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Bio-based and Biodegradable Industries Association

BBIA

The Association's mission is to promote the bioeconomy in the UK and specifically the development of markets for bio-based and biodegradable products and chemicals as well as their production in the UK.

Lobbying Activity

Response to New EU Soil Strategy - healthy soil for a healthy life

30 Nov 2020

The Roadmap "New Soil Strategy - healthy soil for a healthy life", outlines the issues clearly but misses one very significant challenge and opportunity related to the use of organic fertilisers derived from treating food and garden waste (biowaste) from households and businesses. The challenge is that biowaste collections contain significant amounts of pollutants, especially plastics. Data from German cities show as much as 30% of the biowaste collected is constituted of contamination, most of which is plastic. In Catalonia and Romania, the figures are similar. There are very few examples of clean biowaste collections. Currently in the EU, 2/3rds of all food waste is collected and treated in Italy, (6,5 million tons out of 9,5 million tons total); garden waste collections are higher in Germany , France and UK reflecting different climatic and living conditions. Italy has reduced its plastic contamination of food waste to just 1.5% by imposing the collection with compostable bags in 2010. Nobody else has done this, and the plastic contamination entering composting and AD plants is enormous. The more that enters, the more likely plastic is to filter through into the final compost and digestate spread to soil. Currently the amount of plastic pollution filtering to soil is relatively small, because food waste collections are in few places across the EU. However, post 2023, all EU citizens will begin to have personal, separate collections of food waste. Tonnage will increase from 9,5 million to around 50 million tons by 2030. If plastic bags are used to collect this food waste, there will be an gigantic amount of plastic spread to soil. This can be avoided by ensuring that all food waste is separately collected using compostable bags, as per the Italian law from 2010. The opportunity for the EU countries is equally large- 50 million tons treated can lead to approximately 15 million tons of compost available to help fight against desterification in southern Europe and replenish topsoil from soil erosion elsewhere. But the compost must be clean, otherwise we will only result in polluting our soils just like we are polluting our seas, with plastics. A revision to the Fertilising Regulation will be needed to set a limit to inputs of plastic allowed into biowaste treatment plants. incredibly, no such limits currently exist. The UK Environment Agency is considering imposing a limit of just 0.5% plastic entering biowaste treatment plants by 2025 and just 0.08% allowed in the final compost, compared to 0.3% allowed under the Fertilising Regulation now, reducing to 0.25% by 2023. If we are to reduce plastics not just in our rivers and seas, but also in soils, we need to act now to ensure that materials spread to soil are beneficial and not carrying vast amounts of macro and microplastics. It is also therefore opportune to revise the amount of plastic contamination (micro and macro) allowed for in sewage sludge, or to avoid spreading sewage sludge altogether to limit plastic pollution to soil. The use of non biodegradable soil mulch is also another step needed to reduce the pollution of plastic fragments accumulating in soils. We can see in the Murcia region of Spain how this has become a major environmental disaster. The standard EN17033 must be mandated as the only acceptable material allowed for use of soil mulch, to avoid plastic contamination accumulating in soils. Similarly, we can mandate biodegradable bale wrap, tree guards, clips on vines and orchards, to reduce plastics released to soil. Evidence now shows that plant root systems ingest microplastics and that they rise through plants to the fruits that humans consume. A precautionary approach is needed to avoid this and the materials are available for substitution now, before we allow these issues to ruin our soils.
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Response to Review of the requirements for packaging and feasibility of measures to prevent packaging waste

4 Aug 2020

BBIA represents producers of compostable packaging sold, produced and distributed in the UK. We welcome the revision of the Packaging and Packaging Waste Directive with a view to reducing packaging waste. We suggest the guidelines adopted by WRAP in the UK (see https://www.wrap.org.uk/compostable-plastic-packaging-guidance) as a basis of discussion for the role of compostable materials in a transition towards producing less waste and having materials that can be effectively recycled through composting and AD. Food waste collections will be mandated across the EU from 2023 and this is a perfect opportunity to ensure that compostable materials fulfill their mission: to reduce the amount of (above all) flexible plastic packaging that is not and never will be recycled, for example when contaminated with food; and on the other hand to ensure biowaste is collected and returned to treatment with low levels of plastic contamination. Scientific research demonstrates that the use of plastics in collecting food waste leads to soil contamination by plastic fragments. Yet the use of compostable food waste collection bags can avoid this. Such applications should be made mandatory across the EU, as should other listed in the WRAP guidance. The use of these materials can help spark the European Bioeconomy creating investment and jobs as the Italian example has shown. See https://bbia.org.uk/italian-compostables-market-experiences-rapid-growth/
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Response to Environmental claims based on environmental footprint methods

4 Aug 2020

BBIA represents producers of compostable packaging materials in the UK. We strongly support the Option 3 to establish a binding legal EU wide framework for environmental claims. We are sick of companies announcing their packaging to be "biodegradable" without having supporting scientific evidence, standards or test methodologies to support these claims. Packaging must be produced according the Essential Requirement of the Packaging and Packaging Waste Directive to three standards, for mechanical recycling, for incineration or for organic recycling through composting /AD. Therefore claims of generic biodegradability are misleading if not unlawful as the biodegradability has to mean accepted for composting or AD treatment and therefore adhering to the CEN13432 standard. The amount of greenwashing in this field is a significant barrier to the development of markets for compostable packaging as it causes confusion among brands, retailers and consumers as well as waste managers in post consumption phase.
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Meeting with Phil Hogan (Commissioner)

7 Dec 2017 ยท Key Speaker