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European Bioplastics

EUBP

European Bioplastics represents the interests of companies across the bioplastics value chain in the European Union.

Lobbying Activity

Meeting with Luis Planas Herrera (Cabinet of Commissioner Jessika Roswall) and Novamont SpA

4 Nov 2025 · Circular economy

European Bioplastics demands dedicated industrial plan for biobased materials

23 Jun 2025
Topic — The European Commission is reviewing its strategy for a circular, climate-neutral bioeconomy.
Message — The group calls for a dedicated industrial action plan and mandatory targets for biobased content in products. They want renewable carbon treated as a strategic resource equivalent to recycled materials in climate rules.123
Why — These measures would drive market demand and secure funding for scaling bioplastic production.456
Impact — Fossil-based plastic producers would lose market share as biobased alternatives receive preferential treatment.78
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Meeting with Pierfrancesco Maran (Member of the European Parliament, Shadow rapporteur)

28 Apr 2025 · End-of-Life Vehicles

Response to Delegated act on primarily used components under the Net-Zero Industry Act

19 Feb 2025

I write on behalf of European Bioplastics, representing the interests of the bioplastics industry across the entire value chain. Our members are engaged in producing, refining, and distributing bioplastics, i.e., plastics that are biobased, biodegradable, or both. We would like to draw your attention to the fact that many technologies to produce biopolymers (and other biochemicals) are not based on microorganisms or enzymes. Therefore, we ask to modify the Annex to the Commission delegated Regulation so that biopolymers are listed as a stand-alone final product. The same should apply to their primarily used components, such as bio-naphtha.
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Response to List of net-zero technology final products and their main specific components

17 Feb 2025

I write on behalf of European Bioplastics, representing the interests of the bioplastics industry across the entire value chain. Our members are engaged in producing, refining, and distributing bioplastics, i.e., plastics that are biobased, biodegradable, or both.We would like to draw your attention to the fact that many technologies to produce biopolymers (and other biochemicals) are not based on microorganisms or enzymes. Therefore, we ask to modify the Annex to the Commission Implementing Regulation so that biopolymers are listed as a stand-alone final product. The same should apply to their primarily used components, such as bio-naphtha.
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Meeting with Taru Haapaniemi (Cabinet of Commissioner Christophe Hansen) and Novamont SpA

13 Feb 2025 · Exchange on the potential of the bioeconomy

Meeting with Andreea Ticheru (Cabinet of Executive Vice-President Margrethe Vestager)

2 May 2024 · Presenting organisation's European Bioplastics Policy Manifesto in the context of EC's Communication on biotech and biomanufacturing

Response to Update of related legislation as a consequence of the new regulation on recycled plastic Food Contact Materials

15 Apr 2024

European Bioplastics (EUBP) welcomes the opportunity to provide feedback to the public consultation on the draft delegated act amending Regulation (EU) No 10/2011 on plastic materials and articles intended to come into contact with food and amending Regulation (EC) No 2023/2006 on good manufacturing practice for materials and articles intended to come into contact with food as regards recycled plastic and other matters related to quality control and manufacturing of plastic materials and articles intended to come into contact with food. EUBP supports the taking of measures to increase the safety of materials used in food contact. However, we ask for policy makers to create a level playing field and a material neutral approach. As potential migration into food is not limited or specific to plastics, all materials should be assessed equally. Please find EUBP's complete feedback in the attached document.
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Response to Aligning the biodegradability criteria for polymers in EU fertiliisng products to the REACH restriciton on microplastics

5 Apr 2024

Comments on the draft delegated Regulation amending Regulation (EU) 2019/1009 as regards the inclusion of mulch films in Component Material Category 9: The pathway for including soil-biodegradable mulch films in the Fertilising Products Regulation (FPR) is set. By 16 July 2024, the Commission shall carry out a review in order to assess the possibility of determining biodegradability criteria of mulch films, and the possibility of incorporating them into component material category 9 in Part II of Annex II of the Regulation (Art. 50 of (EU) 2019/1009). A first draft delegated Regulation (amending Regulation (EU) 2019/1009 as regards the inclusion of mulch films in CMC 9) is currently open for a public consultation. European Bioplastics (EUBP) welcomes the inclusion of soil-biodegradable mulch films in the Fertilising Products Regulation and the key role given to existing standards concerning the biodegradation of mulch films in soil. The biodegradability criteria specified in Annex I, Appendix 2 are strict but scientifically sound and will ensure that certified soil-biodegradable mulch films are environmentally safe and will contribute to soil health. Certified soil-biodegradable mulch films are proven to increase the yield and quality of crops, control weeds and increase the soil temperature and moisture. At the same time, they allow the reduction of inputs for cultivation (e.g. herbicides) and add a carbon source into the soil, which can be used, for example, as an energy source by soil microorganisms. As such, incorporating this innovative product into the FPR will tackle several environmental and agronomic challenges at once, including the need to produce more food from less land and farm more sustainably using less resources. European Bioplastics highly recommends the inclusion of certified soil-biodegradable mulch films into the FPR. Indeed, the FPR appears to be the most adequate legislation to cover these innovative materials, given that it already covers a broad range of products applied to soil and sets high requirements in terms of environmental safety. The inclusion of certified soil-biodegradable mulch films in the FPR will open a single market for producers and users (i.e., growers), guaranteeing at the same time a high level of soil protection and stimulating further investments, innovation, and research in this field which strongly relates to a circular bioeconomy. The environmentally beneficial use of biodegradable plastics is as well anchored in the EU Commissions Circular Economy Action Plan. Incorporating certified soil-biodegradable mulch films into the FPR is crucial to enable a functioning bioeconomy in the agricultural sector, and to contribute to achieving the target set out in the Communication on the Farm to Fork Strategy. Comments on the draft delegated Regulation amending Regulation (EU) 2019/1009 as regards biodegradability criteria for coating agents and water retention polymers for Component Material Category 9: EUBP welcomes as well the inclusion of the scientifically sound biodegradability criteria for coating agents and water retention polymers specified in Annex I, Appendix 1 and agrees with the Commission that the use of those products contribute [...] to a sustainable use of water in agriculture and to reach the target set out in the Commission Communication on the Farm to Fork Strategy to reduce nutrient losses [...] while ensuring that there is no deterioration in soil fertility.
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Meeting with Sirpa Pietikäinen (Member of the European Parliament)

4 Oct 2023 · PPWR

Meeting with Miapetra Kumpula-Natri (Member of the European Parliament) and Huhtamäki Oyj

3 Oct 2023 · PPWR catch-up

European Bioplastics urges updated footprint rules to benefit bio-based materials

21 Jul 2023
Topic — The European Commission is proposing rules to substantiate environmental claims using specific footprint methods.
Message — The association calls for the footprint method to be revised to recognize the benefits of biomass. They also seek flexibility regarding primary data requirements to protect trade secrets and innovation.123
Why — This allows the industry to highlight its environmental benefits while protecting sensitive intellectual property.45
Impact — Fossil fuel companies would lose their comparative advantage if biomass receives specific carbon removal credits.6
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Response to Ecodesign for Sustainable Products - Product priorities

12 May 2023

At European Bioplastics (EUBP), the association representing the interests of around 80 member companies from the entire bioplastics value chain, we believe that for sustainable products to become the norm across the EU, the potentials of biobased, biodegradable and compostable plastics need to be considered. It is crucial that the ESPR sets concrete incentives to switch to renewable and sustainably sourced materials to deliver on the commitments made in the EU Green Deal and the Circular Economy Action Plan. In this regard, we are calling upon the Commission to promote the use of biobased content equivalent to the horizontal provision on the use or minimum content of post-consumer recycled materials in the identified groups of products of the ESPR. To recycle and repair is good, but not enough to tackle climate change. To achieve a true climate neutral, circular economy, it is essential to substitute fossil-based, virgin materials with sustainably sourced biobased materials. Both, biobased and recycled content contribute to reducing the dependency on virgin fossil resources and GHG emissions, and they should be supported equally. Biobased plastics offer all the same properties and functionalities as conventional plastics, they can be used in durable applications, and can be recycled in existing recycling systems, while additionally having the environmental advantage to make a considerable contribution to increased resource efficiency through a closed resource cycle and use cascades. When regulating the life cycle environmental impact, including carbon footprint, for plastics and polymers and specific product groups that consist of plastics, it is important to acknowledge that current LCA and PEF methods fail to appropriately assess the actual environmental benefits of biobased products. As the Commission recognises in its Communication on a Policy Framework for bioplastics (COM(2022) 682), a lot more effort is needed to make PEF and LCA approaches fit for purpose. An updated method must provide for a balanced and fair evaluation and comparison of biobased and fossil-based products by awarding a carbon bonus at the stage of its uptake and giving a carbon malus when its released back into the atmosphere. This approach would be in line with the standard EN 16760 Bio-based products Life Cycle Assessment. On the proposed horizontal measure of expected generation of waste, such as release of microplastics, it should be considered that biodegradable polymers plastics can help in minimizing environmental impacts, while reducing the accumulation of plastic particles in different environmental habitats. Biodegradable polymers have the advantage that they do not erode into persistent secondary microplastics upon degradation, because natural environments habit microbes that are able to metabolise these polymers. The residence time is considerably lower for biodegradable polymers compared to conventional plastic materials. To claim a products biodegradability, however, the ambient conditions must always be specified, and a timeframe for biodegradation must be set to make claims measurable and comparable. This is regulated in applicable standards. Furthermore, for the identified product group of absorbent hygiene products (AHP), a transition towards the use of compostable plastics would allow to reduce waste that is usually landfilled or incinerated, and instead shift to resource generation. Certified compostable plastics and materials can biodegrade after usage in a closed organic recycling system together with other organic waste and can, for example, be recycled into compost and fertiliser. In general, we consider it vital for the ESPR to enable and drive innovation to ensure that the sustainable materials and products are fit for the future and moving towards a biobased and circular economy model and that the industrys investments into R&D of innovative materials remains in the EU.
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European Bioplastics urges broader inclusion of renewable feedstocks

2 May 2023
Topic — The consultation establishes classification criteria for environmentally sustainable economic activities within the EU.
Message — The group proposes including pre-consumer waste and diverse biomass sources as sustainable feedstocks. They also argue that compostable materials should be recognized for all food-related packaging applications.123
Why — Expanding the criteria allows bioplastic producers to access more investment through the taxonomy.4
Impact — Fossil-based polymer producers lose market share to bio-based materials under this proposal.5
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European Bioplastics urges inclusion of biobased content in targets

19 Apr 2023
Topic — The European Commission is reviewing rules to reduce packaging waste and improve recyclability.
Message — The association requests that biobased materials count toward recycled content targets. They also seek a 10-year grace period for new, innovative packaging materials.12
Why — This would lower compliance costs and give the industry more time to develop infrastructure.3
Impact — Fossil fuel companies would lose market dominance as bio-based materials gain competitive regulatory advantages.4
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Meeting with Luisa Regimenti (Member of the European Parliament, Shadow rapporteur) and Amazon Europe Core SARL and

9 Mar 2023 · PPWR

Meeting with Patrizia Toia (Member of the European Parliament, Rapporteur for opinion)

8 Mar 2023 · Packaging and Packaging Waste Regulation

Meeting with Frédérique Ries (Member of the European Parliament, Rapporteur) and Nestlé S.A.

2 Mar 2023 · PPWR

European Bioplastics urges EU to recognize compostable polymers

29 Jul 2022
Topic — This consultation assesses Member State progress toward meeting 2025 and 2035 waste recycling targets.
Message — The organization asks that the report recognize biodegradable and compostable polymers as tools for waste prevention. They also want industrial composting recognized as a primary solution for collecting and recycling organic waste.12
Why — Official recognition would validate their products as recycled materials, facilitating market growth across all Member States.34
Impact — Member States with restrictive rules would face pressure to overhaul their existing waste management policies.56
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Response to Sustainable Products Initiative

21 Jun 2022

European Bioplastics (EUBP) welcomes the initiatives taken at Commission level to address unnecessary adverse environmental impacts of products placed on the EU market, while harmonising industry requirements. The objectives set in the COM proposal for the Ecodesign for sustainable products Regulation (ESPR) are core to EUBP’s priorities of sustainability, circularity, and resource efficiency. To reach the EU Green Deal goals of carbon neutrality by 2050, a balanced and science-based Regulation will need to consider the important role played by bio-based, biodegradable, and compostable plastics in defossilising the EU economy and in improving end-of-life options for many products placed on the EU market. While we are aligned with most elements outlined in the proposal for ESPR, there are some points which need further consideration and improvement. Our proposals in a nutshell: • LCA methodology to be aligned with EN 16760 Standard “Bio-based products – Life Cycle Assessment” • Consider bio-based content equal to recycled content • No mandatory list or disclosure of quantities for all substances and materials in the product Among the ecodesign requirements, which will be further elaborated through Delegated Acts by the Commission, there is a strong focus on recyclability. In this regard, we call on the EC to position bio-based content at the same level as recycled content in the ecodesign criteria. Currently, except for PET bottles, packaging requiring food contact approval cannot consist of recycled material. Bio-based virgin material, on the other hand, not only reduces the carbon footprint of packaging, similar to recycled material, but also is suitable as food contact material. Furthermore, with the ESPR, the Product Environmental Footprint method (PEF) is anticipated to be the preferred method for evaluating the environmental performance of products. As outlined in the Commission proposal, the definition of “environmental footprint” is based on PEF – “the life cycle assessment method to quantify the environmental impacts of products established by Recommendation (EU) 2021/2279”. However, using the PEF method in line with the JRC LCA methodology of alternative feedstock for plastics production undermines the key advantages of bio-based products - which is to remove carbon from the atmosphere and sequester it into products. Biogenic carbon uptake should be accounted for in the assessment of LCA for bio-based plastics. We would suggest giving CO2 removal credits to biomass when it is produced and establish a charge for CO2 that is released back into the atmosphere (both for bio-based and fossil-based). This procedure would be aligned with the EN 16760 standard “Bio-based products – Life Cycle Assessment”. Furthermore, with regards to end-of-life options (EoL), all recycling options, including organic recycling need to be treated equally and must correctly represent existing and potential future waste infrastructure. To capture the real value of industrial composting in comparison to other EoL options, the LCA method should be performed on waste stream levels rather than on product level. For the reasons outlined above, we propose that the Commission includes in this Regulation pertinent existing standards for comparing data in a transparent and meaningful way, to avoid unfair comparison between products. Moreover, we suggest that the GHG emissions are calculated using the standard EN 16760 Bio-based products – Life cycle assessment. In addition, EUBP recommends that the DPP is designed in a way that promotes the principles of the circular economy, but its requirements should not hinder innovation. We disagree with the EC proposal to include in the DPP the following: - List of materials and substances present in the product - Quantities of materials and substances present in the product - Information on the origin of product components - Recycled content of each material present in the product. Thank you!
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European Bioplastics seeks carbon removal certification for bio-based products

2 May 2022
Topic — The European Commission is developing a regulatory framework for certifying sustainable carbon removals.
Message — The industry requests that the framework recognizes biogenic carbon captured in bio-based plastics. They also seek the inclusion of recyclable bio-plastics to ensure market fairness.12
Why — Certification would enhance the competitiveness of bio-based products against fossil-based alternatives.3
Impact — The fossil fuel sector faces reduced demand as Europe transitions to bio-based materials.4
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Response to Waste Framework review to reduce waste and the environmental impact of waste management

21 Feb 2022

Attached is feedback submitted on behalf of European Bioplastics. The members of European Bioplastics (EUBP) support an ambitious Green Deal that is committed to significantly reducing waste generation, simplifying waste collection for citizens, and ensuring cleaner secondary materials creating a sustainable competitive advantage for the European industry. Our collective ambition is to ensure that the considerable benefits of bioplastics (plastics that are bio-based, biodegradable, or both) are taken into consideration and that these materials can help contribute, to the fullest extent, towards delivering on the EU’s Green Deal and the Circular Economy Action Plan.      The review of the EU Waste Framework Directive should seek to promote the use of bio-based/recyclable and/or biodegradable/compostable plastics as the can play a significant role in reducing the impact on the environment and climate, whilst maximising the benefit of the plastics sector. Therefore, it is crucial that any future amendment to the Waste Framework Directive enables and incentivises further innovation and sustainable growth in this sector.   
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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

European Bioplastics believes that the draft Regulation favours current technologies, which are already developed at scale, as opposed to innovative new products and materials. In addition, the current requirements and definitions are adapted to accommodate mechanical rather than chemical recycling. Deployment of chemical recycling is growing and this should be viewed as a positive development which should be enabled and facilitated by the EU. If appropriately fostered, within a sound regulatory framework, this technology will help the EU to meet its ambitious recycling targets under the umbrella of the European Green deal. At present, however, the complexity of this regulation and the lack of clarity that it provides pose a barrier to the development of new innovative technologies. Further detailed comment and analysis from European Bioplastics can be found in the attached document.
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Response to Measures to reduce microplastic pollution

15 Dec 2021

European Bioplastics supports all efforts to gain a better understanding of the origin and creation of microplastics and their release into and effect on the environment, in order to minimise environmental impacts. Scientific studies are looking into the option of biodegradable materials to be a potential solution for microplastics accumulation.Therefore, data on the residence time of materials in nature needs to be collected and should also be included in the risk assessment of life cycle assessments. Biodegradable polymers have the advantage that they do not erode into permanent secondary microplastics upon degradation, because most natural environments are inhabited by microbes that are able to metabolise these polymers. Thus, the residence time is considerably lower for biodegradable polymers compared to conventional plastic materials.This way, biodegradable plastics can help to minimise environmental impacts and reduce the accumulation of plastic particles in different environmental habitats. Microplastics and their potential environmental and health impacts have been of growing concern in recent years. Everything, including every material originated in or produced by nature, will eventually abrade or degrade. This is just as much true for plants that will turn into humus, as it is for mountains and rocks that will, over the course of many centuries, grind down to the size of sand corns and smaller. The same is true for all man-made materials, including synthetic polymers and plastics. The only difference is that the latter will not easily be incorporated back into the natural cycle – as this is not their natural origin – but will persist in the environment for a longer period of time. In view of the fact that these microplastics can cause harm to the environment and human health, biodegradable plastics and polymers are gaining more significance as a potential solution. Although biodegradable and compostable plastics do – as all solid materials – produce small particles through abrasion when in use, they are not the same kind of persistent microparticles that are caused by conventional, non-biodegradable materials. Instead, these particles will biodegrade, and the merits of using biodegradable materials as intentionally added microplastics (for certain applications such as cosmetics) will be reflected in this discussion. Industrial compostable plastics significantly reduce the amount of persistent, non-biodegradable microplastics in the compost and thus a subsequent leakage into the environment. Furthermore, soil-biodegradable mulch films help to stop leakage and accumulation of persistent microplastics in agricultural soils and standards are already available to support the establishment of biodegradable alternatives to substitute persistent microplastics that are intentionally added to cosmetic products. Consequently, EUBP firmly believes that non-biodegradable microplastics and microbeads should be banned. To read more about EUBP's position on microplastics please see our attached position paper.
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Response to Policy framework on biobased, biodegradable and compostable plastics

25 Oct 2021

EUBP welcomes the Commission’s initiative to prepare a Communication on a Policy Framework for BBPs and BDCPs and remains an active contributor of expertise in this field. We have worked extensively with EU policy makers to develop a series of measures that have enabled sustainable growth. Significantly, the packaging directive in 1994 clarified the concept of organic recycling, and CEN, under the mandate of the Commission, established a series of harmonised standards, necessary for the development of the sector. The LMI for Bio-based products helped to establish standards on bio-based products, also with the support of the European Commission. This series of European standards helped to clarify the terminology, the analytical methodologies, and the modalities for clear communication of bio-based content and the property of compostability to consumers. As a consequence, for almost 30 years, innovation in BBPs and BDCPs has delivered numerous new benefits and market applications which help reduce, reuse and recycle waste. Yet, despite these benefits, misperceptions and biases against the introduction of BBPs and BDCPs still persist, as highlighted by the Commission’s own Roadmap. We address a few of these briefly below and all in greater detail in our attachment. Consumer confusion: In regions where BDCPs are already widely available, experience shows that consumers become quickly accustomed to their appropriate use and end of life treatment. However, communication to consumers can be undermined by a lack of coherence in EU legislation, as seen with the SUPD. This mandates BDCPs to be labeled as “plastics”, although these products are designed for recovery and recycling of organic waste. An important distinction also needs to be made between consumer understanding of terminology (e.g., “biobased” or “biodegradable” etc.), which could be confusing, and understanding of labelling, which is designed to be inherently clear to facilitate identification and sorting. Labelling: With appropriate support from the EU, clear and harmonised labelling will help consumers and customers make informed decisions on the bio-based content in plastics, on the property of compostability, and on correct end of life sorting. Littering: There is scarce evidence that BDCPs represent a source of littering. With regards to the Roadmap’s requirement for BBPs to be marine biodegradable, it seems strange that this property is not required of any of the materials which actually are commonly found in marine litter. BDCPs do, however, play a key role in the separate collection and organic recycling of biowaste, reducing the contamination of soil by conventional plastics. Sustainable sourcing: BBPs are sourced from sustainable, certified feedstocks with benefits including carbon sequestration and jobs and growth creation in rural and coastal regions. Yet, in comparison, the Roadmap suggests that the relative sustainability of fossil carbon feedstocks need not be questioned. Renewable Content: The claim that the benefits of bio-based plastics should “go beyond reducing fossil carbon use” is regrettable and is at odds with the EU’s ambitious climate goals. It’s unclear why this requirement is applied, undervaluing the benefits of BBPs, when the same standard is not required of other renewable sectors e.g., solar, wind etc. Recycling: BBPs can be efficiently mechanically, organically and chemically recycled. BDCPs are intended to be organically recycled and can also be mechanically and chemically recycled. All forms of recycling (mechanical, organic and chemical) are necessary, are interdependent, and should be equally promoted. Suitable applications: It is disproportionate for legislators to propose applications and/or exhaustive lists of uses for these materials. Such legislation would hamper and limit future research and innovation in beneficial resource-efficient products (inc. those funded by the EU) and limit the collection of biowaste.
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Response to Restoring sustainable carbon cycles

7 Oct 2021

European Bioplastics (EUBP) represents the entire value-chain of bio-based, recyclable and biodegradable/compostable materials and products, which provide a key value proposition in waste reduction, recycling and recovery. Over the past 25 years, innovation by this sector has delivered many new benefits and market applications. These include the development of renewable bio-based and compostable products, enabling the separate collection and organic recycling of biowaste/food scraps and the use and development of productivity-boosting mulch films for both conventional and organic agriculture practices. EUBP calls on the Commission to promote policies which enable the recovery and recycling of bio-waste into quality-assured compost. Such policies would help stem soil organic carbon losses and improve soil productivity. They would also enable the sequestering of organic carbon in soil, reducing greenhouse gas emissions and helping tackle both the climate and biodiversity emergencies. Increasing levels of recovery and organic recycling of biowaste, which Member States are mandated to do under the Waste Framework Directive by end 2023, would help close both carbon and nutrient loops. The use of biodegradable and compostable plastics in biowaste recovery and organic recycling is proven to reduce the contamination of soil by conventional plastics. Furthermore, biodegradable agricultural mulch films play an important role in boosting productivity and protecting soils as carbon sinks in both conventional and organic agriculture practices The Commission’s policies with regards to restoring sustainable carbon cycles should seek to stimulate the production of bio-based based plastics as opposed to fossil-carbon based plastics. This would help minimise further extraction and emission of fossil carbon contributing to the EU’s carbon neutrality goals under the European Green Deal. Capturing the potential of both bio-based and biodegradable and compostable plastics would also help contribute to the following EU Green Deal objectives: • Preserving Europe’s Natural Capital • Transition to a Circular Economy • A zero pollution Europe • Farm to Fork • The transformation of agricultural and rural areas • A Just transition In addition, it is important that biowaste treatment through composting and the use of compostable materials from bio-based resources are appropriately valued through the technical screening criteria set out in the Taxonomy guidelines. Please see EUBP's attachment for further proposals for guiding principles and recommendations on this topic.
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Response to European Bioeconomy Policy: Stocktaking and future developments

31 Aug 2021

European Bioplastics (EUBP) represents the entire value-chain of bio-based, recyclable and biodegradable/compostable materials and products, which provide a key value proposition within the sustainable, circular bioeconomy. Over the past 25 years, innovation by this sector has delivered many new benefits and market applications which contribute numerous solutions to the objectives set out by the European Green Deal. Such benefits have included the development of renewable, bio-based, climate-neutral materials, reducing the EU’s dependence on fossil-carbon extraction and use. In addition, significant benefits within the bioeconomy have been derived through the development of biodegradable and compostable plastics, which increasingly enable the separate collection and organic recycling of biowaste/food scraps and the use of productivity-boosting biodegradable mulch films for both conventional and organic agriculture practices. The benefits of bioplastics within the bioeconomy are manyfold contributing positively to economic, societal and environmental sustainable development. With a current share of between 0.5 and 1% of the global plastics market, the bioplastics sector shows steady growth. At the same time, it is important to note that despite the gradual market growth predict over the next five years (2019-2024), land use share for bioplastics will increase to only around 0.1% towards the end of this period. As an active member of the European Bioeconomy Alliance (EUBA), EUBP believes that through coherent policy support and appropriate incentives, a sustainable, circular EU bioeconomy will deliver further significant benefits and solutions for all objectives defined under the European Green Deal. EUBP believes that such a supportive bioeconomy policy framework should go beyond recommendations and should foresee concrete measures and incentives, establishing a truly circular system. An important core objective at the heart of sustainable, circular bioeconomy development should be continued leadership in innovation, through the development of new and novel climate-neutral materials. In addition, a core focus should be the overall reduction of waste and the effective recovery, reuse and recycling of both natural and manufactured resources, closing the loop from primary production right through to consumers, composters and recyclers. EUBP welcomes the Commission and MS’s recent recommendations, as set out in the report on ‘Deploying the bioeconomy in the EU’ . In particular, we appreciate the identification of the crucial need, at the highest political level, for policy makers to ensure demonstrable long-term, ongoing commitment towards the development of national and regional sustainable, circular bioeconomies.  
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Response to Revision of EU rules on food contact materials

28 Jan 2021

European Bioplastics welcomes the European Commission’s initiative to revise the current EU regulatory framework on food contact materials (FCMs), particularly in light of its recent initiative on Single Use Plastics, which has resulted in changes to materials used in this context. Currently, products made from bio-based plastics must undergo the same testing procedures as conventional plastic products to access the market of the European Union. Thereby a health risk for consumers is excluded. Plastics intended to be certified as biodegradable or compostable must undergo additional ecotoxicity tests. In this way, products made of bioplastics pass even more rigorous testing than conventional plastic products. In the EU, plastic products with food contact have to comply with strict regulations. These have to be met by bio-based as well as by conventional plastics. The relevant Commission Regulation, (EU) No. 10/2011, contains requirements for migration tests. A migration limit value indicates the maximum permitted quantity of an ingredient to transit into food. The limit value ensures that food contact material does not pose a health risk to consumers. In addition to the migration test, the composition of multi-component materials is checked. Only those substances and materials that have been assessed and listed in an EU overview as safe (Union List of authorized substances) may be used in their manufacture. Please find attached additional comments on the Commission's roadmap for FCMs from European Bioplastics. We remain available for any further information that you might require.
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Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

We write to express our concern regarding the recently published draft delegated act on technical screening criteria, determining under which conditions an economic activity qualifies as contributing substantially to climate change mitigation and adaptation. Some of these criteria pose a serious threat to future innovation and investment in the EU’s bioplastics sector and to its valuable role both in climate change mitigation and adaptation and within the circular economy. Provisions set out in Annex I (Climate Change Mitigation), #3.16, page 95, of the draft delegated act referring to the criteria for the manufacture of plastics in primary form, excluding food or feed crops for the production of bio-based plastics, represent a regressive initiative to resurrect the over-simplified argument of food v fuels/materials. This is unenlightened, since it has long been acknowledged that land use, fertility and availability are the critical issues at stake in feedstock production rather than the type of feedstock produced. In reality, for both environmental and economic reasons, we seek to extract value from every fraction of any given feedstock, including those that might previously have been regarded as wastes or residues, in the production of bioplastics. The provision is also in contrast with all relevant policies related to EU’s Bioeconomy Strategy, which does not differentiate between the type of crop used. The data shows that bio-based plastics do not lead to land use change and that today only 0.02% of all arable land is used for the production of biomass for bio-based plastics. However, we would suggest - in order to avoid any negative environmental impacts on land use change – that the technical screening criteria for bio-based plastics should be aligned with the ones already provided by the draft delegated act on “Protection of non-agricultural land with high carbon stock from land use change”. Furthermore, we suggest, aligning the technical screening criteria for bio-based products with the widely accepted and upheld EU feedstock sustainability criteria already in place for other economic actives (i.e. agriculture and forestry), in order to guarantee coherence and consistency on relevant sustainability criteria.We therefore respectfully request the cancellation of the feed/food crops limitations placed in the 3.16 letter c) and the strengthening of compliance with the sustainability criteria already stated in the same Annex. If the sustainability of EU feedstock is not taken into consideration, it will deliver a deeply contradictory message to the EU’s primary producers, processers and to all associated bio-based industries. It will undermine confidence and investment within this sector and is in direct contradiction to the recommendations set out in the EU’s Bioeconomy Strategy, Circular Economy Strategy, Horizon Europe’s strategic R&I agenda, as well as the overall ambitions set out under the European Green Deal. Furthermore, it will undermine the EU’s better regulation agenda and the ability to deliver on its own challenging climate objectives, particularly in the field of circularity of materials, fuels, feed, food and of renewability in general. In order to provide a level playing field and a meaningful comparison of bioplastics and conventional plastics it is vital to consider a complete overview of the GHG emissions from cradle-to-grave. These range from the impact of extraction of raw materials to manufacturing, product use, through to recycling/disposal in the end-of-life phase. The draft delegated act should evaluate substantial contribution to environmental objectives through a technology neutral approach using consistent criteria. The value proposition of bioplastics, towards climate change mitigation and adaption is considerable. However, further innovation and development in this sector will be decimated if a retrospective bias against the use of feed/food crops is now re-introduced.
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Response to Environmental claims based on environmental footprint methods

31 Aug 2020

Position of European Bioplastics Inception Impact Assessment on legislative proposal substantiating green claims Introduction – the role of bioplastics: The members of European Bioplastics are active contributors, investors and innovators involved in the transformation of the packaging sector. We support an ambitious Green Deal that recognises the role of sustainable low carbon and circular solutions, such as renewable materials, in achieving circularity and climate neutrality while creating a sustainable competitive advantage for the European industry. Achieving climate neutrality requires the contribution of all sectors of the European economy, and clear incentives for developing climate-friendly and sustainable practices, products and technologies. While energy efficiency and renewable energy are fundamental to reach this objective, climate neutrality will only be possible by also cutting the emissions associated with the production, use and disposal of materials. To fully capture the potential contribution of a circular bioeconomy towards climate neutrality, recognition of the role of renewable and low carbon materials is fundamental. In addition, ensuing maximum waste prevention is clearly the first step towards a circular economy, and bioplastics hold great added value in this respect. Using packaging to reduce food waste and composting biodegradable packaging enables the recycling of food waste which would otherwise be practically and economically prohibitive to otherwise recover. Bioplastics can also be appropriate in reusable models, reducing the generation of plastic waste, and can equally be appropriate for single use, depending on properties, functionality and impact. Our collective ambition is to ensure that the considerable benefits of bio-based, recyclable, compostable and biodegradable plastics are taken into consideration and that these materials can help contribute, to the fullest extent, towards delivering on the EU’s Green Deal. We consider that a failure to harness this potential will be significantly detrimental to the EU’s objectives in this core policy area. Substantiating green claims: EUBP supports the overall objective of this initiative, which is to unlock opportunities for the circular and green economy, including by fostering the growth of green markets through value chain thinking and ensuring a more efficient use of resources. We also specifically support the objective of moving towards a harmonised EU approach to measure and communicate accurate and reliable information on the environmental performance of products. It will be essential that this is done in line with the overarching principles of subsidiarity, in order to ensure that member states have the freedom to harmonise a coherent approach at national level. Furthermore, as a general principle, we believe that this process must be carried out in line with the policy objectives of the European Green Deal and the new Circular Economy Action Plan, which set the basis for an innovation-driven policy agenda to pursue sustainable growth and encourage both ambitious and economically viable solutions to scale-up circularity and contribute to climate neutrality. Critically, EUBP strongly believes that further efforts are needed to revise and finalise the Product Environmental Footprint (PEF) methodology and this will be indespensible if the EU is to effectively drive environmental performance in accordance with the objectives of the Green Deal. Furthermore, with regard to the parallel initiative on ‘Empowering the consumer for the green transition’ significant challenges remain, particularly with regards to ensuring effective communication, which will be essential if consumers, as key stakeholders, are to be enabled to directly engage in the transition towards a more circular economy. EUBP intends to be an active participant in discussions around substantiating green claims and looks forward to contributing further to
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Response to Review of the requirements for packaging and feasibility of measures to prevent packaging waste

5 Aug 2020

Attached is feedback submitted on behalf of European Bioplastics. We believe that bioplastics are a major driver in the evolution of plastics and that they contribute significantly to a more sustainable society. Our mission is to advance the economic and regulatory framework in Europe to allow for the bioplastics market to grow and flourish. Therefore, we aim to bring together all relevant partners and stakeholders and serve as both, a knowledge platform for all audiences and a business platform to support a sustainable technological development along the entire value chain as well as a full-scale market introduction of bioplastics. Our market Plastics make up a large share of the many products in our everyday lives. For almost every conventional plastic material, there is a bioplastics alternative already available on the market. Bioplastics are highly complex and sophisticated materials that can help make plastic products more sustainable and continue to develop the many benefits of plastics further. Due to a growing awareness and demand in our society for sustainable products and their impact on the environment, bioplastics materials are becoming the material of choice for a rapidly growing number of brands and customers around the world. Our latest market data predicts that between 2019 and 2024, global production capacities of bioplastics will grow by 15 percent, from around 2.11 million tonnes in 2019 to approximately 2.43 million tonnes in 2024. Our objectives - Aims for a favourable policy and economic framework to allow for the further technological advancement and full-scale market introduction of bioplastics - Promotes coherent standards, certifications and guidelines for transparent claims about bioplastics and their environmental benefits & impact - Advocates sustainable growing of biomass crops for the production of biobased plastics; - Supports the implementation of a better waste management infrastructure, including more efficient re-use, recycling, and recovery systems. Our members Founded in Germany in 1993 as IBAW, European Bioplastics today represents the interests of around 70 member companies throughout the European Union. With members from the entire bioplastics value chain, including agricultural feedstock, chemical and plastics industries, as well as industrial users and recycling companies that are located all over the globe and engage in the European market, European Bioplastics serves as business network as well as information platform.
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Response to Climate Law

6 Feb 2020

European Bioplastics (EUBP) strongly supports the European Commission’s (EC) ambition for climate neutrality by 2050, as announced in the Green Deal Communication. In view of the Roadmap for the upcoming Climate Law, EUBP invites the EC to consider the following recommendations: 1) Linking the bioeconomy and the circular economy is crucial to achieve climate goals A climate-neutral economy is a circular economy. Bio-based plastics made from sustainably grown and certified feedstock lower the carbon footprint of products and packaging contributing significantly up to carbon neutrality. The majority of bio-based plastics produced today are bio-based version of commodity plastics such as PE, PET or PP. These bio-based plastic versions feature the same properties as their fossil-based counterparts, while presenting the unique advantage of reducing the dependency on limited fossil resources and reducing greenhouse gas emissions. As plants capture CO2 during their growth, using renewable biomass as feedstock to produce bio-based plastics removes CO2 from the atmosphere and keeps it stored throughout the entire product life. This carbon fixation (carbon sink) is particularly relevant for bio-based reusable plastics applications, which allow for multiple uses with a limited carbon footprint. Furthermore, bio-based plastics create low-carbon secondary raw materials when mechanically recycled. Next to bio-based versions of conventional plastics new bio-based and mechanically recyclable plastics that provide increased technical properties need to be acknowledged when defining a circular economy. Materials such as bio-based PEF allow for less resource use (goal: prevention) and feature increased barrier properties (goal: food waste prevention). EUBP welcomes the EC’s commitment to develop a regulatory framework for bio-based plastics in the context of the Green Deal, and invites the EC to consider the benefits of bio-based feedstock when discussing low-carbon alternatives for plastic production. 2) Full circularity is needed to unlock the potential of the low-carbon transition In order to reach climate neutrality by 2050, we need to ensure full circularity is achieved. EUBP believes that wider waste management options should be considered to unlock the potential of the low-carbon transition, and in turn contribute to the EU’s climate ambitions. This is particularly relevant when considering certain categories of bioplastics, notably those, which are biodegradable. Biodegradable plastics that are certified compostable according to standard EN 13432 for compostable plastics focus on key applications in the packaging sector, where they contribute to the collection of bio-waste e.g. through the collection of heavily food-contaminated packaging that would otherwise not be recycled. Certified compostable plastics facilitate clean and separate waste streams by optimising the separate collection of bio-waste. Bio-waste represents with 40-50% the largest fraction of municipal waste, meaning that its efficient handling is a precondition to ensure that recycling targets set by EU waste laws are met. When they can be composted in industrial composting processes, certified compostable plastics used in selected food packaging applications contribute not only to reduce the amount of packaging which would otherwise not be recycled, but also to better collection of valuable volumes of bio-waste. This is needed for the production of high-quality compost and organic fertilisers, which are key to restoring soil’s organic carbon and mitigating climate change. EUBP welcomes the EC’s commitment to develop a regulatory framework for biodegradable plastics in the context of the Green Deal, and encourages the EC to consider compostable plastics and a circular economy approach, which encompasses the material cycle as well as the organic cycle.
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Meeting with Aurore Maillet (Cabinet of Vice-President Karmenu Vella)

19 Jun 2018 · Single-Use Plastics and Marine Litter

Meeting with Helena Braun (Cabinet of First Vice-President Frans Timmermans)

19 Jun 2018 · discussion on single use plastics proposal

Meeting with Helena Braun (Cabinet of First Vice-President Frans Timmermans)

20 Mar 2018 · discussion on Bioplastics & circular economy

Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen)

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Meeting with Heidi Jern (Cabinet of Vice-President Jyrki Katainen)

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Meeting with Sarah Nelen (Cabinet of First Vice-President Frans Timmermans)

21 May 2015 · circular economy