Consorzio Italiano Compostatori

CONSORZIO ITALIANO COMPOSTATORI Page 1 of 7 CIC’s feedback on the Commission’s proposal for a Packaging and Packaging Waste Regulation Prot S 332/R 21.4.2023, Rome (Italy) Italian Compost and Biogas Association (CIC) Contact details: [email protected]; www.compost.it Who we are The Italian Compost and Biogas Association (CIC) welcomes the possibility to comment on the draft document revising the packaging and packaging waste directive released by the EU Commission on November 30th 2023. Since 30 years, CIC represents in Italy the industrial sector that recycles bio-waste (mainly food-waste and garden/park waste) into compost, biogas and more recently biomethane; our Association unites public and private compost producers, local authorities and others involved in compost production, like machinery and equipment constructors, growing media producers, research bodies, etc.

…in compost production, like machinery and equipment constructors, growing media producers, research bodies, etc. Since the very beginning, in 1992, CIC’s mission has been to enhance recycling and prevention of bio-waste, share knowledge and know-how between CIC’s associates, enhance compost quality and market, perform technical training for the composting sector, assist government bodies in improving bio-waste recovery. Hence CIC would like to comment, as the representatives of the industrial recycling sector for bio-waste in Italy, specifically on Article 8 and Annex III and Annex VII of the proposed draft EU regulation on packaging and packaging waste (in short draft PPWR), which is going to regulate the production and marketing of compostable packaging materials in the EU and in single Member States.

…to regulate the production and marketing of compostable packaging materials in the EU and in single Member States. About bio-waste recycling in Italy In 2021 almost 7,4 million tons of bio-waste were separately collected in Italy, representing about 39% of all MSW collected for recycling; of this amount 5,2 million tons (or 87 kg per inhabitant) were represented by food-waste. Thanks to the engagement of more than 50 million citizens, Italy is currently among the best- performing EU Member States in diverting food-waste from disposal, in favour of its recycling in composting or combined anaerobic digestion (AD) and composting facilities. The bio-waste recycling sector is represented by almost 360 composting plants, more than 60 of which include a pre-AD step that allow to produce biogas and thus electricity, heat and biomethane; a small number of facilities apply AD only.

…that allow to produce biogas and thus electricity, heat and biomethane; a small number of facilities apply AD only. About compostable plastics and the recycling sector for bio-waste in Italy The production and use of compostable items in Italy started more than 25 years ago, by providing compostable bags to households as a convenient tool for sorting food-waste; these bags and liners Ref. Ares(2023)2834003 - 21/04/2023 CONSORZIO ITALIANO COMPOSTATORI Page 2 of 7 contributed positively to the increase of the separate collection of bio-waste, making Italy a best practice case in terms of spread of the collection, quality and quantity of the waste sorted and sent to recycling.

…practice case in terms of spread of the collection, quality and quantity of the waste sorted and sent to recycling. As a proof of the effectiveness of the use of compostable bags in bio-waste recycling, our Country adopted since 2010 – first case in Europe - the obligation to use exclusively compostable bags for the collection of bio- waste, followed in 2011 by a ban1 to put on the Italian market any single-use carrier bags made of conventional plastics; paper or compostable plastic bags, certified according to EN-13432 standard are exempted from the ban.

…plastics; paper or compostable plastic bags, certified according to EN-13432 standard are exempted from the ban. Hence this strategy has successfully contributed in two decades to: • boost the capture rate for food-waste, especially when collection is done by pick-up schemes, often leading to collect more than 100 kg per-capita also in large cities and metropolitan areas • keep low levels of contaminants inside the food-waste collected, thus preventing pollutants such as glass and plastics to be carried - during the recycling process - into the compost and hence to soils. Generally speaking, according to Italy’s long experience, compostable plastic products certified according to the EN-13432 standard have properties that allow them to be incorporated into industrial composting processes.

…the EN-13432 standard have properties that allow them to be incorporated into industrial composting processes. In fact, during the composting process, these materials behave in an analogous way to organic waste, i.e. they are partly converted into water and carbon dioxide, and partly transformed into compost, the final product of our plants and used to contribute to soil fertilization.

…and partly transformed into compost, the final product of our plants and used to contribute to soil fertilization. CIC emphasises that a product or material complying with the EN-13432 standard has to pass both a biodegradability test (a laboratory test assessing the degradation of the product into water and carbon dioxide), a disintegration test (so to verify the effective fragmentation during composting) and the determination of the absence of possible negative effects on compost due to the addition of the product/material; hence fulfilling these tests represents a certainty that these materials are considered suitable to be recycled by industrial composting systems.

…represents a certainty that these materials are considered suitable to be recycled by industrial composting systems. In summary, compostable products specifically realised to help to increase the efficiency of bio-waste collection and to reduce its contamination by unwanted materials (first of all plastic, the main "enemy" of the organic waste recycling sector, but also glass and metal) can lead to a reduction in organic waste management costs. Thus, CIC welcomes all EU initiatives that prevent or eliminate conventional plastics to enter our recycling sector.

Thus, CIC welcomes all EU initiatives that prevent or eliminate conventional plastics to enter our recycling sector. With the enlargement of the EU market for compostable products, the main potential thread that could arise is the confusion among consumers deriving from the simultaneous presence on the market of products made of compostable plastics and of conventional plastics; if these two types are not clearly distinguishable, there is a risk of dragging conventional plastics into the bio-waste stream, undermining the "organic recycling" process. Secondly, a sudden growth of compostable products would imply a potential change in the features of the organic waste that the plants are specialized to treat, even though the current and forecasted quantities are a small percentage compared to conventional plastic items, hence this scenario does not seem to be realistic at present.

…small percentage compared to conventional plastic items, hence this scenario does not seem to be realistic at present. Governing these changes in the best possible way requires collaboration among the stakeholders of the entire supply chain (i.e., the producers of compostable products, the large-scale retail traders, consumers, 1 Since 2011 Italy has banned single-use shopping bags (under 100µm thickness) and from 2018 the ban was extended also all single-use ultra-light carrier bags; paper or compostable plastic bags, certified according to EN-13432 are exempted from the ban. CONSORZIO ITALIANO COMPOSTATORI Page 3 of 7 public authorities, MSW collection companies and recycling plants).

…ban. CONSORZIO ITALIANO COMPOSTATORI Page 3 of 7 public authorities, MSW collection companies and recycling plants). In this sense, CIC stigmatizes the action of some packaging producers who, without any preventive confrontation with the entire collection and recycling chain, have or are introducing on the market new products made of compostable plastic, without the certainty that these can actually "close the circle" of organic recycling. The Certification scheme “Compostabile CIC” In 2006 CIC launched the certification scheme Compostabile CIC on biodegradable and compostable materials2 under the EN-13432 harmonised technical standard; the scheme applies the EN-13432 certification by relying on full-scale testing3 of the disintegration of the items.

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