European Balloon & Party Council
EBPC
Our mission is to create a positive and sustainable environment to grow the industry.
ID: 386179231554-03
Lobbying Activity
Response to Reducing marine litter: action on single use plastics and fishing gear
12 Jul 2018
The EBPC, with approx. 21,000 employees through it's members welcomes efforts to reduce marine litter but has serious concerns about the proportionality & the effectiveness of the SUP proposal with regard to balloon & balloon sticks. We regret that the EC has proposed the SUP without impact assessment on balloons & balloon sticks, risking a disproportionate negative impact on our industry with very high economic costs for little environmental gain.
1) The principle of proportionality requires EU acts to be suitable & necessary to attain the objectives; any disadvantages caused must not be disproportionate to the aims pursued. The EC has failed to demonstrate firstly, evidence on the harmful impact of balloons & sticks on marine life (comments RSB; see 2013 DEFRA report here: http://randd.defra.gov.uk/Document.aspx?Document=11133_AC0229-DefraWAGReportFinal.pdf); secondly, how banning of balloon sticks would reduce marine litter if no single beach count refers to balloon sticks as a separate item & only 1 dataset mentions balloon sticks in its data (EEA ranks balloons & sticks at n°36 of plastic & rubber items found); thirdly, the availability of alternatives to balloon sticks that comply with the Toy Safety Directive 2009/48/EC & Standard EN 71 (shatter proof, no choking or sharp hazard).
2) The EC has failed to review socio-economic impacts of the measures on balloons & sticks, even though approx. 21,000 direct jobs in Europe are at risk (manufacturing & supply) & up to 150,000 indirect jobs (SME retailers, balloon artists etc). A ban is only proposed for balloon sticks, but sticks are crucial to use balloons as promotional items & games. The labelling requirements for balloons risk leading to stricter national regulations, which is unacceptable when the inclusion in the SUP is based on assumptions, lack of transparent data & no impact assessment. The EC is obliged to review effects for each product category, as also pointed out by the RSB. Nonetheless, only a general estimate for the overall plastics industry was made on jobs, without taking into account the nature of the products nor of the sector (strong manufacturing presence in Europe; high number of SMEs)
3) The EC has failed to set out supporting facts when including balloons & sticks among top 10 items. First, lack of transparency as not all reports used are publicly available (e.g. JRC report JRC108181). Second, there is a lack of consistently collected data & great variability among sources. Third, a bias towards & hence over representation of lightweight, bright items (such as balloons) is cautioned for by JRC. Fourth, none of the data sources place balloons in top 10, if even mentioned at all (Arcadis, Helcom). Balloons only enter the top 10 due to grouping of other items, the aggregation methodology for which is unclear. The EC admits that this exercise affects final rankings & is not objective. As a result, low frequency items (less than 0,5% of beach litter) are now targeted disproportionately.
4) A ban is proposed on balloon sticks, even though there is no data on balloon sticks being found. Banning sticks would be counterproductive for reducing litter, as balloon sticks prevent balloons from floating due to their additional weight. Balloons that are only attached to a string are more likely to be inflated with balloon gas to enable them to float. When air filled, a balloon on a string will simply fall. Gas balloons on strings are more likely to be unintentionally released.
5) Industry is already self-regulating by public statements against balloon releases; educational campaigns (partysafe.eu; #Dontletgo); the launch of labelling symbols to not release balloons later in 2018, required for all industry members.
6) Recital(8) excludes products with polymeric coatings. Art.3 does not define ‘main structural component of final products’ & hence does not exclude explicitly these materials. Clarification is required for Art.3 to avoid doubt.
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