Chemical recycling is essential for processing plastics that are difficult or impossible to recycle mechanically. The mass balance model enables the integration of chemically recycled feedstock into existing production systems—ensuring traceability and regulatory compliance without the need for physically separate infrastructure.

However, the absence of finalized EU rules on how to calculate recycled content through mass balance is creating uncertainty, slowing down investment and technological development in both European and Croatian chemical sectors.

Without a harmonized and transparent EU-wide approach, companies cannot accurately calculate recycled content, making investment planning difficult. Limiting the use of mass balance could reduce the availability of recycled plastics, increase costs, and hurt the competitiveness of European industry—without delivering better environmental outcomes. Building recycling infrastructure and processes can take years. Clear, supportive regulation now will unlock future capacity and innovation.

AmCham Recommendations:

• Recognize mass balance across all EU regulations, directives, and incentive schemes to encourage circular economy practices.
• Allow flexibility in applying the approach to support wide adoption and market access.
• Integrate mass balance into life cycle assessments (LCA) and product environmental footprint (PEF) metrics to ensure a full understanding of environmental benefits.

This model tracks the flow of materials through a supply chain where physical segregation is not feasible. Already used in sustainable sourcing schemes (e.g., FSC, fair trade), mass balance ensures the volume of certified input matches certified output, validated through ISO standards and third-party audits.

Adopting a flexible and inclusive mass balance model will promote investment, innovation, and the decarbonization of the plastics and chemical industries in Croatia and across the EU. It is a vital step toward a circular, carbon-neutral economy that meets environmental targets without sacrificing industrial competitiveness.