SUEZ Group

SUEZ - GROUPE TOUR CB21 - 16, PLACE DE L’IRIS 92040 PARIS LA DÉFENSE CEDEX, FRANCE TEL +33 (0)1 58 81 20 00 WWW.SUEZ.COM DEPARTMENT OF INSTITUTIONAL AFFAIRS – EUROPE Bio-sourced and compostable plastics – SUEZ recommendations (05/2019) 1/2 SUEZ recommendations concerning Bio-sourced and Compostable Plastics May 2019 Interest Representative Identification Number: 27799842497-69 In the interest of preserving the environment (“Single-Use Plastics Directive, EU Plastic Strategy, etc.), facing the scarcity of oil deposit resources which are likely to run out in the next 50 years, the increase in greenhouse gas emissions, it is hardly surprising that in the search for alternatives to plastics issued from fossil fuel, the idea came to produce plastics from more renewable sources (vegetables, animals, algae etc.). These “bio-sourced” plastics represented approximately 0,75% of the world market…

…impact on the following waste treatment processes: composting (aerobic digestion), anaerobic digestion and recycling. 1. The definition and labelling of plastics that degrade Bioplastics is a term that is defined in French texts1 as a plastic that is Bio-sourced (a material that is entirely or partially made from biological matter)2 and biodegradable (a substance or material that decomposes into various elements under the action of living organisms). Bio-sourced plastics are often misunderstood with biodegradability. Not all bio-sourced plastics are biodegradable and if they are, different levels of biodegradability exist. Biodegradability also exists for some fossil sourced plastics depending on the polymer composition (for example, Polycaprolactones (PCL)). Today, different standards present different conditions for degradability and a generic definition for “compostable” plastics…

…term will also avoid such plastics being thrown out in nature and will require the need for dedicated composting units. 2. Findings from the SUEZ study Compostable plastics (which include bio-sourced plastics), despite receiving much attention, do not in fact decompose rapidly nor completely in the environment. Laboratory trials were conducted using paper bags as well as compostable plastics that were collected with organic matter.  Under laboratory conditions (test duration: 4 months), it was clear that the paper bags decomposed no matter the temperature. However, under ambient temperature, compostable plastics stay intact. At 55°C they begin to fragment, with the exception of rigid compostable plastics.  In current industrial methanisation conditions, compostable and non-compostable plastics perturb the functioning of the digesters.

…industrial methanisation conditions, compostable and non-compostable plastics perturb the functioning of the digesters. Normally, such plastics are sorted out before entry into anaerobic digestion facilities. During our study, we confirmed that compostable plastics hardly degrade during tests in anaerobic controlled conditions. The risk for microplastics in the soil and in digesters is therefore real. In the case of anaerobic digestion plants, this risk would even increase if compostable plastics entered these plants. 1 Cf. avis de la Commission d’enrichissement de la langue français, JORF n°0297 of 22 December 2016 (text n° 211) 2 Also defined in a French text (n° 2016-1170 of 30 August 2016) Ref.

JORF n°0297 of 22 December 2016 (text n° 211) 2 Also defined in a French text (n° 2016-1170 of 30 August 2016) Ref. Ares(2020)7910938 - 23/12/2020 Bio-sourced and compostable plastics – SUEZ recommendations (05/2019) 2/2 It should be noted that the presence of plastics, even partially, would cause:  an additional cost because these plastics must be removed before entry into the digester, and  an additional cost for the Composting business as it requires supplementary refining before exploitation. When we consider waste sorting units, the following findings should be taken into account:  Bio-sourced plastics that have the same chemical structure as the fuel based plastics do not impact recycling (notably for PET and PE).

…that have the same chemical structure as the fuel based plastics do not impact recycling (notably for PET and PE).  An external study (Cotrep) has shown that the presence of bio-sourced PLA plastics, within even as little as 0,1%, will weaken the properties of the PET recycled and will evidently pose a problem regarding the loss of materials for recycling; affecting the supply of recycled plastics for recycling. In general, any compostable plastic mixed with recyclable plastics will reduce the mechanical properties of the recyclates. This means that it will degrade the quality and reduce the recycling opportunities. To avoid that, there would need to be a separate collection of such compostable plastics which does not exist at the moment.  An increase in the diversity and the mix of plastics only complicates sorting operations.

…not exist at the moment.  An increase in the diversity and the mix of plastics only complicates sorting operations. A complementary study in operational conditions would be beneficial to better quantify the results of the laboratory study for use in establishing standards, legislation, etc. It should also be noted that compostable polymers contain the plastic molecule itself and also a number of additives which gives special properties (Anti-oxidant, anti UV, demolding agents, pigments….). Even if the base molecule can degrade, other additives could be released in the soil and in the oceans. The release of additives in the soil and in the oceans should also be evaluated.

…in the soil and in the oceans. The release of additives in the soil and in the oceans should also be evaluated. In conclusion, it is crucial that these compostable plastics (bio-sourced or not) be completely separated from other plastics through sorting, which today requires the addition of another sorting step at an increased cost. 3. SUEZ position and recommendations SUEZ’s position on compostable plastics is that they should be avoided in the current recyclables stream. It should be noted that plastics that are compostable will require separate collection streams to be put in place and concerted efforts from consumers to separate their waste correctly. We propose that organic waste be collected using the brown paper bags (which are easily compostable) for household organic waste.

…that organic waste be collected using the brown paper bags (which are easily compostable) for household organic waste. This demands increased levels of public educational initiatives and raises the issue of additional costs associated with separate collection. SUEZ cannot see the justification for compostable plastics (including bio-sourced compostable plastics) being used for compost if it is not processed industrially in specific units that take into account specific conditions and the length of time for the plastics to fully degrade. This raises the question on the economic and environmental benefit of such a unit. Finally, lest we forget, compost is used to enrich the soil for agricultural use and not as a means to treat plastic waste. SUEZ in short: With 90,000 people on the five continents, SUEZ is a world leader in smart and sustainable resource management.

…short: With 90,000 people on the five continents, SUEZ is a world leader in smart and sustainable resource management. We provide water and waste management solutions that enable cities and industries optimize their resource management and strengthen their environmental and economic performances, in line with regulatory standards. To meet increasing demands to overcome resource quality and scarcity challenges, SUEZ is fully engaged in the resource revolution. With the full potential of digital technologies and innovative solutions, the Group recovers 17 million tons of waste a year, produces 3.9 million tons of secondary raw materials and 7 TWh of local renewable energy. It also secures water resources, delivering wastewater treatment services to 58 million people and reusing 882 million m3 of wastewater.

…resources, delivering wastewater treatment services to 58 million people and reusing 882 million m3 of wastewater. SUEZ generated total revenues of 17.3 billion euros in 2018 globally, 61% of it generated in Europe.

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SUEZ TOUR CB21 - 16, PLACE DE L’IRIS 92040 PARIS LA DÉFENSE CEDEX, FRANCE TEL +33 (0)1 58 81 20 00 WWW.SUEZ.COM DEPARTMENT OF PUBLIC AFFAIRS – EUROPE Packaging and Packaging Waste – SUEZ Groups’ contribution (04/2023) 1/5 Packaging and Packaging Waste Regulation SUEZ’s comments and recommendations 24 April 2023 Interest Representative Identification Number: 27799842497-69 Executive summary SUEZ welcomes the European Commission’s proposal on the packaging and packaging waste regulation. In this position paper SUEZ wants to highlight some remarks on the proposed legislation. There should be an obligation to extend a minimum of recycled content in packaging for all kinds of materials (paper, cardboard, and glass) and not only to plastic. Moreover, paper and carton reuse have difficulties for a long duration, sometimes recycled plastics offers a more sustainable reuse option.

…carton reuse have difficulties for a long duration, sometimes recycled plastics offers a more sustainable reuse option. Deposit and return systems should remain flexible to be applicable only according to Member States’ situations. Finally, SUEZ suggests limiting the use of compostable packaging as it has a low biodegradability and cannot be recycled. Introduction The European Commission proposed on the 30th of November 2022 the revision of the packaging and packaging waste directive. This revision, which will transform the directive into a regulation, is part of the European Plastics Strategy which aims at fostering reusability and recyclability of plastic packaging and is embedded within the European Circular Economy Action Plan (CEAP), two initiatives whose objectives SUEZ supports.

…is embedded within the European Circular Economy Action Plan (CEAP), two initiatives whose objectives SUEZ supports. Packaging, on the one hand, consumes large amount of virgin materials resulting in resource utilization, and is, on the other hand, a major source of pollution of soils, land, water when inadequately disposed. For example, the foundation Ellen MacArthur estimates that 150 million tons of plastic waste1 can be found in the oceans. Currently, packaging material in the European Union is essentially made of paper (50 %) and plastic (40%), two materials that can be recycled if packaging are eco-designed, efficiently collected and if secondary resources are adequately integrated in secondary markets.

…are eco-designed, efficiently collected and if secondary resources are adequately integrated in secondary markets. Therefore, SUEZ welcomes the European Commission’s proposal and supports the initiative to make all packaging recyclable by 2030 and to create a whole low-carbon circular economy in Europe. The 1 Citeo: « Le point sur : Le tri et le recyclage des emballages en plastique », 2022. Ref. Ares(2023)2891207 - 24/04/2023 Packaging and Packaging Waste – SUEZ Groups’ contribution (04/2023) 2/5 renewed ambition set by the directive is necessary to improve recycling rates for packaging waste since only 64%2 of packaging in the European Union is recycled. However, to ensure the best impact of this directive on circular economy, SUEZ recommends the European Commission’s proposal takes into consideration the following elements. 1.

…economy, SUEZ recommends the European Commission’s proposal takes into consideration the following elements. 1. Clarifying the notion of recyclability and favoring mechanical recycling (article 3 and 6) a) Recyclability at scale The regulation envisions that all packaging should be recyclable. Article 6 lays down several criteria to define recyclable packaging among which the notion of recycled at scale (art. 6.2.e). SUEZ shares the integration of this notion in the definition of recyclability. However, to be recycled at scale, packaging must also be collected at scale. Recyclability at scale also depends on the volume of packaging waste arriving in recycling facilities. Therefore, SUEZ would like to insist on the importance to maintain transfers of waste streams between European countries to gather enough materials to recycle efficiently and economically.

…of waste streams between European countries to gather enough materials to recycle efficiently and economically. In this perspective, this revision is intertwined with the waste shipment directive revision which should reduce red tape and regulatory burdens for exchange within EU countries. A maintained ambition for this revision is essential. Moreover, for a high recyclability packaging must be easily separated. Some packaging materials, as liquid packaging cardboards made of glued plastics / aluminum / cardboards are difficult to separate and therefore to recycle and only the fiber is recovered. Only monomaterial packaging should be added as a criterion of recyclability. b) Mechanical and chemical recyclability The regulation states that packaging is considered as recyclable if designed for recycling (article.

…recyclability The regulation states that packaging is considered as recyclable if designed for recycling (article. 6.2a) and defines this notion as “design of packaging, including individual components of packaging, in order to ensure its recyclability with state-of-the-art collection, sorting and recycling processes” (article 3.(31)). Two main recycling methods currently exist: mechanical and chemical recycling. Mechanical recycling is used for transformation of the plastic waste into secondary raw materials without changing the chemical structure. It is the most used way to recycle plastics in Europe. On the contrary, chemical recycling changes the chemical structure of plastic waste because of the use of several technologies as pyrolysis or gasification to break the hydrocarbon chains into shorter ones.

…of the use of several technologies as pyrolysis or gasification to break the hydrocarbon chains into shorter ones. Chemical recycling is a promising solution to improve circular economy within Europe. However, it is more energy and resource consuming and should only be favored when mechanical recycling is not technically feasible. Therefore, SUEZ strongly recommends that all notions of recyclability within the regulation should be understood as mechanical recyclability. In addition, the quality of secondary raw materials as stated in article 6. 2d should be evaluated according to mechanical recycling standards. 2 Eurostat : “Recycling rates for packaging waste”, last update 21/03/2023, https://ec.europa.eu/eurostat/databrowser/view/ten00063/default/table (last access: 31/03/2023°. Packaging and Packaging Waste – SUEZ Groups’ contribution (04/2023) 3/5 2.

(last access: 31/03/2023°. Packaging and Packaging Waste – SUEZ Groups’ contribution (04/2023) 3/5 2. Considering reusability when adequate A solution for reducing packaging waste is to encourage reusability as considered in the regulation. Nevertheless, reusability can also present difficulties and should be encouraged only when more environmentally favorable than recycling. First, reusability can have a more important carbon footprint than recycling. Indeed, reusable packaging requires more materials—potentially of high-quality concerning food contact. Transport of reusable packaging, if part of a deposit and return system for instance, also increases the environmental impact of reuse. Reusability could also be hindered by the lack of standardization of contents.

…the environmental impact of reuse. Reusability could also be hindered by the lack of standardization of contents. Indeed, reusability will prove economic and environmental benefits only if scalable, in order to reduce transport emissions and costs. A comprehensive cost-benefit analysis should be developed prior to generalizing reusable packaging in different fields. Second, paper or carton represent 50% of packaging materials. If they can sometimes qualify as a more sustainable option than plastic packaging, they also degrade more easily and are therefore not very conducive for reuse. Conversely, plastic is in some cases a better material to ensure reuse objectives. There is an apparent contradiction between the promotion of reusability on the one hand and public distrust for plastic packaging which could hinder the Commission’s objectives on reusability.

…the one hand and public distrust for plastic packaging which could hinder the Commission’s objectives on reusability. Finally, even if packaging is reused for a long time, they eventually degrade or get damaged and must be disposed. SUEZ recommends that the regulation imposes recyclability for reusable packaging as well. A form of traceability of the former content would also be necessary to ensure efficient recycling. 3. Keeping the balance of collecting systems and national flexibility Deposit and refill systems are solutions to reduce packaging waste and are used in many European countries for beverage bottles. The European Commission proposes to implement collecting systems on an EU level. SUEZ would like to express its concern on this subject.

…proposes to implement collecting systems on an EU level. SUEZ would like to express its concern on this subject. Modalities for improving collection systems must respect subsidiarity and let Member States applicate a system that is the most adequate to their situation, without imposing deposit systems. Improving collection must take into account that primary material for recycling should remain accessible on the market to allow competition on the overall recycling value chain. In some countries, deposit system may increase the risk of monopoly of the recovery of materials that would fragilize recycler’s economic models. Moreover, the coexistence of several models within a country, separate collection for some materials and deposit systems for others can be a source of confusion for consumers, increasing the risk of mistake and poor quality of collection.

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