Ref. Ares(2024)3550805 - 16/05/2024
European
Commission
ELISA FERREIRA Rue de la Loi, 200
MEMBER OF THE EUROPEAN COMMISSION B-1049 Brussels
Tel. +32-2 295 10 50
COHESION AND REFORMS
[email protected]
Brussels
Ares(2024)3240818
Dear Minister,
Thank you for the letter dated 28 February 2024 (our ref. Ares(2024)1538168) in which you
ask for clarifications on the position of the Commission on the eligibility of projects of
pyrolysis in the context of plastics recycling within the Just Transition Fund (JTF) framework.
The question of chemical recycling of mixed plastics by pyrolysis processes is a complex and
technical issue that significantly differs in terms of processes, inputs and outputs, which are
difficult to compare.
We engaged in the analysis of the projects of pyrolysis in the context of plastics recycling
within the JTF framework in other Member States, to ensure a coherent approach. After
careful re-examination, my services concluded that pyrolysis of plastic waste can be admitted
under the following specific conditions:
• the pyrolysis oil output of a pyrolysis process is effectively used for the production of
high-quality recycled plastic;
• the pyrolysis process should fully reuse the recycled carbon fuel by-product as an
additional input in the pyrolysis process. On this basis, the recycled carbon fuel would
not count as a fossil fuel output.
I would like to recall the existing regulatory requirements regarding the do-no-significant-
harm principle and climate proofing, which also need to be respected.
I invite you to verify whether the project proposed by Viru Keemia Grupp (VKG) in Estonia
fulfils these conditions. The Commission services remain available to discuss further the
details.
Yours faithfully, Dy
ElisďFERREIRA
Mart Võrklaev
Minister of Finance
Ministry of Finance of the Republic of Estonia
[email protected]
Electronically signed on 16/05/2024 17:25 (UTC+02) in accordance with Article 11 of Commission Decision (EU) 2021/2121