traceless materials
traceless materials GmbH is a bioeconomy company that develops and produces innovative natural biomaterials.
ID: 530841294836-94
Lobbying Activity
Response to Circular Economy Act
5 Nov 2025
traceless materials GmbH welcomes the European Commissions consultation on the forthcoming Circular Economy Act. As an EU-funded bioeconomy scale-up developing an innovative traceless® material based on chemically unmodified natural polymers, we aim to contribute to a level playing field for new circular material classes. Natural polymers occur naturally in renewable resources such as starch, proteins, and cellulose and, unlike plastics or bioplastics, are not chemically modified. Traceless offers fully compostable, plastic-free alternatives derived from agricultural residues, reducing greenhouse gas emissions by up to 91% and fossil energy demand by up to 89% compared to conventional plastics. The CEA provides an opportunity to integrate bio-based and regenerative materials into Europes circular economy policy framework and to establish a coherent biocircular economy that recognises biological regeneration and material substitution as legitimate forms of circularity. To achieve this, the Act should recognise biological circularity as an essential component of the circular economy, alongside technical recycling. For natural polymers, composting and biogenic energy recovery close the carbon loop without persistent waste or microplastic leakage and can in many cases outperform technical recycling from a life-cycle perspective. The CEA should therefore explicitly recognise composting and anaerobic digestion as legitimate recycling options and avoid blanket penalisation of biogenic energy recovery, which displaces fossil energy and aligns with IPCC principles on biogenic carbon neutrality. Furthermore, coherence with the Packaging and Packaging Waste Regulation (PPWR) and related waste legislation is essential to ensure legal certainty for innovative materials. Natural polymers should be formally acknowledged as a distinct material category, separate from plastics, and the forthcoming delegated acts under Article 6(4) PPWR should establish clear, science-based criteria for assessing recyclability and end-of-waste status. Existing independent certification schemes, such as the Flustix plastic-free certification, already provide credible mechanisms to verify compliance with REACH and SUPD definitions of natural polymers and should be recognised to ensure consistent verification. At the same time, fair and fit-for-purpose Extended Producer Responsibility (EPR) schemes are crucial to support innovation and ensure a level playing field. EU-level harmonisation, life-cycle-based eco-modulation of fees, and transparent reporting frameworks are necessary to ensure that EPR systems reward materials with genuine environmental benefits rather than penalise bio-based alternatives. The Circular Economy Act represents a unique opportunity to unite competitiveness, bioeconomy, and circularity in Europe. By meaningfully integrating biological circularity into EU policy frameworks, ensuring coherence with the PPWR, and establishing harmonised, fair, and transparent EPR systems, the EU can unlock the potential of natural polymers to contribute to climate neutrality, circularity, and resilience while strengthening Europes bio-based industry and reducing dependence on fossil resources.
Read full responseResponse to Towards a Circular, Regenerative and Competitive Bioeconomy
23 Jun 2025
traceless materials GmbH welcomes the opportunity to contribute to the European Commission's consultation on the revised EU Bioeconomy Strategy. As an EU- and nationally funded clean-tech scale-up developing plastic-free, regenerative materials from agricultural residues, we urge the Commission to address urgent regulatory and investment barriers that currently prevent the deployment of next-generation circular material innovations in Europe. Our material, traceless, is based on unmodified natural polymers, naturally occurring, chemically unmodified macromolecules derived from renewable biomass such as plants or algae. Unlike bioplastics, which are synthetically polymerised and still legally considered plastics, traceless and comparable materials are excluded from the plastic definition under both the Single-Use Plastics Directive (SUPD) and the Packaging and Packaging Waste Regulation (PPWR). traceless is made from second-generation feedstocks with no food conflict, is certified home-compostable, free of toxic chemicals and microplastic pollution, and can be processed using existing plastics infrastructure. It offers up to 95% GHG reduction and 89% less fossil energy demand compared to virgin plastic. Natural polymers present a strategic opportunity to deliver on EU climate, circular economy, and biodiversity goals, particularly in packaging and short-lived applications where reuse or mechanical recycling is not feasible. Yet despite their environmental and technical benefits, they remain largely unrecognised in EU law. Without regulatory clarity, these materials risk de facto exclusion from the internal market by 2035 due to their ineligibility for recyclability compliance under the PPWR. To ensure a future-proof, innovation-enabling bioeconomy, the EU Bioeconomy Strategy should include the following actions: Embed the bioeconomy into the EUs circular economy agenda. The Strategy must help establish a coherent Biocircular Economy that recognises biological cycles and regenerative materials as legitimate circularity pathways alongside reuse and technical recycling. This requires alignment across bioeconomy and circularity policies. Secure market access for natural polymers under the PPWR. Natural polymers must be recognised as a non-plastic material class eligible for compliance under Article 6. The current lack of legal basis for including them in Annex II creates a structural barrier to scale-up. This gap must be addressed ahead of the delegated act deadline in January 2028 to provide legal certainty for investors and customers. Acknowledge regenerative materials in the EU waste hierarchy. Biological recycling routes-such as home and industrial composting-should be accepted as valid end-of-life pathways for materials that are inherently compostable and bio-circular. Recyclability criteria must reflect real-world environmental performance, based on life-cycle assessment. Expand financing access for bioeconomy scale-up. Startups in the industrial bioeconomy face well-documented financing gaps for production infrastructure. The Strategy should include targeted scale-up instruments to complement early-stage innovation finance. Prioritise high-impact use cases and standardisation. Natural polymers should be prioritised for applications where reuse or recycling is infeasible, such as coatings, films and molded packaging. The Strategy should promote harmonised technical standards and labelling frameworks to ensure traceability, integration into EPR systems, and consumer trust. The revised Bioeconomy Strategy is a key for Europe to lead in sustainable materials innovation. Natural polymers are not bioplastics. They are a new class of plastic-free, clean-tech materials that combine low climate impact, safe degradability, and industrial scalability. To fulfil the goals of the Green Deal, Clean Industrial Deal, and a circular bioeconomy, these materials need legal clarity, policy support, and a path to scale.
Read full responseMeeting with Peter Wehrheim (Head of Unit Research and Innovation) and Ecopreneur.eu
13 Jun 2025 · Discussion on circular bioeconomy, bridging innovation to production, funding instruments and legislative bottle necks