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APK AG

APK

APK AG, a pioneering plastics recycling company in Merseburg, Germany, utilizes its innovative Newcycling technology to transform multi-material, flexible plastic waste into high-quality recyclates.

Lobbying Activity

Response to Waste Framework review to reduce waste and the environmental impact of waste management

22 Feb 2022

Revision of EU waste framework APK AG, an innovative plastics recycling company and technology developer from Merseburg (Germany), welcomes the legislative review of the Waste Framework Directive, which represents a milestone towards achieving circularity for plastic packaging. We call on the Commission to overcome remaining barriers by • Setting high recycling targets for plastic (packaging); • Ensuring effective separate collection and improving the quality of sorting; • Strengthening EPR schemes; • Supporting investments in mainstream as well as in ‘at scale’ novel recycling technology and infrastructure. Provision of feedstock and product legislation The concept of circular economy must be integrated in product legislation. Progress in collection, sorting and recycling systems alone will not lead to a circular economy. The use of plastic recyclates must be mandatory in products and therefore product designs. In this context simplified access to quality input material for recycling plants across the EU is paramount. Defining key terms: ‘at scale recycling’, closed-loop recycling / high-quality recycling The revision should also focus on providing harmonised definitions on key terms often used in the EU legal framework on waste and plastics such as ‘at scale recycling’, ‘closed-loop recycling’ and – in contrast to open-loop recycling – ‘open-loop recycling’. Further terms to be considered include ‘high-quality recycling’. Technologies which are available ‘at scale’, which foster ‘closed-loop recycling’ (quality level / from product to same product) and which feature an environmental footprint lower than that of virgin plastics production should be given priority as regards future investments in an efficient EU recycling infrastructure. About APK AG APK AG was founded in 2008 with the vision of producing pure polymers with properties close to virgin plastics, from plastic waste. Researchers and engineers of APK AG have developed an advanced physical recycling process, which combines mechanical recycling steps with a targeted solvent-based separation and purification step: Newcycling®. In its industrial-scale plant at Merseburg (Saxony-Anhalt, Germany) APK AG is currently employing around 150 engineers, researchers, and administrative staff and features a recycling capacity of up to 20,000 tonnes per year. The two well established plastic recyclate products created in Merseburg are marketed as Mersalen® and Mersamid®. More information is available at www.apk-ag.de/en.
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Response to Amendment of Regulation (EU) No 282/2008 on the recycling of plastic materials to be used as food contact materials

17 Jan 2022

APK AG welcomes the initiative of the European Commission to define a framework and conditions for the use of plastic recyclates in food contact materials. As the current revision still contains some challenges to innovation, we would like to contribute the following points from the perspective of a material recycler that recently scaled a novel, physical and solvent-based recycling technology. 1. Ensuring competitiveness and support for innovation The extensive administrative provisions on notification, registration, reporting, etc. (Art 10-16) represent an extreme time and cost factor for recyclers offering a novel technology. Certain provisions such as public sharing of detailed data will not be feasible for novel technology providers due to sensitivity of data. Also the provision in Art 14 that the Commission can delay a request by a company to be assessed by up to two years ‘if other operators are developing the same or similar novel technologies’ would remove the motivation to push innovation forward and should be deleted. 2. Hazard vs potential approach We welcome a uniform approach and defined criteria for decontamination. Also, a sound control of the input stream is highly welcome and will help recyclers obtain quality feedstock. Still a certain element of inconsistency seems to present itself in the strong limitation of the input stream to food-contact material waste and the equally strong hazard-prevention-driven approach to decontamination. If criteria and threshold values for the latter are defined then all waste streams should be potentially eligible as source, provided the decontamination process is achieving the set thresholds. We recommend including an additional recital on the potential consideration of further waste streams besides food packaging waste. What is more, post-industrial waste from packaging manufacture should be included in the scope of the provisions due to very low contamination risk. Furthermore, the concept of a common set of rules for decontamination of plastic waste input for recycling stays rather theoretical and needs to be sharpened. Rules for assessing the process in different technologies are needed. And minimum criteria regarding decontamination efficiency need to be defined. Another point which would need clarification concerns the concept of closed loops. It is linked to the idea of schemes/systems as well as linked to technology. As these are two very different aspects – even though they can be connected – the presentation of the concept in the document is not fully clear. Based on the current, vague concept a general exemption from authorisation of individual recycling processes applying the closed-loop recycling technology is not justified. 3. Openness to novel recycling technologies We welcome the general openness to novel recycling technologies underlined in recital 3 and visible throughout the document. In this context it is relevant that the regulation as well as the annexes reflect the entire spectrum of innovative approaches to recycling plastics – physical processes, such as standard mechanical recycling as well as novel physical and solvent-based approaches – and chemical processes. 4. Alignment with relevant waste legislation / reporting towards recycling targets The definitions of decontamination technology and pre-processing as given in Art 2 and the mention of it in Art 7 show that decontamination is not seen as a pre-processing / advanced pre-treatment step. The difference between pre-treatment steps such as washing – which is also ‘purifying’ the waste feedstock – and decontamination operations needs to be clarified. The understanding presented here might contradict provisions in other legislation (e.g. reporting towards recycling towards, calculation point after pre-treatment and before extruder). Kindly see the attached position paper for a more detailed feedback. Information on APK AG is available at www. apk-ag.de/en.
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Response to EU strategy for sustainable textiles

29 Jan 2021

APK AG, an innovative plastics recycling company from Germany, welcomes the initiative of the European Commission to create an EU strategy for textiles. As outlined in the Roadmap, textile recycling has not yet been widely established (only 1% according to Ellen MacArthur Foundation), largely due to the presence of substances of concern (SoC). Innovative recycling processes that are able to handle complex input materials and include purification steps can aid in driving recycling for textiles, in removing SoC and in providing high-quality levels of recycled plastics. Advanced physical recycling technology such as APK’s Newcycling®-technology is proven to valorise multi-layer, flexible plastic waste, at industrial scale, into commercially available high-quality recyclates. Following a mechanical pre-treatment of the plastic waste input the process adds a solvent purification step, in which contaminants such as organic residues and hazardous substances are removed. The purified polymer is then re-granulated and ready for use in new high-quality products. As the process is not impacting the molecular chain of the polymer no re-polymerisation is needed and the emissions reduction potential of Newcycling® is similar to that of standard mechanical processes. Newcycling® recyclates currently feature an average of 66% lower emissions than virgin-plastic versions of a polymer. Assessing the purification potential for textile applications While Newcycling® was originally tested for the packaging market, APK and its partners from industry and science are currently conducting several projects to assess the potential of this technology for textile applications. The projects focus on recycling used clothing, recycling textile fibres such as polyamide (nylon) and polyester, and on recycling specific elements such as zippers. In addition, APK is also optimising its technology with regard to its decolourisation potential. With progress on these projects, and counting on growing interest, engagement and support from the textile value chain in the coming years, an adaptation of the APK technology to this new input stream at industrial scale is eminently feasible by 2025 or shortly thereafter. Considering that the basic parameters for collection, sorting, recycling and even the initially targeted products still need to be defined, the technological readiness level of Newcycling®, along with other advanced physical recycling options, is timely, therefore representing a relevant supporting factor in the textile industry’s transition. Recommendations APK fully supports the Commission’s initiative and recommends: - establishing a legislative framework for the set-up of collection, sorting and recycling infrastructure for textiles, - setting targets for reuse and recycling efforts as well as green public procurement measures, - considering Newcycling® and other advanced physical recycling approaches in this context, as they can help to rapidly increase recycling rates for textiles within a limited period of time, - defining recycled content targets for certain initial textiles, so that the efforts mentioned above have a clear target at which to aim and can fuel an ambitious transition to circularity. About APK APK was founded in 2008 with the vision of producing pure polymers from plastic waste, with properties close to virgin plastics. Its innovative recycling technology Newcycling® is implemented at industrial scale in Merseburg (Saxony-Anhalt, Germany). APK currently employs around 130 engineers, researchers and administrative staff and features a recycling capacity of up to 20,000 tonnes per year. Find APK's position paper attached.
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Response to Revision of EU rules on food contact materials

29 Jan 2021

APK AG, an innovative plastics recycling company located in Germany, welcomes the European Commission’s initiative to review the rules for food contact materials. Plastic food packaging plays a major role in protecting food against adverse environmental elements. It guarantees food safety during handling, preserves food quality for an extended period, and is therefore key to preventing food waste. The high level of performance this packaging type requires is nearly impossible to achieve with the current quality of plastic recyclates on the market. This is where innovative recycling technology can play a significant role, as referenced as referenced in Point 7 of the Roadmap: Consideration of safer and sustainable alternatives. It is important here, however, to clearly distinguish between the different innovative recycling technologies available and to assess their potential contribution to the creation of food packaging that is circular in design. Advanced physical, solvent-based recycling: dissolution recycling Advanced physical recycling technology, such as APK’s Newcycling® technology, is able to valorise multi-layer, flexible plastic waste, at industrial scale, into commercially available high-quality recyclates. Following mechanical pre-treatment of the plastic waste input, the process adds a solvent purification step, in which contaminants such as organic residues and hazardous substances are removed. The purified polymer is then re-granulated and ready for use in new high-quality products. The purification potential of Newcycling® supports the efforts of the Commission with regard to a ‘non-toxic environment’ and the treatment of hazardous substances. It is therefore highly relevant to the current consultation regarding revisions to the rules for food contact materials. Assessing the purification potential Independent risk assessments and toxicological evaluations have proven that the quality of Newcycling® LDPE re-granulates complies with safety standards for use in cosmetic packaging (leave on and rinse off scenarios). With further technological optimisation and assessment, APK is confident that it will be possible to provide a quality level sufficient for the recycling of plastic food packaging into recyclates that will be suitable for re-use in food packaging, creating a truly closed loop by 2025 at the latest. A major milestone for APK in obtaining more information will come from an industrial scale post-consumer feedstock recycling campaign that will be conducted at the plant in Merseburg (Germany) in Q2 2021. Insights on the results will be shared prior to summer 2021 and we look forward to contributing this input to the ongoing legislative process on the revision of rules for food contact material. Recommendations Newcycling® and other advanced physical recycling approaches can help to close the gap between performance requirements for plastic food packaging and the environmental imperative to facilitate uptake of recycled content use in this important product segment. What is more – advanced physical recycling features decisively reduced emissions output. The contribution of the technology branch of advanced physical recycling to the 2025 and 2030 goals of the Commission is key to increasing recycle quality while at the same time reducing emissions. The initial challenges of industrial scale and commercialisation have been successfully mastered and further scaling and optimisation is ongoing. Consequently, the potential of advanced physical recycling processes such as dissolution recycling (Newcycling®) should be assessed and acknowledged in the revision of the rules for food contact materials, as this technology can provide a sustainable alternative to the use of virgin plastic for food packaging. As a representative of the advanced physical recycling technology sector, APK looks forward to a continuous dialogue with the European Commission. Find APK's position paper attached.
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Response to Climate change mitigation and adaptation taxonomy

14 Dec 2020

APK response to call for feedback on the delegated act on taxonomy for sustainable finance The goal of this act is to help identify activities transforming the EU to a modern, resource-efficient and competitive economy with net GHG emissions by 2050. It is important that selection of activities is completed on the bases of key merits, in this technical act on the bases of greenhouse gas emission reduction potential. However the technology neutral approach is not coherently implemented in the document, especially with regard to recycling activities in point 3.16 and 5.9. Missing coherence on this matter creates the risk that the Commission’s activities on a circular economy for plastics will miss out on tapping into the potential of innovative recycling technologies that are physical processes with a solvent-based process step. All recycling technologies are needed to achieve sufficient recycling capacities and different levels of quality in the coming years aiming to fulfil the Plastic Strategy’s 2025 and 2030 goals. In this sense the delegated act should base its understanding of recycling on the definition provided in the Waste Framework Directive which allows for the integration of different processes: WFD Art 3 (17) recycling means any recovery operation by which waste materials are reprocessed into products, materials or substances whether for the original or other purposes. It includes the reprocessing of organic material but does not include energy recovery and the reprocessing into materials that are to be used as fuels or backfilling operations. Instead of mentioning technologies specifically (mechanical, chemical), the paper should either just mention recycling (and add the requirement on GHG emissions). Or it should include a mention of advanced physical processes as well. In the attached position APK suggest a number of amendments completing the technological processes mentioned in the delegated act by integrating innovative physical recycling. About APK AG APK AG was founded in 2008 with the vision of producing pure polymers with properties close to virgin plastics, from plastic waste. Researchers and engineers of APK AG have developed an efficient recycling process which combines mechanical recycling steps with a targeted solvent-based purification step. In its industrial-scale plant at Merseburg (Saxony-Anhalt, Germany) APK AG is currently employing around 130 engineers, researchers, and administrative staff and features a recycling capacity of up to 20,000 tonnes per year. The two well established plastic recyclate products created in Merseburg are marketed as Mersalen® and Mersamid®. More information is available at www.apk-ag.de/en.
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Response to Review of the requirements for packaging and feasibility of measures to prevent packaging waste

6 Aug 2020

APK AG welcomes the initiative of the European Commission (EC) to examine the feasibility of reinforcing the Essential Requirements (ER) for packaging with a focus on 'improving design for reuse and promoting high quality recycling'. In this context and in the context of the EU Plastics Strategy, the EU Green Deal, and the New Circular Economy Action Plan APK will support the EC’s work to create a well-functioning market for secondary raw materials through harmonised rules on packaging. The approach provided in the Inception Impact Assessment (IIA) and reflected in the scoping study poses a challenge to achieving this goal though as e.g. the IIA section ‘Problem the initiative aims to tackle’ covers only a certain problem-angle for efficient treatment of packaging waste and high-quality recycling. Indeed, stable quantities of high-quality secondary materials are only available to a limited extent. And we agree that this is ‘partly’ correlated to the aspect of packaging design. Still the second angle to solving the problem is not covered in the IIA and in the scoping study: missing progress in assessing and investing into innovative recycling technologies. Re-design of today’s packaging options will be feasible for a certain share of packaging formats. Still such re-design needs to be analysed against a set of well-defined sustainability criteria. A loss of performance of the packaging – especially in the food packaging sector – or an increase of resource use to achieve a certain performance would negate the goals of the circular economy and the Green Deal. Furthering progress in recycling technology is paramount to reaching circularity for packaging where re-design is not feasible or sustainable. Innovative recycling Technologies, therefore, need to be taken into account when developing a common understanding of what is a ‘recyclable packaging’ as basis for the ER. Advanced physical plastics recycling technology such as dissolution recycling (mechanical pre-treatment and solvent-based purification step; the polymer’s molecular structure is retained throughout the process) is available at industrial scale and for packaging featuring different polymer combinations. Such technologies ultimately dissipate the alleged contradiction between light-weighting and recyclability. What is more, advanced physical approaches such as dissolution recycling produce much higher quality than mechanical recycling. Closed loop recycling (from product to product) is becoming a reality by counting on innovative technologies. In this respect APK supports the conclusions of the EASAC report on plastic packaging and recycling of March 2020 pointing out that re-design and innovation in recycling technology need to go hand in hand to achieve circularity. Recommendations for the further work on a revision of the ER for packaging: The definition of recycling in the Waste Framework Directive covers physical recycling processes such as mechanical recycling and dissolution recycling. When discussing if a packaging is recyclable these different technologies need to be assessed as to their relevance today, in the short- and mid-term. The scoping study should be extended as to the angle of innovation in recycling technology in order to provide a sufficient basis for drafting a legislative proposal on the revision of the ER with regard to - the definition of recyclable packaging, - the determination of design for recycling guidelines, - the consideration of mandatory recycled content targets for certain products and the quality levels of recyclates needed for such products, - an accurate overview of how to best reach plastic waste recycling targets by 2030. Such an extension of the study and an assessment of innovative technologies should also foster common definitions and understanding of innovative recycling processes, which is a highly relevant prerequisite to making the ER more tangible and reinforceable.
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