associazione italiana delle bioplastiche e dei materiali biodegradabili e compostabili
ASSOBIOPLASTICHE
To promote the development of the use of bioplastics in packaging, agricolture and other uses, through education, information, formation, events and newsletters etc.
ID: 84791296291-88
Lobbying Activity
Response to Climate change mitigation and adaptation taxonomy
15 Dec 2020
Assobioplastiche, representing the Italian bioplastics value chain, welcomes the EC’s proposal on the taxonomy.
We would like to highlight the following issues:
Food or feed crops exclusion from the taxonomy
The exclusion of food and feed crops for the production of bio-based plastics from the taxonomy represent an unprecedent threat for the entire bioeconomy sector.
It should be duly pointed out that many feedstocks used for the production for bio-based plastics, have been used for industrial purposes for nearly a century. For example, the EU production of starch, derived from corn, maize or potatoes, accounts for 10,7 million tonnes (2019), where the EU consumes 9,2 million tonnes of starch (excluding proteins and fibres totaling around 5 million tonnes), of which 56% in food, 3% in feed and 41% in non-food applications, primarily paper making (31%). Bio-based plastics accounts for less than 5% of EU’s consumption of starch, falling in the category of “other non-food applications” (Source: Starch Europe).
Therefore, the main point to take into consideration when defying the technical screening criteria for bio-based plastics is not the type of crops used, rather the land use. According to the data bio-based plastics are not causing a land use change. The land used to grow the renewable feedstock for the production of bioplastics is estimated to 0.02 percent of the global agricultural area of 4.8 billion hectares (2019). Despite the market growth predicted in the next five years (2019-2024), the land use share for bioplastics will remain at only around 0.02 percent (Source: European Bioplastics).
The delegated draft under consultation, provides for agriculture and forestry technical screening criteria in order to avoid land use change. We suggest aligning the technical screening criteria for bio-based plastics to the ones provided for other economic actives (i.e. agriculture and forestry “Protection of non-agricultural land with high carbon stock from land use change”).
Standards for bio-based plastics
We propose to define “plastics derived wholly or partially from renewable feedstock” according to the standard EN 17228, avoiding any confusion regarding what has to be considered a bio-based plastics “.
When analysing life cycle stages and their GHG emission, it is vital that all cycles are addressed, allowing to have a complete overview of the GHG emissions from cradle-to-grave, ranging from the extraction of raw materials to manufacturing, product use, and recycling/disposal in the end-of-life phase. We propose to substitute ISO 14061-1 with the standards EN 16760 , ISO 14044 and ISO 22526 , because the current standard (ISO 14061) refers to the quantification and reporting of GHG for organizations and not polymers/plastics. The proposed standards would, instead, allow to better identify the GHG based on life cycle assessment (LCA) and, more important, the amount of CO2 removed from the air and incorporated into bio-based plastics.
Read full responseResponse to Review of the requirements for packaging and feasibility of measures to prevent packaging waste
3 Aug 2020
Assobioplastiche is the Italian association representing the bio-based, biodegradable and compostable plastics sector. The following feedback is related to the study “Effectiveness of the Essential Requirements for Packaging and Packaging Waste and Proposals for Reinforcement” commissioned by the European Commission to Eunomia and published in April 2020.
One of the essential requirements concerns the "recoverability" of packaging. Recovery in the form of compost, which is typical of compostable packaging certified according to EN 13432 which are precisely “processed for the purpose of composting”, comply with the essential requirements and are in line with the definition of "recycling" provided by the Waste Framework Directive 2008/98.
Concerning Eunomia’s proposals on the definition of "recyclable packaging", with the objective to narrow down which packaging can be placed on the market and which not, Assobioplastiche is in principle in favour. However, the definition of "recyclable packaging" has to expressly mentions and include organic recycling among the possible recycling technologies.
Eunomia then proposes 3 different options for the revision of the essential requirements of compostable packaging. From this point of view, since the notion of recovery in the form of compost is clear and there is already the European standard (EN 13432) which allows to distinguish and certify compostable packaging, the revision proposed by Eunomia does not appear necessary. If the proposed revision is driven by the fact that the current Essential Requirements provide two categories, "Packaging recoverable in the form of composting" and "Biodegradable packaging", is leading to some sort of misunderstandings, it seems quite clear that the second definition helps to clarify the first, in fact it does not exist a category “packaging recoverable in the form of biodegradability”. Therefore, the revision proposed by Eunomia does not seem necessary or in any case it would be enough to merge the two definitions, thus leaving in place the only definition of recovery in the form of compost.
Last but not least, we would like to drive the attention to one specific option proposed by Eunomia on compostable packaging which proposes to limit through the essential requirements the applications that could be produced with compostable packaging. It is clear that this would discriminate compostable materials (paper or compostable plastics) thus violating the principle of technological neutrality between materials and polymers (traditional fossil-based polymers would be privileged, compared to compostable polymers which are made entirely or in part with renewable resources). Therefore, Assobioplastiche suggests to reject this option and focus on a more evidence-based approach concerning bio-based, biodegradable and compostable packaging also looking at the Italian experience, since it is the main bioplastic producer at European level.
Read full responseResponse to A new Circular Economy Action Plan
20 Jan 2020
ASSOBIOPLASTICHE’S PRELIMINARY VIEWS ON THE NEW CIRCULAR ECONOMY ACTION PLAN
The Italian Bioplastic and Biodegradable and Compostable Material Association (Assobioplastiche) welcome the intention of the European Commission to “develop a regulatory framework for biodegradable and bio-based plastics” in the context of the EU Green Deal and the new Circular Economy Action Plan. We truly believe that it should be recognized the role that this type of material have in the solving specific waste management issue and in contributing to deliver solution to environmental problems.
However, we are concerned the generic definition of "biodegradable" can be confusing. It is recommended to follow the relevant European legislation on biodegradable packaging (including plastics) and the related definitions. Directive 94/62/EC established the principle of ‘organic recycling’, which makes use of biodegradability of packaging. European lawmakers specify their intentions regarding organic recycling, albeit in a somewhat convoluted manner, in points 3c (Packaging recoverable in the form of composting) and 3d (Biodegradable packaging) of Annex II to the Directive, when they provide the definitions of essential requirements.
This differentiation between recoverable packaging in the form of compost (3c) and biodegradable packaging (3d), which is made in Annex II, can generate the erroneous idea that there is a ‘biodegradable packaging’ different from a ‘compostable packaging’.
This is not the case, packaging recoverable in the form of composting (3c) must be biodegradable (3b). Packaging waste can consist of elements that may or may not be biodegradable. However, the mixture of packaging waste must ‘not hinder the separate collection and the composting process or activity into which it is introduced.” This is clarified by Annex II.
The corresponding harmonised standard EN 13432 ‘Requirements for packaging recoverable through composting and biodegradation - Test scheme and evaluation criteria for the final acceptance of packaging’ provides the presumption of conformity to the essential requirements for packaging with regard to biodegradable packaging recoverable in the form of compost in accordance with the European Directive.
Biodegradable and compostable plastics represent an improvement of the end-of-life management of some plastic packaging for which recycling is technically and/or economically not viable and which often contamintes the biowaste recycling stream. The benefits of these materials have been demostrated by several studies, where these materials help to reduce the plastic contamination of bio-waste, thus of the compost produced in the process. Biowaste could, therefore, be used for the production of high quality compost, organic fertilizer that helps restoring soil organic carbon, tackling the desertification issues. This is indeed the issue that compostable plastics help to tackle; the land degration is recognized to be a problem in Europe (see study: Quantification of land degradation sensitivity areas in Southern and Central Southeastern Europe), where it shown that large amount of territories in Southern European Countries are at risk: Italy 59%; Romania 30%; Spain 74%; Portugal 50%; Cyprus 99%. Bringing back carbon to soil it would help to combat desertification and climate change, thus contributiong to the ultimate goal of the EU Green Deal.
Finally we suggest to the new Circular Economy Action Plan would look also at the climate impact of plastics and furthers renewable content. In compliance of the goals of the Directive 2018/852 amending Directive 94/62/EC PPWD, and in order to foster a sustainable bio-economy, decreasing the Union’s dependence on imported raw materials and reduce Europe’s global emissions, bio-based packaging could represent an opportunity to promote renewable sources for the production of packaging.
Read full responseResponse to Reducing marine litter: action on single use plastics and fishing gear
12 Jan 2018
Assobioplastiche, the Italian Association of Bioplastics and Biodegradable Materials, has been founded by a group of companies working (involved in manufacturing biopolymers biodegradable and compostable and finished products), Authorities, NGO, Universities and other Associations and Consortium involved in end of life disposal of biodegradable products.
Among the approaches examined to reduce the impacts caused by SUP waste, more sustainable alternatives are also envisaged (Point 2, Section B). In particular, substitution with materials is considered.
The text indicates specific materials (paper and wood) as a possible solution.
In our view, strategic options should just identify the desired performance but remain neutral from the point of view of the material and technology. In fact it does not matter the nature of the material (whether it is cellulosic or ligno-cellulosic or based on other biodegradable polymers), but rather the satisfaction of technical and environmental performances. Therefore, the text should be reworded as follows:
"...Options may include reduction targets, design requirements (e.g. replacement by materials, such as biodegradable materials, which degrade quickly in the natural environment, or design of lids and caps in a way that they cannot be detached from the bottle), or requirements for Member States to implement a charge at the point of sale.
Read full response