Dear members,

Please find below an overview of the activities of European Bioplastics throughout October 2019.

Regulatory Affairs (WG REGA)

European Bioplastics’s Working Group Regulatory Affairs met on 9^th October in time to prepare and discuss three major Commission workshops on relevant EU policy and research initiatives:

• Study on Relevance of biodegradable plastics in a Circular Economy:
  • The final workshop of this initiative took place on 22 October. The consultancy will prepare its final report merging the outcome of the two workshops (July and October) by end of November.
  • EUBP has contributed to these initiatives since April of this year, and many insights, studies and contacts have been shared. The first workshop on 3 July was neutral to positive assessing biodegradable plastics technology and studies on composting. The second workshop unfortunately took a different perspective and treated biodegradable plastics not from a ‘potential benefit’ perspective but rather as an issue. The status quo of waste management across EU countries was taken as basis for judgement, and not the on-going developments (separate collection of bio-waste by 2023; build up of composting capacities necessary) or the perspective of best practice countries (such as Italy). As in other initiatives, a clear trend to demote organic recycling and pushing mechanic recycling was evident. The ultimate goal of this research/study effort is to produce a first draft of criteria for determining when biodegradable/compostable plastics are beneficial to a certain product. Keeping this in mind, EUBP urged the Commission and consultancy to step away from an ‘only issue driven’ notion and to accept that for certain products compostable solutions (paper or plastic, or combinations) are simply the better fit. The workshop included an exercise to develop criteria, and the results were quite constructive. Therefore we hope that our arguments will be taken into account, and the final report will be more balanced than the second workshop preparation. We are currently preparing a detailed follow-up input to the consultancy and will meet the responsible policy officers of DG Environment on 12 November. The outcome of this initiative is referenced in other on-going policy work, such as the revision of the Essential Requirements for packaging, and is therefore crucial for our industry.
• Revision of Essential Requirements for Packaging:
  • The second workshop of this initiative took place on 15 October.
  • EUBP intervened several times during the discussion asking to not only interpret recycling as mechanic and chemical but also to consider organic recycling. The approach the consultancy has taken so far did ignore the Implementing Decision on the calculation of waste with a view on bio-waste and compostable packaging. The ID clearly sets criteria for when a compostable packaging can be called recycled after entering organic treatment. We will also reference this lack in our meeting with DG Environment on the 12th of November.
  • Another point important in the context of the revision is that the Commission tries to include an element of support for the use of recycled content in the requirements. EUBP is arguing to also consider renewable feedstock in this context – however we are putting our approach on a broader level and aim to include a general reflection on climate (which would benefit all kinds of low carbon materials, such as recyclates, bio-based materials, etc.). As the requirements are a general and material-neutral document, we need to consider what can be supported by a majority of stakeholders (from aluminium to plastics and paper). The Commission is very much focussed on its recyclate focus, and therefore EUBP will need to build an alliance and push awareness for this aspect to a higher level (DG management / Commissioner / Vice-Presidents) in the coming months. An important aspect to underline in this context is that a too narrow focus on mechanical recycling and use of recyclates is going to hamper material innovation. Provisions of the Single-use Plastics Directive (SUP) Art 6 (30% recycled content target for all beverage bottles as of 2030) cannot be fulfilled by new materials that do not have a separate collection stream and simply no recyclate volumes to use. This passive banning of innovation from the market is a major argument we need to create awareness for with all relevant Commission institutions. Especially in the context of the Council Conclusions on the Circular Economy that demanded recycled content targets for further products.
• Guidelines for eco-modulation of EPR fees:
  • The final workshop of this initiative took place together with the one on the Essential Requirements on 15 October.
  • The background paper provided on this project had a rather hidden chapter on ‘allowing for innovation’. The mention basically stipulated that materials, that could be mechanically recycled but which had not sufficient volume for a separate treatment and would reach this level in the mid-term, could be given a separate fee category.
  • The approach, however, was equally narrow as the work done on the revision of the Essential Requirements.
  • In this context, EUBP once again mentioned the low carbon material approach and pushed to include renewable resources based materials.
  • On another aspect, we also demanded in the EPR context that fees paid for compostable plastics packaging should be allocated to composting infrastructure and not to mechanical recycling and sorting, as is the case at the moment.
• JRC project on a methodology for comparative LCA for alternative feedstock in plastics production:
  • With the extension of the project until autumn 2020, we will pick up work again with the JRC and DG Grow in mid-November.
  • The project will now feature another round of public consultation and also a round of peer review.
• Guidance on the Single-use Plastics Directive
  • This initiative just started in late summer 2019 and will focus on clarifying several points of the Single-use Plastics Directive (Art 12 of the SUP Directive urges the Commission to provide this guidance by mid-2020).
  • This will involve the specification of recital 11 of the Directive, which calls for exemptions of ‘natural polymers’ that are not chemically modified and occurring in nature (material scope of the directive), as well as a key point for many covered products – the definition of ‘main structural component’ (e.g. relevant for paper products coated with plastic).
  • What is more, EUBP will address on a product specific level that material innovation should not be blocked by defining recycled content targets for a certain product (e.g. recycled content for bottles; not clear if only PET bottles are targeted).
  • EUBP has formed a temporary Task Force for the SUP specifications called TF SUPSPEC.
  • TF SUPSPEC took up work immediately and drafted the input for the first round of stakeholder surveys (4 October).
  • The first workshop on this project took place on 18 October. Industry representatives uttered quite directly frustration with the ‘fast-track’ process of the creation of the SUP Directive and that this would create disruptions across the single market of the EU and not benefit the environment. The point interesting to EUBP on natural polymers was discussed, and we identified contact persons to include when preparing our follow-up to the workshop.
  • Discussions with other stakeholders (European Plastics Converters) during the workshop showed that also in this context we need to raise awareness for the discrimination of SUP Art 6 (recycled content for bottles by 2030) and in the long-term ask for a revision of this provision by 2025.
• ECHA initiative on intentionally added microplastics:
  • EUBP reviewed the status of the initiative as the consultation period ended on 20 September. The report at this stage recognises that biodegradable plastics should be exempted and provides well-founded arguments in the Annex to the report. For the time being there was no need to add to the discussion in the consultation.
  • We will continue to monitor this dossier throughout the coming procedural steps.

For detailed information on the work of the WG Regulatory Affairs, please contact Kristy-Barbara Lange (lange@european-bioplastics.org). The next meeting will take place on 12 November 2019 in Brussels.

Product Groups

Product Group Biobased

The setting up of the Task Forces 1-3 has been finalized and first web meetings will take place in November.

The chairpersons of PG Biobased/the Task Forces together with the convenor held a conference call to discuss in detail the working plan and the next steps for the coming months.

The latest market data has been processed to update the graphic on “Land use estimation for bioplastics”, which will be published early in November on the EUBP homepage.

The Fact Sheet on mechanical recycling has been revised together with Task Force 2 (End-of-Life) and is ready to be published on the EUBP homepage.

For more information regarding bio-based plastics including sustainability issues and the work of the PG and TFs, please contact Katharina Hinse (hinse@european-bioplastics.org).

Product Group Biodegradables

No relevant activities concerning the PG Biodegradables in October.

For more information regarding PG Biodegradables, the TF Marine, and Seedling certification, please contact Katharina Hinse (hinse@european-bioplastics.org).

Working Group Standardisation

On 21 October, EUBP attended a web meeting of CEN/TC 261/SC4/WG 2 during which details of the standard for home compostable carrier bags were further discussed.

For more information on standards for bioplastics, current standardisation processes, and certification of bioplastics, please contact Katharina Hinse (hinse@european-bioplastics.org).

Communications

Please find at the following link a selection of relevant media clippings from October 2019 (pdf).

In October, the Packaging Journal (special edition “Kreislaufwirtschaft im Fokus” 2019) published a EUBP guest contribution (pdf) on the new German packaging law. The article (in German) sheds light on the importance of bioplastics for the whole plastics industry by providing a brief overview on the global market data and giving examples of recent innovations by EUBP members. The second part of the article gives a critical view on the new German Packaging Law, whose implementation so far lacks incentives for innovative materials, such as bioplastics.

During the K trade fair in Dusseldorf, EUBP communication promoted bioplastics in general and our members in particular. Besides the usual distribution of information material at the booth and a press compartment at the K press center, EUBP covered most of its members with representation at the trade fair on Twitter.

We are currently working on the following position paper:

• Bioplastic carrier bags.

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

Seedling logo

The Advisory Committee for the Seedling Mark (ACS) met on 30 October in Berlin to discuss relevant topics concerning compostability certification. The ACS has been established by European Bioplastics in order to exchange experiences and to harmonise testing and certification procedures. The Committee also discusses and updates the certification scheme for products made from compostable materials, “Seedling Certification Scheme”. The current version dates from January 2016, a revised version of the Seedling Certification Scheme is finalized and will be valid as of January 2020. EUBP members will be informed about the new scheme and the main changes in the coming weeks.

Events

In October, EUBP attended the K-2019 in Dusseldorf, Germany with great success.

Throughout the whole K-2019, the feedback from visitors at our booth was very positive. Furthermore, we were able to visit all member booths. The feedback we received was almost exclusively positive, especially regarding the visitor numbers at the booths, the questions that were asked on bioplastics in general, as well as on future businesses, but also the contacts that were built during K, which could lead to new clients for our members.

Regarding the Conference in December, we are happy to announce that our exhibition space is completely sold out.

If you would like to discuss sponsorship to promote your brand through the European Bioplastics Conference, exhibit your products and services, or otherwise be involved, please get in touch with our new Event Manager Hannah Heimann (conference@european-bioplastics.org).

Planned activities

WG Regulatory Affairs:

• Final input to Eunomia study on ‘Relevance of biodegradable plastics in a Circular Economy’, preparation of workshop on 22 October
• Preparation of position with TF SUPSPEC as input for workshop on SUP Directive on 18 October
• Liaison with ACE and Europen in preparation for workshop on Essential Requirements on 15 October
• Revise discussion paper on feedstock for bioplastics;
• Start planning next EP event on standards and labelling for end of November 2019

Communications:

• Further improvement of coms network and development of knowledge on bioplastics
• Preparation of EUBP presentation on bioplastics during Eurofin workshop in Hamburg (14 November)

PG Biobased:

• Web meetings of Task Forces 1-2

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