# EUR-Lex - 52013DC0123 - EN

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# 52013DC0123

**GREEN PAPER On a European Strategy on Plastic Waste in the Environment /* COM/2013/0123 final */**

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TABLE OF CONTENTS

GREEN PAPER On a European Strategy on Plastic
Waste in the Environment.............................. 2

1........... Plastic waste, description of a
growing problem............................................................... 3

2........... Regulation addressing plastic
waste in Europe.................................................................. 5

3........... Plastic waste management and
resource efficiency........................................................... 7

4........... The international dimension............................................................................................. 8

5........... Policy options for improving
management of plastic waste in Europe................................ 9

5.1........ Application of the waste
hierarchy to plastic waste management....................................... 9

5.2........ Achievement of targets, plastic
recycling and voluntary initiatives.................................... 10

5.3........ Targeting consumer behaviour....................................................................................... 11

5.4........ Towards more sustainable plastics................................................................................. 12

5.5........ Durability of plastics and
plastic products...................................................................... 13

5.6........ Promotion of biodegradable
plastics and bio-based plastics........................................... 15

5.7........ EU initiatives dealing with
marine litter including plastic waste......................................... 17

5.8........ International action........................................................................................................ 18

GREEN PAPER

On a European
Strategy on Plastic Waste in the Environment

The purpose of this
Green Paper is to launch a broad reflection on possible responses to the public
policy challenges posed by plastic waste which are at present not specifically
addressed in EU waste legislation. The follow-up to the Green Paper will be an
integral part of the wider review of the waste legislation that will be
completed in 2014. This review will look at the existing targets for waste
recovery and landfill as well as an ex-post evaluation of five directives
covering various waste streams.

The inherent
characteristics of plastic create specific challenges for waste management. Plastic
is relatively cheap and versatile with many industrial applications, leading to
exponential growth over the past century; a trend that is set to continue.
Secondly, plastic is a very durable material which outlives the products made
of it. As a result, the generation of plastic waste is growing worldwide. The
durability of plastic also means that uncontrolled disposal is problematic as
plastic can persist in the environment for a very long time. The need to
continue efforts to reduce the incidence and impacts of plastic in the marine
environment was particularly highlighted at the Rio+20 Summit.

There are not only
challenges, but also opportunities arising from better management of plastic waste.
Although plastic is a fully recyclable material, only a small fraction of
plastic waste is at present recycled. Enhanced recycling would contribute to
the aims of the Roadmap to a Resource Efficient Europe adopted in 2011[1] and help to reduce greenhouse gas emissions and
imports of raw materials and fossil fuels. Appropriately designed measures to
recycle plastic can also improve competitiveness and create new economic
activities and jobs.

This Green Paper will
help reassess the environmental and human health risk of plastic in products
when they become waste, addressing their environmentally sound design, both
functionally and chemically, and open a reflection process on how to tackle the
problem of uncontrolled disposal of plastic waste and marine litter. It should
also help move forward the reflection on internalization of life-cycle impacts,
from raw material extraction to the end of life phase, into the costs of
plastic products.

The Commission launches this consultation in order to
collect the facts, assess the stakes and to gather the views of all interested
stakeholders on a phenomenon that has many dimensions.

Comments are invited on all or some aspects of
the document. Specific questions are listed after each section on policy
options.

Member States, the European Parliament, the
European Economic and Social Committee and all other interested parties are
invited to submit their views on the suggestions set out in this Green Paper.
Contributions should be sent to the following address to reach the Commission
by 7 June 2013 at the latest: http://ec.europa.eu/environment/consultations/plastic_waste_en.htm.

Please note that the majority of references in this text
based their data on official statistics from EUROSTAT and the EEA.

1.           Plastic
waste, description of a growing problem

Plastic
production

Plastic is a relatively
new material which went into industrial production only in 1907[2]. It now pervades industrial and consumer goods,
and modern life is unthinkable without it. At the same
time the characteristics that make plastic so useful, such as its durability,
light weight and low cost, also make its disposal problematic[3].

Global plastics
production grew from 1.5 million tonnes (Mt) per annum in 1950 to 245 Mt in
2008, with 60 Mt[4] in Europe alone. Production during the last 10
years equalled production during the whole of the 20th century
combined[5]. It is estimated (under a business as usual
scenario) that 66.5 Mt[6] of plastic will be placed on the EU market in
2020 and global plastic production could triple by 2050[7].

Plastic waste

In the European Union (EU
27), it is estimated that around 25 Mt of plastic waste was generated in 2008.
Of this 12.1 Mt (48.7%) was landfilled while 12.8 Mt (51.3%) went to recovery[8], and only 5.3 Mt (21.3%) was recycled[9]. While a projection to 2015 assumes an overall
increase of 30 % in the level of mechanical recycling (from 5.3 Mt to 6.9 Mt),
landfilling and incineration with energy recovery[10] are expected to
remain the predominant waste management pathways[11].

Plastic production is going
up with GDP[12] and an associated overall increase in the
generation of plastic waste between 2008 and 2015 of 5.7 Mt (23%)[13]. This is largely driven by a 24% rise in the
packaging sector and is part of an unbroken trend of increasing plastic waste
in Europe. In the absence of improved product design and improved waste
management measures, plastic waste will increase in the EU as production
increases.

Trends observed in the
EU are likely to be stronger in fast-growing economies like India, China, Brazil and Indonesia, but also in developing countries. The world's population is
forecast to grow by 790 million every decade and may reach over 9 billion by
2050 with a new middle class of around 2 billion[14]. This is likely to increase demand for plastic and the
amount of plastic waste worldwide.

The plastics
industry

The plastic industry
plays an important economic role in Europe, employing in total around 1.45
million people in over 59 000 companies and generating turnover in the region
of around € 300 billion per year. The producing sector provides 167 000 and the
converters 1.23 million jobs (EU 27, 2005-2011, ESTAT) mostly in SMEs[15].

On the waste management
side, collection and sorting of waste from electric and electronic equipment
(WEEE) and plastics provide the greatest job opportunities, with a total of 40
and 15.6 jobs respectively being created per 1 000 tonnes of material
processed. Plastic recycling alone has the potential to create 162 018 jobs in
the EU 27 if the recycling rate increases up to a level of 70% by 2020[16].

Plastic is mostly used
in packaging as a low-cost one-way product that is most often not reusable or
not foreseen for reuse. The plastics converting market is dominated by plastic
packaging (40.1%) followed by the building and construction sector (20.4%). The
Plastics industry expects a long-term growth of around 4% globally, well ahead
of expected global GDP growth[17]. Europe is still a net exporter of plastic
products with a value of €13 billion in 2009, but Chinese production has
reached similar levels since 2008[18].

Fate in the
environment

Once in the environment
- particularly in the marine environment - plastic waste can persist for
hundreds of years[19]. Harm to the coastal and marine environment and
to aquatic life follows from the 10 million tonnes of litter, mostly plastic,
which end up in the world's oceans and seas annually, turning them into the
world's biggest plastic dump. Waste patches in the Atlantic and the Pacific
oceans are estimated to be in the order of 100 Mt, about 80% of which is
plastic. Plastic debris causes sea species to suffer from entanglement or
ingestion[20]. "Ghost fishing"[21] through derelict
plastic fishing gear causes high economic cost and substantial environmental
harm. Invasive species use plastic debris to travel long distances in oceans.
Most plastic debris eventually comes to rest on the seabed[22].

Plastic is not inert.
Conventional plastic contains a large number, and sometimes a large proportion,
of chemical additives which can be endocrine disruptors, carcinogenic or
provoke other toxic reactions and can, in principle, migrate into the
environment, though in small quantities[23]. Persistent organic pollutants (POPs), such as pesticides
like DDT and polychlorinated biphenyls (PCBs)[24], can attach themselves from the surrounding
water to plastic fragments which can be harmful[25] and enter the food chain via marine fauna which ingest the
plastics (Trojan horse effect)[26]. These POPs do not break down
naturally very easily but accumulate in body tissue, potentially having
carcinogenic, mutagenic and other health effects[27].

Small and fine particles
(so called micro plastics), result from decades of photo degradation and
mechanical abrasion and are of particular concern. They are ubiquitous and
reach even the most remote areas[28] with a concentration in water sometimes higher than that
of plankton. These micro plastics, and the chemical additives they contain, if ingested
in large quantities by marine fauna may have a high potential for contaminating
the food chain through predator-prey interaction.

Poor waste management on land,
in particular only marginal plastic waste recovery rates, aggravate the problem
of plastic marine pollution which is one of the most important emerging global environmental
issues[29]. Experts judge that around 80% of marine
plastic waste is coming from land[30].

Major land
based sources of plastic marine litter appear to be: storm water discharges,
sewer overflows, tourism-related litter, illegal dumping[31], industrial activities, improper transport, consumer
cosmetic products, synthetic sandblasting media or polyester and acrylic fibres
from washing clothes[32]. Plastic pellets can be found in most of the
world’s oceans, even in non-industrialised areas such as the Southwest Pacific[33].

2.           Regulation
addressing plastic waste in Europe

Waste legislation

Plastic waste is not
specifically addressed by EU legislation despite its growing environmental
impact. Only the Packaging Directive 94/62/EC has a specific recycling target for
plastic packaging. The Framework Directive on waste 2008/98/EC sets a general
recycling target for household waste which covers, among other materials,
plastic waste. The Waste Framework Directive is relevant in some other
respects. For instance, the Directive establishes extended producer
responsibility as a key principle in waste management. It also sets out the
waste hierarchy giving precedence to waste prevention, reuse and recycling over
recovery, including energy recovery, and disposal. There persists, however, a
sharp contrast between legislative requirements and actual waste management
practice.

The Waste Framework Directive
invites the Commission to review its targets and to consider additional targets
for other waste streams if appropriate. In addition, the Commission has also
been asked to review the targets in the Landfill Directive for the reduction of
landfilling of biodegradable waste as well as the recycling and recovery
targets in the Packaging and Packaging Waste Directive 94/62/EC for several
categories of packaging waste.

The Commission has
decided that it will conduct a wide ranging review of the existing waste
legislation and the various targets which will be completed in 2014. This
review also involves an ex-post evaluation ("fitness check") of five
existing waste stream Directives[34]
that will assess effectiveness, efficiency, coherence and relevance. The
follow-up to this Green Paper will form an integral part of this wide ranging
review of the waste legislation.

Chemicals
legislation

The REACH Regulation
1907/2006/EC is of some relevance for plastics recycling. While the Regulation
contains specific provisions[35] that facilitate the placing on the market of
recycled materials, in some cases, the use of additives in plastics may hinder
compliance within REACH if the additives are not allowed in new products. Some
REACH processes are also relevant for improving the resource efficiency of
plastics, including its recyclability, and the risks associated with plastic in
the environment. In particular, restrictions remain key tools to reduce the
hazards associated with certain plastics. Authorisation could be used to
achieve the progressive substitution of those plastic additives posing the
highest concern in EU-produced plastics.

The Classiﬁcation,
Labelling and Packaging Regulation 1272/2008/EC (CLP) allows identification of
hazardous chemicals and informs users about these hazards through standard
symbols and phrases on the packaging labels and through safety data sheets.
This information is crucial for stimulating the production of less hazardous
plastics in Europe and is, therefore, crucial for enhanced plastic recycling in
 Europe.

The hazards of plastic
waste in the environment would be significantly lower if existing European
waste legislation was properly implemented. Landfilling remains the predominant
disposal route for plastic waste[36] in many Member States. Moreover, illegal dumping has not
been fully eradicated and many landfills are illegal or
are badly managed[37].
More worrying still are the number of households not covered by any municipal
waste collection system[38];
a situation where plastic waste is under no control increasing the likelihood
of lightweight plastic reaching water bodies and finding its way to the sea.

Implementation of
waste legislation

Compliance with waste legislation can
significantly contribute to fostering economic growth and job creation. A
recent study suggested that full implementation of EU waste legislation could
save €72 billion a year, increase the annual turnover of the EU waste
management and recycling sector by €42 billion and create over 400,000 jobs by
2020[39].

Since plastic waste is categorized
non-hazardous, it can be exported to non-OECD countries following the procedure
of the Waste Shipment Regulation (WSR) and provided the import is not
prohibited by the country of destination. Total
exports of plastic waste from EU Member States increased by a factor of five
between 1999 and 2011. Most exports went to Asia[40].

Insufficient enforcement of the WSR results
in illegal shipment of high quantities of waste outside the EU[41]. One of the most common types
of waste involved is e-waste, rich in plastic. Such exports contribute to
environmental pressures, particularly in countries with poorly developed waste
management systems. Illegal shipments of plastic waste also represent an
important loss of potential resources and lost opportunities for recycling in Europe.

The Commission has recently published a
communication[42]
stressing the need to improve responsiveness at national, regional and local
level for implementation of environmental legislation. This communication
recognises that improvements may be available by upgrading the existing
framework for inspections and surveillance.

3.           Plastic
waste management and resource efficiency

More sustainable patterns
of plastic production and better plastic waste management - particularly higher
recycling rates - offer considerable potential for improving resource
efficiency. At the same time, they would help to reduce imports of raw
materials as well as greenhouse gas emissions. Resource savings can be
significant. Plastic is produced almost exclusively from oil and, at present,
plastic production accounts for approximately 8% of world oil production, of
which 4% as a raw material and 3-4% as energy for manufacturing processes[43].

From a resource
efficiency perspective, it is particularly important to prevent landfilling of
plastic waste. Any landfilling of plastic is an obvious waste of resources
which should be avoided in favour of recycling, or of energy recovery as the
next best option. However, plastic landfilling rates remain high in several
Member States due to the lack of suitable alternatives and insufficient use of
economic instruments which have been shown to be effective.

The need to save natural
resources and to enhance resource efficiency could be a driver for increasing
sustainability in plastic production. Ideally all plastic products should be
fully recyclable and at reasonable costs.

Recycling already starts
in the product design phase. Therefore, product design has the potential to
become one of the essential tools to implement the recently adopted Resource
Efficiency Roadmap[44].

Low recycling rates and
exports of plastic waste for reprocessing in third countries are an important
loss of non-renewable resources, and of jobs, for Europe. The potential for
plastic recycling is still significantly under-utilized. For example, the Irish
Marked Development Programme for waste resources identified (inter alia)
plastics as offering the greatest potential for recycling activity in Ireland[45]. In Germany, with 60% of plastic waste
presently being incinerated, there is also wide scope to increase the rate of
plastic recycling[46].

In a recent study,
plastic recycling and material savings were found as having the highest
contribution to impact savings in climate change, abiotic resource depletion
and freshwater aquatic ecotoxicity. Greater material productivity in plastics
would deliver the highest contribution to reduced environmental impacts. In
relation to greenhouse gases, plastic showed the highest potential for
reductions, together with biomass and metals[47].

4.           The
international dimension

Plastic is a major source
of marine pollution globally. Plastic waste travels across borders and
international action on marine plastic litter is necessary to tackle it
effectively. This was clearly acknowledged at the Rio+20 United Nation
Conference on Sustainable Development in June 2012.

Recent UN resolutions,
global environmental agreements and decisions of international agencies have
raised international attention to the problem. The 5th international
Marine Debris Conference in Honolulu, co-organised by UNEP and the NOAA[48] in March 2011, could be a first step towards a
global strategy and action plans on plastic marine pollution. It identified
poorly developed waste management systems in large parts of the world as an
overriding issue because they are the major factor affecting the transfer of
land based plastic litter into the marine environment. Capacity building in
waste management is an area where more efforts are needed[49].

The Stockholm Convention
on Persistent Organic Pollutants (POPs) is relevant for plastic in that it
restricts the use of commercial flame retardants such as penta and octa
bromodiphenylether (BDE). The Convention also prohibits the recycling of
materials containing POPs such as some brominated flame retardants.

Regional sea Conventions
such as OSPAR, Barcelona, Helcom, and the Black Sea can also play a role in
tackling the problem of marine litter. For example, the Conference of the
Parties of the Barcelona Convention adopted in 2012 a Policy Document and an
associated Strategic Framework for Marine Litter management. Action under
regional sea agreements would also help Member States to implement better their
obligations under the MSFD to achieve or maintain good environmental status in
the marine environment by 2020.

5.           Policy
options for improving management of plastic waste in Europe

The Directive on Waste
2008/98/EC already paved the way for a new thinking in waste management. It
establishes extended producer responsibility (Article 8) and describes strong
and innovative drivers for sustainable production taking into account the full
life cycle of products. Member States are encouraged to take legislative or
non-legislative measures in order to strengthen re-use and the prevention,
recycling and other recovery operations of waste. Producers should be
encouraged to engage in setting up acceptance points for end-of-life products.
They may engage in waste management and take financial responsibility for that
activity. They shall make information publicly available on the extent to which
a product is re-usable and recyclable. Appropriate measures shall be taken to
encourage the design of products in order to reduce their environmental impact
and the generation of waste during production and subsequent use. Such measures
may encourage development, production and marketing of products that are fit
for multiple use, technically durable and fit for environmentally-safe end-of-life
management.

The policy options
presented in this section follow a life-cycle approach starting with plastic
design. It is indeed clear that design of plastics and plastic products play a
key role for sustainability and determine further stages in the life-cycle of
plastics. For example, plastic recycling depends to a large extent on the
composition of plastic materials and on the design of plastic products.

5.1.        Application
of the waste hierarchy to plastic waste management

As a matter of principle,
recycling of plastic waste is a better option than energy recovery or
landfilling. Although under a life cycle perspective not all plastic waste may
be suitable for recycling, there are no technical reasons why plastic should go
to landfill rather than being recycled or exploited for energy recovery. This
could be done through a gradual phasing out or a ban on landfilling plastic
waste through an amendment to the Landfill Directive 1999/31/EC. Both options
are already used for bio waste (phasing out) and tyres, liquids, explosives
(ban).

Member States with
landfill rates below 5%, such as Germany, the Netherlands, Sweden, Denmark, Belgium, and Austria achieve between 80% and 100% plastic waste recovery, including
recycling. All of these countries have enacted measures leading effectively to
a diversion of combustible waste from landfills, equivalent to a landfill ban.
The majority of less performing Member States apply no such measures and base
acceptance of waste in landfills on landfill taxes/fees sometimes as low as
only 7€ per tonne.

However, some Member
States with high recovery rates and landfill bans still have modest plastic
recycling rates of around 28% on average[50]. The present ratio between plastic recycling and plastic
waste energy recovery could be improved via measures on separate collection,
sorting and material recovery. A landfill ban generating an automatic
preponderance of energy recovery over recycling would not be in line with the
waste hierarchy. It may be useful to reflect on how economic instruments could
be used to steer the waste flow through the waste hierarchy, avoiding a
"vacuum cleaner effect" in favour of waste to energy.

Nearly 50% on average of
all plastic in the EU goes to landfill, most of it packaging. The widespread
absence of separate waste collection and the lack of other alternatives in many
Member States help explain the high disposal rate of plastic in landfills[51]. Landfilled plastic contributes nothing to
material recovery and energy recovery and is therefore highly resource
inefficient. A study on European waste generation projections to 2035 assessed
the introduction of strong policies to extend recycling, and found plastic to
have the largest potential for reducing the environmental impacts of waste[52].

Questions:

(1)
Can plastic be appropriately dealt with
in the existing legislative framework for waste management or does the existing
legislation need to be adapted?

(2)
How can measures to promote greater
recycling of plastic best be designed so as to ensure positive impacts for
enhanced competitiveness and growth?

(3)
Would full and effective implementation
of the waste treatment requirements in the existing landfill legislation reduce
sufficiently current landfilling of plastic waste?

(4)
What measures would be appropriate and
effective to promote plastic re-use and recovery over landfilling? Would a
landfill ban for plastic be a proportionate solution or would an increase of
landfill taxes and the introduction of diversion targets be sufficient?

(5)
What further measures might be
appropriate to move plastic waste recovery higher up the waste hierarchy
thereby decreasing energy recovery in favour of mechanical recycling? Would a
tax for energy recovery be a useful measure?

(6)
Should separate door step collection of
all plastic waste combined with pay-as-you-throw schemes for residual waste be
promoted in Europe, or even be made mandatory?

5.2.        Achievement
of targets, plastic recycling and voluntary initiatives

Targets and exports of plastic waste

Approximately 16
Mt/year of plastic waste could be recycled if all current recycling targets
were met for municipal solid waste, construction and demolition (C&D)
waste, end-of-life vehicles (ELV), Packaging, Battery and WEEE. This figure
suggests that there is approximately another 9 Mt of plastic waste (out of the
total 24.9 Mt) not specifically covered by mandatory reuse/recovery targets;
mainly plastic in furniture and equipment other than EEE[53]. The Packaging Directive is the only EU legal instrument
establishing a specific recycling target for plastic packaging. It could be
considered to set further specific plastic waste recycling targets beyond
plastic packaging waste.

Recycling targets in European waste legislation may also
have boosted the supply of recyclable waste, as the EEA concludes[54]. This, together with high prices paid by the
booming Asian economy let plastic waste exports to Asia exponentially increase
during the last 10 years. While this is not objectionable in itself, it may be
argued that recycling plastic waste in Europe is, in environmental terms, a better
option and that plastic waste exported to non-EU countries should be recycled
in facilities complying with standards equivalent to those applied in the EU.
Export of plastic waste ending up in substandard facilities or being disposed
could contravene the environmental objective of resource conservation spelled
out in the WFD.

(7)
Are specific plastic waste recycling
targets necessary in order to increase plastic waste recycling? What other type
of measures could be introduced?

(8)
Is it necessary to introduce measures to
avoid substandard recycling or dumping of recyclable plastic waste exported to
third countries?

Voluntary
Action

Voluntary action could
also help significantly ease the problem of plastic waste in the environment
and contribute to minimising resource use. An obvious low hanging fruit would
be plastic packaging waste, contributing to 63% of the total plastic waste
generated. Setting up "sustainable packaging guidelines"
to which producers and retailers would commit could be a step in the right
direction. Such an initiative could comprise setting parameters for measuring
sustainability of packaging, best available techniques for plastic packaging
producers, an independent labelling system to measure consumers' individual
footprints, information campaigns raising consumer awareness for plastic
hazards and plastic disposal and organising separate collection. Existing
initiatives such as the European Retail Forum, EUROPEN, the PET bottle platform
and Vinyl 2010+ could bundle their initiatives towards more sustainable plastic
production and disposal. Similar schemes could be set up for collection and
recovery of non-packaging agricultural plastics which are easy to recycle due
to their uniform chemical composition. The UK "Agricultural Waste
Plastics Collection and Recovery Programme" could serve as
an example[55]. Similar initiatives could concentrate on WEEE
and ELV plastic, which account for 10% of European plastic waste. Finally,
producers' investment in improved product design will become a more important
driver to reduce plastic waste. Article 8 of the WFD points in that direction
and early voluntary adaptation might lead to better results than change imposed
by legislation.

(9)
Would further voluntary action, in
particular by producers and retailers, be a suitable and effective instrument
for achieving better resource use in the life cycle of plastic products?

5.3.        Targeting
consumer behaviour

Giving plastic a
value

Plastic is perceived as a
material with no value of its own. This perception favours littering. However,
all plastics are high tech and complex materials that consumers should value in
order to incentivise re-use and recycling.

Some plastic products
(e.g. PET beverage bottles) can be made subject to a deposit and return system,
which would motivate the holder of the end-of-life product to recuperate his
deposit by bringing the object back to a designated collection point whilst
avoiding restrictions of competition or monopolistic structures. For certain
plastic items, new entrepreneurial models such as lease systems, where the
producer remains the owner of the product, could be a useful tool to ensure
that the item is collected and treated in an environmentally sound manner.

Questions:

(10)
Is there scope to develop deposit and
return or lease systems for specific categories of plastic products? If so, how
could negative impacts on competition be avoided?

Empowering
consumers to know what they buy

Informed consumers can play a decisive role
in promoting more sustainable production patterns for plastic and plastic
products that also improve resource efficiency. In targeting consumer
behaviour, clear, simple and concise information could be instrumental for informing consumers of the plastic
content of a product and its potentially harmful additives/colours, their
influence on recyclability and necessary precautions for the use of products.

Such information could also include
environmental performance indicators, such as recyclability,
compostability and resource efficiency performance of plastic products. For
certain plastic products information on recycled contents, recyclability and
reparability may also be relevant.

Full consumer product information on the type
of plastic and its recyclability could be provided
beyond existing schemes, in order to enable consumers to make an informed
choice when buying a plastic product. Simple and effective recyclability could
be reflected in the product price and could be used as a marketing strategy.
Information based on the environmental footprint or eco-labels could also be
used to facilitate informed choice in relation to the overall life cycle
performance of the product.

Question:

(11)
What type of information would you
consider necessary to empower consumers to make a direct contribution to
resource efficiency when choosing a plastic product?

5.4.        Towards
more sustainable plastics

Plastic design for
easy and economic cradle-to-cradle recycling[56]

An important element for
achieving more sustainability in plastic production is the design of plastic
itself. While there are relatively few basic plastics (polymers), the multitude
of additives used in plastic production can be a major obstacle for plastic
recycling or lead to more "down-cycling" than cradle-to-cradle
recycling.

Reducing hazardous
substances in plastics would increase their recyclability. Gradual phasing out
of those substances in both new and recycled products would also reduce risks
associated with their use. The Roadmap on a Resource Efficient Europe suggests that
by 2020 all relevant Substances of Very High Concern should be placed on the
REACH Candidate List which would capture relevant plastic additives.

An adequate flow of
information from producers to recyclers is also important. Clear safety data
sheets for plastic pellets used by converters could enhance high quality
recycling. Labelling and information on the chemical content of plastic
delivered to converters, including all additives, could also play a useful
role.

Question:

(12)
Which changes to the chemical design of
plastics could improve their recyclability?

(13)
How could information on the chemical
content of plastics be made available to all actors in the waste recycling
chain?

New challenges
through innovative materials

New risks may arise from
the use of innovative materials such as nano-materials, for example in bottles
made from polyethylene terephthalate (PET)[57] or packaging in general, or providing selective gas penetration in food packaging, or from nano-sensors to detect food spoilage[58].
The EU's approach is to assess the risks of individual nano-materials on a case
by case basis. The assessment of
potential environmental and health risks is, however, difficult due to the
scarcity of environmental and toxicological data. A now existing common
European definition of nano-materials may facilitate more effective generation
and collection of such relevant data[59].

The increasing use of
virgin micro-plastics is also a matter of concern. In some consumer products,
such as scrub creams and shower gels, producers add micro-plastic instead of
natural scrubbing particles. Those particles may end up in the seas as water
management systems are not equipped to hold this material back.

Question:

(14)
How can challenges arising from the use
of micro plastics in products or industrial processes and of nano-particles in
plastics be best addressed?

5.5.        Durability
of plastics and plastic products

Many
challenges in the field of plastic waste management such as increasing volumes
and marine plastic are due to the extreme durability of plastic materials,
which usually outlive the products containing them. Problems are exacerbated
when plastic products are specifically designed for a single use or for a short
life–span, or when their life is deliberately shortened.

Product
design for a longer life, reuse and repair

To ensure sustainability
in production and consumption of plastic goods, and to avoid the loss of
non-renewable natural resources, plastic goods should be designed to maximize
durability. There are several adverse functions making this a difficult goal to
attain, such as planned or technical obsolescence[60], as well as designs that make repair of plastic products
uneconomic or even technically impossible.

Plastic products such as
electric and electronic equipment are often not designed to make their re-use
possible. Because design can just be a marketing tool, even small steps in
technical innovation are often used for marketing an entirely new product
rather than choosing a modular system designed for making replacement of
innovative components cheap and easy. For example it is common to sell an
entirely new plastic laptop when a simple replacement of the CPU chip might be
technically sufficient to update the equipment.

Any design that
deliberately makes plastic products impossible to repair should be avoided[61]. Developing requirements or guidelines for
reusability and reparability of plastic products is an option to be explored.
Some work on the development of methodologies to measure reusability of
products has already started[62]. One solution might be the development of eco-design
rules, setting particular criteria on reusability, durability, reparability and
modular construction, as already envisaged in Art. 9(1) WFD.

(15)
Should product design policy tackle
planned obsolescence of plastic products and aim at enhancing re-use and
modular design in order to minimize plastic waste?

(16)
Could new rules on eco-design be of help
in achieving increased reusability and durability of plastic products?

Single-use and
short-lived plastic products

From a waste prevention
and resource efficiency perspective, it is desirable to take measures to avoid
the proliferation of short-lived and single use disposable products (such as
plastic bags), if based on a life cycle assessment (LCA) and Product
Environmental Footprint (PEF)[63] analysis.

Cheap plastic gadgets,
by-packed to consumer products, fun articles, short life toys and similar
categories of products are broadly available at prices which do not reflect
their full environmental costs including waste management. The same applies to
single-use products such as single-use plastic carrier bags.

Plastic carrier bags are
emblematic of modern consumer society, light, practical, with no value, often
thrown away after single use. Yet the environmental pressure from plastic
carrier bags is considerable. In 2010 there were 95.5 billion plastic carrier
bags (1.42 Mt) placed on the EU market, most of them (92%) are for single use.
More worryingly, plastic bags unnecessarily add to the plastic waste load in
the marine environment, having the same detrimental effect as other plastic
waste. As a striking example, plastic bags accounted for 73% of the waste
collected by trawlers along the Tuscany coast[64]. Subsequent to the public consultation on plastic carrier
bags held in summer 2011, the European Commission is (as a separate initiative)
assessing options to reduce single-use plastic carrier bags.

The development of
market-based instruments on the basis of environmental impact indicators may be
an option to steer production and consumption away from short-lived and single
use disposable plastic products. This would ultimately find its justification
in the polluter pays principle.

More generally, prices
may be distorted and discriminate against sound environmental practice[65]. A system reflecting the true environmental
costs from extraction of raw materials to production, distribution and disposal
would encourage more sustainable production and compensate for market failures.
Green public procurement and financial instruments such as environmental taxes
could also help to improve this situation.

Questions:

(17)
Should market based instruments be
introduced in order to more accurately reflect environmental costs from plastic
production to final disposal?

(18)
How can the waste burden posed by
short-lived and single-use disposable plastic products best be addressed?

5.6.        Promotion
of biodegradable plastics and bio-based plastics

Biodegradable plastics

Biodegradable plastic[66] products are often perceived as a potential
solution to plastic littering and have attracted increasing public attention.
Although it is still a small segment of the market, production of biodegradable
plastics operates today at industrial scale capacity, with a projected increase
in Europe from 0.23 Mt/pa in 2007 to 0.93 Mt/pa in 2011[67].

The term "biodegradable"
itself may be misunderstood by customers. While they might interpret the
labelling "biodegradable" to mean fit for home composting, in
reality, the large majority of biodegradable plastics can only biodegrade under
very specific conditions of constantly high temperature and humidity in
industrial composting installations and are neither fit for home composting nor
do they decompose in reasonable time when littered[68]. A clear distinction between home-compostable and
industrially-compostable plastics may be required, along with consumer
education about proper disposal channels. Confusion could cause consumers to
take insufficient care in their disposal out of a misunderstanding that objects
labelled as biodegradable would decay within short time periods under natural
conditions.

There are also
biodegradability claims that should be scrutinized. For example, fragmentation
of plastic enhanced with an oxidising agent (usually a metal salt) in the
presence of oxygen, heat and UV light results in microscopic plastic fragments
with similar properties as the bulk plastic. Oxo-degradation residues may have
unclear impacts[69]. Oxo-degradable plastics might risk
contributing to the microplastics load reaching the marine environment and
therefore might significantly increase the risk of ingestion by animals[70]. The presence of oxidising agents in the
plastic waste streams may also make plastic recycling more difficult[71]. It should be
assessed whether the use of the term biodegradable is at all permissible in
this case.

Another open question is
the extent to which biodegradable plastic can be a solution to plastic marine
pollution. Decomposition in the marine environment depends on many factors,
such as the type of product, the sufficient presence of relevant micro-organisms,
the water temperature and the density of the product. In some Plastral Fidene
trials, a starch-PCL[72] blend was found to degrade in 20 to 30 weeks in
Australian waters while being able to degrade in 20-30 days in compost[73]. Moreover, many biodegradable plastics may not
degrade in the intestines of marine species and injury is likely to remain an
issue.

There are several
barriers for biodegradable plastics to achieve quick market penetration. Without
further technical progress in terms of their functional properties, they may not
be suitable for some types of packaging applications, such as for fresh food[74]. Existing manufacturing chains, used to
petro-plastics, may need costly adaptation to function with biodegradable
plastics[75]. The exact influence of biodegradable plastic
on aquatic environments, as well as compost toxicity, is yet further to be
investigated[76]. Waste treatment systems already in place are
not yet capable of separating sufficiently biodegradable plastic from
conventional plastic which can jeopardize recycling processes. Technical
adaptation might increase separation costs because more sophisticated equipment
is likely to be required.

As regards composting of
bio degradable plastics, investment into composting facilities providing
sufficient pre-processing and an adequate composting process would be needed.

(19)
What are the applications for which biodegradable
plastics deserve to be promoted, what framework conditions should apply?

(20)
Would it be appropriate to reinforce
existing legal requirements by making a clear distinction between naturally
compostable and technically biodegradable plastics, and should such a
distinction be subject to mandatory information?

(21)
Would the use of oxo-degradable plastic require
any kind of intervention with a view to safeguarding recycling processes, and
if so, on which level?

Bio-based plastics

While the market is still
dominated for over 99% by petroleum-based plastic[77], there is an emerging and growing market for bio-based
plastic produced from renewable resources[78]. Current bio-based plastics are usually made from starch
extracted from maize, rice, sugar cane or potatoes.

The prefix
"bio-based", is clearly defined by the European Committee for
Standardization (CEN)[79].
Yet, consumers need to be fully informed that this relates to the origin of the
resource and not to end of life management. Although the majority of biodegradable
plastics are currently bio-based plastics, biodegradable plastics can also be
made from petroleum based or a combination of petroleum and bio-based
resources. Moreover, some bio-based polymers, such as polyethylene (PE) from
bio-ethanol are not biodegradable. Competition with food production, already
broadly discussed in the context of biofuels, is a problematic and highly
disputed issue for bio-based plastics. A significant increase in bio-based
plastics production to a level comparable to conventional plastics might
negatively impact on the production of food crops used to make bio-based
plastics. This could have a negative impact on developing economies and
economies in transition. A link between the rises in corn prices subsequent to
the rise in ethanol production 2008 in the US has been documented[80]. An increase in land use and raw material
prices might result, as well as a loss of biodiversity through transformation
of idle land and forests into fields, increasing agricultural consumption of
water and fertilizers. Such concerns would not apply to bio-based plastics made
from agricultural waste and food-crops by-products or saltwater algae.

Question:

(22)
How should bio-based plastics be
considered in relation to plastic waste management and resource conservation?
Should the use of bio based plastics be promoted?

5.7.        EU
initiatives dealing with marine litter including plastic waste

The Marine Strategy
Framework Directive (MSFD) 2008/56/EC aims to achieve good environmental
status (GES) for all marine waters by 2020. The Directive identifies marine
litter as one of the factors determining GES for which the "properties and
quantities of marine litter do not cause harm to the coastal and marine
environment." Marine litter includes all types of waste. However, studies
have shown that the majority of waste found in our seas and oceans is plastic.

In 2010 the Commission
outlined criteria for Member States to assess the environmental status of their
seas in the context of MSFD[81]. Several of these criteria relate to marine
litter. A Working Group on marine litter has developed an overview of existing
data and methodologies for the monitoring of marine litter, as required by the
MSFD. It underlined both the seriousness of the issue and the urgent need for
further coordinated research to ensure a common approach to monitoring and
mitigation. The group continues to work on (inter alia) the harmonisation of
monitoring, estimating the costs involved and assessing the harm done by marine
litter[82].

In parallel, the
Commission has started a dialogue with stakeholders (plastic producers,
recyclers, retailers, packing industry, port and shipping authorities, NGO's)
to develop partnerships and voluntary actions to address marine litter.
Furthermore, there are a number of projects and initiatives on-going which aim
at understanding better the sources and impacts of marine litter as well as the
possible solutions. An overview of all initiatives and potential measures that
address this problem is given in a separate Commission Staff Working Document
SWD (2012) 365.

Successful implementation
of waste policy is a key prerequisite to avoid plastic litter entering the
marine environment. There are discussions about setting targets to guide policy
efforts and to monitor their success (e.g. in the final version of the
Ministerial declaration of OSPAR 2010). The upcoming reporting under the MSFD
and the on-going projects should allow development of a baseline for the EU in
2013 which could be used to establish benchmarks, milestones and targets for
policy.

Within some Regional Seas
Conventions, action plans on marine litter are under development. For the Mediterranean, strategy on marine litter was endorsed in February 2012[83]. For the North East Atlantic, next to its
marine action plan, 'Fishing for Litter' will be implemented in more areas of
the Convention. In addition, there are many initiatives at EU level including
policy developments which take increasing account of the marine litter impacts,
such as the revision of the Port Reception Facility Directive (see CSWD for
more complete overview). EU waste policy already provides many provisions
which, if fully implemented, would reduce the marine litter problem
significantly. This Green Paper sets out a number of further policy options
which would help to reduce marine litter. However, there are many other actions
outside the scope of this Green Paper which would need to be taken, such as conducting
behavioural studies for improving the understanding for how to go about raising
consumer awareness.

One such action is
raising awareness amongst consumers, which has been achieved in several Member States, regions and communities by, for example, organisation of beach clean-up
days. Such initiatives are numerous and happen at different levels on different
days, however, there is no EU-level coordination of all the on-going
activities, including these awareness raising events.

Questions:

(23)
What actions other than those described
in this Green Paper could be envisaged to reduce marine litter? Should some
marine litter related actions be coordinated at EU level (e.g. by setting up a
coordinated European Coastal Clean-up Day to raise awareness)?

(24)
In its proposal for a new Environment
Action Programme the Commission suggests that an EU wide quantitative reduction
target for marine litter be established. How can the setting of such a target
provide added value to measures that reduce plastic waste generally? How could
such a target be developed?

5.8.        International
action

Article 4 of the Basel
Convention (BC) obliges parties to ensure the availability of adequate disposal
facilities for the environmentally sound management of hazardous wastes and
other wastes that shall be located to the extent possible within the party's
territory whatever the place of their disposal. This general requirement
applies also to plastic waste.

The “new strategic
framework” for 2012 – 2021, adopted at the 10th Conference
of the Parties (CoP) of the Basel Convention in 2011 includes environmentally
sound management (ESM) in waste prevention and minimization in its strategic
goals. The CoP also decided to mandate a technical expert group to develop a
framework for the environmentally sound management of waste on the
international level[84].

More recently, the Global
Partnership on Waste Management (GPWM) UNEP IETC[85] established in 2010, tries to promote internationally a
holistic approach on waste management, serving as a platform to enhance
international cooperation among stakeholders. Work plans for sponsored focal
areas such as solid waste management, marine litter and waste minimization, all
of crucial importance for plastic waste management internationally, are being
developed. A focal area for plastic waste could be envisaged.

The EU’s “new
neighbourhood policy” (ENP) and pre-accession policy may play a useful
role in promoting action to improve plastic waste management and address
current challenges. For instance, the involvement of neighbouring states in the
southern Mediterranean and the Black Sea region are very essential to achieve
the -plastic free - good environmental status of the Mediterranean and the Black Sea[86].

Plastic marine litter
should also be an issue raised through bilateral and regional
discussions/fora/Action Plans etc. (ENP). There is furthermore a clear need for
linking these policy frameworks and actions to the actions in the context of
UNEP, such as the Mediterranean Action Programme to reinforce implementation of
the Barcelona convention and minimize the impact of plastic marine litter.

The Rio+20 Summit offered the opportunity
to address the issue of marine litter at global level. The final document
acknowledged the need for continuing efforts to reduce the incidence and
impacts of marine pollution, including marine debris, especially plastic, from
a number of marine and land-based sources, including shipping and land run-off.
A concrete commitment was made to take action by 2025, based on collected
scientific data, to achieve significant reductions in marine debris to prevent
harm to the coastal and marine environment.

Questions:

(25)
Should the EU attach a higher priority to
plastic waste in the framework of its "New Neighbourhood Policy",
particularly in order to reduce plastic littering in the Mediterranean and in
the Black Seas?

(26)
How could the EU promote more effectively
international action to improve plastic waste management worldwide?

[1]               COM(2011) 571.

[2]               Gerhard Pretting/Werner Boote, Plastic Planet, Ornage
Press, Freiburg 2010, p.8.

[3]               In depth report Plastic Waste: Ecological and Human
Health Impacts, Science for Environment Policy, November 2011, p.1.

[4]               (BIOIS) Plastic waste in the Environment, final
report, European Commission, November 2010, http://ec.europa.eu/environment/waste/studies/pdf/plastics.pdf.

[5]               KPMG International (2010). The future of the chemical
industry.

[6]               Plastic waste in the Environment, loc.cit, p. 163.

[7]               Wurpel G.,Van den Akker J.,Pors J., Ten Wolde,
Plastics do not belong in the ocean. Towards a roadmap for a clean North Sea. IMSA Amsterdam (2011), p. 39.

[8]               Member State's statistics do generally only report on
plastic packaging. The actual amount of plastic waste can be assumed to be
higher. See: FORWAST, 2010, Policy recommendations, p. 43. (http://forwast.brgm.fr/Documents/Deliverables/Forwast_D63.pdf).

[9]               (BIOIS) Plastic waste in the Environment, loc.cit.,
p. 73.

[10]             R 1 recovery operation under Annex II of the Directive
on Waste 2008/98/EC.

[11]             (BIOIS) Plastic waste in the Environment, loc.cit, p.
123.

[12]             (BIOIS) Plastic waste in the Environment, op.cit., p.
122 ff.

[13]             (BIOIS) Plastic waste in the Environment, loc.cit., p.
123.

[14]             WBCSD,
Vision 2050, ttp://www.wbcsd.org/templates/TemplateWBCSD5/layout.asp?type=p&MenuId
=MTYxNg&doOpe.

[15]             Plastics Europe, plastics – the facts, 2012, p.5.

[16]             Friends of the Earth, Report of September 2010, more
jobs, less waste, p. 16, p. 31.

[17]             Plastics
Europe, loc.cit., p 5.

[18]             Plastics
Europe, loc.cit., p. 12.

[19]             Wurpel
G. et al, loc cit., p. 13.

[20]             UNEP, 2009, Marine Litter: A global challenge,
http://www.unep.org/pdf/unep_marine_litter-a_global_challenge.pdf.

[21]             A phenomenon by which large lumps of derelict fishing
nets float in water, unintentionally catching large amounts of fish.

[22]             Near large cities and offshore canyons, the density
could extend to 100.000 pieces per /km2. See further: Wurpel,G. loc.cit., p.
32, 35.

[23]             Most additives are fillers and reinforcements,,
plasticizers, colorants, stabilizers, processing aids, flame retardants,
peroxides and antistats, each representing a whole family of chemicals.

[24]             Mato Y., Isobe T., Takada H., Kanehiro H., Ohtake C.
and Kaminuma T. (2001) “Plastic resin pellets as a transport medium for toxic
chemicals in the marine environment” in Environmental Science and Technology
35(2): 318-324.

[25]             Rios, L.M., Moore, C. and P.R. Jones (2007) “Persistent
organic pollutants carried by synthetic polymers in the ocean environment” in Marine
Pollution Bulletin 54: 1230-1237.

[26]             Rios, L.M., Jones, P.R., Moore, C. and U. Narayan
(2010) “Quantification of persistent organic pollutants adsorbed on plastic
debris from the Northern Pacific Gyres’ “Eastern Garbage Patch””, accepted in Journal
of Environment Monitoring.

[27]             (BIOIS) Plastic waste in the Environment, loc.cit, p.
117.

[28]             (BIOIS) Plastic waste in the Environment, loc.cit, p.
114.

[29]             UNEP yearbook; Emerging issues in global environment,
Nairobi 2011; GESAMP (2010,IMO/FAO/UNESCO-IOC/UNIDO/WMO/IAEA/UN/UNEP Joint
Group of Experts on the Scientific Aspects of Marine Environmental Protection);
Bowmer, T. and Kershaw, P.J., 2010 (Eds.), Proceedings of the GESAMP
International Workshop on plastic particles as a vector in transporting
persistent, bio-accumulating and toxic substances in the oceans. GESAMP Rep.
Stud. No. 82, 68 pp., p.8.

[30]             UNEP
(2005). Marine litter, an analytical overview: http://www.unep.org/regionalseas/marinelitter/publications/docs/anl_oview.pdf.

[31]             Liffman M. and Boogaerts (1997) “Linkages between
land-based sources of pollution and marine debris” in Marine Debris. Sources,
Impacts, Solutions pp. 359-366.

[32]             Browne,
M.A., Crump, P., Niven, S.J., Teuten, E., Tonkin, A., Galloway, T., Thompson,
R. (2011). Accumulation of microplastics on shorelines worldwide: sources and
sinks. Environ Sci Technol, 45(21), 9175-9179.

[33]                    Derraik J.G.B (2002) “The pollution of the marine environment by
plastic debris: a review” in Marine Pollution Bulletin 44:842-852.

[34]             Batteries Directive 2006/66/EC,,OJL 266, 26.0.2006,
p. 1-14, End of Life Vehicles Directive 2000/53/EC. OJ L 269, 21.10.2000,
p.34; Packaging and Packaging Waste Directive 1994/62/EC, OJ L 365,
31.12.1994, p. 10–23;PCB/PCT Directive, 1996/59/EC, OJ L 243, 24.9.1996, p.
31–35;Sewage Sludge Directive , 1986/278/EEC; OJ L 181, 4.7.1986, p. 6–12.

[35]             Especially, Article 2.7 (d).

[36]             (BIOIS) Plastic waste in the Environment, loc.cit., p.
74.

[37]             Follow-up study on the implementation of Directive
1999/31/EC on the landfill of waste in EU-25, COWI consultants, June 2007, p.
79.

[38]             COWI study, loc. cit., p. 5. In some EU 10 MS 50% of
households are concerned.

[39]             (BIOIS), implementing EU waste legislation for green
growth, final report 2011, pp. 11-13, 88.

[40]             EEA Report No.7/2012, Copenhagen 2012, “movements of
waste across the EU’s internal and external borders“, p. 20.

[41]             BiPRO/Umweltbundesamt, "Services to support the
IMPEL network in connection with joint enforcement actions on waste shipment
inspections and to co-ordinate such actions, Final Report 15 July 2009.

[42]             ('Improving the delivery of benefits from EU
environmental measures; building confidence through better knowledge and
responsiveness') COM (2012) 95 final of 07 March 2012.

[43]             Hopewell, Dvorak, R. & Kosior, E. (2009). Plastics recycling: challenges and
opportunities. Philosophical transactions of the Royal Society N 364:
2115-2126.

[44]             Roadmap to a resource efficient Europe COM (2011) 571
final; for accompanying staff working papers, see: http://ec.europa.eu/environment/resource_efficiency/pdf/com2011_571.pdf.

[45]             (BIOIS) implementing EU waste legislation for green
growth, final report, p. 187.

[46]             Trendresearch: Der Markt für das Recycling von Kunststoffen in Mitteleuropa,
Marktentwicklung, technische Machbarkeit und ökologischer Nutzen, Bremen, 2011.

[47]             (BIOIS) (2011) Analysis of the Key Contributions to
Resource Efficiency, final report, p. 101.

[48]             National Oceanic and Atmospheric Administration.

[49]             GESAMP (2010), loc.cit., Rep. Stud. No. 82, 68 pp.,
p.31.

[50]             CONSULTIC Marketing & Industrieberatungs GmbH, Kunststoffabfälle
und Recycling in Deutschland und Europa, Alzenau 2012.

[51]             BiPRO, Organisation of awareness raising events
concerning the implementation of Directive 1999/31/EC on the landfill of waste,
Final Report, 30 May 2007, p. 17.

[52]             FORWAST,2010, Policy recommendations, loc.cit.

[53]             (BIOIS)(2011), Study on coherence of waste legislation
, loc.cit., p. 30.

[54]             EEA Report No.7/2012, Copenhagen 2012, “movements of waste
across the EU’s internal and external borders“, p. 21.

[55]             Non-packaging agricultural plastics include bale twine,
plant jackets, greenhouse film, horticultural cover, mulch film and silage
wrap. See www.defra.gov.uk/corporate/consult/agri-plastics/index.htm.

[56]             Plastic
waste and recycling are addressed in the Public Private Partnership SPIRE
(Sustainable Process Industry), under preparation. For details, see: http://www.suschem.org/documents/document/20120124124146-sustainable_process_industry_1209c(1).pdf.

[57]             Centre for Technology Assessment. Dinner is served!
Nanotechnology in the kitchen and in the shopping basket – Abstract of the
TA-SWISS study “Nanotechnology in the food sector”. 2009:
www.ta-swiss.ch/a/nano_nafo/KF_Nano_im_Lebensmittelbereich.pdf.

[58]                    Busch L.
Nanotechnologies, food, and agriculture: next big thing or flash in the pan?
Agric Hum Values. 2008;25:215–218; Sozer N., Kokini JL. Nanotechnology and its
applications in the food sector. Trends Biotechnol. 2009; 27(2): 82-9.

[59]                    Commission
Recommendation of 18 October 2011 on the definition of nanomaterial
2011/696/EU; http://eurlex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2011:275:0038:0040:EN:PDF.

[60]             Planned obsolescence is a business strategy in which
the obsolescence (the process of becoming obsolete—that is, unfashionable or no
longer usable) of a product is planned and built into it from its conception,
see: Slade, G., “Made to Break: Technology and Obsolescence in America”, Harvard University Press, 2006.

[61]             Countless electrical appliances such as mobile phone
chargers, are hermetically sealed, and cannot be opened for repair.

[62]             By the International Electrotechnical Commission (IEC)
and Commission services. See: JRC study and reports: "Integration of
resource efficiency and waste management criteria in European product
policies": http://lct.jrc.ec.europa.eu/assessment/projects#d.

[63]             See
http://ec.europa.eu/environment/eussd/product_footprint.htm.

[64]             ARPA, ARPAT, DAPHNE II (2011), L’impatto della plastica e
dei sacchetti sull’ambiente marino.

[65]             OECD, Environmentally harmful subsidies: challenges for
reform, 2005.

[66]             Biodegradable plastics shall be understood as plastics that can be degraded by living organisms
– in particular microorganisms into water, CO2, methane (CH4) and possibly
non-toxic residues (i.e. biomass).

[67]             (BIOIS) (2012), Options to improve the biodegradability
requirements in the packaging Directive, p. 30.

[68]             (BIOIS) (2012), Options to improve..., loc.cit., p. 21,
34.

[69]             (BIOIS) (2012), Options to improve ..., loc.cit., p. 15,
16, 23, 37

[70]             Gregory,M.R., & Andrady, A.L.(2003) Plastics in the
marine environment, in: A.L.Andrady (Ed.), Plastics in the Environment, Hoboken, N.J.:Wiley-Interscience, pp. 379-402.

[71]             STAP (2011). Marine Debris as a Global Environmental
Problem. Global Environmental Facility, Washington, DC. 2011, p.21.

[72]             Polycaprolactone (PCL).

[73]             Nolan-ITUPty, Ltd, 2002, Report on Biodegradable
Plastics – Developments and Environmental Impacts.

[74]             (BIOIS) Plastic waste in the Environment, loc.cit., p.
61.

[75]             (BIOIS) (2012), Options to improve..., loc.cit., p.
47/48.

[76]             For further reference, see: BIOIS (2012), Options to
improve..., loc.cit., p. 43.

[77]             EUROPEN, 2011, Packaging and Packaging Waste Statistics
in Europe: 1998-2008.

[78]             Plastic waste in the Environment, loc.cit, p. 13.

[79]             ftp://ftp.cen.eu/CEN/Sectors/List/bio_basedproducts/BTWG209finalreport.pdf

[80]             Fortenbery, Randall T. and Park, Hwanil (2008). The
Effect of Ethanol Production on the U.S. National Corn Price, Staff Paper
Series, University of Wisconsin-Madison.

[81]             2010/477/EU of 1st September 2010.

[82]             JRC, Marine Litter – Technical Recommendations for the
Implementation of MSFD Requirements, EUR 25009 EN, Luxemburg 2011.

[83]             http://www.mepielan-bulletin.gr/default.aspx?pid=18&CategoryId=10&ArticleId=95&Article=
MEDITERRANEAN-SEA---The-COP-17-of-the-Barcelona-Convention-Adopts-the-Paris-Declaration.

[84]             UNEP/CHW.10/CRP.25 of 20 October 2011.

[85]             http://www.unep.or.jp/Ietc/SPC/activities/GPWM/GPWMFrameworkDocumentv.11282011.pdf.

[86]             56% of municipal solid waste is landfilled in
unregulated dump sites in Turkey.