Ref. Ares(2020)4498708 - 31/08/2020
Brussels, 28 March 2018
To: Mr Günther H. Oettinger, Commissioner for Budget and Human Resources
Ref: EU Plastics Tax
Dear Commissioner Oettinger,
We herewith want to thank you for having invited EuPC on 22nd March 2018 to your round table meeting
on a possible EU-wide plastics tax. We regret very much that as representative of 50.000 possibly affected
companies and representative of above 1.600.000 people employed in the plastics converting sector with
a EU wide turnover of over € 250 billion we were only given 3 minutes to present our case.
Obviously, the huge impact of such an EU-wide tax on our industry has been underestimated and
regretfully we learned that potentially the additional EU revenues will not be used to ensure a more
circular plastics industry in Europe.
The implementation of a plastics tax would have a large array of devastating effects on
Competitiveness,
the
Voluntary Commitments, the
Stimulation of Circularity and the
Principle of Subsidiarity:
Competitiveness
• A tax on production of polymers will without doubt lead to a transfer of production outside the
EU and a further consolidation of an already oligopolistic polymer market in Europe. The majority
of the polymer or upstream producers are globally active companies with production facilities all
over the world.
• From a converters perspective our industry already today suffers from the highest polymer prices
globally and we see over 10 million tonnes of imported and taxed polymers from outside the EU
as a clear reference that suppliers are prepared to increase this share if needed shortly. Evidence
on pricing and imports is attached to this letter (
Annex 1).
• Loss of direct supply and close communication between suppliers and converters will be
detrimental to innovation (one great strength of our industry); 1,6 million jobs and growth in the
EU, while not generating the desired revenues.
All this has been outlined and documented by the empirical industry study of Plastic Converters
elaborated in June 2016 (
Annex 2).
Avenue de Cortenbergh 71 - B-1000 Brussels • Phone: +32 (0)2 732 41 24 • Fax: +32 (0)2 732 42 18
xxxx@xxxx.xxx • www.plasticsconverters.eu
Voluntary Commitments vs. Discrimination
• It is absolutely unclear how the discrimination of a single specific material could contribute to
more sustainability and how this could be legally compliant with the principles of free trade and
free market
• Instead of a general discrimination, the focus should be directed on voluntary commitments of
the industry and pledges from brand owners as it is outlined in the EU Plastic Strategy. Voluntary
commitments can work and contribute to circularity and environmental protection as proofed by
VinylPlus® since early 2000. The EU should put trust in this and not counteract voluntary action
by industry with general taxation.
• Some specific polymer types have nothing to do with the environmental issues such as littering,
hence a polymer specific approach should be considered.
Stimulation of Circularity
• The main question remains how circularity could be stimulated. An EU tax on certain products
identified as detrimental to circularity and the environment might potentially be a starting point
if there are more sustainable solutions available. Here we would like to refer to a most recent
study (March 2018) of the Danish Environmental Protection Agency, stating that plastic carrier
bags have the lowest environmental impact (
Annex 3), along the same line of the certified Pro.mo
LCA Study on disposable tableware that plastics has the lower impact across its whole life cycle
(
Annex 4)
• However, a much more effective measure might be the creation of a pull effect for circularity by
taxation on plastic waste in member states that is not being recycled or reused. If we continue to
tolerate plastics being landfilled, how on earth can we expect a change in the behaviour of
consumer, who are wasting and littering plastic material. This is the real challenge and therefore
the EU should tax plastic waste when it is not being recycled and reused in order to raise the sense
of urgency at the widest possible scope.
• Should taxes be raised, must the corresponding amount be reinvested in sustainable measures to
fuel circular projects in the plastic industry by better collecting, sorting and recycling and
therefore contribute to growth and lower consumption of carbon based raw materials. The EU
circular economy would lose momentum if the tax income would be redirected to fund EU
projects not linked to the circular economy.
• Actual quality and quantitative issues on recycled plastics materials (rPM) are the most important
points to be solved in the next decade in Europe. This will need industrial engagement and time,
as the 2017 study on the use of rPM by plastics converters in Europe shows (
Annex 5).
Avenue de Cortenbergh 71 - B-1000 Brussels • Phone: +32 (0)2 732 41 24 • Fax: +32 (0)2 732 42 18
xxxx@xxxx.xxx • www.plasticsconverters.eu