Sulapac oy
Reduce the use of plastic with our products.
ID: 415832931499-23
Lobbying Activity
Meeting with Sirpa Pietikäinen (Member of the European Parliament) and Paptic
11 Oct 2023 · PPWR, other relevant legislation
Meeting with Johan Nissinen (Member of the European Parliament, Shadow rapporteur)
25 May 2023 · PPWR
Response to Review of the requirements for packaging and feasibility of measures to prevent packaging waste
24 Apr 2023
Sulapac welcomes the EUs efforts to both combat packaging waste and accelerate the EU transition to a circular economy. This will not only require strong recycling, re-use and recycled content targets but also measures to reduce the harmfulness of packaging waste. Sulapacs mission is to develop microplastic emission and toxic-free biobased materials to replace plastics both in recycling and re-use in order to help end the dependency on fossil oil and to address the threat of permanent microplastics to biodiversity and our health. Recycling and re-use are insufficient solutions without changing what we recycle and re-use into materials that cause no harm to the environment during their life cycle. Whether recycled or reused, conventional fossil-based plastics cause accumulative emissions of microplastics during their whole lifespan. These so-called secondary microplastic emissions result from mechanical erosion and degradation of plastic matter during their use or as litter in the environment. In use, microplastics can result even when a plastic package is opened. The gradual disintegration of plastic objects into microplastic particles in the environment can take from decades to hundreds of years but is always inevitable. Every single plastic object in nature will turn into an equivalent weight of permanent microplastic particles as well as residual toxic additives. In the oceans, it has been estimated that so far 250 000 tons of plastic litter have disintegrated into 5 trillion microplastic particles. It is also estimated that by 2025 there will be 250 million tons of plastic litter in the oceans. Microplastics have also been found to be already accumulating in the soil. The continued use of conventional plastics will also drive oil dependency while alternatives are being adopted in transport and energy. All mechanical recycling of conventional plastics requires the input of new fossil oil during each cycle of recycling. Moreover, conventional plastic can currently be recycled at best once or twice before the material quality decreases resulting in perpetual demand for virgin plastics. According to IEA, petrochemicals are set to be the largest driver of world oil demand in 2050. Sulapac is one of the many material innovators that have recognized the acute need for alternatives to plastics. The alternative material recipes should not only be designed to be fully recyclable, but also be fully biobased and certifiably biodegradable. Moreover, the biodegrading materials should contain no harmful chemicals or ecotoxins to prevent negative environmental impacts in case the material ends up in nature because of littering or failures in waste management. The proposal for the PPWR does not acknowledge or address the microplastic pollution in a single article or a recital nor does it recognize the potential of novel material innovations to replace plastics. While the measures to increase the recycling rate of conventional plastic are crucial, they should not inadvertently close the material loops from more sustainable alternatives available today and developed in the future. Therefore, Sulapac calls for the following adjustments to the PPWR to support the producers of alternative materials: 1. Recognize the recyclability of biobased & biodegradable packaging under Article 6 instead of relegating all biodegradable packaging under the compostable packaging in Article 8. 2. Distinguish sustainable packaging made with biodegradable natural polymers as a separate category of packaging from conventional plastics. 3. Recyclability at scale requirements should allow for the growth of sustainable alternatives. 4. Recycled content requirement for biobased and biodegradable materials should allow for waste & residues as an alternative to post-consumer plastic waste. 5. Risk of microplastic emissions from the production, use and waste-management of packaging should be accounted for in the EPR fees.
Read full responseMeeting with Karen Melchior (Member of the European Parliament, Shadow rapporteur for opinion)
30 Mar 2023 · Discussion and policy paper handover: concerns regarding access to market for small and innovative producers
Meeting with Miapetra Kumpula-Natri (Member of the European Parliament)
8 Mar 2023 · Meeting on PPWR
Meeting with Mauri Pekkarinen (Member of the European Parliament)
8 Mar 2023 · Meeting on PPWR
Meeting with Elsi Katainen (Member of the European Parliament)
8 Mar 2023 · Packaging and Packaging Waste Regulation, (PPWR)
Meeting with Frédérique Ries (Member of the European Parliament, Rapporteur) and EPPA SA
8 Mar 2023 · PPWR
Meeting with Salvatore De Meo (Member of the European Parliament, Rapporteur) and Carlsberg Breweries A/S and
7 Mar 2023 · PPWR
Meeting with Silvia Modig (Member of the European Parliament)
7 Dec 2022 · Regulation on packaging and packaging waste
Meeting with Sirpa Pietikäinen (Member of the European Parliament)
7 Dec 2022 · Proposal Packaging and Packaging Waste
Meeting with Malte Gallée (Member of the European Parliament)
27 Sept 2022 · Packaging and Packaging Waste Directive
Meeting with Margrete Auken (Member of the European Parliament)
31 May 2022 · Packaging
Meeting with Sirpa Pietikäinen (Member of the European Parliament)
19 Apr 2022 · Packaging and Packaging Waste Directive, Sustainable Product Initiative
Meeting with Sirpa Pietikäinen (Member of the European Parliament)
1 Mar 2022 · Packaging and Packaging Waste Directive
Response to Measures to reduce microplastic pollution
18 Jan 2022
Sulapac welcomes the Commission’s initiative to tackle microplastics unintentionally released into the environment. It is very important to recognize and raise awareness of the threat caused by microplastics to the environment and human health.
However, the scope of the initiative on the sources of microplastic is very limited. Every time an item made of conventional plastics is used – even as simply as opening a plastic package – microplastic emissions are produced. The current initiative addresses only a few of the sources responsible for secondary microplastic pollution. To mitigate the issue of microplastics, actions on many levels are needed. In particular, biodegradable materials should be highlighted for their potential to substantially reduce the accumulation of plastics and microplastics in the environment. With biodegradable materials already able to replace several products made of conventional plastics, their use should be incentivised as a crucial part of the solution to the plastic waste and microplastics problems.
1. Recognize the potential of fully biodegradable materials
We believe that truly biodegradable materials will become prevalent in various products and applications soon due to the holistic sustainability benefits they provide when compared to conventional plastics. Therefore, it is imperative that the current legislation takes this into account; if not promoting the use of biodegradable materials, at minimum the regulations should be formulated in such a way that they do not hinder the current or future use of biodegradable materials.
It is scientifically proven that most natural environments on Earth habit microbes that can enzymatically degrade these biodegradable materials. The smaller the fragments are, the faster this enzymatic biodegradation happens (Tosin et al. 2019). If the particles are of nanometer size, the total biodegradation process is extremely fast, lasting only 10-20 days at maximum, which is a time frame similar to that required by the OECD for the classification of “readily biodegradable chemicals”. This shows that that the chemical permanence time of truly biodegradable materials is very short, and these materials do not generate persistent microplastics, even if the material is used in medium-life time products, a fact not often known or acknowledged by the decision makers. Therefore, the potential fear that promoting biodegradable materials would facilitate polluting is not justified.
2. Establish clear standards and labelling to distinguish and promote truly sustainable biodegradable materials as a solution to microplastics
Clear labelling rules and standardization for biodegradable materials on the EU level are needed to recognize truly biodegradable and sustainable material options and to avoid greenwashing. When setting the standard for biodegradable materials, it is important to recognize that different products require different kind of functionality even if made from a biodegradable material. Therefore, the criteria should not exclude medium-life time applications. This means that the product needs to withstand couple of years of shelf-life and use but can biodegrade at the end of its life.
In addition, the criteria for truly biodegradable and sustainable materials should require that any particles eroding during its use (or fragments resulting from misplaced item if it accidentally ends up in nature) will biodegrade in the environment within 1-5 years, similar to tree leaves or branches, and to fully prevent accumulation of microplastic pollution. The risk of something residing in nature for 1-5 years is of totally different magnitude than for conventional plastics which take hundreds or thousands of years to disappear.
Sources: Tosin et al., Biodegradation kinetics in soil of a multi-constituent biodegradable plastic, Polymer Degradation and Stability, 166 (2019), 213-218.
Read full responseResponse to Policy framework on biobased, biodegradable and compostable plastics
27 Oct 2021
Sulapac, a Finnish company developing novel sustainable materials from biocomposites and side-stream wood, welcomes the Commission’s initiative to prepare a Communication on a Policy Framework for BBPs and BDCPs.
BBPs and BDCPs could play a significant role in providing new innovations in clean technology and alternatives to fossil-based plastics. With sufficient regulatory support these innovations could help the EU achieve its visions of carbon neutrality and green transition as envisioned by the EGD and the CEAP. Further, BBPs and BCDPs offer meaningful, sustainable business opportunities across the EU and have the potential to make Europe the leader in the biomaterial cluster and to create new, sustainable jobs.
To realize their potential, BBPs and BDCPs would need a level-playing field with existing fossil-based plastics – we would need regulations that actually encourage innovation and green transition, not regulatory actions intended to sustain status quo by imposing additional limitations to novel, sustainable solutions and that will have an effect no only on bio-based materials but also to other related technologies (e.g., solutions linked to chemical recycling and carbon recycling) that could have a meaningful effect in EU’s push towards carbon neutrality.
Yet, the Commission’s own Roadmap appears to contain misperceptions and biases against the introduction of BBPs and BDCPs that act as an indication to stakeholders in the field that innovation and investment in their business is not encouraged but shunned, and that a focus on the existing fossil-based plastics economy would somehow be preferable.
Sulapac wishes to address the following misperceptions and biases in more detail:
• Consumer confusion: There is no clear evidence that there is any widespread confusion in consumers when it comes to disposing conventional and compostable packaging in regions where BDCPs are widely available.
• Littering: Again, there is little evidence relating to BDCPs as a source of littering. In any case, since it is not realistic or not even targeted by the EU that all plastic waste would in fact be recycled, it would be logical to try to advance such materials and solutions that, should they end up in nature, would in fact biodegrade without leaving permanent microplastics behind. Reaching EUs targets for protecting the biodiversity of marine environment and preventing marine pollution require tackling of microplastics pollution. Focus on recycling of fossil-based plastics is not by itself sufficient to tackle it, and novel, sustainable materials are needed. Therefore, it is not logical that this Roadmap envisions new limitations to materials and solutions that could in fact help in achieving the set climate goals by reducing the reliance on fossil-based alternatives.
• Suitable applications: It is self-evident that any limitation of applications where BBPs and BDCPs could be used would lead to reduction of innovation and investment in the field of sustainable material alternatives and in the field recycling solutions and would only sustain the status quo at the expense of an actual green transition. Further, it is evident that any such limitations will only lead to (a) increased accumulation of permanent microplastics in nature since materials ending up in nature will not biodegrade, and (b) difficulties in reaching even the targeted recycling goals. There is no true justification for proposing an exhaustive list for uses or applications of BDCPs.
• Recycling: It should be noted that both BBPs and BDCPs can be mechanically, organically, and chemically recycled. The focus of the Commission should be in assuring that all said forms of recycling are equally promoted and that sufficient regulatory and financial support is put into the creation of a more efficient and varied recycling infrastructure that can realistically help the Member States in reaching the set recycling goals.
Read full responseResponse to Farm to Fork Strategy
20 Mar 2020
Sulapac is grateful for the opportunity to give our feedback on the European Commission’s upcoming Farm to Fork Strategy. Food and feed chains must remain safe and sustainable. This includes safe and sustainable use of chemicals in food contact materials.
Sulapac designs circularity with materials that mimic nature with first applications in the fields of packaging and straws. Our main raw materials are wood chips and plant-based binders, and the resulting composites can be processed with existing plastic production machinery. By designing materials, the raw materials of which are inherently safe for people and the environment we can promote cycles which are safe on the molecular level.
When Sulapac materials reach their end of life, they are compostable according to CEN standard EN 13432, biodegrading into CO2, biomass and water. Mechanical recycling and chemical recycling are likely to become feasible options when the volumes on the market increase and the recycling infrastructure develops. Sulapac materials provide an innovative and sustainable alternative to conventional plastics, and the company is actively working with a range of retailers and food companies to reduce their use of conventional plastics in order to better protect the environment and humans from plastic pollution.
We are pleased to see the European Commission is committed to addressing the safety of food and feed chains in its roadmap for the Farm to Fork Strategy. Sulapac wishes to highlight the following aspects that are related to food contact materials:
1) Promotion of the use of safe and sustainable food contact materials that don’t leave microplastics behind
Intentionally added microplastics will be addressed in the forthcoming restrictions by ECHA. Unintentional release of microplastics will also be addressed in the Circular Economy Action Plan. This should also be linked closely to the Farm to Fork Strategy. The secondary microplastic leaks is not a bare end-of-life issue. One great advantage of fully biodegradable materials is that in contrast to conventional plastics, these materials do not leave permanent microplastics behind as they can be ‘eaten up’ by naturally occurring micro-organisms. According to several recent studies, problematic human reliance on conventional plastic packaging and food processing methods cause that microplastics are found both in indoor and outdoor environments and even in many food items. EC should introduce labels and guidelines for products that guarantee no microplastics will be leaked from food contact materials during/after use.
2) Level playing field for all forms of sustainable carbon in food contact materials
If blending quotas on thermoplastic materials are established, all forms of sustainable ("renewable") carbon should have a level playing field. The quota should be possible to fulfil by; a) Renewable carbon from sustainably sourced biomass; b) Recycled fossil carbon; and c) Carbon extracted from CO2. This would also promote food safety, as certain grade of contamination and special technical requirements, only some specific types of recyclates can be used as raw materials for food contact materials. For food safety and hygiene reasons it’s also impossible to adapt reuse models for all food contact materials. Thus, the need for some virgin raw materials and single use products remains.
3) Recognition of the important role of organic recycling of food packaging materials
It’s of crucial importance to recognize the special benefits of organic recycling of food packaging materials. The nutrients and other valuable molecules of food rests remaining in the packaging are not wasted if the packaging is recycled via the
organic route. Thus, the role of organic recycling of packaging materials should be appreciated & clarified e.g. in the EPR guidelines in progress, related to the on-going revision of the Packaging and Packaging Waste Directive.
Read full responseResponse to A new Circular Economy Action Plan
20 Jan 2020
Sulapac welcomes the objective of the initiative to speed up the transition, reaping the benefits of the circular model in the EU
and abroad. We are pleased that one of the focus areas is plastics and want to point out the following:
i) Forthcoming restrictions on primary microplastics are welcomed. The secondary microplastics leaks should also be addressed. It should be recognised that it's not a bare end of life issue: to some extent, all solid materials release small particles due to wearing in use. One great advantage of fully biodegradable materials is that in contrast to conventional plastics, these materials are converted into CO2, water and biomass in nature, which means that the particles which are released do not accumulate. Advantages of biodegradable materials are currently analysed related to their areas of applications. This approach is not wide enough, as the property of being "microplastic-free" gives advantages despite the area of application, e.g. in conventional packaging, textiles and other consumer goods. A quotation from Kieran Cox, an oceanographer with the University of Victoria in British Columbia who was lead author on a 2019 study looking into human consumption of microplastics: "Human reliance on plastic packaging and food processing methods for major food groups such as meats, fruits and veggies is a growing problem. Our research suggests microplastics will continue to be found in the majority – if not all – of items intended for human consumption. We need to reassess our reliance on synthetic materials and alter how we manage them to change our relationship with plastics.“
https://www.downtownpublications.com/single-post/2019/12/27/Microplastics-infiltrate-the-human-food-chain
Study published in 2018 in the journal Environmental Pollution concluded that people were more likely to ingest plastic through dust in their environment than by eating shellfish: https://www.sciencedirect.com/science/article/pii/S0269749117344445?via%3Dihub
ii) If blending quota regarding thermoplastics materials are established, a level playing field for all forms of sustainable ("renewable") carbon should be established. It should be possible to fulfil the quota by any of the following
-Renewable carbon from sustainably sourced biomass
- Recycled fossil carbon
- Carbon extracted from CO2
Literature: Carus M. et al, paper #10 on bio- and CO2-based economy 2018-08, Renewable carbon is key to a sustainable and future oriented chemical industry, Nova Institute, Germany.
iii) A technology-neutral definition of ‘recyclable’ should be created. It should leave the door open for new recycling technologies, such as the different forms of chemical recycling. Europe will lose its power to innovate new sustainable materials if the market entry is dictated solely by the status quo of the current recycling infrastructure. The role of organic recycling of packaging materials should be recognized and its role in EPR schemes enabled, clarified & justified. Infrastructure of separate biowaste collection should also be utilized in the organic recycling of compostable packaging. The collaboration along the whole value chain from material innovators to waste management sector should be increased and the infrastructure developed and aligned with standards, such as EN 13432.
iv) The development and implementation of new sustainability metrics is essential in the transition towards a more circular economy. LCA alone is not a comprehensive measure of circularity. Futhermore, LCA does not always provide a level playing field for biobased polymers compared to fossil based polymers. New circularity metrics metrics have already been developed e.g. by Ellen Mac Arthur foundation (Circulytics) and WBCSD (The Circular Transition Indicators).
Literature: Carus, M. et al, How can the environmental effects of bio-based polymers be compared with those of petrochemical polymers on equal footing? , Nova Institute, Germany 2019.
Read full responseMeeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen) and Aula Europe and Paptic
20 Mar 2019 · Microplastics and marine biodegradation
Meeting with Helena Braun (Cabinet of First Vice-President Frans Timmermans) and Aula Europe and Paptic
20 Mar 2019 · discussion on Microplastics and marine biodegradation
Meeting with Sebastien Paquot (Cabinet of Vice-President Karmenu Vella)
26 Nov 2018 · Single Use Plastics and alternatives to plastic
Meeting with Jyrki Katainen (Vice-President)
9 Oct 2018 · EU Plastics Strategy; plastic waste; biodegradable plastics