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Novamont SpA

Novamont

Novamont is a world leader in bioplastics and bioproducts, promoting a circular bioeconomy model focused on sustainable use of renewable resources and soil regeneration.

Lobbying Activity

Meeting with Grégory Allione (Member of the European Parliament)

16 Dec 2025 · Rencontre avec Novamont

Eni S.p.A. urges EU to harmonize circular economy rules

6 Nov 2025
Topic — The consultation seeks input on the proposed EU Circular Economy Act.
Message — Eni calls for harmonized waste criteria and simplified permitting to boost circular investments. They advocate for a single market for secondary raw materials and mutual recognition of national authorizations.123
Why — Uniform standards and reduced bureaucracy would lower operational costs and protect Eni's bio-based investments.45
Impact — Non-European manufacturers would face higher barriers to entry due to proposed equal treatment requirements.6
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Meeting with Luis Planas Herrera (Cabinet of Commissioner Jessika Roswall) and European Bioplastics

4 Nov 2025 · Circular economy

Novamont urges EU to revise pesticide hazard weighting methods

14 Oct 2025
Topic — This consultation simplifies regulatory requirements for food safety and plant protection products.
Message — Novamont requests a revision of the calculation method for determining pesticide risk reduction. They propose adjusting hazard weightings to favor low-risk substances or excluding naturally occurring products from reduction targets.12
Why — New calculation rules would increase the market competitiveness of Novamont's bio-based products.3
Impact — Synthetic pesticide manufacturers would see their products ranked as significantly more hazardous.4
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Response to European Innovation Act

3 Oct 2025

We welcome the development of the Innovation Act, to foster the innovation and remove the barriers that do not allow the innovative companies to scale up their products and access the market, promoting industrial development in strategic sectors related to circular economy and bioeconomy. In particular, the bioeconomy offers sustainable solutions for food, bio-based materials and energy needs while preserving natural resources, contributing to addressing climate change and ensuring high-quality environmental services. To fully exploit the potential of the EU bioeconomy, the future EU Innovation Act should be strictly connected to the objective of the EU bioeconomy strategy and the future Circular Economy Act, thus guaranteeing a legislative framework able to safeguard the European competitiveness in the international market by removing current regulatory barriers that create disproportionate burdens and hamper the development and growth of innovative technological solutions in the EU. It is important to exploit the full potential of European companies that have already made investments in the decarbonization of products, by supporting their innovation activities, also in order to support European leadership in this sector. In this sense, the EU Innovation Act can be seen as an opportunity to support all the innovative activities and products of chemical industries providing solutions to preserve the ecosystems from pollution and to decarbonize the economy Focusing on the bioeconomy sector, the biomass-derived products are tools to improve European strategic autonomy and to contribute to the decarbonization goals. In addition, bio-based biodegradable and compostable plastics both potentially reduce the volume of plastic waste sent to landfill, and contribute to the EU bio-waste collection (not contaminating compost) and pollution reduction objectives. To enhance the contribution of bio-based products, to the decarbonization of the economy and the reduction of climate-changing emissions, it will therefore be necessary to identify tools to accelerate the market access to such products. The EU Innovation Act, in synergy with the Bioeconomy Strategy and the Circular Economy Act, should facilitate the use and valorization of scraps and byproducts coming from bio-based industries, removing the obstacles that do not allow their full valorization. It should also facilitate the access to market of bio-based products that represent a sustainable alternative to existing ones (i.e. phytosanitary products) reducing the time required for their authorization. At research and innovation level, the need for Europe is to demonstrate, on the large scale, the integration of processes for the production of biobased monomers and derived biobased materials by increasing processes yield and selectivity, optimizing the recovery of by- and co-products from the different process steps exploiting the synergy with the agricultural sector and leveraging investments at industrial scale. In this sense it would be important to activate new tools/incentives to support the scale up of innovation to market (TRL9), in synergy with CBE-JU and the EU Innovation Fund. In terms of topics covered, in order to assist the development of circular bioeconomy it would be essential to invest more on the scale-up of existing technologies at industrial level and to facilitate the market uptake of the final products via specific financial tools and incentives. The route towards implementing and running biorefineries needs a coordinated effort for overcoming some of the existing technological, legislative and commercial barriers. It will be crucial to integrate knowledge of previous projects results as a basis not only for building new programs but also for capitalizing on successful investments already made.
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Novamont seeks Nature Credits for bio-based and biodegradable products

30 Sept 2025
Topic — This consultation explores a roadmap for Nature Credits to value ecosystem-strengthening activities.
Message — Novamont requests that Nature Credits reward industrial bioeconomy activities that use bio-based feedstocks and provide ecosystem solutions. They advocate for credits for compostable plastics and biodegradable agricultural films that protect soil health.123
Why — This framework would create new income streams for Novamont's bio-based products and bioplastics.4
Impact — Manufacturers of traditional plastics face a competitive disadvantage against credited biodegradable alternatives.5
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Novamont backs biodegradable mulch and new bio-based feedstocks

19 Sept 2025
Topic — Evaluation of the EU Fertilising Products Regulation assessing its effectiveness and relevance.
Message — Novamont supports rules for biodegradable mulch films to tackle persistent microplastic pollution in soil. They request that the EU allow bio-based industrial sludges to be repurposed as fertilizer ingredients. The company advocates for replacing conventional plastics with biodegradable alternatives in high-risk agricultural applications.123
Why — This enables the company to trade its products across the European Single Market without restrictions.4
Impact — Conventional plastic manufacturers lose market share as the EU prioritizes biodegradable alternatives for soil health.5
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Meeting with Stefan Köhler (Member of the European Parliament)

28 Jul 2025 · Politischer Austausch

Novamont pushes for biowaste inclusion to restore soil fertility

25 Jul 2025
Topic — This regulation lists products and waste streams with potential for critical raw materials recovery.
Message — Novamont advocates for the direct use of digestate and compost to enhance soil health. They suggest mandatory compostability for certain items to ensure high-quality, uncontaminated organic waste collection.12
Why — Mandatory compostability rules would secure a larger market for Novamont's bioplastic products.3
Impact — Traditional plastic manufacturers would be excluded from specific organic waste-related product markets.4
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Novamont urges dedicated Innovation Fund calls for bio-based products

8 Jul 2025
Topic — Evaluation of the EU Innovation Fund’s performance in supporting industrial decarbonization and technology.
Message — Novamont requests dedicated funding calls for bio-based industries to support technology scale-up. They advocate for tools that bridge the competitiveness gap between bio-based and fossil products.12
Why — Targeted support would reduce Novamont's financial risk when scaling up biorefineries to industrial levels.34
Impact — Fossil material producers face displacement as the fund prioritizes substituting fossil feedstocks with bio-based alternatives.5
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Eni urges EU to support industrial transition to bioeconomy

23 Jun 2025
Topic — The consultation seeks views on building a circular and climate-neutral bioeconomy.
Message — Eni wants a framework that supports converting traditional industrial plants into biorefineries. They suggest mandatory bio-based content targets and tax incentives to offset fossil product costs. They also call for harmonized waste regulations to facilitate the reuse of industrial residues.123
Why — These measures would protect Eni's investments and reduce the price gap with fossil products.45
Impact — Fossil fuel producers face lost market share as regulations accelerate the substitution of fossil feedstocks.6
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Novamont urges EU to mandate bio-based plastic targets

11 Jun 2025
Topic — The European Commission is consulting on measures to accelerate the EU's biotechnology sector.
Message — Novamont seeks mandatory bio-based targets and financial incentives for biomass usage. They also request a unique industrial classification code to distinguish bio-based products.123
Why — Mandatory targets and unique codes would secure market share and unlock new subsidies.4
Impact — Traditional petrochemical companies lose out as regulations favor biomass over fossil-fuel materials.5
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Meeting with Giorgio Gori (Member of the European Parliament) and Eni S.p.A.

20 May 2025 · Presentation of priorities

Novamont Urges EU Strategy to Mandate Bio-based Content Targets

17 Apr 2025
Topic — This consultation gathers views on a new strategy to improve European life sciences competitiveness.
Message — Novamont calls for mandatory bio-based content targets and financial incentives for bioeconomy products. They request dedicated NACE codes and simplified waste valorization to improve circularity. They also advocate for promoting compostable plastics in agriculture and packaging.123
Why — Mandatory targets and financial incentives would secure market demand for Novamont’s bio-based products.4
Impact — Producers of traditional plastics would face market displacement and competitive disadvantages from bio-based alternatives.5
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Meeting with Taru Haapaniemi (Cabinet of Commissioner Christophe Hansen) and European Bioplastics

13 Feb 2025 · Exchange on the potential of the bioeconomy

Response to Aligning the biodegradability criteria for polymers in EU fertiliisng products to the REACH restriciton on microplastics

5 Apr 2024

Novamont, one of the leading companies in the production of biodegradable and compostable materials, welcomes and supports the drafts published by the European Commission on 8th March 2024, proposing biodegradability criteria for biodegradable mulch films and polymers to be used for coating agents in the European Fertilizers Regulation 2019/1009 (FPR) and the proposal to include biodegradable mulch films in the Component Material Category 9, Annex II of the European Fertilizers Regulation 2019/1009. We support the challenging biodegradability criteria proposed for the two end of life compartments (soil and water), as guarantee for soil health and functionality. Specifically, the criteria proposed for soil are in line with those included in the European standard EN 17033:2018 on biodegradable mulch films. Biodegradable mulch films have been tested and commercially exploited since over 20 years, mainly on vegetable crops, where they have been proved to have yield and quality comparable to conventional plastic films and represent a solution increasingly used by growers. This proposal represents a milestone in the recognition of the role of biodegradable mulch films as effective and sustainable solutions for agriculture in the transition towards the implementation of circular bioeconomy products for the sector and as contribution to reaching the target set out in the Communication on the Farm to Fork Strategy in terms of reduction and optimization of inputs and soil health. Biodegradable mulch films would achieve a clear status in all the Member States and would be able to access a single European market.
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Response to Measures to reduce microplastic pollution

12 Jan 2024

Please find attached Novamont feedback on the consultation
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Novamont urges incentives for compost and soil-biodegradable plastics

3 Nov 2023
Topic — This consultation addresses the creation of a legal framework for protecting EU soils.
Message — Novamont recommends financial rewards for using compost to improve soil and carbon storage. They demand mandatory rules including the use of special soil-friendly biodegradable plastics.12
Why — Stronger mandates for biodegradable products would significantly increase Novamont's European market share.34
Impact — Producers of traditional plastics lose out as regulations shift demand toward biodegradable materials.56
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Novamont demands scientific rigor for EU green claims

19 Jul 2023
Topic — The initiative requires companies to substantiate environmental claims using specific footprinting methods.
Message — The company supports strict criteria based on scientific evidence and life-cycle assessments. They argue current footprint methods are insufficient because they fail to account for microplastics. They suggest claims for bio-based products must be based on measurable biogenic content.1234
Why — Harmonized rules would reduce regulatory burdens for Novamont’s international bioplastics trade.5
Impact — Firms using vague mass balance labels would lose the ability to claim sustainability.67
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Meeting with Patrizia Toia (Member of the European Parliament, Rapporteur for opinion)

28 Jun 2023 · PPWR (meeting held by the APA responsible)

Novamont demands EU include bioeconomy in Net-Zero Industry Act

27 Jun 2023
Topic — The EU is consulting on regulations to support domestic manufacturing of net-zero technologies.
Message — Novamont requests that the Net-Zero Industry Act includes the circular bioeconomy as a strategic pillar. They seek funding for operating costs and capital expenditures to compete with global markets. The group urges the EU to integrate bioeconomy into all policies.123
Why — This proposal would provide Novamont with the funding needed to compete against global rivals.45
Impact — Rural regions lose out on vital knowledge transfer and industrial revitalization efforts.67
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Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness)

1 Jun 2023 · Taxonomy and plastics

Response to Ecodesign for Sustainable Products - Product priorities

11 May 2023

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 promote properties such as renewability, biodegradability and compostability, 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 for biodegradable and compostable products. To achieve a true climate neutral, circular economy, it is essential to promote the adoption of sustainably sourced biobased resources. Both, biobased and recycled content contribute to reducing the dependency on virgin fossil resources and GHG emissions, and they should be supported. 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 and compostable 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 have microbes that are able to metabolise these polymers. The residence time is considerably lower for biodegradable polymers compared to conventional plastic materials. Certified compostable plastics and materials biodegrade after usage in a closed organic recycling system together with other organic waste and can, for example, be recycled into compost and fertiliser. Scientific Opinion No.10 of the European Commissions Group of Chief Scientific Advisors on Biodegradability of Plastics in the Open Environment notes that applications [...] in which plastics and organic waste unavoidably mix and cannot be easily separated could benefit from using biopolymers that biodegrade under conditions of the managed composting system (December 2020, p.24). Furthermore, a transition towards the use of biodegradable and compostable plastics would allow to reduce waste that is usually landfilled or incinerated, thus significantly reducing the impact of these single-use products on climate and environment, and instead shift to resource generation. 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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Novamont urges broader EU Taxonomy recognition for compostable packaging

3 May 2023
Topic — The EU is defining sustainable investment criteria for manufacturing plastic packaging goods.
Message — They want the EU to include agricultural biomass and recognize organic composting as sustainable. They also seek to expand the list of approved compostable packaging applications.12
Why — This would enable Novamont to attract sustainable investment for its entire bioplastic product range.345
Impact — Mechanical recyclers might lose market share to composting facilities for processing contaminated food packaging.6
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Novamont calls for greater role for compostable packaging in PPWR

21 Apr 2023
Topic — The EU is revising packaging regulations to promote recycling and reduce waste.
Message — Novamont requests a 60% minimum bio-based content for compostable packaging and expanded mandatory composting lists. They also seek a five-year derogation for innovative polymers to establish sorting technologies.123
Why — These changes would protect Novamont's competitive position and increase the market for bioplastics.4
Impact — Conventional plastic recyclers face risks from compostable materials potentially contaminating their waste streams.5
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Novamont urges EU to include bioeconomy in carbon certification

23 Mar 2023
Topic — The European Commission is proposing a regulatory framework for certifying carbon removals.
Message — Novamont requests that sustainability objectives include the promotion of the bioeconomy and soil protection. They argue that compostable applications enable efficient organic waste collection and carbon storage.12
Why — This would allow Novamont to certify its bioplastic products as carbon-removing solutions.3
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Meeting with Patrizia Toia (Member of the European Parliament) and McDonald’s Global Franchising Limited

15 Feb 2023 · Packaging Regulation

Novamont seeks reclassification of bacteria as sustainable biofuel feedstock

30 Dec 2022
Topic — The consultation concerns updating the list of sustainable feedstocks for advanced biofuels.
Message — Novamont argues that bacteria such as Escherichia Coli should be reintroduced to Annex IX. This would allow spent bacteria from industrial fermentation to be used for advanced biomethane.12
Why — This would allow the company to monetize its manufacturing byproducts as advanced fuel.34
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Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness)

6 Oct 2022 · Bioplastics and other products

Novamont calls for high compost standards in carbon certification

2 May 2022
Topic — The EU is proposing a regulatory framework for monitoring and certifying sustainable carbon removals.
Message — Incentives should only support high-quality compost that meets EU Fertiliser Regulation standards. Specific land management practices like regenerative agriculture and mandatory grassland maintenance must be prioritized.12
Why — Stricter quality standards would create a larger European market for their bioproducts.3
Impact — Waste treatment facilities producing low-quality compost would be excluded from carbon incentives.4
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Response to Soil Health Law – protecting, sustainably managing and restoring EU soils

15 Mar 2022

A European Soil Health Law is urgently needed to make credible the challenge of reducing soil degradation, developing a set of regulative tools and levers to guide the behavior of economic, social and institutional actors, supporting their choices consistent with 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. The promotion of circular bioeconomy should be considered as a key element in the strategy aimed at achieving the protection of soil from pollution and degradation. The bioeconomy, declined in the circular perspective, is based on three principles: • territorial regeneration • soil health • creation of interconnections between different sectors The circular bioeconomy is an essential tool to combat the phenomenon of climate change and to increase the competitiveness of Europe. The circular bioeconomy is a key tool for doing more with less, overcoming the excessive exploitation of resources, the problems of pollution, and closing the carbon and nutrients cycle. Three are the priorities that should be expressed in promoting this sector: 1. STOP THINKING ABOUT UNLIMITED GROWTH: Avoiding the one-to-one replacement of fossil-based materials with renewable materials. 2. USING BIOPRODUCTS TO TRIGGER A CULTURAL CHANGE: Redesigning the way in which materials are produced, consumed and disposed of, encouraging the growth of multi-product supply chains with high added value. 3. STOP THE DEGRADATION AND POLLUTION OF WATER AND SOIL: Use biodegradable products for those applications where there is a high risk of dispersion and accumulation in the environment and to avoid the loss and waste of organic matter. To implement the circular bioeconomy requires a systemic redesign effort, capable of correlating soil and water health, food production and safety as well as the pressure of anthropogenic activities at different levels, creating a society in which agriculture, environment, industry, large retailers, the waste treatment sector and the academic and training world are integrated. Biodegradable and compostable products – according to the European standards - which do not accumulate into the environment can provide a substantial contribution to pollution and contamination problems, as well as a key vehicle to bring organic carbon back in soil as well as other nutritive elements, increasing its fertility. The use of clean compost and other organic materials in agriculture is an important solution to two problems: by preventing organic waste from ending up in a landfill, a practice prohibited by the new Waste framework directive as from 2024; by adding an invaluable soil improver. This practice leads to a gradual improvement in crop health, increase soil fertility while reducing the inputs of pesticides and inorganic fertilisers. The application of compost in soil allow to obtain advantages in terms of carbon sink and reduction of GHG emissions, by incorporating carbon in soil. In this sense, Carbon farming should be promoted, as a way to increase soil carbon sequestration through a variety of agricultural methods, while also preserving and restoring soil health through the increase of soil organic matter. Moreover, circular bioeconomy promotes the construction of integrated agro-industrial value-chains based on sustainable use of biomass, valorizing dryland crops which can be grown on marginal lands. Finally, it will be important to strengthen the link between farmers and research and innovation through Lighthouse Farms in which farmers, researchers, civil society and other stakeholders plan together innovative agricultural systems aimed at reducing environmental impacts and maximizing the efficient use of resources for high quality soil.
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Response to Waste Framework review to reduce waste and the environmental impact of waste management

15 Feb 2022

Food waste collection (and – prevention) is crucial for the objectives of the waste framework directive. Zero Waste Europe reported that only 26% of the food waste generated is separately collected. This means that the majority of food waste is landfilled or incinerated. The separate collection of food waste is important because it can be recycled into mature compost, whose application on soil will improve its health: - the moisture-retaining capacity will increase and thus the production of biomass, also in drier periods; - the adsorption, filtration and purification capacity are increased, which in turn results in a higher quality of the groundwater; the higher adsorption capacity of the soil leads to inactivation of chemical contaminants, which prevents the absorption of these components by plants, resulting in improved food quality; - binding of extra carbon contributes to climate mitigation (see the “4per1000” launched at the Paris Climate Summit in 2015) - soil life is stimulated, which increases biodiversity. A healthy soil is crucial, and by collecting food waste separately -i.e. increased the production of compost- a contribution is made to several Sustainable Development Goals It is crucial that the quality of compost is high, both in relation to maturity and lack of contamination. - Contamination with plastic (but also glass) is a major concern for food waste, digestate and compost. Similar to work done in the US, the risk of non-biodegradable plastic contamination should be investigated. Current legislation in many EU-countries allows 0,5% of contaminants, which may be not stringent enough. - Mature compost contains more stable organic matter and is crucial for carbon sequestration - As a general remark, the current focus of (organic) waste collection is on the quantity of food waste processed and not on the quality of compost produced. Therefore specifications on both maturity and level of contamination should be considered. The EMF has developed a vision for a circular plastics economy, which promotes that all packaging should be re-usable, mechanical recyclable or compostable (i.e. recovered by organic recycling); leakage of materials in the environment should be minimized. A huge amount of packaging in the market is not recycled at all. Wageningen University has reported for the Netherlands that only 27% of the plastic packaging on the Dutch market is easily recyclable using current sorting and recycling techniques. Statistical data on the leakage of products is lacking. There is a lot of attention on litter, i.e. (single use) plastics products disposed by consumer in the environment, but leakage of material in general, e.g. tear and wear of products or plastics used in agriculture are not known. DIRECTIVE (EU) 2018/851 states that bio-based and compostable products could represent an opportunity to stimulate further research and innovation and to promote the use of renewable resources. In order to promote this, but also to achieve the production of high quality compost, the production and development of compostable products should be incentivised based on the following criteria: -The product helps to increase the amount of food waste collected, -The product helps to decrease contamination of compost -Separation of product from attached organic waste is not possible, -Collection for recycling is not possible Recommendations for policy measures in the Waste Framework Directive: -Policy should promote the use of compostable plastics bags and packaging for those products that are prone to be mixed with organic waste and/or that support the optimization of the organic waste collection and treatment, by allowing the production of pure and clean compost, to be used to restore soil fertility and to capture carbon. -Policy should promote the application of quality compost to soil (very strict limitations on the amount of contamination, financial incentives for carbon sequestration of compost
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Response to Food waste reduction targets

29 Oct 2021

The prevention, collection and organic recycling of bio-waste is one of Europe’s biggest challenges. The New Waste Framework Directive (WFD), included in the Circular Economy Package, mandates the introduction of separate collection of bio-waste as of 1 Jan 2024. Recycling bio-waste into high quality compost allows to bring back carbon to soil and close the loop of the “carbon cycle”, thus contribution to the overall goal of building a resilient circular economy and contribution to EU’s climate neutrality goal. In this context biodegradable and compostable plastics could contribute to EU’s policies on circular economy and reducing plastics persistence in soil, as well as in the valorization of unavoidable food waste. The introduction of door-to-door collection systems is a key tool to increase the amount of food waste collected, as well as the promotion of the use of biodegradable and compostable bioplastics for those applications that are more prone to be mixed with organic content (i.e. bags for the collection of biowaste, food packaging, food service ware), allowing to reduce the risk of contamination of biowaste with traditional non-compostable plastics. The use of these products should be promoted also in closed-loop systems, such as public events or canteen, where they allow to facilitate the process of waste collection, maximizing quantity and quality of biowaste. In fact, biodegradable and compostable plastics plays an important role in achieving the EU’s ambitious targets for bio-waste recovery and its diversion away from landfill and incineration by 2024. Evidence show that biodegradable and compostable plastics play a vital role in the collection, sorting and recycling of bio-waste: • Increase the capture rate of compostable plastics: from the report published by the Bio-based Industry Consortium and Zero Waste Europe on bio-waste: “In terms of performance, commingled schemes for bio-waste (food + garden waste) without the use of compostable bags as a liner for food waste […] usually capture 10-30 kg per capita per year. […] Households are given caddies with liners of either paper or EN-13432 certified compostable bags. […] Such schemes typically allow collection of 60- 100 kg per capita per year of food waste. • Reduce plastic contamination in the final compost: recent presentation done by the UK association of biodegradable and compostable plastics shows that in countries such as Italy, where compostable materials are more used, the plastic contamination of bio-waste is lower (https://ebcd.org/wp-content/uploads/2020/08/BBIA-David-Newman-PDF-Presentation.pdf) This sector, as well as the circular bioeconomy as a whole, will be crucial to support the European goals related to the Farm to Fork Strategy, as well as the circular economy package, the Green New Deal, the next generation Europe and the Bioeconomy Strategy. As a virtuous example, the separate collection of organic waste is one of the strengths of Milan waste management system: these good practices have been encouraged by the introduction of the door-to-door collection system, with a process that began in November 2012 and that in June 2014 reached 100% coverage of the territory of the Municipality of the town. The introduction of the residential food waste collection allowed Milan to achieve a level of 103 kg of organic waste collected per person in 2017, that makes of Milan a “virtuous case” at an international level of the “Italian model” for separate collection of organic waste.
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Response to Policy framework on biobased, biodegradable and compostable plastics

26 Oct 2021

Europe is a global pioneer in the field of biobased, biodegradable and compostable plastics (BBPs and BDCPs), with a series of measures that have marked the history of the sector and have so far enabled its development. 1. The packaging directive in 1994 clarified the concept of organic recycling and the European Committee for standardisation (CEN), on a mandate (Mandate M200) from the European Commission (EC), established a series of harmonized standards that were the first guidelines necessary for the development of the sector. 2. Subsequently, the Lead Market Initiative for Bio-based Products gave rise to in-depth studies and finally to the production of European standards on bio-based products, under a series of mandates from the EC. These European standards clarify the terminology, the analytical methodologies, and finally the means for a correct communication to consumers on the bio-based content. 3. On this basis the EC invested in scientific programmes and research activities related to the development of BBPs and BDCPs, which generated a lot of valuable scientific data, as well as economic and social development. The evolution of the sector certainly now requires a review of the work done in the last thirty years. However, surprisingly, many European legal acts and related implementing actions that founded an innovative industrial sector in Europe are not mentioned in the Roadmap, together with the many success stories. it is necessary now to reap the fruits of a research, development, and industrial activity which sees Europe in a leadership position, but which appears closely chased by growing initiatives in other continents (i.e. Asia). We welcome the necessary revisions and updates of the EU legal acts, but on condition that they do not turn into an obstacle towards this sector. In particular Novamont wants to point out: 1. Confusion/labelling: REGULATION (EU) 2020/2151 mandates specific products to be labelled as plastic, while at the same time compostable versions of these products are already allowed in the organic waste collection and treatment. Compostable items (labelled with compostability logos) that are allowed in the organic waste are mandated to be labelled as “plastics”. This creates consumers confusion and cross contamination issues, undermining the Italian EPR schemes for plastics and compostable plastics and future similar schemes in Europe 2. Recycling: Mater-Bi, BBPs and BDCPs produced by Novamont, as other compostable plastics, is fully chemically, mechanically and organically recyclable. Current applications are focused on organic recycling, due to the strict connection with food waste collection and treatment. The increasing collection of food waste in Europe could transform the food waste treatment plants into biorefinery able to separate and generate new raw materials for the compostable plastic industry. Moreover Mater-Bi does not generate quality issues in the mechanical recycling of films. 3. Organic recycling is recycling: PPWD provide a level playing field among recycling technologies and organic recycling is considered as “recycling” and compostable plastics contribute to the recycling target of plastic packaging (see Article 6a.4 of PPWD) 4. Suitable applications: It is discriminatory for legislators to propose applications and/or exhaustive lists of uses for these materials. Such legislation will hamper R&I activities that the EC funded under Horizon 2020 (BBI-JU) and will fund under Horizon Europe (CBE-JU) and also limit future research and innovation in beneficial resource-efficient products and the collection of bio-waste (mandatory since Jan 2024).
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Response to European Bioeconomy Policy: Stocktaking and future developments

30 Jul 2021

The circular bioeconomy is a cornerstone between agriculture and industrial production of food, feed and biobased products that are functional to both sustainable agriculture practices and soil protection. The systemic adoption of a circular bioeconomy approach in agricultural and industrial activities provides the opportunity to address the multifaceted challenges posed by land degradation, by implementing transformative changes in managing our land and forests in a sustainable way with the aim to meet carbon sequestration needs in line with the goal of achieving carbon neutrality. Toward this goal the key priorities could be: • stop thinking about unlimited growth: avoiding one to one replacement of materials from fossil resources with renewable ones. The drop-in logic should be overcome by an approach focused on rethinking the whole model, finding appropriate solutions for specific environmental issues • be regenerative and transformative using bio-based material to trigger a cultural change making more with less: it will be crucial to redesign how products are produced, consumed and disposed of, encouraging the growth of added value chains with multiple products. These integrated value chains can be used as open labs, involving different actors leading to an induced incremental innovation process of learning-by-doing and creating a participative innovation approach to fill the existent knowledge gap. • Stop degradation and pollution of soil and water using bio-based resources for those applications where there is a risk of accumulation of traditional products in the environment. In this respect, biodegradability becomes fundamental for products at high risk of dispersion in soil (like mulch film and auxiliary product such as slow release devices, coatings for seeds, bioherbicides, biolubricants etc.), in compost (like foodservice products, coffee capsules, labels etc), or in wastewater (such as additives for cosmetic and detergence). In addition, for those products which cannot be recycle due to food contamination, as in the case of foodpackaging. In this scenario an efficient network of treatment plants, ensure that no persistent substances accumulate in purified water, in sludge and organic matter. Thus, clean organic matter can close the carbon cycle, regenerating soil fertility and health, maintaining biodiversity and decarbonizing the atmosphere. • Fix priorities based on a real systemic impact assessment. For this reason, reliable systemic assessment tools should be implemented, capable to measure environmental, economic and social impacts at local level, applied to integrated value chains taking in mind their evolution potential. • Achieve coherent policies and market pull tools to accelerate cultural transformation and market penetration. ATECO codes to identify the bioeconomy sector should be crucial to overcome the uncertainties on end of waste, to support sustainable bio-based biodegradable products for applications where there is risk of accumulation of substances in the environment. To conclude, Circular Bioeconomy could be a key tool to accelerate the post-covid 19 relaunch programs, interconnecting 4 of the 5 Missions action plans, the EU Strategies and Policies of the Green New Deal and to co-create joint solutions for addressing the pressing challenges of EU society “making more with less. This sector will be crucial to support the European goals related to the Fit for 55' package, by reducing emissions, by replacing fossil-based materials and energy with bio-based ones, notably biomaterials, and biochemicals, and by facilitating the use of compost in agriculture (thus allowing carbon sink effects). It will be crucial for EU policies and legislation to be in continuity with strategies and R&D investment, promoting at market level those products that are supported at R&D and strategic level, in order to maximize the return on investments and to create a stable and clear policy framework.
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Response to New modules for European environmental economic accounts

7 Jun 2021

Within the revision of the environmental economic accounts it will be important to stress the link between environmental protection and sustainable economic development, especially in certain sectors, such as the circular bioeconomy. The circular bioeconomy is a cornerstone between agriculture and industrial production of food, feed and biobased products that are functional to both sustainable agriculture practices and soil protection. The systemic adoption of a circular bioeconomy approach in agricultural and industrial activities provides the opportunity to address the multifaceted challenges posed by land degradation, by implementing transformative changes in managing our land and forests in a sustainable way with the aim to meet carbon sequestration needs in line with the goal of achieving carbon neutrality. Expanding bio-based activities across Europe will also provide new or additional income for actors in the primary sectors; creating vibrant sustainable communities in rural, coastal, and urban areas; providing new income for municipalities and actors in waste recycling operations. In this context, biobased products such as biodegradable and compostable bioplastics are crucial to promote the better management of organic waste and reduce the risks of its contamination. Bioplastics are also fundamental tools to reduce pollution in those sectors where there is high dispersion rate, such as agriculture. The circular bioeconomy is a great opportunity in those areas characterized by marginal lands, where integrating the cultivation of dry crops with multiple sectors will enable soil regeneration (through agricultural best practices, such as the use of biodegradable mulching films, bioherbicides for the control of infestations or biolubricants) and enhance its carbon sink functionality. It will also encourage the development of multi-product value chains, with the cascading use of biomass generating new opportunities for production and income. Increasing the rewards for climate-friendly action and applying better the “polluter-pays” principle would trigger the price signals that are needed for the desired change at the level of producers and consumers. Carbon farming should be promoted, as a way to increase soil carbon sequestration through a variety of agricultural methods, including the application of compost from organic waste treatment, while also preserving and restoring soil health through the increase of soil organic matter. For this reason, the measurement should include the introduction of a monitoring system together with compensation mechanisms based on incentives for soil carbon sequestration (carbon farming).
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Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

With reference to the criteria for the manufacture of plastics in primary form, Annex I (Climate Change Mitigation), #3.16, pages 95, 96, please note that in letter c) one wrong ISO standard has been referred to and several ISO standards are missing. The current wording fails to specify the requirements to properly assess the GHG emission of bio-plastics in comparison to their fossil-based counterparts. There is also one main comment we would like to raise regarding the exclusion of “food and feed crops” used for the production of bio-based plastics. Four points in particular need amending: 1) The technical screening criteria excludes food and feed crops for the production of bio-based plastics. This sentence needs eliminating or at least needs the addition of the word ‘sustainable’ because: a)It is in stark contrast with the EU’s official Bioeconomy Strategy where the use of sustainable agricultural biomass is clearly recommended; b)It is in contradiction with this very same Delegated Act where at #1.1. it defines sustainable agricultural biomass. It is highly illogical that the present Act defines sustainable agricultural products in its text but then forbids the use of such sustainable biomass by one of the most strategic sector in the EU, the bioeconomy; c) Data shows that bio-based plastics does not require food and feed crops in any significant quantity (today only 0.02% of all arable land is used for the production of biomass for bio-based plastics, see PDF attached) and therefore causes no land use change whatsoever; d) The paragraph is in contrast with the DNSH in the adaptation criteria (AnnexII) where no such exclusion is present. 2) Standard EN 17228 needs to be introduced to avoid confusion regarding what is to be considered a plastics “derived wholly or partially from renewable feedstock”. Standard EN 17228 specifies vocabulary, methods for characterization, and templates for reporting about bio-based polymers and plastics products. The standard has been prepared in agreement with the European Commission’s Mandate M/430 (“Mandate addressed to CEN for the development of European standards and CEN workshop agreements for bio-polymers and bio-lubricants in relation to bio-based product aspects”). 3) When analysing life cycle stages and their GHG emission, it is vital that all cycles are addressed, allowing to have a complete overview of the GHG emissions from cradle-to-grave, ranging from the extraction of raw materials to manufacturing, product use, and recycling/disposal in the end-of-life phase. 4) ISO 14061-1 must be replaced by standards EN 16760 , ISO 14044 and ISO 22526 , because the current standard (ISO 14061) refers to the quantification and reporting of GHG for organizations and not polymers/plastics. The proposed alternative standards are the appropriate ones and would allow to identify the GHG based on life cycle assessment (LCA) and, more importantly, the amount of CO2 removed from the air and incorporated into bio-based plastics. We consider that bio-based plastics, not conceived as simple drop-in solutions, need to fulfil the overall objective to trigger a real circular and sustainable bio-economy.
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Response to New EU Soil Strategy - healthy soil for a healthy life

4 Dec 2020

The promotion of circular bioeconomy should be considered as a key element in the strategy aimed at achieving the protection of soil from pollution and degradation. Circular bioeconomy is based on the use of renewable resources for applications that are designed not to integrally substitute all the fossil-based alternatives, but to be a solution for specific environmental issues, thus allowing the protection of soil from pollution and depletion. Biodegradable and compostable products which don’t accumulate into the environment can provide a substantial contribution to pollution and contamination problems, as well as a key vehicle to bring organic carbon back in soil, increasing its fertility. Compostable bioplastics allow an efficient and clean separate collection and recycling of bio-waste in clean compost, to be used as soil improver to bring organic carbon back in soil. It should be considered both the key aspect of soil nutrition and the useful contribution of compostable plastics in the reduction of microplastics in compost which will then end up in soil. A 2019 study indicated up to 169 g per person of microplastics entering the environment from the products of organic recycling every year . Compostable plastics could solve this serious environmental problem, allowing to increase the quantity and the quality of biowaste, that can be then converted into clean compost to be used to bring organic carbon back in soil, providing nutrition and increasing fertility, against the desertification issues and allowing, through the carbon sink process, to reduce GHG emissions. The use of these products should be promoted specifically for those applications that are more prone to be mixed with organic content, such as organic waste bags, food packaging, coffee capsules, foodserviceware, etc. The use of clean compost and other organic materials in agriculture is an important solution to two problems: by preventing organic waste from ending up in a landfill, a practice prohibited by the new Waste framework directive as from 2024; by adding an invaluable soil improver. This practice leads to a gradual improvement in crop health, increase soil fertility and keeps the input of pesticides and fertilisers to a minimum. On the other hand, biodegradable and compostable materials and products -by allowing biodegradation avoid/prevent soil contamination from non-biodegradable materials. Soil biodegradable mulch film, can be directly processed in soil after use, avoiding the accumulation of microplastics that could be associated with an improper use of traditional mulch film. Biodegradable in soil pelargonic acid can be use as substitute of traditional pesticides. Biolubricants can be used for machinery that works in proximity with natural resources. Finally, biodegradable ingredients for cosmetics avoid the accumulation of microplastics in sea, being readily biodegradable according to OECD 301 guidelines. Circular bioeconomy is based on the reconversion of decommissioned sites into biorefineries, allowing the regeneration of brownfields, thus reducing soil consumption and greenfields exploitation, meanwhile allowing social and economic recovery of those sites. Moreover circular bioeconomy promotes the construction of integrated agro-industrial value-chains based on sustainable use of biomass, valorizing dryland crops which can be grown on marginal lands. Finally it will be important to strengthen the link between farmers and research through Lighthouse Farms, in which farmers, researchers, civil society and other stakeholders plan together innovative agricultural systems aimed at reducing environmental impacts and maximizing the efficient use of resources for high quality soil.
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Response to Land use, land use change and forestry – review of EU rules

26 Nov 2020

We fully support the objective of aligning the regulatory framework to an EU-wide target to reduce emissions by 55% in 2030 (compared to 1990 levels) and with the goal of becoming a climate-neutral economy in 2050, while ensuring a just transition. We welcome the Commission’s inception Impact Assessment on Amending the Land Use, Land Use Change and Forestry Regulation (LULUCF) - (EU) 2018/841. We agree with the Commission’s view that the land and bio-economy sectors can contribute to the EU increased climate ambition by reducing emissions (e.g. from food production, organic soils, deforestation) and by replacing fossil-based materials and energy with bio-based ones, notably biomaterials, and biochemicals. Therefore, the reviewed LULUCF Regulation should enhance the synergies between the LULUCF sector and other land-related sectors (agriculture, bioeconomy), uses (nature-based solutions, closer-to-nature forestry) and policies. We believe the implementation of the updated Bioeconomy Strategy 2018 will greatly support the EU’s potential to reduce land emissions, by enhancing substitution of fossil-based materials and land-based sinks in the land use sector to accelerate the transition towards a resilient and climate-neutral bioeconomy. The circular bioeconomy is a cornerstone between agriculture and industrial production of food, feed and biobased products that are functional to both sustainable agriculture practices and soil protection. The systemic adoption of a circular bioeconomy approach in agricultural and industrial activities provides the opportunity to address the multifaceted challenges posed by land degradation, by implementing transformative changes in managing our land and forests in a sustainable way with the aim to meet carbon sequestration needs in line with the goal of achieving carbon neutrality. Expanding bio-based activities across Europe will also provide new or additional income for actors in the primary sectors; creating vibrant sustainable communities in rural, coastal, and urban areas; providing new income for municipalities and actors in waste recycling operations. In this context, biobased products such as biodegradable and compostable bioplastics are crucial to promote the better management of organic waste and reduce the risks of its contamination with non biodegradable plastic residues. Bioplastics are also fundamental tools to reduce pollution in those sectors where there is high dispersion rate, The circular bioeconomy is a great opportunity in those areas characterized by marginal lands, where integrating the cultivation of dry crops with multiple sectors will enable soil regeneration (through agricultural best practices, such as the use of biodegradable mulching films, bioherbicides for the control of infestations or biolubricants) and enhance its carbon sink functionality. It will also encourage the development of multi-product value chains, with the cascading use of biomass generating new opportunities for production and income. Assobioplastiche shares the Commission’s view that the substitution of fossil-based materials with bio-based ones should also be better incentivised. Increasing the rewards for climate-friendly action and applying better the “polluter-pays” principle would trigger the price signals that are needed for the desired change at the level of producers and consumers.
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Response to EU Action Plan Towards a Zero Pollution Ambition for air, water and soil

29 Oct 2020

The promotion of circular bioeconomy should be considered as a key element in the strategy aimed at achieving the protection of natural resources from pollution and degradation. Circular bioeconomy is the economic sector that is based on the use of renewable resources for the development of applications that are designed not to integrally substitute all the fossil-based alternatives, but to be a solution for specific environmental issues, thus allowing the protection of soil and water from pollution and depletion. More specifically, the use of biodegradable and compostable products which don’t accumulate into the environment can provide a substantial contribution to pollution and contamination problems. Compostable bioplastics (according to EN 13432 standard) allow an efficient and clean separate collection and recycling of bio-waste in clean compost, to be used as soil improver to bring organic carbon back in soil. It should be considered the useful contribution of compostable plastics in the reduction of microplastics in compost which will then end up in soil. A 2019 study from Germany into plastic in the environment indicated up to 169 g per person of microplastics entering the environment from the products of organic recycling every year [1] . Thus, the major origin of microplastics is caused by non-biodegradable packaging present in the composting stream. Needless to say that compostable plastics could solve this serious environmental problem, allowing to increase the quantity and the quality of biowaste collected, that can be then converted into clean compost to be used to bring organic carbon back in soil, providing nutrition against the desertification issues and allowing, through the carbon sink process, to reduce GHG emissions. The use of these products should be promoted specifically for those applications that are more prone to be mixed with organic content, such as organic waste bags, food packaging, coffee capsules, foodserviceware, etc. The use of clean compost and other quality organic materials in agriculture is an important solution to two types of problems: firstly, by preventing organic waste from ending up in a landfill, a practice prohibited by the new Waste framework directive as from 2024; and secondly, by adding an invaluable soil improver. This practice leads to a gradual improvement in crop health and keeps the input of pesticides and fertilisers to a minimum. On the other hand, biodegradable and compostable materials and products - such as soil biodegradable mulch film, biolubricants, pelargonic acid for agricultural use, biodegradable ingredients for cosmetics - by allowing biodegradation avoid/prevent soil contamination from traditional non-biodegradable materials. Soil biodegradable mulch film, can be directly processed in soil after use, avoiding the accumulation of microplastics in soil that could be associated with an improper use of traditional mulch film. Pelargonic acid can be use as substitute of traditional pesticides, with the additional advantage of being completely biodegradable in soil after use. Biolubricants are also biodegradable and can be used for those machinery that works in proximity with natural resources, avoiding the negative consequences related to the dispersion of traditional lubricants. Finally, biodegradable ingredients for cosmetics are a key solution to avoid the accumulation of microplastics in sea, by being readily biodegradable according to OECD 301 guidelines. [1] Fraunhofer Umsicht. Kunststoffe in der Umwelt: Micro- und Makroplastik. 2019. www.umsicht.fraunhofer.de https://www.umsicht.fraunhofer.de/content/dam/umsicht/de/dokumente/publikationen/2018/kunststoffe-id-umwelt-konsortialstudie-mikroplastik.pdf (accessed April 17, 2020)
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Response to Sustainable Products Initiative

28 Oct 2020

The promotion of circular bioeconomy should be considered as a key element in the strategy aimed at making products placed on the EU market more sustainable. In fact, the circular bioeconomy is the economic sector that is based on the sustainable use of renewable resources for the development of applications that are (eco)designed not to integrally substitute all the fossil-based alternatives, but to be a solution for specific environmental issues, thus allowing the protection of natural resources from pollution and depletion. Examples are bio-based chemistry derived products, which don’t accumulate into the environment: biodegradable and compostable bioplastics, biolubricants, pelargonic acid for agricultural use, biodegradable ingredients for cosmetics. Compostable bioplastics (according to EN 13432 standard) allow an efficient and clean separate collection and recycling of bio-waste in clean compost, to be used as soil improver to bring organic carbon back in soil. It should be considered the useful contribution of compostable plastics in the reduction of microplastics in compost which will then end up in soil. A 2019 study from Germany into plastic in the environment indicated up to 169 g per person of microplastics entering the environment from the products of organic recycling every year [1]. Thus, the major origin of microplastics is caused by non-biodegradable packaging present in the composting stream. Needless to say that compostable plastics could solve this serious environmental problem, allowing to increase the quantity and the quality of biowaste collected, that can be then converted into clean compost to be used to bring organic carbon back in soil, providing nutrition against the desertification issues and allowing, through the carbon sink process, to reduce GHG emissions. The use of these products should be promoted specifically for those applications that are more prone to be mixed with organic content, such as organic waste bags, food packaging, coffee capsules, foodserviceware, etc. On the other hand, biodegradable and compostable materials and products - such as soil biodegradable mulch film, biolubricants, pelargonic acid for agricultural use, biodegradable ingredients for cosmetics - by allowing biodegradation avoid/prevent soil contamination from traditional non-biodegradable materials. Soil biodegradable mulch film, can be directly processed in soil after use, avoiding the accumulation of microplastics in soil that could be associated with an improper use of traditional mulch film. Pelargonic acid can be use as natural substitute of traditional pesticides, with the additional advantage of being completely biodegradable in soil after use. Biolubricants are also biodegradable and can be used for those machinery that works in proximity with natural resources, avoiding the negative consequences related to the dispersion of traditional lubricants. Finally, biodegradable ingredients for cosmetics are a key solution to avoid the accumulation of microplastics in sea, by being readily biodegradable according to OECD 301 guidelines. The circular bioeconomy, by creating new value chains among agriculture and chemistry, promotes a model based on the efficient use of resources and on territorial regeneration. This sector shows a concrete example on how the eco-design of products can provide concrete benefits both on the environment and society, by creating sustainable products, jobs and economic growth. [1] Fraunhofer Umsicht. Kunststoffe in der Umwelt: Micro- und Makroplastik. 2019. www.umsicht.fraunhofer.de https://www.umsicht.fraunhofer.de/content/dam/umsicht/de/dokumente/publikationen/2018/kunststoffe-id-umwelt-konsortialstudie-mikroplastik.pdf (accessed April 17, 2020)
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Response to Review of the requirements for packaging and feasibility of measures to prevent packaging waste

31 Jul 2020

NOVAMONT FEEDBACK ON THE CONSULTATION ON THE REVISION ON ESSENTIAL REQUIREMENTES: FOCUS ON BIODEGRADABLE & COMPOSTABLE PLASTICS PACKAGING The review of the Packaging and Packaging Waste Directive (PPWD) in 2018 required the European Commission to examine the feasibility of reinforcing the Essential Requirements (ERs) for packaging with a view to “improving design for reuse and promoting high quality recycling, as well as strengthening their enforcement”. In this context and, moreover, in the context of the EU’s New Circular Economy Package and Plastics Strategy, the European Commission will work on the revision of the Essential Requirements for placing packaging (Directive 1994/64). The European Commission assigned to the consultants, Eunomia Research & Consulting Ltd, a study assessing possible options and feasibility for the review of the PPWD’s Essential Requirements (ER). The study was recently published and this contribution represents a first analysis with a particular focus on biodegradable and compostable plastics packaging. The study on the legal review of the ER focuses on the need to provide a definition of “recyclable” packaging. Within the several options provided by Eunomia, it seems that the definition does not include the organic recycling/reprocessing of packaging. Not including the reprocessing of compostable packaging (both paper and cellulose) within the definition of recyclable packaging would not respect EU legislation (Waste Framework Directive and Packaging and Packaging Waste Directive) creating legal uncertainty and would lead to different legislative frameworks across Europe. It is, therefore, paramount that the definition of “recyclable” packaging includes expressively organic recycling. For the revision of the Essential Requirements for biodegradable and compostable packaging Eunomia outlines three different options. The preferred option – in line with the other study carried out by Eunomia “Relevance of Biodegradable and Compostable Consumer Plastic Products and Packaging in a Circular Economy” – would introduce a requirement for an assessment at the packaging specification/design stage of whether or not compostable packaging is suitable for the intended application and “choices for products and packaging should prioritise recyclability over compostability”.This option would: • fix by law what could be done with compostable plastics – which per se is a serious discrimination for these materials; • neglect the organic recycling/reprocessing of packaging creating a hierarchy among recycling technologies that represents a breach of EU legislation (WFD and PPWD).
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Response to Communication on the future of research and innovation and the European Research Area

31 Jul 2020

The depletion of natural ecosystems, the pollution of soils and waters and the loss of soil fertility contribute to create a more vulnerable environment. It is essential to definitively embrace a new model, where agriculture and forests are at the center of integrated value chains and innovative infrastructures, capable of regenerating natural capital bringing back clean organic matter to the soil. 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. Climate neutrality will only be possible by also cutting the emissions associated with the production, use and disposal of materials. Materials and manufactured products account for nearly one fifth of the total EU CO2 emissions (data 2018 from Eurostat: https://ec.europa.eu/eurostat/statistics-explained/index.php?title=Greenhouse_gas_emission_statistics_-_carbon_footprints#Carbon_dioxide_emissions_associated_with_EU_consumption). It is necessary to accelerate on the issues of the circular economy, not intended as reductive and basic concept of material recycling, but as a redesign of production not anymore based on a “silos approach” yet on the creation of interlinks among different sector (agriculture, forestry, materials, chemicals, energy, etc.) and where R&I needs to play a vital role. As a matter of fact the bioeconomy is interdisciplinary and creates integrated value chains, delivering bio-based products that can reduce our dependence on fossils and contribute to the climate neutrality goal It is, therefore, crucial that the European Research Area’s vision addresses the potential for climate change mitigation offered by materials and links climate policy with the circular economy. Bioeconomy is one of the most successful examples of a European strategic value-chain. The bioeconomy sectors are instrumental players in the transition to a circular and climate neutral economy and are keen to pursue their continuous research & innovation efforts to make the European Research Area a success. To fully unleash the contribution of a circular bio-economy to the transition to a circular and climate neutral economy, we suggest that the European Research Area (ERA) provides R&I policy measures that: • Are in line with the existing EU Research and Development programs, starting from Horizon Europe • Are in line with the EU objective that are stated in the most important strategic and legislative documents that have been developed to orient the next years EU actions, specifically the Farm to Fork strategy, the Circular Economy Action Plan, the Climate Law, the Chemical Strategy • Are focused on both research and development and scaleup of existing technologies • Are focused on the development of solution aimed to tackle the main environmental issues: climate change, soil desertification, plastic pollution, biodiversity loss, depletion of natural resources. In this sense the circular bioeconomy is a sector to be put at the center of this transition, products such as biodegradable and compostable bioplastics, biolubricants, bioherbicides, biodegradable ingredients for cosmetics are concrete solution to tackle environmental issues by also deploying social and economic development from pollution and exploitation of fossil resources
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Response to Strengthening the consideration of sustainability risks and factors for financial products (Regulation (EU) 2017/565)

3 Jul 2020

Novamont welcomes the EU’s action plan on sustainable finance. To further improve the initiative we recommend to address, within the activities that provide genuine long-term benefits for society, those that allow to protect and restore natural resources from a systemic perspective. The use of high quality compost from organic waste treatment as soil amendment, in order both to increase the carbon stock and to face the issue of desertification by bringing clean organic matter back into the soil, is a concrete example of systemic activities providing benefits both in terms of waste management and in terms of natural resources preservation. Therefore all activities related to its proper functioning should be welcomed and considered as providing long-term benefits for the society. A virtuous sector in this term is the one of biodegradable and compostable bioplastics, which makes the mixed waste suitable for organic recycling. This way, biowaste is diverted from landfill and separate collection facilitated – resulting in the creation of high quality compost, that can be used as soil improver. Other bioproducts, such as biolubricants and bioherbicides, are conceived to protect soil from accidental release, since they naturally biodegrade without leaving any trace nor causing pollution. From a wider perspective, according to the Bio-Based Industries Consortium bioeconomy sectors are instrumental players in the transition to a circular and climate neutral economy and are keen to pursue their continuous research & innovation efforts to make the EU Climate Law a success. The bioeconomy is already worth more than €2 trillion annually and employs over 18 million Europeans. By storing and utilizing carbon dioxide and replacing carbon intensive fossil-based resources, sustainably sourced renewable materials offer a key opportunity to help achieve Europe’s climate ambitions. By enabling the substitution of finite fossil-based materials and through their re-circulation in the economy thanks to recycling (mechanic, organic and chemical), renewable materials are also key for the European circular economy and security of supply of raw materials, as well as for the preservation of natural resources. By promoting the reconversion of decommissioned sites, the bioeconomy allow the regeneration of brownfields, thus reducing soil consumption and greenfields exploitation, meanwhile allowing social and economic recovery of those sites.
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Response to Integration of sustainability risks and factors related to alternative investment fund managers

3 Jul 2020

Novamont welcomes the EU’s action plan on sustainable finance. To further improve the initiative we recommend to address, within the activities that provide genuine long-term benefits for society, those that allow to protect and restore natural resources from a systemic perspective. The use of high quality compost from organic waste treatment as soil amendment, in order both to increase the carbon stock and to face the issue of desertification by bringing clean organic matter back into the soil, is a concrete example of systemic activities providing benefits both in terms of waste management and in terms of natural resources preservation. Therefore all activities related to its proper functioning should be welcomed and considered as providing long-term benefits for the society. A virtuous sector in this term is the one of biodegradable and compostable bioplastics, which makes the mixed waste suitable for organic recycling. This way, biowaste is diverted from landfill and separate collection facilitated – resulting in the creation of high quality compost, that can be used as soil improver. Other bioproducts, such as biolubricants and bioherbicides, are conceived to protect soil from accidental release, since they naturally biodegrade without leaving any trace nor causing pollution. From a wider perspective, according to the Bio-Based Industries Consortium bioeconomy sectors are instrumental players in the transition to a circular and climate neutral economy and are keen to pursue their continuous research & innovation efforts to make the EU Climate Law a success. The bioeconomy is already worth more than €2 trillion annually and employs over 18 million Europeans. By storing and utilizing carbon dioxide and replacing carbon intensive fossil-based resources, sustainably sourced renewable materials offer a key opportunity to help achieve Europe’s climate ambitions. By enabling the substitution of finite fossil-based materials and through their re-circulation in the economy thanks to recycling (mechanic, organic and chemical), renewable materials are also key for the European circular economy and security of supply of raw materials, as well as for the preservation of natural resources. By promoting the reconversion of decommissioned sites, the bioeconomy allow the regeneration of brownfields, thus reducing soil consumption and greenfields exploitation, meanwhile allowing social and economic recovery of those sites.
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Response to Integration of sustainability risks and factors in relation to the business of insurance and reinsurance

3 Jul 2020

Novamont welcomes the EU’s action plan on sustainable finance. To further improve the initiative we recommend to address, within the activities that provide genuine long-term benefits for society, those that allow to protect and restore natural resources from a systemic perspective. The use of high quality compost from organic waste treatment as soil amendment, in order both to increase the carbon stock and to face the issue of desertification by bringing clean organic matter back into the soil, is a concrete example of systemic activities providing benefits both in terms of waste management and in terms of natural resources preservation. Therefore all activities related to its proper functioning should be welcomed and considered as providing long-term benefits for the society. A virtuous sector in this term is the one of biodegradable and compostable bioplastics, which makes the mixed waste suitable for organic recycling. This way, biowaste is diverted from landfill and separate collection facilitated – resulting in the creation of high quality compost, that can be used as soil improver. Other bioproducts, such as biolubricants and bioherbicides, are conceived to protect soil from accidental release, since they naturally biodegrade without leaving any trace nor causing pollution. From a wider perspective, according to the Bio-Based Industries Consortium bioeconomy sectors are instrumental players in the transition to a circular and climate neutral economy and are keen to pursue their continuous research & innovation efforts to make the EU Climate Law a success. The bioeconomy is already worth more than €2 trillion annually and employs over 18 million Europeans. By storing and utilizing carbon dioxide and replacing carbon intensive fossil-based resources, sustainably sourced renewable materials offer a key opportunity to help achieve Europe’s climate ambitions. By enabling the substitution of finite fossil-based materials and through their re-circulation in the economy thanks to recycling (mechanic, organic and chemical), renewable materials are also key for the European circular economy and security of supply of raw materials, as well as for the preservation of natural resources. By promoting the reconversion of decommissioned sites, the bioeconomy allow the regeneration of brownfields, thus reducing soil consumption and greenfields exploitation, meanwhile allowing social and economic recovery of those sites.
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Response to Integration of sustainability risks and factors in relation to insurance undertakings and insurance distributors

3 Jul 2020

Novamont welcomes the EU’s action plan on sustainable finance. To further improve the initiative we recommend to address, within the activities that provide genuine long-term benefits for society, those that allow to protect and restore natural resources from a systemic perspective. The use of high quality compost from organic waste treatment as soil amendment, in order both to increase the carbon stock and to face the issue of desertification by bringing clean organic matter back into the soil, is a concrete example of systemic activities providing benefits both in terms of waste management and in terms of natural resources preservation. Therefore all activities related to its proper functioning should be welcomed and considered as providing long-term benefits for the society. A virtuous sector in this term is the one of biodegradable and compostable bioplastics, which makes the mixed waste suitable for organic recycling. This way, biowaste is diverted from landfill and separate collection facilitated – resulting in the creation of high quality compost, that can be used as soil improver. Other bioproducts, such as biolubricants and bioherbicides, are conceived to protect soil from accidental release, since they naturally biodegrade without leaving any trace nor causing pollution. From a wider perspective, according to the Bio-Based Industries Consortium bioeconomy sectors are instrumental players in the transition to a circular and climate neutral economy and are keen to pursue their continuous research & innovation efforts to make the EU Climate Law a success. The bioeconomy is already worth more than €2 trillion annually and employs over 18 million Europeans. By storing and utilizing carbon dioxide and replacing carbon intensive fossil-based resources, sustainably sourced renewable materials offer a key opportunity to help achieve Europe’s climate ambitions. By enabling the substitution of finite fossil-based materials and through their re-circulation in the economy thanks to recycling (mechanic, organic and chemical), renewable materials are also key for the European circular economy and security of supply of raw materials, as well as for the preservation of natural resources. By promoting the reconversion of decommissioned sites, the bioeconomy allow the regeneration of brownfields, thus reducing soil consumption and greenfields exploitation, meanwhile allowing social and economic recovery of those sites.
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Response to Strengthening the consideration of sustainability risks and factors for financial products (Directive (EU) 2017/593)

3 Jul 2020

Novamont welcomes the EU’s action plan on sustainable finance. To further improve the initiative we recommend to address, within the activities that provide genuine long-term benefits for society, those that allow to protect and restore natural resources from a systemic perspective. The use of high quality compost from organic waste treatment as soil amendment, in order both to increase the carbon stock and to face the issue of desertification by bringing clean organic matter back into the soil, is a concrete example of systemic activities providing benefits both in terms of waste management and in terms of natural resources preservation. Therefore all activities related to its proper functioning should be welcomed and considered as providing long-term benefits for the society. A virtuous sector in this term is the one of biodegradable and compostable bioplastics, which makes the mixed waste suitable for organic recycling. This way, biowaste is diverted from landfill and separate collection facilitated – resulting in the creation of high quality compost, that can be used as soil improver. Other bioproducts, such as biolubricants and bioherbicides, are conceived to protect soil from accidental release, since they naturally biodegrade without leaving any trace nor causing pollution. From a wider perspective, according to the Bio-Based Industries Consortium bioeconomy sectors are instrumental players in the transition to a circular and climate neutral economy and are keen to pursue their continuous research & innovation efforts to make the EU Climate Law a success. The bioeconomy is already worth more than €2 trillion annually and employs over 18 million Europeans. By storing and utilizing carbon dioxide and replacing carbon intensive fossil-based resources, sustainably sourced renewable materials offer a key opportunity to help achieve Europe’s climate ambitions. By enabling the substitution of finite fossil-based materials and through their re-circulation in the economy thanks to recycling (mechanic, organic and chemical), renewable materials are also key for the European circular economy and security of supply of raw materials, as well as for the preservation of natural resources. By promoting the reconversion of decommissioned sites, the bioeconomy allow the regeneration of brownfields, thus reducing soil consumption and greenfields exploitation, meanwhile allowing social and economic recovery of those sites.
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Response to Integration of sustainability risks and factors for undertakings for collective investment in transferable securities

3 Jul 2020

Novamont welcomes the EU’s action plan on sustainable finance. To further improve the initiative we recommend to address, within the activities that provide genuine long-term benefits for society, those that allow to protect and restore natural resources from a systemic perspective. The use of high quality compost from organic waste treatment as soil amendment, in order both to increase the carbon stock and to face the issue of desertification by bringing clean organic matter back into the soil, is a concrete example of systemic activities providing benefits both in terms of waste management and in terms of natural resources preservation. Therefore all activities related to its proper functioning should be welcomed and considered as providing long-term benefits for the society. A virtuous sector in this term is the one of biodegradable and compostable bioplastics, which makes the mixed waste suitable for organic recycling. This way, biowaste is diverted from landfill and separate collection facilitated – resulting in the creation of high quality compost, that can be used as soil improver. Other bioproducts, such as biolubricants and bioherbicides, are conceived to protect soil from accidental release, since they naturally biodegrade without leaving any trace nor causing pollution. From a wider perspective, according to the Bio-Based Industries Consortium bioeconomy sectors are instrumental players in the transition to a circular and climate neutral economy and are keen to pursue their continuous research & innovation efforts to make the EU Climate Law a success. The bioeconomy is already worth more than €2 trillion annually and employs over 18 million Europeans. By storing and utilizing carbon dioxide and replacing carbon intensive fossil-based resources, sustainably sourced renewable materials offer a key opportunity to help achieve Europe’s climate ambitions. By enabling the substitution of finite fossil-based materials and through their re-circulation in the economy thanks to recycling (mechanic, organic and chemical), renewable materials are also key for the European circular economy and security of supply of raw materials, as well as for the preservation of natural resources. By promoting the reconversion of decommissioned sites, the bioeconomy allow the regeneration of brownfields, thus reducing soil consumption and greenfields exploitation, meanwhile allowing social and economic recovery of those sites.
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Response to EU Strategy on Adaptation to Climate Change

30 Jun 2020

According to the IPCC (Climate Change and Land, 2019), climate change has adversely impacted food security and terrestrial ecosystems as well as contributed to desertification and land degradation in many regions. At the same time, soils can be a source for capturing carbon, by reducing CO2 emissions through the application of proper land management practices. For all these reasons, within the context of the EU Adaptation Strategy it will be important to stress and enhance the resilience of the agri-food systems to climate change. Action 6 “Facilitate the climate-proofing of the Common Agricultural Policy (CAP), the Cohesion Policy and the Common Fisheries Policy (CFP)” provide the background to include measures and policies aimed at increasing soil resilience and protection, by promoting the adoption of agricultural practices focused on restoring clean organic carbon in soil. The use of high quality compost from organic waste management, in the face of the problem of desertification, exacerbated by climate change, appears to be a concrete solution to restore nutrition and fertility to soils and stock carbon in land, avoiding the increase of CO2 emissions. Moreover the cultivation of dryland crops for bio-based industries, able to grow in marginal lands with low amount of inputs (i.e. water) could be a solution to promote the bioeconomy, reducing the amount of water used in agricultural and exploiting underused agricultural lands. Moreover, the bioeconomy sectors are instrumental players in the transition to a circular and climate neutral economy, that will only be possible by also cutting the emissions associated with the production, use and disposal of materials. Therefore promoting the bioeconomy through legislation schemes and R&D incentives could be a solution to both adapting to dryland conditions and reducing the effects of climate change.
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Response to Chemicals strategy for sustainability

19 Jun 2020

Please find attached Novamont's feedack
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Response to Climate change mitigation and adaptation taxonomy

20 Apr 2020

Novamont welcomes the EU Taxonomy for Sustainable Finance. To further improve the initiative we recommend to address the following issues included within attached paper.
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Meeting with Peter Wehrheim (Cabinet of Commissioner Phil Hogan)

7 Jun 2018 · EU Bio economy strategy

Response to Update of the 2012 Bioeconomy Strategy

27 Feb 2018

Novamont welcomes the European Commission’s initiative to update Europe’s Bioeconomy Strategy. Since its launch the Bioeconomy has proven to be an interesting sector for Europe’s reindustrialization and modernization bearing in mind the environmental global challenges and commitments. As chemical company we strongly believe that the bioeconomy is drawing a path towards a new systemic approach which links together different worlds: innovative industries, academia, R&D centers, institutions, labour organizations. A lot has already been done and there is still a great deal to be done in creating a biobased chemical value chain. We believe that a “circular bioeconomy model” is based on three pillars: 1. Reindustrialization of Europe: the bioeconomy is creating the opportunities to keep the production in Europe, but in order to do so it is necessary to set in place the adequate infrastructures, biorefineries. These plants are integrated and interconnected with the local area there are placed in, linking the different economic players (see point 2) 2. Development of integrated agricultural value-chains: These should be based on the sustainable use of biomass, which is a decisive element in ensuring that the model is successful. Targeted value-chain projects can support multiple purposes: creating additional production and income opportunities, especially for rural areas of Europe; reducing the environmental impact on the soil, water and air by using innovative solutions; creating a whole range of synergistic products for the agro-industrial sphere. 3. Products seen as solution: the objective is not simply to launch products to replace others which are already on the market, the choice of the applications on which to focus the development of the value-chain is based on how the products we will develop help to solve real problems faced by society. Thus, considering the important recognition provided by the Roadmap on the creation of markets for biobased products through regulatory frameworks, it would be necessary, on this matter, to move forward and have a clear and homogenous support to the bioeconomy from both the European Commission and industry.
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Meeting with Carlos Moedas (Commissioner)

30 Jun 2015 · Bioeconomy