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EuropeanDiscussionEuropean Bioplastics e.V. Marienstr. papere.V. Marienstr. 19/20 of 19/20 10117 European Berlin 10117 Berlin Bioplastics EuropeanEuropean Bioplastics Bioplastics e.V. e.V. European Bioplastics e.V. Marienstr. 19/20 10117 Berlin European Bioplastics e.V. Marienstr.Marienstr. 19/20, 19/20, 10117 10117 Berlin Berlin phone phone+49.30.28+49.30.28 48 23 48 50 23 50 CRITERIA FOR SWITCHINGfax PRODUCTSfax+49.30.28Marienstr.+49.30.28 48 19/20,23 48 59 23 1011759 Berlin [email protected][email protected] 48 23 50 webfax webwww.european-bioplastics.org+49.30.28www.european-bioplastics.org 48 23 59 TO CERTIFIED COMPOSTABLEe-mail [email protected] web www.european-bioplastics.org

European Bioplastics welcomes the European Commissio’s 3. Potential to reduce non-biodegradable plastics contami- initiative regarding a study on the ‘Relevance of biodegrad- nation of bio-waste collection; able and compostable plastics in a circular economy1. The 4. No efficient re-design possible in order to move to reus- corresponding stakeholder consultation and workshops able solutions. aim to define criteria for when a product should preferentially be made from certified compostable plastics. These criteria clarify, that all applications need a differenti- ated consideration concerning their best option. This offers considerations on criteria as well as exam- In the graphic (end of the paper) we illustrate with some ple products made from compostable plastics. exemplary applications their ability to be recycled but also Managing bio-waste efficiently is key to establish a circular their appearance in the composting stream. economy The products covered by these criteria would in addition In order to ensure that compostable plastics can deliver the need to fulfil the criteria of EN 13432 for industrially com- optimal contribution to realising a circular economy in Eu- postable plastics (criteria regarding impact on bio-waste). rope it is important to acknowledge that they are not a gen- Examples for compostable plastic products eral solution but a specific technology for specific products that can foremost help to efficiently manage the biggest The criteria given above lead to the following list of example fraction of the municipal waste stream: bio-waste. Indus- products: trially compostable plastics can help to separately collect 1. Bio-waste organic waste, divert larger volumes of bio-waste to organic recycling and to reduce conventional plastic contamination 2. Very thin plastic / fruit and vegetable bags in the bio-bin ultimately reducing microplastics in compost. 3. Tea bags Consequently, corresponding criteria and target products need to be defined. 4. Coffee capsule, coffee pads, coffee filters

Criteria for when plastic products should be made of com- 5. Fruit stickers postable plastics 6. Cling-film (and/in combination with) stickers/labels for Plastic products should be produced from compostable fresh produce2 plastics if the following criteria apply: 7. Paper towels (wet-strength paper) 1. Contamination with food waste; 8. Catering items such as cups, trays, plates, cutlery3, 4 2. Likely to end up in the organic waste collection and un- 9. Multi-material flexible packaging for perishable food likely to be effectively mechanically recycled in the plas- tic recycling stream;

1 This would consequently also lead to a reduction of microplastics in organic fertiliser and would reduce the leakage of conventional plastics into soil across the EU. 2 A cling film is often used for the placement of the fruit sticker and labels. Currently, it is either made of or polyvinylchloride, which can contaminate the organic waste stream. In addition, PVC also harms incineration and is rarely recycled mechanically. Due to its very good properties in shelf-life extension of fresh food (similar to PVC), avoidance of organic waste contamination and no harm to other waste streams, we consider cling film to be a good example for recommendable replacement of conventional plastics with certified compostable alternatives. 3 Only in closed-loop systems (provision of goods and waste management is guaranteed) if multi-use options are not feasible. VR4 Flexible, 19997VR semi-rigid19997 Nz, Amtsgericht Nz,and rigid Amtsgericht packaging: Charlottenburg, Most Charlottenburg, of the products forUSt-IdNr. which USt-IdNr. the criteria DE235874231 are DE235874231 relevant are flexible packaging applications (additional flexible products not defined as packaging such as fruit stickers). In some cases of closed loop systems also compostable plastic catering items (semi-rigid) could increase waste management efficiency. The market for compostable rigid packaging is very limited to negligible, as HypoVereinsbank rigid HypoVereinsbankpackaging will potentially Rosenheim, developRosenheim, into BLZ the “reuse, 711BLZ 200refund 711 77, system200 Konto 77,etc.” Konto- direction.6356800, 6356800, IBAN IBAN DE26 DE26 7112 00777112 00770006 0006 3568 00,3568 BIC/SWIFT 00, BIC/SWIFT HYVEDEMM448 HYVEDEMM448

VR 19997 Nz, Amtsgericht Charlottenburg, USt-IdNr. DE235874231 HypoVereinsbank Rosenheim, BLZ 711 200 77, Konto 6356800, IBAN DE26 7112 0077 0006 3568 00, BIC/SWIFT HYVEDEMM448 EuropeanFor Europeanthe Bioplastics identified Bioplastics e.V. Marienstr. e.V.products Marienstr. 19/20 that 19/20 10117 fulfil Berlin 10117 the Berlin four criteria a step- propose a study to identifyEuropeanEuropean the Bioplastics 10 Bioplasticsmost e.V.littered e.V. articles into European Bioplasticsby-step e.V. switch Marienstr. of non-degradable19/20 10117 Berlin plastic products contami- the organic waste stream European and createBioplastics a detailed e.V. legislative Marienstr.Marienstr. 19/20, 19/20, 10117 10117 Berlin Berlin 6 nating bio-waste to compostable plastic products is recom- proposal basedphone on phone these+49.30.28 findings.+49.30.28 48 23 48 50 23 50 mended while Member States build up separate collection fax fax+49.30.28Marienstr.+49.30.28 48 19/20,23 48 59 23 1011759 Berlin In the short-term,phone however,+49.30.28 EUBP 48 recommends 23 50 supporting of bio-waste and organic recycling facilities as demanded by [email protected]@european-bioplastics.org the compostablewebfax plasticwebwww.european-bioplastics.org+49.30.28 bio-wastewww.european-bioplastics.org 48 bag23 59 EU wide as of now the Waste Framework Directive by 2023.5 and to providee-mail [email protected] on the technology and its specif- A step-by-step approach also will facilitate information of ic role within a webcircularwww.european-bioplastics.org economy. Furthermore, until mid of municipalities, waste managers and composters (bio-waste 2020 fully compostable (plastic) alternatives for fruit labels, value chain) as well as the education of consumers across coffee capsules and tea bags should be promoted EU wide. Europe so that they can gain experience on compostable About European Bioplastics plastics and the benefits. European Bioplastics is the association representing the inter- Further steps ests of the bioplastics industry along the entire value chain in The products described are only exemplary. Interesting ap- Europe. Its members produce, refine, and distribute bioplas- plications are, as mentioned above, those, which are typi- tics, i.e. plastics that are either bio-based, biodegradable, or cally littered into the organic recycling and for which a con- both. More information is available on www.european-bioplas- sumer behaviour change cannot be expected. We therefore tics.org.

PlasticPlastic items items(examples (examples only) & recycling only) options & recycling options

common Single use Fruit bags stickers Tea bags/ Coffee Organic recycling / Coffee capsule filter composting advisable!

Cling film Wrappers Single use Multilayer service packaging Reusable ware plastic bags PET

Item found in compost PP packaging shrink film rarely rarely common Recycling* *Defined in coherence with Waste Framework Directive and Packaging and Directive as including organic, mechanic and chemical recycling.

5 Article 22 of Directive 2018/851 amending Directive 2008/98/EC on waste requires Member States to ensure that, by 31 December 2023 bio-waste is either separated and recycled at source, or is collected separately1 12.09.19 and is not mixed with other types of waste. Member States may allow waste with similar biodegradability and compostability properties, which complies with relevant European standards or any equivalent national standards for packaging recoverable through composting and biodegradation, to be collected together with bio-waste. 6 Known sources evaluating ‚contamination levels’ of compost with conventional, non-biodegradable plastics usually give a percentage of contamination contained in the final compost. The studies do not indicate which products are contaminating the bio-waste collection in the first place (beyond the obvious conventional plastic bags). Such a study should be undertaken in early 2020 and can serve as basis for a legislative proposal promoting compostable alternatives by end of 2020 (coinciding with a proposal to revise the Essential Requirements for packaging).

Contact: European Bioplastics e.V., Kristy-Barbara Lange, Phone: +49 30 28 48 23 56, Email: [email protected] www.european-bioplastics.org VR 19997VR 19997 Nz, Amtsgericht Nz, Amtsgericht Charlottenburg, Charlottenburg, USt-IdNr. USt-IdNr. DE235874231 DE235874231 HypoVereinsbankSeptemberHypoVereinsbank 2019 Rosenheim, Rosenheim, BLZ 711BLZ 200 711 77, 200 Konto 77, Konto 6356800, 6356800, IBAN IBAN DE26 DE26 7112 00777112 00770006 0006 3568 00,3568 BIC/SWIFT 00, BIC/SWIFT HYVEDEMM448 HYVEDEMM448

VR 19997 Nz, Amtsgericht Charlottenburg, USt-IdNr. DE235874231 HypoVereinsbank Rosenheim, BLZ 711 200 77, Konto 6356800, IBAN DE26 7112 0077 0006 3568 00, BIC/SWIFT HYVEDEMM448