European Bioeconomy Bureau

(formerly the European Circular Bioeconomy Policy Initiative) +44 7435 840357 Rue d’Oultremont 34, 1040 Bruxelles www.bioeconomybureau.eu April 14th 2023 The European Bioeconomy Bureau represents industries, academics and consultancies whose activities are related to the development of the circular bioeconomy. Supporters come from across the European Union and many participate in EU funded research projects investigating the new frontiers of materials and systems to develop the bioeconomy. The development of new industries, employment and added value in producing materials that are derived from the multitude of research projects the EU has financed is indeed a great success story highlighted by the CBE JU (https://www.cbe.europa.eu/).

…projects the EU has financed is indeed a great success story highlighted by the CBE JU (https://www.cbe.europa.eu/). Many projects are related to materials designed to be produced from bio-based or renewable resources, including wastes, and biodegradable in controlled conditions at end of life. The rapid growth experienced and foreseen in coming years of the use of such materials is partly due to the need to reduce plastic pollution; and to help meet industrial goals in reducing GHG emissions, leaving oil and gas in the ground. Where packaging is concerned new technological prospectives are opening daily and whilst the production capacity and market uptake is still very small compared to overall packaging needs (perhaps 1-2% now) legislation should allow these markets to grow and indeed stimulate their uptake. Why ? There are three principal reasons:

…should allow these markets to grow and indeed stimulate their uptake. Why ? There are three principal reasons: 1. The link between food waste and packaging is rarely understood unless clearly explained. When packaging contains or holds food waste, it is not mechanically recyclable. When such packaging is organically recyclable, it may be collected and sent to composting and AD together, recycling the food waste. In these terms, packaging that meets the criteria of the certified EN13432 standard, play an essential role as a vector for food waste.

…packaging that meets the criteria of the certified EN13432 standard, play an essential role as a vector for food waste. 2. As the Soil Strategy and the FAO report on agricultural plastics clearly indicate, soils are increasingly dumping grounds for huge volumes of unrecycled plastics- coming through waste systems such as sewage sludge, compost and digestate, or from the use of plastics directly in farming. Packaging can partly help reduce these environmental burdens by ensuring the materials entering waste treatment are themselves biodegraded in the treatment processes. EN 13432 packaging ensures this. Leakage into the wider environment is to be avoided but all research to date shows these materials to be non-toxic and benign if lost in soil or even aqueous environments. Moreover such packaging increases the interception of biowastes and their return to soil, enhancing organic carbon…

…increases the interception of biowastes and their return to soil, enhancing organic carbon restitution and storage. 3. Using renewable resources, including biowastes, as feedstocks for the production of polymers, packaging and chemicals, offers Europe a chance to move away from fossil dependence whilst simultaneously reducing the GHG impact of production processes. These feedstocks put agriculture at the heart of new, circular bioeconomy industrial processes, both as feedstock suppliers and end users of the outputs. This represent an opportunity, at scale, Ref. Ares(2023)2654694 - 14/04/2023 to improve farm incomes. Similar opportunities are being grasped in the USA under President Biden’s enormous Green Deal package. Indeed, President Biden in March announced a goal to make 90% of all plastic materials bio-based within 20 years.

Indeed, President Biden in March announced a goal to make 90% of all plastic materials bio-based within 20 years. This gives an idea of the scale of opportunity for a new industrialisation of Europe. Unless the EU moves quickly, all investments in innovative materials will go the United States even more rapidly than they already are. Whilst it is clear that there are barriers to the use, recovery and recycling of a new generation of biomaterials in many nations, it should also be remembered that the barriers to recycling and recovering materials available since 1950 are as large today as they were then. In fact, plastic recycling is still spectacularly unsuccessful; the waste industry likewise is still not in a position to recycle large volumes of WEEE exporting much to developing countries, nor textiles.

…is still not in a position to recycle large volumes of WEEE exporting much to developing countries, nor textiles. Yet we have allowed these products and materials onto European markets indiscriminately since they were invented and became available. Now, the PPWR is paradoxically taking measures (on the one hand) to mandate the use of compostable materials in certain restricted uses, and (on the other hand) to discourage their use through legislation which determines they must also be mechanically recycled (when we have seen to date the failure of mechanical recycling of plastics). It is clear that the waste industry takes decades to understand and then build the appropriate infrastructure to handle new materials. We will see in coming years crises related to handling waste solar panels, EV batteries, new generation WEEE.

We will see in coming years crises related to handling waste solar panels, EV batteries, new generation WEEE. Yet these are all on the market now and it is inevitable that these waste streams needing new infrastructure will grow. Similarly, most of the waste industry is incapable of sorting or handling innovative biomaterials. Product innovation is always ahead of waste management but this can never be a reason to stop innovation. The key to success in creating a circular bioeconomy for the production, recycling and recovery of certified compostable packaging in the EU is to promote the steady reform of a waste industry still heavily invested in some countries in incineration and in others in landfilling. In these countries advanced composting is often absent.

…in some countries in incineration and in others in landfilling. In these countries advanced composting is often absent. Where advanced composting combined with AD is present, such as in Italy, innovative certified compostable materials enter food waste streams and are treated without difficulty. They lead to a reduction of plastic waste, less contamination of biowaste streams, and a greater interception of biowastes to produce compost, returning nutrients and organic carbon to soil. Such a model takes time to develop but without a vision, which is lacking in this proposal, we will continue to send new materials along with plastics to disposal whilst ensuring continued pollution of soil with plastic contamination of food waste streams.

…with plastics to disposal whilst ensuring continued pollution of soil with plastic contamination of food waste streams. It is therefore necessary to ensure that, apart from the mandated products that must respect the EN13432 standard, all bags used for biowaste collection are compostable to the same standard, in whatever material is used - a policy endorsed by EEB and ZWE; that packaging containing fresh food also meets this standard; that catering products, when used in closed loop situations in which collection can be undertaken, are similarly compostable to ensure co-collection with food waste in the same locations; that an annual review of mandated products is made and published, giving industry clear timelines in which to adapt.

…that an annual review of mandated products is made and published, giving industry clear timelines in which to adapt. With the revision of the WFD in 2023, measures must be laid out to reform and enhance the technical capacity of biowaste treatment facilities across the EU ensuring maximum recovery not only of biowastes but also innovative biomaterials; the revision of the Fertiliser Regulation in 2024 should strongly improve the quality of outputs allowed to soil both in terms of contamination but also soil health (eg ammonia emissions, nitrate run-off from wet digestates). Such recommendations have been adopted in the draft proposal of the Commission on Taxonomy (article 2.5) for which the public consultation is open until May 3rd 2023. ENDS

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