Two very different claims

    Mass balance or physical recycled content: which one do you actually need?

    Two suppliers quote you 30% recycled content. One ships pellets that physically contain 30% recycled polymer. The other ships fossil-based pellets with a certificate allocating a recycled attribute. Both are legal claims today; they are not the same risk. Here is how to tell them apart and decide.

    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 pelletMechanical: recycled polymer · Mass balance: allocated attribute
    VerificationMechanical: physical traceability · Mass balance: chain-of-custody audit
    Typical schemesEuCertPlast, RecyClass · ISCC PLUS
    Food contactRestricted for most mechanical polyolefin · Feasible chemically
    Regulatory exposureLow · Depends on the pending Art. 7(8) allocation rules
    Cost vs virginUsually below virgin · Usually above virgin

    Mass balance FAQ

    Does mass-balance recycled content count under PPWR?

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    Content derived from qualifying post-consumer waste can count, but the allocation methodology is exactly what the pending Article 7(8) delegated act must define. Treat the claimable share as provisional until it is published.

    Is chemical recycling worse than mechanical?

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    No — it is different. It handles streams mechanical recycling cannot and reaches food-contact quality, but it costs more and its claimable content depends on accounting rules rather than physical presence.

    Can I mix both in one part?

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    Yes, and many converters do. Keep the two sources documented separately so you can show which share is physical if the rules on allocation tighten.

    Build a physical recycled baseline

    Start with 20% off your first order of ISCC PLUS certified post-consumer PolyAl and see how much declarable, physically present recycled content you can add to your part.

    Claim my 20% discount