Regulatory Affairs (WG REGA)
Revision of the Packaging Directive's essential requirements: On 9 July, DG Environment together with consultancy Eunomia, held a second workshop of this initiative. EUBP focussed on the following key points during the workshop: - Keep generic definition of recycling conform to WFD Art 3 (17) so that organic recycling remains included and there is room for innovation in the ER.
- Move from biodegradability concept to compostability concept in the context of the Packaging and Packaging Waste Directive; define clear criteria and establish marking.
- Promote inclusion of renewable resources as feedstock complementary to promotion of recyclates (should Eunomia/DG ENVI suggest an inclusion of recyclates in the essential requirements); otherwise suggestion to include a new element of carbon reduction to requirements.
Stakeholder opinions & workshop development: - About 40 stakeholders as well as the consultancy and several people of the EC were present.
- Recyclers were overrepresented, and a clear tendency was present to narrow-down the definition of recycling in the essential requirements to mechanic recycling.
- However, there were clashing opinions between food packaging and other packaging representatives (e.g. detergent bottle producers).
- Food Drink Europe as well as Europen strongly argued against a limited understanding of recycling as well as a too strong focus on promoting the use of recyclates.
- FDE as well as Europen and partially ACE as well as present EUBP members BASF and Novamont supported EUBP’s key arguments.
- All in all the discussions were quite agitated but not so much focussing on our main points. The suggested ‘changes to the ER’ prepared by Eunomia on compostable plastics were all constructively formulated and in coherence with the ‘relevance study’ also organised by Eunomia.
EUBP identified some collaboration potential with several other associations and will liaise with them in the aftermath of the workshop. The project is due to be finalised by end of the year. A final presentation of the results is expected around mid-October. Afterwards, the results will be evaluated by DG ENVI and might be the basis for a legislative proposal by end of 2020. Study on ‘Relevance of biodegradable plastics in a circular economy’: EUBP provided ample input to DG Environment and consultancy Eunomia following the workshop in June on the following points: - Criteria for when a packaging should be made from compostable plastics
- Example products
- Phase-wise approach of introduction and legislation
- Information on standardisation processes and specific details of EN 13432
- Notes on AD and home composting in connection to bioplastics
What is still missing is research on consumer education with regard to the transferability of consumer experience with one product to another. What is more, Eunomia requested an additional input end of July concerning the share of certified compostable plastics compared to non-certified (but claimed) compostable plastics put on the market in Europe. We will try to provide input with the help of our members. However, we will only be able to deliver a rough orientation in such a short timeframe and also considering the sensitivity of the information and that we only represent the major producers but not all companies (worldwide). Another workshop is envisaged for the second week of September (tbc). JRC project on LCA for ‘alternative feedstock for plastics production’ The position on ‘Sound LCA as basis for policy making’ drafted by PG Bio-based TF 1 in collaboration with WG REGA was very much appreciated by the Directorate General for Growth of the European Commission. According to the policy officer Laure Baillargeon, the input triggered an intense internal discussion, and DG GROW as well as JRC saw that many of the points delivered were valid. An extension is decided, but it is not clear yet for how long the project will be prolonged exactly. We are in contact with JRC project leader Rana Pant and will get an update from him on how far the administrative extension process has progressed in our September meeting. Single-use Plastics Directive – remaining EC actions and transposition into national law Even though adopted, the Single-use Plastics Directive (SUP) is still of vital interest to EUBP and its members. A core action of the EC still needs to be delivered by mid of next year (mid-2020) with the (Art 12) specification of criteria what a single-use plastic product actually is. The responsible policy officer, Anna Bobo Reminj, started to define the scope of the project in late July together with the elected consultancy. We will request a meeting with her for beginning of September in order to get a detailed update and define our points of focus. WG REGA: the July meeting of WG REGA took place on 10 July, and the next WG REGA meeting is taking place on 04 September in Brussels. For detailed information on the work of the WG Regulatory Affairs, please contact Kristy-Barbara Lange (lange@european-bioplastics.org).
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