Constance Ißbrücker, Head of Environmental Affairs at European Bioplastics e.V.

The EU Plastics Strategy presented a vision where innovative materials and alternative feedstocks would ultimately replace fossil resources. In this context, the Joint Research Centre (JRC) was tasked in 2018 by the European Commission to elaborate an appropriate life cycle assessment (LCA)-based method to evaluate the potential environmental impacts of plastic products from different feedstocks. The resulting JRC “Plastics LCA method”, published in summer 2021, however, turned out to be highly problematic and biased, making it impossible to carry out an adequate and balanced evaluation of bio-based and fossil-based plastics. 

The LCA methodology is structurally flawed, it lacks a basic understanding of the innovative character of bio-based plastics, and undermines the key advantages of these products. In its current form, the method even strengthens the overwhelming dominance of fossil-based plastics and neglects the negative impacts of the extraction of fossil resources on climate and environment. This is grossly at odds with the EU’s commitment towards reducing the dependency on fossil-carbon and becoming climate neutral. The methodology also undermines many of the targets set out in the EU Green Deal and Plastics Strategy. 

European Bioplastics (EUBP), together with the partners of the European Bioeconomy Alliance (EUBA), have, therefore, recently called upon the Commission not to make use of the methodology until it has been re-opened and significantly revised and improved (to read the position). 

By way of example, three of the areas that are most problematic to illustrate the enormous asymmetry and shortcomings of the methodology: 

Biogenic carbon sequestration 

The methodology ignores the key advantage of bio-based products, which is to remove biogenic carbon from the atmosphere, sequester and store it into products, and prevent that carbon from contributing to climate change. This is a clear superiority over fossil-based plastics. Bio-based products replace fossil carbon and reduce the emissions of greenhouse gases. This fact must be accounted for by being a mandatory part in a fair and balanced assessment of environmental impacts. As an example, the EU standard EN 16760 (“Biobased products – Life cycle assessment”) provides guidance on how biogenic carbon uptake should be accounted for in the assessment of bio-based plastics, but this calculation remains a voluntary, meaningless option in the suggested methodology. 

Incorporation of (indirect) Land Use Change 

In contrast to this, a highly questionable and scientifically controversial issue is given great importance in the LCA methodology: Indirect Land Use Change (iLUC). It’s based on mere model calculations that vary greatly due to the lack of standardized or harmonised guidelines – interestingly, unlike the calculation methods for biogenic carbon uptake. Still, the assessment of iLUC is considered important and mandatory in the LCA methodology.  While nothing is wrong with making assumptions about the impact of iLUC, in order to have a fair methodology, there is an urgent need to also include indirect effects of fossil-based plastics, and to also have a look at positive indirect impacts (for more information on LCAs). 

Comparing mature and immature production systems

A fair assessment and comparison of bio-based and fossil-based plastics must consider the innovative character of bio-based plastics and their high potential for further progress and improvements in processes and value chains. While fossil-based plastics have had about 60 years to straighten out their raw material extraction, production, conversion, logistics, and end of life (EOL) options, bio-based plastics are only at the beginning of their maturity and optimisation curve. By not acknowledging these differences and potentials, the LCA methodology willingly supports the status-quo and stifles innovation. That clearly can’t be the goal. 

How committed are we, really? 

It is surprising and startling how biased and unfit for purpose the final LCA methodology turned out to be after three years of extensive discourse and contributions of scientific expertise by the bio-based industries and related experts. There is a choice whether we want to continue the road we are on or whether we are serious about a transition to a fossil-independent, bio-based circular economy. If we are committed to reduce climate change, we need to start introducing the appropriate tools and frameworks that enable such progress. Of course, it would be desirable for the EU Commission to consider reopening the JRC study in order to make the necessary adaptations to replace fossil carbon in plastics. LCAs are deemed an important and popular method to assess the sustainability of products. But are they, really? In the light of the JRC method’s shortcomings, we might need to start a discussion on whether LCAs, as currently conducted, really are the best tool to properly assess the benefits and impacts of a bio-based circular economy. 

For a more in-depth analysis of the JRC LCA methodology, please view through the presentation “A review of the JRC report on LCA of alternative feedstocks for plastics production” by Erwin Vink, NatureWorks, held at the recent 16th European Bioplastics Conference 2021 in Berlin.