OpenLobby.EU
Explore

European Bioeconomy Bureau

EBB

The EBB is a registered Not for Profit organisation which is made up of supporters adhering to a policy manifesto to promote the circular bioeconomy in EU policies.

Lobbying Activity

Response to Circular Economy Act

5 Nov 2025

EBB is a Brussels NGO promoting the circular bioeconomy and is a partner in the PROSPER project financed through the Horizon CBE JU Grant #101157907. The project researches into advanced technologies for the sorting and recycling of bioplastics and involves 17 partners across the EU (see Prosper). As lead partner for policy activities and being registered in the EU Transparency Register, EBB is submitting this document on behalf of the PROSPER consortium.
Read full response

Response to Towards a Circular, Regenerative and Competitive Bioeconomy

12 Jun 2025

EBB would like to emphasise the importance of market pull for products from the bioeconomy. We incentivise heavily the burning of biomass to make energy (and lots of Co2 and deforestation) but we make no incentives, drivers, targets, or obligations for materials using biomass and locking in (even if for short periods) Co2. For example: the very few obligations under the Packaging & Packaging Waste Regulation (PPWR) for compostable packaging are in fact mostly being supplied by the paper industry. Meanwhile, where materials are used in applications coming into contact with the natural environment, such as in agriculture, the use of non-biodegradable materials is leading to considerable pollution of soils and waterways. See the report from Eunomia which illustrates that more than one third of plastics used in agriculture in the EU are disposed of in an unauthorised manner (ie dumped or burnt): https://eunomia.eco/reports/conventional-and-biodegradable-plastics-in-agriculture/. EBB strongly believe the upcoming Bioeconomy Strategy shall provide a legal framework to accelerate the shift from fossil carbon to renewable sources and boost competitiveness. EBB identified three key actions: 1. Harmonising regulations: There is a lack of integration of bioeconomy concepts and priorities within the existing EU regulatory framework. In the Communication on Sustainable Carbon Cycles, the European Commission announced that at least 20% of carbon used in chemical and plastic products will come from sustainable non-fossil sources by 2030. However, there is a discrepancy between the high-level political support for the bioeconomy and EU legislation concerning biobased and compostable plastics which is hampering investment in the sector and creates barriers to market entry and expansion. 2. Boost Market Demand: Address the lack of demand for renewable feedstocks by implementing policies to make fossil alternatives less competitive. 3. Enable Fossil-to-Renewable Transition: Repurposing current fossil-based manufacturing to use renewable feedstocks. Clear sustainability criteria, access to various biomass sources, and broader definitions of biomanufacturing processes are essential to achieving this transition. The Bioeconomy Strategy should also complement a strategic roadmap to transform EUs chemical industry by transitioning from fossil-based to renewable carbon sources. The industrys current crisis is driven by global competition, high energy costs, and regulatory pressure, and stresses the urgency of reducing dependence on fossil feedstocks.
Read full response

Response to Initiative on EU taxonomy - environmental objective

3 May 2023

the feedback from the European Bioeconomy Bureau is in the attached document
Read full response

Response to Review of the requirements for packaging and feasibility of measures to prevent packaging waste

14 Apr 2023

The feedback from the European Bioeconomy Bureau (formerly the ECBPI) is attached. References to the statements made are available if required by the Commission
Read full response

Response to Early Warning Report on Waste

1 Aug 2022

The consequences of the failure to create binding targets for the recycling of the largest municipal waste stream, biowaste, is now being seen. Although all EU member states will have to implement separate collection of biowaste from 2024 many have still not begun to even plan the changes needed to their waste management infrastructure- both in collection and treatment systems. Many nations that installed incinerator capacity over the last 25 years (D, NL, B, FR, DK, SW ) still separately collect very little food waste and with the need to feed these industrial installations, are unlikely to change collection methods any time soon. Still today, mid 2022, about half of all food waste collected in the whole EU is collected and treated in only one country- Italy. Whilst we can be hopeful there will be progressive change over the next 18 months up until the 2024 deadline (Spain, Ireland, Slovakia, Slovenia are examples), unless there is a binding target for the interception of food waste (kilos per inhabitant or percentage remaining in residual waste), those municipalities and companies that own or manage incinerators will continue to burn these valuable resources. As the EU suffers increasing desertification, there is a dramatic need to restore organic carbon to soil rather than burn it. Further, biogas can be produced to substitute imported Russian gas. Finally, we need to ensure the biowaste we collect is collected free of contamination because any contaminants will eventually leak through into Nature, by being deposited on soils. So we need new, strict rules on the methodologies used to collect biowaste to prevent both the cost of contamination in the biowaste treatment facilities, and the spreading of (above all) plastics to soil in the outputs which are compost and disgestate. ECBPI will be presenting a report on plastics contamination in biowaste later this year. The numbers we have found are quite remarkable.
Read full response

Response to Carbon Removal Certification

29 Apr 2022

Please see the attached submission from ECBPI
Read full response

Response to Soil Health Law – protecting, sustainably managing and restoring EU soils

7 Mar 2022

Our submission is contained in the attached paper. Our essential points are 1. Healthy soil is also the result and, at the same time, the prerequisite of the agroecological transition in the agricultural sector. For all these reasons, healthy soils are the seedbed in which the European Green Deal can take root. 2. Soil protection in Europe requires a concert of actions by all actors, private and public but must recongise the principle of subsidiarity, national sovreignity and local discretionality. 3. There must be shared targets in order to preserve biodiversity, food security, natural carbon sinks, citizens' health and the quality and safety of food production, which depend on soil. It is also essential to establish a level playing field for businesses in transactions involving land use that may affect the ability to provide ecosystem services. 4. We ask that a special chapter of the Soil Health Law be dedicated to the protection of intact soils, such as those covered by forests, pastures, bogs, meadows, wetlands, moors, grasslands: they contain the largest continental stock of organic carbon and host the most significant repository of terrestrial biodiversity in the entire European continent. 5. We call for efforts to reduce the ecological footprint of European imports on the soils of other continents. As the major impacts are linked to imports of feed, meat, biofuels and raw materials, including minerals and hydrocarbons, the Soil Health Law must cooperate with other mechanisms, treaties and food system regulations, and support investments in circular economy and bioeconomy, to stop the outsourcing of soil degradation. 6. We urge the European institutions to fully commit to the soil-related targets of the Green Deal strategies: reduce the application of fertilisers and chemicals in agriculture and animal husbandry in order to meet the limits of the environmental impact and load capacity, increase the land covered by organic farming and natural landscapes in rural areas, promote the agroecological transition of EU agriculture, restore natural habitat, reclaim and regenerate the soils of degraded, sealed or contaminated sites. 7. We call for an update of the 'zero net land take by 2050' target, introducing a binding timeline, including short- and medium-term intermediate milestones and targets for the reuse of urban areas and the conservation and regeneration of permeable and vegetated urban surfaces, essential for the provision of ecosystem services and resilience to climate events at the urban scale. 8. Lastly, we urge that the opportunity provided by the possibility of regenerating soils through the biocycle of organic wastes, is not lost. With the whole EU initiating separate food waste collections and treatment from 2024, the opportunity is to provide up to an extra 15 million tons p.a. of high quality composts to apply to soil. To ensure materials fit for purpose, the Fertiliser Regulation will possibly require strengthening whilst the quality of inputs through source segregated collections will need to be defined and implemented to avoid contamination leaking through to soil. This needs to be linked into carbon farming policies to stimulate the restoration of carbon to soil through organic recycling. Currently, we peversely incentivate the incineration of organic wastes to produce GHG/CO2 but not the replenishment of organic carbon to soil.
Read full response

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

21 Feb 2022

please see the attached paper from ECBPI which focusses upon soil health in the context of biowaste management. Biowaste is different to other wastes streams in that its outputs end up in Nature, therefore the legislator needs to concentrate on how to reduce contaminants in the inputs to avoid negative impacts when biowaste outputs are spread to soil.
Read full response

Response to Measures to reduce microplastic pollution

17 Dec 2021

see attached file from ECBPI
Read full response

Response to Policy framework on biobased, biodegradable and compostable plastics

22 Oct 2021

ECBPI welcomes the proposal to establish a reliable legislative framework to support the development of the bioplastics and compostable plastics sector. Without legal certainty it is difficult to invest, both for industry and farmers, and for governments. The Commission recognizes the market of these products is small (1% of global plastic production capacity, 1/4 of total biobased production capacity being located in Europe) but is growing fast (+5-8% in the period 2020-2025). It is therefore important to address the sustainability challenges of these materials essentially from the point of view of their contribution to combating climate change, improving sustainable soil and biomass management, stimulating proper biowaste management and modernizing organic recycling infrastructure. Land degradation, desertification are major concerns across the EU, posing an important societal challenge to the EU and beyond, as soil is non-renewable resource. Actions to stop and reverse progressive soil degradation and ensure food security involve the implementation of transformative technologies and practices enhancing carbon accumulation in soil. We are evidencing an increasing quantity of scientific data that illustrates deterioration of soils due to persistent pollution from plastic contamination. Studies show that plastic fragments are left in soils when plastic film soil mulch is used and removed; is deposited when sewage sludges are spread to soil; is deposited when digestate from anaerobic digestion of urban wastes and compost, from the composting of the organic fraction of municipal solid waste are deposited to soil. Thus, the role of a high-quality, plastic-free compost is crucial, both from a quantitative and a qualitative point of view. Bio-based and compostable products must be considered in the broader context of the circular bioeconomy as a cornerstone between agriculture and industrial production of renewable-sourced products that are functional to both sustainable agriculture practices and soil protection. Innovative systems using a combination of products from integrated regenerative chains, such as recycled nitrogen and phosphorous, clean sludges, compost, stabilised digestate, biodegradable and compostable plastics and mulch films, bioherbicides, bio-based biodegradable lubricants, represent key deliverables of the circular bioeconomy. Therefore, we support the Commission's initiative in so far it is aimed at establishing a clear regulatory framework including standards and labels, certification schemes, implementation of waste legislation, food and bio-based, compostable products. This will provide certainty for investors, farmers, local communities who have already recognized the role of sustainable bio-based and compostable plastics in preventing compost and pollution from conventional plastics, while stimulating research and innovation, supporting the creation of markets for novel products and maximising co-benefits of the circular bioeconomy. We should not forget the need for constant and clear, uniform communications on the correct use and collection of all consumer packaging including compostable materials to ensure they enter the correct waste management streams and appropriate treatment. Labelling without comprehensive communications will achieve only minimal results in terms of collection efficiency (see the example of Contarina, Italy). We attach a more complete paper linking bioeconomy, climate, soil quality and the production of bio-based and compostable materials.
Read full response

Response to Restoring sustainable carbon cycles

29 Sept 2021

The European Circular Bioeconomy Policy Initiative (ECBPI) appreciates the opportunity to comment on the roadmap on restoring sustainable carbon cycles. We value the roadmap focus on sustainable carbon cycles. This should then provide impetus to formulate both nature-driven and technological solutions at EU level based on better understanding and recognition of the connections between the quality and health of our soils, and their importance in combatting climate change. We believe bio-waste, soil and the bioeconomy are inextricably linked to climate change. European policy therefore also needs to be linked so that current damaging practices are stemmed, and the benefits of recycling and the bioeconomy can be harnessed in a synergistic way. That is the challenge for EU’s policy makers. An estimated total of 50-60 million tonnes of food waste alone is not currently collected in the EU but is instead dumped or incinerated. Beyond this, waste from gardens account for similar amounts. This currently represents a considerable loss of organic matter, biogas and plant nutrients that could be used as valuable products in the bioeconomy. Thus, we welcome the assumption that recycling carbon from biomass and waste play a key role in replacing fossil carbon. By recycling waste-derived biological materials into new products or creating high quality compost, the natural carbon cycle, which is the basis of all life on Earth, can continue. This is where the link between the bioeconomy, soil and waste management is to be found – recycling the carbon we have used to produce a material from biological resources back into new materials or to soil as organic carbon through the application of quality compost, manures and other organic materials. Enabling efficient use of renewable feedstocks would support climate mitigation and contribute towards achieving the ambitions of the EU Green Deal. As Europe continues to experience increases in flooding, droughts and extreme events which exacerbate erosion, it is therefore urgent to mobilise and harmonise the political and technological instruments at our disposal to maintain and improve soil quality by prioritising and investing in innovative, enabling solutions from the bioeconomy sectors. The 2018 Bioeconomy Strategy should also be fully implemented to support the goals of this initiative. See our longer and more detailed briefing paper attached.
Read full response

Response to European Bioeconomy Policy: Stocktaking and future developments

6 Aug 2021

The ECBPI welcome the consultation and believes that the Commission has to strongly focus actions to prevent them being weak and diluted. Our suggested priorities are 1. a holistic, cross sectorial view of the circular bioeconomy is needed to integrate environmental, economic and social sustainability in the industrial sectors and production systems to contribute to a sustainable rural development and transition to a circular bioeconomy. 2. The promotion of practices to restore, regenerate and replenish soil quality across the EU are essential. 3. Land use efficiency as a priority. The development of the bioeconomy must not take place by increasing the stock of cultivated land at the expense of natural spaces. It must be a priority to encourage the use waste raw materials or by-products as a supply of material flows required by new production processes. 4. Clear boundaries to the use of biomass as an energy source; decarbonisation of our energy systems cannot contemplate substituting coal or oil with wood. The inclusion of municipal waste incineration, or Waste to Energy, within the Emissions Trading System, is an essential move to ensure a level playing field for the treatment of biowastes. 5. Waste biomass for energy through anaerobic digestion to produce biogas and biomethane is to be supported provided that the outcomes in terms of material recovery are met and their feeding avoids the use of biomass from dedicated energy crops and ensures animal health and well being. 6. The role of biobased and biodegradable materials as a solution to some pollution is to be recognised. Current policies do not favour the use of materials whose applications can achieve reductions in pollution of traditional oil /fossil based materials. 7. Conclusions: Producing biomaterials from locally sourced wastes or specific crops reinforces the link between the farming community, urban populations and industry, whilst the correct management of organic wastes, brought back to farmland whilst ensuring high quality, enables us to produce materials using renewable resources and above all, less resources. The recently published report from the USDA shows the importance of recognising the bioeconomy as a key economic driver to diversify farm incomes, improve sustainable product manufacturing and reduce GHG emissions. This has been achieved in part through the introduction in 2011 of the BioPreferred programme which promotes Green Public Procurement of products and materials able to meet the schemes standards. There are some 16,000 products now certified to meet the scheme’s standards. Our full paper is attached.
Read full response

Response to Agriculture - List of products and substances authorised in organic production

22 Apr 2021

Annex II allows the use in organic farming of fertilisers providing they are compliant with the Fertiliser Directive 2019/1009. We remind the Commission that the plastic contamination allowed in the Fertilisers Directive now looks to be extremely high given what we now know in the years since its implementation. Quote below from EU Fertiliser Regulation 1009-2019 The compost shall contain: (a) no more than 6 mg/kg dry matter of PAH 16 ( 5 ); (b) no more than 3 g/kg dry matter of macroscopic impurities above 2 mm in any of the following forms: glass, metal or plastics; and (c) no more than 5 g/kg dry matter of the sum of the macroscopic impurities referred to in point (b). From 16 July 2026, the presence of plastics above 2 mm within the maximum limit value referred to in point (b) shall be no more than 2,5 g/kg dry matter. By 16 July 2029 the limit-value of 2,5 g/kg dry matter for plastics above 2 mm shall be re-assessed in order to take into account the progress made with regards to separate collection of bio-waste. The digestate shall contain: (a) no more than 3 g/kg dry matter of macroscopic impurities above 2 mm in any of the following forms: glass, metal or plastics; and (b) no more than 5 g/kg dry matter of the sum of the macroscopic impurities referred to in point (a). From 16 July 2026, the presence of plastics above 2 mm within the maximum limit value referred to in point (a) shall be no more than 2,5 g/kg dry matter. By 16 July 2029 the limit-value of 2,5 g/kg dry matter for plastics above 2 mm shall be re-assessed in order to take into account the progress made with regards to separate collection of bio-waste. What this signifies is that plastic fragments permitted in compost and digestate are equivalent to 0.25% or, for one metric tonne (1000 kilos) of compost, 2.5 kilos or 2500 grammes. To give a sense of scale, a plastic shopping bag typically weighs 6 grammes. Therefore, the Regulation allows for every tonne of compost spread to soil the equivalent of 416 plastic carrier bags. A farmer may typically spread anywhere between ten tonnes and thirty tonnes of compost per hectare. The Regulation allows the spreading of 25 to 75 kilos of plastics, or ~4,000 to ~12,000 carrier bags per hectare. As these fragments accumulate, we can imagine large scale accumulation in certain farmlands of plastic fragments from compost and digestate. When the Fertiliser Directive was negotiated, over the period 2015-2018, there was not the awareness there is now about plastic pollution to soils. In the UK, this awareness is leading to a UK-wide limit of plastics in compost to be reduced from the previous 0.25% to 0.125% and further to 0.08% by 2025. Scotland has already applied this limit. It would be ironic if the UK, after leaving the EU, has stricter environmental limits on plastics to soil than the EU. Numerous studies, which we are happy to share with the Commission, evidence the high volumes of plastic pollution to soils. These can be avoided in ensuring upstream practices such as reducing plastic inputs to compost and AD plants. However for the purposes of this Regulation on inputs to organic farming, we recommend that the UK wide limit of 0.08% plastics to soil in organic farming from compost and digestate, is adopted immediately with a view to adopting it more widely, across non organic farming, when the Fertiliser Directive is revised in 2024-25. Further, we recommend the Commission to stop the use of non biodegradable soil mulch in organic farming immediately, to prevent the build up of plastic fragments left behind when these sheets of plastic are stripped out. This will require price support for organic farmers, as soil biodegradable certified (EN17033) mulches can cost three times more than PE films. More use of these will lower the price long term.
Read full response