MODULE 3: PROJECT REGISTRATION

Related PPRS Documents:

1. Project Preliminary Information Sheet (PPRS-OP-002-F1, version 2 - 01 March 2024)

2. PPRS Project Registration Terms and Conditions and PPRS Registry Terms of Use (Version 2 - 01 August 2023)

3. PPRS Validation and Verification Body (VVB) Application Form (PPRS-OP-002-F6, version 1 - 20 June 2023)

4. Terms and Conditions for PPRS VVBs (Version 1 - 20 June 2023)

5. PPRS Conformity Assessment Checklist

6. PPRS Compliance Monitoring and Review Checklist

CRITERIA AND REQUIREMENTS

PCX Solutions provides robust criteria and requirements that will further strengthen the credibility of PPRS Plastic Credits. These requirements provide a comprehensive framework within which the Project Partners are able to extensively describe their processes and environmental impact along with the co-benefits to the communities they operate in. The Project, reviewed through a third-party independent validation and verification body, shall demonstrate its compliance through documentation and data.

Projects shall be eligible plastic credit generators once they satisfy (through systems and supporting documentation) the following criteria:

CRITERIA 1: Sound Environmental Process

For a Project to be able to generate plastic credits, it is important that all collected plastic waste is diverted from nature and is instead repurposed through a properly managed facility. Processes using diverted post-consumer plastic should not cause adverse impacts on the environment (see Module 2, Environmental and Social Risk Management).

REQUIREMENT 1.1: The Project Partner shall provide documented information to demonstrate their Project’s process(es) and technology(ies). The following or similar evidence can be presented:

a. Scope of the Project – the Project Partner shall define the scope of its Project, including:

i. Facilities and locations included in the Project

ii. Post-consumer plastic waste feedstock types

iii. Partner entities and activities covered/roles

iv. End-of-Waste product/s or output/s

v. Estimated collection and processing capacity per annum

Note to VVBs: In cases where the Project scope encompasses numerous collection sites (greater than 3 sites with significant geographical distance from each other) and/ or multiple processing facilities/ units (greater than 2 processing facilities with significant geographical distance from each other), the VVB may use a non-statistical or risk-based sampling methodology to determine the sites to be physically inspected. Risk-based sampling methodology would mean prioritizing for inspection the sites that have historically collected and/or processed the most quantity of plastic waste, or sites that have higher risks in terms of social conflict, grievance or legal issues, or sites within or nearest areas of environmental importance or socio-economic impact. It is also important that where different processes exist within a project (i.e. processing can either be mechanical recycling or waste-to-energy), each type of processing is represented in the sample.

b. Process Flow Diagram – the Project Partner shall provide a visual representation of the end-to-end process from collection until End-of Waste processing in the form of a flow diagram, block diagram, or other schematic representation. This may be a significant input to the mass balance requirement in criteria 4.

c. Process Description – the Project Partner shall provide a detailed description of the process from collection until End-of-Waste processing. This should be consistent with the process flow diagram. Details such as the following should be included:

i. Standard Operating Procedures or similar for the process flow

ii. Collection methods and sources, feedstock condition requirements, per type of plastic waste feedstock

iii. Sorting, aggregation and storage method, equipment, facilities, and partners, per type of plastic waste feedstock

iv. Pre-processing activities, equipment, facilities, method, and partners, per type of plastic waste feedstock

v. End-of-Waste processing activities, equipment, facilities, method, and partners, per type of plastic waste feedstock

vi. Transportation/Logistics partners or arrangements

vii. Destination of End-of-Waste product

viii. Description of sub-processes for applicable pollution control methods, as applicable (e.g. wastewater treatment, air emissions treatment, hazardous and residual waste management, chemical and spill management, etc.)

d. Evidence for the use of Calibrated Equipment for weighing and other process-critical monitoring equipment

REQUIREMENT 1.2: The Project Partner shall provide documented information to show their identification, evaluation, monitoring, and compliance to their national/local environmental regulations. The VVB shall validate the required permits/licenses/clearances from the process description in requirement 1.1 and from the Project’s assessment of environmental risks, benefits, and impact as in requirement 1.3.

The following permits/licenses/certificates/clearances or the like may be provided, as applicable:

Environmental Compliance Certificate or environmental permit to operate the facility
Permit to operate air pollution sources and control facilities
Permit to discharge treated wastewater
Permit to extract/use water sources
Permit to use chemicals or for handling, storage, transport, and treatment of hazardous wastes
Air emissions tracking and analysis
Wastewater discharge quality analysis
Other certifications (e.g. ISO 9001 or ISO 14001), if available

Information collected from chemical analyses and their intended use shall be recently collected (within the past year) and shall be confirmed to be within acceptable levels based on local (environment regulators) guidance.

REQUIREMENT 1.3: The Project Partner shall provide documented information to show the assessment of relevant environmental risks and impacts and the applicable preventive/ mitigation measures in relation to Module 2, Safeguard Systems: Environmental and Social Risk Management. The following or similar evidence can be presented:

a. Environmental Risks, Benefits, and Impacts Register

b. Solid waste or by-product waste management plan, as applicable

c. Environmental management plans/procedures (or similar) for applicable impacts, including monitoring and continuous improvement programs

CRITERIA 2: Additionality and Ownership

To provide guidance on determining additionality, the PPRS considers two types of additionality: quantitative (tonnage) and qualitative (environment and socio-economic).

To determine quantitative additionality, the following baseline conditions shall be considered, depending on the extent of available data from either published government reports or similar reports by reputable organizations that provide these data and deemed acceptable by the country’s or regional government. The following regional baseline aspects can be used:

Current collection rate of the country (ideally more granular, i.e. state-, region-, province- or locality-wise, and/or by plastic waste type)
Current leakage or mismanaged plastic waste data of the country (ideally more granular, i.e. state-, region-, province- or locality-wise, and/or by plastic waste type)
Current recycling or material/ energy recovery rate (ideally more granular, i.e. state-, region-, province- or locality-wise, and/or by plastic waste type)

To determine qualitative additionality, the following environmental and socio-economic baseline conditions related to safeguard systems in module 2 shall be considered:

No forced or compulsory labor
No child labor
Minimum wages for direct employees or fair wages/earnings for indirect employees (note: In cases where there is no employee-employer relationship, a baseline income is required if the case to be presented for additionality is on the basis of incremental income)
Legally required employee benefits (e.g. healthcare, pension funds, etc.)
Working conditions that ensure basic provisions for health and safety for both direct and indirect employees or workers.

The Project Partners shall then establish and demonstrate the additionality of their Project compared to the regional baseline based on their respective processes:

REQUIREMENT 2.1.a: Quantitative Additionality

The Project Partner shall demonstrate their Project’s contribution to improve on the regional baseline. Quantitative additionality can come from either increased sourcing or processing of post-consumer plastic waste. This can be done by showing that these plastic wastes currently are or would have been mismanaged or are leaking or could have potentially leaked into the environment if not for the intervention of the Project. This could be demonstrated through the below examples:

No existing collection
Collection is present but unlikely to be responsibly processed or managed
Collection is present and feedstock is reintroduced into the circular economy, and the Project aims to divert the feedstock to higher levels of processing (in accordance with figure 2 of this standard[34])

Quantitative additionality can also be on the basis of financial assistance needed by the project to sustain the operation of the project, or support the expansion of the project, whether through additional collection or processing capacity, in the same or additional area/geographical jurisdiction.

In all cases, the intended financial flow of plastic credit funding towards the claimed additionality basis shall be presented by the Project Partner and shall be evaluated by the VVB.

In all cases, the Project shall not operate below the regional baseline. Only the volumes collected or processed at the conditions of the baseline and above shall be eligible for plastic credits.

REQUIREMENT 2.1.b: Qualitative Additionality and Environmental/Socio-Economic Benefits

The Project Partner shall demonstrate their Project’s contribution to improve on the regional baseline. It is possible that there is no additional waste volume collected or processed, but the Project may still qualify as additional if it can demonstrate improvement to the regional baseline conditions.

Examples of qualitative additionality can include the following:

Increased wages or incremental income to workers and/or members of the supply chain
Shift from material-based income to service-based income for workers
Inclusion of social security benefits (health and others) above what is legally mandated
Inclusion and empowerment of vulnerable groups (e.g. informal sector, impoverished groups, indigenous people, women, etc.)
Increased livelihood opportunities for frontline communities and vulnerable groups, including skill development programs and prioritization of local community members for employment/income generation

The VVB shall carry out an evidence-based assessment of those environmental and socio-economic benefits that the Project Partner claims are delivered by the Project. The Project shall also put in place monitoring and reporting mechanisms for their benefits to allow impact evaluation over time. In all cases, the Project shall not operate below the regional baseline.

Figure 3 illustrates a flow chart for the evaluation of additionality.

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Figure 3: Additionality evaluation illustration.

REQUIREMENT 2.2: Ownership of Credits

Project Partners shall establish the ownership of the Plastic Credit associated with the collection and processing of the post-consumer plastic. There may be Plastic Credits generated from a Project where a sponsor or an owner has already counted, claimed, or reported the plastic waste diversion. It is important that these Credits are accounted for properly and prevented from double counting, double claiming, or double reporting. Ownership of the Credits should also be established across the value chain where multiple value chain actors (i.e. collectors, aggregators, processors, and users of End-of-Waste output/products) exist.

Documented agreements shall be in place to show the prior and informed consent of the value chain partners and their agreement to the Project Partner’s intent to sell credits for the shared volume and a warrant that no one other than the plastic credit owner will attempt to sell credits for the same shared volume. The VVB has the right to ascertain that the ownership of these plastic credits is clearly communicated and documented, and agreed upon by all parties involved that have a commercial interest in the plastic credit that will potentially be generated or claimed.

For cases where part of a Project’s tonnage is sponsored or will be claimed by another company, organization, or individual, the Project Partner should be able to demonstrate proper tracking, monitoring, accounting, and reporting mechanisms to ensure that no double counting or double claiming is taking place. The same requirement applies when a Project is eligible to generate plastic credits under multiple plastic crediting schemes (i.e. the project has been certified under another plastic crediting certification methodology in addition to the PPRS).

Only tonnages that have no prior claim by any individual or organization, nor any outstanding disputes or doubts on ownership shall be eligible for Plastic Credit issuance.

CRITERIA 3: Safeguards Systems

Project Partners are required to demonstrate that their overall operations do not adversely impact the environment and society, and where adverse effects are unavoidable, actions are in place to prevent, mitigate, and abate the impacts.

The Safeguard system is elaborated in Module 2 of the PPRS. The Project Partner shall be able to demonstrate that the safeguards are in place and communicated to relevant stakeholders.

REQUIREMENT 3.1: Due Diligence

Validation and Verification Bodies (VVBs) shall conduct due diligence activities, including stakeholder consultations and onsite validation, in order to ascertain the implementation of the Project safeguards. Due diligence shall also include the review of the following documented information, as applicable:

a. Environmental and Social Impact Assessment (may be covered by the same evidence provided in Requirement 1.3 of this module)

b. Documentation and monitoring of relevant compliance obligations

c. Social risk management and monitoring plan/program (including outcomes if operational), including stakeholder mapping and stakeholder consultation meeting minutes, documentation of outcomes related to environmental and social assessments, impacts, and mitigation

d. Environmental impact mitigation, resource management, and pollution prevention plan or program

e. Permits/certifications/registration showing compliance with national/local labor laws

f. Register of staff/employees to ascertain fair wages, absence of forced/compulsory labor, and child labor

g. Occupational health and safety policies/programs, risk assessments, and mitigation plans

h. Policy on child labor and evidence of implementation/mechanism for implementation

i. Policy against forced labor and evidence of implementation/mechanism for implementation

j. Policies for direct, indirect, and contracted workers and implementation and monitoring mechanism

k. Policies against discrimination or harassment based on gender, age, ethnicity, culture, literacy, sickness, disability, and economic disadvantage and mechanism for implementation

l.Project grievance mechanism process, including resolution of previous grievances (if any), and evidence that the grievance mechanism process has been communicated and is accessible to the stakeholders.

The PPRS does not require use of specific templates to evidence the above. The Project Partner is free to document these requirements in accordance with their management systems and document control procedures.

CRITERIA 4: Traceability and Transparency

REQUIREMENT 4.1: Documented Information

It is recommended that the Project Partners assign document numbers, document status (active/draft/obsolete), and date of last update/effective date to all submitted documents, forms, and records to determine the validity and relevance of each document. The Project Partners are required to notify their VVB directly, in a timely manner, if there are significant revisions or changes to the documents made within the period of the PPRS Registration.

REQUIREMENT 4.2: Mass Balance and Chain of Custody

Documentation related to the Project Partners operations is required to enable complete and accurate reporting and issuance of plastic credits. Any discrepancy within the chain of custody shall be duly analyzed and explained by the Project Partner. Documents to support all transactions shall be made available to the VVB and PCX Solutions, and can include the following:

a. Monitoring records and their evaluation

b. Collection records

c. Processing records

d. Inventory records

e. Discrepancy reports and analysis

f. Communication of transactions of Plastic Credits with other partners, as applicable

g. Impact monitoring and reporting

The templates of the above records that have been validated by the Project VVB during the conformity assessment, should be used by the Project Partner as supporting documents when requesting for verification and issuance of Plastic Credits. In the case that template(s) or format(s) of these documents are changed by the Project Partner, PCX Solutions shall be notified in a timely manner.

PPRS CONFORMITY ASSESSMENT AND PROJECT REGISTRATION PROCESS

Figure 4 illustrates the process of project registration, including the requisite PPRS Conformity Assessment. Further details are explained in this section.

Figure 4: General Process Flow for PPRS Conformity Assessment and Project Registration.

Preliminary Evaluation and PPRS Scoping

The Project Partner may use the Project Preliminary Information Form (as available at pcxsolutions.org or through this link) to assess the proposed project’s eligibility for PPRS registration. The Project Partner may submit the preliminary information sheet to PCX Solutions for initial guidance and scoping.

This step is not mandatory but is recommended to help Project Partners assess their readiness prior to engaging a VVB.

Engaging a VVB

Once the Project Partner confirms that the proposed project is within the scope of the PPRS and the Project Partner is able to fulfill the requirements of the PPRS, they can engage a VVB directly and submit the required project documentation for a PPRS Conformity Assessment.

PPRS Conformity Assessment

The PPRS Conformity Assessment includes the review of project documentation, onsite visit(s), and stakeholder interviews, as well as the completion of the PPRS Conformity Assessment Checklist and PPRS Conformity Assessment Report by the VVB engaged by the Project Partner. The PPRS Conformity Assessment Report shall include a signed statement from the VVB regarding positive or negative results of the Project’s validation.

Proof of positive PPRS Conformity Assessment shall be submitted to PCX Solutions by the Project Partner as a requisite for Project Registration in the PPRS Registry.

The PPRS registration is valid for five (5) years from the date of the Project Registration.

Project Registration

Upon review and confirmation by PCX Solutions, a Project Registration number shall be assigned to the Project and an entry will be created on the PPRS Registry.

The Project Partner is responsible for keeping its listing updated and aligned with the information as declared in the PPRS Conformity Assessment Report, or the Annual Compliance Monitoring and Review Report (details below). If there are material changes to the Project that warrant the reassessment by a VVB, the Project Partner is responsible for communicating this to its VVB without undue delay. The Project Partner shall also give notice of reassessment to PCX Solutions and the status of the Project will be reflected on the PPRS Registry.

The Project or Project Partner may choose to maintain its own registry but acknowledges that in case of variances or discrepancies, the PPRS Registry will prevail.

Once a Project is registered, all transactions relating to the plastic credits it generates, as well as their movements and status must be recorded and tracked in the PPRS Registry to avoid double counting.

It is through this timely and accurate recording in the PPRS Registry that the PPRS’ guiding principles of integrity, consistency, transparency, and traceability can be manifested, and the mechanism against double-counting can be established for the benefit of the Project Partner, potential Plastic Credit Buyers or transferees, stakeholders, and the public.

Annual Compliance Review and Monitoring

Compliance of the Project with the PPRS is a continuous requirement for the validity of Project Registration. The Project shall thus be subjected to an Annual Compliance Monitoring and Review by the VVB that conducted its first independent third-party audit. The evidence of successful review and monitoring shall be submitted to PCX Solutions at least thirty (30) days prior to the anniversary of the Project Registration. The Project Partner shall engage the same VVB (the same entity that performed the PPRS conformity assessment for the current cycle) to perform the annual compliance monitoring and review.

Annual Compliance Monitoring and Review shall consist of filling out the PPRS Compliance review checklist and submitting such to the initial VVB together with the supporting evidence e.g. documented information. Onsite visit(s) and stakeholder interviews are not required for the annual compliance monitoring and review, unless the VVB deems it necessary. The VVB shall issue a Notice of Acceptance and No Objection to the continued registration of the Project, and this shall be the evidence submitted by the Project Partner to PCX Solutions to maintain its registration within the five (5)-year Project Registration cycle.

Renewal of Registration

At the end of each cycle (5 years), the Project must undergo a re-assessment by a VVB if it wishes to continue its registration. If the Project Partner chooses to maintain the same VVB as in the previous cycle assessment, a new lead auditor/ audit team from the said VVB should be assigned to conduct the subsequent conformity assessment.

Grievance Mechanism

Any stakeholder and/ or member of the public, may at any time, provide feedback and/or grievance regarding any Project that is currently registered under the PPRS. This may be done by sending an email to pprs@pcxsolutions.org or through the Grievance and Feedback - PPRS Projects form. The PCX Solutions grievance mechanism is demonstrated in Figure 5.

When PCX Solutions receives a grievance or feedback regarding a Project, we shall notify the concerned Project Partner through written communication within ten (10) days of receipt of said feedback, and request for an explanation from the Project Partner. The Project Partner shall have a maximum of thirty (30) days to provide an explanation, which PCX Solutions will evaluate within a reasonable time upon receipt. PCX Solutions will seek clarification with the relevant stakeholder as necessary.

If the grievance is deemed to be unreasonable or invalid, the relevant stakeholder will be notified and the issue will be closed. If the grievance is deemed valid, PCX Solutions will notify the Project Partner and the applicable VVB in writing (electronic) of the need for investigation and corrective and preventive action.

The VVB shall submit the results of its investigation and subsequent recommendations to the Project Partner within thirty (30) days from the receipt of request for investigation. The Project Partner shall then put in place corrective and preventive actions and submit proof of implementation of these actions to the VVB within thirty (30) days. The VVB shall have ten (10) days to evaluate the effectiveness and adequacy of the corrective action and revert to the Project Partner. In the case that an investigation by the responsible VVB is required, the Project Partner shall bear the costs of these and directly compensate the VVB for the same.

The Project Partner must notify PCX Solutions of the results of the investigation and submit evidence of acceptance of corrective and preventive actions and subsequent resolution of the feedback/grievance. This shall happen within a reasonable time from the date of receipt of the notification from PCX Solutions to the Project Partner. PCX Solutions will then share the results of the investigation and subsequent corrective and preventive actions with the relevant stakeholder that filed the grievance. In cases where the stakeholder wishes to further appeal the results and corrective and preventive actions, they may communicate this to PCX Solutions, and the latter may attempt to organize a conflict resolution discussion between the Project Partner and the complainant.

During the investigation period, the Project’s ability to request validation and issuance of plastic credits will be put on hold and only reinstated once the grievance has been resolved.

Figure 5: PCX Solutions PPRS Project Grievance Mechanism.

QUALIFICATIONS OF AND APPLICATION PROCESS FOR VVBS

Qualifications of a VVB for the PPRS

The Applicant VVB shall present evidence of:

Demonstrated competence in auditing quality management systems (e.g. ISO 9001), environmental management systems (e.g. ISO 14001), or in the conduct of validations and verifications of environmental information statements (e.g. ISO 14065:2020). Having the relevant accreditation by a member of the International Accreditation Forum (IAF) is desirable.
Significant experience in environmental and/or social auditing, with knowledge of sustainability issues and independent assessment of Project activities against standards.
Experience in waste management systems, with knowledge of waste streams, value chains, circularity concepts, and plastics.
Evidence confirming legal status of the VVB entity to operate within legal frameworks.
Signed Terms and Conditions for VVBs.

VVB Application Process

An applicant VVB may express its interest to become a VVB for the PPRS through pprs@pcxsolutions.org. The applicant VVB may fill out the application form and provide the evidence for meeting the qualification criteria above. Once PCX Solutions has completed a positive evaluation of the application, the VVB shall be granted an approval status as a VVB for the PPRS, which is valid for five (5) years, subject to the VVB's acceptance and continued compliance with the terms and conditions.

Approved VVBs for the PPRS

The list of approved VVBs for the PPRS is available on the PCX Solutions website: https://www.pcxsolutions.org/vvb. Project Partners may refer to this list when choosing a VVB to engage for their PPRS Conformity Assessment.

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[34] The PPRS recognizes that countries may have different preferences and prioritizations for the type of processing technologies applied to wastes. In this regard, the PPRS then requires that projects take into account their country-specific plastic waste management hierarchy in their determination of quantitative additionality.

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