Concern that EU waste-to-fuel plans could undermine recycling

Plans to include fuels made from non-renewable materials in the EU’s renewable energy plans could undermine recycling progress, according to a new policy briefing.

The policy briefing, entitled ‘Recycled Carbon Fuels in the Renewable Energy Directive’ and produced by Zero Waste Europe (ZWE), Bellona Europa and Rethink Plastic, was released today (16 June) and outlines concerns over the inclusion of ‘Recycled Carbon Fuels’ in the EU’s revised Renewable Energy Directive (REDII).

The REDII establishes a common framework for the promotion of energy from renewable sources in the electricity, heating, cooling and transport sectors for the 2021-2030 period.

Recycled Carbon Fuels – liquid or gaseous fuels derived from liquid or solid waste streams of non-renewable origin, which often include plastics, or from waste processing gas and exhaust gas of non-renewable origins – may be used by EU member states as part of renewable targets in the transport sector.

However, ZWE, Bellona Europa and Rethink Plastic contend that this will mean fuels derived from recyclable plastics could be promoted through the transport targets, thereby undermining recycling efforts.

The briefing claims that when municipal solid waste containing 65 per cent non biogenic waste, much of which is plastic, is turned into fuel, its emissions range between 52.6 grammes of carbon dioxide equivalent per MegaJoule (gCO2e/MJ) to 124.6gCO2/MJ, which increases the more non-renewable waste is included.

Where emissions reductions are achieved compared to conventional fuels, they range from 1-14 per cent, below those needed to achieve EU emissions reduction targets.

Furthermore, the authors of the briefing are concerned that the REDII gives ‘insufficient guarantee’ that recyclable plastics that should be recycled mechanically will not end up in mixed waste streams and used as fuels. That concern extends to the prospect that the use of waste-to-fuel technology could be used to achieve the 55 per cent plastic packaging recycling target for 2030 set by the EU Packaging and Packaging Waste Directive.

There are fears among the authors that establishment of waste-to-fuels infrastructure could lock in this technology and disincentivise the redesign of plastic products to be mechanically recyclable or designed for reuse as pursued by the EU’s Circular Economy Action Plan.

The use of Recycled Carbon Fuels would be regulated by EU sustainability rules, which are not expected to be finalised before the end of 2021. The briefing recommends that member states do not include Recycled Carbon Fuels in their national targets until a ‘proper evaluation of their environmental impact is made by 2021’.

The briefing calls on the European Commission to incorporate the following criteria into its assessment of Recycled Carbon Fuels:

• Greenhouse gas (GHG) emissions savings need to be at least 70 per cent compared to fossil fuels;
• GHG accounting related to these fuels must take into account emissions through all stages of the product lifecycle;
• Emissions avoided elsewhere in the system cannot be included in the calculation of GHG emission reductions;
• Energy inputs need to be counted in a similar way as electricity and fossil energy inputs are calculated for biofuels when determining GHG performance;
• CO2 reductions should not be counted as abatement twice under the EU Emissions Trading System and the transport sector; and
• Any potential support to Recycled Carbon Fuels needs to be fully in line with other environmental and climate policies.

Ana Šerdoner, Industry Policy Manager at Bellona Europa and author of the briefing, said: ”We need to start focusing on effective and scalable climate change solutions to transition to net-zero by 2050 – and plastic fuels don’t fit the bill. Burning plastic made from oil and gas at the back of the car will not help mitigate, but will exacerbate climate change.

“Claiming that turning fossil plastic into fossil fuels is a solution for climate change is part of a growing greenwashing trend in climate accounting. It’s very simple for industry to announce support for net zero climate goals when they simultaneously attempt to dismantle basic accounting of the climate damaging emissions they and their products cause.”

Janek Vahk, Zero Waste Europe's Climate, Energy and Air Pollution Programme Coordinator, said: "The current crisis is creating an opportunity for real change. Yet, plastic-to-fuel is encouraging reliance on our current linear system, convincing consumers that this waste can be “recycled” when in fact it is getting burned. That's not the idea of a cycle.”

You can read the policy briefing, ‘Recycled Carbon Fuels in the Renewable Energy Directive’ on the Rethink Plastic website.