Current E.U. regulatory developments for sustainability affecting the adhesive tape value chain

The second presentation of Afera’s first Session if its digital 63rd Annual Conference addressed E.U. regulation—most appropriately, the Circular Economy Action Plan (CEAP), which was created with a “sustainable vision for the future of Europe”. Paulo Da Silva Lemos, policy officer for sustainable products and plastics at DG Environment at the European Commission (E.C.), updated the adhesive tape industry on the E.U. Plastics Strategy, Chemicals Strategy for Sustainability, European Green Deal, and Product Development Footprints within the context of the CEAP. Mr. Lemos has been working for the E.C. for the last 4 years on the Plastics Strategy, specifically on Single-Use Plastics (SUPs) and Ecodesign, including microplastics and digital in the Circular Economy (particularly the question of product passports).

Circular Economy Action Plan (CEAP) and E.U. Plastics Strategy

The concept for plastic, which was considered a priority, was expressed in the first CEAP from the E.C. in 2015. Preceded by long consultations with stakeholders and seminars, a Plastics Strategy was delivered by industry NGOs in 2018, based on 4 axes:

  1. Improve the economics of quality of plastics recycling: Despite being everywhere, they are trying to see why plastics are some of the least recycled materials in our economy. “On a global level, only 6% of products contain recycled content,” Mr. Lemos said. “Even in Europe, the share is between 6% and 10%, meaning that there is a lot of room for incorporating more recycled plastics into products.” Along these lines, in the E.U. market, all packaging has to be reusable or recyclable by 2030.
  2. Curb plastic waste and littering (3 areas): The European Chemicals Agency (ECHA) is working on restricting microplastics intentionally added to products such as cosmetics, paints and detergents. The Port Reception Facility Directive ensures that all E.U. ports have adequate facilities to receive waste generated in ships. Lastly, in May 2019 the E.U. approved a pioneer legislation to curb SUPs. The Directive aims to prevent and tackle marine litter by, among other things, phasing out unnecessary single-use plastics, introducing economic incentives to reduce consumption and transition to reusable systems, and establishing high collection rates and extended producer responsibility schemes (EPR).
  3. Drive investments and innovation towards circular solutions: The E.U. will provide for research, innovation and funding for bringing new plastics solutions to the market, including alternative feedstocks that are bio-based and biodegradable.
  4. Harness global action: Mr. Lemos said that Europe cannot solve the problem of plastic pollution alone, and at the same time, many countries around the globe are currently working on their own conservation strategies, including their own legislation on SUPs. Discussions on a global treaty on plastics are also underway.

“It is important to note that the SUP Directive is not a one-size fits all piece of legislation,” explained Mr. Lemos. “People may think we are banning all SUPs, but it is not true. We are only banning those which already have alternatives on the market.” Articles such as single-use plastic cutlery, cotton buds, straws and stirrers will be banned in the E.U. by 2021.

Current issues and actions
Importantly, the CEAP foresees that we might face mandatory requirements for plastics for packaging, construction materials and vehicles.

Much of the CEAP is implementing the measures of the European Green Deal (EGD), which describes a sustainable vision for the future of Europe. The E.U. wants to work with consumers and promote global efforts toward a circular economy.

35 actions relate to the lifecycle of products within key value chains, like plastics, textiles, packaging, batteries, automobiles and electronics. There will be mandatory requirements for recycled content, specifically concerning the intentional and unintentional release microplastics, e.g. relating to textiles, tires and pellets. The E.C. is launching a study to determine what kinds of measures should be taken and legislation proposed.

Of the many issues they are discussing concerning the implementation of the SUP Directive, one of the most complex is the definition of plastics and SUP. This will be announced soon. The E.C. is also discussing the issue of bio-based and biodegradable plastics, which are considered to be the same as plastics under the SUP Directive. “The Plastics Strategy is not against plastics—just single-use,” Mr. Lemos stressed. “The E.C. thinks that plastics have a role in the economy, such as in transport—cars, planes, even boats, which are made of plastic. They reduce weight and increase durability, and that is not a bad thing.”

What does the Plastics Strategy mean for the tape industry?
“As I said, there are uses for plastics that need to continue, and the classes of use of the products of the tape industry will be needed,” commented Mr. Lemos. “Mainly in the question of films, we must see how we can promote recycled content—and its collection—and reduce the quantity of use. I think there will be a function and an incentive for this.”

What are the main challenges that the CEAP creates for manufacturers?
“One of the main, flagship actions of the CEAP involves the product initiative, which is to try to put products on the European market that are more durable and usable,” Mr. Lemos remarked. “This is a challenge for all products.” He added that traceability of product contents, i.e. the elements they contain, such as chemicals, and whether they are recyclable, will be a big issue.

Other initiatives within the CEAP have to do with consumer protection. The E.C. aims to create legislation that requires companies to use a standardised method to demonstrate green claims they make about their products put on the E.U. market. There is the Product Environmental Footprint (PEF), which will also be related to E.U. Ecolabel.

Waste Framework Directive (WFD)

Within the WFD, which was amended in 2018, the E.U. has an ambitious target for packaging recycling of 55% by 2030. The Plastics Strategy has an annex of 48 actions, and there are many studies in development on how to implement these.

Circular Plastics Alliance (CPA)
One of the outcomes of the Plastics Strategy—with the launching of a pledging campaign to increase the recycled content in plastic products that fell short—was the creation of the Circular Plastics Alliance. In striving to overcome the obstacles to achieve more recycled content, the CPA aims to boost the E.U. market for recycled plastics to 10 million tonnes by 2025. The Alliance covers the full plastics value chains and includes over 175 organisations representing industry, academia and public authorities. New stakeholders can join the alliance by signing its declaration.

Plastic-based own resource

“Getting the economic stress right in the framework of the E.U. budget,” Mr. Lemos said, “we are still in ongoing discussions about a plastics own resource, which, under the Packaging and Packaging Waste Directive, can contribute to reduce pollution from plastic packaging waste.” An Own Resource which is based on a national contribution (not a tax) proportional to the quantity of plastic packaging waste that is not recycled in each Member State will provide an incentive to reduce the consumption of single-use plastics, foster recycling and boost the circular economy. At the same time, MSs will be free to take the most suitable measures to achieve those goals, in line with the principle of subsidiarity.

In July 2020, the European Council established a correction mechanism to take account of the impact of the Own Resource contribution on lower-income MSs, i.e. MSs that had a GNI per capita below the E.U. average in 2017. Negotiations are ongoing.

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