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SYSTEMIQ LIMITED

SIQ

SYSTEMIQ is a combined advisory and investment company that combines high-level research with impactful, on-the-ground action to address global challenges that affect business, society and planet.

Lobbying Activity

Response to EU rules for the calculation and reporting of recycled content in single-use plastic bottles

19 Aug 2025

Feedback on the draft implementing decision laying down rules for the application of Directive (EU) 2019/904 of the European Parliament and the Council as regards the calculation verification and reporting of data on recycled plastic content in single-use plastic beverage bottles. Feedback submission by Systemiq Ltd on behalf of a group of 11 companies and associations representing the end-to-end value-chain for plastic packaging manufacturing, use and recycling. > Endorsements: - Multinational petrochemical companies: Borealis, Covestro, Eastman, LyondellBasell, MOL Group, Versalis. - Multinational technology providers: Axens. - Multinational converters: Amcor. - Trade association for chemical recycling: Chemical Recycling Europe*. - Representation of multinational consumer brands: The Flexible Packaging Initiative*. - Multinational plastic waste management: GreenDot. The organisations listed here support the approach laid out in the Draft Implementing Decision, in particular the recognition of chemical plastic recycling as a complementary technology alongside mechanical recycling, and the establishment of a clear and implementable framework for mass-balance allocation of recycled plastic content following the principle of fuel-use-exclusion. The endorsing organisations highlight four benefits of the proposed approach laid out in the Draft Implementing Decision: 1. It provides clear recognition of chemical recycling of plastics, a critical capability necessary to enable the delivery of recycled content targets and recycling rate targets in the Single Use Plastics Directive (SUPD) and the Packaging and Packaging Waste Regulation (PPWR), achieve voluntary commitments made by leading companies in the food and packaged goods industry, and reduce dependency on virgin fossil resources. 2. It applies a fuel-use-excluded methodology for mass balance allocation consistent with existing legislation (e.g. Waste Framework Directive), and principles endorsed by the value chain, standard-setters (e.g., ISO standard 18604), multinational companies in the packaged goods industry (Consumer Goods Forum 2022: Chemical Recycling in a Circular Economy for Plastics) and civil society actors (EMF 2022: Enabling a Circular Economy for Chemicals with the Mass Balance Approach, WWF 2022: Chemical Recycling Implementation Principles). 3. It supports robust recycled content claims in materials and products by maintaining a strict proportional approach to dual use outputs. 4. It promotes competitiveness of the European plastics/chemicals sector to build a circular economy for plastics in the EU and enable European leadership in circular economy technology innovation. > For clarity, a separate technical response has also been developed by a smaller group of companies and associations, including some but not all companies listed above, and submitted by these organisations as an attachment to their feedback submission. This separate technical response is endorsed only by those companies that are listed on the technical response. >*Further details of endorsing organisations. > FPI: The Flexible Packaging Initiative is open and is currently composed of six members: Ferrero, Mars, Mondelez International, Nestlé, PepsiCo and Unilever. Participants to the Flexible Packaging Initiative have committed to increasing investment and providing support for a series of public policy interventions to accelerate the transition towards a circular economy for flexible packaging across Europe. > Chemical Recycling Europe (CRE): CRE is the trade association uniting companies committed to giving new value to plastic waste and driving the transition toward a more sustainable, circular economy in Europe. Our members develop and license chemical recycling technologies, operate recycling plants, or provide essential support services to the sector. Current members include Agylix, Arcus, BlueAlp, Freepoint, Itero, LBC, Plastic Energy, Promeco, Pryme, Quantafuel, Siemens, and 2GCPR.
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Meeting with Bruno Tobback (Member of the European Parliament) and Zero Waste Europe

2 Jul 2025 · Fossil-Free Plastic Production in Belgium and Europe

Meeting with Koen Van De Casteele (Director Competition)

19 Feb 2025 · Introduction of Project SkyPower. Discussions of their ideas concerning support mechanisms for the uptake of synthetic aviation fuels (e-SAF)

Meeting with Florika Fink-Hooijer (Director-General Environment) and World Resources Institute and

2 Jul 2024 · Speech on the implementation of the European Green Deal at Systems Transformation Hub Summer Reception

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

20 Apr 2023 · Transition to a circular plastics economy in the EU

Response to European Critical Raw Materials Act

25 Nov 2022

As the EU finds itself on an exciting transition to a new energy and mobility system, it needs to create a contingency plan to secure the continuous supply of important materials required for the clean energy transition, such as Cobalt, Nickel, Lithium, or Silicon. For too long, discussions about energy systems have overlooked the hardware dimension: decarbonisation does not mean dematerialisation, a reality which becomes blindingly obvious in the face of resource scarcity and geopolitical tensions. The newly announced EU Critical Raw Materials Act seeks to diversify supply, strengthen domestic production, and promote recycling of materials. But a much broader set of circular economy strategies and more research into effective approaches will be necessary to curb overall demand and prevent material shortages which the EU will face in the 2030-40s. To meet these challenges, the EU should not fall into the trap of replacing one dependency with another. Instead, the EU needs to think holistically, first, how to increase supply chain resilience for these clean energy materials and secondly to think about stock management of the materials in circulation and how to reduce material demand overall. This requires a range of strategies, the building blocks of which have been gradually refined through EU legislation over the past decade. In the context of reducing the demand for virgin raw materials needed to achieve the clean energy transition, four circular economy strategies, in particular, should be employed; these are in accordance with the IRP principles of better (minimise product design through better system design), leaner (optimise product design), longer (maximise lifespan of products), and cleaner (minimise waste and pollution). The EU cannot simply recycle its way out of the resource consumption dilemma. Even highly ambitious recycling targets (e.g. for passenger vehicles) will be insufficient: If historical rates of car sales increases were to continue until 2050, along with existing recycling rates of 30% in passenger vehicles, the global raw material use in the passenger car market would increase by over 350%. Recycling alone would do a lot to reduce this (approximately 60% compared to 2050 BAU levels), but it would be insufficient to keep raw material consumption within planetary boundaries. Only an actual reduction of overall vehicles would bring the consumption levels in line with the IPCCs LED scenario. To achieve such a scenario, recycling rates would have to double along with an annual reduction of car sales of 1.4% between 2020-2050. The CE strategies taken together could then reduce the material demand for passenger cars by almost 80% compared to 2050 levels and achieve even 20% lower material consumption levels compared to 2020. This would be a scenario in line with the IPCCs LED scenario, and it would make the EU economy less dependent on foreign raw material imports. Demand-side reduction does not need to go together with decreased convenience or prosperity. Mobility-as-a-Service and other new business models offer tremendous new economic growth opportunities already today with much higher utilisation rates for cars (and thus lower absolute number thereof). Policy makers should more rigorously consider introducing and supporting circular economy principles along the 4-R circular economy framework, embedded in a re-envisioning the economy through the UN IRP lens of provisioning systems. In the attached summary study, SYSTEMIQ investigates the challenges and opportunities related to CRM and proposes concise actions related to the EU legislative body - with a focus on clean energy technologies and automobility/EV batteries.
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Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans)

22 Feb 2022 · Circular economy transition

Meeting with Stephen Quest (Director-General Joint Research Centre)

9 Nov 2021 · Exchange of views on systemic transformation.

Response to Ecodesign and energy labelling working plan 2020-2024

2 Jun 2021

While the Ecodesign and Energy Labelling Directives have greatly contributed to cutting emissions and increasing energy efficiency, it now needs to face a system change of all regulations in order to be compliant with EGD clear goals of net-zero emissions and resource decoupling by 2050, thus we recommend the following for Ecodesign & Energy Labelling Workingplan 2020-2024: 1) Set a clear goal for products to become fully in line with EGD goals: This is crucial but often skipped to align with science and stakeholders. The workplan must state clear goals for European products compatible with net-zero emissions, nature-positivity, zero pollution and circularity. While these goals cannot be achieved by 2024, everything decided within this time frame must be placed firmly within that clearly formulated path. 2) Pursue fundamental redesign of incentives towards fully sustainable products: The CEAP aims to explore producer ownership (PO) models as these would create the fundamental incentive for producers to design and manage products for full circularity (see attached Producer Ownership Whitepaper, 2021). While the fundamentals of PO cannot be fully changed within 4 years, the work plan can set pilot projects and further research legal options. 3) Improve product regulations that will pave the way, and go hand in hand, with PO model: - More circular Ecodesign: We fully support the stated idea to include standards for “pollutant emissions, durability, reparability, recyclability” and strongly recommend adding standards for high and shared utilization (potentially as part of durability) and mandatory reuse indexes. - Wider product inclusion: We support to include all suggested product categories and strongly recommend including heavy machinery and motors, as these are particularly suitable for remanufacturing and “as a service” models (see IRP report “the manufacturing revolution”). We suggest committing to working closely with initiatives in charge of improving buildings and vehicles, as these are the principal consumers of energy-intensive materials and producers of large amounts of waste. - More ambitious and innovation-promoting: The key is to design these standards as guardrails while not hampering innovation or locking-in old technologies, that become obsolete in future. It is important to not regulate for current levels of feasible efficiency and circularity but for future levels to encourage innovation. One way could be to regulate for steadily increasing levels of efficiency with first years being based on current best practices, to leave time for innovation, but with a fully circular target in the future. 4) Step up Market Surveillance for effectiveness of measures: A sufficient market surveillance is key for the effectiveness of directives and stakeholder motivation. Member states lack in guidelines for testing methods, administrative and testing facility capacity. Here clarifying and cost-effective standards and metrics are needed. Extending ICSM platform for material and energy efficiency will aid the cooperation among member states. 5) Improve product transparency and empower consumers: Include information on country of origin, and impact footprints/waste occurring across the production value chain in other countries, as well durability information/warrantees. 6) Harmonize regulations for a clear market guidance: Products/materials face diverse legislations along their life cycle enforcing narrow thinking and prolonging legislative processes e.g. WEE Directive vs. Ecodesign Directive, EPR schemes via Waste Framework and Plastic Packaging Directive. Unharmonized legislations risk double regulating and insufficiency, hindering clear market signals and allowing negative rebound effects. We thus encourage the EC to explore a redefinition of the Eco-design and Energy Labelling Directive to a more inclusive one, synthesizing a clear framework for EOL and waste management regulations, Ecodesign and tax/ relief schemes.
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Response to Modernising the EU’s batteries legislation

26 Feb 2021

Current regulatory measures and existing conditions do not sufficiently support the effective circular management of batteries and must therefore be modified. The EU Commission's draft for the revision of the EU Battery Directive represents a promising approach to support the circular economy for traction batteries. Based on our extensive work and expertise regarding battery sustainability, industry and lifetime management, SYSTEMIQ supports the measures laid out in the draft of the Battery Regulation and calls upon the European Parliament and the Council to support its implementation in its ambitious form. In particular, - Material specific, ambitious recovery rates are key. The rates proposed are appropriate – with the exception of Lithium: here, both the short- and long term values could be much more ambitious given status quo technology - Addition: these recovery rates must be accompanied by detailed definitions on key elements including calculation approach, what constitutes “recyclate”, scope of “recycling process”. – see CEID report for proposition. “Recyclates” should be defined as similar quality as input materials, to avoid downcycling and thus substantial losses of economic value. - Data is key: creating transparency on value chain human rights, CO2, and recyclate contents across the value chain are of utmost importance and must be upheld in the draft. - Digital Battery Passports are key: they would allow to capture and appropriately transmit such and other relevant supply chain-, production-, and product data across the value chain. Dynamic data especially on battery state of health should be included to support higher value business models. - Supporting second life applications is important; harmonizing and facilitating conditions for potential market actors (e.g. via battery passport) is key to give this potentially valuable and impactful market a chance. - Addition: large (esp. vehicle & traction) Batteries are high value, highly strategic, long lived products that should be managed as productively as possible as assets beyond the immediate sense for which they are brought into the market. Especially their potentially critical role in supporting the transition to a renewable energy system is significant, as described for example by IRENA and the Global Battery Alliance. Therefore, the regulation should make reference to how traction batteries can be integrated efficiently into power grids via smart and bidirectional charging. For comprehensive recommendations, SYSTEMIQ would like to reference to the report “Resource-Efficient Battery Life Cycles: Driving Electric Mobility with the Circular Economy” (2020) by Circular Economy Initiative Deutschland – a multi-stakeholder initiative of over 50 leading organizations founded led by the German academy for technical sciences acatech and SYSTEMIQ and co-funded by its members and the German Ministry for Education and Research. In the report, the 24 expert members of the working group derives founded and comprehensive recommendations for policy makers. The members of the working group “Traction Batteries” are representatives from leading academic institutions, German companies, and associations with proven expertise on traction batteries and covering the entire value chain of traction batteries. The report can be found here: https://www.circular-economy-initiative.de/s/TB_Gesamtbericht-EN.pdf A Summary can be found here: https://www.circular-economy-initiative.de/s/TB_Kurzfassung-EN.pdf More information on CEID here: https://www.circular-economy-initiative.de/english
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Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans)

24 Feb 2021 · Circular Mobility

Meeting with Johannes Hahn (Commissioner)

18 Feb 2021 · NGO Club of Rome and Systemic Limited presentation to Cabinet Hahn of their co-authored report on A System Change Compass - https://www.systemiq.earth/system-change-compass/

Meeting with Daniel Mes (Cabinet of Executive Vice-President Frans Timmermans)

27 Jan 2021 · Smart mobility as driver for the EU Green Deal

Response to Proposal for a legislative act on methane leakage in the energy sector

26 Jan 2021

Please find our feedback on the inception impact assessment in the attached document.
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Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans)

3 Dec 2020 · Regenerative agriculture

Response to EU Methane Strategy

5 Aug 2020

We are thrilled that the European Commission intends to publish its revised “EU methane strategy” in September 2020. We strongly urge the European Commission to include a regulatory pathway towards ambitious methane emissions performance standards for the oil and gas industry as part of this strategy. Such performance standards should reflect the intensity of methane emissions associated with both domestic production and imports from third countries. Many stakeholders point out that methane performance standards will be difficult to enforce without robust measurement and reporting data. Some are calling for a staged approach, in which the European Commission focuses on improved emissions measurement first, and only once such a data reporting system is perfected, begins to consider regulating emissions. However, while credibility of data is important, such an incremental approach delays the critical methane abatement work required to meet Europe’s Green Deal net-zero 2050 goals and avoid exceeding 1.5 degrees Celsius of warming. Market mechanisms designed to certify gas produced with lower methane emissions, coupled with voluntary reporting programs including that established by UN Environment’s Oil and Gas Methane Partnership, can pave the way for emissions reductions by increasing reporting and transparency across gas value chains. A market-based certification approach, as we envisage it, is complementary to both regulatory action and the work done by voluntary initiatives. It can deliver transparent, trustworthy, and independently verified methane emission figures. Thus, it not only fills the knowledge gaps required for solid regulation, but also creates an economic incentive for the natural gas industry to improve operations and drastically reduce the leakage of methane into the atmosphere. Crucially, a certification scheme is also a viable future policy option that can be adopted by ambitious regulators across the globe to benchmark supply chain emissions of methane against a performance standard, while continuing on a voluntary basis in less regulated jurisdictions, applying the same technical standards globally and allowing comparability of emission figures regardless of the source of gas.
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Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans)

28 Jul 2020 · Sustainable food systems

Meeting with Daniel Calleja Crespo (Director-General Environment)

13 May 2020 · Systemiq’s work on Green Deal systems thinking

Meeting with Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans)

14 Feb 2020 · Sustainable food systems

Meeting with Annukka Ojala (Cabinet of Commissioner Stella Kyriakides)

14 Feb 2020 · Discussion on sustainable food systems