Stichting Global Organization for PHA
GO!PHA
The Global Organization for PHA is a member-driven, non-profit initiative to accelerate the adoption of biobased, biodegradable (and compostable) materials (BBM).
ID: 946264840278-51
Lobbying Activity
Response to Towards a Circular, Regenerative and Competitive Bioeconomy
23 Jun 2025
On behalf of Stichting GO!PHA, this submission provides key points for enabling the use of renewable and biobased materials and products, highlighting their immense potential to advance a competitive and sustainable EU Bioeconomy Strategy. -------------------------------------------------------------------- Advances in technology have vastly improved the ability to harness renewable resources including renewable carbon feedstock, aligning innovation with the principles of a circular bioeconomy. A major circular economy and bioeconomy principle and goal needs to be the transition to renewable carbon based substitutes and alternatives to plastics and reduce the reliance fossil-fuels. These biobased materials include naturally occurring biopolymers that can be produced industrially using bioprocess like fermentation, involving a redesign of the sources and systems commonly used to produce materials for the economy. Not only do the resulting products offer sustainable alternatives to currently linear and established products but also enable new technological pathways for resource utilization and waste valourisation. The new Bioeconomy Strategy presents a significant opportunity to unlock the full potential of renewable and biobased materials by: 1. Creating a level playing field via dedicated regulatory support, targeted financial incentives, and market-based instruments to boost uptake. 2. Addressing inconsistencies in the science and policy definitions of Natural Polymers used for material sustainability assessments, and shifting towards a holistic criteria-based approaches -- considering material origin, properties, impact, and safety for evaluation. 3. Ensuring biomass access for the material sector with a dedicated sustainability criteria. 4. Updating life-cycle assessment (LCA) methodologies used by reflecting overall, long-term benefits of biobased materials. 5. Promoting public awareness and communication for clarity to build consumer confidence, and reduce greenwashing. ---------------------------------------------------------------- The attached document expands on these recommendations. GO!PHA and members of our network remain available for further dialogue and collaboration.
Read full response5 Apr 2024
GO!PHA would like to applaud the Commission for amending Regulation (EU) 2019/1009 to introduce a biodegradability criteria for polymers used in EU fertilising products (coating agents, water retention agents, mulch films and other polymer-based technical additives). Establishing test specific biodegradation criteria covering soil, as well as aquatic environments addresses the risk of leakage in the latter. We further appreciate that the Commissions assessment for developing test methods included temperature as a key factor with respect to polymer characteristics, since microbial activity decreases with lowering water temperatures, it decreases the rate of polymer biodegradation. We also want to highlight the reference made to 'natural polymers' as polymers that are the result of a polymerisation process that has taken place in nature, which are not chemically modified substances. This interpretation of natural polymers is concerning as it focuses on the place polymerisation process. The place where the polymerization process takes place has no impact on biodegradation, making the definition discriminatory towards innovative biopolymers coming from diverse sources yet qualifiable as natural. It is also inconsistent with EUs current efforts to reduce challenges for cutting edge biotech material and product innovation. Please the detailed explanation attached. Yours Sincerely, Anindya Mukherjee Co-Founder and Board Member, GO!PHA anindya.mukherjee@gopha.org, +49 221 20471582 EU Transparency Register No: 946264840278-51
Read full responseResponse to Waste Framework review to reduce waste and the environmental impact of waste management
22 Nov 2023
GO!PHA is a non-profit engaged in promoting circular and sustainable materials such as PolyHydroxyAlkanoate (PHA) biopolymers that are renewable, biodegradable and compostable. We welcome the Commissions proposal to revise the Directive on waste. Notably, the renewed focus on addressing food waste within this directive reflects a keen awareness of the pressing challenges associated with the intricate nature of food waste management. This revision is an opportunity for the EU to demonstrate a commitment to fostering innovative solutions. In its pursuit of waste reduction, resource efficiency and adherence to the principles of Reduce, Reuse, and Recycle, there also arises a clear need to recognize bio-waste, which includes food waste, as a valuable resource. Preventing food waste is essential, but it is equally important to distinguish between "food waste" and "food wastage." We support the amendments proposed by MEPs on the original text asking for differentiating food wastage (food which could have been eaten) from just food waste (non-edible parts) more distinctly and encouraging the use of food waste for biogas, bio-fuels. Understanding this difference is key to implementing targeted strategies for minimising avoidable food waste and utilising overall food loss in the supply chain. GO!PHA believes that this revision is an opportunity to recognize and promote the value of the carbon in food and other organic waste. This can be achieved most effectively through the use of compostable and biodegradable materials as carriers for increasing the collection volume of bio waste, on-the-go food carriers and packaging of difficult to remove food content (coffee capsules, ketchup sachets, tea bags, etc.). The revision of the WFD should closely align with the Packaging and Packaging Waste Regulation (PPWR). The PPWR is concurrently working on establishing a mandatory list of biodegradable and compostable applications, such as tea bags and coffee capsules. These applications have a direct impact on food waste and have demonstrated benefits through life cycle assessment conducted as part of the PPWR revision. This way, while simultaneously prohibiting the use of fossil based and non-compostable/non-biodegradable materials for food waste management, there can be increased collection, which would subsequently increase their use, putting more of the renewable carbon in these waste to reuse. In order to achieve this within this revision, please review the attached document.
Read full responseResponse to Review of the requirements for packaging and feasibility of measures to prevent packaging waste
24 Apr 2023
The Global Organization for Polyhydroxyalkanoates (GO!PHA) is a non-profit science, advocacy, and networking platform promoting the proliferation of PHA biopolymers. PHA Biopolymers are renewable and biodegradable, home and industrially compostable, and an excellent replacement for many plastic materials. GO!PHA supports the Commissions draft proposal for Packaging and Packaging Waste Regulation (EC 2019/1020) on November 30, 2022. The proposal tackles many essential challenges related to reducing packaging, over-packing, and, as a result, packaging waste. The proposal highlights waste reduction measures and targets that add to packaging circularity goals which complement the new circular economy action plan. We also see the potential for achieving an even higher circularity impact by addressing missing elements integral to packaging and packaging waste collection, recycling, and reuse.
Read full responseResponse to Sustainable Products Initiative
22 Jun 2022
Dear Members of the European Commission,
We are pleased to respond to your proposal for “establishing a framework for setting ecodesign requirements for sustainable products and repealing Directive 2009/125/EC”. We believe that such an initiative is extremely important and that it should further highlight the many benefits of bio-based (renewable carbon feedstocks), biodegradable, and compostable materials relative to current fossil incumbents. In addition, a broad and fair policy that respects the free market, protects the consumer and the environment would bring enormous benefits to the European Union in significant economic growth and in reducing (and even eliminating) waste, thereby creating a truly circular economy in carbon-based materials.
The Global Organization for PHA (GO!PHA) is an advocate for such a framework where materials that are naturally found, renewable, and have multiple end-of-life outcomes become the materials of choice.
We attach a summary of our rationale and recommendations for making the entire materials sector circular.
Read full responseResponse to Measures to reduce microplastic pollution
18 Jan 2022
Dear Members of the European Commission,
We are pleased to respond to your proposed “Roadmap Policy framework to reduce the presence in the environment of unintentionally released microplastics from tyres, textiles and plastic pellets”. We believe that such a framework is extremely important if it emphasises to identify the root cause of the problems arising from microplastics - use of non-biodegrabale materials. We believe that this would then highlight the many benefits of bio-based (renewable carbon feedstocks), biodegradable, and compostable materials relative to current fossil incumbents. In addition, a broad and fair policy that respects the free market, protects the consumer and the environment would bring enormous benefits to the European Union in significant economic growth and in reducing (and even eliminating) waste, thereby creating a truly circular economy in carbon-based materials.
The Global Organization for PHA (GO!PHA) would advocate a framework where materials that are naturally found, renewable, and have multiple end-of-life outcomes become the materials of choice.
We attach a summary of our rationale and recommendations for making the entire materials sector circular.
Next attachment establishes GO!PHA’s position
Read full responseResponse to Policy framework on biobased, biodegradable and compostable plastics
27 Oct 2021
Dear members of the European Commission,
We are pleased to respond to your proposed “Roadmap for Policy framework on biobased, biodegradable, and compostable plastics”. We believe that such a framework is extremely important if done in the context of the entire carbon-based materials industry, their downstream markets as well as the waste management industry. The source of carbon for materials and the end-of-life outcomes of these and all carbon-based materials, including fossil plastics, are important and must be considered. We believe that this would then highlight the many benefits of bio-based (renewable carbon feedstocks), biodegradable, and compostable materials relative to current fossil incumbents. In addition, a broad and fair policy that respects the free market, protects the consumer and the environment would bring enormous benefits to the European Union in significant economic growth and in reducing (and even eliminating) waste, thereby creating a truly circular economy in carbon-based materials.
The Global Organization for PHA (GO!PHA) is an advocate for such a framework where materials that are naturally found, renewable, and have multiple end-of-life outcomes become the materials of choice.
We attach a summary of our rationale and recommendations for making the entire materials sector circular.
Read full responseResponse to Climate change mitigation and adaptation taxonomy
18 Dec 2020
GO!PHA, the Global organization for Polyhydroxyalkanoates (PHA) and our members are very concerned about the draft delegated act and Annex I thereto on technical screening criteria, determining under which conditions an economic activity qualifies as contributing substantially to climate change mitigation and adaptation.
We believe that excluding food and feed stock as a raw material for the production of renewable plastics in primary form (p. 95 Annex I) seriously undermines the potential of renewable polymers such as PHA to become a sustainable substitute for fossil fuel-based plastics.
PHA is one of the most innovative and versatile materials known to man. They are found in nature and are produced by bacterial. They biodegrade in soil, fresh water and in marine environment. The EU has sponsored over 110 Million Euros worth of research and innovation projects in the last ten years to develop PHA for various uses as a more sustainable material than conventional plastics. A spreadsheet outlining these projects are
given on the next page.
While it may be understandable that the EU does not wish to support food and animal feed crops from being used for producing renewable polymers, residues from food and feed can easily be used as a feedstock. We therefore recommend accepting food and feed crops as a feedstock for plastic in primary form. For sake of regulatory consistency we propose to align the primary plastic definition in view of food and feed crops with the Renewable Energy Directive (RED) definition: “…food and feed crops means starch-rich crops, sugar crops or oil crops produced on agricultural land as a main crop excluding residues, waste or lignocellulosic material and intermediate crops, such as catch crops and cover crops, provided that the use of such intermediate crops does not trigger demand for additional land.”
The current definition for plastics in the primary directive undermines confidence and investments in our sector and contradicts recommendations of Circular Economy Strategy, EU’s Bioeconomy Strategy, Horizon Europe as well as EU’s better regulation and innovation principle.
Please find attached our official letter including annex.
Read full response