September 1, 2022

Guidelines on “bio-attributed plastics”
in the Eco Mark certification criteria
Eco Mark Office, Japan Environment Association
1. Background of development of the guidelines
Eco Mark Office developed the “Guidelines on plant-based plastics in the Eco Markcertification criteria” (the general guidelines) in 2015, introduced certification criteria
for individual product categories on the content of bio-based plastics (PE, PET, PTT
and PLA) that had been confirmed to be effective for reducing environmental impacts
and has given certification to products that met the criteria.
Some plastics available particularly on the recent EU market are made from bio-basedhydrocarbons (such as bio naphtha) that are blended with fossil-based materials in the
manufacturing process. Similarly, in Japan, leading trading companies andpetrochemicalcompanies

have

been

undertaking

commercialization

andmanufacturing of those plastics around 2020 and this move is expected to expand in the
future. This kind of plastics are managed under the mass balance approach that keeps
track of the inputs of biomass feedstocks and the production outputs and attributed tothe characteristics of the biomass feedstocks.
This kind of plastics are called “bio-attributed plastics” and have potential for
promoting the government initiative of “Resource Circulation Strategy for Plastics” andexpanding the use of renewable resources (biomass, etc.) significantly in a transition
aiming to ensure that bio-based plastics assume a dominant position in newly developed
plastics toward the achievement of carbon neutral society by 2050. Technologically, it
is feasible to produce a wider variety of bio-attributed plastics than that of the existingbio-based plastics with biomass materials in the manufacturing processes.
In October 2020, Eco Mark Office received a proposal from business operators to create
new product categories containing bio-attributed plastics and set up the “Working
Group on revision of the guidelines on bio-based plastics in the Eco Mark certification
criteria.” Separately from the general guidelines, Eco Mark Office developed thefundamental guidelines for introducing bio-attributed plastics as a new criteria item
for individual product categories.

2. Principles on application of bio-attributed plastics to the Eco Mark certification
criteria
The principles on the application of bio-attributed plastics to Eco Mark certification
criteria in individual product categories and the criteria items are described below. The

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guidelines also apply to bio-attributed synthetic fiber. In this case, the term “plastics”
is read as “synthetic fiber.”
1) Product categories subject to the guidelines
The guidelines will apply to the Eco Mark product categories (certification criteria) that
focus on the environmental characteristics of plastic materials at appropriate times inline with the fundamental policies such as the “Act on Promotion of Procurement of
Eco-Friendly Goods and Services by the State and Other Entities (Act on Promoting
Green Procurement).”
2) Criteria items
3. Terms and definitions
Biomass

Bio-attributed plastics

Mass balance approach

Biomass is a term originally used in ecology to describe
the amount (mass) of living organisms (bio). In thisGuideline, it refers to resources that are organic
matter-derived from plants and animals, excluding
fossil fuels.
(source: Roadmap for Bioplastics Introduction,
January 2021 (Ministry of the Environment, Ministryof Economy, Trade and Industry, Ministry ofAgriculture, Forestry and Fisheries, Ministry of
Education, Culture, Sports, Science and Technology))
Plastics that are produced from organic compounds
derived from biomass materials (hydrocarbons, fatty
acid, alcohol, etc.) mixed with fossil-based materials in
the manufacturing process and that are attributed tothe biomass materials under the mass balance approach
A method in which, during the process of turning raw
materials into final products and the distribution
process (chain of custody), raw materials with certain
properties (e.g., bio-based raw materials) are mixed
with raw materials that do not have the properties(e.g., fossil-based raw materials); thus, the properties
are assigned to a portion of the product according to
the amount of input of the raw materials with those
properties.
(source: Roadmap for Bioplastics Introduction,
January 2021 (Ministry of the Environment, Ministryof Economy, Trade and Industry, Ministry ofAgriculture, Forestry and Fisheries, Ministry of
Education, Culture, Sports, Science and Technology))

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4. Certification Criteria and Certification Procedures
4-1. Environmental criteria and evidence
4-1-1. Criteria for the attribution factor and traceability of biomass feedstock(1) The attribution factor of characteristics of biomass feedstock to plastic shall meetthe criteria. The attribution factor shall be managed under the mass balance
approach and maintained after a relevant product has obtained an Eco Markcertification.

* The attribution factor of characteristics of biomass feedstock will be defined byCriteria Development Committee and Criteria Review Committee for individual
product categories in consideration of the criteria for bio-based content inproducts under the existing bio-based plastics certification schemes.
Examples of Eco Mark product categories (certification criteria) subject to thediscussion on the setting of attribution factor of characteristics of biomass
feedstock
Product categories
Plastic products (general)
Stationery
Household commodity
Waste bags, films
Fiber productsContainers andMolded products, etc.
packaging material
Laminated packaging material[Certification Procedure]
An applicant shall submit a certificate that states the attribution factor ofcharacteristics of biomass feedstock to plastic and supportive documents(product specifications, etc.).
Manufacturers and other relevant parties in the supply chain of the plastics
shall calculate and record all inputs of biomass feedstocks attributed to theplastics and their production outputs and the attribution factors throughout
a year (including supportive documents) to maintain the attribution factorsof biomass feedstocks at an appropriate level. An applicant shall also submit
any evidence documents of third-party audit or certification (an internationalsustainability certification for plastics, etc.) (submit an audit report, a copyof certificate, etc.). An applicant shall retain the evidence documents for five
years.

4-1-2. Sustainability criteria for biomass supply chains(2) Sustainability of biomass mixed into plastic as raw material shall meet therequirements of Appendix 1 “Sustainability checklist of bio-attributed plastics(raw resin)” and the supply chains of the biomass shall be identified. If thebiomass material has undergone third-party audit or certification forsustainability (an international sustainability certification for plastics, etc.),
the result of audit or certification may be submitted as evidence instead of
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Appendix 1.
[Certification Procedure]
An applicant shall submit documents on the source of biomass material (acultivation area (country, state, city, etc.), a generation process of waste andresidues, etc.), a manufacturing flowchart of plastic (describe the name of
manufacturers of chemical raw materials, fundamental chemicals(monomers), polymers, etc.), and checklists or an evidence of international
certificate.
4-1-3. Criteria for effects for reducing environmental impacts(3) It shall be confirmed through life cycle assessment (LCA) that the bio-attributed
plastic does not cause an increase of GHG emissions (in terms of CO2) throughout
the product life cycle in comparison with fossil-based one to replace with.
[Certification Procedure]
An applicant shall submit the result of LCA conducted by a third-party. (Anapplicant shall provide the LCA result and the calculation conditions. If theapplicant has undergone LCA under an international sustainability
certification scheme for plastics, it may submit the data instead. The applicant
may submit an academic paper published on a journal as an evidence as longas the same materials and/or manufacturing processes (sites) are mentioned
in the paper as those used for the product applied for certification.)
4-1-4. Criteria for labeling on products containing bio-attributed plastics(4) Eco Mark shall be provided on products, packages, catalogues and the website inaccordance with the “Environmental Labeling Guidelines” (Ministry of theEnvironment) and the following instructions:1) Necessary information shall be provided on products, etc. to make the reason for
Eco Mark certification known to consumers properly.
Example: “This product has a content of bio-attributed plastics of XX percent.”[Examples of unacceptable claims]
Avoid phrases that may mislead consumers into believing that the productactually contains biomass material. :・Phrases suggesting that the product contains biomass material, for example,“Use” and “Contain” biomass material
・The content of bio-based synthetic polymer XX%
・Bio-based content XX%

2) An applicant shall assure that it does not make a claim for the content of biobased plastics in products that are not attributed to biomass characteristics
in a single product category managed under the mass balance approach.
If a single product (or a molecular structure) is consisted of a material
managed under the mass balance approach and other materials that actuallycontain bio-based plastics, the claims for those materials shall be madeseparately (not making a claim of them together).

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*Example 1 Manufacturing a multilayer film consisting of a bio-attributed
polystyrene film and a bio-based polyethylene film.
Example 2 Manufacturing PET by using bio-based ethylene glycol and bioattributed terephthalic acid
[Certification Procedure]
An applicant shall submit a text, etc. of environmental claims. For the
instruction 2), an applicant shall submit a statement of assurance.

September 1, 2022

Established5/29

Appendix 1 “Sustainability checklist of bio-attributed plastics (raw resin)”No

PurposeRequest (Item that must be realized)

1

Prevention of
globalwarming,
conservationof the natural
ecosystem

Hasn’t the farm land where plants arecultivated been converted from valuable
land in biodiversity or land with highcarbon storage (forests, peatland, etc.)
since 2008?

Subject

Realized

Farm land□Not
converted□Converted□Notapplicabledue toresidues or
waste

Implementation Method (Check off all relevant
items.)□Confirmed the laws and regulations concerning theland conversion for the site.
□Gained the understanding of the actual condition of
the site through on-site investigation or hearings.
□Defined and released the guideline for procurement ofplants. Alternatively, conforming to the guideline of an
independent third party.
- Name of the guideline:- Location of release:□Also using the certification system of an independent
third party, regarding the procurement of plants.
-Name of certification system:□Others (Describe specifically.):[2

Conservationof theecosystem

If the Applicant uses the geneticallymodified crop as a raw material, has the
Applicant assessed ensuring of safety?

]□Confirmed the laws and regulations concerning
□Yes/
□No/
□Not

Farm land

applicable(GM crops
Not used)□Not
applicabledue toresidues orwaste

genetically engineered crop on the site.
□Gained the understanding of the actual condition of
the site through on-site investigation or hearings.
□Defined and released the guideline for procurement ofplants. Alternatively, conforming to the guideline of an
independent third party.
- Name of the guideline:- Location of release:□Also using the certification system of an independent
third party, regarding the procurement of plants.
-Name of certification system:□Others (Describe specifically.):[3

Prevention ofland

Has the Applicant gained theunderstanding of usage conditions ofFarm land
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]

□Yes/

□Confirmed the laws and regulations concerning□No

fertilizers/agricultural chemicals on the site

No

PurposeRequest (Item that must be realized)

acidification/nutrient
enrichment,
water
contaminationfertilizers/agricultural chemicals in themain cultivation area of plants?
Isn’t any agricultural chemical
regulated under the “Stockholm
Convention on Persistent Organic
Pollutants” (POPs Treaty) used?

Subject

Implementation Method (Check off all relevant
items.)

Realized□Not□Gained the understanding of the actual condition of

applicabledue toresidues orwaste

the site through on-site investigation or hearings.
□Defined and released the guideline for procurement ofplants. Alternatively, conforming to the guideline of an
independent third party.
- Name of the guideline:- Location of release:□Also using the certification system of an independent
third party, regarding the procurement of plants.
-Name of certification system:□Others (Describe specifically.):[4

Appropriate
water usage

Has the Applicant gained theunderstanding of usage conditions ofwater in the main cultivation area ofplants?

]□Confirmed the laws and regulations concerning usage

□Yes/
□No
□Not

Farm land

applicabledue toresidues orwaste

of water (limits on the amount of water) on the site.
□Gained the understanding of the actual condition of
the site through on-site investigation or hearings.
□Defined and released the guideline for procurement ofplants. Alternatively, conforming to the guideline of an
independent third party.
- Name of the guideline:- Location of release:□Also using the certification system of an independent
third party, regarding the procurement of plants.
-Name of certification system:□Others (Describe specifically.)
[

5

Use
recycledresources,
avoidanceof If recycled resources are available as apart of crude raw materials of bioattributed plastic (raw resin) on theof site, did the Applicant preferentially□Yes/

Raw resin

□No/
□Not

applicable
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Name of recycled resource in use[]

Generated amount/percentage of recycled resources
[

]

No

Purpose6

competition
for food
Prevention of
globalwarming

7

8

Utilization of
non-fossil
energysources andrenewableenergysourcesLegalcompliance

Request (Item that must be realized)

Subject

use them?
Has the Applicant gained theunderstanding of the processing statusof methane having a high global
warming potential if it is generated byfermentation in the main
manufacturing plant for the crude raw
material?
In the course of cultivation to raw resin
manufacturing, did the Applicant
utilize as many non-fossil energy
sources (for example, bagasse, biogas,
off gas, etc.) or renewable energy
sources as possible?

Implementation Method (Check off all relevant
items.)

Realized(Notavailable)□Gained the understanding of the actual condition of

Crude rawmaterial
manufacturi
ng plant

□Yes/
□No

the site through on-site investigation or hearings.
□Others (Describe specifically.)
[

□Not

]

applicable
Energy name and method of utilization[

Manufacturi
ng plant

Does the manufacturing plant of the bioattributed plastic (monomer, raw resin)follow related environmental laws and Resinregulations and pollution control manufacturi
agreement with respect to air pollution, ng plantwater contamination, noise, vibration,
offensive odor, and emission of
hazardous materials?

* Residues or Waste defined in Renewable Energy Directive (RED) of EU

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]

□Yes/
□No

Monomer manufacturer / plant name[]Resin manufacturer / plant name
□Yes/
□No

[

]

Explanation material

Guidelines on “bio-attributed plastics” in the Eco Markcertification criteria

1. Definitions of terms
1) “Bio-based plastics”
The existing Eco Mark certification criteria for “plant-based” plastics are based on theassumption that plastics are made from “plant-based” materials such as sugar cane andcorn. Recently, however, the term “plant-based” is unsuitable for some types of plastics
containing animal-based fat that are emerging on the market. The “Roadmap for
Bioplastics Introduction” jointly developed by Ministry of the Environment, Ministry of
Economy, Trade and Industry, Ministry of Agriculture, Forestry and Fisheries, andMinistry of Education, Culture, Sports, Science and Technology uses the term “biobased plastics” in the same vein as “plant-based plastics” and the term will be used in
the Eco Mark certification process. The definitions of “biomass” and “bio-based plastics”
used in the Eco Mark certification process were created based on the Roadmap. The
term “biomass” is defined in ISO 14021:2016, 3.1.1 as “material of biological origin,excluding material embedded in geological formations or transformed to fossilisedmaterial and excluding peat” and the same definition is used in the Roadmap. The term
“plant-based plastics” may also be used for plastic products made from plant-basedmaterials (including those given an Eco Mark certification).
2) “Bio-attributed plastics”
In the context of the guidelines, bio-attributed plastics mean plastics produced fromorganic compounds derived from biomass materials (hydrocarbons, fatty acid, alcohol,etc.) mixed with fossil-based materials in the manufacturing process and attributed tothe biomass materials under the mass balance (MB) approach that manages the inputsof biomass materials and production outputs. This type of plastics has no particular
designation under Japanese and international laws and regulations, the JapaneseIndustrial Standards (JIS) and industry guidelines. The Working Group discussed
whether the existing designation of “bio-based (plant-based) plastics” was suitable foruse for this type of plastics.
In ISO 16620, an international standard for determining the amount of bio-based
content in plastic products, the terms of “biobased synthetic polymer” and “biobased
synthetic polymer content” are defined in Sections 3.1.4 and 3.1.5 respectively. They
refer to the existing bio-based plastics (plastics added with biomass material). The
paper “Mass balance approach to accelerate the use of renewable feedstocks in chemical
processes 1” published by Plastics Europe in January 2020 states that the term “biobased” shall refer to products from “Identity Preserved” or “Segregated” supply chains1

https://plasticseurope.org/wp-content/uploads/2021/10/20100129-View-Paper-Mass-Balance-ApproachRenewable-Feedstocks.pdf

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and that must not be used for those from “Mass Balance” supply chains. In the paper,products from mass balance supply chains are referred to as “Renewable Attributed
Products.” In addition, the glossary of the paper defines “Renewable Feedstock” as“Materials that have been produced from a source, usually plant or animal b iomass,that can be renewed by short-to-medium-term regeneration as referred to in ISO 24699
section 3.1.1.” With this definition as a guide, some members of the Working Groupsuggested that the term “renewable feedstock” be used. To distinguish from plastics
produced through chemical recycling of plastic waste, the Working Group decided toinclude “biomass” and “attribution” in the designation and avoided the use of “massbalance” and “credit” whose meaning may be difficult to understand for users andconsumers.
In the end, the Working Group decided to refer to this type of plastics as “bio-attributed
plastics” in the Eco Mark certification system in consideration of the phrase of “bioattributed PP, PE and other general-purpose plastics managed under the mass balance
approach will come into widespread use ahead of bio-based ones” in the report of the
38th Central Environment Council, Subcommittee for Recycling Society, the Ministryof the Environment, Japan (on August 5, 2021).
3) “Mass balance approach”
The definition of mass balance approach under the guidelines was cited from the“Roadmap for Bioplastics Introduction” developed with some international standards
as a guide. ISO 22095 “Chain of custody - General terminology and models” defines themass balance model as the models “in which materials with a set of specified
characteristics are mixed with materials without that set of characteristics inprocessing/distribution processes and the specified characteristics are attributed to a
product in proportion to the input.” The whitepaper titled “Enabling a Circular
Economy For Chemicals With the Mass Balance Approach” published by Ellen
MacArthur Foundation suggests the four different Chain of Custody models in which
processing/logistics supply chains from raw materials to products are supervised 2(Note: The table below was created by Eco Mark Office with reference to the Whitepaperof Ellen MacArthur Foundation):
Model
Identity
Preserved

Segregated2

Conceptual image

Description
Products originate from a single source and their
specified characteristics are maintained throughout
the supply chain.
Example: Existing bio-based plastics, recycled plastics
Materials from different sources may be mixed to
produce products as far as those materials meetcommon criteria. The specified characteristics ofmaterials are maintained from the start of input to theend of output.
Example: Existing bio-based plastics, recycled plastics

ISO 22095 suggests five Chain of Custody models including the “Controlled Blending” model that is positioned
between “Segregation” and “Mass Balance” models.

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Mass BalanceBook & Claim

Materials with a set of specified characteristics are
mixed to produce products. The products are
attributed to the specified characteristics of materials
in the proportion to their input.
Example: Forest certification, palm oil certification
The supply flow of certified materials has no physicallink with the supply flow of products. Products are
attributed to the specified characteristics of materials
through trading credits and certificates issued byindependent agencies.
Example: Green electricity certification
This model does not apply to common bio-based
plastics.

2. Background of development of the guidelines on bio-attributed plastics in the Eco
Mark certification criteria
1) Manufacturing processes of bio-attributed plastics
The figures below show general manufacturing processes of bio-attributed plastics
under development toward commercialization. Biomass such as used cooking oil ishydrogenated and deoxygenated into bio diesel and bio naphtha (hydrocarbons(mixture) with characteristics similar to naphtha produced from fossil-based materials(fossil naphtha)) (no attribution to biomass characteristics is made yet at this stage).
In the next process, bio naphtha and fossil naphtha is charged into a cracking unit toproduce fundamental chemicals such as ethylene and propylene. In this stage, thecharacteristics of biomass materials can be attributed to the plastics as shown in theright of the figure “2. Cracking process.” Then, those plastics are processed into finishedproducts through “3. Polymerization” and “4. Forming” processes in which the products
can be attributed to the biomass materials through the management of inputs andoutputs.
Note) Eco Mark Office created the figures below to illustrate a relation between
manufacturing processes and the attribution of characteristics of biomass materials to
help the understanding of mass balance approach. Each business operator may havedifferent manufacturing processes and attribution methods.

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2) Background of development of the guidelines on bio-attributed plastics in the Eco
Mark certification criteria
Bio-attributed plastics have potential for promoting the government initiative of“Resource Circulation Strategy for Plastics” and expanding the use of renewable
resources (biomass, etc.) significantly in a transition aiming to ensure that bio-based
plastics assume a dominant position in newly developed plastics toward theachievement of carbon neutral society by 2050.
The Eco Mark certification system has covered bio-based plastics (PE, PET, PLA and
PTT). On the other hand, the guidelines cover plastics that are attributable to biomass
materials used in the manufacturing process. Bio-attributed plastics and bio-based
plastics are expected to be effective in reducing environmental impacts respectively.
Theoretically, both can reduce the same level of environmental impacts on the global
basis if they are produced through the same manufacturing processes.
Most bio-attributed plastics can be produced in the manufacturing processes of fossilbased plastics. This eliminates the need of large-scale capital investment and allows
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production by any business operators that have necessary equipment. Technologically,
it is feasible to produce a wider variety of bio-attributed plastics than that of theexisting bio-based plastics. The concept of attribution (under the mass balance
approach) is common in forest certification and palm oil certification, but still
unfamiliar among consumers and business operators in Japan. Toward the widespreaduse of bio-attributed plastics in the Japanese market, it is important that the Eco Markcertification system covers bio-attributed plastics with defined certification criteria andthat serves as a communication tool between business operators and consumers topromote correct recognition and understanding of bio-attributed plastics. The Eco Markcertification system covering both bio-attributed and bio-based plastics will facilitate
technological innovation and advancement toward 2050 and help consumers accept a
new concept of bio-attributed plastics.

3. Product categories subject to the guidelines
For bio-based plastics, Eco Mark certification criteria are defined for the productcategories of plastic products (stationery/office supplies, household commodity,
construction and civil engineering, furniture), containers and packaging material, andfiber products. Eco Mark Office will define criteria items of bio-attribute plastics forthese product categories according to the guidelines. In addition, Eco Mark Office will
newly define the criteria for bio-attributed plastics to the product categories in which
no bio-based plastics have been available as a replacement for existing plastics withthe aim of expanding the use and demand for biomass resources.
The Working Group discussed as to whether the criteria for bio-attributed plastics
should be introduced to specified areas/applications in which the use of bio-attributed
plastics is expected, but concluded that the criteria should be introduced to all productcategories uniformly. For products subject to the Act on Promoting Green Procurement,
however, the time of introducing bio-attributed plastics to the certification criteria
should be decided in a manner consistent with the basic principles of the Act (the Eco
Mark certification criteria are similar or stricter to/than the criteria of the Act inprinciple and can serve as a reference in procurement).

4. Basic principles of the guidelines
1) The relation with the “Guidelines on “bio-based plastics” in the Eco Markcertification criteria”
The Working Group discussed the details of the “Guidelines on bio-attributed plastics
in the Eco Mark certification criteria” (the guidelines) based on the principles of theexisting guidelines on bio-based plastics. To avoid confusion for business operators andcompanies due to different principles present in guidelines, the Working Group decided
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to develop new guidelines (the guidelines) separately.
2) Types of plastics covered by the guidelines
The present Eco Mark certification criteria cover bio-based PE, PET, PLA and PTT that
produced by fermentation and confirmed to be effective for reducing environmental
impacts. It is difficult to produce bio-based PP and PA (nylon) used for food containers
and packaging material and bio-based polycarbonate (PC) and ABS used for electronic
devices.
Bio-attributed plastics covered by the guidelines are produced by the same
manufacturing method (cracking, etc.) as fossil-based plastic. Therefore, it is possible
to produce a wide variety of bio-attributed general-purpose plastics (PP, PE, PET, PVC
and PS) and engineering plastics (PA, ABS, etc.). A report says that bio-based PP has ahigher effects for reducing environmental impacts than fossil PP as bio-based PP is
made from biomass such as used cooking oil and wood by-products through the same
manufacturing processes as those of fossil PP after the biomass is turned into bio
naphtha 3 . The “Roadmap for Bioplastics Introduction” mentions the mass balance
approach and suggests the “introduction of bio-based plastics appropriate for individual
categories of plastic products” without limitations of types of non-biodegradable biobased plastics. In light of this, the guidelines do not limit the types of applicable bioattributed plastics.
3) Biodegradability in the guidelines
Biodegradable plastics are subject to the certification criteria for Eco Mark productcategory No.141 “Biodegradable Plastic Products Version 1.” Bio-attributed plastics
may be produced from biodegradable plastics, but biodegradability is not included in
the criteria items under the guidelines.
4) Considerations in the application of the guidelines to individual product categories
The guidelines define criteria items common to all product categories including theattribution factor, traceability, sustainability, the effects for reducing environmental
impacts, claims, etc. of bio-attributed plastics. The Eco Mark is operated as Type I
environmental labeling program that assesses the environmental aspect of the whole
product life cycle comprehensively. In this regard, some of Eco Mark certification
criteria required to meet for individual product categories are not covered by theguidelines, including the restriction of use of hazardous substances, ease ofdegradability after use and ease of recycling. To apply the guidelines to definecertification criteria for particular product categories, additional criteria items may be
defined according to the characteristics of product categories considering the3

https://www.researchgate.net/publication/339484276_Environmental_life_cycle_assessment_of_
polypropylene_made_from_used_cooking_oil

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replacement for the existing fossil plastics used in the product categories (material
properties, the use of additives, increase/decrease of plastic content, etc.), ease ofdegradability after use and ease of recycling.
5. Discussions on individual criteria items
4-1-1. Criteria for the attribution factor and traceability of biomass feedstock(1) The attribution factor of characteristics of biomass feedstock to plastic shall meetthe criteria. The attribution factor shall be managed under the mass balance
approach and maintained after a relevant product has obtained an Eco Markcertification.

* The attribution factor of characteristics of biomass feedstock will be defined byCriteria Development Committee and Criteria Review Committee forindividual product categories in consideration of the criteria for bio-based
content in products under the existing bio-based plastics certification schemes.
Examples of Eco Mark product categories (certification criteria) subject to thediscussion on the setting of attribution factor of characteristics of biomass
feedstock
Product categories
Plastic products (general)
Stationery
Household commodity
Waste bags, films
Fiber productsContainers
and Molded products, etc.
packaging material
Laminated packaging material[Certification Procedure]
An applicant shall submit a certificate that states the attribution factor ofcharacteristics of biomass feedstock to plastic and supportive documents(product specifications, etc.).
Manufacturers and other relevant parties in the supply chain of the plastics
shall calculate and record all inputs of biomass feedstocks attributed to theplastics and their production outputs and the attribution factors throughout
a year (including supportive documents) to maintain the attribution factorsof biomass feedstocks at an appropriate level. An applicant shall also submit
any evidence documents of third-party audit or certification (an internationalsustainability certification for plastics, etc.) (submit an audit report, a copyof certificate, etc.). An applicant shall retain the evidence documents for five
years.

1) How to assure that all biomass inputs are converted into (contained in) products(yield, etc.)?
In the discussion on the guidelines, there was a comment on the importance of
establishing a scheme to confirm all biomass inputs are converted into (contained in)
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products. If a biomass material has a chemical yield greatly different from a fossilbased one, it is inappropriate that a finished product is attributed to the characteristicsof the biomass material under the mass balance approach with the same chemical yieldas that of fossil-based one. Such an attribution of characteristics is undesirable in thatit damages the confidence of consumers and the public in the mass balance approachand that prevents the widespread use of mass balance approach. Therefore, it isimportant to establish a scheme under which the Eco Mark plays a role of strengthening
the confidence in the mass balance approach.
In the general manufacturing process of the plastics covered by the guidelines (PE, PP,etc.), used cooking oil, etc. is turned into bio naphtha through hydrogenation anddecarbonization. Then, bio naphtha produced is mixed with fossil naphtha, subjected to
cracking and processed into ethylene and propylene. After the mixing of bio and fossil
naphtha, the mixture undergoes the same manufacturing processes as those for fossilbased plastics. There was a comment that scientific verification should be conducted tosee if bio naphtha exhibits the same behavior as fossil naphtha in the cracking process.
Some international certification schemes (such as ISCC 4) for managing and assuring
sustainability of biomass and renewable materials in manufacturing supply chains(including those under the mass balance approach) require calculation of attribution of
biomass materials in consideration of their inputs and yields (calculated from the actual
yields in the past three months) and production outputs.
Naphtha, a refined product charged into the cracking process is mixture with a boiling
range of 30 ℃ to 180 ℃, a similar range to gasoline. On the other hand, light naphtha,
distillate from crude oil charged into a naphtha cracker for producing ethylene, has aboiling range of 35 ℃ to 80 ℃. As an example of bio naphtha composition available tothe public, UPM Biofuels “BIOVERNO NAPHTHA 5” is described as mixture with aboiling range of 40 ℃ to 190 ℃, “rich in saturated hydrocarbons with a carbon number
range from C6 to C10” in the Safety Data Sheet. However, the published data is just an
example of boiling range of bio naphtha. According to the discussion at the Working
Group, there may be wide variations in a boiling range and the differences of distillation
properties of naphtha should be assessed based on the comparison of distillation
temperature. Raw materials for a naphtha cracker are required to meet strict
specifications in procurement and those out-of-specifications are never accepted. Crudeoil-based naphtha also has slight differences in properties depending on its sources anda boiling range for distillation and this may cause slight variations in production yields.
This means that bio naphtha meeting the procurement specifications never causes anextreme loss of production yields and that the variations in production yields shouldInternational Sustainability and Carbon Certification offers a certification system for managing and assuring thesustainability of biomass and renewable resources in global supply chains (ISCC PLUS program). https://www.isccsystem.org/
5 https://www.upmbiofuels.com/siteassets/documents/upm-bioverno-naphtha-safety-datasheet-2022-en.pdf
4

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fall within a similar range to oil-based naphtha. Off-gas produced in the cracking
process, such as methane and ethane, is used as fuel at plants and helps reduce CO 2
emissions as a whole.
From the discussions above, there seem to be no major differences in production yields
between fossil-based and bio-based feedstocks as far as they are used in the cracking
process. It was concluded that the criteria should be defined assuming that both typesof feedstocks are converted into products at a similar yield. If any findings different
from the present assumption are obtained from scientific verification on the bio
naphtha behavior during cracking, the Working Group will discuss the revision of thecriteria.
2) How to define the criteria for attribution factor
To define the standard attribution factor of biomass feedstock, it is not appropriate totreat bio-attributed plastics in the same manner as bio-based plastics in terms of the“effects for reducing environmental impacts” and the “superiority or inferiority inenvironmental values.” In the present Eco Mark certification system, the criteria forthe content of recycled- and bio-based plastics is defined from the same perspectives.
To ensure bio-based plastics will replace with as many fossil plastics as possible in thesociety, it is necessary to define the standard attribution factor of bio-attributed plastics
from a strategic viewpoint considering technological limitations (the upper limit ofcontent in products, ease of manufacturing, limitations of use) and cost/pricelimitations. In defining the standard attribution factor, considerations should also begiven not to prevent the widespread use of bio-based plastics.
<Technological considerations>(1) The upper limit of plastic content in products
In the Eco Mark certification system, the content criteria are defined for individual
product categories considering general ingredients and their content in products. For
example, laminated packaging material, in the category of containers and packaging
material, is a multi-layered film

consisted of multiple ingredients and bio-attributed

plastics can be used easily for some layers and not for others for manufacturing reasons.
The guidelines will define the upper limit of attribution of biomass material withreference to the content criteria for bio-based plastics.
(2) Ease of manufacturing and the limitations of use
Recycled plastics have more limitations than fossil-based plastics in durability,
properties, safety and hygiene (the requirements by the Food Sanitation Act, etc.) andthose limitations are considered in defining the content criteria for recycled plastics for
Eco Mark certification. Bio-attributed plastics, on the other hand, are similar to fossil-

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based plastics in properties and performance for use and have no particular limitationsin processing and use depending on the difference in the attribution factor.
(3) Assumption of partial attribution of characteristics of biomass feedstocks
Taking bio-based PET (PET mixed with biomass in the manufacturing process) as an
example, ethylene glycol, an ingredient accounting for 31% of the molecular structureis derived from biomass sources. For products assuming the use of polyester (PET) suchas clothing, the criteria for the content of bio-based synthetic polymer are eased fromthose for general applications (molded products) of 25% or more to 10% or more. As canbe seen from the example of bio-attributed PET, the partial attribution of biomass
characteristics assumes that either of monomers of plastic are attributed to thecharacteristics. However, the plastic bottle industry is striving to offer 100-percent biobased PET bottles, and therefore, the Eco Mark Office will not define the criteria for
attribution factor to PET on the assumption of “partial attribution of biomass
characteristics.”<Costs and prices>
To define the criteria, considerations should be given to capital investment, rawmaterial costs and manufacturing costs. For capital investment, bio-based plastics areproduced with dedicated equipment. A certain amount of capital investment is needed
to construct a plant even on a relatively small scale. Bio-attributed plastics, on theother hand, require new installation and/or renovation of equipment, but can beproduced with that for fossil-based plastics after the cracking process. This saves
capital investment and allows mass production.
According to a source, the price of bio-based PE is approximately three times as highas that of fossil-based PE6. The prices of bio-attributed PE, PP and other plastics are
estimated to be two to three times as high as oil-based naphtha 7 although no specificinformation is available. Bio naphtha is offered at a higher price than fossil naphtha.
The prices of biomass feedstocks are passed onto products attributed to them, not tothose with no content of biomass feedstocks. The price of bio naphtha varies in relation
to that of bio diesel as bio naphtha is produced from used cooking oil as by-products ofbio diesel. The price of bio diesel is influenced by the EU policies. The demand for bio
diesel is expanding with the soaring crude oil prices and the global trend toward
decarbonization. Accordingly, it is expected that the price of bio naphtha will not dropsoon.
Some plastics such as PE are offered in the forms of bio-based and bio-attributed
plastics. If business operators want to produce PE from biomass, they choose either of
http://www.env.go.jp/recycle/plastic/bio/pdf/bioplasticRoadmap_210329.pdf
Bio naphtha speeds up the Japan's first attempt by Mitsui Chemicals to achieve a carbon neutr alsociety and production of bio-based plastics - Japan Chemical News
6
7

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bio-based or bio-attributed form considering ease of manufacturing, ease ofunderstanding for consumers and the difference in price between them. On the other
hand, such bio-based PP actually using biomass materials is not available on thecurrent market. Business operators which want to produce PP from biomass offer bioattributed PP. At the discussion at the Working Group, there was a comment that bioattributed plastics should be offered at reasonable prices toward wide acceptance in thesociety (business operators and consumers) and that the criteria that promote rapid
expansion of use should be defined. Toward the achievement of carbon neutral society
by 2050, plastic waste should be reprocessed into new plastic products to the extent
possible (through material recycling or circular chemical recycling) and most of newly
developed plastics should be derived from biomass sources. The mass balance approach
serves as a production management method in a transition toward the achievement ofcarbon neutral society by 2050 and considerations should be given to facilitate
development of bio-based plastics.
In the report of the 38th Central Environment Council, Subcommittee for Recycling
Society, the Ministry of the Environment (on August 5, 2021), “(1) Basic principles on
recycling waste plastics” described the outlook for “Further widespread use of bio-based
plastics.” According to the outlook, “In 2050, after the innovation scenario is achieved,around 2.5 million tons of bio-based plastics will be used in the society (assuming 2.5
million tons of biomass sources will be used to produce plastics), and, in a transitionary
period toward the full-fledged introduction of bio-based plastics, bio-attributed PP, PE
and other general-purpose plastics managed under the mass balance approach will
come into widespread use ahead of bio-based plastics.” Eco Mark is expected to play arole in facilitating the move.
The attribution factor of characteristics of biomass feedstock will be defined by Criteria
Development Committee and Criteria Review Committee for individual productcategories in consideration of the criteria for bio-based content in products under the
existing bio-based plastics certification schemes.
Examples of criteria for bio-based content in plastic products
Product categories
Plastic products (general)
Stationery,
householdcommodity
Waste bags, films
Fiber productsContainers
andpackagingmaterial

Moldedproducts, etc.
Laminatedpackagingmaterial

Eco Markcertification
criteria for biobased content inplastic products

Japan Organics
Recycling
Association
Biomass MarkJapan
BioPlastics
Association
Biomassbased plastics

RSB
Advanced
Product

ISCC
PLUS,
REDcert2

25% ormore

Biobasedcontentor
reductionof usageof fossilbased
content:
25% ormore

Nonedefined

25% or more
25% ormore*
25% or more

Bio-based
content
10% or more

10% or more

*In the form of plant-based synthetic fiber

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3) How to manage inputs and outputs of biomass feedstocks and attribute theircharacteristics to products properly
The key point of mass balance approach is to manage inputs of biomass feedstocks andproduction outputs (and yields) at every stage in a supply chain for a certain period andensure that products are attributed to the characteristics of biomass feedstocks
properly. This efforts build the confidence of consumers and society in the mass balance
approach and products attributed to the characteristics of biomass feedstocks andpromotes the widespread use of bio-attributed plastics. International sustainability
certification scheme (ISCC, RSB8 and REDcert9) have basic principles of attribution
under the mass balance approach as follows:
・ The attribution amount is calculated based on the inputs, the outputs and the yield
for a defined period.
・ Attribution can be made to products within the same product group only.
・ Only products that can be produced physically and chemically are attributed tobiomass feedstocks used in production .
・ Attribution is made within a single site in principle (a certification scheme may
accommodate manufacturing at multiple sites by a single operator if those sites
have obtained certification and manage the attribution amount).
・ Attribution of the characteristics of biomass feedstocks cannot be made to products
in duplicate.
If both bio-based and fossil-based materials are used in production, the loss of
production has a bio-based content according to the input. Therefore, it is necessary
under the guidelines to deduct a bio-based content in production loss in calculating theattribution of biomass feedstocks to products. If no attribution is made to production
loss accordingly for the reason that the yield has declined substantially, morecharacteristics of biomass feedstocks are given to products than they are actually.
Making proper attribution is important to facilitate the use of mass balance approach.
The same holds true for off-gas reused for power generation. If a relevant product has
obtained an international certification, the rule may apply instead. To maintain acertificate of any international sustainability certification scheme, certified companies
are required to calculate and record inputs of biomass feedstocks, production outputs
and the attribution amount of characteristics of biomass feedstocks in manufacturing
processes at every stage throughout supply chains and undergo regular audits. Under
the ISCC PLUS certification scheme, audit reports of certified companies are publishedon the ISCC website and certified companies are required to submit a Sustainable
Declaration (SD) that describes the attribution amount, etc. for every business

8

The Round Table for Sustainable Biomass (RSB) runs a certification program with the aim of facilitating thewidespread adoption of social and environmental requirements to ensure sustainable bio fuel production.
https://rsb.org/
9 A kind of voluntary certification scheme run under the Renewable Energy Directive (RED), EU. REDcert 2 is acertification scheme for chemical products made from bio-based and recycled materials. https://www.redcert.org/en/

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transaction.
In Japan, no management methods and no certification schemes under the massbalance approach have been established yet. No government guidelines andinstructions have been available yet. On the other hand, ISCC PLUS and otherinternational certification schemes are operated overseas. Under such a situation, it ispremature for Eco Mark Office to develop its own certification scheme. At the discussion
on the guidelines, the Working Group decided to use third-party audits and the existing
international certification schemes in a transitionary period until a consensus will bebuilt on management under the mass balance approach in Japan.
It is desirable to adopt an Eco Mark-own certification system that matches with thebusiness practice and supply chains unique to Japan and that offers credibility andrationality in a well-balanced manner. Eco Mark Office will continue to discuss the
adoption of its own certification system in line with the future discussions in Japan andgovernment guidelines.
A public comment was given to Eco Mark Office that the requirement for third-party
certification should be eliminated after the processes in which the characteristics ofbiomass feedstocks are attributed to products. It is appropriate, for example, if relevantbusiness operators (a brand owner, etc.) have agreed in writing that re-attribution will
not be made after a forming process. At actual certification audits, however, theattribution method and acquisition of certification is assessed according to the rules of
relevant certification schemes and the third-party auditors to which business operators
submit their evidences. It should be noted that, in this context, relevant certification
schemes are not limited to those listed for explanation in the guidelines.
ISCC and some certification schemes cover substances other than organic compounds
such as ammonia. Accordingly, the guidelines define bio-attributed plastics as “plastics
that are produced from organic compounds derived from biomass materials(hydrocarbons, fatty acid, alcohol, etc.) mixed with fossil-based materials in the
manufacturing process and that are attributed to the biomass materials under the massbalance approach” (see “3. Terms and definitions).

4-1-2. Sustainability criteria for biomass supply chains(2) Biomass mixed into plastic as raw material shall meet the requirements ofAppendix 1 “Sustainability checklist of bio-attributed plastics (raw resin)” andthe supply chains of the biomass shall be identified. If the biomass has
undergone third-party audit or certification for sustainability (an internationalsustainability certification for plastics, etc.), the result of audit or certification
may be submitted as evidence instead of Appendix 1[Certification Procedure]
An applicant shall submit documents on the source of biomass material (a21/29

producing area, a generation process of waste and by-products, etc.), a
manufacturing flowchart of plastic (describe the name of manufacturers ofchemical raw materials, fundamental chemicals (monomers), polymers, etc.),
and checklists or an evidence of international certificate.

4) Sustainability of biomass materials
To facilitate the reduction of environmental impacts and build the social confidence inbio-based and bio-attributed plastics, it is essential that biomass materials are used in
production in a sustainable and appropriate manner. To this end, it is important to keep
track of biomass feedstocks throughout their life cycle (a producing area, a generation
process of waste and by-products, etc.) and understand manufacturing processes ofplastics.
For bio-based plastics, cultivation sustainability (particularly from an environmental
perspective) and traceability of materials is checked by “Sustainability checklist of biobased plastics” assuming the use of plant-based materials such as sugar cane and corn.
Bio-attributed plastics, on the other hand, are made from a variety of materials suchas used cooking oil, wood by-products (tall oil), food waste, waste wood and vegetable
oil and all of those materials may not be covered by the above-mentioned checklist. The
Working Group discussed the development of checklist for bio-attributed plastics inconsideration of the types of biomass materials listed in the “Basic Plan for the
Advancement of Use of Biomass (September 2016) 10” as shown in the table below:

Annual amount ofgeneration (*2)

The current usage
rate

Target usage
rage toward2025

Livestock excreta

About 81 million tons

About 87%

About 90%

Sewage sludge

About 78 million tons

About 63% (*3)

About 85%

Black liquor

About 13 million tons

About 100%

About 100%

Paper

About 27 million tons

About 81%

About 85%

Food waste

About 17 million tons

About 24%

About 40%

Residues from woodprocessing plants, etc.

About06.4 million tons

About 97%

About 97%

Wooden residues fromconstruction sites

About05 million tons

About 94%

About 95%

About 13 million tons

About 32%

About 45%

About08 million tons

About 9%About 30% or
moreType of biomass

Waste

Unusedmaterial

Non-food agricultural
products (except fertilizing
materials)

Logging residues*1 The annual amount of generation and the usage rate are calculated based on statistics and data as of March
2016 (some data include estimated figures).
*2 The figures of black liquor, residues from wood processing plants and logging residues arecalculated in dry weight. The figures of other biomass materials are calculated in wet weight.
*3 The usage rate of sewage sludge has declined after the occurrence of Great East Japan Earthquake.

10

https://www.maff.go.jp/j/shokusan/biomass/attach/pdf/index-4.pdf

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For sustainability assessment, there are 16 voluntary schemes recognized by the EU
Committee under the Renewable Energy Directive (RED) including ISCC, RSB andREDcert. In particular, the certification schemes (including the sustainability aspect)of ISCC PLUS, RSB Advanced Products and REDcert 2 cover plastic products and theacquisition of the certification by several Japanese companies has been reported to EcoMark Office. For sustainability assessment items under these certification schemes,
the International Trade Center (ITC) offers the “Standard Map 11,” a tool to compare
various sustainability standards and “Blauer Engel (Blue Angel),” a Type I ecolabel
program in Germany publishes a comparison report 12 on the website. According to the
ITC’s comparison tool, ISCC PLUS, RSB Advanced Products and REDcert2 have a wide
range of similar sustainability standards broadly with minor differences in details.
Under each scheme, biomass materials are assessed for sustainability mainly at the
point of cultivation (residues, by-products and waste are assessed from the point ofgeneration or collection in accordance with the RED). Under the guidelines, a certificate
of any applicable international sustainability certification system proves theconformance with the Eco Mark certification checklist. The applicable internationalsustainability certification schemes include ISCC PLUS, RSB Advanced Products andREDcert2 for example and are not limited based on the differences with each other. On
the other hand, the checklist for bio-based plastics for Eco Mark certification was
prepared bearing plants such as sugar cane and corn as materials in mind and does notinclude “protection of peatland,” a requirement by ISCC and other schemes. The
Working Group decided to add “protection of peatland” to the checklist because bioattributed plastics may contain vegetable oil as ingredients. The products that had
obtained Eco Mark certification before the addition of “protection of peatland” areexempt from the application until the expiry date of the current certificate. The
Working Group also decided that the principles of RED applied to the management ofresidues, by-products and waste and that regulatory compliance was assessed at the
point of production of monomer and plastics respectively.

4-1-3. Criteria for effects for reducing environmental impacts(3) It shall be confirmed through life cycle assessment (LCA) that the bio-attributed
plastic does not cause an increase of GHG emissions (in terms of CO 2) throughout
the product life cycle in comparison with fossil-based one to replace with.
[Certification Procedure]
An applicant shall submit the result of LCA conducted by a third-party. (Anapplicant shall provide the LCA result and the calculation conditions. If theapplicant has undergone LCA under an international sustainability
1112

https://standardsmap.org/
https://www.umweltbundesamt.de/sites/default/files/medien/1410/publikationen/2019 -08-19_texte_872019_be_biomassenutzung_uebergreifende-aspekte.pdf

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certification scheme for plastics, it may submit the data instead. The applicant
may submit an academic paper published on a journal as an evidence as longas the same materials and/or manufacturing processes (sites) are mentioned
in the paper as those used for the product applied for certification.)5) Effects of bio-attributed plastics for reducing environmental impacts
The “Guidelines on bio-based plastics in the Eco Mark certification criteria” apply tobio-based PE, PET, PLA and PTT, which were confirmed to have the effects for reducing
environmental impacts from the results of typical life cycle assessment of each plastic.
The guidelines on bio-based plastics require an applicant to submit the assessment
result of the effects for reducing environmental impacts of relevant bio-based plastics
in comparison with fossil-based plastics to replace with. The assessment ofenvironmental effects throughout a product life cycle is described in the “Guidelines onplastic product design” (Public Notice No.1 by the Cabinet Office, Ministry of Finance,
Ministry of Health, Labour and Welfare, Ministry of Agriculture, Forestry and
Fisheries, Ministry of Economy, Trade and Industry, Ministry of Land, Infrastructure,
Transport and Tourism on January 19, 2022) issued based on the “Act on Promotion of
Resource Circulation for Plastics” with effect from April 2022.
“Guidelines on plastic product design”(3) Product life cycle assessment
In plastic product design, it is important to assess environmental effects
throughout a product life cycle from manufacturing to transport, logistics, sales,
provision, use, disposal, recovery and disposal.
It is desirable to assess environmental impacts and other effects throughout aproduct life cycle in a comprehensive manner in terms of safety, functionality andother performance required for plastic products depending on their use and therequirements of (1) and (2) with a possible trade-off between these factors in mind.
It is desirable to conduct product life cycle assessment in accordance with ISO
14040 (2006) or JIS Q 14040 (2010) and ISO 14044 (2006) or JIS Q 14044 (2010).
Note from Eco Mark Office: (1) and (2) mentioned in the above text describe<Structure> and <Material> of plastic products respectively.
3. Requirements to conform for design certification(1) Comprehensive assessment and disclosure of information
As part of efforts to facilitate plastic recycling, business operators engaged inplastic product design shall assess environmental impacts and other effects
throughout a product life cycle in a comprehensive manner on the items definedfor individual product categories in consideration of application of those plastic
products. Business operators shall disclose the assessment result and theprinciples on those recycling efforts that were decided rationally and voluntarily.
The guidelines apply to all types of bio-attributed plastics without limitations andrequire that any products applied for Eco Mark certification be effective for reducing
environmental impacts throughout their life cycle in comparison to those made fromfossil-based plastics to replace with. The Act on Promoting Green Procurement does not
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cover bio-attributed plastics. The Act on Promoting Green Procurement covers biobased plastics and requires that “products made from bio-based plastics be confirmed
to be effective for reducing environmental impacts including trade-off throughout theirlife cycle by third-party LCA experts based on quantitative, objective and scientificanalysis.” Accordingly, it is desirable under the guidelines that the effects for reducing
environmental impacts are calculated in a reliable manner to the extent possible.
For bio-attributed plastics, a limited number of LCA results are published on academic
journals. Some business operators disclose the effects of bio-attributed plastics for
reducing environmental impacts on their website, but a detailed calculation method is
not presented in some cases. At the discussion of the Working Group, there was acomment that the attribution of product to biomass characteristics is not enough as anevidence of reduction of CO2 emissions in the LCA calculation. According to thecomment, it is not enough, for example, to compare environmental impacts between biobased and fossil-based materials prior to the point of charge into a naphtha cracker. It
is necessary to compare environmental impacts between them “throughout a productlife cycle,” up to the point of plastic production as required by the criteria specified in
4-1-3 (3). In this regard, to present the real effects for reducing environmental impacts,a decline in environmental impacts should be shown by any means, even if it is a small
amount, through comparison of plastics production processes between using and notusing bio naphtha without making attribution of biomass characteristics under themass balance approach. Another issue pointed out in the discussion is the difficult ofobtaining data by tracing back a long supply chain up to procurement of materials.
Some international sustainability certification schemes mentioned above require theverification of GHG emissions throughout a product life cycle (Cradle to Grave). The
RSB has a certification requirement to reduce GHG emissions by 10 percent ascompared with the existing fossil-based plastics. The Working Group decided that the
RSB verification result can be used for Eco Mark certification if an applicant submit
the “Certification Evaluation Report” and the conditions for calculating GHG emissions
as an evidence. Under the ISCC and REDcert schemes, on the other hand, thecalculation of GHG emissions is an optional requirement for certification (notmandatory). If an applicant chooses the option and undergoes verification according to
the calculation rule, it may submit the verification result as an evidence to obtain Eco
Mark certification (in this case, the applicant is required to submit the comparison withfossil-based plastics and the calculation conditions in the same manner as thesubmission of RSB verification result).
On the basis of these discussions, the guidelines require an applicant for Eco Markcertification to submit a result of product life cycle assessment conducted by a thirdparty in accordance with ISO 14040 “Environmental management - Life cycle
assessment - Principles and framework” and ISO 14044 “Environmental management- Life cycle assessment – Requirements and guidelines.” Third-party assessment is
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intended to enhance transparency and reliability of the result and include RSB
verification results and joint studies and reviews with third-parties. An academic paper
published on a journal may also be submitted instead of those evidences as long as thesame materials and/or manufacturing processes (sites) are mentioned in the paper as
those used for the product applied for certification. If the scenario from the point of
production of bio-attributed plastic is the same as that for fossil-based one, an applicant
may submit an LCA result up to the point.
Bio-attributed plastics currently available on the market are made from used cooking
oil, wood by-products, etc. The EU Renewable Energy Directive (RED) classifies
renewable sources into residues, waste, etc. In line with the classification of RED, the
ISCC and other certification schemes require data “from the point of production” forresidues and by-products (the amount generated at the point of cultivation is ratedzero) and “the point of collection” for waste to conduct LCA, and the same applies to thechecklist for Eco Mark certification for bio-attributed plastics. Calculation is required
at every stage of product life cycle from cultivation and harvest of raw materials,
disposal to recycling in principle. If bio-attributed plastics undergo the same processes
as those of fossil-based plastics from the point of production of plastics, the calculation
result from cultivation and harvest to production of plastics may be accepted.
The guidelines will be revised in line with national and international standards if any
method to calculate the effects for reducing environmental impacts under the massbalance approach is presented.
<Reference> ISCC / RSB / REDcert standards for calculating GHG emissions
ISCC PLUS
ISCC PLUS Version 3.3: https://www.iscc-system.org/wp-content/uploads/2022/02/ISCC-

PLUS_V3.3_20082021_final_JA_FIN_NEU2.pdf
ISCC EU 205 Greenhouse Gas Emissions: https://www.iscc-system.org/wpcontent/uploads/2021/06/ISCC_EU_205_Greenhouse-Gas-Emissions-v4.0.pdf
ISCC PLUS 205-01 GHG Emission Requirements: https://www.iscc-system.org/wpcontent/uploads/2017/02/ISCC_PLUS_205_01_GHG-Emission-Requirements.pdf
RSB Advanced Products
RSB Standard for Advanced Products(Non-energy use) (RSB-STD-02-001) Version 2.0:
https://rsb.org/wp-content/uploads/2018/12/18-12-11_RSB-STD-02-001-v2.0-RSB-Standardfor-Advanced-Products.pdf
RSB GHG Calculation Methodology (RSB-STD-01-003-01) Version 2.3 : https://rsb.org/wpcontent/uploads/2020/06/RSB-STD-01-003-01-RSB-GHG-Calculation-Methodology-v2.3.pdf
REDcert2
REDcert2 "Scheme principles for the certification of sustainable material flows in thechemical industry“ Version: RC² 1.1：
https://www.redcert.org/images/SG_RC%C2%B2C_Sustainablematerialflows_Vers.1.1.pdf
REDcert EU Scheme principles for GHG calculation:
https://www.redcert.org/images/SP_EU_GHG_Vers.05.pdf

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4-1-4. Criteria for labeling on products containing bio-attributed plastics(4) Eco Mark shall be provided on products, packages, catalogues and the website inaccordance with the “Environmental Labeling Guidelines” (Ministry of theEnvironment) and the following instructions:1) Necessary information shall be provided on products, etc. to make the reason
for Eco Mark certification known to consumers properly.
Example: “This product has a content of bio-attributed plastics of XX percent.”[Examples of unacceptable claims]
Avoid phrases that may mislead consumers into believing that the productactually contains biomass material:・Phrases suggesting that the product contains biomass material, for example,“Use” and “Contain” biomass material
・The content of bio-based synthetic polymer XX%
・Bio-based content XX%
2) An applicant shall assure that it does not make a claim for the content of biobased plastics in products that are not attributed to biomass characteristics
in a single product category managed under the mass balance approach.
If a single product (or a molecular structure) is consisted of a material
managed under the mass balance approach and other materials that actuallycontaine bio-based plastics, the claims for those materials shall be madeseparately (not making a claim of them together).
*Example 1 Manufacturing a multilayer film consisting of a bio-attributed
polystyrene film and a bio-based polyethylene film.
Example 2 Manufacturing PET by using bio-based ethylene glycol and bioattributed terephthalic acid

[Certification Procedure]
An applicant shall submit a text, etc. of environmental claims. For the
instruction 2), an applicant shall submit a statement of assurance.

6) Environmental claims and provision of information for users and consumers
The Working Group discussed how to indicate the use of bio-attributed plastics in Eco Markcertified products (an environmental claim) on their packages, catalogues and the website.

As of September 2022, no instructions and guidelines are provided by the governmentand relevant organizations on how to make an environmental claim for bio-attributed
plastics under the mass balance approach. In the transition toward the widespread useof bio-attributed plastics in the Japanese market, there is a risk of greenwashingcaused by labels misleading consumers in distinguishing between bio-attributed andbio-based plastics. To address this, it is important to provide correct information for
consumers and help them understand and distinguish those types of plastics properly.
To make an environmental claim for bio-attributed plastics in Japan, it is a precondition
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to comply with the “Environmental Labeling Guidelines” required by the Ministry of
the Environment. With reference to the papers published by Plastics Europe andinternational certification schemes such as ISCC, Eco Mark Office will define criteria
items with which manufacturers must comply to provide users and consumers withcorrect information about the bio-content under the mass balance approach. A precise
expression, for example, “This product contains plastics with XX percent of attributionof biomass characteristics” is acceptable. On the other hand, expressions suggestingthat biomass materials were actually added to produce a product, for example, “Thisproduct contains/is comprised of/blended with biomass material” are prohibited bycertification schemes and organizations that accept the mass balance approach, andtherefore, those expressions are not accepted in the Eco Mark certification (see the
ISCC’s rule on logos and claims shown below). The guidelines will be revised if theJapanese government and/or other organizations establish any guidelines onenvironmental claims under the mass balance approach.
If more biomass materials are charged at the cracking process in plastics production,
carbon from biomass materials may be detected by 14C content measurement inproducts that are not attributed to biomass characteristics in a single product category
managed under the mass balance approach. In this case, a claim of direct mixing of
biomass materials into those products is prohibited because the attribution of biocontent has been made to other products (to prevent making the attribution of biomass
characteristics in duplicate). If a single product (or a molecular structure) is consistedof bio-attributed material under the mass balance approach and bio-based material,
such as a multilayer film and products partially attributed to biomass material, it isrequired to make claims for those materials separately (not making a claim of them
together).
To gain widespread acceptance of the mass balance approach in the society, it isessential to provide correct and easy-to-understand information for business operatorsand consumers. In addition to claims on products, Eco Mark Office will make efforts topromote the understanding of mass balance approach in a correct manner incooperation with the national government and relevant organizations.
ISCC’s rule on logos and claims under the mass balance approach 13

Do’s

Don’ts✔

Claim can refer to the effort to sourcing ofsustainable raw material and must not referto the physical characteristics of the product:• “supports the production of”• “contributes to”• “product from certified sources on a massbalance basis / from mixed sources”• “investing in”
13

×Cannot reference physical productcharacteristics directly, e.g. a claim
regarding a bio-based content is not possible
as this claim would suggest that the productcontains bio-based material physically.
This product・ is coming from a sustainable/responsible

https://www.iscc-system.org/wp-content/uploads/2017/02/ISCC_208_Logos-and-Claims_1.1.pdf

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• “committing to”• “linked to”
Examples: ISCC compliant from mixed sources Support of responsible production in linewith ISCC requirements
 Support of ISCC certified production
 An equivalent amount of ISCC compliant
material has been sourced The required quantity of sustainable
material is certified according to ISCC
requirements
 By buying ISCC certified (feedstock),(company) supports sustainable (feedstock)farmingsource・ made from certified resources
・ based on renewable sources
・ 100% plant-based/bio-based・ 100% renewable
・ completely based on renewable sources
・ contains

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