Renewable Carbon Initiative
RCI
The Renewable Carbon Initiative (RCI) was initiated by nova-Institute after observing the struggles of the chemical and plastics industry facing the enormous challenges in meeting the climate goals set by the European Union and the sustainability expectations held by societies around the globe.
ID: 683033243622-34
Lobbying Activity
Response to EU rules for the calculation and reporting of recycled content in single-use plastic bottles
19 Aug 2025
For a full version of our feedback, please refer to the attached file. RCI welcomes the draft Implementing Decision and supports the Commissions efforts to establish a methodology for MBA a key step to defossilise the chemical industry and promote sustainable carbon cycles. MBA is essential for shifting the chemical industry away from fossil feedstocks, not only for recycled materials in large-scale processes where full segregation is not feasible, but also for other renewable carbon feedstocks e.g. from biomass or CCU. By attributing such shares to outputs, MBA enables investment in renewable carbon and advanced recycling, diverting waste from incineration and landfill to circular uses. We commend the Commission for recognising MBA as a vital tool to track and attribute recycled content in chemical processes. The draft puts a strong emphasis on mass balance accounting and attributed amounts, ensuring transparent attribution of renewable feedstocks, accounting for process losses, and excluding fuel uses. The approach credits only recycled feedstock actually in products, preventing over-attribution and building trust. For single-use plastic bottles, the draft supports recycled content targets, including contact-sensitive applications, by enabling use of chemically recycled materials meeting food safety standards. RCI advocates for MBA principles to be extended beyond plastics to the wider chemical sector, harmonising rules across bio-based, CO-based, and recycled feedstocks to drive comprehensive carbon management. While the approach has commonalities with certification systems like ISCC PLUS, RSB, and REDcert, it will increase administrative burden and introduces restrictions compared to existing schemes, such as facility-based mass balance, stricter attribution rules, exclusion of credit transfer, and more calculation points than in current certification practice. Exchange and harmonisation with existing certifiers and industrial practice should be intensified to find an optimal balance that minimises administrative burden while ensuring a reliable methodology. In this context, there are concerns that the draft's fuel-use excluded approach and dilution rules (e.g., in Article 7(3)) may potentially discourage the renewable carbon transition, both for existing petrochemical assets (e.g. refineries) and new investments, EU competitiveness, and complementarity with mechanical recycling. This could result in a lack of level-playing field for recycled feedstocks by not fully leveraging existing EU assets, diverting investments from expanding new recycling capacities. RCI urges a further considerations to ensure the rules provide a feasible pathway for all sites, including existing ones, without deviating from core mass balance principles. In our attached feedback, we would like to highlight a few additional aspects that we believe warrant further consideration, relating to: - Paragraph (9) Clarification on Chemical Recycling Outputs - Article 1 (11) Harmonise the definition of Mass Balance Accounting with ISO 22095 - Article 1 (15) Consider widening the definition of Chemical Building Blocks - Article 7 Mass Balance Accounting a) clarify meaning in paragraph 4 b) further detail paragraph 4a c) double check and clarify to avoid exclusion of polymers Overall, RCI welcomes this draft as a foundation for enabling MBA in the EU. A swift adoption to secure demand for recycled content should be aimed for, but with further considerations on ensuring that the methodology properly enables the core of mass balance for all technologies and sites, in particular existing refineries. Investment in chemical and physical recycling will accelerate defossilisation and sustainable carbon cycles. RCI advocates extending MBA rules to all polymers and sectors, incentivising recycling over incineration where it makes sense, and enabling all types of renewable carbon from biomass, carbon capture, and recycling.
Read full responseResponse to Industrial Decarbonisation Accelerator Act
8 Jul 2025
Accelerating Renewable Carbon in Chemicals and Materials via the IDAA RCI strongly supports the goals of the IDAA to scale up decarbonisation and defossilisation technologies and to create lead markets for low-carbon products in energy-intensive industries. A key barrier is the implementation gap for defossilisation technologies (e.g., advanced CCU, sustainable biomass, chemical recycling) to go from pilot/demo to market scale, which requires substantial investment. Overcoming this demands targeted financial support, regulatory certainty, and market-pull mechanisms to bridge the implementation gap. The Act's emphasis on incentivising clean carbon feedstocks (CCU, biomass, recycling) is therefore crucial. To facilitate this transition, a comprehensive framework is required to provide for financial support for scaling technologies and adapting regulation to facilitate the uptake of renewable carbon. A high-level EU commitment to defossilisation would provide a clear vision and sense of accountability to inform and align all future EU policy. To stimulate demand for clean products, RCI recommends implementing effective policies for enhancing market competitiveness of renewable carbon in chemicals & derived materials. Instruments should be introduced to compensate for structural disadvantages vs. fossils, e.g. pricing fossil carbon or introducing phased quotas for renewable carbon. Such quotas should start near current market penetration and increase gradually to provide planning security and investment signals. They could be implemented via new regulation or by amending existing regulation viable near-term options are e.g. the PPWR and ELVR. Furthermore, embedding renewable carbon requirements within the ESPR and the DPP, supported by robust certification, would ensure transparency and traceability while enabling sustainable procurement. At the same time, embedded fossil carbon could be addressed via the EU ETS and CBAM or alternatively a dedicated extension of ETS via separate trading scheme for embedded carbon in products. The Acts objective to identify and promote priority projects and clusters aligns with RCIs call for improving local access to renewable carbon feedstocks and technologies. RCI recommends harmonising end-of-waste criteria, particularly for plastics and textiles, to facilitate the transition from waste to feedstock and maximise the circularity of European industries. Sustainability criteria for biomass are essential for nurturing European lead markets. These criteria provide assurance that utilised biomass and renewable carbon are sourced responsibly, but NEED to be combined with incentives to facilitate a shift away from fossil feedstocks. Without such criteria coupled with incentives, policy certainty needed for scale up and achieving net-zero targets is lacking. RCI recently published a position on this. A future EU low-carbon label must include not only carbon footprint data but also the origin of the feedstock. Complementary certifications like the recently launched "OK renewable" (which indicates non-fossil carbon share) can support transparency. Finally, regulatory frameworks must be developed similarly to energy and then balanced between energy and material carbon uses is necessary to avoid resource competition and unlock synergies. In summary, the IDAA should leverage RCI's recommendations: set ambitious renewable carbon/material quotas, provide financial/regulatory support for scale-up, ensure transparency via certification/labelling, and harmonise criteria. This will accelerate the transition to a sustainable, circular, and resilient industrial base while protecting competitiveness. Disclaimer: RCI members are a diverse group of companies, institutions and associations addressing the challenges of the transition to renewable carbon with different approaches. The opinions expressed in this feedback may not necessarily reflect the exact individual policies and views
Read full response8 Jul 2025
Accelerating Renewable Carbon in Chemicals/Materials via EU ETS Core Objective: Reform ETS to drive the transition from fossil to renewable carbon feedstocks (biogenic, captured CO, recycled) in chemicals and materials, ensuring improving circularity and tackling Scope 3 emissions. Integrate a Carbon Loop View in EU ETS: Embedded fossil carbon in chemicals and materials is currently not subject to ETS (because actual emissions mainly occur outside of ETS boundaries), while CO2 captured and used for chemicals and polymers is considered as emitted. The ETS should integrate a carbon loop view that acknowledges the benefits of capturing emissions to keep renewable carbon in a cycle and substitute virgin fossil carbon. Cover Embedded Fossil Carbon in ETS: MWI is a significant source of GHG emissions. It covers a major share of emissions from day-to-day products manufactured from chemicals and derived materials. These emissions are a viable point source for CCU. By inclusion of MWI (e.g. via Art. 30(7)), embedded fossil carbon in most products would be covered at emission-relevant end-of-life. To incentivise a shift away from fossil carbon along the entire value chain, a separate system focused on feedstock could alternatively be considered (e.g. CUTS). Designate CCU as Critical Transition Pathway: CCU must be designated as critical transition pathway for its systemic role in defossilisation of carbon-dependent industries. This involves recognition of the mechanism of substitution/avoided extraction, where CCU-based products mainly displace fossil-based counterparts. Sector-specific rules should be applied, but also build on fuel-centric standards harmonisation across frameworks remains essential. Discuss Point of Pricing of Captured and Utilised Emissions: Emissions that are captured and used can lead to another emission at end-of-life of the CCU-based product. ETS needs to ensure that no emission is unaccounted for, but also avoid double counting. A critical discussion is whether the original (but captured) emission (upstream) or the final emission (downstream) should be accounted and priced for. Upstream pricing incentivises capture; downstream pricing is consistent with life-cycle emissions accounting. RCI believes that payment by the end user provides the most elegant solution, adheres to the polluter pays principle, and helps to prevent circumvention via international trade. Further discussions will be required. Close the Implementation Gap by using ETS revenues to accelerate (virgin)-fossil free feedstocks: Future ETS regulations should ensure that revenues are reinvested in facilitating the transition of hard-to-abate sectors and innovative pathways away from the use of virgin fossil carbon. Scaling up alternative carbon feedstocks presents challenges and additional costs, and the accounting framework should be designed to help close the price gap between fossil-based products and their renewable alternatives. Improve CBAM to make it work for Embedded Carbon in Chemicals/Polymers: CBAM introduces a carbon tax on products manufactured outside Europe full enforcement for initial sectors is foreseen for 2026. To fully capture embedded carbon in the system, CBAM needs to also include chemicals and polymers, but this is a Herculean task in such a complex sector. ETS protection for sectors inadequately covered by CBAM should be maintained until demonstrated leakage prevention. We recommend inclusion only once pricing of embedded carbon is properly established in ETS to avoid possibilities of circumvention up- or downstream. Efforts on a globally harmonised CO2 pricing are also relevant. Disclaimer: RCI members are a diverse group of companies, institutions and associations addressing the challenges of the transition to renewable carbon with different approaches. The opinions expressed in this report/paper/press release may not necessarily reflect the exact individual policies and views of all RCI members.
Read full responseResponse to Towards a Circular, Regenerative and Competitive Bioeconomy
23 Jun 2025
The bioeconomy has a vital role in enabling defossilisation of chemicals & materials and achieving climate neutrality. Sustainable land management and biodiversity protection are needed to ensure sustainable supply of biomass. This needs inclusion of high-volume food and feed crops. We advocate integrating bioeconomy with CCU and recycling for a circular carbon economy. Strong political support is critical. The Bioeconomy is key for defossilisation of carbon-dependent sectors Reliance on fossil feedstock depletes limited resources, pollutes environment, drives climate change, harms biodiversity and creates dependencies. TA fundamental shift in how we source and use carbon is needed, with defossilisation as key lever. An overarching commitment on defossilisation provides for a flourishing bioeconomy There is agreement that defossilisation of carbon-dependent sectors is needed, but still pushback when enabling individual pillars. The EU successfully implemented high-level targets on climate change and energy, providing a clear framework for subsequent legislation, plans and mechanisms. A high-level commitment on defossilisation provides strong momentum for the bioeconomy. Market incentives preferably targets are key to create lead markets and facilitate upscaling The transition to bioeconomy faces barriers rooted in systemic challenges. Central is the lack of competitiveness from critical market failures: not pricing true environmental costs of fossils, inadequate pricing of GHG emissions, and underinvestment in scale-up. Market incentives bridge the implementation gap and create lead markets. We highlight quotas as effective approach to drive this transition. They are prescriptive, but impactful. Include first-generation biomass as essential part of sustainable feedstock supply First generation crops are often not considered a preferable, sustainable feedstock option, e.g. in aviation & shipping. We need to find a balance between extraction and sustainability/biodiversity, but focusing on biogenic waste streams and residues only will not be sufficient. Using primary agricultural crops does NOT in itself negatively impact on food security: Using agricultural biomass for non-food uses does not harm food security. On the contrary, growing sustainable, land-efficient food and feed crops can simultaneously provide biomass for food, feed, chemicals, materials and energy and have multiple benefits for local and global food security, climate mitigation and more. Establish sustainability criteria for biomass across use cases The lack of sustainability criteria for biomass in chemicals and derived materials creates inconsistencies between different use cases. Sustainability criteria need to be linked to incentives (e.g. quotas) to be effective. Clarify Sustainable Supply and Demand of Biomass and Captured Carbon Biomass is limited, with demand from several sectors food and feed, energy, fuels, chemicals and material. A clear understanding of sustainable supply and demand is needed. With BIC, e have published a scientific report on biomass availability and demand to facilitate this understanding. Incorporate Innovation of Agriculture and Forestry in the strategy Prospective policy-making should consider impact of innovation on sustainable biomass availability. The Vision for Agriculture and Food wants to leverage opportunities for farmers income, which chemicals and derived materials provides. Aim for a Balanced Regulatory Framework Between Energy and Materials Policy incentives for renewable carbon for chemicals and materials needs to create comparable impact to existing framework for energy & fuels to establish a level-playing field. Strengthen and Diversify Global Partnerships Through Trade of Renewable Carbon Number of fossil feedstock extractors is limited. Biomass is available from every region. The EU should look to create new or strengthen existing partnerships while diversifying their portfolio to reduce depend
Read full responseMeeting with Aurel Ciobanu-Dordea (Director Environment) and
18 Jun 2025 · Exchange of views on the Bioeconomy Strategy
Response to Delegated act on primarily used components under the Net-Zero Industry Act
20 Feb 2025
Thank you for the opportunity to provide feedback on the draft Net-Zero Industry Act (NZIA) delegated act. We strongly support the overall objectives of the NZIA to increase the EU's manufacturing capacity for net-zero technologies and to accelerate the clean energy transition. The Act's objective to ensure that the EU achieves a manufacturing capacity for net zero technologies sufficient to meet at least 40% of its annual deployment needs by 2030 is commendable and critical to achieving the EU's climate goals. While we appreciate the comprehensive approach taken in identifying end products and specific components for various net-zero technologies, we would like to suggest some additions and amendments to further strengthen the effectiveness of the legislation: Renewable carbon for the defossilisation of chemicals and materials: We propose adding a new category focused on renewable carbon for chemicals and derived materials. The chemical industry, like aviation, will need carbon feedstocks in the long term. Defossilisation of the chemical industry's carbon feedstock is critical to achieving net zero emissions. This category should include end products derived from biomass, carbon capture and recycling, recognising the importance of sustainable carbon sources in chemical manufacturing. CO2 utilisation technologies: While the current draft mentions thermochemical and electrochemical utilisation of CO2, we suggest including biotechnological/biochemical utilisation. This addition would cover a wider range of innovative CO2 utilisation technologies and support the development of bio-based solutions. Sustainable Alternative Fuel Technologies: We suggest broadening the scope to include carbon sources beyond biomass. In particular, this means that synthetic fuel (derived with green energy via carbon capture / waste carbon) should be considered as a potential feedstock for sustainable alternative fuels. This approach would be consistent with existing targets for Sustainable Aviation Fuels. Recycled carbon from fossil feedstocks: We understand the importance of avoiding fossil lock-in. However, we believe that the NZIA should not exclude recycled carbon from originally fossil feedstocks at this stage. While fossil feedstock is still in use, its capture and subsequent use should not be discouraged because the alternative would be its emission. Instead, we suggest developing an overarching agreement on defossilisation, similar to climate targets with milestones, to provide a more focused framework for phasing out fossil feedstocks without immediately excluding potentially beneficial transitional technologies. In its current form, this can potentially inhibit willingness to invest in carbon capture technologies. These proposals aim to improve the NZIA's comprehensive approach to net-zero technologies, while addressing key aspects of carbon use and circular economy principles. By incorporating these elements, the EU can further strengthen its position as a leader in clean technology manufacturing and accelerate the transition to a net-zero economy. We appreciate the EU's efforts to create a regulatory environment that enables the rapid expansion of clean technology manufacturing. The NZIA is an important step towards achieving climate neutrality by 2050, while improving the EU's competitiveness and creating quality jobs. We believe that these proposed additions will contribute to the effectiveness of the legislation in meeting its ambitious goals and ensuring a sustainable, resilient future for European industry.
Read full responseResponse to Carbon capture utilisation and storage deployment
31 Aug 2023
Using renewable carbon leads to emission reductions, even in short-term products and without storage A large degree of product-related emissions is caused by carbon embedded in the products, which is emitted at the end of life if the products are not collected and recycled. The use of all renewable carbon sources recycling, biomass and CO2 leads to emission reductions, even in short-term products and without storage, compared to fossil-based alternatives. When biomass or atmospheric CO2 is used for products, their end of life only emits CO2 which has been absorbed by the plants during the growth phase. Using recycled materials or CO2 captured from point sources substitutes units of fresh fossil resources which will therefore not enter the atmosphere. However, making all of these feedstocks usable requires energy and materials, which in turn produce CO2 emissions. The actual reduction in GHG emissions therefore has to be calculated using LCA and in comparison to the fossil counterpart. The results can be impressive and also apply to short-term products: Using biogenic or atmospheric carbon, reductions in GHG emissions of up to 90% are possible; and even using fossil CO2 from industrial and power plant exhaust gases, savings of up to 50% are still possible (using green hydrogen). For recycling, it can be up to 70%. For biomass, the GHG emission reduction is about 30 to 50% for cultivated biomass, for biogenic waste it can even be higher. (Kaiser et al 2022, Tonini et al 2021, Zuiderveen et al 2022) This is why we are convinced that the focus on long-term products and carbon dioxide removal for these technology options is not adequate for a strong climate policy. Even if a short-lived CCU product causes 30% to 90% GHG emission reduction instead of 100%, it can be a quickly valid business case and should receive support. The same applies to short-lived bio-based products. CCU enables a system where the future technosphere will act as long-term carbon storage: As the proportion of recycled materials increases in the future, the long-term carbon storage effect of CCU-based products will become significant, independent of the lifetime of the product and the storage duration. In essence, the technosphere will become an increasingly stable carbon pool. We therefore suggest to strengthen the initiative by introducing specific, quantified targets for capturing and utilising CO2 in parallel to the targets being discussed for the CCS sector. Carbon needs to be comprehensively managed from supply to emission As it currently stands, the initiative only addresses carbon when it is emitted to the air in form of CO2. In other words, it reduces carbon management to CO2 management. This fails to acknowledge that comprehensive carbon management (CCM) from source to emission has the potential to achieve much higher climate mitigation than only addressing it at end-of-pipe, while at the same time providing much-needed carbon feedstock to essential European industries. While emission mitigation in form of capture, storage and use is needed in some hard-to-abate sectors, it would be equally important to facilitate the shift towards a supply with non-fossil or as we call it renewable carbon for the chemical and material industries. Europe needs a CCM framework which is understood as an organised approach from feedstock to emission to gain the strategic advantages of CO2 emission reductions, secure feedstock supply for the industry and carbon removals. CCM organises the phasing out of carbon use in sectors where carbon is not needed long term, e.g. transport and energy. In sectors where carbon cannot be replaced, CCM organises the transition from fossil to sustainable, renewable carbon, e.g. for chemicals and materials, long-distance aviation and shipping. Here, CCM means establishing a circular economy that keeps carbon in a cycle through high recycling rates, carbon capture and utilisation (CCU) and the use of biogenic carbon.
Read full responseResponse to Ecodesign for Sustainable Products - Product priorities
10 May 2023
The Renewable Carbon Initiative and its members welcome the Commissions proposal on Ecodesign for Sustainable Products (ESPR) The proposal contains many issues that are in line with the RCIs objective to decrease the dependence on fossil carbon and speed up the transition to renewable carbon for all organic chemicals and materials. We would like to acknowledge that expanding the scope beyond energy-related products to other product groups is a step in the right direction to enable a more circular, efficient and sustainable economy. Against this background, the Renewable Carbon Initiative has compiled recommendations that aim to further develop the proposals potential: 1. Another horizontal criterion should be introduced putting renewable materials from sustainably sourced biomass and CO on equal footing with recycled content. Not doing so could cripple the efforts to reach net-zero by 2050 by continuing the reliance on fossil carbon and at the same time undermining the objectives proposed in the Communication on Sustainable Carbon Cycles. With regards to the sourcing of biomass, we support the application of the sustainability criteria established within the Renewable Energy Directive II (Art. 29 (2-7)), further referenced in the Taxonomy and the Policy Framework on bio-based, biodegradable and compostable plastics. 2. Currently, the European Commission is generally in favour of the Product Environmental Footprint to determine products' environmental footprints. As it stands, the production of bio-based or green CO2-derived products does not receive CO credits in the cradle-to-gate calculations despite extracting CO2 from the atmosphere. This disincentivises producers from using renewable materials, since they have no possibility to communicate this important property. In this regard, we suggest to include other scientifically validated means for the quantification of environmental impacts such as the internationally recognized ISO 14040 series, as currently stated in the proposed Green Claims Directive. 3. We would like to stress the importance of policy coherence in regulating the chemical sector and that redundancy should be avoided. The ESPR should complement the existing regulation regarding environmental and sustainability issues. Its current scope covers both end-products and intermediates, with the latter including chemicals, polymers and plastics. This carries the double danger of overregulating, since firstly, REACH already regulates chemicals regarding hazardousness and toxicity. And secondly, chemicals, plastics and polymers, will end up in the end-products also covered by the ESPR. It may be worthwhile to amend the scope of products in order to avoid double regulation of intermediaries and their end-use products. We propose to exclude chemicals from the intermediary products scope and focus on regulating the end-use applications which will force the value chains to adapt subsequently. 4. More clarity is needed regarding the nature of the proposed horizontal measures and how these are going to be applied. Are there going to be product specific horizontal measures? Are the measures going to be identical and mandatory for all products in scope of the ESPR? The nature and characteristics of the products in scope are greatly heterogenous which should be accounted for in the final horizontal measures and how these will be applied. Please see the attached document for more details.
Read full responseMeeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans), Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans)
24 Mar 2023 · EU green policies and their impact on using renewable carbon in the chemicals sector
Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans), Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans), Stefanie Hiesinger (Cabinet of Executive Vice-President Frans Timmermans)
28 Apr 2022 · European Green Deal and renewable carbon