Interesų grupė
Sulapac Ltd © / VAT code 2739393-2 / Iso Roobertinkatu 21 FI-00120, Helsinki, Finland / [email protected] / www.sulapac.com THE PACKAGING AND PACKAGING WASTE REGULATION (PPWR) MUST ACCOUNT FOR MICROPLASTICS AND ALLOW FOR GROWTH OF ALTERNATIVES TO PLASTICS April 2023 Sulapac welcomes the EU’s efforts under the Packaging and Packaging Waste Regulation (PPWR) to both combat packaging waste and accelerate the EU transition to a circular economy. This will not only require strong recycling, re-use and recycled content targets but also measures to reduce the harmfulness of packaging waste. Sulapac’s mission is to develop microplastic emission and toxic-free biobased materials to replace plastics both in recycling and re-use in order to help end the dependency on fossil oil and to address the threat of permanent microplastics to biodiversity and our health.
…end the dependency on fossil oil and to address the threat of permanent microplastics to biodiversity and our health. Recycling and re-use are insufficient solutions without changing what we recycle and re-use into materials that cause no harm to the environment during their life cycle. Why the PPWR must support alternatives to conventional plastics in addition to recycling and re-use? Whether recycled or reused, conventional fossil-based plastics cause accumulative emissions of microplastics during their whole lifespan.1-4 These so-called secondary microplastic emissions result from mechanical erosion and degradation of plastic matter during their use or as litter in the environment.
…result from mechanical erosion and degradation of plastic matter during their use or as litter in the environment. In use, microplastics can result even when a plastic package is opened.5 The gradual disintegration of plastic objects into microplastic particles in the environment can take from decades to hundreds of years but is inevitable. Every single plastic object in nature will turn into an equivalent weight of permanent microplastic particles in millions as well as residual toxic additives. A ton of plastic litter will eventually turn into a ton of microplastics. In the oceans, it has been estimated that so far 250 000 tons of plastic litter have disintegrated into 5 trillion microplastic particles.
…been estimated that so far 250 000 tons of plastic litter have disintegrated into 5 trillion microplastic particles. It is also estimated that by 2025 there will be 250 million tons of plastic litter in the oceans.6 Microplastics have also been found to be already accumulating in the soil.7 The use of conventional plastics will also drive oil dependency while alternatives are being adopted in transport and energy. All mechanical recycling of conventional plastics requires the input of new fossil oil during each cycle of recycling. Moreover, conventional plastic can currently be recycled at best once or twice before the material quality decreases – resulting in perpetual demand also for virgin plastics. According to IEA, petrochemicals are set to be the largest driver of world oil demand in 20508.
…for virgin plastics. According to IEA, petrochemicals are set to be the largest driver of world oil demand in 20508. Sulapac is one of the many material innovators that have recognized the acute need for alternatives to plastics. The alternative material recipes should not only be designed to be fully recyclable, but also be fully biobased and certifiably biodegradable. Moreover, the biodegrading materials should contain no harmful chemicals or ecotoxins to prevent negative environmental impacts in case the material ends up in nature because of littering or failures in waste management. Sulapac, founded in 2016, has developed and commercialized these materials. The proposal for the PPWR does not acknowledge or address the microplastic pollution in a single article or a recital nor recognize the potential of novel material innovations.
…the microplastic pollution in a single article or a recital nor recognize the potential of novel material innovations. While the measures to increase the recycling rate of conventional plastic are important, they should not inadvertently close the material loops from more sustainable alternatives available today and developed in the future. Therefore, Sulapac calls for the following adjustments to the PPWR to support the producers of alternative materials: 1. Recognize the recyclability of biobased & biodegradable packaging under Article 6 instead of Article 8. 2. Distinguish sustainable packaging made with biodegradable natural polymers as a separate group of packaging from conventional plastic packaging. 3. Recyclability at scale requirements should allow for the growth of sustainable alternatives.
…plastic packaging. 3. Recyclability at scale requirements should allow for the growth of sustainable alternatives. 4. Recycled content requirement for biobased and biodegradable materials should allow for waste & residues as an alternative to post-consumer plastic waste. 5. Risk of microplastic emissions from the production, use and waste-management of packaging should be accounted for in the EPR fees. Ref. Ares(2023)2874510 - 24/04/2023 Sulapac Ltd © / VAT code 2739393-2 / Iso Roobertinkatu 21 FI-00120, Helsinki, Finland / [email protected] / www.sulapac.com 1. Recognize the recyclability of biodegradable polymers under Article 6. The PPWR’s approach to biodegradable materials is narrowly through the lens of composting.
…polymers under Article 6. The PPWR’s approach to biodegradable materials is narrowly through the lens of composting. If a material can certifiably biodegrade in industrial compost, it is regulated under Article 8, which mandates the use of compostable packaging for specific uses. However, biobased & biodegradable materials are equally, if not better, suitable for recycling than conventional plastics. For example, hydrolysis is a water-based chemical recycling method suitable for biobased & biodegradable materials is significantly more environmental, requiring temperatures of only 100 degrees Celsius. Chemical recycling can keep biopolymers to stay infinitely in the material cycle and allows for the production of recycled food contact material. These qualities allow innovative biobased & biodegradable materials to replace conventional plastics in the recycling cycle.
…qualities allow innovative biobased & biodegradable materials to replace conventional plastics in the recycling cycle. The PPWR Article 8 paragraph 1 and 2 requires specific packaging to be industrially compostable. Paragraph 3 provides that 'biodegradable plastic polymers may be used in other packaging if they 'allow material recycling without affecting recyclability of other waste streams'. While the requirement is the same as the design for recycling criteria provided in Article 6 – paragraph 1 – point (c) for all packaging, the articles put biodegradable packaging intended for recycling into a disadvantageous position compared to conventional plastics due to the 24-month deadline after PPWR’s entry into force.
…disadvantageous position compared to conventional plastics due to the 24-month deadline after PPWR’s entry into force. Secondly, the interpretation of Article 6 will be elaborated by a Delegated Act whereas what ‘affecting recyclability of other waste streams’ under Article 8 means for biodegradable packaging will have no guaranteed guidance. This will put biobased & biodegradable packaging not intended for recycling (or re-use) under a threat of ban 2 years from entry into force of PPWR, which will inevitably undermine investment security and growth of the sector. Proposed solution: • Remove Article 8 paragraph 3 and allow all biodegradable packaging not intended for composting to compete with other forms of packaging under Article 6 paragraph 1 on recyclability.
…not intended for composting to compete with other forms of packaging under Article 6 paragraph 1 on recyclability. • Amend the definition of ‘compostable packaging’ under Article 3 paragraph 1 point 41 to specify that the composting must be the intended end-of-life solution for the packaging for it to qualify as ‘compostable packaging’. This would clarify the scope of Article 8 and align the PPWR with the ‘Policy Framework of Biobased, Biodegradable and Compostable Packaging’ which clarifies that ‘‘‘Compostable plastics’ are a subset of biodegradable plastics designed to biodegrade under controlled conditions” (p.3.). 2. Distinguish sustainable packaging made from natural polymers as a separate group of packaging.
…conditions” (p.3.). 2. Distinguish sustainable packaging made from natural polymers as a separate group of packaging. The fundamental issue in the PPWR undermining the growth of novel biobased materials to replace plastics is that they are regulated in the same category as packaging made from conventional plastics. PPWR fails to recognize the fundamental difference between novel biobased and biodegradable materials (such as PHA) and conventional fossil- based plastics or biobased plastics that are chemically identical to conventional fossil plastics. Likewise, innovative materials composed of natural polymers and natural fillers (e.g., wood, clay minerals or biochar) that further improve the sustainable properties fall in the same category as conventional plastic packaging.
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