EUBP STATEMENT on the EU policy framework on biobased, biodegradable and compostable plastics

Comments on biobased plastics

Key advantages of using biomass:

Climate neutrality – Europe’s ambition for 2050 – will only be achievable by cutting the emissions associated with the production, use and recycling of materials. They account for nearly one fifth of the total EU CO2 emissions. Biobased plastics can and will, if enabled, contribute towards this objective by storing and repurposing CO2, replacing the need for further fossil carbon extraction and the related environmental impacts. Biobased plastics are produced using renewable, plant-based feedstocks. Sustainably sourced renewable materials offer a key opportunity to help achieve Europe’s climate ambitions while supporting a sustainable economic development in EU’s rural areas.

Biobased and recycled content:

The Commission’s Communication on ‘Sustainable Carbon Cycles’ sets out the aspirational objective that at least 20% of the carbon used in chemical and plastic products should be from sustainable, non-fossil resources to help reaching climate neutrality. Focussing on recycling and reuse alone is not enough to replace the EU’s dependency on fossil resources and to reduce GHG emissions. Every product has a lifespan and losses are inherent to any recycling process. Virgin raw materials will therefore always be needed, especially when strict requirements on food safety and health must be met. To achieve a true circular economy, it is essential to substitute fossil-based, virgin materials with sustainably sourced biobased materials. Consequently, the Commission should promote a minimum biobased content to the same extend as recycled content in plastic products, such as the recycled content targets for plastic packaging set out in the proposal for a revised Regulation on Packaging and Packaging Waste (PPWR). Both, biobased and recycled content contribute to reduce the dependency on virgin fossil resources and GHG emissions, and they should be supported equally.

Methods to calculate and communicate biobased content:

When communicating with consumers, claims on ‘biobased’ plastics should refer to the share of biobased content in the product, stating for example that the ‘product contains 50% biobased content’. Claims on the biobased (carbon) content of a plastic product in B2C communication can only be made based on calculations using the C-14 (radiocarbon) method in line with the European standard EN 16785-1. Independent, third-party certification schemes for biobased content based on C-14, such as the TÜV Austria OK biobased scheme and the DIN CERTCO biobased scheme, already exist.

Product Environmental Footprint and Life Cycle Assessment approaches:

As the Commission plans to rely on the Product Environmental Footprint (PEF) and Life Cycle Assessment (LCA) methods as the guiding approach for environmental impact assessment, an accurate method to assess the carbon footprint of biobased products is critical. Yet, in the currently proposed PEF rules addressing biogenic carbon, there is no recognised benefit granted for the use of biogenic carbon at the beginning of the product life cycle. The JRC’s Plastics LCA method referenced in the policy framework does not even account for biogenic carbon uptake at all. Thus, as it stands, there is no appropriate incentive to use biobased resources, and these methods fail to appropriately assess the actual environmental benefits of biobased products. A lot more effort is needed to make PEF and LCA approaches fit for purpose. An updated method must provide for a balanced and fair evaluation and comparison of biobased and fossil-based products by awarding a carbon bonus at the stage of its uptake and giving a carbon malus when it’s released back into the atmosphere. The European Commi