The recent methodological proposal on lifecycle assessments (LCAs) by the Joint Research Centre (JRC), the scientific body of the European Commission, will create additional barriers to the transition away from fossil feedstocks and towards these alternative feedstocks.
- A new report from the Renewable Carbon Initiative of Nova-Institute has argued that the methodology does not exist in a vacuum. “Some methodological aspects remain unresolved and, more importantly, the policy landscape in which the methodology is implemented creates systemic disadvantages for innovative industries using alternative feedstocks.”
- The JRC Plastics LCA method is a detailed scientific approach that aims to ensure that all environmental impacts are considered when assessing alternative feedstocks.
Key Challenges and Disparities: The report has pointed out a number of flaws:
- The environmental footprint of fossil feedstock is likely to be underestimated, not transparent and lacks regional differentiation. Given that fossil feedstocks are the root and main cause of climate change, this is a critical issue that deserves more attention.
- Renewable/Alternative feedstocks are much more critically evaluated than fossil feedstocks. There is a discrepancy of scrutiny between the alternative/renewable feedstocks and the current main feedstock – fossil crude oil.
- There is a long-standing inconsistency in methodological approach and regulatory support between energy (e.g., based on RED) and material use (e.g., based on JRC Plastics LCA) of alternative materials, which tends to favour energy use over material use. This is in stark contrast to the EU’s waste hierarchy, cascading use principles and circular economy objectives.
- Biogenic/Atmospheric carbon uptake cannot be transparently visualised in PEF and the JRC Plastics LCA method at the factory gate, to clearly illustrate the benefits of renewable carbon for sustainable carbon cycles.
- The methodology does not consider the interface of environmental sustainability assessment, policy design and the influence of the JRC on the European policy landscape. The JRC should facilitate future-oriented policy design, e.g., by including scenario analysis or sensitivity assessment.
- Despite its scientific rigour, the methodology is still criticised as unbalanced in certain aspects. This includes debates on land use change, data reporting, indirect effects, biodiversity, carbon sequestration and the comparison of mature and immature systems.
The background: In 2021, the JRC published a study titled ‘LCA of alternative feedstocks for plastic products’, commonly referred to as the JRC Plastics LCA Method. Alternative feedstocks refer to the three feedstocks: biomass, CO2 utilisation and recycling.
- The study describes a methodology developed by the JRC to assess the environmental performance of alternative feedstocks, potentially in comparison with fossil-based plastic products. While the methodology presents a detailed scientific approach, it has faced significant criticism from various stakeholders, mainly from the bio-based sector, even eliciting responses from the JRC.
- This RCI report—' Non-level playing field for renewable materials vs. fossil in Life Cycles Assessments’—aims to provide additional context, highlighting potential issues that might arise with implementation of the JRC Plastics LCA methodology.
The way forward: The RCI has developed the following recommendations to meet these needs:
- Investigate the environmental impact of fossil feedstock at least at the same level of detail as the alternative feedstocks.
- Require the same proof, sourcing demands and data provision of all feedstocks.
- Enable comparisons of novel and established products.
- Establish a level-playing field in LCA methodology between energy and material use.
- Acknowledge the value of renewable carbon uptake in cradle-to-gate approaches.
- Consider the policy interface and landscape of developed methodologies.
- Develop future scenarios or add sensitivity analysis.
- Develop concepts to reflect and incorporate positive environmental aspects.
