1. How each one works
In mechanical recycling, post-consumer waste is sorted, washed, dried and pelletised. What you receive is the recycled material. In chemical recycling with mass balance, waste is converted to a feedstock, injected into a cracker alongside fossil feedstock, and the recycled attribute is allocated to a share of the resulting polymer according to a defined rule.
Chemical recycling solves real problems — it handles contaminated or mixed streams and can produce food-grade polyolefin. The controversy is not the technology, it is which allocation rule is used and how much recycled content it lets you claim.
- Mechanical: physical presence, verified by traceability
- Chemical + mass balance: allocation, verified by chain of custody
- Different allocation rules give very different claimable percentages
2. The regulatory risk gap
Whether, and how, mass-balance content counts under PPWR Article 7 depends on the pending delegated act. A rule change that tightens allocation could reduce a company's declarable content overnight, after the material has been bought and the packaging launched.
Physical recycled content has no such exposure: the polymer is in the part. If the calculation methodology changes, your evidence still holds.
- Mass-balance percentage can move with the rulebook
- Physical content is verifiable independently of the rulebook
- Consumer-protection rules (Directive (EU) 2024/825) also require substantiation
3. The pragmatic strategy
Most compliance teams end up with a hybrid: a physical mechanical baseline that is safe under any interpretation, topped up with allocated content where food contact or performance leaves no alternative. Your non-contact-sensitive packaging — the 35%/65% bracket — is exactly where a physical baseline is easiest and cheapest to build.
This page is general information about EU legislation, not legal advice. Check the consolidated text of each instrument and your national transposition before you rely on a figure.
- Physical baseline on non-contact-sensitive packaging and technical parts
- Allocated content reserved for food-contact formats that need it
- Document which model each declared percentage relies on
4. Where PolyAl fits
PolyAl is mechanically recycled, LDPE-dominated post-consumer polyolefin with an aluminium fraction. It is a physical recycled input for rigid, technical and transport applications, produced following UNE 53925:2026 and supplied in homogeneous 60-tonne batches, and it costs less than the virgin resin it displaces.
- Physical post-consumer content — counts under any allocation rule
- Density 950–1050 kg/m³, MFI 2–4 g/10 min, Vicat 90–100 °C
- Percentage blend on existing injection and extrusion lines
- ≈1.6 t CO₂e avoided per tonne replacing virgin polyolefin
Mass balance vs mechanical
| What is in the pellet | Mechanical: recycled polymer · Mass balance: allocated attribute |
|---|---|
| Verification | Mechanical: physical traceability · Mass balance: chain-of-custody audit |
| Typical schemes | EuCertPlast, RecyClass · ISCC PLUS |
| Food contact | Restricted for most mechanical polyolefin · Feasible chemically |
| Regulatory exposure | Low · Depends on the pending Art. 7(8) allocation rules |
| Cost vs virgin | Usually below virgin · Usually above virgin |