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16 Nov.2017 ,

Letter to European Commission Vice President Timmermans on Plastics Strategy


The undersigned organisations are writing to express deep concern over the European plastics strategy currently under development. Based on drafts released by the media, we believe the strategy seriously risks: 1) being developed in silos of plastics without a systemic view, 2) failing to respect the principle of technological/material neutrality and having serious unintentional and unassessed consequences for competing materials and technologies that may in some cases perform better in terms of environmental impacts and circularity and 3) missing the opportunity to drive a low-carbon circular economy. Representing sectors that both compete and work with plastics, we would call upon you to take corrective measures, including the concrete requests for actions listed below before the Commission moves to adopt the strategy.

1) The strategy is being developed in silos of plastics without a systemic view
Plastic materials compete on the market with many other materials with similar or better functionalities and similar or lower negative impact. We strongly believe that the silo approach adopted by the Commission – ignoring interactions, market mechanisms, competition, implications on the whole packaging value chain – will have serious unassessed and unintended consequences and does not ensure fair and equal treatment of all materials. In our view, the draft plastics strategy fails to consider and assess the value chain systems both within the petrochemical industry and even more so in the wider economy. Our observations include:
• the evident market failures of plastic prices; instead the strategy seems to suggest introducing more financial support mechanisms despite the fact that oil and gas subsidies in the EU are significant and have been growing in the OECD at a much higher rate than the growth of GDP ;
• the potential to substitute plastics by better alternatives for some applications;
• the potential to replace fossil feedstock by alternative feedstocks (to name but one, sustainable lignin );
• the sourcing element as circularity is not only about recycling but about the sustainable production of input material; sustainable sourcing is a growing concern and already a legal requirement for other technologies;
• the market impacts for other solutions, materials and products;
• other key policies such as climate change, mobility or bio-economy.

The undersigned deeply regret that - despite several attempts to be heard - they have not been allowed to contribute to the discussion on the strategy.

We would call for the Commission to incorporate the following elements in the plastics strategy:
I. Interaction of the many connected policies, including low-carbon bioeconomy.
II. Implications for competing technologies and materials to ensure fair competition and a level playing field.
III. A holistic view reflecting the reality where plastics are not addressed in isolation and a dynamic understanding of the sectors involved and impacted by the strategy.
IV. Assessment of the systems of value chains within the petrochemical industry, with a view to subsidies for fossil-based plastics and in the wider economy.
V. Assessment of the petrochemical industry as a resource.
VI. Improved assessment of alternative feedstocks, including existing by-products from other sectors and their accessibility, and symmetry in assessing traditional fossil feedstocks’ environmental impacts.
VII. Our industry should be included in the platforms which will be established to discuss and implement this strategy as it will have a direct impact on us.

2) The strategy risks failing to respect the principle of technological neutrality
The measures proposed in the draft plastics strategy and the associated financial and other support would fail to respect the principle of technological neutrality and non-discriminatory policy. And this, notwithstanding that circular economy targets would remain lower for plastics than for other materials.

We find it unfair to have a strategy that rewards the laggards whilst other materials who have done the work and paid for it themselves in the past decades risk being penalised. It would be a strange outcome if the final strategy were to favour a material that remains problematic over less problematic ones.

We would call for the Commission to incorporate the following elements in the plastics strategy:
VIII. Full respect of the principle of technological neutrality in a fair and equal approach.
IX. Reserving an equal amount of public funding for other solutions, materials and technologies as will be the case for plastics.
X. Acknowledgment and promotion of sustainable substitution by competing solutions, materials and technologies; more sustainable packaging materials should be preferred when there is a choice.
XI. Assessment of, and setting policy requirements for, plastics with metrics and boundaries comparable to competing technologies; targets set for plastic materials have to be set on a par with targets for other materials.
XII. Consideration of the full life cycle of plastics, including upstream sourcing of feedstocks (both alternative and traditional).

3) The strategy misses an opportunity in a low-carbon and circular economy
The strategy misses an opportunity to combine a drive for resource efficiency and a move away from non-renewable resource use. As highlighted by President Juncker and the Industrial Policy Strategy released by his Commission, the aim is to build a low-carbon circular economy.

The potential offered by the bio-based economy should be considered alongside the potential to streamline the plastics value chain and make it more efficient. The US public procurement strategy for bio-based materials and products has had a significant positive impact in terms of growth and jobs : similarly the public procurement in Europe should first consider sustainable substitutes to plastics.

We would call for the Commission to incorporate the following elements in the plastics strategy:
XIII. To ensure that public procurement rules or economic incentives are fair, proportionate and not unduly supporting a material, such as recycled plastics, instead of choosing other solutions, materials and technologies, in particular renewable or already highly recycled, over fossil-based plastics.
XIV. Indeed, we would call for the Commission to incentivise industry to encourage companies to choose more sustainable, renewable materials in the first place when selecting their packaging materials. This might be through taxation on the use of plastic or providing positive incentives to use more sustainable materials.

We share a common aim: producing a sustainable circular European economy. The buy-in of the wider economy and society in general for the plastics strategy prepared by the European Commission would require a much more holistic and systemic approach and respect of the principle of technological neutrality by giving a fair and equal treatment to all sectors. At the same time, the plastics strategy should be seized as an opportunity to bring the plastics industry on a par with other industry sectors regarding responsible performance, not least to protect the marine environment and other water bodies.

We remain at your disposal to discuss the matter further and will be in contact with your respective teams of Commissioners in order to support the development of the strategy.

Kind regards,

CITPA, International Confederation of Paper & Board Converters
CEPI, Confederation of European Paper Industries
ACE, The Alliance for Beverage Cartons and the Environment
CEPI CONTAINERBOARD, European Producers of corrugated case materials
CEPI EUROKRAFT, European Producers of Sack Kraft Paper and Kraft Paper
ECMA, European Carton Makers Association
EMBALPACK, European Association of Makers of Packaging Papers
EMFA, European Moulded Fibre Association
EUROSAC, European Federation of Multiwall Paper Sack Manufacturers
FEFCO, European Federation of Corrugated Board Manufacturers
PRO CARTON, European Association of Carton and Cartonboard Manufacturers

 

CC: Commission Vice-President Katainen, Commissioners Moedas, Vella, Bienkowska
Secretary General of the Commission
Director Generals of DG Grow, DG RTD, DG ENV

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29 Mar.2017

Joint letter on alignment of Renewable Energy Directive with the Circular Economy Policies

TO: Members of the European Parliament ITRE Committee

Subject: Alignment of the revision of the Renewable Energy Directive with the Circular Economy Policies

Dear Members of the ITRE Committee,
Ahead of the report of the ITRE committee on the revision of the EU Renewable Energy Directive (RED II), the undersigned organisations, representing plastic and paper recyclers and zero waste associations around Europe, would like to bring to your attention our concerns as regards to inconsistency of the Commission’s proposal in RED II with the Circular Economy policies and the EU’s climate policy agenda.

This is due to the consideration of the biomass fraction of mixed municipal solid waste as a source of renewable energy when it is actually burning thanks to other materials (e.g. plastics and paper). Member States are consequently allowed to support various forms of energy generation from waste, to meet targets set under the RED II. These schemes which support waste-to-energy generation from mixed municipal waste, run counter to the EU’s transition to a low-carbon and circular economy, furthermore this would work to:

1. Undermine the Waste Hierarchy and the Circular Economy policies
Financial support for waste-to-energy from mixed municipal waste subverts one of the cornerstones of the EU waste policy – the waste hierarchy -, which establishes an order of priority in waste prevention and management i.e. prevention, preparation for re-use, recycling, other recovery (energy recovery), and disposal1. Waste is therefore meant to be firstly prevented, then prepared for reuse and, finally, recycled. Conversely, the RED II classifies it as a source of ‘renewable energy’ and allows renewable energy support schemes that conflict with the waste hierarchy by encouraging waste-to-energy processes, which is the second least desirable option of the waste hierarchy.

The effect so far has been a clear distortion of the market whereby investment in waste infrastructure and operation costs are organised on the basis of subsidies for the extraction of energy from waste instead of sound environmental and economic performance of the best waste management option. As a result, several European countries e.g. Denmark have overinvested in energy-from-waste plants whilst underinvesting in recycling facilities.

2. Undermine the Communication on Waste-to-Energy in the Circular Economy
The RED II also contradicts the Commission’s recent Communication on the Role of Waste-to-Energy in the Circular Economy which states that public financing of waste management, whether national or at EU level, should be consistent with the waste hierarchy and Member States should phase-out public support for the recovery of energy from mixed waste in line with the separate collection obligations and more ambitious EU recycling targets proposed in the legislative proposal on Circular Economy2.
1 http://ec.europa.eu/environment/waste/framework/pdf/guidance_doc.pdf
2 http://ec.europa.eu/environment/waste/waste-to-energy.pdf

3. Undermine the EU’s Climate Policy Agenda
The Commission’s proposal also undermines the EU’s climate agenda by supporting energy generation from mixed municipal waste, which is never solely composed of biogenic carbon. Much of the calorific value from waste-to-energy processes from mixed waste (incineration, pyrolosis or gasification) comes from the treatment of fossil carbon based materials such as plastics. For example, a typical waste incineration facility has a carbon intensity of approximately 600 kg CO2 eq. per MWh of electricity. This compares with a figure of 380 kg CO2 per MWh of electricity at an efficient natural gas power station using Combined Cycle Gas Turbine technology3.
Moreover, the monitoring of the amount of the proportion of organic waste compared to the amount of fossil-based waste in municipal mixed waste is both logistically and technologically difficult. It’s often assumed that the proportion is 50% - even if industrial and commercial waste is frequently included in the mix of waste entering a waste-to-energy facility. Given the heterogeneity of waste and the great differences from plant to plant, this percentage is neither constant nor reliable, which supports the evidence that much of the so-called renewable energy from waste-to-energy comes in fact from incinerating fossil carbon based materials.

The undersigned organisations therefore urge the members of the ITRE Committee to align the Commission’s proposal for a revised Renewable Energy Directive with the circular economy policies by explicitly excluding primes of subsidies for waste-to-energy generation from the mixed municipal solid waste.

Kinds regards,
On behalf of signatories
Joan Marc Simon
ZWE Executive Director
Contacts:
Janek Vahk, Development and Policy Coordinator, Zero Waste Europe: janek@zerowasteeurope.eu
Ulrich Leberle, Raw Materials Director, The Confederation of European Paper Industries: u.leberle@cepi.org
Antonino Furfari, Managing Director, Plastics Recyclers Europe: antonino.furfari@eupr.org
3 https://www.zerowasteeurope.eu/downloads/the-potential-contribution-of-waste-management-to-a-low-carbon-economy/

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14 Mar.2017 ,

Made to measure ‘real’ recycling rates will target investment where it matters most

The European Parliament has today opted to follow the ambitious lead set by Environment committee’s vote on the Circular Economy package in January this year.


The most important outcome from today’s vote is that MEPs moved in favour of one single calculation method that enshrines real and comparable recycling rates both in and for Europe.


“Today, the European Parliament has fully grasped the opportunity to make the Circular Economy work for Europe by enabling industry and local authorities to better target where investment needs to take place” says CEPI Director General Sylvain Lhôte


CEPI recognises that the new recycling targets are ambitious while providing new opportunities in terms of improving quality.


“For an industry where over half of our feedstock comes from paper for recycling, the Parliament’s approach means greater use of raw materials whilst putting the emphasis on quality” says CEPI Raw Materials Director Ulrich Leberle


The vote to encourage the use of bio-based packaging also demonstrates the importance of a Circular Economy that builds upon Europe’s wealth of renewable resources while accelerating the transition towards a low-carbon economy.


Finally the continued assertion of the separate collection of paper is viewed by the European paper and board industry as a means to bridge ambitious targets with higher quality recycling.


CEPI together with other partners in the European paper value chain will shortly publish its updated European Declaration on Paper Recycling where it addresses its commitment to the new targets.


The Circular Economy is one of the core elements necessary to achieving industry transformation in Europe as outlined in our ‘Investment Roadmap’ towards a low-carbon bioeconomy. Check out our alignment matrix for the full picture.


For more information, please contact Ulrich Leberle at u.leberle@cepi.org or by phone at (+32) 2 627 49 23
For press related enquiries, please contact Ben Kennard at b.kennard@cepi.org or by phone at (+32) 487 39 21 82
 

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09 Mar.2017 ,

Waste Framework Directive: European material industries renew call for measurement of real recycling rates

Europe‘s metals, steel and paper industries renew their call for a harmonised method to measure Member State recycling rates at input into the 'final recycling process'. The full document can be consulted via the link below.
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24 Jan.2017 ,

ENVI committee vote: one step closer towards a truly circular economy in and for Europe

The Confederation of European Paper Industries (CEPI) welcomes today’s vote in Environment Committee (ENVI) strengthening the foundation of a truly circular economy in Europe.
MEPs are now one step closer to building a truly circular economy” says Sylvain Lhôte, CEPI Director General. “The package needs to be kept on the right track in order to deliver the circular economy in and for Europe".


CEPI welcomes ENVI’s call to measure real recycling rates at the input to the final recycling process. To truly drive circularity in Europe, it is essential that material is only considered recycled once it enters the final production process and is actually reprocessed.


CEPI also supports the ENVI’s call for quality standards and traceability in the paper recycling chain that will enhance targeted investments and serve the efficient functioning of the secondary raw material market in Europe.


The reinforcement of separate collection will also drive quality recycling and boost circularity of Europe’s economy. In the past, authorities have used a loophole in the separate collection obligation to collect paper in co-mingled streams, undermining high quality recycling. CEPI is therefore concerned that the proposal to exempt scarcely populated areas from this obligation may unnecessarily open up a gap.


CEPI will further assess the extremely high gap between recycling targets of competing packaging materials, envisioned by MEPs.


Finally, CEPI is also encouraged by ENVI’s call on Member States to promote the use of bio-based recyclable packaging. “Leveraging on nature’s cycles for the circular economy is a welcome complement to the ambition of the Commission’s proposal” says Ulrich Leberle, CEPI Raw Materials Director.
 

For more information, please contact Ulrich Leberle at u.leberle@cepi.org or by phone at (+32) 2 62749 23


For press related enquiries please contact Ben Kennard at b.kennard@cepi.or by phone at (+32) 487 39 21 82
 

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