/98/EC is one of the most relevant regulations for recyclers. This law defines recycling as "any recovery operation by which waste materials are reprocessed into products, materials or substances whether for the original or other purposes". It is relevant to specify that the EU's definition excludes any type of waste processing that is used for the purpose of energy recovery, plastic-to-fuel applications, and backfilling<fnref n="271" /> (28). 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.

The latest update on the subject dates 2021, when the European Chemicals Agency published a study focused on the investigation of the chemical and physico-chemical recycling of plastic waste. Within the report, the agency recognizes the need for further clarity on chemical and physico-chemical recycling's

<footnote n="268">²⁶⁸ https://www.regulations.gov/comment/EPA-HQ-OLEM-2020-0443-0142</footnote>

<footnote n="269">²⁶⁹ Bill HB21: https://trackbill.com/bill/maryland-house-bill-21-environment-recycling-prohibition-on-the-chemical-conversion-of-plastic/1957979/</footnote>

<footnote n="270">²⁷⁰ https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32008R0282&from=EN</footnote>

<footnote n="271">²⁷¹ EU definition: "'backfilling' means any recovery operation where suitable non-hazardous waste is used for purposes of reclamation in excavated areas or for engineering purposes in landscaping." (28)
Study RECORD n°21-0919/1A</footnote>
terminology and for the harmonization of EU directives on plastics' recycling. Several actors operating in the sector (such as Chemical Recycling Europe) have indeed been arguing that the delay in the adjustment of regulations constitutes a hindrance for technology developers. Yet, according to the ECHA, generalizations on chemical and physico-chemical recycling should be avoided. New regulatory measures should be developed on a case-to-case basis depending on the technology in question. As an example, regulation should consider that chemolysis<fnref n="272" /> seems to be a more circular solution than pyrolysis and gasification. Chemolysis produces in fact virgin monomers with no evidence on the presence of by-products, while pyrolysis and gasification produce by-products and non-reusable residues (making it an open-loop process).

Some of the stakeholders of the industry (e.g., NGOs and organizations such as Rethink Plastic and Plastic Recyclers Europe), advocate that chemical recycling processes are a form of recovery rather than actual recycling. The Joint Research Center (JRC) is still investigating whether all these processes technologies should be included or excluded from the current definition of recycling.

Zero Waste Europe advanced the proposal to categorize them as following:

* **Thermal recovery:** plastic to fuel solutions.

* **Material recovery:** polymer to molecule solutions (pyrolysis and gasification).

* **Chemical recycling:** polymer to monomer/oligomer solutions (depolymerization, solvolysis, chemolysis)<fnref n="273" />.

Zero Waste Europe also suggested that, following the phase of technology categorization, the European Waste Hierarchy should be reviewed. According to their recommendations, mechanical recycling and dissolution should be preferred over depolymerization, which should likewise be favored to pyrolysis and gasification. In their opinion, pyrolysis and gasification are to be considered as recovery due to their low material recovery rates, high energy requirements, high CO₂ emissions, and consequent lower circularity. These technologies should therefore be ranked lower than recycling.

According to the ECHA report, being also classified as manufacturers/producers, chemical recyclers also have to comply with the following regulations:

* Regulation 1907/2006 on the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH).

* The Regulation on classification, labelling and packaging (CLP Regulation).

* The consolidated version of the Regulation (EU) No 2019/1021 on persistent organic pollutants (POPs Regulation).

Although legislations that are specific to chemical and physico-chemical recycling are still being drafted on a European level, some technology developers<fnref n="274" /> have already been selling their output in compliance with REACH (29).

Chemical Recycling Europe (CRE) promotes the vision by which chemical and physico-chemical recycling could significantly contribute to the achievement of the carbon-neutrality targets set by the EU Green Deal (2019) and to the attainment of the ambitious recycling rates set through the Packaging and Packaging Waste Directive (Directive 94/62/EC - objective to recycle 50% of plastic packaging by weight by 2025, and 55% by 2030). Hence, the organization strongly supports the idea that regulation should be harmonized among the Member States, and that the Waste Framework Directive and the REACH regulation should be aligned (30). They additionally share the perspective of Zero Waste Europe that recycling should be better promoted as an alternative to waste shipment to non-EU countries, that plastic

<footnote n="272">²⁷² The ECHA refers to chemolysis as a synonym of solvolysis/chemical depolymerization. It is defined as a process that treats plastic waste using solvents and reagents (or catalysts) to depolymerize the polymer into low molecular weight chemicals and oligomers.</footnote>

<footnote n="273">²⁷³ There is no definition of chemolysis, depolymerization and solvolysis in ZWE document.</footnote>

<footnote n="274">²⁷⁴ Information published by CRE. The source does not specify which technology developers it refers to.
Study RECORD n°21-0919/1A</footnote>
products should be designed by reference to the EU Waste Hierarchy, that Extended Producer Responsibility (EPR) should be "expanded to other groups beyond packaging and WEEE"<fnref n="275" /> (31).

While sharing a common perspective on several topics, Chemical Recycling Europe and Zero Waste Europe have contrasting views on a variety of other subjects. In particular, Zero Waste Europe believes that new regulations should be created to prevent chemical recycling from hindering the development of more circular solutions in the waste hierarchy (prevention, minimization, reuse). To do so, they suggest restricting plastic inputs for chemical recycling to contaminated and degraded plastics, to prevent plastics from separate collection to be chemically recycled, and to ensure that the outputs of these technologies will be limited to plastic-to-plastic applications (32). In July 2020, Rethink Plastic (Zero Waste Europe among the members) published a report suggesting seven steps to effectively legislate chemical recycling. The document recommended the following actions (33):

1. Define the term "chemical recycling" within the Waste Framework Directive so that it will formally exclude all types of plastic-to-fuel applications.

2. Define the legal status of chemical recycling, clarifying its position on the Waste Hierarchy.

3. Prevent chemical recycling from becoming a solution for single-use plastics or plastics that are collected to be mechanically recycled by limiting input to degraded and contaminated plastics.

4. Assess the environmental and health impact of chemical recycling on an industrial level.

5. Determine a methodology to exhaustively calculate both direct and indirect emissions of chemical recycling technologies.

6. Develop a standard that will be used to determine the amount of recycled content of materials obtained via chemical recycling.

7. Ensure that EU funds will only be attributed to develop processes with a lower environmental impact than the production of virgin feedstocks.

Chemical Recycling Europe strongly disagrees with some of these viewpoints. The organization advocates that chemical recycling is by definition a circular solution. Its input should therefore not be restricted to degraded and contaminated plastics but should include all plastics for which mechanical recycling is too complex or not economically viable. Furthermore, they suggest that plastics from separate collection should be eligible for chemical recycling to valorize all waste that is not suitable for mechanical recycling (thus preventing it from being incinerated), and that plastic-to-fuel solutions should not be restrained as they present a better alternative than the extraction of new primary materials (31).

It seems however that none of the stakeholders weigh chemical recycling against energy recovery. A more precise regulation seems to be expected.

From a financial perspective, rules that apply to recyclers are the same as traditional manufacturers. This includes environmental taxes that are either set by the European Union or by different Member States. Energy, transport, pollution, and resources are the aspects which are most frequently subject to environmental taxation. No specific environmental taxes were found for chemical recyclers (34). It should additionally be highlighted that, as of today, chemical recyclers do not seem to receive incentives through Extended Producer Responsibility (EPR) schemes as their technology is still under development.

### b. Opportunity to use recycled resins for food-contact applications after approval by competent authorities

In the European Union, recycled plastics that are to be used for food-contact applications must comply with the requirements set by Regulation No 282/2008. This regulation is currently under review. A new draft of regulation 282/2008 has been circulated by EU in December 2021 for consultation<fnref n="276" />. EU is

<footnote n="275">²⁷⁵ As of today, all EU Member States are required by law to have EPR schemes in place for the WEEE, Batteries, ELV, and packaging sectors. Certain States have put in place additional EPR schemes for tyres, waste oil, paper and card, construction and demolition waste, etc.</footnote>

<footnote n="276">²⁷⁶ https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12013-Food-safety-recycled-plastic-in-food-packaging-updated-rules-en</footnote>
aiming at publishing the new version of Regulation 282/2008 by summer 2022. Inclusion of chemical and physico-chemical recycling in the future new draft is still unclear. This could delay the development of chemical and physico-chemical recycling technologies. However, Article 1 of the regulation points out that this law only applies to mechanical recycling processes. Forms of chemical recycling which lead to the depolymerization of plastics into monomers and other starting substances (referred to as chemical depolymerization), are to be excluded from the scope of this legislation. Monomers and oligomers resulting from chemical depolymerization are instead 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 (35). The latest information available concerning the adaptation of Regulation No 282/2008 to plastics other than mechanically recycled PET was found in a document released by the British Plastics Association (BPA) in April 2020. As stated in the report "steps for establishing evaluation criteria where these do not currently exist would be drawn up and an Annex setting out material specific rules would be included. This is expected to be discussed and further developed during 2020 and 2021" (35). So far, no further updates have been found on this topic and no commercialized outputs have yet received the food grade approval. Based on the available information, it seems that chemical and thermal depolymerization will be more likely than dissolution (referred to by Eunomia as solvent purification) to obtain the food grade for their outputs (16).

In accordance with Article 13 of Regulation No 282/2008, mechanical recycling technology developers are to submit their request for approval to the European Food Safety Authority (EFSA) in compliance with the respective EFSA Guidelines (latest version published in March 2021)<fnref n="277" />. As of today, such guidelines have not been adapted to chemical and physico-chemical recycling. According to Chemical Recycling Europe, based on the rationale of Regulation No 282/2008 for which substances obtained from chemical depolymerization are to be considered as those obtained via chemical synthesis, the authorization of the EFSA should not be deemed necessary to obtain their food-grade approval. Policies for pyrolysis and depolymerization recognition are still being discussed by DG SANTE (or DG Health and Food Safety) and are yet to receive official authorization. An exception exists for hydrocarbon oils obtained from pyrolysis, which have been approved to be used in food-grade packaging<fnref n="278" /> (29).

**Note on substances of concern based on the ECHA report:** Substances of concern (such as plasticizers, flame retardants, and stabilizers) can be found in plastics used for applications such as EEE, the automotive industry, construction waste, etc. These components are listed and subject to restrictions within the REACH legislation<fnref n="279" />, under the Stockholm Convention (POPs), or in EU sectorial or regional regulations. Their use is highly regulated due to the high threat they constitute for the environment and to human health. While already challenging to manage, handling these substances can become even more complex due to the lack of traceability along the supply chain. Poor historical data on plastic composition is a major challenge for the recycling industry. Chemical and physico-chemical recycling technologies are often claimed as a solution for the recycling of plastics containing these components. Yet, a recent investigation by the ECHA concluded that more research has to be conducted to determine whether chemical and physico-chemical recycling technologies are a suitable option to treat plastics featuring substances of concern. On this topic, the agency highlighted the importance of improving screening and sorting technologies, as well as the role of digitalization to improve substances' traceability<fnref n="280" />.

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

As of today, no legislation nor harmonizing standard regulating the mass balance approach has been approved on a European level. Despite the lack of regulation, mass balance is one of the most debated subjects in the field of chemical recycling. In 2020, the Ellen MacArthur Foundation (EMF) published a

<footnote n="277">²⁷⁷ https://efsa.onlinelibrary.wiley.com/doi/epdf/10.2903/sp.efsa.2021.EN-6512</footnote>

<footnote n="278">²⁷⁸ This information was published by CRE. The source of the information does not specify which regulation it refers to, nor which authority authorized the approval.</footnote>

<footnote n="279">²⁷⁹ Within the REACH regulations, substances of concern include those listed as substances of very high concern and within Annex XVII.</footnote>

<footnote n="280">²⁸⁰ https://echa.europa.eu/documents/10162/1459379/chem_recycling_final_report_en.pdf/887c4182-8327-e197-0bc4-17a5d608de6e?t=1636701265520</footnote>
white paper by the title "Enabling a circular economy for chemicals with the mass balance approach".
Following an extensive introduction on the principles of mass balance and its applicability to the chemical
sector, the EMF discusses how the formal validation of this approach could become a key enabler for
reducing plastic pollution and increasing recycled content in manufactured goods. It is argued that this
system can be beneficial for both mechanical and chemical recycling. Yet, the Foundation supports the
principle by which establishing appropriate standards is vital to protect consumers. According to their
point of view, relevant standards used to regulate mass balance should: be international, be recognized
as a contribution to the achievement of recycling targets, ensure transparency on societal and
environmental benefits, be applicable both on a corporate or on a finished product level, and consider
that multiple different feedstock sources might be used to manufacture the same product (36). Similarly,
to the EMF, PlasticsEurope published a position paper supporting the mass balance approach. Although
focused on renewable rather than recycled feedstocks, the organization also puts a strong emphasis on
the necessity to create regulating standards (37).

While organizations such as the EMF and PlasticsEurope are presenting the mass balance approach as an enabler for circular economy and advocate for the harmonization of reference standards, other stakeholders appoint it as a potential greenwashing tool. Rethink Plastic published a position paper<sup>281</sup> on this subject. The organization supported the idea by which, in order to prevent greenwashing activities and protect consumers from misleading marketing claims, the regulation applied should be very strict when the mass balance approach is used in the context of calculating recycled content. Moreover, setting a rigorous legislation is deemed as necessary to prevent the chemical recycling industry from hindering incentives to increase the recyclability of plastics and from discouraging efforts to increase the recycled content in plastic products. To this end, the organization proposes the following recommendations (38):

1. Aim for the highest possible amount of recycled content and segregate recycled feedstock from virgin feedstock in the supply chain.

2. Use 'batch level' mass balance to determine recycled content when segregation is not feasible, which enables you to know the proportion of recycled material fed into the process and estimate actual recycled content in final products placed on the market.

3. Do not allow for the trading of recycled content as part of a credit system, both between sites and countries, including other sites belonging to the same company.

4. Evenly allocate the recycled content to output products where mass balance is used instead of allocating it arbitrarily (unless the actual recycled content of each output can be verified).

5. Ensure strong physical and chemical traceability of recycled content, thus ensuring that there is a proven chemical route between the input feedstock and the final product; and that input material can only replace its own share of the final product.

6. Avoid converting recycled content into theoretical 'currencies' such as calorific value or carbon, which would further facilitate a certification scheme for recycled content.

7. When determining recycled content, only include post-consumer waste and not pre-consumer waste.

8. Set strict eligibility criteria for plastic waste used for 'chemical recycling' to avoid competition with mechanical recycling feedstock.

9. Account for the full life cycle of products in the chain of custody model, taking consideration to material and carbon losses.

10. Ensure full transparency towards consumers by avoiding false claims and excluding additives from counting towards recycled content targets.

Numerous discussions are still ongoing on the mass balance approach and its use in the chemical recycling sector.

<footnote n="281">281 https://ecostandard.org/wp-content/uploads/2021/02/2021_zwe_joint-paper_recycling_content_mass_balance Approach.pdf#:~:text=The%20%E2%80%98mass%20balan ce%20approach%E2%80%99%20is%20one%20such%20set,while%20harming%20the%20credibility %20of%20the%20recycling%20industry.%C2%A0%C2%A0</footnote>
### d. Departure from the status of waste

The Waste Framework Directive 2008/98/EC sets the basic criteria to determine under which conditions waste regains the status of product or acquires the title of secondary raw material. Article 6 – “End-of-waste status” (EoW) of this European law specifies that, for materials to cease to be waste, the following requirements must be met (28):

* The substance or object is to be used for specific purposes (e.g., no fuel nor energy applications, etc.).

* A market or demand exists for such a substance or object.

* The substance or object fulfils the technical requirements for the specific purposes and meets the existing legislation and standards applicable to products; and

* The use of the substance or object will not lead to overall adverse environmental or human health impacts.

Since the publishing of the Directive in November 2008, the European Commission has been working on the adaptation of this regulation to specific waste streams. This work, which has been carried out with the collaboration of the Joint Research Centre Institute for Prospective Technological Studies (JRC-IPTS), aims at setting Union-wide end-of-waste criteria that are specific to certain types of waste (39). On one hand, the IPTS drafts waste-specific technical proposals containing all the information that is necessary to ensure compliance with Article 6 of the Directive. On the other hand, the Commission uses these technical proposals to implement the existing regulation. The latest available official document discussing the end-of-waste (EoW) criteria for waste plastic for conversion was published in 2014 by the JRC. This technical proposal explicitly excluded chemical recycling from its scope. The reasons behind the decision of not including chemical recycling<fnref n="282" /> in the study were (39):

1. The refined output of feedstock recycling was considered to be out of scope as no barrier was found in the process of recognizing it as a product.

2. Mechanical and chemical recycling technologies were claimed to be too different for their output to be evaluated using the same EoW criteria.

3. The lack of clear distinctions between plastic-to-plastic and plastic-to-fuel outputs raised concerns that the adaptation of EoW criteria could incentivize non-recycling uses. Such outcome would have conflicted with regulations promoting the recycling of plastic waste.

4. Feedstock recycling still had a marginal role, accounting for only 50kt of materials treated yearly in the EU compared with over 5Mt for mechanical recycling.

Since the “End-of-waste criteria for waste plastic for conversion: Technical proposal” was published in 2014, no amendments have been officially released by the European Commission on chemical and physico-chemical recycling. Even when the Waste Framework Directive was last modified in 2018 (Directive 2018/851), no implementations were made regarding this subject (40). The adaptation of the EoW regulation to chemical and physico-chemical recycling is therefore assumed to either be on hold (not progressing) or still under discussion.

### e. Qualification of a recycled state

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

The main reference standard used on a European level for the evaluation of recycled plastics is the EN 15343:2007 - Plastics - Recycled Plastics - Plastics recycling traceability and assessment of conformity and recycled content<fnref n="283" />. This standard provides the basic directives to calculate the amount of recycled content within a product and establishes reference procedures for the appropriate traceability of mechanically recycled plastics. Additional standards exist that are applicable to the recycling of specific type of plastics, examples include:

<footnote n="282">²⁸² The 2014 publication from the JRC that his paragraph refers to uses the terms « feedstock » and « chemical » recycling interchangeably.</footnote>

<footnote n="283">²⁸³ https://shop.bsigroup.com/ProductDetail/?pid=000000000030097507</footnote>
* EN 15342:2008 Plastics. Recycled plastics. Characterization of polystyrene (PS) recyclates

* EN 15344:2021 Plastics. Recycled plastics. Characterization of polyethylene (PE) recyclates

* EN 15345:2008 Plastics. Recycled plastics. Characterization of polypropylene (PP) recyclates

* EN 15346:2015 Plastics. Recycled plastics. Characterization of poly(vinyl chloride) (PVC) recyclates

* EN 15348:2015 Plastics. Recycled plastics. Characterization of poly(ethylene terephthalate) (PET) recyclates

All these standards were created in compliance with the CEN/TR 15353:2007 Guidelines for the development of standards for recycled plastics. As of today, no standards have been found which are explicitly applicable or created with the purpose of evaluating chemical and physico-chemical recycling processes.

Multiple certifications exist on a European level to evaluate production tools and to qualify recycled materials/products.

In August 2020, the European Commission presented the Recycled Plastics Traceability Certification on its Circular Economy Stakeholders Platform. This certification is part of the RecyClass initiative (one initiative launched amongst others)<fnref n="284" />, which aims at increasing the recyclability of plastic packaging by harmonizing the methods for recyclability and recycled content evaluation across the EU. The Certification Audit Scheme developed by RecyClass is used to evaluate and calculate the recycled content found in plastics. Traceability and Chain of Custody<fnref n="285" /> are the core principles on which the Scheme is based. These two concepts ensure monitoring and verification at each step of the supply chain (including pre- and post-consumer phases), while also ensuring compliance with the ISO 22095 and the EN 15343:2007 standard (41). Section 5 of the Audit Scheme – Production Process includes information concerning the inclusion of a mass balance calculation method as part of the auditing process. Further details on the calculation are however not publicly available (41). Given that this certification was created as part of an initiative from the European Commission, it is assumed that it is valid mainly on a regional (European) level. Moreover, it is not specified whether chemical recyclers are eligible to obtain this type of certification.

In France, LNE (laboratoire national de métrologie et d'essais) and IPC (Centre Technique Industriel de la Plasturgie et des Composites) published a certification scheme on recycled content in January 2022²⁸⁶. Polymers produced from chemical and physico-chemical recycling seem eligible to this kind of certification.

The Recycled Plastics Traceability Certification was created as a complementary initiative to the already existing EuCertPlast. The EuCertPlast certification<fnref n="287" /> was launched by the European Commission as part of the Eco-innovation program (2009-2012). It is mainly used to trace plastics across the value chain and assess the quality of the recyclates that are integrated into end-products. This verification is based on the EN 15343:2007 standard and is claimed to help recyclers meet REACH and food-grade application requirements (42). Plastic recyclers wishing to be certified by EuCertPlast must forward an online request for their plant to be evaluated by an accredited auditor and undergo third party checks that ensure impartiality. Recyclers that successfully complete the application process receive a one-year valid certificate, which can be used as proof that their facility operates in compliance with the best available practices and respecting the environment. Based on the available data (e.g., EuCertPlast online database<fnref n="288" />) it seems that, so far, no chemical recycler has been accredited the certification, this information has however not been officially confirmed. Given that this certification was created as part of an initiative from the European Commission, it is assumed that it is valid mainly on a regional (European) level.

<footnote n="284">²⁸⁴ https://recyclass.eu/recyclass/</footnote>

<footnote n="285">²⁸⁵ The term “Traceability and Chain of Custody” refers to the fact that the certified product should be trackable across the whole value chain, from the origin of the waste to the material.</footnote>

<footnote n="286">²⁸⁶ https://www.lne.fr/fr/actualites/matieres-plastiques-recyclees-lancement-nouvelle-certification</footnote>

<footnote n="287">²⁸⁷ https://www.eucertplast.eu/about</footnote>

<footnote n="288">²⁸⁸ https://www.eucertplast.eu/certified-recyclers</footnote>
Supplementary REDcert² scheme principles for the chemical industry (or REDcert²)<fnref n="289" /> is also a relevant standard valid on a European level. REDcert GmbH was originally created in 2010 by German actors operating in the field of agricultural and biofuel economy. The organization was funded with the goal of supporting the implementation of Sustainability Ordinances by encouraging the use of certified sustainable biofuels and liquid biomass. Given the increasing reliance of the chemical industry on biomass as an alternative to primary fossil resources, the organization later decided to create an additional certification that is applicable to the chemical sector. That is why, in 2018, the "Supplementary REDcert² scheme principles for the chemical industry" (or REDcert² - certification of sustainable material flows in the chemical industry) was launched in compliance with EU Directive on Renewable Energy. This initiative consisted in the integration of the TÜVSÜD's CMS 71 standard<fnref n="290" /> into the already existing REDcert² certification (43). At first, the REDcert² scheme was reserved to companies integrating both sustainable biomass and recycled fossil-based materials into new products. However, since 2019, chemical companies can also receive a REDcert² certification of sustainable material flows in the chemical industry for integrating sustainable (recycled) fossil waste materials within their products even when no biomass content is added to them. This decision was made to better support decarbonization and circular economy objectives (43). The REDcert² scheme relies on the certification of the mass balance approach for recycling. Actors that successfully meet the requirements to obtain this certificate can then use it on their products as an advertising tool<fnref n="291" />. This certification is valid on German territory and on a European level<fnref n="292" />. BASF was the first actor belonging to the chemical sector to receive the REDcert² for the allocation of biomass to its products<fnref n="293" />. In 2019, REDcert published a press release supporting the applicability of REDcert² to chemical and physico-chemical recycling (no additional definition provided)<fnref n="294" />. The REDCert² logo can be sticked to the certified products. The following product-related claims on the mass balance approach are allowed: "Fossil resources saving product", or "Fossil resources saving product by using recycled materials in the value chain", or "This product supports / comes with / leads to / entails a x% substitution of fossil with recycled materials in the value chain"<fnref n="295" />. No further details were found about other certified chemical and physico-chemical recycling technologies.

No additional information was found concerning the certifications of chemically recycled products.

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

As mentioned in the previous paragraph, the European Waste Framework Directive establishes that, in order for a technology to be considered as recycling, its output has to be used for plastic-to-plastic applications. It is acknowledged that, in some cases, the output of chemical recycling technologies is suitable for both plastic and fuel applications. The end-of-life applications of these materials will therefore determine whether or not they can be attributed the status of "recycle". This is the case for pyrolysis oil. Pyrolysis oil could only be recognized as recycled if it is used as an input in the manufacturing of new polymers. If used for plastic-to-fuel applications, this same material could not be acknowledged as a recycled output.

However, this raises the question of material traceability to ensure that the company, which purchases the recycled material (e.g., pyrolysis oil) and claims it will be used for plastic production, will actually process the material for such purposes (and not for fuel applications).

<footnote n="289">²⁸⁹ https://www.redcert.org/en/redcert-systems/chemical-industry.html</footnote>

<footnote n="290">²⁹⁰ https://www.tuvsud.com/de-de/-/media/de/industry-service/pdf/broschueren-und-flyer/is/energie/zertifizierungsstandard-erneuerbare-rohstoffe-tuvsud-is-ut.pdf?la=de-de</footnote>

<footnote n="291">²⁹¹ https://www.redcert.org/en/redcert-systems/chemical-industry.html</footnote>

<footnote n="292">²⁹² https://www.redcert.org/en/about-us.html</footnote>

<footnote n="293">²⁹³ https://www.basf.com/global/en/who-we-are/sustainability/whats-new/sustainability-news/2019/BASF-REDcert2-standard.html</footnote>

<footnote n="294">²⁹⁴ https://www.redcert.org/images/REDcert Press Release.pdf</footnote>

<footnote n="295">²⁹⁵ https://www.redcert.org/images/REDcert_Guidelines_of_using_the_logo_and_claims_V10.pdf</footnote>
### f. European green taxonomy

In June 2020, the European Union published the Taxonomy Regulation (2020/852) within the Official Journal of the European Union. The EU taxonomy is a classification system establishing a clear guidance for the identification of sustainable economic activities. This system works by setting a list of technical criteria. Economic activities that comply which such criteria can officially recognized as sustainable. This new system is meant to help direct financial investments towards green activities. Areas of focus involve sectors that have the highest environmental impacts in the EU (such as energy, manufacturing, transportation, construction, etc.). Sustainable economic activities must respect the four following conditions (44):

1. Make a substantial contribution to at least one of the six environmental objectives

* Objective 1: Climate change mitigation.

* Objective 2: Climate change adaptation.

* Objective 3: Sustainable use and protection of water and marine sources.

* Objective 4: Transition to a circular economy.

* Objective 5: Pollution prevention and control.

* Objective 6: The protection and restoration of biodiversity and ecosystems

2. Do no significant harm to any of the other environmental objectives.

3. Comply with minimum social safeguards.

4. Comply with the technical screening criteria.

The Regulation, which entered into force in July 2020, will help the EU reach the objectives set by the European Green New Deal and will support the achievement of 2030 climate and energy targets<fnref n="296" />.

In June 2021, one year after the initial publication of the Taxonomy Regulation, a first delegated act (setting the criteria for activities to meet environmental objectives 1 and 2) was formally adopted by the Commission for scrutiny by the co-legislators. The act, which came into force at the beginning of 2022, focuses on defining sustainable activities that contribute to climate change adaptation and mitigation objectives. No additional delegated acts have been published since. However, a second act (setting the criteria for activities to meet environmental objectives 3, 4, 5, and 6) is expected for mid-2022, entering into force in 2023.

The first delegated act contains information that will directly impact plastics manufacturers and recyclers. The document contains in fact compliance criteria for the manufacturing of plastics in primary form (including plastics manufactured using mechanical recycling, chemical recycling<fnref n="297" />, as well as entirely or partially derived from renewable feedstock<fnref n="298" />). Specific requirements can be found within section 3.17 of Annex I of the first delegated act. Annex I focuses on objective 1 – Climate change mitigation, of the taxonomy criteria. Based on this document, “manufacturing of plastics in primary form is to be considered a sustainable activity if it can prove its contribution to climate change mitigation though these technical screening criteria”<fnref n="299" />:

a) “The plastic in primary form is fully manufactured by mechanical recycling of plastic waste”.

b) “Where mechanical recycling is not technically feasible or economically viable, the plastic in primary form is fully manufactured by chemical recycling of plastic waste and the life-cycle GHG emissions of the manufactured plastic (excluding any calculated credits from the production of fuels) are lower than the life-cycle GHG emissions of the equivalent plastic in primary form manufactured from fossil fuel feedstock. Lifecycle GHG emissions are calculated using

<footnote n="296">²⁹⁶ https://ec.europa.eu/info/business-economy-euro/banking-and-finance/sustainable-finance/eu-taxonomy-sustainable-activities_en</footnote>

<footnote n="297">²⁹⁷ Please note that, although mechanical and chemical recycling are discussed within the Taxonomy legislation, the European Commission does not include a definition of these terms within the regulation nor in its first delegated act.</footnote>

<footnote n="298">²⁹⁸ “Renewable feedstock refers to biomass, industrial bio-waste or municipal bio-waste”.</footnote>

<footnote n="299">²⁹⁹ https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=PI_COM:C(2021)2800&from=EN
Study RECORD n°21-0919/1A</footnote>
Recommendation 2013/179/EU or, alternatively, using ISO 14067:2018 or ISO 14064-1:2018. Quantified life-cycle GHG emissions are verified by an independent third party."

c) "Derived wholly or partially from renewable feedstock and its life-cycle GHG emissions are lower than the life-cycle GHG emissions of the equivalent plastics in primary form manufactured from fossil fuel feedstock. Lifecycle GHG emissions are calculated using Recommendation 2013/179/EU or, alternatively, using ISO 14067:2018 or ISO 14064-1:2018. Quantified life-cycle GHG emissions are verified by an independent third party."

Annex II, which focuses on objective 2 - Climate change adaptation, also contains clauses for the manufacturing of plastics in primary form. However, no reference was found to recycling activities within this section.

Criteria for meeting the remaining four environmental objectives of the EU Taxonomy are yet to be published. In August 2021, a draft report was published by the Technical Working Group (TWG) of the Platform on Sustainable Finance<fnref n="300" />. The document was published with the aim of collecting feedback on proposed preliminary recommendations on technical screening criteria for:

* Objective 3 - Sustainable use of water and marine sources,

* Objective 4 - Circular economy,

* Objective 5 - Pollution prevention,

* Objective 6 - Healthy ecosystems and biodiversity.

Within the annex, the report additionally puts forward the idea by which an activity should be considered sustainable if it involves design for recycling for food/beverage packaging. The document mentions that food/beverage packaging product manufacturing (including primary, secondary, and tertiary food/beverage packaging<fnref n="301" />) activities can be considered sustainable if at least 85% of total packaging (by weight) respects the following criteria<fnref n="302" />:

* "Fully manufactured by mechanical or chemical recycling of post-consumer material, with claims on recycled content made using a batch level mass balance<fnref n="303" /> method. For chemical recycling technologies the material conversion rate should be at least the rate of existing mechanical recycling technologies for that material."

* Derived from renewable feedstock, which is material that is composed of biomass from a living source and that can be continually replenished, or from a source which is continually replenished by nature. When claims of renewability are made for virgin materials, evidence is provided to show that those materials shall come from sources that are replenished at a rate equal to or greater than the rate of depletion."

* "A combination of the options above."<fnref n="304" />

The paper additionally suggests that all claims on recycled and/or renewable content should be validated using international certification systems (e.g., ISCC PLUS certified packaging).

<footnote n="300">³⁰⁰ The Platform on Sustainable Finance is a permanent expert group created by the European Commission to support the implementation of the new Taxonomy regulation.</footnote>

<footnote n="301">³⁰¹ *Primary packaging*: packaging in direct contact with the product that is being sold. *Secondary packaging*: packaging used to keep a certain number of products together. *Tertiary packaging*: bulk/transport packaging used to group a large number of products.</footnote>

<footnote n="302">³⁰²</footnote>

<footnote>https://ec.europa.eu/info/sites/default/files/business_economy_euro/banking_and_finance/documents/210803-sustainable-finance-platform-report-technical-screening-criteria-taxonomy-annex_en.pdf</footnote>

<footnote n="303">³⁰³ The term « batch level mass balance » is not defined within the report. The ISEAL Alliance refers to batch-level mass balance also as 'percentage blending' or 'batch blending'. They define it as a type of mass-balance that "ensures the end-product contains at least a proportion of certified product". "This model maintains segregation until the final point of blending or mixing for a specific batch of a product. Mixing with non-certified product is controlled and recorded, so the proportion of certified content in each final product is known.". From: https://www.isealliance.org/sites/default/files/resource/2017-11/ISEAL_Chain_of_Custody Models Guidance September 2016.pdf</footnote>

<footnote n="304">³⁰⁴ No further details available.</footnote>