Styrenics Circular Solutions
SCS
Styrenics Circular Solutions (SCS) is the value chain initiative to realise the circular economy for styrenics.
ID: 198696432927-14
Lobbying Activity
Meeting with Stefano Soro (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs) and Plastics Europe and
29 Sept 2025 · Discussion of several issues that European plastics value chain is facing.
Response to Initiative on EU taxonomy - environmental objective
3 May 2023
We focus our feedback exclusively on criterion 3 for activity CE 1.1 Manufacture of plastic packaging goods. Please find it attached.
Read full responseResponse to Review of the requirements for packaging and feasibility of measures to prevent packaging waste
24 Apr 2023
SCS fully supports the objectives of the PPWR proposal, including preventing or reducing adverse impacts on the environment, and in particular increasing recycling and the use of recycled materials while reducing other forms of recovery and disposal after all options to prevent waste have been exhausted. To these ends, our industry has been working towards all packaging being economically recyclable by 2030 or earlier. While we continue to engage with the EC, other policymakers, and stakeholders on breadth of issues addressed by the proposal, we have chosen to focus on one aspect in our feedback, in light of the ongoing legislative discussions. An unofficial leaked draft of the proposal included a pre-determined negative list with disparate characteristics purportedly preventing or inhibiting recycling. The EC has observed that "[t]here is currently no evidence that these packaging design features/ materials will not become recyclable by 2030 as considerable efforts are being made by industry to enable this". We welcome that, after receiving evidence in response to the leak, the EC decided not to include such a list in its proposal for good reason, as also the example of extruded polystyrene (XPS) shows, as we explain in our attached position. A negative list based on outdated assumptions and without independent technical analysis and proper consultation would inadvertently contradict the general regime under the PPWR to ensure recyclability, as well as broader EU policy. Even if the PPWR in theory allowed rebutting presumption of non-recyclability of a such negative list, its chilling effects in practice would jeopardise all the already ongoing work and investments in design, collection, sorting and recycling, inadvertently leading to less recycling as a self-fulfilling prophecy. Therefore, we welcome that the ENVI Rapporteur has not proposed such a negative list in her draft report, and call on all co-legislators to refrain from introducing any such list. We appreciate that the EC has publicly explained the compelling reasons against including it in its proposal and ask the EC to continue defending its right decision, if necessary. Please see our attached position for details.
Read full response17 Jan 2022
SCS, the value chain initiative to realise the circular economy for polystyrene (PS), welcomes the opportunity to comment on the draft regulation repealing Reg. 282/2008.
We share the circular economy objectives expressed in recital 1, while the safety of all our processes and materials and the warranted trust of the consumer remain paramount also to us. We have demonstrated the PET-like safety of mechanical recycling of PS in a pending application for EU authorisation (please see technical annex).
Generally, to further increase investments in recycling and the safe use of recycled content in line with these objectives, it is important to provide a proportional and predictable framework for all recycled FCM. Therefore, we ask the EC to continue providing the utmost possible clarity in the final regulation as well as through supporting measures, e.g. comprehensive guidelines.
Specifically, within the limits desired by DG SANTE, we focus on the following:
1) As widely used, equally safe and economic solutions, functional barriers/ABA are important for the attainment of the mentioned objectives. We understand from DG SANTE (presentation of 16/12, slide 53) that the general requirements of Art. 6-8 will apply, without addressing ABA explicitly. Recital 3 should be extended and clarified to help with the interpretation.
2) To more clearly reflect recital 14 and DG SANTE’s intention (slide 35), Art. 4(4b) should explicitly state that specific requirements in Annex I and/or authorisations may derogate from the general requirements. Furthermore, the reference to Art. 4(5) in Annex I, Table 5 should be reviewed. This is relevant e.g. for recognising the safe recycling of intermingled waste.
3) To increase the predictability of the long process until a decision on the suitability of a novel technology, as well as to facilitate the eventual assessment, Art. 10 should provide for a right to request a regular exchange of views with EFSA, following the notification. Those exchanges could be similar to ECHA’s Teleconference Based Information Sessions (TIS). Furthermore, with a view to recital 17 as well as legal certainty, the assessment should start as soon as, objectively, sufficient data is available, taking into account the nature of the technology. Hence, the words “the Commission considers” in Art. 14(1) should be deleted and “it may” replaced with “the Commission shall”.
4) To allow for the appropriate protection of developers’ commercially relevant information, the last part of Art. 10(3) after “The information shall be considered of commercial relevance to the developer” should be replaced with a reference to Art. 20 of Reg. 1935/2004.
5) We understand that DG SANTE intends to set out transition periods that will allow the continued placing on the market when the EC decides that recycling processes shall be subject to authorisation, while applications for authorisation are prepared and pending (slide 50). However, these transition periods should be set out in Art. 4(4), 15 and/or 17.
6) Relying on the applicable rules, stakeholders like SCS have invested months in preparing applications for EU authorisation, which cover solutions that will be important to the attainment of the mentioned objectives. They could not predict the timing of the fundamental change of that framework. It would be inappropriate to frustrate their legitimate expectations in the proper completion of at least separable parts of the procedure, as well as efforts that EFSA has already undertaken. EFSA’s opinions have relevance themselves for ascertaining safety and fostering investor confidence. Hence, Art. 31(3) should provide that EFSA shall opine on all applications duly pending when the new regulation enters into force.
We remain available to elaborate further. We also look forward to continuing to clarify with the EC the multitude of solutions to safely use recycled PS as low diffusion FCM, which will remain available for good reason.
Read full responseMeeting with Helena Braun (Cabinet of First Vice-President Frans Timmermans) and EUMEPS and
22 Oct 2018 · discussion on the implementation of the Plastics Strategy