Last week, the U.S. Plastics Pact published its PCR Certification Principles. The principles recognize that, as Pact Activators work toward their 30% recycled material use targets (part of Target 4 of the U.S. Pact Roadmap), there is a need for increased transparency and standardization of accounting. The use of robust certification programs can provide this, and a consistent approach to assessment of certification programs will help level the playing field and ensure that measurement of PCR use is aligned among Plastics Pact Activators.
The principles are especially noteworthy because they reflect a growing alignment among U.S. industry players about what constitutes a good certification scheme. Over the past several years, there have been a number of certification programs in use in North America, but with different attributes that have led to confusion about what brands should be looking for. Product-level certifications verify the amount of recycled content in one product, such as resin pellets, but don’t carry through the supply chain to verify that the final product made from those pellets still contains the specified level of recycled materials. Other certification programs, including RMS, recognize the importance of a certified chain of custody to verify the provenance of recycled materials and ensure that claims are accurately transmitted to the finished product. Meanwhile, there is growing recognition that mass balance allocation is needed to enable the use of certain types of chemically recycled materials, but different certification programs take different approaches to key aspects, such as the treatment of co-produced fuels, and book and claim accounting methods are entirely new to the recycled plastics space.
This alignment around certification principles has value beyond the specific commitments of Pact Activators. Increasingly, we have seen policy instruments, such as EPR schemes and minimum recycled content standards, that make reference to use of certified recycled materials, often with specifics left up to the rulemaking process. As the packaging industry coalesces around shared principles for good certification programs, policymakers can look to these principles for direction.
Let’s take a look at the specific features the principles promote and what brands should be considering when selecting a certification method.
Chain of Custody
The principles state that certifications should provide a chain-of-custody certification – meaning every participant in the supply chain must be certified. Chain of custody is defined by the ISO 22095 standard and is the most robust method of ensuring claims made by the brands and retailers. Product-level certifications without chain of custody can’t provide the same level of assurance since auditing does not follow recycled material as it transforms towards an end product. That’s why a continuous and transparent chain of custody of certified material forms the backbone of the RMS.
Transparency and Best Practices
The principles create a consensus for industry best practices for any third party certification program. They set a threshold for meaningful, diverse, and equitable stakeholder participation. They also set an expectation for transparency in scheme decision making and operations, such as having accessible complaint and appeal mechanisms and requiring independent verification by an accredited third-party certification body. These principles are not specific to recycled material certifications, but reflect established best practices for standards recognized by organizations such as ISEAL and the U.S. EPA, and are among the practices followed by RMS as part of the development and maintenance of our standard.
Mass Balance
A major resolution provided by the Certification Principles is the agreement on key criteria for mass balance allocation, which has been increasingly recognized as an important tool for tracking both mechanically and chemically recycled materials. Mass balance is a powerful accounting application but currently includes a diversity of approaches. Importantly, the principles state that mass balance accounting methods must consider fuel outputs as a yield loss in the recycling process. Not all standards in use today follow this approach, but given that conversion of waste to fuel does not meet the U.S. Plastics Pact definition of material recycling, this is essential to ensure that recycled claims from materials converted to fuel aren’t inappropriately allocated to other products. Because the RMS also does not recognize waste-to-fuel conversion as recycling, we align with the Plastics Pact. The RMS encourages proportional allocation, while being among the first standards to establish free allocation with a fuel exclusion for chemical recycling processes.
Book & Claim Certificates
One of the most progressive principles is the recognition of book and claim accounting (also called environmental commodities or plastic credits) as a tool to invest in recycling infrastructure and build the supply of recycled materials brands will ultimately need to meet their targets. Through Attributes of Recycled Content (ARCs), RMS offers the only book and claim system focused specifically on plastic recycling in North America. ARCs can be generated by reprocessors of recycled plastic materials, and are tied specifically to new investments in recycling infrastructure, and are tracked in a secure registry to avoid double-counting of claims. They provide recyclers with direct investments that help them compete with virgin materials and build new recycling infrastructure, while at the same time giving brands the opportunity to move faster toward their recycled material goals than can be supported by their direct supply chain, and ultimately help build the system that will supply recycled materials in the future.
By providing some guardrails around the use of certifications to measure progress toward recycled material goals, the U.S. Plastics Pact is helping to ensure that brands can consistently and reliably track the recycled materials used in their supply chains. At this time, RMS is the only certification that enables companies to employ all of the chain of custody models approved by the U.S. Plastics Pact: average content claims backed by robust chain of custody, mass balance with fuel exclusion, and book and claim. This makes the use of RMS-certified materials a great strategy for Pact Activators that need an “all of the above” approach to meet their 2025 goals.