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Minderoo Foundation Limited ATF The Minderoo Foundation Trust

We are a modern philanthropic organisation that takes on tough, persistent issues to drive massive change.

Lobbying Activity

Response to Measures to reduce microplastic pollution

17 Jan 2024

In this position paper we provide our input to the launch by the European Commissions of a public consultation about the proposal for a regulation on preventing pellet losses to reduce microplastic pollution (Regulation). We strongly support the Regulation as a significant step towards addressing the growing environmental concern related to microplastic pollution associated with amongst others pellets. Minderoo Foundation (Minderoo) welcomes the release of European Commissions proposal for a regulation on preventing pellets losses as a significant step towards the implementation of measures to reduce microplastic pollution in European Union (EU). We appreciate the emphasis given to prevention, transparency in the reporting process, mandatory certifications and access to justice and penalty measures. There are, however, opportunities to strengthen the regulation proposal to reduce pellet losses and microplastic pollution further. Pursuing such opportunities would match the EUs stated ambition and pave the way for the Global Plastics Treaty, by setting harmonised, robust and mandatory measures to address pellet losses across the full lifecycle of plastics. We support the transition to a non-toxic circular economy by minimising the use of plastic and reducing unnecessary (production of) plastics. Prevention is key. We suggest enhancing the regulation proposal by clearly emphasising the health risks of microplastic-associated chemicals and the polluter pays principle to prevent microplastic pollution as much as possible. The polluter pays principle , as underlined by the EU law , requires that those who pollute should bear the costs managing impacts on human health and the environment. This includes preventing, reducing, monitoring, and remediating the spills and losses of plastic pellets, as well as to include legal recourse for justice, enforcement and compensation for harm to the environment and health. In light of our concerns regarding microplastic pollution, we strongly advocate for the Regulation to include: - ambitious targets for reducing pellet loss , in line with the EUs goal of reducing microplastic pollution by 50% by 2030. - reviewing the definitions by emphasising the hazards and toxicity of microplastics to protect the health of workers and enhance safety. - extending the scope to tackle other particles. - eliminating the threshold and exemptions. - incorporating Extended Producer Responsibility (EPR) obligations and measures as a tool to apply the polluter pays principle by including all producers and operators in the scope and hence responsible for achieving the EPR targets. - strengthen the requirements for pellet (waste) management. - introducing stricter penalties for non-compliance and enforcement. - promoting international cooperation .
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Meeting with João Albuquerque (Member of the European Parliament, Rapporteur) and Plastics Recyclers Europe

15 Jan 2024 · Preventing plastic pellet losses to reduce microplastic pollution

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

22 Nov 2023

The current revision of the Waste Framework Directive, which has guided EU policy in this area since 1975, offers an opportunity to design a coherent and consistent policy framework for a circular economy. Unlocking this potential requires a policy landscape that will create the opportunities, incentives, and confidence necessary for businesses to innovate and invest in the new business models that will break the link between material consumption and prosperity. As the EU seeks to continually enhance its environmental policies, Minderoo Foundation welcomes the revision of this regulation and recognises the need for further regulatory measures to achieve a circular economy. The current WFD has played a significant role in reducing waste generation and promoting waste prevention, reuse, and recycling. However, there is still room for improvement to achieve the ambitious goals of the Circular Economy Action Plan as underlined by the report from Eunomia and supported by Minderoo Foundation, Zero Waste Europe, TOMRA and Handelens Miljøfond Reimagining the Waste Framework Directive - an EU regulatory framework for a circular economy consistent with 1.5 degrees. Minderoo believes that the revision of the WFD is an opportunity to make a real difference in addressing the environmental impact of waste management. By strengthening the waste hierarchy, promoting extended producer responsibility (EPR), setting ambitious targets, improving data collection, and promoting innovation, the revised WFD can help to achieve a more circular economy in the EU. Please read the document attached if you want to know more on our recommendations for an ambitious revision of the Waste Framework Directive.
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Response to Environmental claims based on environmental footprint methods

21 Jul 2023

Minderoo welcomes the publication of the proposal for a Green Claims Directive as a positive step towards promoting transparent and accurate environmental claims in the European market. Indeed, Minderoo supports the general objective of this initiative, which is to unlock opportunities for the circular and green economy, including 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 and meaningful information on the environmental performance of (packaged) products. Recommendations to improve the methodology: Minderoo calls the EU legislator to clearly indicate the criteria and conditions companies must fulfil to display environmental claims. Trade-off analysis should be conducted via LCA for indicators for which there is a consensual methodology set by the Commission, such as the Product Environmental Footprint (PEF), to guide the design stage of products to eliminate unsustainable patterns from the beginning. ISO 14040 and 14044 provide guidance on the validation of Life Cycle Assessments. In addition, key environmental information from other sources should be included, such as land use, biodiversity, and social aspects. Human health risk assessment, chemical declaration, and relative magnitude of environmental impacts should be clearly displayed in line with REACH regulation revision. The assessment for such complementary criteria should be made through a qualitative explanation and Minderoo advocates for an EU-approved methodology to be defined through secondary legislation. It is crucial to prohibit environmental claims for products containing hazardous substances, and such requirements should not be delayed until a possible revision of the Directive. To avoid misleading claims, conditions and binding requirements with positive and negative lists (cf recommendation below on the plastic greenwashing claims to ban) should be specified aligned with UCPD. From this perspective, Minderoo believes that improvements are still required in the current proposal, especially in the following points: - While it is positive that the PEF method is not considered a one-size-fits-all method, the current proposal allows too much flexibility to companies, and further guidance on harmonised rules for which conditions apply to what claims are needed. - Unfortunately, the proposal to prohibit environmental claims for products containing hazardous substances, except where their use is considered essential for society, is postponed to a possible revision of the directive. As underlined in our PPWR position, the transition to a safe and just circular economy transition must be toxic-free for the consumers. Recommendations to improve the third-audit process: - To avoid generic claims and enable consumers to choose products that are genuinely better for the environment than their competitors, Minderoo recommends using specific and proportionate claims supported by tangible proof. - Claims which are already reviewed by a third-party expert who is independent and free from any conflicts of interest as well as with experience and competence in environmental aspects, should not have to go through an additional process. - A clear timeframe would be needed for approval regarding the other claims to avoid any cherry picking opportunity from the Member States for transposing the rules for pre-approval. - All information should be transparent, freely accessible, easy to understand and sufficiently detailed, on the pack or offline, using the digital product passport proposal of the ESPR, as mentioned above. - The directive should suggest a reasonable timeframe between processing and verification to ensure efficiency.
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Response to European Sustainability Reporting Standards

7 Jul 2023

Minderoo Foundation calls on the European Commission: a. Not to further reduce the ambition of the EFRAG standards proposal. b. Not to remove the mandatory core of the standards, given the risk of misinterpretation by preparers, auditors and supervisory authorities. The Commissions proposal to change a large number of disclosures under policies, actions and targets from mandatory to voluntary under the topical ESRS is alarming. Removing mandatory status allows companies the freedom to choose what to disclose, severely threatening the quality, comparability and overall reliability of sustainability information accessible to stakeholders. For example, under the current proposal, a company that determines the circular economy is a material topic does not need to report its targets in line with ESRS E5 (nor the metrics) to be compliant with the CSRD. This added flexibility proposed by the Commission will result in a sustainability statement with cherry-picked information on circularity that is not necessarily useful or relevant to sustainability report users, as well as decreasing comparability between different companies (and possibly the same companies year on year). In order to act effectively, companies must develop a robust understanding of how they contribute to the triple planetary crisis and the financial, commercial, legal, and reputational impacts, opportunities and risks they face as a result. Further, without actual data on the financial performance of a company, undertakings, financing institutions and investors are unable to make strategic and operational decisions. Keeping these metrics voluntary will mean that disclosure becomes an administrative burden rather than a tool for companies and stakeholders to drive towards greater sustainability and management of sustainability-related risks. EFRAG spent a considerable amount of time and involved a myriad of experts to determine which policies, actions, targets, and metrics are needed to assess the circularity performance of a company. We call on the Commission to adhere to these recommendations. c. Reintroduce the old phase-in periods recommended by EFRAG. The CSRD already includes later application dates for newly covered companies, listed SMEs and third-country corporate groups, agreed upon directly by the legislators. Only companies previously covered by the NFRD which have been reporting since 2018 need to start collecting data before the financial year of 2025. Additional phase-ins generate confusion about the exact timing each company will have to comply with the new reporting requirements. Delaying the entry into application of the reporting requirements does not seem to be the most meaningful way to improve the state of corporate reporting. It would merely push back transparency and action on addressing sustainability problems further into the future. Further, Minderoo Foundation recommends to: a. require a more granular breakdown of data, including by-country disaggregation, as well as further standardizing the datapoints disclosed to ensure their interoperability. Country-level breakdowns of data will highlight dependencies on sustainability topics and will grant financial market participants, companies, regulators, and policy makers greater insight to address impacts, risks, and opportunities as they are issues not only globally but nationally. Such data would heighten transparency, and support better data-driven policymaking at local and national levels to align with a 1.5, nature-positive future. b. Mandate companies to report on the process and the outcome of the materiality assessment and why they consider or do not consider a topic material.
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Meeting with Malte Gallée (Member of the European Parliament) and Deutsche Umwelthilfe e.V.

4 May 2023 · Packaging and Packaging Waste

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

21 Apr 2023

Minderoo welcomes the Commission's proposal for a revision of EU legislation for regulation on Packaging and Packaging Waste (PPWR proposal), to prevent negative environmental impacts of packaging and bolster reuse and recycling. The European Union has shown a commitment to transitioning towards a circular economy and production and use of safe and sustainable chemicals. This was shown in its Circular Economy Package II, its Chemical Strategy for Sustainability and the plastics strategy. Now, this proposal offers an important opportunity for the much-needed transition towards safer, more sustainable, and circular packaging systems at a time where it is crucial to prevent emissions, environmental pollution, biodiversity losses and non-renewable resource use in all sectors. In the context of the revision of the Packaging and Packaging Waste Directive and the Waste Framework directive according to Minderoo it is necessary to give agency to the actors of the value chain to be able to fulfil the different objectives with a concrete and stable regulatory framework and timeline by: - Contributing to limit fossil-fuel plastic production and consumption linked with the Circular Plastics Alliance commitment to boost the EU market for recycled plastics to 10 million tonnes by 2025 and the EU position for international negotiations of the treaty against plastic pollution. - Recognising the importance and utility of plastic materials and products in society and the imperative for a safe and circular economy for plastics. - Taking a whole-of-lifecycle approach: o Including the adverse impacts to human health and the environment in connection with the production, consumption and management of plastic materials and products across the life cycle (including in connection with raw material extraction, monomer production, polymerisation, product and material manufacture, use, re-use, recycling and disposal); and o Addressing all pollutants that result from or arise in connection with the production, consumption and management of materials and products across the life cycle, including macro- and micro-plastic pollution and leakage, toxic and hazardous chemicals and emissions, and greenhouse gas emissions across the lifecycle of plastics, from feedstock extraction through to end-of-life. - Supporting the transition to a safe and just circular economy for plastics, including by ensuring that plastic products and materials are designed to enable safe circularity and are circulated in practice. - Eliminating problematic and harmful substances and materials. - Achieving an ambitious and sustained reduction in the overall packaging waste generation with targets laid down for the reduction of packaging waste per material, including plastics, per capita to be achieved by 2030. - Eliminating plastic leakage to the environment across the life cycle, including through environmentally sound plastic waste management. - Avoiding regrettable substitution through ensuring alternatives are safe and sustainable. - Prioritising environmental and health protection by ensuring a timely adoption of the legislation. - Achieving ambitious targets on recycling and landfill ban of all packaging by 2030. - Recognising collection of packaging with the hierarchy and complementarity vision of packaging collection methods via Deposit Return Systems (DRS), Extended Producers Responsibility (EPR) schemes and mixed waste sorting. - Eliminating littering and increase separate collection rates of all packaging, including single use plastic packaging by: o Including in the EPR scheme costs the litter clean-up costs for all packaging. o Including separate collection targets for all packaging. - Defining key principles of closed loop recycling for DRS and high-quality recycling for the complementary systems and tools. - Informing consumers and citizens on the environmental impact of their packaging, littering and the sorting gesture.
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Meeting with Delara Burkhardt (Member of the European Parliament, Shadow rapporteur) and Industriegewerkschaft Bergbau, Chemie, Energie

18 Apr 2023 · Packaging Waste

Meeting with Martin Hojsík (Member of the European Parliament)

13 Apr 2023 · Plastic, health & environment

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

24 Jun 2022 · Circular plastics economy and fighting single use plastic pollution

Response to Sustainable corporate governance

23 May 2022

Minderoo Foundation’s No Plastic Waste Initiative seeks to increase transparency across global supply chains, in particular for single-use plastics (SUP), a key driver of global plastic pollution. Today, we have limited visibility on plastic material flows, from production to end-of-life. The lack of data makes it difficult to evaluate industry’s progress to their circularity and zero pollution targets. [1] We thus welcome the proposal for a Corporate Sustainability Due Diligence (CSDD ) Directive and the introduction of mandatory due diligence requirements to increase transparency and accountability for environmental impacts in global value chains. In particular, we support the application of the same due diligence standards on EU and non-EU companies with significant activities in the EU, as a way to ensure accountability for all products and services sold in the EU. We also welcome the requirement to conduct due diligence in the entire value chain, including suppliers and downstream customers. Complex, global value chains should not be cited as a reason for lack of transparency on serious environmental and human rights violations. The proposal takes a proportionate approach by applying these obligations to multinationals, not on SMEs for which they might be too burdensome. However, a number of points in the proposal need to be addressed: 1. Strengthen the provisions on climate change: The proposal contains an obligation for companies to draft a climate plan. However, it does not foresee any consequences for the breach of the duty to align their business model with the Paris Agreement 1.5 °C target. To avoid making the obligation ineffective, the provision on climate change must be linked to the main due diligence obligations as well as those on civil liability. 2. Strengthen civil liability and improve access to justice: Civil liability is restricted to first tier suppliers, if the company used contractual cascading and assurances and it was unreasonable to expect that the action taken would be adequate to prevent, mitigate or end the adverse impacts. This approach attempts to balance the need for accountability with the burden of conducting due diligence in the entire value chain. However, to avoid that this exemption leads to a mere box ticking exercise, further guidance and criteria for contractual cascading and assurances must be provided. Next, the proposal does not address the legal hurdles for bringing civil liability claims - in particular the often-disproportionate burden of proof and restricted access to internal company documents.[2] 3. Align the CSDD and CSRD provisions on environmental goals: While climate change is explicitly referred to in the proposal, the EU’s other interconnected environmental goals (for example ending pollution) are not. We call for a reference to the six environmental objectives laid out in Article 19b of the proposed EU Corporate Disclosure Directive (CSRD). As the CSDD due diligence requirements will inform corporate disclosures under the CSRD, it is important to align these proposals. Similarly, non-binding due diligence guidelines developed by the Commission under the CSDD should mirror the sustainability areas included in the CSRD. 4. Hold Boards accountable: The directors’ duty of care in the proposal should be strengthened. Boards should have a clear obligation to integrate sustainability risks and impacts into the company strategy. Further, a minimum percentage of variable remuneration of directors should be linked to the sustainability performance of companies. Such a measure has already received support from a significant group of EU company Directors [3]. [1] Minderoo Foundation, Plastic Waste Makers Index, May 2021 [2] Letter to the Commission by Accounting Europe, Pascal Canfin and 40 CEOs, February 2022. [3] For example, mechanisms to lower the burden of proof were adopted under the EU Damages Directive (2014/104/EU) and are considered for the digital age and AI
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Meeting with Pernille Weiss-Ehler (Member of the European Parliament, Rapporteur)

5 May 2022 · Waste Shipment Regulation

Meeting with Pascal Durand (Member of the European Parliament, Rapporteur)

22 Mar 2022 · ESG (APA only)

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

22 Feb 2022

The Minderoo Foundation welcomes the review of the Waste Framework Directive. To inform this policy process, we would like to submit findings and recommendations from ongoing Minderoo and KPMG research into plastic waste streams in 5 EU countries (FR, GE, IT, NL and PL). 1. Almost half of our plastic waste is not collected for sorting and recycling. A major share of plastics (excluding DSR) ends up in municipal solid waste (MSW), and is almost fully incinerated or landfilled. In most markets, separate collection of plastics remains limited to 60–80% due to poor discipline or other factors. There is therefore a big opportunity to recover plastics through MSW sorting. Plastics from MSW are often perceived as too contaminated for recycling, but major technology improvements have been made (e.g. automated sorting, purification and deodorizing technologies) which can produce virgin replacement quality for food and non-food applications. Some countries are already sorting plastics from MSW (NL, DEN, SP). 2. There is an opportunity to reduce losses in the sorting process caused by non-recyclable plastics (e.g. multi-material laminates). These losses - and the overall cost of recycling - can be reduced through design for recycling guidelines. 3. A large share (~30%) of sorted plastics are lost in the recycling process. There is a quality issue at the sorting level, partly driven by EPR. Sorters often receive EPR contributions for volumes “sent-to-recycling” with minimum purity requirements. A high share of mixed plastics - resulting from poor quality sorting - is mostly used for RDF or incinerated, as recyclers do not have the business case or technology to process these. Costs of further sorting are often not covered by a higher market price. 4. The uptake of recycled plastics in new products is limited (~10%) and mostly focused on downcycling. This is driven by low prices for (near-) virgin quality recyclate and limited infrastructure investments. While technologies for advanced mechanical and chemical recycling exist, the business case for high-quality recycling is not yet sufficiently attractive for the fast ramp-up that is required. Recommendations: 1. Strengthen the waste hierarchy through re-use and higher-quality plastic recycling: measures to increase plastic product re-use and uptake of recycled content can include: • Binding re-use targets. • “Design-for recycling” guidelines for plastics to improve recyclability, reduce costs and increase recycling yields. • Boost demand through recycled content targets for plastics, beyond packaging. • Establish preferential access principles for plastic waste feedstock to prioritize low-carbon, high-value outcomes. For example: • Limit chemical recycling to plastics not suited for mechanical recycling or for applications that are high-risk from a food safety perspective. • Give packaging producers priority access to plastic waste over downcycling and incineration (incl. sustainable fuels). 2. Extend mandatory EPR to plastics other than packaging, including textiles. 3. Level the playing field for plastics sorting from MSW: The WFD prioritizes separate collection of waste over MSW sorting. This focus is reflected in other EU policies (e.g. PPWD or even the draft EU Taxonomy criteria) and impacts the growth potential of MSW sorting systems. While for other waste categories (e.g. paper), separate collection is needed to maintain quality, evidence shows that this is not necessarily the case for plastics. Measures can include: • Establishing that EPR systems cover plastics sorting from MSW, as a complement or alternative to separate collection (cf. Denmark). • Guidelines to help authorities and PROs determine which mix of collection and sorting systems for plastics (DRS, separate collection, MSW sorting) is most effective. Guidelines can describe best practices for MSW sorting, including examples of incentives to sort plastics from MSW (gate fees, tax credits).
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Response to Setting the Course for a Sustainable Blue Planet -Update of the International Ocean Governance Agenda

15 Feb 2022

Minderoo Foundation is a philanthropic organization based in Australia and the Netherlands. Through our No Plastic Waste initiative, we seek to end plastic leakage to nature and maximize circularity for plastics by 2030. We increase transparency across the plastics supply chain to help industry, investors and governments to better understand the sources of pollution. Minderoo’s Flourishing Ocean initiative aims to return our global ocean to a healthy state. We invest in data, methods and infrastructure to address the problem of overfishing and promote marine conservation. We welcome the initiative to update the EU International Ocean Governance Agenda and step-up action to protect our global ocean. Minderoo Foundation published the following research which can inform the EU agenda to drive global action: A. The 2021 Plastic Waste Makers Index unveils the largest producers responsible for Single-Use Plastic (SUP) waste, and who funds them. The Index models global single-use plastic material flows from polymer production to waste generation. The five key findings of our report are: 1. In 2019, just 20 polymer producers accounted for more than half of all SUP waste generated globally – and the top 100 accounted for 90%. 2. By 2025, global capacity to produce fossil fuel-derived polymers for SUP could grow over 30%. 3. Not a single company among the largest 100 polymer producers procures more than 2% of its feedstock from recycled materials. 4. US$ 10 billion is invested in SUP production by 20 institutional fund managers, led by Vanguard, BlackRock and Capital Group. US$ 30 billion in loans for SUP production were also made by 20 of the world’s largest banks since 2011. 5. SUP waste is a geopolitical problem. This is underscored by the high degree of state ownership in polymer producers – an estimated 30% of the sector, by value, is state-owned. Without urgent action, the plastic pollution crisis is set to become a lot worse before it even starts to get better. The EU should therefore push for a global plastic treaty which sets legally binding targets to phase down the production of virgin SUPs, and work with other countries to increase the recycled content used in plastic products. www.plasticwastemakersindex.org B. The 2021 Global Fishing Index is the most-comprehensive assessment of the state of fisheries to date, reporting on the sustainability status of 1,465 fish stocks across 142 countries. The Index reports these data alongside assessments of data availability and fisheries governance to report on country-level progress toward SDG target 14.4. Our report finds that: 1. Countries are not delivering against global fisheries sustainability commitments. 2. Half of the global fisheries catch is from stocks that lack sufficient data to determine if they are sustainable or not. 3. Almost half of stocks assessed are overfished, while nearly 1 in 10 been driven to the brink of collapse. 4. Most fisheries lack science-based management: fisheries data are not consistently collected or analysed, data aren’t used for management, and laws aren’t being enforced. 5. Vital stakeholders, including local fishing communities, are unable to effectively participate in fisheries management The Index also identifies critical actions which are needed to help reverse fisheries decline and meet sustainability targets. Governments must set strong, time-bound and measurable targets to restore fish stocks and improve management. Strong systems of fisheries governance are integral to protecting and restoring the health of the ocean more broadly. The EU can demonstrate global leadership and drive action on these outcomes by (i) pushing for the rapid conclusion of WTO fisheries subsidy reform, (ii) driving the adoption by both EU and non-EU countries of mandatory corporate due diligence requirements related to fisheries, and (iii) ramping up the enforcement of existing EU MCS regulations. www.minderoo.org/global-fishing-index
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Meeting with Sarah Nelen (Cabinet of Executive Vice-President Frans Timmermans)

7 Jul 2021 · Meeting on Hydrogen

Meeting with Frans Timmermans (Executive Vice-President) and Fortescue

28 Jun 2021 · Hydrogen Policy

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

11 Jun 2021 · Discussion on ending plastic pollution and ensuring a circular plastics economy

Meeting with Frans Timmermans (Executive Vice-President) and Fortescue

31 May 2021 · Hydrogen Policy