Interesų grupė
BACKGROUND APK AG – Public Affairs December 2020 Page 1 APK AG Beunaer Straße 2 D-06217 Merseburg T +49 3461/79457 – 0 E [email protected] W www.apk-ag.de Contribution of innovative, dissolution recycling of plastics to EU’s Green Deal targets by 2025 and 2030 APK AG, an innovative plastics recycling company from Germany, welcomes the initiative of the European Commission for reinforcing the essential requirements (ER) for packaging as well as revising the Packaging and Packaging Waste Directive in order to strengthen waste prevention, reusability, and high-quality recycling of plastic packaging. We fully support the Commission’s work in mobilising untapped potential in the plastics and packaging value chains in order to create a functioning market for secondary raw materials through harmonised rules for packaging.
…chains in order to create a functioning market for secondary raw materials through harmonised rules for packaging. Achieving the declared goal of the EU Plastics Strategy, reinforced by the Green Deal and the Circular Economy Action plan, that by 2030 all packaging shall be reusable or recyclable, will require a 360-degree appraisal of the untapped potential in the areas of product design and technological innovation. This paper focusses on presenting the key aspects that innovative dissolution recycling technology can contribute to achieving the Commission’s 2030 targets: • availability at industrial scale, • valorisation of untapped ‘waste potential’ (multi-layer / mixed waste streams), • increase of recyclate quality, • purification potential can help to remove hazardous substances, • Broad end market perspective (e.g.
…quality, • purification potential can help to remove hazardous substances, • Broad end market perspective (e.g. cosmetic packaging), • Emission reduction potential compared to virgin plastic production at an average of 66%1 , • Cost-efficient, physical process avoiding energy- and cost-intensive re-polymerisation. Based on dissolution recycling’s technological readiness level (TRL), seeing that it is already being implemented at scale, and based on ongoing/recent investment decisions2, the qualitative and quantitative development of this innovative technology is viable as follows: 1 This reduction potential is based on the process of APK’s dissolution recycling technology Newcycling® which valorises multi- layer films (PA/PE) in its industrial scale plant (8,000 t/a) in Merseburg, Germany. More information at www.apk-ag.de.
…films (PA/PE) in its industrial scale plant (8,000 t/a) in Merseburg, Germany. More information at www.apk-ag.de. 2 APK is currently negotiating with its partners to establish a commercial-scale plant of around 20,000 tonnes. The plant will focus on valorising mixed, flexible post-consumer packaging waste. The facility is envisaged to start production in Europe by 2025. Additional news concerning investments and scale-up recently was published by the dissolution recycler PureCycle Technologies, who will construct a 50,000 t/a plant in Ohio (USA): https://www.recyclingtoday.com/article/purecycle- technologies-raises-250-million-bonds-ironton-ohio-plant/. Ref.
…https://www.recyclingtoday.com/article/purecycle- technologies-raises-250-million-bonds-ironton-ohio-plant/. Ref. Ares(2020)7779824 - 19/12/2020 BACKGROUND APK AG – Public Affairs December 2020 Page 2 APK AG Beunaer Straße 2 D-06217 Merseburg T +49 3461/79457 – 0 E [email protected] W www.apk-ag.de Scale and capacity: APK’s Newcycling® facility in Merseburg, Germany, valorises post-industrial multi-polymer, multi-layer plastic waste via a dissolution recycling process at industrial-scale. The plant features an annual capacity of 8,000 t/a. The mixed input material is transformed into high- purity recyclates exceeding the level of quality produced with standard technology. Several more facilities are envisaged to come on stream by 2025. These plants will be scaled up to around 20,000- 50.000 tonnes and will aim at valorising post-consumer flexible packaging waste.
…will be scaled up to around 20,000- 50.000 tonnes and will aim at valorising post-consumer flexible packaging waste. Preparative steps are ongoing for a major post-consumer campaign at the plant in Merseburg in Q1/Q2 2021, allowing insights to be gained for further planning of the next facility. Replicability and scalability of the technology are a given. With the increasing scale in future facilities, different products will be able to be provided (20,000 tonnes – LDPE; 50,000 tonnes – LDPE, HDPE, PP, 100,000 tonnes – LDPE, HDPE, PP and PET). In view of the dynamic market developments and the growing need in the packaging and plastics value chain for low-carbon, high-quality recyclates, a dissolution recycling capacity of 200,000 tonnes by 2025 and of around 1 million tonnes 2030 are to be expected.
…a dissolution recycling capacity of 200,000 tonnes by 2025 and of around 1 million tonnes 2030 are to be expected. This will include projects by APK but also by other market competitors active in dissolution recycling.3 Quality: One essential element to consider is the purification potential of dissolution recycling, which will enable high-quality recycling of post-consumer waste and support the efforts of the Commission with regard to a ‘non-toxic environment’ and the treatment of hazardous substances. Given the technological developments, and in view of research and development efforts approval of dissolution recycling recyclates for food contact applications seem realistic in the mid-term. By 2025 or shortly thereafter, with the establishment of the first post-consumer waste plant, this important achievement can be accomplished.
…with the establishment of the first post-consumer waste plant, this important achievement can be accomplished. Food contact approval for recyclates stemming from post-industrial sources could potentially take place prior to 2025.4 End markets: The high purity of dissolution recyclates diversifies the potential end markets. The different quality levels produced by different recycling technologies will all be needed for achievement of the 2025 and 2030 targets. With its LDPE recyclates, APK is focusing on the packaging segments such as cosmetic packaging and in the mid-term also food packaging. Other output products such as today’s second string of recycled PA but also future plant’s products such as recyclates from HDPE, PP and PET will boost the use of recycled content in many more market sectors such as textiles, automotive or components of household appliances.
…use of recycled content in many more market sectors such as textiles, automotive or components of household appliances. Emissions: The emissions-reduction potential of a recycling process is, next to its capability for producing high-quality secondary raw materials, a key element when measures are drafted for establishing a strong recyclate market in the EU. APK’s Newcycling® process saves, on average, 66% of emissions as compared to virgin plastics production. The currently valorised mixed waste is a mixture of PA and LDPE.5 3 Next to APK one of the most active dissolution recyclers is US-based PureCycle Technologies who recently announced an ambitious goal of 30 commercial lines by 2030, partially to be build in Europe.
Technologies who recently announced an ambitious goal of 30 commercial lines by 2030, partially to be build in Europe. The estimates shared in this paper are more conservative compared to the prognosis of PureCycle but nevertheless represent a considerable contribution to a circular economy for plastics and a sound opportunity for investments in Europe over the coming decade. More details on updates from PureCycle: http://www.globenewswire.com/news-release/2020/11/16/2127251/0/en/Roth-CH-Acquisition-I-to-Combine-With- PureCycle-Technologies-Accelerating-a-Revolution-in-Plastics-Recycling-Through-Impact-Investing.html Further examples of companies from the plastics value chain engaged in dissolution recycling technology: CreaCycle GmbH, Fraunhofer IVV, Unilever, Suez, P&G, Total, Solvay, VinyLoop, PolyStyreneLoop, Polystyvert, Henkel, Saperatec and Sulayr.
IVV, Unilever, Suez, P&G, Total, Solvay, VinyLoop, PolyStyreneLoop, Polystyvert, Henkel, Saperatec and Sulayr. 4 More information on recent risk assessment and toxicological evaluations of APK’s Mersalen NCY LDPE recyclates available here: https://www.apk-ag.de/en/apk-enables-the-use-of-plastic-recyclates-in-cosmetic-packaging-toxicological-evaluations- confirm-quality-of-newcycling-ldpe-recyclate/. 5 In order to further assess the emissions reduction potential of its technology, APK will mandate additional studies on the topic. BACKGROUND APK AG – Public Affairs December 2020 Page 3 APK AG Beunaer Straße 2 D-06217 Merseburg T +49 3461/79457 – 0 E [email protected] W www.apk-ag.de This prognosis could well be exceeded, given a favourable legislative framework that facilitates a strong secondary raw materials market and enables investments into innovative recycling infrastructure.
…facilitates a strong secondary raw materials market and enables investments into innovative recycling infrastructure. About APK APK was founded in 2008 with the vision of producing pure polymers from plastic waste, with properties close to virgin plastics. Its innovative recycling technology Newcycling® is implemented at industrial scale in Merseburg (Saxony-Anhalt, Germany). APK currently employs around 130 engineers, researchers and administrative staff and features a recycling capacity of up to 20,000 tonnes per year.
POSITION APK AG Beunaer Straße 2 D-06217 Merseburg APK AG - Public Affairs December 2020 Page 1 T +49 3461 / 79457– 0 E [email protected] W www.apk-ag.de Contribution to the European Commission’s revision of essential requirements for packaging and other measures to prevent packaging waste APK AG, an innovative plastics recycling company from Germany, welcomes the initiative of the European Commission for reinforcing the essential requirements (ER) for packaging as well as revising the Packaging and Packaging Waste Directive in order to strengthen waste prevention, reusability and high-quality recycling of plastic packaging. We fully support the Commission’s work in mobilising untapped potential in the plastics and packaging value chains in order to create a functioning market for secondary raw materials through harmonised rules for packaging. Achieving the declared goal of the EU Plastics…
…require a 360-degree appraisal of the untapped potential in the areas of product design and technological innovation. 1. Reflections on the Inception Impact Assessment and the current consultation In general, the Inception Impact Assessment (IIA) as well as the present consultation reflect all of the relevant aspects for truly kick-starting a circular economy for plastics in the coming years – such as a harmonised understanding of what constitutes recyclable packaging, consideration of recycled content standards and targets, and the issue of hazardous substances. The approach to these issues taken by the Commission and reflected throughout the IIA, the scoping study, and the consultation, however, poses a challenge to achieving this goal.
…throughout the IIA, the scoping study, and the consultation, however, poses a challenge to achieving this goal. The current approach to a solution for facilitating efficient treatment of packaging waste and high- quality recycling focuses on standard recycling technology and re-design of packaging applications to better fit those recycling processes (design for recycling). Indeed, this is one valid pathway for ensuring the improved quality of secondary raw materials. Nevertheless, the approach has clear limitations when it comes to both the sustainable1 re-design of products and the valorisation of mixed waste streams and complex applications. The options for increasing the quality of recyclates are consequently limited, reducing the number of products and end markets in which such recyclates can be used.
…are consequently limited, reducing the number of products and end markets in which such recyclates can be used. To overcome these limitations, the definition of ‘recyclable packaging’ must reflect the game-changing influence that innovative recycling processes will be able to contribute in the coming years – by 2025 and 2030.2 1 The term ‘sustainable’ as used here hints at potential negative effects that might be entailed in a re-design of a packaging so as to suit standard recycling processes – such as lowered performance or increased material use. A multi-criteria approach should ensure that re-design is not shifting the environmental burden from ‘recyclability’ to other impact categories.
…ensure that re-design is not shifting the environmental burden from ‘recyclability’ to other impact categories. 2 European Academies’ Science Advisory Council (EASAC), report ‘Packaging plastics in the circular economy’, March 2020: The report finds that recycling of low-value mixed plastic waste is currently still uneconomical, which is a concrete systemic failure in the current linear plastics packaging economy model with regard to end-of-life of plastics packaging. The report suggests tackling this problem by 1) establishing a recycling hierarchy featuring closed-loop recycling (product-to-product) at its top and 2) developing and applying concepts of advanced plastics reprocessing facilities.
(product-to-product) at its top and 2) developing and applying concepts of advanced plastics reprocessing facilities. Furthermore, the report stresses that ‘it is essential to develop integrated recycling systems which can deal with all waste plastics, while achieving net savings in emissions and resource use’. Along with progress in technology, the report encourages trends towards uniform recyclability. Ref.
…resource use’. Along with progress in technology, the report encourages trends towards uniform recyclability. Ref. Ares(2020)7779824 - 19/12/2020 POSITION APK AG Beunaer Straße 2 D-06217 Merseburg APK AG - Public Affairs December 2020 Page 2 T +49 3461 / 79457– 0 E [email protected] W www.apk-ag.de The current focus on standard technology has resulted in questionable conclusions and statements in the current consultation questionnaire, such as that light-weighting and the resultant multi- material, multi-layer packaging solutions are not recyclable and that the complexity of packaging formats, therefore, must be reduced. Innovative dissolution recycling technology, a physical, solvent based process3, however, is available at industrial scale today and is capable of separating different polymer types and different layers of mixed plastic packaging waste to produce high-quality recyclates.
…different polymer types and different layers of mixed plastic packaging waste to produce high-quality recyclates. APK would like to strongly urge the Commission to complement its current focus with a solid emphasis on technological innovation and infrastructure development. This will ensure that the envisaged legislative proposals do not hamper or delay investments into innovative recycling technology and infrastructure during this crucial build-up to the first milestone – the Circular Plastic Alliance’s 2025 target. Moreover, it will prevent the initiation of unsustainable re-design efforts. Assessing and analysing the relevance of innovative recycling technologies for a circular economy for plastics could be integrated in the Commission’s ongoing work in the form of an additional study and consultation, leading to the draft of a legislative proposal.4 2.
…ongoing work in the form of an additional study and consultation, leading to the draft of a legislative proposal.4 2. Innovative technology’s contribution to key points of the present consultation: Rethinking the definition of recyclable packaging The untapped potential of innovation in technology (sorting, collection, and innovative recycling) is relevant for all packaging – both established forms and future innovative solutions. The successive unfolding of such potential will change our understanding of what is recyclable.
…innovative solutions. The successive unfolding of such potential will change our understanding of what is recyclable. In consideration of this and within the context provided, the definition of recyclable packaging suggested in the IAA and the current consultation should be slightly revised: ‘Recyclable packaging is that which can be effectively and efficiently separated from the waste stream, collected, sorted, and aggregated into defined streams for recycling processes, and recycled at scale through relevant industrial processes such that it is turned into a secondary raw material, in line with Article 6a of the PPWD for calculating recycling targets, and of a sufficient quality that it can find end markets to replace the use of primary raw material.
…recycling targets, and of a sufficient quality that it can find end markets to replace the use of primary raw material. Innovative pPackaging placed on the market that requires new and innovative collection, sorting and recycling infrastructure to be developed shall be recycled at scale within a certain period of time. At least 95% of the functional unit of packaging shall be recyclable according to this definition, with the remaining minor components compatible with the relevant recycling process and not hindering the recyclability of the main components, in accordance with CR 13688.’ 3 Definition: Dissolution recycling is a physical process in which plastic waste, pre-treated through mechanical recycling practice, is dissolved either partially or completely in a solvent or solvent mixture. The molecular structure of the polymer remains intact during the entire process.
…in a solvent or solvent mixture. The molecular structure of the polymer remains intact during the entire process. Once dissolved, a series of purification steps are undertaken to separate the target polymer/polymers. Publications of the Federal German Environment Agency as well as of CEFIC and the Chemical Recycling Coalition support the underlying approach of this definition. Therefore, dissolution recycling as physical technology is suggested to be seen as separate from chemical recycling technologies and is definitively to be clearly demarcated from solvolysis. Links: https://www.umweltbundesamt.de/sites/default/files/medien/1410/publikationen/2020-07-17_hgp_chemisches- recycling_online.pdf, https://www.coalition-chemical-recycling.eu/#questions. The first dissolution recycling plant at industrial scale in Europe with a capacity of 8000 t/a is located in Merseburg (Germany).
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Contribution to the consultation on the European Commission‘s Inception Impact Assessment regarding the review of the requirements for packaging and other measures to prevent packaging waste APK AG, an innovative plastics recycling company from Merseburg (Germany), welcomes the initiative of the European Commission to examine the feasibility of reinforcing the Essential Requirements (ERs) for packaging with a focus on “improving design for reuse and promoting high quality recycling”. In this context and in the context of the EU Plastics Strategy, the EU Green Deal, and the New Circular Economy Action Plan APK will support the European Commission’s work to create a well-functioning market for secondary raw materials through harmonised rules on packaging.
…work to create a well-functioning market for secondary raw materials through harmonised rules on packaging. The approach provided in the Inception Impact Assessment (IIA) and reflected in the scoping study poses a challenge to achieving this goal though as e.g. the IIA section ‘Problem the initiative aims to tackle’ only covers a certain problem-angle for efficient treatment of packaging waste and high-quality recycling. Indeed stable quantities of high-quality secondary materials are only available to a limited extent. And we agree that this is ‘partly’ correlated to the aspect of packaging design. Still the second angle to solving the problem is not covered in the IIA and in the scoping study: missing progress in assessing and investing into innovative recycling technologies.
…the IIA and in the scoping study: missing progress in assessing and investing into innovative recycling technologies. Only consideration of innovation in design and innovation in recycling technology can lead to well-founded conclusions on the definition of ‘recyclable packaging’, resilient recommendations on investments into future efficient recycling infrastructure across Europe, reliable conclusions on (future) volumes and quality levels of secondary raw material. Re-design of today’s packaging options will be feasible for a certain share of packaging formats. Still such re-design needs to be analysed against a set of well-defined sustainability criteria. A loss of performance of packaging – especially in the food packaging sector – or an increase of resource use to achieve a certain performance would negate the goals of the circular economy and the Green Deal.
…of resource use to achieve a certain performance would negate the goals of the circular economy and the Green Deal. Furthering progress in recycling technology is paramount to reaching circularity for packaging where re-design is not feasible or sustainable. Innovative recycling technologies, therefore, need to be taken into account when developing a common understanding of what is a ‘recyclable packaging’ as basis for the ER. A multilayer flexible plastic packaging, for example, that has been optimised with regard to its resource use (weight), costs, performance (e.g. food protection, shelf life) and which is foremost not counted as recyclable in today’s average physical recycling process (mechanical recycling) is in many cases easily recyclable via innovative and advanced physical recycling practice (e.g. mechanical pre- treatment with an additional dissolution recycling step).
…advanced physical recycling practice (e.g. mechanical pre- treatment with an additional dissolution recycling step). Such innovative technology is available at industrial scale and for different polymer combinations. Innovative recycling technologies ultimately dissipate the alleged contradiction between light-weighting and recyclability. APK AG Beunaer Straße 2 D-06217 Merseburg T +49 3461/79457 – 0 E [email protected] W www.apk-ag.de POSITION PAPER APK AG - Public Affairs August 2020 Page 1 Ref. Ares(2020)4138578 - 06/08/2020 What is more advanced physical approaches such as dissolution recycling produce much higher quality than average physical approaches such as mechanical recycling. Closed loop recycling (from product to product) is becoming a reality by counting on innovative technologies.
Closed loop recycling (from product to product) is becoming a reality by counting on innovative technologies. In this respect APK supports the conclusions of the EASAC report on plastic packaging and recycling of March 20201 pointing out that re-design and innovation in recycling technology need to go hand in hand to achieve circularity. Recommendations for the further work on a revision of the ER for packaging: The definition of recycling in the Waste Framework Directive covers physical recycling processes such as mechanical recycling and dissolution recycling. When discussing if a packaging is recyclable these different technologies need to be assessed as to their relevance today, in the short- and mid-term.
…is recyclable these different technologies need to be assessed as to their relevance today, in the short- and mid-term. The scoping study should be extended as to the angle of innovation in recycling technology in order to provide a sufficient basis for drafting a legislative proposal on the revision of the ER with regard to the definition of recyclable packaging, the determination of design for recycling guidelines, the consideration of mandatory recycled content targets for certain products and the quality levels of recyclates needed for such products, an accurate overview of how to best reach plastic waste recycling targets by 2030. Such an extension of the study and an assessment of innovative technologies should also foster common definitions and understanding of innovative recycling processes which are a highly relevant prerequisite to making the ER more tangible and reinforceable.
…recycling processes which are a highly relevant prerequisite to making the ER more tangible and reinforceable. About APK AG APK AG was founded in 2008 with the vision of producing pure polymers with properties close to virgin plastics from mixed plastic waste. Researchers and engineers of APK AG have developed an innovative physical recycling process, the Newcycling®-technology, which combines mechanical pre-treatment with a solvent-based purification step (dissolution recycling). In its industrial-scale plant at Merseburg (Saxony-Anhalt, Germany) APK AG is currently employing 130 engineers, researchers, and administrative staff. The plant features a recycling capacity of up to 20,000 tonnes per year. The two well established plastic recyclate products created in Merseburg are marketed as Mersalen® and Mersamid®. More information is available at www. apk-ag.de/en.
…created in Merseburg are marketed as Mersalen® and Mersamid®. More information is available at www. apk-ag.de/en. 1 EASAC report ‘Packaging plastics in the circular economy’, 2020, ISBN: 978-3-8047-4129-4; www.easac.eu. APK AG Beunaer Straße 2 D-06217 Merseburg T +49 3461/79457 – 0 E [email protected] W www.apk-ag.de POSITION PAPER APK AG - Public Affairs August 2020 Page 2