TotalEnergies Corbion B.V.

TotalEnergies Corbion is a global technology leader in Poly Lactic Acid (PLA) and lactide monomers.

Lobbying Activity

Meeting with Pascal Canfin (Member of the European Parliament) and Futerro

23 Oct 2025 · Bioéconomie et économie circulaire

Meeting with Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné)

15 Oct 2025 · Exchange of views on the Industrial Accelerator Act and EU regulation linked to chemical activities

Meeting with Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné), Vilija Sysaite (Cabinet of Executive Vice-President Stéphane Séjourné) and

23 Sept 2025 · Futerro requested the meeting to exchange on biobased plastics

Meeting with Olivér Várhelyi (Commissioner) and

22 Sept 2025 · The role of bioplastic and food contact materials in reducing food waste

Meeting with Carlo Fidanza (Member of the European Parliament)

16 Jul 2025 · legislative updates

Meeting with Beatrice Timgren (Member of the European Parliament)

23 Apr 2025 · Carbon Capture Storage, Omnibus.

Meeting with Valérie Deloge (Member of the European Parliament, Shadow rapporteur)

2 Apr 2025 · Directive Allégations vertes

Meeting with Pietro Fiocchi (Member of the European Parliament)

29 Jan 2025 · Alternative Fuel

Meeting with Thomas Pellerin-Carlin (Member of the European Parliament)

9 Oct 2024 · Meeting with Totalenergies on energy

Meeting with Bergur Løkke Rasmussen (Member of the European Parliament)

7 Feb 2024 · EU energy policy

Response to Initiative on EU taxonomy - environmental objective

1 May 2023

TotalEnergies Corbion welcomes the inclusion of the manufacturing of plastic packaging in the Taxonomy Environmental Delegated Act, in line with the previous Delegated Regulation on climate change mitigation or climate change adaptation. However, TotalEnergies Corbion would like to highlight specific inconsistencies with the previous Delegated Regulation regarding the use of circular feedstock and the use of bio-waste feedstock, as well as the contributions to the circular economy of compostable materials used in packaging. Circular Feedstock: include pre-consumer plastic waste among the feedstock for the recycled content target, in order to achieve a higher recycled content target and build an holistic circular economy and, more importantly, will reduce waste and reduce virgin material consumption. Including pre-consumer waste in the recycled content target will incentivize all of the objectives of the circular economy. Regarding the definition of pre-consumer material waste the standard ISO 14021 Environmental labels and declarations Self-declared environmental claims (Type II environmental labelling) should be used as a reference. Use of bio-waste feedstock: we point out that the inclusion of only bio-waste and the exclusion of other renewable raw materials is not in line with the circular economy principle and it is once again limiting the contribution of the bioeconomy to store and keep carbon in the cycle. Already in the first Delegated Act on climate change mitigation and adaptation, published in June 2020, the Technical Screen Criteria for Manufacture of plastics in primary form included renewable feedstock. The same Delegated Act, defined renewable feedstock as biomass, industrial bio-waste, or municipal bio-waste. No further definition of biomass is provided; thus, we assume that both primary as well as secondary biomass are included in the scope. Compostable materials used in packaging: limiting compostable materials used in packaging only to handful of applications, will hamper innovation and investment in compostable plastics materials, like the one produced by TotalEnergies Corbion. We therefore suggest to consider all packaging applications that are linked to the collection of bio-waste and food waste. For detailed amendment please see the attached template.
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Response to Review of the requirements for packaging and feasibility of measures to prevent packaging waste

20 Apr 2023

TotalEnergies Corbion supports the overall objective of recycled content targets in packaging. However, the proposed Regulation despite the initial announcements fails to tackle the most urgent matter of reducing GHG emission in the packaging (and material) sector, which is relevant if the EU wants to reach the climate neutrality goal by 2050. TotalEnergies Corbion is concerned with the following measures of the proposal: it neglects the contribution of biobased plastics in the overall decarbonization/defossilization goals set by the EU Green Deal as well as the ones set by the Circular Economy Action Plan it does not recognize the benefits of innovative polymers (such as PLA) it sets unclear measures on compostable plastic packaging and its end of life In view of the ongoing legislative procedure, TotalEnergies Corbion suggests the following measures: 1. Allow bio-based plastics, produced from sustainable sourced biomass, to contribute to the overall targets by the EU Green Deal on carbon neutrality. The regulation recognizes that Packaging increases faster than the gross national income, which leads to CO2 and other emissions and the acceleration of climate change and Article 5 of the proposed Regulation states that there should be a minimization of the emissions coming from packaging. Therefore the use of bio-based plastics is essential to reach the climate neutrality goal. In order to reward the use of bio-based content in packaging, this should pay as proposed for recycled plastics a reduced extended producer responsibility fee based on the percentage of biobased content present in the packaging. 2. Innovative polymers should be included among the definition of innovative materials in order to give legal certainty that these fall in this class of materials. In particular, innovative polymers, like PLA, should have a 10 year derogation period from the recyclable at scale criteria, in order to allow that different polymers could be aggregated into defined streams and recycled. More specifically it should be defined a timeframe to upscale the proper sorting technologies that would enable better waste streams and allow the chemical recycling of innovative polymers. In order to accelerate this process the EPR fee paid by plastic producers should be earmarked for the upscale of NIR sorting technologies. 3. Compostable plastic should be promoted for the use of packaging intrinsically linked to the separate collection of bio-waste as already recognized for some, limited, applications. However, the use of compostable plastic for other packaging, than the ones included in the proposal, should be possible and have access to the bio-waste bin when the necessary infrastructure is in place. 4. Include pre-consumer plastic waste among the feedstock for the recycled content target: in order to achieve a higher recycled content target and build an holistic circular economy, pre-consumer plastic waste should be allowed to contribute to the target. 5. Include PLA among the packaging type for design for recycling criteria. Thanks to progress in sorting technology, PLA can be easily separated from other types of polymers. Once sorted, PLA can be recycled using mechanical or chemical recycling (chemical depolymerization) processes. 6. Packaging sorting target: thanks to progress in sorting technologies many other materials could be easily separated on the sorting line. Therefore, to increase the amount of recycled packaging, all packaging entering waste management and recycling plants should sorted into defined waste streams.
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Meeting with Luisa Regimenti (Member of the European Parliament, Shadow rapporteur) and Amazon Europe Core SARL and

9 Mar 2023 · PPWR

Meeting with Nils Torvalds (Member of the European Parliament, Shadow rapporteur for opinion)

2 Mar 2023 · Packaging and packagingwaste

Response to Sustainable Products Initiative

7 Jun 2022

TotalEnergies Corbion welcomes the “Ecodesign Requirements for Sustainable Products” Regulation, we believe it is important that a balanced and science based regulation (and subsequent measures) will help to set a level-playing field for European companies while achieving the overall goals set by the European Green Deal to reach a climate neutrality by 2050. Bio-based, recyclable and compostable plastics, as PLA, could be used in many applications – from packaging to automotive - and therefore could provide a solution both from a “decarbonization of feedstock” standpoint, as well as improved end of life options. However, there are some elements of the proposed Regulation that would need further attention and consideration. 1. “Environmental footprint” & Product Environmental Footprint The Regulation provides a definition of “environmental footprint” based on the Product Environmental Footprint method (Article 2 (23)). However, using PEF methodology, bio-based products, including plastics, will not receive any credit for the fact that CO2 was removed from the atmosphere during photosynthesis and plant growth. In our view, the current PEF methodology is not incentivizing the use of biogenic carbon. A much more meaningful way, applied in LCA and environmental footprint which is not in use in PEF today would be based on giving CO2 removals credits to biomass when produced and giving CO2 penalty to all CO2 (biobased and fossil) when it is actually released back to the atmosphere. In this case, the emissions and removals are shown alongside the time periods that are in the scope of the calculations. With this approach, the data can be shown in a transparent and meaningful way. In addition, this procedure follows the standard EN 16760 “Bio-based products - Life Cycle Assessment” which is the commonly applied standard. Proposal: we suggest to include pertinent standards in the Regulation and also suggest for the upcoming delegated acts that the GHG emission calculation is done by using the standard EN 16760 Bio-based products - Life Cycle Assessment. 2. Biobased/renewable materials criteria: The Regulation represents an opportunity to exploit the potential of bio-based materials, including plastics, to improve the carbon and environmental footprint of products. This would be in line with the European Green Deal goal to reach climate neutrality by 2050. Proposal: include in the Ecodesgin requirements (Article 5) a requirement concerning bio-based material. 3. Harmonized standards vs. non-harmonized standards The proposed Regulation considers only harmonized standards (Article 2(48), Article 5). However, CEN-CENELEC has developed widely accepted and applied voluntary standards (which are updated regularly) for a broad range of sectors. Proposal: We suggest to integrate the Regulation and the delegated acts with the possibility to include non-harmonized standards among the ecodesign requirements 4. Ecodesign Forum (article 17): The composition of the Ecodesign Forum(s) is still unclear. Proposals: • There should be targeted forums for each of the sectors that will be included in the prioritization and planning of the European Commission • Balanced stakeholders representation, including private companies specialized in specific sectors, such as bio-based plastics
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Response to Carbon Removal Certification

2 May 2022

TotalEnergies Corbion welcomes the proposal of the European Commission on certifying carbon removals, that will contribute to Europe's goal of climate neutrality and represents an unique opportunity for Europe's bioeconomy sector. Since the launch of its first European Bioeconomy Strategy in 2012, the European Union recognized that "the bioeconomy has a huge potential for climate mitigation and a carbon neutral future." The attention of the EU to climate issues lead to several EU policies with the overall objective of making Europe carbon neutral by 2050. We support the EU’s effort to achieve climate neutrality by 2050, to protect the future of our planet by providing the inputs for a low carbon bioeconomy, while creating a sustainable competitive advantage for the European industry. 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. While energy efficiency and renewable energy are fundamental to reach this objective, climate neutrality will only be possible by also cutting the emissions associated with the production, use and disposal of materials, including plastics. Materials and manufactured products account for nearly one fifth of the total EU CO2 emissions (data from 2018). It is, therefore, crucial that a European Commission addresses the potential for climate change mitigation offered by bio-based, recyclable (chemically or mechanically) & compostable plastics.
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Response to Waste Framework review to reduce waste and the environmental impact of waste management

11 Feb 2022

1. Collection, sorting & recycling of plastics In order to increase the circularity of plastic materials it is needed to act on the three steps of the end of life treatment: collection, sorting and recycling. Regarding collection of plastics, it would be necessary to have a clear and harmonized labelling thus to would help consumers to correctly dispose it. Sorting technologies have been improving over the years. In the plastic sector NIR (near infra-red) allows to reduce the high cross contamination of polymers. As producers of a bio-based & recyclable polymer (PLA), we have tested NIR on our PLA and found that can be sorted from plastic with a purity of 97% (Source: CE Delft). Efficient sorting and recycling streams are the solution to increase the global recycling rates. Innovative materials like PLA and conventional polymers can coexist in the recycling system without endangering each other as proved by recent study "Effect of poly lactic acid trays on the optical and thermal properties of recycled poly (ethylene terephthalate)" Last but not least, we suggest that EPR fee paid by the plastic sector should be ring-fenced to an update of sorting facilities, in order to increase the circularity of plastics 2. Chemical recycling of plastics This recycling technology should be recognized in the overall definition of “recycling” guarantying a level-playing field. Regarding specifically bio-based plastics such as PLA, we would like to highlight that our plastic is bio-based, biodegradable & compostable, and it can also be mechanically and chemically recycled. As written above, PLA can be sorted from plastic waste very efficiently, thus we believe that mechanical and chemical recycling should become viable, economically feasible and commonly used end-of-life solutions for PLA-based products. Moreover, PLA thanks to its specific features contributes to build a true circular economy by maintaining the carbon embedded and recycled via different recycling technologies. Finally, the development of innovative materials should not be discriminated against other materials with well-established recycling value chains, especially if they can provide solutions in terms of “circularity” and “carbon neutrality” 3. Biowaste output quality Bio-waste accounts in Europe for more than 100 million tons per years. According to a study done by Zero Waste Europe and the Biobased Industry Consortium, only 34% of bio-waste and 16% of food waste is being collected. This situation must drastically improve over the next two years in order to meet the requirement set by Article 22 of the WFD of a mandatory separate collection of bio-waste by end 2023. Consequently, the amount of bio-waste treated will increase, which will also lead inevitably to an increase of contaminants entering composting plants, especially by conventional plastics. In order to avoid a decrease in quality of the output of the organic recycling of bio-waste, we suggest to set minimum requirements for the quality of the compost by, also, requiring that a there is an actual composting phase which would allow to stabilize the outcome and produce mature compost and avoid any negative impacts on soil 4. Biobased & Compostable plastics and composting Following the previous point, it is vital that also the input in bio-waste stream is free from contaminations. According to composters, plastics is one of the major contaminants of their input and thus has negative impacts on the final compost. In this case biobased and compostable offer a solution, because they fit the organic recycling process of bio-waste (see studies published in Italy , the Netherlands , Spain , Germany ) and help to increase the amount of bio-waste recycled
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Response to Amendment of Regulation (EU) No 282/2008 on the recycling of plastic materials to be used as food contact materials

17 Jan 2022

TotalEnergies Corbion launched the world’s first commercially available chemically recycled bioplastics product. Our recycled PLA grades boast the same properties, characteristics and regulatory approvals as virgin PLA, but are partially made from post-industrial and post-consumer PLA waste. TotalEnergies Corbion is already receiving and depolymerizing reprocessed PLA waste, which is then purified and polymerized back into commercially available recycled PLA . TotalEnergies Corbion is currently investing in the scale of this recycling technology and the placing on the market of recycled PLA, we would like to send - in the line with the feedback shared by European Bioplastics - our comments and request further clarification regarding the Commission’s draft regulation
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Response to Policy framework on biobased, biodegradable and compostable plastics

25 Oct 2021

Total Corbion PLA welcomes the development of a policy framework. We believe it is important that a balanced and science based policy framework it is developed. Please find below some critical points and attached a document analyzing the supporting studies 1. Mechanical recycling & chemical recycling of PLA While the Roadmap makes a distinction between biobased plastics (BBP) and biodegradable and compostable plastics (BDCP), it does not indicate that PLA is biobased, biodegradable and compostable, and it could also be mechanically and chemically recycled. PLA can be sorted from plastic waste very efficiently using industry-standard NIR (near infra-red) sorting technologies. We believe that mechanical and chemical recycling should become viable, economically feasible and commonly used end-of-life solutions for PLA-based products. Moreover, PLA thanks to its specific features contributes to build a true circular economy by maintaining the carbon embedded and recycled via different recycling technologies. Finally, the development of innovative materials should not be discriminated against, especially if they can provide solutions in terms of “circularity” and “carbon neutrality” 2. Littering & Labelling The Roadmap mentions that BDCP may increase littering. It should be clear that industry did not promote BDCP as a solution to plastic pollution. However, as mentioned also in a study conducted for the European Commission, there are no “empirical evidence that clearly correlates the marketing of plastics packaging or products as biodegradable/compostable with an increase in the tendency to litter”. It should be also mentioned, that BDCP placed on the market are labelled as “compostable” and not “biodegradable”, therefore consumers are not confused with misleading information. Indeed, the decision by the Commission to label as “plastic” even BDCPs under the SUP, has added to consumer confusion 3. Organic Recycling is recycling The Roadmap does not highlight the role of organic recycling of BDCP and implies that it should be considered as an inferior option compared to mechanical recycling and chemical recycling. All recycling technologies should be included in a holistic plan contributing to increase the recyclability of plastic materials. We recall that the WFD and the PPWD provide a level playing field among recycling technologies and that organic recycling of BDCP contributes to the recycling target of plastic packaging (see Article 6a.4 of PPWD). Moreover, we recall the role that BDCP play in the recycling of bio-waste: BDCP contribute (together with other organic wastes) to balance the carbon-nitrogen ratios and generate mature compost 4. Compostable plastics & market restrictions The Roadmap states that “The circular economy and ‘waste hierarchy’ principles would suggest using BDCP only for limited, specific applications for which reduction, reuse and recycling are not feasible or desirable”. We disagree with this approach: a) a level playing field between recycling technologies should be guaranteed, b) BDCP is circular because it contributes to close the loop of the carbon cycle, c) BDCP should not be limited by law only to specific applications, this would hamper R&I activities that the European Commission funded under Horizon 2020 and will fund under Horizon Europe 5. Comparison with “alternative options” It is mentioned – also in the context of the revision of the PPWD – that a comparison with “alternative option” should be made: however it is not mentioned which are the alternatives. If the comparison among BBP/BDCP and fossil-based plastics is made through the use of LCAs, we call upon the commission to develop a common methodology to develop such LCAs. Finally, we would like to emphasize that the Taxonomy already recognized the use of biobased feedstock in plastics as a part of Europe’s ambition to reach carbon neutrality by 2050, therefore this should be recognized also in the upcoming Policy Framework
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