EU: European Commission publishes first-ever plastics strategy, Feb 9, 2018

The EU Commission has developed and published a plastics strategy designed to do more for the circular economy and truly address the 3 Rs: Reuse, Repair, and Recycling.  The new strategy will supposedly include design, which is one of the most challenging aspects in complex and very complex articles.

This article By Dr. Alex Martin of RINA Consulting gives more detail:

The European Commission has developed and published a wide-ranging strategy pertaining to plastics that seeks to curb the environmental pollution that arises from the material’s manufacture, use and, most prominently, disposal. In sum, the strategy seeks to lay the foundations for what the European Commission calls the “new plastics economy” in which the design and production of plastics and plastic products “fully respect reuse, repair and recycling needs”; in other words the strategy is about the role of plastics in transitioning towards a more circular economy. An overarching aim is that, by 2030, all plastic packaging supplied in the EU is to be recyclable.

Context 

The strategy begins by contextualizing the challenges posed by plastics. These are said to span: 

  • A twentyfold increase in the global production of plastics over the last 50 years; 
  • Little change in the low reuse and recycling rates that exist for plastics at end of life; 
  • Corresponding to the above, high rates of landfilling and incineration that have yet to dip and remain a preferred disposal route for plastics waste; 
  • Demand for recycled plastics only accounting to a small percentage of the overall plastics demand in Europe (circa 6%); 
  • The attribution of plastics production and waste plastics incineration to the generation, globally, of approximately 400 million tonnes of carbon dioxide per year. 

 Moreover, the issue of marine pollution is of particular note. As the strategy explains: “very large quantities of plastic waste leak into the environment from sources on both land and at sea, generating significant economic and environmental damage… It is estimated that plastic accounts for over 80% of marine litter.” The strategy also gives a European dimension to this, asserting that, in the EU, 150,000-500,000 tonnes of plastic waste enter the oceans every year. While this might be a relatively small proportion of global marine litter, it is problematic as it can end up in especially vulnerable marine areas like the Mediterranean Sea and parts of the Arctic Ocean. This can have an economic impact; the strategy states that the cost of litter to EU fisheries is about 1% of total revenues from catches by the entire EU fleet.

Focus on three plastics types 

The strategy stresses the need to tackle environmental pollution that arises from three particular types of plastics: “single-use”, plastics with biodegradable properties, and microplastics. Single-use plastics span the likes of small packaging, bags, disposable cups, lids, straws and cutlery. In these instances, plastic is widely used due to its lightness, low cost and practical features. Plastics with biodegradable properties are a potential problem as their classification come be something of a misnomer; generally they degrade under specific conditions that may not always be easy to find in the natural environment and might not be apparent to those using or consuming the materials. Microplastics refers to tiny fragments of plastic below 5mm in size. They can enter the seas directly, or else occur from the fragmentation of large pieces of plastic waste over time.

Key measures 

The strategy presents various measures, with the following a summary account of these: 

  • Promotion of design for recyclability. This is seen to be a way to incentivize producers of plastic articles (that might include items of electrical and electronic equipment) and packaging to consider, far more thoroughly than is common today, recycling or reuse when they design their products. Plastics are made from a range of polymers and are highly customized, with specific additives to meet each manufacturer’s functional and/or aesthetic requirements. The diversity can complicate the recycling process, make it more costly, and affect the quality and value of recycled plastic. Hence, the European Commission believes change in product design to be one of the keys to improving recycling levels. For businesses involved in the manufacture, import and/or distribution of electrical and electronic equipment in the EU, this may well mean that ecodesign legislation comes to focus upon plastics usage and recyclability in the years ahead. What is additionally of note is the referencing, in the strategy, to revision of the EU Packaging and Packaging Waste Directive, something that is being set up as the main legal instrument for effecting the required changes to bring about the “all plastic packaging to be recyclable from 2030 onwards” target. Any revision will likely look again at the essential requirements of the Directive, which address recyclability as well as issues like use of noxious substances. It is interesting that the harmonized standards that were created to help manufacturers achieve these requirements have been barely used and are by no means on a par with the harmonized standards used for demonstrating product safety under, for example the Low Voltage Directive. 
  • Boost demand for recycled plastics. This measure is intent upon developing a European market for recycled plastics as well as developing quality standards for sorted plastic waste and recycled plastics. A pledge is made that, by 2025, 10 million tonnes of recycled plastics are to find their way into new products. 
  • Better and more harmonized separate collection and sorting. This measure is framed to be implemented via (a) new guidance on separate collection and sorting of waste, and (b) better implementation of existing obligations on separate collection of plastics. 
  • Generate investment while also harnessing global action (the latter spans global collection and recycling streams, international standards, and certification schemes for recycled plastics). 
  • Introducing specific legislative initiatives pertaining to single-use plastics, plastics with biodegradable properties, and microplastics. The thinking here spans new Extended Producer Responsibility legislation; a clearer regulatory regime for plastics with biodegradable properties that gives emphasis to labelling and better instruction pertaining to the conditions under which such plastics do/do not degrade; and further examination of the instances when microplastics are intentionally added to product categories, the risks, and, potentially, restrictions with the European Chemicals Agency already tasked to perform a restriction proposal that would also have oxo-degradable plastics in its scope (such plastics are designed to degrade into particles and have uses as agricultural films, rubbish bags and food packaging). 

Outlook 

Publication of the strategy appears to have generated a mixed response from stakeholder groups, with several prominent trade and industry associations supportive but a number of environmental non-governmental organizations pushing for more commitments. For the electronics and engineered goods sectors, the likely impact of the strategy will not be now but in revision of the Packaging and Packaging Waste Directive (long overdue since it has not been significantly overhauled in the 24 years since it was first adopted), furtherance of ecodesign requirements, and, potentially, new restrictions on particular types of plastics – most likely through additional entries to REACH Annex XVII. In the meantime, we have 12 years to wait before we know whether the EU’s first-ever plastics strategy proved a success. If, come 2030, all plastic packaging in use in the EU is actually recyclable then it will have been. At the moment, that feels like something of a tall order to achieve. The vision is, however, laudable and certainly a goal to shoot for.