In order to achieve the ambitious goals of the European Green Deal, respectively the Circular Economy Action Plan, the European Commission already initiated a significant number of regulatory processes. To improve Europe’s waste management in line with the waste hierarchy and the implementation of the polluter principle, the Commission had initiated a Call for Evidence in February 2022 for an environmental impact assessment of the EU waste management, which will likely lead to a legislative proposal to revise the EU Waste Framework Directive (WFD). Objectives of such a revision include decreasing waste generation, improving separate waste collection (incl. how to improve citizen participation in separate collection), avoiding contamination of recyclable waste and recycling streams, and expanding the role of EPR schemes in attaining waste-prevention objectives. Besides the revision of the Packaging and Packaging Waste Directive, the revision of the WFD ranks amongst the key legislative processes with a major impact not only for the bioplastics but for the whole plastics industry.
It is important that the review of the Waste Framework Directive seeks to promote the use of bio-based/recyclable and/or biodegradable/compostable plastics as they can play a significant role in reducing the impact on the environment and climate. Therefore, it is crucial that any future amendment enables and incentivises further innovation and sustainable growth in this sector.
Bio-based and biodegradable/compostable plastics can provide several benefits that contribute to the objectives of the WFD. Ensuring maximum waste prevention is certainly the first step towards a circular economy, and bioplastics hold great added value in this respect. Through increased performance and resource efficiency, e.g., by improved barrier properties that help extending the shelf life, or thinner, lighter, and less complex materials that need less resources, bioplastics contribute to the key objective of reducing waste. Bioplastics are also appropriate for reusable models, thus reducing the generation of waste. At the same time, industrially compostable packaging enables the (organic) recycling of food waste which would otherwise not be practically and economically recoverable.
When it comes to waste management options, it is important to note that bioplastics include a whole family of different materials. They can be treated in various established recycling and recovery streams and offer additional options such as organic recycling or chemical recycling. The major share of bioplastics produced today is mechanically recyclable. Efficient waste management can only be achieved if mechanical and organic recycling are understood as interdependent and are allocated equal levels of hierarchical importance and regulatory provision, as is the case in the current WFD (Art 3 point 17). Industrially compostable plastics, certified according to the harmonised European standard EN 13432 for the organic recovery of packaging, contribute to efficient waste management by helping to separately collect more organic waste and to divert larger volumes of biowaste towards organic recycling. They also help to reduce the contamination of biowaste with conventional plastics, and ultimately decrease microplastics from conventional fossil-based polymers in the compost. The current WFD Art 22 (bio-waste) promotes the use of biodegradable and compostable packaging for the separate collection of biowaste, and it is crucial that this support is reiterated.
Furthermore, the promotion of alternative feedstock concepts in EU legislation should not be limited to recycled feedstock but needs to also include bio-based feedstock, which can contribute to the overarching goals of the EU Green Deal to achieve climate neutrality by 2050. If we only focus on fossil resources in combination with mechanical (or chemical) recycling, our dependence on fossil carbon will also remain for the longer term. For a truly circular economy that is climate neutral, carbon must be regenerated by use of renewable resources. Those benefits of using renewable resources for the manufacture of packaging need to be reflected in the eco-modulation of EPR fees by setting an adequate waste management fee. In the same manner, the positive contribution of biodegradable and compostable packaging in increasing separate organic waste collection should be recognised.
What are the next steps towards revising the WFD? The input to the Call for Evidence which ended on 22 February 2022, will be considered in the drafting of an impact assessment report. A more comprehensive stakeholder consultation is planned to start in March 2022, initiated by an open (12-week) public consultation. They will be followed by targeted consultations and workshops to seek technical input. The likely outcome of this initiative is a legislative proposal for a revision of the EU Waste Framework Directive.
For more information, also read the complete feedback EUBP provided to the European Commissions’ Call for Evidence.