Minimum requirements
for plastic waste recovery

You are invited to comment and support

This is an initiative of the PREVENT Waste Alliance's
 "Core Working Group on Plastic Waste Recovery"

These minimum requirements represent a verified metric tonne of post-consumer plastic that has been recovered and delivered to a better end destination than where it came from. 

Only a small portion  of the plastic packaging placed into national markets is collected and recycled by the private and informal sectors, especially in developing countries. Plastic recovery projects allow for funds to be raised from private corporations, philanthropic institutions, multilateral and bilateral development finance institutions, as well as NGOs. These funds will pay for and help scale up local plastic waste management services, usually in developing countries. In exchange for payment of a waste collection service, the service provider may have to prove that it has indeed collected the payable tonnes of used plastic. The minimum requirements below describe the bare minimum terms and conditions of this proof of a plastic waste recovery service. The PREVENT Core Group on Plastic Recovery encourages local service providers to set even higher standards than the minimum requirements described below, allowing these organizations to attract more funds per tonne of plastic waste collected and managed.

The principles and minimum requirements:

I. Transparency

II. Legal Compliance

III. Impact


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Next Steps:

All comments and suggestions will be reviewed by the Core Group on Verfied Plastic Recovery of the Prevent waste Alliance, and used to improve this framework for plastic waste recovery. We will publish the comments (anonymously) once we have received several. 

COMMENTS


Dec 10, 2023


The Plastic Footprint Network’s response to the consultation will focus on the following 3 key elements:

1. Harmonization of definitions & methodologies

2. Scope of the VPU instrument and of the consultation

3. Transparency in impact assessment and claims


As the Plastic Footprint Network, our mission revolves around unifying the framework for measuring plastic leakage into a single, science-based methodology for organizations to accurately assess the environmental impact of their plastic use and build robust mitigation plans that align not only with common target setting but also proportional to the required collective actions needed to bring plastic pollution to an end.

As such, we strongly advocate that common/harmonized definitions, metrics, methodologies and guidance aligned with the harmonized and updated plastic footprint methodology published by the Network and reviewed by its scientific committee be used to assess the impact of interventions aimed at mitigating plastic pollution. A new terminology and set of guidelines for plastic credits will only enhance the fragmentation we see in the field and further add confusion to the marketplace, instead of driving harmonization and credibility. The proposed minimum requirements should build on existing methodologies and guidelines for best practice.


Furthermore, we fear that the scope of the proposed ‘VPU’ minimum requirements is too constrained and would benefit from covering more than collection activities. We suggest the scope of the instrument and the consultation to also entail recycling and upstream solutions that critically need funding. Additionally, the objective and positioning of the VPU instrument among other actors is not clear.


We advocate for transparency as a key principle for environmental impact assessment. Under Principle I. Transparency, there is no mention of results being made publicly available (item #1). Financial and material flows should be publicly traceable (item #2). Accordingly, under III. Impact assessment, the methodology used for additionality (item #6) should be publicly disclosed. Likewise, the third objective of the VPU instrument “agreeing on guidelines for environmental claims that are made in relation to these services and projects” should ensure that claims made are clear, transparent, accessible, accurate, conservative, verifiable and comparable.


We invite the Prevent Waste Alliance to engage and participate in the Plastic Footprint Network scientific working groups that inform the strategy to set target and develop mitigation actions in line with the latest scientific evidence. This work will lead the publication of a Corporate Accountability Framework which will guide businesses on how to tackle their plastic strategy, starting with a strong baseline assessment, followed by the alignment of their targets with either the future Treaty Targets or with zero pollution by 2040, and subsequently followed by a mitigation plan which actions should align with the evidence of collective efforts needed to bring plastic pollution to zero. Corporations supporting actions outside their value chain is key to bridging the gap of investments needed in upstream and downstream interventions.

The PFN also strongly believes that developing new claims / any claim is at this stage premature and risks derailing any collective action; the PFN recommends to focus on the short term on aligning all actors around a strong mitigation framework that truly builds circular infrastructure.


The plastic footprint methodology is published and publicly available under https://www.plasticfootprint.earth/assessment-methodology/.


The Vision Statement for Corporate Accountability developed with PFN Advisory Committee (EMF, WWF, WEF’s GPAP, Pew, WBCSD) and CDP is published under https://www.plasticfootprint.earth/target-setting-and-mitigation/


We welcome engagement and further discussion on the topic. contact@plasticfootprint.earth



December 8   

We appreciate the PREVENT Waste Alliance’s initiative to develop minimum requirements for plastic waste recovery. We have several comments and observations on the proposed framework, that have been categorized as general and specific comments below:


General comments:


1. The scope of minimum requirements is limited only to collection activities. Circularity can be achieved only when waste is collected and appropriately managed or recycled; we know that a funding gap exists for both collection and recycling activities. We propose expanding the scope of the framework to include recycling activities as well.  


2. We don’t think a comparison with carbon markets is well placed – plastic and carbon are two different externalities and should not be compared or conflated. Concepts such as baseline and additionality are important requirements for plastics as well, as they demonstrate net environmental benefit and a real reduction in plastic waste in the environment. Further, some of the challenges of carbon markets as outlined here may not be applicable to plastic credits. For example, existing programs like Verra’s Plastic Program already include environmental and social safeguards as mandatory requirements to ensure that project activities do not lead to any negative impacts on the natural environment or local communities.  


3. We agree that there is a need to harmonize multiple standards to enable comparability and exclude poor quality and non-additional projects from being credited. However, these minimum requirements currently stand as too broad without clear definitions or references, and may therefore amplify the risks currently being experienced or anticipated in the market. Verra’s Plastic Program goes above and beyond these minimum requirements, incorporates specific mandatory environment and social safeguards and is backed by a rigorous development and governance process, all of which ensure a high integrity framework is applied to certify plastic waste collection and recycling projects.  


One example of lack of detail with the proposed framework is in regards the delivery of  environmental and social impacts to the informal sector. Currently there is no mention of specific labor, health & safety, and environmental safeguards that a VPU must adhere to in order to realize its anticipated impact.  


4. The framework’s current proposal may cause oversimplification, risking a lack of rigor applied to projects. While the goal should be to have inclusive and accessible methodologies, oversimplifying the processes, rules, and assessments minimizes the level of rigor needed to measure, monitor and verify the impact of plastic waste collection and recycling projects.  



Upon reviewing the proposed frameworks, we have specific comments and questions about the following elements:


1. Verification


- We would like to understand more about the verification of these services. Who qualifies as an “independent third party”? What would be the scope of their verification? What are the requirements for their accreditation? Would they verify that the project meets the different impact principles and requirements? If so, how?


- As an example, how would they verify that the project “is collecting a higher tonnage of plastic waste than would have been achieved in the absence of the services”? How would one verify “the service aims to minimize and mitigate unintended harm”? Generally, third-party verification requires a standard set of criteria to assess against. These minimum requirements don’t appear to go to the level of detail to allow for standardized verification.


- How would verification of the project’s adherence to these principles be revisited and revalidated over time?  


- Who will be responsible for approving the verification conducted by an independent third party?


2. VPUs:


- On the "Why" page there is a section that says: "This is neither a certification standard, nor a plastic credit standard, but a definition of a universal metrics for plastic waste recovery activities: Verified Plastic Recovery Units (VPU).  The VPU is a unit of measure upon which plastic credits and certification standards can be quantified and independently verified. From this starting point other requirements can be added to create specific standards.


--We would like to understand what this means. How would a standard be quantified and independently verified against the VPU?    


--What types of “specific standards” do you envision being created?  


- If a VPU is not a certification standard, nor a plastic credit standard, but a definition of a universal metric,” how do you perceive this metric being integrated into existing plastic credit standards?


3. End destination


- What is the definition of “delivered to a better end destination than where it came from?” If it was collected from land vs ocean/waterway, does this best end destination change?  


- Are there any studies you would rely on to ensure this requirement is followed when we are comparing specific technologies within a destination class, such as pyrolysis vs gasification? The minimum requirements must prescribe clear criteria for what “better” end destinations mean and how they will be assessed and compared.  


- Do the requirements to minimize and mitigate unintended social or environmental harm apply to the end destinations? We recognize that many negative externalities result from the processing of the collected plastic waste, not the collection service itself. Thus, we think end destinations must be held to requirements to comply with national laws and mitigate any negative social or environmental risks.


4. Terminology section: In general, the definitions need to be more specific and supported with clear references from where they have been taken or adapted.  


- Open burning vs incineration needs to be differentiated as they are not interchangeable


- The current definition of non-commercially recyclable plastic waste is too broad and subjective in nature. It needs to be more specific to avoid misuse. How would one determine if plastic is not commercially recyclable? What is the definition of a price that is “too low” and transport costs that are “too high”?


- Were there independent studies or research that informed the definition of “plastic credits”?  Surely, we need a harmonized definition, but this one does not accurately reflect what the mechanism is or what it stands for.


- The definition of “working conditions” is extremely broad and several terms used therein need definitions of their own, such as “minimum wage.”


- We identified an inconsistency in the “managed landfill” and “dumpsite” definition. If a “simple managed landfill” is only fenced, wouldn’t there still be run-off and leachate leaks, thus making it an “open dumpsite” under that definition?


5. The third objective of the minimum requirements is “agreeing on guidelines environmental claims that are made about these services and projects.” What guidelines are being proposed? Are specific claims being evaluated for consideration in the minimum requirements? Are the claims for project developers generating VPUs, buyers of VPUs, or both?  


6. The “Why” page says “our industry should adopt methodologies, rules, and assessments no more complicated than they need to be and focus on the most important components required to meet VPU requirements.” What methods, rules, and assessments will be required to meet the VPU requirements?  


7. One of the objectives of these requirements is “Agreeing on a framework of minimum requirements for all actors, including service providers on the ground.” However, it is not clear who “all actors” are. What actors are included within the scope of a plastic recovery activity?  


To conclude, while we appreciate the thought behind creating minimum requirements, we emphasize leveraging existing and established frameworks such as Verra’s Plastic Program to ensure consistency in the way impact of these activities is measured, verified and reported. Creating yet another new framework is counterproductive to our harmonization efforts, and may create more ambiguity and confusion in market that is still nascent.  



29 Nov 2023 

A standard needs to work for all members. This puts at a disadvantage high value plastic waste collection operations with co-benefits on oceans, livelihoods, infrastructure, and climate. The high value plastic ecosystem has to work in this crediting scheme as well as it can help channel financing of the low value plastic collection.

The co-benefit featured in the minimum requirements is lacking. This is not enough to scale towards a system change.

There is no proof of alignment to the 11 best practices outlined by The Circular Initiative on crediting and certification schemes.


24 Nov 2023 

I think that the concept of "mass flow" should be considered.

Every recycling process or every treatment process has a process yeld and also generates waste (ex. a recycling process that has a 90% yeld don´t treat or recycle 100% of one ton of waste) - to conclude my point I think the approach should be material and specifi mass oriented to avoid green washing.

This approach could also already prepare the market for the new technologies that are coming (that can treat also mixed waste, and without a mass balance the tracking of the value chain will be very hard to certify).


23 Nov 2023
Before plastic every thing is reused, the needed action is ban plastic bags, as per waste hierarchy prevention is prefered than reduse and reuse.


22 Nov 2023 

1) There is a need to define what is a waste stream in the framework of regulations for waste, rcycling, circular economy. Operators in waste management and designers for recycling are using this term (Waste stream) and it must have the same meaning.

2) Destination class and its levels must be clearly defined, including samples in the definition.

3) There is a need to define what non-commercially recyclable plastic waste mean. Credits for these non-recyclable (for a given period) and hard to recycle plastics must be separatelly allocated.

4) The waste have been sorted and the plastics separated / disassmbled to recover....

5) The service aims to minimize and mitigate unintended harm, socially or environmentally, resulting from its activities and from the nature of the treated plastic wastes (DNSH criteria must be applied)

6) The service aims to keep the value of the plastics materials under its activities


22 Nov 2023 

Recycling of Multi layer packaging film waste need focus. we have patented technology to separate layers of MLP waste which make it easier to recycle into good quality PCR.


19 Nov 2023 

Suggestion to complement item 6: "The service collects a higher tonnage of plastic waste than would have been achieved in the absence of this service, (CONSIDERING THAT ADEQUATE/MINIMUM SOCIAL CONDITIONS ARE ALREADY IN PLACE)."

Otherwise environmental additionality requirements could help perpetuating unfair social conditions.


17 Nov 2023 

Can you please also add or provide differentiation or detail on Collection Credits v/s Recycling Credits since these are the 2 different types of credits that can be generated through a recovery project.

I believe the minimum requirement approach provides lots of relief to waste management agencies which current is unable to access the finance through plastic credit mechanism. Congratulations for this great initiative.


Few suggestions I would like to share:


Double Counting: Since there is no common project platform it may become difficult to keep a check on double counting.

As a suggestion, there can be an online open ledger or registry where all the programs can list their transactions through a standard format. This can help us track all the credits transactions under one place and double counting can be mitigated.


Project Ratings: Recovery projects can be provided ratings based on the impact, compliance level and social value it creates through the activities. This can help develop a roadmap for the projects as well as can help WMA's improve their projects. Credits from high rated projects may sell at a higher cost and this may also regulate the price of the credits to some level. I am open to discuss this in detail to arrive at a proof of concept.


31 Oct 2023  

In a glance, I found a little bit confusing that the VPU itself is only mentioned in the tab "Why", I think it should be introduced since the homepage about the minimum requirements.


30 Oct 2023 

1. First of all, the request was to review systems for plastics credits, which represent a landscape than what it now says, "plastics recovery projects." Plastics credits systems are a relatively new attempt to introduce digital traceability by essentially compensating private formal and informal recycling entrepreneurs for sharing information which is traditionally secret and private. This understanding of plastics credits is completely lost in the current wording.

2. Secondly the ambitions proposed are noble but not very practical or sensible; the specifics are politicised, full of implicit assumptions, and for my feeling are beyond naive in that they show a lack of understanding both of how the value chains work, and a naiveté about the ability of "us" to introduce changes in an industrial landscape whose commercial culture is 200+ years old. The specific way English is used is biased and far from neutral. Why (for example), do you use the politically charged "free market" and not the more neutral and descriptive standard description of the "private sector industrial value chains".

3. The term "non-commercially recyclable plastic waste" is misleading, non-specific and does not correspond to value chain understandings. I suggest you substitute a more neutral and accurate terminology such as "non-recyclable grades of plastic packaging, or recyclable grades that are difficult to market because of contamination, weak demand, difficult to achieve specifications, or other factors".

4. "The service ensures that waste now goes to the highest local ‘destination class’ compared to the waste’s source". For someone who has been working on recycling for 45 years, this sentence is not understandable. For one thing, if something is recyclable, it is not "waste", it is "materials." Secondly, the market drives where there is demand for grades of plastic having verifiable specifications, it is not up to the seller who will buy. If I understand the words quoted above, this would imply that the seller would be penalised for selling for the highest price or the closest-by demand. This is not realistic or fair or even moderately useful.

5. "The waste has been sorted to recover any recyclable materials, whenever feasible and socially or environmentally acceptable, and not harmful to workers". Most recyclables collected for sale are not collected mixed, so the concept of sorting is not likely to be relevant. The operational term is more likely to be "extracted" or "separately collected", whereas "sorting" describes a physical process where materials are mixed first, and then sorting is required. 6. Furthermore, feasibility and social and environmental acceptability are subjective concepts, and this formulation suggests that the recyclers themselves do not have the right to make decisions about what is needed to market the materials.

7. Finally, in the quote above, the word "workers" implies an assumption that the sellers are employed, and not in control of the process. While this may be the case, it is an empirical question and putting it into a guideline is disadvantaging the independent entrepreneurs by denying them the autonomy to pursue their entrepreneurial goals in the manner that they themselves choose and find best.

8. "The service aims to improve the working conditions for any informal collectors engaged". There are two problems here. Most recovery of recyclables is not a "service" in the sense that waste management is a service of removal. The effect may be similar, but in a waste removal service, the value is in the clean empty space left behind after removal. In recycling collection, in contrast, the value is in the materials themselves and can be earned only when they are sold.

9. The wording deprives collectors of recyclables of their agency to choose to collect and valorise recyclables. Who is the agent that "aims to improve the working conditions?" What if they prefer to have higher income and choose to work under informal and less clean or favourable conditions? For example, Red Nica members interviewed in 2018 complained that they were earning much less than previously in order to have health insurance -- and that they themselves had not had the opportunity to choose this change in situation.

10. These minimum requirements imply that the private (informal or formal) recycling entrepreneurs are not eligible for plastics credits, which disenfranchises many people and creates subsidised competition that can put them out of business. Unless the recyclers themselves are given key choices, such globalisation efforts, regardless of how well-meaning they are, violate the recyclers' agency and autonomy and go against the principle "Nothing about us without us." Much more (evidence of) consultation would make this initiative stronger and more likely to succeed in the short, middle, and long term.