Name of the Director who has cleared the briefing: Joaquim Nunes de Almeida
BASIS request ID: 8244 Name of main contact person:
GROW I.3
Background
1. Pathways to plastics circularity
• According to a JRC study commissioned by DG GROW (2020), 25Mt CO2 eq. /year can be saved
by recycling all plastic waste in Europe. This is
15.8% of the total GHG emissions of the
chemicals, rubber and plastics industry (EU-27, 2018) and
0.55% of EU’s total CO2 emissions
(2018). However, this scenario only takes mechanical recycling into account. It is now essential
to include chemical recycling in the scenario and pathway, i.e.
clarify the environmental
performance (Life Cycle Assessment)
of chemical recycling. The call for data by the JRC on this is
until end of this month.
• Plastics recycling will not suffice to achieve climate neutral plastics by 2050 and will need to
combine with other alternative feedstock (biomass, captured CO2) and low-carbon production
(e.g. electrification of crackers or pyrolysis units).
• PlasticsEurope has commissioned an independent study by
Systemiq, cal ed “The Future of the
European Plastics System: A Comprehensive Assessment of Pathways to Plastics Circularity in
Europe”.
Jyrki Katainen, who launched the Circular Plastics Alliance as a Commissioner, chairs
the Steering Committee.
2. Chemical recycling
• Chemical recycling refers here to “thermal recycling” i.e. plastic waste heated at 400-500° in a
reactor, to produce pyrolysis oil, which then goes as feedstock into a refinery or cracker, where
it gets mixed with other feedstock (e.g. fossil fuels) to produce multiple outputs ( (e.g. aromatics,
monomers, fuels). In this process, it is not always feasible to “follow” the plastic waste into the
various outputs, hence to determine how much recycled plastics ‘comes from’ the initial plastic
waste (in physical terms).
• To ensure a business case for plastics, plastics producers would like to be able to “attribute”
plastic waste freely to any of the outputs of the cracker/refinery, e.g. assume that all plastic
waste put into pyrolysis has eventual y become a monomer (and then a recycled plastic) – while
a share may have actually become fuels.
DG ENV position is that any losses to energy or fuels
should be deducted (which can be 50-70 %), and there is free attribution within “products
outputs”. It seems this position
would be acceptable for PlasticsEurope (TBC)
• The taxonomy on sustainable finance is clear that chemical recycling is eligible where mechanical
recycling is not “technically feasible” or “economic viable” and CO2 emissions of the recycled
plastics are lower than the virgin equivalent. There are however many
worries from NGOs and
mechanical recyclers that large petro-chemical and chemical companies may start a “hunt for
plastic waste” to feed their existing crackers and refineries and claim recycled content, thus
creating shortages of plastic waste for the smaller mechanical recyclers. We cannot discard this
risk because chemical recycling is more efficient when using “good” plastic waste (i.e. clean
waste from separate collection, equally fit for mechanical recycling).
A no-regret policy option is
anyway to significantly increase the separate col ection and sorting of plastic waste before
mandatory recycled content enters into application, and try to clarify, where possible, which
waste streams is better managed with which technology – depending on the available
infrastructure (e.g. study or recommendations on waste collection)
• A sensitive question is the possible
price of a ton of recycled plastics from chemical recycling vs.
mechanical recycling.
1
link to page 2
Name of the Director who has cleared the briefing: Joaquim Nunes de Almeida
BASIS request ID: 8244 Name of main contact person:
, GROW I.3
3. Single Market
We have received a
number of complaints regarding national (or sometimes regional) provisions
imposing label ing requirements on packaging. The main provisions affecting the packaging industry
(based on stakeholder comments) are:
•
FR Decree 2021-835 of 29 June 2021: mandatory labelling of almost all household products with
a national symbol (‘Triman-logo’) that indicates whether the product is subject to sorting rules
and information on correct disposal.
A Detailed Opinion was issued on 1/10/2020 (TRIS
procedure) indicating that the measures are not proportional and less restrictive means are
feasible (e.g. digital logo).
FR ignored the opinion and GROW E.2 currently assesses the next
steps.
• IT Legislative decree nº 116 of 3 September 2020 (not notified; currently under assessment):
mandatory indication of identification code of the packaging materials and instructions on
correct disposal.
DG ENV envisages harmonised labelling under the revised Packaging and Packaging Waste Directive,
with Commission proposal expected not before mid-2022; hence, the entry into force and/or
application will take
4. Mandatory recycled content in plastics packaging
• PlasticsEurope’s has recently called for 30% mandatory recycled content in plastics packaging by
2030, which is quite ambitious
1.
•
Plastics converters, while agreeing on a 30% target for recycled content in packaging, are
reluctant to mandatory recycled content on
final products (i.e. pressure on manufacturers and
converters to purchase recycled materials). They would prefer mandatory recycled content on
plastics materials (i.e. pressure on producers to make and sell recycled materials). Converters
fear that mandatory recycled content will lead to higher prices for recycled plastics, while quality
does not improve. Besides, converters may struggle to “pass through” the higher costs of inputs
(many plastics packaging converters are SMEs while their suppliers are large chemicals
companies and their customers large brands).
• The
Circular Plastics Alliance can play a role to
help the supply of recycled plastics increase in
paral el with the demand, by fostering quick, voluntary action on design-for-recycling of key
plastic products and separate col ection of plastic waste, and by keeping an overview not only of
all the key value chain steps but also of most key plastics-using sectors.
5. Circular Plastics Alliance vs. European Plastic Pact
• The Circular Plastics Alliance has 290+ signatories, covering the whole plastics value chain, and
positive deliverables. Unfortunately, the alliance only has a limited number of representatives of
public authorities, mainly: Portugal, the Swedish Environmental Protection Agency, and 3
associations of regions and cities.
• The refusal by many Member State authorities to join the CPA has been due to the creation of a
European Plastic Pact, a few months after the CPA, led by the FR and NL Ministries of the
Environment, more “political”, with 150 signatories positioned as “pioneers” (including 13
Member States). It focuses on packaging only.
• Recent efforts to step up the cooperation have not been very effective in triggering joint work.
1 Although fully aligned with 1) the CPA roadmap by 2025 and 2) DG ENV’s options for impact assessment (30
or 40%)
2
Name of the Director who has cleared the briefing: Joaquim Nunes de Almeida
BASIS request ID: 8244 Name of main contact person: Laure Bail argeon, 51226, GROW I.3
• Interests from national authorities to join the Circular Plastics Alliance (e.g. Ministry of economy)
are systematical y hampered by the Pact membership (e.g. Ministry of the environment)
• A recurring criticism from NGOs and Ministries of the Environment is that the CPA is “limited” to
recycling (the reason being that the CPA shal be limited to existing EU targets) and doesn’t work
on reduction and reuse.
•
3