Dear members,

Please find below an overview of activities carried out by European Bioplastics throughout May 2022.

Regulatory Affairs (WG REGA)

The WG REGA met in person on 10 May 2022 in Brussels to discuss the following top policy priorities:

The Commission’s proposal for the review of the Packaging and Packaging Waste Directive (PPWD), including Essential Requirements received a negative opinion from the Regulatory Scrutiny Board (RSB) which will likely push the publication of the proposal for end of summer/ early autumn. The RSB expressed concerns on the proposal to shift the Directive towards a Regulation, as well as the mandatory reuse targets. EUBP is currently finalising a position paper on the PPWD which will be shared with key stakeholders early June. At the same time, EUBP will address a letter to the Cabinets of Commissioners Timmermans, Gabriel, Breton and Sinkevicius expressing our concerns with regards to upcoming policy proposals impacting our industry, while also highlighting the potential which bio-based, biodegradable, and compostable plastics can bring to achieving the priorities of the EU Green Deal.
On 25 May 2022, EUBP met with the Cabinet of MEP Jan Huitema to discuss the upcoming PPWD revision. MEP Huitema is interested in taking an active role in the PPWD revision – either as rapporteur or shadow rapporteur on behalf of the ENVI Committee of the EP. The focus on recycled content and mandatory reuse targets are some of the priorities outlined by MEP Huitema.

On 30 May 2022, Eunomia held a Stakeholder Workshop on the PPWD Revision which shed some more light on the proposed measures included in the Impact Assessment regarding the relevant areas of intervention, incl. "recyclability and compostability" and "recycled content”:
In particular, a bio-based equivalent to the recycled content target is still being considered (but not yet included in the IA). Compostable packaging is considered in the definition of recyclable packaging, with further clarifications and potential restrictions (to particular packaging items) being proposed, which risk restricting the market and innovation of the sector and which will have to be rebutted with further evidence and argument. EUBP was given the opportunity to make a comment during the workshop and highlighted the fact that compostable plastics do neither pose a risk nor are a source of contamination for plastics recycling streams, and that a proposed limiting list of packaging items to be compostable is restricting the market and hampering innovation. In addition, EUBP supported the proposal to introduce a bio-based equivalent for recycled content.
Eunomia is currently redrafting the Impact Assessment and will consider the issues and concerns raised during the workshop. EUBP will finalise the position paper on the PPWD Revision according to the points that have been highlighted in the workshop and submit it to Eunomia. The IA will be resubmitted to the RSB on 2 July. Adoption of the COM proposal is planned for autumn 2022 (including the legal draft and Impact Assessment).

EUBP is preparing a response to the Commission’s proposal for the Ecodesign for sustainable products Regulation (as part of the Sustainable Products Initiative), which was published on 30 March. A public consultation was launched by the EU Commission with deadline to provide feedback by 22 June. The main issues of concern for EUBP include the proposed use of PEF and LCA to develop a single consumer labelling scheme, and a proposed ‘Digital Product Passport’ that would list information on composition (material and chemical properties) for each product.

Regarding the JRC report “Assessment of the definition of recycling”, EUBP provided input on 5 May and asked the JRC for a dedicated meeting to discuss some aspects in the report which were unclear with regards to compostable plastics. During the latest REGA WG meeting, it was suggested to invite JRC representatives for an educational tour of a composting plant.

EUBP took an active role within the European Bioeconomy Alliance (EUBA) in the process of drafting a science-based position paper on the benefits of the bioeconomy in the context of food security and ongoing discussions around food versus fuel/ competition for food. The Public Affairs agency FIPRA was selected to draft the paper – deadline end of June 2022. The position will then be used by all EUBA member associations in their external engagement with key policy makers.

Following the publication of a position by the DUH on “composting of packaging made of compostable and biodegradable plastics is not recycling”, EUBP held a meeting with ECOS (one of the signatories of the letter) to better understand the reasons for their endorsement of such a paper. EUBP understands that the position was prepared in direct response to the JRC report “assessment of the definition of recycling”. The DUH shared proactively the paper with the JRC and other relevant DG’s in the European Commission. WG REGA agreed that EUBP should prepare a statement in response to the letter from DUH, including science-based evidence that composting should be considered recycling.

The Commission launched the public consultation on the Waste Framework Directive (WFD) on 23 May. Deadline to submit input is 16 August. The priorities of the EC focus on: separate collection of waste, prevention, application of the waste hierarchy, and polluter pays principle. EUBP will prepare an answer.

On 31 May the JRC held their workshop on “End of Waste criteria”. The purpose of the EoW criteria project is to set end of waste criteria for plastics. The criteria will be legally binding through Implementing Acts. The project is expected to finish in 2024. Mechanical recycling is being prioritised and chemical recycling is out of the scope of the project. There will be no end of waste criteria for materials which can only end in incineration. The JRC will use 2019 as reference year for data collection, and a survey will be sent to all relevant stakeholders with deadline to provide feedback by 15 July 2022.

EUBP continues to monitor the publication of the Policy framework for bio-based, biodegradable, and compostable plastics expected for 20 July, as well as the publication for the proposal on Green Claims. Among others, EUBP is actively engaged with EUBA in the issues around the Taxonomy Regulation (technical screening criteria for manufacture of plastic packing).

The next EUBP REGA WG meeting will take place online on 14 June between 10:30 –12:30.

For further detailed information on the work of the WG Regulatory Affairs, please refer to the slides and minutes of the last meeting and contact Maria Negut (negut@european-bioplastics.org) or Katrin Schwede (schwede@european-bioplastics.org). 

BON Europe

The BON Europe group met on 19 May 2022 to update each other on current policy developments on national level.

The Royal Decree on packaging and packaging waste to implement the Spanish law has been communicated by the Spanish Ministry for the ecological transition and the demographic challenge to the European Commission and was published on the TRIS notification procedure website where contributions can be submitted until 8 August.

The French Decree setting out the terms and conditions for the application of Article 13 of the AGEC Act, LAW No. 2020-105 from 10 February 2020 to tackle waste in all sectors and foster circular economy was published, too. Diverging from the provisions stated in the law, the published Decree does not include the prohibition of the mention 'compostable' if the compostability can only be obtained in an industrial unit, but only the prohibition of the mention 'biodegradable'.

According to a new Belgian law, fruit labels/stickers will have to be industrial compostable (EN 13432) from 2023 onwards, and home compostable from 2025 onwards. It is expected that the implementation of these measures will be delayed, as there are a number of uncertainties, incl. which standard to apply.

In light of the upcoming revision of the German Biowaste Ordinance and targeting the new government, there’s a strong lobbying effort by NGOs campaigning against the use of compostable plastics, led by DUH.

The group further agreed to start producing specific country fact sheets on relevant national regulations, legislation, standardisation, and composting landscape for each of the EU Member States that are represented in BON.

The next BON Europe meeting will take place on 16 June 2022.

For more information regarding BON Europe, please contact Katrin Schwede (schwede@european-bioplastics.org).

Product Groups

Product Group Bio-based

A draft position on mass balance approaches has been developed and shared with the PG. Comments can be submitted until Friday 3 June.

TF 1 will write a letter responding to the letter from the JRC concerning the EUBA position on the LCA methodology. It should then be sent as a common EUBA letter again.

The next meeting of the PG will take place on 28 June.

For further information regarding bio-based plastics, including sustainability issues and the work of the PG and TFs, please contact Constance Ißbrücker (issbruecker@european-bioplastics.org).

Product Group Biodegradables

The position paper on AD is still with the group chairs, and the new draft will be distributed in the PG for another short revision as soon as possible.

The TF on compostable plastics in recycling met on 3 and 11 May to discuss further changes to the comprehensive slide deck that has been prepared on the subject. The project will now be finalised, and all interested members can use the presentation or parts of it when needed. There is a need to decide how EUBP can make further use of this, e.g., by updating fact sheets or background papers.

TF AGRI had a short meeting on 23 May. The Q&A document on misconceptions and wrong claims on biodegradable agricultural products is still under development. A list of relevant policy stakeholders has been compiled and shared with the group. A next meeting will take place on 29 June.

The ad hoc TF dealing with the polymer registration met to discuss recent developments and decision in the responsible (CARACAL sub-group on polymers). The former PLC (polymers of low concerns) approach has now been replaced by a PRR (polymers requiring registration) or non-PRR decision flow chart. Polyesters will be exempted if the monomers or precursors they are made of can be found on a list that is still to be compiled by ECHA/COM. It is currently not clear if and what implications there could be for certain biopolymers. The process is in close cooperation with WG REGA and both WGs will inform their members in case of relevant developments.

The next meeting of the PG will take place on 12 July.

For more information regarding PG Biodegradables, please contact Constance Ißbrücker (issbruecker@european-bioplastics.org).

Working Group Standardisation

CEN/TC 261 SC 4 WG 2 met on 6 May to discuss how to deal with FprEN 17428 (disintegration test method under home composting conditions) which had been disapproved in the European voting by the national committees. No immediate decision was made, but, instead, an additional meeting was set up with a small group of experts to come up with a solution. Most likely there will be a new voting with some adaptions to the previous version (e.g., higher temperature). WG 2 met again on 20 May to discuss comments on the draft EN13432. So far, no agreement has been reached regarding disintegration time and the inclusion of AD in the standard.

CEN/TC 249 WG 9 had a meeting on 25 May to discuss comments on the last version of the draft technical report “Biodegradable plastics - Status of standardisation and new prospects.” The work on this document is finalised for now, and a formal public vote will be set up in the coming weeks.

No meetings are currently scheduled for WG Standardisation.

For more information on standards for bioplastics, current standardisation processes, and certification of bioplastics, please contact Constance Ißbrücker (issbruecker@european-bioplastics.org).

Communications

Please find under the following link a selection of relevant media clippings from May 2022 (online).

Throughout the month, EUBP Comms further proceeded with the drafting of the Annual Report 2021, which was completed on 18 May and sent out for printing. EUBP also proceeded with the update of several EUBP publications.

In order to further improve EUBP’s external appearance, Comms initiated a process to update the association’s power point master by organizing a brainstorming session with relevant EUBP staff. The basic as well as specific requirements for the new master were summarized in a briefing paper. A first preparatory meeting with the graphic designer contacted for the update work took place on 30 May.

In order to further improve EUBP’s media monitoring, Comms held an online meeting with Meltwater to revise the monitoring tool’s search structure and list of search words.

On 24/25 May, Comms attended the 7th PLA World Congress in Munich and represented EUBP by giving a presentation about the regulatory environment for bioplastics in the EU.

For more information or questions concerning the communications activities of EUBP, please contact Oliver Buchholz (buchholz@european-bioplastics.org).

Seedling Logo

The changes to the certification scheme decided in the last two years have been implemented, and the members of the ASC have sent their final feedback.

A more extensive communication around the Seedling Logo is currently discussed. The reason for this is the increased need for more transparent communication, including, for example, being clearer about industrial and/or home compostability.

The next meeting of the ACS is scheduled for 3 June 2022, 2 p.m.

For more information on the Seedling Logo or the Certification Scheme, please contact Constance Ißbrücker (issbruecker@european-bioplastics.org).

Events

The Networking Event and the Members Meeting will take place at the Representation of the State of North Rhine-Westphalia in Brussels on 22 & 23 June. The organization of the events has been finalized. Two sponsors have been found, and a third one will most likely be confirmed at the beginning of June.

For the conference, marketing material (flyers, etc.) has been produced. Two sponsors are already confirmed (Technip and Echo), and the acquisition of further sponsorships is ongoing as well as the call for abstracts promotion.

For more information or questions concerning the annual conference and further EUBP events, please contact Denise Valdix (valdix@european-bioplastics.org or conference@european-bioplastics.org).

Planned activities

Regulatory Affairs:

• Update position on PPWD & ER
• Circulate letter on upcoming policy developments at EU level to Commissioners’ Cabinets
• Prepare answer to public consultation on WFD/ deadline 16 August 2022
• Outreach to MEPs on PPWD and forthcoming policy framework on bio-based, biodegradable, and compostable plastics
• Develop position on SPI (public consultation until 22 June)
• Increase outreach on LCA/PEF
• Next meeting on 14 June (online)
  

Communications:

• Update EUBP publications
• Update PPT master
  

BON Europe:

• BON presentation on 2 June @ Nordics Bioplastics webinar on an overview of national bioplastics legislation
• Next meeting on 16 June
  

PG Bio-based:

• Position paper on mass balance approaches
• Draft response to JRC Letter (TF1, together with EUBA)
• Collect information on bio-based additives (TF3)
• Next meeting PG 28 June 2022, 10 a.m.
• TF meetings to be scheduled
  

PG Biodegradables:

• PP Anaerobic Digestion
• Draft Q&A document on soil-biodegradable mulch films (TF Agri)
• Finalise presentation on compostable plastics in recycling (TF Recycling)
• Next meeting PG on 12 July 2022, 10 a.m.
• Next meeting TF Agri on 29 June 2022, 10.30 a.m.
  

WG Standardisation:

• Monitor revision process EN 13432 and activities in relevant WGs of CEN/TC 249 and 411
  

Seedling Logo:

• Finalisation of the new version of the CS
• Next meeting 3 June, 2 p.m.
  

If you have any suggestions regarding the content and/or format of our monthly report, please do not hesitate to share them with us.  

This email is sent to all the contacts of our member companies that we have registered in our database. If you would like to share it with further colleagues, kindly send us an email to members@european-bioplastics.org. 

Kind regards,
Hasso v. Pogrell

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