Interesų grupė
Chemical Recycling Europe Avenue de Cortenbergh 71, 1000 Bruxelles, Belgium Contact : [email protected] Consultation: Reducing Plastic Packaging Feedback on the review of the requirements for packaging and other measures to prevent packaging waste August 2020 Chemical recycling is one of the key solutions contributing to the circular economy of plastics. In addition to increasing the recycling rates of some plastics currently not being recycled, it is creating recycled content of virgin-quality which will be essential to fulfil the strong demand incentivized by the EU Plastic tax, the Circular Economy Action Plan or the EU Green Deal. This move toward a circular economy will reduce oil extraction necessary for the creation of virgin plastic, and reduce GHG in line with the Paris Agreement.
…reduce oil extraction necessary for the creation of virgin plastic, and reduce GHG in line with the Paris Agreement. Chemical Recycling Europe represents the chemical recycling technologies necessary to enable the conversion of plastic waste into new chemical substances and/or products, supporting the circular economy for plastics and complementing traditional mechanical recycling. We strongly support the Commission’s initiative to prevent packaging waste, promote recycling, and increase and incentivize the use of recycled content and its quality. We would suggest the Commission to work along side the industry and platform such as the Circular Plastic Alliance (CPA) as its works overlap with the current goals and work necessary for this initiative.
…the Circular Plastic Alliance (CPA) as its works overlap with the current goals and work necessary for this initiative. Design for recyclability should create a level playing field for recycling technologies and materials choice • To revise the packaging design and recyclability, this review needs to account for all technologies for recycling and innovation, this includes chemical recycling. Some packaging can be recycled through chemical recycling currently but not through mechanical recycling. Without accounting for chemical recycling, increase in recycling rates will be limited. Taking the recyclability based only on traditional existing infrastructure would close some opportunity and disincentivize investment in new technologies for recycling.
…existing infrastructure would close some opportunity and disincentivize investment in new technologies for recycling. Chemical recycling can indeed enable some flexible packaging for instance to keep their functionality, lightweight, while still being recyclable. Chemical recycling still has some specifications and we encourage the Commission to work together with Chemical Recycling Europe to ensure the packaging design is adapted to all recycling methods. • These revisions on packaging design and recyclability should align with the application of eco- modulation fees to all recyclable materials, no matter the technology used. This would create a level playing field in terms of recycling methods and optimize EPR fees directed towards recycling and packaging material recyclable according to the new assessment.
…and optimize EPR fees directed towards recycling and packaging material recyclable according to the new assessment. • These two previous points would effectively shift the plastic packaging from a waste to a valuable resource and incentivize circular solutions. • Finally, a holistic LCA and general impact analysis will be essential for companies to assess packaging from the intersection of variables including recyclability, climate change, functionality & safety. Recyclability should not be considered independently of the other factors in the choice for packaging material. Harmonization in recyclability and collection will be key to support the recycling industry Ref.
…packaging material. Harmonization in recyclability and collection will be key to support the recycling industry Ref. Ares(2020)4083758 - 03/08/2020 Chemical Recycling Europe Avenue de Cortenbergh 71, 1000 Bruxelles, Belgium Contact : [email protected] • Packaging directive essential requirements harmonization across EU countries and clarity will support recycling provide clarity for the private sector and investors to invest in appropriate sorting and recycling infrastructure. • However, this harmonization should go hand-in-hand with an harmonization of collection. If collection is partial, it then will not be adapted to the sorting and recycling of all plastic packaging. The harmonization of collection, starting with the collection of all plastic packaging waste will be essential to harmonized and improve sorting and recycling.
…with the collection of all plastic packaging waste will be essential to harmonized and improve sorting and recycling. Recycling solutions will develop faster if they know there is a clear market for a specific technology, and they can secure the packaging waste. In addition, if efforts are made on design by packaging producers, we should ensure that these are collected, sorted properly to ensure it is recycled at its highest possible grade. Development of policy and methodologies for recycled content to ensure the good functioning of the internal market • Effective and harmonized EU end-of-waste criteria application across countries will ensure the strengthening of the internal market for waste plastics and secondary raw materials.
…across countries will ensure the strengthening of the internal market for waste plastics and secondary raw materials. • The development of adapted measurement methodology for the recycled content from chemical recycling will be crucial to the development of this promising recycling method. We would suggest the Commission to work with the us, the chemical recycling industry, as well as with the chemical and plastic industry on the use of the Mass-Balance Approach. • Finally, the official confirmation that recycled content from chemical recycling are suitable for food-grade application will increase availability of virgin-quality recycled content, currently in high demand with new plastic taxes and circular economy action plan.