NGO Policy Brief on Plastic to Fuels

The revised Renewable Energy Directive1 (REDII) establishes a common framework for the promotion of energy from renewable sources in the electricity, heating and cooling, and transport sectors for the 2021-2030 period.

As a part of the transport target, member states may choose to include “Recycled Carbon Fuels.”

The REDII includes liquid and gaseous fuels that are either produced from (a) liquid or solid waste streams of non-renewable origin or (b) from waste processing gas and exhaust gas of non-renewable origin as part of the definition of “recycled carbon fuels.”2

`This means that fuels derived from non-renewable waste streams (such as fossil wastes like plastic, rubber, gaseous wastes etc.) could be promoted through transport targets and support schemes, despite recognition that they cannot be considered to contribute to overall renewable energy targets.

This briefing highlights key concerns and recommendations to ensure that the REDII is implemented in a way that decarbonises transport fuels in a sustainable manner.


At this stage, the EU sustainability rules for Recycled Carbon Fuels haven’t been completely finalised.

The rules have been largely left to delegated acts, the last of which are due by the end of 2021.

Even though member states have the option to include Recycled Carbon Fuels into their national frameworks, this decision would be based on unknown criteria, and should not be made before the last delegated act is published.

We therefore recommend that member states do not include Recycled Carbon Fuels into their national targets until a proper evaluation of their environmental impact is made by 2021.

Despite their fossil origin, Recycled Carbon Fuels will still be evaluated in the Renewable Energy Directive under a delegated act.

In the context of this evaluation, we urge the European Commission to incorporate the following criteria into their assessment:

GHG emissions savings need to be at least 70% compared to fossil fuels; the same threshold is applied for Renewable Fuels of Non-Biological Origin (RFNBO).

  • a. To ensure that all of the emissions related to these fuels are taken into account, the GHG accounting must include all stages of the lifecycle of the product. This includes emissions related to energy inputs, production, and to the use or combustion of the fuel.3 Any use of resources must be thoroughly evaluated and ‘waste’ carbon flows to the atmosphere must not be discounted.
  • b. Emissions avoided elsewhere in the system cannot be included into the calculation of greenhouse gas emission reductions, since there is no proven causality between such emission reductions elsewhere in the system and the production of plastic fuels.
  • c. Energy inputs need to be counted in a similar way as electricity and fossil energy inputs are calculated for biofuels when determining their GHG performance. For electricity inputs similar provisions to those identified for RFNBO should be considered. Data which does not reflect real-life and real-time emissions in the system, such as predictions of the electricity in 2050, should not be included.
  • d. The CO2 reductions should not be counted as abatement twice (e.g. both under EU Emissions Trading System4 and the transport sector).

Any potential support to recycled carbon fuels needs to be fully in line with other environmental and climate policies (e.g. ensure that efforts to improve recycling are not jeopardised).

Given the unknown availability of the suitable waste streams, and potentially decreasing sources,5 these fuels will not be a game changer in transport emissions reductions, and are incompatible with a renewable and carbon free transportation system.

Read the policy brief

Policy brief plastic to fuel

Plastics in the Circular Economy

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12 June 2020 – Michigan Waste, Definitions, Greenpeace Malaysia, Tax and Voluntary Schemes, Shell Sustainable and Circular Plastics News

7 June 2020 – Industry 4.0, PEF, Perstorp, Timber and Chemical Recycling

5 June 2020 – Woodly, Plastic-Free Masks, Plastic Tax, UK & US Survey, Biodegradable War, Spain

3 June 2020 – Chemical Recycling Europe, Sustainability on Hold, Lyondellbasell, Ikea, Covestro

2 June 2020 – EU and Compostable Plastics, Biodegradable Additives, RWDC, Black Plastic, Oxo

1 June 2020 – Nestle, Denmark, Weather, Mitsui, Plastic Free July, Compost Shortage

31 May 2020 – Iowa, Zalando, Sabic, South Africa, Dow and Mondelez

29 May 2020 – China Scandal, Mitsubishi, Tyres, Flexible Packaging, Sargassum, Canada Lignin

27 May 2020 – SK Chemical, Borealis, Omya, Stora Enso, UPM, Dow and Good Natured


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