EUROPEAN COMMISSION Brussels,16.1.2018 SWD(2018) 16 final COMMISSION STAFF WORKING DOCUMENT Accompanying the document Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions A European Strategy for Plastics in a Circular Economy {COM(2018) 28 final}



Table of Contents 1 Introduction 2 Taking the opportunity: re-inventing plastics 2.1 Importance of plastics and the plastics industry 2.1.1 Current uses of plastics 2.1.2 Feedstock for plastics 2.1.3 The European plastics industry 2.2 Environmental impacts 2.2.1 Causes, pathways and figures 2.2.2 Impacts on the environment, health and economy 2.3 Moving towards more circular plastics 2.3.1 Linear vs. circular: a new approach for the plastics life-cycle 2.3.2 Plastics produced in a circular value chain 2.3.3 Enhanced circularity of plastics improving reuse and recycling rates 3 Improving the economics and quality of plastics recycling 3.1 Design for recyclability 3.1.1 Issues at stake 3.1.2 Existing EU measures 3.1.3 Actions to be taken

3.2 Boosting demand for recycled plastics 3.2.1 Issues at stake 3.2.2 Existing EU measures 3.2.3 Actions to be taken 3.3 Better and more harmonised separate collection and sorting 3.3.1 Issues at stake 3.3.2 Existing EU measures 3.3.3 Actions to be taken 4 Curbing plastic waste and littering 4.1 Preventing plastic waste in our environment 4.1.1 Single use plastics 4.1.2 Over-packaging 4.1.3 Plastic waste from sea-based sources: shipping, fishing and aquaculture products 4.1.4 Agricultural plastics 4.2 Establishing a clear regulatory framework for biodegradable plastics 4.2.1 Issues at stake 4.2.2 Actions to be taken 4.3 Oxo-degradable plastics: addressing the growing concerns 4.3.1 Issues at stake 4.3.2 Actions to be taken

4.4 The rising problem of micro-plastics 4.4.1 Issues at stake 4.4.2 Actions to be taken 5 Driving investment and innovation towards circular solutions 5.1 Issues at stake 5.1.1 Support the necessary investments 5.1.2 EPR fee modulation and more transparency 5.1.3 Deposit return schemes (DRS) 5.1.4 Innovation for more circularity 5.1.5 Specific actions to diversify the feedstock 5.2 Existing EU measures 5.2.1 Supporting the necessary investments 5.2.2 Enhancing Public Procurement and Ecolabel 5.2.3 The Commission proposal to introduce minimum requirements and providing a possibility for fee modulation for EPR schemes 5.2.4 Deposit-return schemes (DRS) 5.3 Actions to be taken 5.3.1 Guidance on EPR fee modulation 5.3.2 Establishment of EPR schemes for a wider plastic product categories 5.3.3 Actions to support innovation and research 6 Harnessing global action

6.1 Issues at stake 6.2 Existing EU actions 6.2.1 Multilateral cooperation at the United Nations and through environmental agreements 6.2.2 G7 and G20 6.2.3 Bilateral and regional cooperation 6.2.4 Relevant EU policies and programmes with an international dimension 6.3 Actions to be taken 6.3.1 UN Level 6.3.2 G7 and G20 6.3.3 EU international actions Annex I Problem and solution mapping Annex II Standards for bio-based and biodegradable plastics Annex III EU Cohesion Policy programs: examples of funded projects related to plastics



1Introduction Back in 2013, the European Commission launched a broad reflexion of possible responses to the public policy challenges posed by plastic waste considering that they were not at that time specifically addressed in EU waste legislation. Already, in this Green Paper it was stressed that there were challenges, but also opportunities arising from better management of plastic waste. The reflexion has evolved putting plastics in the Circular Economy context. The transition to a more circular economy, where the value of products, materials and resources is maintained in the economy for as long as possible, and the generation of waste minimised, is an essential contribution to the EU's efforts to develop a sustainable, low carbon, resource efficient and competitive economy. Plastics is one of the five priority areas addressed in the “EU action plan for the Circular Economy". In this EU action plan the European Commission set out a commitment to develop a Plastics Strategy. The Plastics Strategy is part of a broader agenda aiming at the modernisation of our economy, with long-term societal objectives in mind: a competitive, low-carbon, circular, sustainable economy that creates jobs and growth, and increases the quality of life of our citizens. The EU Action Plan for a Circular Economy also stressed the importance of strategic approach on the interface between chemicals, products and waste legislation, relevant to plastic waste streams and recycled plastics.

The recently published EU Industrial Policy Strategy stresses the need to strengthen the European industry's ability to continuously adapt and innovate by facilitating investment in new technologies and embracing changes brought on by the transition to a low-carbon and more circular economy. It announces that the Commission will put forward a new series of actions, including a strategy to move towards a circular plastics economy in Europe. In its 2017 letter of intent , the Commission has also announced that such strategy "will work towards all plastic packaging being recyclable by 2030". This new initiative on plastics aims to address three interrelated issues: 1.High dependence on virgin fossil feedstock, 2.Low rate of recycling and reuse of plastics, and 3.Significant leakage of plastics into the environment. Higher plastic waste recycling rates, increased volumes and improved quality of recyclates will boost the demand for secondary raw materials. The additional effort to diversify the feedstock will lead to more independence for the EU in terms of energy and resources and will contribute to the climate and energy goals and the jobs and growth agenda. In addition, more circular plastics economy will significantly reduce the negative environmental externalities by limiting the plastic leakage phenomenon. This staff working document accompanying the Communication "A European Strategy for Plastics in a Circular Economy", reports on the analysis performed by the Commission regarding the three issues mentioned above, largely supported by evidence, data and information collected during the Fitness Check of five waste stream Directives and taken on board in the Commission December 2015 legislative proposals on the waste targets review. Three additional studies were launched and contributed to gathering the knowledge gaps. Targeted stakeholder consultations, workshops and a major stakeholders' conference were organised by the Commission covering the main aspects of the whole lifecycle and value chain of plastics. It also contributes to the EU initiatives combatting marine litter and its international commitments. The policy options have emerged from this continuous flow of exchanges but they do not indicate a final position of the Commission and are only listed to enable an informed debate. Future discussions with the European Parliament, the Council and interested parties will enable choosing options and defining specific actions at a general or sectorial level for the transition to a more circular plastics economy. This document first outlines the opportunities and challenges of plastics, before going into the envisaged measures to tackle the environmental leakage and the economics of recycling, and finishes with the international dimension.



2Taking the opportunity: re-inventing plastics 2.1Importance of plastics and the plastics industry 2.1.1Current uses of plastics A plastic material is an organic solid, essentially a polymer, i.e. chain of several thousand of repeating molecular units of monomers, or combination of polymers. The monomers of plastic are either natural or synthetic organic compounds. The term resin is sometimes used as synonym of a commercial polymer. Plastics can be classified by chemical structure: the acrylics, polyesters, polyolefins, silicones, polyurethanes, and halogenated plastics. Plastics can also be classified by the chemical process used in their synthesis, such as condensation, and cross-linking. Other classifications are based on properties that are relevant for manufacturing or product design, e.g. thermoplasticity, biodegradability, electrical conductivity, density, or resistance to various chemical products. Plastic is an important component of our economic activity and daily lives. It has an outstanding number of functionalities such as lightness, robustness, malleability and durability. These characteristics as well as relatively low cost, have led to make plastic a privileged resource and material and also giving a contribution to solve many societal challenges from energy savings to innovation in healthcare and medical devices. Services that plastics can deliver to the society are increasing constantly and is a key enabling materials for many manufacturing industries which explain its ubiquitous presence in many products and applications. Currently a large variety of polymers is available. As shows the data from Plastics Europe, different types of polymers respond to different type of needs.

Although in some cases plastics are in competition with other traditional materials, e.g. wood, stone, metals, paper, glass, or ceramics, polymers can also be used to create so-called composite materials to obtain different and additional functionalities. Within Europe, plastics are primarily used in packaging (40%), while the building sector is the second user (20%). Automotive, electrical & electronic and agriculture are the three other sectors with significant plastic use, as explained in the following figure. 2.1.2Feedstock for plastics As for many other materials, the functionality of the wide array of plastics variants depends on the properties and functionalities of the polymers present in the plastic, largely independent from their origin, primary produced or from recycling. Plastics are traditionally derived from fossil sources, mainly oil and gas. Plastics can also be made of alternative feedstock such as renewable resources currently mainly derived from different types of agriculture (biomass), organic waste and residues, gaseous effluents (e.g. CO2). And finally, plastics can also be made from secondary materials obtained through the chemical or mechanical recycling of collected plastic waste. Bio-based products are wholly or partly derived from materials of biological origin, excluding materials embedded in geological formations and/or fossilised. In industrial processes, enzymes are used in the production of chemical building blocks, detergents, pulp and paper, textiles, etc. By using fermentation and bio-catalysis instead of traditional chemical synthesis, higher process efficiency can be obtained, resulting in a decrease in energy and water consumption, and a reduction of toxic waste. As they are derived from renewable raw materials such as plants, bio-based products can help reduce CO2and offer other advantages such as lower toxicity or novel product characteristics (e.g. biodegradable plastic materials). Increasing the use of bio-based plastics could provide greenhouse gas savings in the EU in 2020 of 9-27 million tons of CO2. However, whether bio-based plastics are effectively the more sustainable alternative, not only depends on their origin from renewable materials and their carbon balance, but also on other aspects such as land use, water use, eutrophication and potential toxicity impacts, e.g. due to pesticides. A broad range of environmental aspects needs to be looked at from a life cycle perspective to evaluate in a comprehensive manner if bio-based plastics have a higher or lower environmental impact compared to fossil-based plastics for specific applications. Bio-based plastics should not be confused with biodegradable plastics, i.e. they are not synonymous. Both materials were developed these past years in response to multiple environmental, societal and economic concerns or emerging political objectives, such as high rates of CO2emissions from fossil based plastic production processes, development of the bio-economy or reduction of the impact of plastic leakage in the environment. Biodegradable plastics are materials that can be bio-transformed and decomposed by microorganisms into water, naturally occurring gases like carbon dioxide (CO2) and methane (CH4) and biomass (e.g. new microbial cellular constituents). Bio-based plastics have the same properties as conventional plastics but are derived from biomass. The property of biodegradation does not depend on the resource basis of a material (fossil based or biomass). This biodegradability feature is directly linked to the chemical structure of the polymer and additives included. Biodegradable plastics can be fossil based (e.g. PBAT, PBS, or PCL) or bio-based (e.g. PHA or PLA), and the same is true for non-biodegradable plastics (e.g. PE, PP, PET or PS are fossil-based, while bio-PET or bio-PE are bio-based). In other words, even if they can, not all bio-based plastics have these biodegradable properties. Additionally to these two sources of feedstock, recently, several companies have made a statement that in future other alternative feedstocks will be used for plastic polymer production such as gaseous effluents (e.g. CO2). For the time being, more research and innovation is needed to scale up production processes and make this type of feedstock economically viable. Even more important for the purposes of attaining the circular economy goals, plastics can also be made from secondary materials obtained through the chemical or mechanical recycling of collected plastic waste. Mechanical recycling refers to operations that aim to recover plastics waste via mechanical processes such as grinding, washing, separating, drying, re-granulating and compounding. Chemical recycling also known as feedstock recycling, allows to chemically degrading the collected plastics waste into monomers, additives or other basic chemicals and separating the "building blocks" into reusable chemicals for the producers of chemicals and plastics. This technology, currently under development is of a particular interest when it comes to contaminated and mixed plastic waste. 2.1.3The European plastics industry International dimension As a leading exporter and importer of goods and services, the EU is deeply embedded in global value chains. The EU's share of global goods exports is above 15% . The EU accounted for a 21.8% share of the world’s GDP in 2016 (GDP per capita in the EU’s 28 Member States is €29,000) . This places Europe among the five top performing global economies. The EU is also at the forefront of efforts to support environmentally sound waste management through the promotion of a more circular economy. Per capita plastic consumption has reached 100 kg in Western Europe and North America; Asia currently uses just 20 kg per person, but this figure is expected to grow rapidly . Plastics production in Asia in 2013 accounted for 45.6 % of global plastics, while China alone produced nearly a quarter of world's plastic. Increasing trends of plastics production have also been seen in India, mainly driven by population growth and the expansion of the manufacturing sector The Middle East, Africa and Central and South America account for the smallest global shares of product (see Figure 3 ).

International trade in waste plastics is increasing. With global production of plastics skyrocketing and a continuing shift of production from the West to Asia (more than 40% by weight of world production in 2013), the annual volume of transnationally traded waste plastics is 15 million tonnes . According to EU estimates, about half of the plastics waste collected in the EU for recycling is exported to third countries, where more labour-intensive, low-tech processes remain widespread. Europe's insufficient domestic recycling capacity, higher cost of recycling and the insufficient quality of the sorted materials are key drivers for such high export levels. China hosts the world’s largest recycling industry, importing over 50% of the global trade for end-of-life plastic and 85% of the EU's plastic waste exports. This is a situation that is expected to change following China's decision to ban the import of certain types of wastes, including plastic waste. Plastics production in Europe If plastics are produced worldwide, mainly in China, Asia, North America, they are also produced here in Europe. The global production represents approximately 322 million tons of fossil based plastics (approximately 4% is used annually as raw material for production of plastics). In Europe 57 million tonnes of primary plastics were produced in 2016, the share of bio-based plastics being 0.5 and 1% of EU annual plastic consumption. The European plastics industry is a big part of the chemicals industry and plays a vital role in the EU economy. It employs about 1.45 million people and has a turnover of 350 billion (including plastic converters and technology providers). In 2013, the bioplastics industry accounted for around 23,000 jobs in Europe. Plastics recyclers account for a 30 000 jobs linked to the plastics industry. This general information can be details as follows. ·In 2014, in the EU 28, the manufacturing of plastic in primary forms (NACE C2016) employed more than 135 thousand persons in 2,600 firms. In terms of value added (at factor costs), the sector generated 15 billion EUR, i.e. the 0.9% of total EU manufacturing. SMEs account for roughly 25% of value added. ·The manufacturing of plastic products (NACE C222) employed some extra 1,300,000 persons, distributed over 55 thousand firms, of which only 753 were not SMEs. About 20% of persons are employed in the manufacturing of plastic packaging goods. In terms of value added, the sector generated 64 billion EUR, accounting for 3.7% of total EU manufacturing. ·In 2014, about 17,700 firms with 164 thousand employees were active in the recovery of sorted materials (NACE E3832). This category does not only refer to the recovery of plastic, but also of other materials such as paper and metal. Recovery of sorted materials generated nearly 10 billion EUR in value added. SMEs can be estimated to contribute with 17,200 firms, accounting for 8.5 billion EUR value added. Information on the specific share of plastic however is not available. 2.2Environmental impacts 2.2.1Causes, pathways and figures While the importance of plastics for our economies and society cannot be underestimated, there are also important health and environmental externalities. The Green Paper on plastics waste already pointed out the gravity of these impacts. According to the Eurobarometer survey on citizens perception of plastics almost three in four (74%) agree that they are worried about the impact on their health of everyday products made of plastic, while an even greater proportion (87%) agree that they are worried about the impact of plastic products on the environment. Marine litter is therefore one of the most important emerging global environmental issues. From mismanaged waste to marine litter Major land based sources of plastic marine litter appear to be: storm water discharges, sewer overflows, tourism-related litter, wastes released from dumpsites near the coast or river banks, illegal dumping, industrial activities, improper transport, consumer cosmetic products, synthetic sandblasting media or polyester and acrylic fibers from washing clothes. Plastic pellets can be found in most of the world’s oceans, even in non-industrialized areas such as the Southwest Pacific. Sea-based sources such as shipping, fishing, aquaculture and offshore also contributes to marine pollution. A frequently quoted study estimated to 4.8 to 12.7 million tonnes the quantities of plastic waste enter our oceans per year (see Error! Reference source not found. ). For the EU the estimated quantities are approximately 0.15 to 0.5 million tonnes. While these amounts are not measured but calculated on the base of models and they do not take into account transboundary shipments of plastic waste, they do give us an idea of the high order of magnitude of the problem

A recent assessment concludes that 79% of the plastic waste generated since the beginning of plastic production has accumulated in landfills or the natural environment , with uncontrolled disposal still being a major problem, predominantly in developing countries. According to Jambek et al. (2015), over 50% of the global leakage into the marine environment currently comes from five emerging markets in Asia (see Error! Reference source not found. ).



Research shows that river networks can facilitate the transport of plastics thus connecting most of the global land surface to the ocean. According to Schmidt et al. (2017), rivers from the 10 top-ranked catchments alone (see Figure 6. The top-10 rivers for land-based contribution to marine litter ) contribute between 88% and 94% of the total plastic debris and reducing plastic loads by 50% in the 10 top-ranked rivers would reduce the total river-based load to the sea by 45%. Poor waste management on land, in particular marginal plastic waste collection and recovery rates, aggravate the problem of plastic marine pollution. While the EU is relatively well equipped for the land-based sources in terms of legislation (mainly through waste management and waste water treatment legislation), this is less the case for sea-based sources such as shipping, fishing, aquaculture and offshore (e.g. oil and gas) activities, where the only legal instruments at our disposal are the Port Reception Facilities Directive and certain provisions of the Common Fisheries Policy and especially the Control Regulation. Accumulation of plastics in the environment Since 1980, over 150 million tonnes of plastic marine litter are estimated to have accumulated, out of which between 1.4 and 3.7 million tonnes in the EU. Deep-sea sediments were demonstrated to accumulate micro-plastics and retention of macro and micro-plastics in particular sea-bed locations is increased by topographic features. Micro-plastics, i.e. plastic particles (so called micro-plastics particles), are generally defined as synthetic water insoluble plastic polymers of 5mm or less in any dimension, result both from the intentional use of such particles in products as well as from decades of photo degradation and mechanical abrasion of macro plastics that have leaked into the environment. Recent research conducted by the University of Ghent suggests that Europeans currently consume up to 11,000 pieces of plastic in their food each year as a result of consumption of seafood. The impact on human health of this exposure still needs to be further assessed. Micro-plastics intentionally added in products such as cosmetics and detergents or generated during use of products such as tyres and textiles or along the plastics production and supply chain i.e. plastic pellets, were calculated in the order of 200 thousand tonnes in the EU. Updated calculations are under preparation for all major sources of all types of micro-plastics. It should be noted that data about the use of microbeads in products is scarce. All plastic waste entering the sea, if not removed, fragments in smaller pieces and becomes ultimately, because of weathering and fragmentation, micro-plastics. 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 is accumulating in the Mediterranean Sea at a similar scale to that in oceanic gyres (the rotating ocean currents in the Indian Ocean, North Atlantic, North Pacific, South Atlantic and South Pacific) . Plastic debris found in the Mediterranean surface waters are composed by millimetre-sized fragments, together with a proportion of large plastic objects, larger than the one present in oceanic gyres (see Figure 7 ).

The accumulation of plastic in the Mediterranean Sea is likely to be the result of a significant plastic input combined with a limited export to the Atlantic Ocean. In addition to this, the Mediterranean Sea acts as a convective basin, absorbing also the floating plastic originating from the Atlantic and many other terrestrial and maritime sources (e.g. the inputs from the Nile River). The special distribution of plastics concentrations in the Mediterranean is often irregular due to the variability of the Mediterranean Sea circulation patterns that prevent the formation of fixed plastic retention areas. Moreover, the multiple sources of plastic leakage and pollution in the Mediterranean could significantly impact plastic concentration in the short term. See Figure 8 concentrations of plastic debris in surface waters of the Mediterranean Sea compared to the plastic concentrations reported for the global ocean. 2.2.2Impacts on the environment, health and economy Once in the environment - particularly in the marine environment - plastic waste can persist for hundreds of years. The 10 million tonnes of litter, mostly plastic, which ends up in the world's oceans and seas annually, turning them into the world's biggest plastic dump, harm the coastal and marine environment as well as aquatic life. Marine litter causes enormous harm to ecosystems : impacts include mortality or sub-lethal effects on plants and animals through entanglement (e.g. from ghost nets ) physical damage, smothering, ingestion of plastic by animals such as turtles or birds, including micro-plastics; these micro-plastics have the potential to accelerate accumulation of chemicals throughout the food chain, with potential negative impacts on human health. Furthermore, marine litter facilitates the invasion of alien species, altering benthic community structure. Most plastic debris eventually comes to rest on the seabed . Species known to be affected by the marine litter are now almost 800, the proportion of cetacean and seabird species has risen to 40% and 44% respectively, while some surveys show that 100% of turtles are affected by ingestion of litter. A recent technical report from JRC provides insight about the major negative impacts from marine litter by describing the mechanisms of harm. Micro-plastics are ubiquitous and reach even the most remote areas 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. Plastic is not inert. Conventional plastic contains 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 . Persistent organic pollutants (POPs), such as pesticides like DDT and polychlorinated biphenyls (PCBs) since 1970s have been progressively banned but, as they are very persistent in the environment and sometimes still present in some materials or products in use, their presence can still be detected. They can attach themselves from the surrounding water to plastic fragments which can be harmful and enter the food chain via marine fauna which ingest the plastics (Trojan horse effect) . These POPs do not break down naturally very easily but accumulate in body tissue, potentially having carcinogenic, mutagenic and other health effects . Given the high leakage worldwide of plastics in the natural environment with harmful effects for a very long period of time, solutions have been sought to design plastics in a way that they can biodegrade in different environmental compartments. These solutions will only make sense as a complement to a paramount effort to reduce plastic leakages. Complete biodegradation of plastics, a process involving microbial action, occurs when none of the original polymer remains. Most currently available biodegradable plastics generally degrade under specific conditions which may not always be easy to find in the natural environment and can thus still cause harm to ecosystems. Biodegradation in the marine environment is particularly challenging even though recent research projects have shown some progresses made regarding this issue.



The economic activities directly affected by marine plastic litter and micro-plastics include shipping, fishing, aquaculture, tourism and recreation. The cost associated could be estimated to be at least $8bn per year (UNEP, 2016). For the EU, costs to the tourism and recreation sector (extrapolated from beach cleaning costs) have been estimated up to 630 million€ per year; costs to the fishing industry up to 57 million€. The "best estimate" within this range is a total of almost 470million€. Economic damage from litter on marine industry users was estimated to be $1.26bn per annum to marine industries in the Asia Pacific region. UN Environment estimates the damage to marine environments globally to be at least $8billion per annum. While it is clear that marine litter affects economic activities such as tourism and fisheries and entails substantial cleaning costs, it is also true that fighting against it creates economic opportunities : innovation in product design to avoid plastic litter and micro-plastics, but also investments for marine litter prevention (e.g. in waste and waste water treatment, in port reception facilities or recycling of fishing nets) can create jobs and strengthen technical and scientific skills and industry competitiveness in areas of growing global interest. 2.3Moving towards more circular plastics 2.3.1Linear vs. circular: a new approach for the plastics life-cycle

According to the linear model very frequently applied with this material plastic will then follow a "take-make-consume-dispose" pattern of lifecycle which is not the most resource efficient approach especially if considering the growing demand from a growing world population. It is commonly agreed that this type of model does not correspond to a sustainable growth principles in a sense that it is based on the assumption that resources are abundant, available, easy to source and cheap to dispose of. On the opposite, the circular economy model acknowledges that resources are limited and should be used in an efficient way. Strained natural resources and climate change are becoming an ever more tangible reality. Therefore, a model that is circular has become necessary in order to keep the added value in products for as long as possible and eliminate as much as possible waste generation. In 2014, the EU generated about 25 million tonnes of post-consumer plastic waste of which only 30 % was recycled. The performance as regards recycling of plastics wastes, although in progress, shows there is ample room for improvement. For example, the current target for recycling of plastic packaging waste is 22.5%. The average recycling rate of plastic packaging waste being 39.8% in 2015 clearly demonstrates that this target is obsolete. A more ambitious target is needed to provide incentives for increasing recycling; this is one of the elements of the recently proposed amendment to the Packaging and Packaging Waste Directive (55% of plastic packaging waste to be recycled by 2025). Once plastic wastes are considered as a resource to be kept as long as possible in the value chain the lifecycle should be modified accordingly. 2.3.2Plastics produced in a circular value chain Defining with precision a unique plastic value chain is difficult given the wide number of applications. However, it is legitimate to say that plastics production is just the starting point of a long material/product lifecycle. After being produced (from virgin or secondary raw materials, alternative feedstock or fossil based), plastic goes to plastics converters who manufacture finished plastic products. From converters, plastics in a form of an article or incorporated in articles, go to consumer through a more or less complex purchasing and selling process. Through consumers and the way they manage the end-of-life phase, plastics end up in the hands of waste collecting authorities and recyclers. In a circular model this is not the end of the story because if properly collected, sorted and recycled, plastic waste will serve as a raw material for new purposes. The recycling of PET bottles shows there is a real business case for a circular approach. This example should be followed by other polymers and applications. The circular plastics value chain could be presented as in the following figure. In order to achieve its goals in terms of efficient use of resources, raw materials as well as energy, the plastic sector has managed, in recent years, to produce more plastic with less material input. Additional investment and research are needed to find ways of producing plastic products with less virgin raw materials. The incorporation of secondary raw materials, i.e. recycled plastics, in the products is a way of avoiding the use of virgin raw materials with benefits in terms of energy consumption, imports of fossil fuels, environmental protection and GHG emissions. The use of virgin raw materials for products of a very short lifecycle such as single use items, might be seen as a clear example of inefficient use of resources and contrary to the circular economy principles where the value of products, materials and resources is maintained in the economy for as long as possible and the generation of waste is minimised. Also in line with the waste hierarchy, one should always go for the highest option where it is available, safe for the environment and human health and economically feasible and viable e.g. repair, remanufacturing and reuse over recycling). More durable alternatives are also a way of promoting resource efficiency. 2.3.3Enhanced circularity of plastics improving reuse and recycling rates Reuse and recycling of end-of-life plastics remains very low, in particular when compared to other materials such as paper, glass or metals. In 2014, 25.8 million tonnes of post-consumer plastics waste ended up in the official waste streams in the EU, and the greatest proportion is used for food and drink packaging. Only 29.7% of all post-consumer plastic waste was recycled and 39.5% was energetically recovered while 30.8% still went to landfill. No comprehensive data on reuse are available, but experience shows that it is only an option for a limited number of waste streams. These figures show that circularity is still far from being a reality for most plastics. Packaging is the main application of plastics and also the principal source of plastic waste generated due to the relatively short life of packaging products. In 2014 in the domestic sector alone, 15.2 million tonnes of plastic packaging were generated. It is also the plastic application with the highest recycling rate (39.5% in 2015) as there are in most cases comprehensive collection schemes for that type of waste. However, this recycling figure is very low compared with other packaging materials. The average packaging recycling rate is currently at 65%: Metals (76%), paper and cardboard (83%), glass packaging (73%) achieved significantly higher recycling rates. One of the reasons for the low recycling rate is the use of different plastic polymers (e.g. PP, PET, PVC, etc.) for different plastic applications. In some cases, a plastic packaging is made from several different polymers, depending on the functions of the packaging. The diversity of polymers, as well as the presence of multi-material and multi-layer packaging, makes recycling more difficult as it requires separation and leads to small quantities of a given polymer type to be managed, which makes logistics difficult and is an obstacle to achieving economies of scale. Reuse of consumer plastic packaging is not very common. There is increasingly prevalent and widespread use of plastic packaging in applications where the packaging is intended to be thrown away after one use even though more sustainable alternatives (including other plastics) exist. Use of refillable plastic containers (e.g. some PET bottles, some hygiene and detergent bottle refill) happens only where this is mandated (e.g. in Germany), but has declined to very low levels in general. In some cases, this is due to the business models used to deliver products to consumers: e.g. the use of refillable bottles for detergents and washing up liquids relies on the existence of available refill points that consumers can use, or suitable take-back schemes for refillable containers. In addition, refillable models are rejected by well-known consumer brands which tend to use packaging as one of the principal means to differentiate their products from (cheaper) competitors. Reuse and recycling of plastic packaging is relatively simple for tertiary and secondary packaging, as it is produced in large quantities and results usually in relatively clean and pure recyclates: much of this packaging is also composed of a single polymer.

Reuse is mostly used in the business-to-business (B2B) sector. Reuse of plastic crates between manufacturers and retailers, for example, is common practice. Even plastic film packaging waste from the industrial and retail sectors can be baled and collected in bulk, thus making recycling economically viable. However there are indications that the share of reused packaging is declining. Recycling rates for building/construction plastic waste are also remarkably low: In 2014, only 24% of this waste stream was recycled, with 42% sent to energy recovery, and the remaining 34% sent to landfill. The fact some Member States are recycling more than 40% of this waste stream shows that the recycling potential is not fully exploited. Direct reuse of construction plastic products at end of first life is considered to be very limited in scale and only in particular niches (such as over- ordered materials), and products (such as PVC windows and doors). The low recycling rates are due to the fragmentation of the plastics construction product supply chain, which leads to a lack of coordination and consistency between the construction and demolition companies, the material re-processors and manufacturers of plastic products. In addition, the fact that selective demolition and separation at source is not commonly applied in many Member States, and the presence of legacy additives in some plastic products are obstacles to reuse and recycling. Despite a high recycling rate for end of life vehicles (ELVs), the proportion of plastics from ELVs being recycled is extremely low: only 9%. Closed loop recycling of plastics is generally hindered by the limited effectiveness of collection/pre-sorting activities, the lack of a market for recyclates, and the limited skills and collaboration between value chain partners. The fact that the recycling target laid down in the ELV Directive can be achieved mostly by recycling metals provides little incentives for recycling of plastic parts, which in addition consist of different polymers and may contain hazardous additives, hence requiring more elaborated technology. Waste electrical and electronic equipment (WEEE) is an important source of waste plastics. In the European Union about 3.5 million tonnes of WEEE are being collected yearly , but according to reports the figure of total WEEE generated is much higher with approximately 9.4 million tonnes of WEEE generated each year. Approximately 20% of this waste stream consists of plastics. The estimated quantity of WEEE plastics based on the plastic content per WEEE category is 1.2 million tonnes . The quantity of plastic recyclate from the EU WEEE collected is estimated to be around 0.5 million tonnes.

3Improving the economics and quality of plastics recycling Increasing plastic recycling could bring significant environmental and economic benefits. It is becoming increasingly clear that higher level of plastic recycling, comparable to those of other materials, will only be achieved by improving the way plastics and plastics articles are produced and designed and by increasing cooperation across the value-chain. The economics and quality of plastics recycling could be improved through enhanced recyclability of plastics and plastic products, increased and improved separation of plastic waste collection and modernised EU's sorting and recycling infrastructure. By achieving these objectives, the Commission will boost both the supply of and the demand for recycled plastics. In order to achieve these objectives, a supportive and business friendly framework should be established providing economic incentives where justified and supporting research and innovation. 3.1Design for recyclability It is estimated that over 80% of all product-related environmental impacts are determined during the design phase of a product. Optimised design can lead to more durable, reparable, reusable, dismantable and recyclable plastic products. It can also help to fight planned obsolescence since the plastic components can constitute the weakest link in some products like electronics. However, design for increased circularity is currently facing several obstacles that are linked to the production processes, habits and a lack of dialogue across the value chain and between different actors. The choices made at the product design phase have a direct impact on the recyclability of plastics and the possibility to find their way back in the loop. 3.1.1Issues at stake Although it is estimated that over 80% of all product-related environmental impacts are determined during the design phase of a product, currently, there is no agreed definition of design for recyclability. Optimised design can lead to more durable, reparable, reusable, dismantable and recyclable plastic products. It can also help to fight planned obsolescence since the plastic components can constitute the weakest link in some products like electronics. The choices made at the product design phase have a direct impact on the recyclability of plastics and the possibility to find their way back in the loop. However, design for increased recyclability is currently facing several obstacles that are linked to the production processes, habits and a lack of dialogue across the value chain and between different actors. There may be some plastic items that, taken in isolation, are recyclable but are not suitable for recycling if occurring in low quantities and collected together with other often incompatible plastic materials. Moreover, although recycling is technically possible, it could not be economically viable. Use of different types of polymers and additives A plastic material is an organic solid, essentially a polymer, i.e. chain of several thousand of repeating molecular units of monomers, or combination of polymers. The monomers of plastic are either natural or synthetic organic compounds. The term resin is sometimes used as synonym of a commercial polymer. Plastics can be classified by chemical structure: the acrylics, polyesters, polyolefins, silicones, polyurethanes, and halogenated plastics. Plastics can also be classified by the chemical process used in their synthesis, such as condensation, and cross-linking. Other classifications are based on properties that are relevant for manufacturing or product design, e.g. thermoplasticity, biodegradability, electrical conductivity, density, or resistance to various chemical products. Plastics contain a main polymer, and a bespoke load of additives. Whereas these additives render plastics extremely versatile material that can display a number of specific properties (e.g. hardness, softness, UV resistance, flame formation resistance, or behaviour during manufacture), some additives cause some problems during the recycling phase or may be hazardous substances.

Type Function Anti-Counterfeiting Manufacturers and brand owners can combat counterfeiting by employing one of several or indeed multilayer anti-counterfeiting technologies. Optical brighteners absorb ultraviolet and violet light then re-emit this energy at a higher wavelength, normally as a blue glow. Antimicrobials/ Biostabilisers Help prevent deterioration of plastic materials where part of the material might be susceptible to microbiological attack. Such attacks can cause staining, discolouration, odour and loss of aesthetics but more importantly, loss of electrical insulating properties, hygiene and overall loss of mechanical properties in the material. Antioxidants Help prevent "oxidation", the polymer reacting with oxygen. Oxidation can cause loss of impact strength, elongation, surface cracks and discolouration. Antioxidants help prevent thermal oxidation reactions when plastics are processed at high temperatures and light-assisted oxidation when plastics are exposed to UV light. Antistatic Agents Help to prevent the build-up of static electric charge. Plastics are generally insulating and so have the capacity to build up static charges on the surface which greatly disturb processing procedures and can be an issue for hygiene and aesthetics. Biodegradable Plasticisers Used to make plastics softer and more flexible and to enhance the degradability of the product. Blowing Agents Form gases in the plastic to produce a foam material. The blowing agents form gases by breaking down on heating at a pre-determined temperature and form a foam structure within the plastic's polymer matrix. External Lubricants To prevent damage to plastics or the mould during processing. Applied to the material or directly to the machine to allow processing without damage. Fillers/ Extenders Natural substances used to improve strength and lower the cost of the material. Usually mineral-based, fillers/extenders literally increase the overall "bulk" of the plastic. Flame Retardants To prevent ignition or spread of flame in plastic material. Plastics see substantial use in critical construction, electrical and transport applications which have to meet fire safety standards either by mandatory regulations or voluntary standards. Flame retardants are added to plastics to meet these requirements. Fragrances Fragrances and deodorants for plastics are used in a variety of applications and products for the home. Heat Stabilisers To prevent decomposition of the polymer during processing. Processing usually results in temperatures well above 180°C, which without the addition of heat stabilisers would result in the plastic material literally falling apart Impact Modifiers Enables plastic products to absorb shocks and resist impact without cracking. Particularly relevant for polyvinyl chloride (PVC), polystyrene (PS) and polypropylene (PP) materials. Internal Lubricants Used to improve processability of plastics by increasing the flowability. Internal lubricants improve the melt flow of material by lowering the viscosity and heat dissipation (also see Processing Aids). Light Stabilisers Used to inhibit the reactions in plastics which cause undesirable chemical degradation from exposure to UV light. Pigments Tiny particles used to create a particular colour. Plasticisers Used to make plastics softer and more flexible. Process Aids Used to improve processability of plastics by increasing the flowability. Internal lubricants improve the melt flow of material by lowering the viscosity and heat dissipation (Also see Internal Lubricants) High-polymeric processing aids also improve flowability of PVC compounds. Reinforcements Used to reinforce or improve tensile strength, flexural strength and stiffness of the material. Often fibre-based. Source: Eunomia (2017) The content of additives in plastics varies widely, ranging from less than 1% in PET bottles to 50-60% in PVC, striking often a balance between technical properties and economics, as some additives are considerably more expensive than the main polymers, while others are inexpensive (inorganic fillers such as limestone or talc). Worldwide consumption of plastic additives is estimated to have reached 12.6 million tonnes in 2013 and is expected to increase to some 17.1 million tonnes by 2020. The Asia-Pacific region is leading globally both in terms of production and consumption of plastic additives. The demand is expected to increase worldwide, led by China and India. The on-going replacement of metals by plastics in many application areas, the increase in environmental awareness and intervention by governments to promote non-toxic plastic additives are among the factors driving growth in the plastic additives market. Plasticizers dominate the market of additives followed by flame retardants. PVC is the polymer consuming most additives, about one-third of the sum of plasticizers and heat stabilizers, and used in the early 2000's ca. 73% of the world production of additives by volume, followed by polyolefins (10%) and styrenics (5%) . About 40% of antioxidants and light stabilizers are used in polypropylene. Scientific evidence has shown that some additives that were massively used in the past are substances of very high concern and have been restricted by environment, health and safety legislation worldwide and in particular in Europe. This has led to a phase-out or a reduction in the consumption of some additives (e.g. phthalate-based plasticizers). Additives generally enhance plastic performance. They are essential to compensate the plastic monomers' incapacity to withstand use conditions without losing their useful properties and enhance their performance. However, they cannot be removed using traditional mechanical recycling methods. Hence, in their use there must be a balance between functionality and other characteristics that those additives may confer to plastics. Indeed, if some of those additives are not removed, they may remain in the recycled plastics and occur as legacy substances in recyclates, hinder their quality and create concerns about their safety in certain cases. Therefore, the use of additives must be carefully analysed during the design phase to ensure that, where possible, less toxic substitution are made, that they can be either easily removed at the end of life stage or do not compromise further recyclability of those materials. Even for those products that are suitable for recycling and for which recycling schemes exist in some countries (e.g. PVC windows and doors), there are some issues linked to the presence of legacy additives that were allowed to be used in the past but have been restricted in the meantime as there was evidence of their harmfulness. The presence of these additives may make recycling impossible. Alternatively, recycled content may be limited to small percentages in new products to ensure that the existing thresholds for these additives in new products are not exceeded. A more promising approach consists in dissolving the plastic waste and separating the polymer from the (toxic) additive. A pilot plant is applying this technique to recycle polystyrene waste that is contaminated with the banned flame retardant hexabromocyclododecane (HBCD), obtaining a clean polymer that can be used in the production of new plastics and a contaminated waste stream that has to be treated. Several substances of concern have been phased out over the last decades. However, their presence can still be traced in some cases. Design choices can negatively affect the value of recyclates The EU policies on product design have until now focused more on energy efficiency achieved in the use phase of the product and less on material design and composition for circularity, durability and reparability. However, it appears clearly that a circular plastic economy requires that materials used are recyclable. Plastics are currently a waste stream with very low recycling figures (30% recycling overall; 40% for plastic packaging) compared to other materials such as paper, metal or glass. Complex designs, either material design, for instance, by combining multiple polymers, additives, etc, or functional design, for instance, by integrating plastic materials in complex structure rendering the dismantling very complicated. These design flaws that result of paying little consideration to end-of-life sorting and recycling aspects is one of the reasons that hampers achieving higher plastic waste recycling rates. These choices have also an impact on the final quality of recyclates. Products are very often designed taking into account technical, economic and marketing aspects, involving co-operation among experts in these areas. However, end-of-life aspects are too often not taken into account during the design phase, and related experts not involved. Cooperation between production and recycling companies is also lacking. Examples of a design choice Negative effects on recyclability Fillers (e.g. chalck, talc powder and marble) Fillers will increase the density of polymer. This will lead to material losses during the recycling process. Multilayers and combination of non-compatible materials (PE/paper, PE/aluminium etc.) Plastics combined with different materials are difficult to segregate. If it is first properly sorted by the final user (aka consumer) it will be discarded during the sorting. If it is not taken out of the waste stream in time, if might lead to contamination of the waste stream and of recyclates. Dark pigments Unpigmented is preferred. Dark recyclates have a lower value. Direct printing on the packaging Should be avoided because inks will have an impact on the colour of recyclate and will often make it less attractive for future applications or introduce incompatible contaminants. Use of inks Inks must be chosen that do not bleed colour when agitated in water. Label inks that bleed and can discolour unpigmented HDPE for example regrind in the reclamation process, diminishing or eliminating its value for recycling. Use of additives Some additives might present a risk for human health if are still present in recycled materials (e.g. flame retardants) in particular if the intended use is sensitive as it is the case for food contact materials. There is little incentive to take into account recycling or reuse aspects when designing plastics for applications in automotive, construction and electronics given that the plastic waste fraction is small and there are no EU wide targets for recycling and recovery. Given that the overall recycling and recovery targets can be met without (or with only marginal) recycling of the plastics contained in these products and there are no reuse targets at all, there is little incentive to take into account recycling or reuse aspects when designing plastics for these applications. Packaging Design for recyclability is particular relevant for plastic packaging given that it is the most abundant plastic waste type and its short lifetime. However it is not defined in the Essential Requirements of the Packaging and Packaging Waste Directive (PPWD). It is estimated that around 30%, by weight of the plastics used for packaging needs fundamental redesign and innovation in order to be reused or recycled. Otherwise these materials will end up as litter, will be incinerated or landfilled. It is estimated that improvements in design have the potential of cutting by half the cost of recycling plastic packaging waste . In addition, there is little or no incentive to sort packaging whose value is low e.g. sachets, or which is a small proportion of what is in the waste stream, unless targets and incentives demand this. The low rates of plastic packaging recycling may also be due to the fact that most sorting systems detecting plastics are using near infra-red technology and sorting will be based primarily on the nature of the polymer that is picked up by the system as the packaging passes the detectors. For each additional stream that is to be sorted, an additional adaptation of the sorting system is required which leads to additional costs and investments. Whether such an investment makes sense will depend on the proportion of the material being targeted in the waste stream, and its value when extracted as a separate material (represented as revenue net of avoided treatment / disposal cost).

Plastic packaging presents often some design flaws that make their reuse or recycling difficult : ·Their design and material may confuse the consumers who do not put the waste in recyclable materials bin (e.g. plastic packaging which resembles paper, multi-material packaging, etc.). ·Plastic components in packaging that are difficult to separate manually from other materials (e.g. plastic labels on glass packaging, plastic handles on cardboard packaging, etc.). ·Coloured plastic materials that are difficult to separate in sorting plants. ·Plastics made of uncommon materials and for which no automatic sorting is foreseen in most of the sorting plants because of their low quantities (PVC, ABS, PU, etc.). ·Compound materials, such as multi-layer materials or multi material materials, are usually difficult to recycle. ·The presence of incompatible materials in the same waste stream (e.g. different types of PET) hampers recycling. ·Thin PET foils and semi-rigid PET foils are difficult to recycle. Construction materials Construction products containing plastic have a long lifetime, usually 25 years or more. For this reasons, in the design phase other factors, such as functionality, durability and energy efficiency, are prioritised over end of life issues. Recycling plastic waste from demolition is hampered by the fact that many plastic construction materials are part of composite structures (e.g. insulation materials), which are difficult to separate. Material degradation can also pose a problem: some polymers can be affected by exposure to ultraviolet radiation, and products using these materials may degenerate over time. These issues lead to concerns over warranty and liability for construction companies and building owners considering reuse, and so products need to be retested and recertified. From a market perspective, there are also a number of challenges in terms of the reuse of plastic building components at the end of first life. The performance specification (grade) of reusable products is often unknown: e.g. the insulation or fireproofing properties of insulation foam may be unclear. This is both in terms of the product specification when manufactured, and any repair, maintenance or modification that may have occurred during its operating life. These challenges are further compounded by a wide range of non-standard size products: while pipes, guttering etc. are often directly reusable, windows and doors are often not standard sizes, or obsolete in terms of meeting construction products regulation (CPR) and building code requirements. As regards plastic waste from demolition of buildings, one should keep in mind that the massive use of plastic as construction is relatively recent. Therefore, volumes of plastic waste are still low and often of poor quality. During the demolition, plastic waste is often mixed with other waste streams. In consequence, the recycling of plastic waste from demolition is often not economically viable. However, the use of plastic materials in constructions is increasing, which will lead in future to more plastic waste from demolition. In automotive sector In the automotive sector, Directive 2005/64 specifies that vehicles may be put on the market only if they are reusable and/or recyclable to a minimum of 85 % by mass and are reusable and/or recoverable to a minimum of 95 % by mass. It can be observed that currently vehicles in general are designed to be more and more resource efficient and durable, their spare parts repairable, reusable and replaceable, tackling safety and weight issues. However when applied specifically to plastic parts in vehicles this design for recycling obligation is not sufficiently taken into account. The ELV Directive aims, as a first priority, at the prevention of waste from vehicles and, in addition, at the reuse, recycling and other forms of recovery of end-of life vehicles and their components so as to reduce the disposal of waste. Although the ELV Directive requires vehicles to be designed for deconstruction, the disassembly or the recycling of car parts can still be improved. Many of the plastic parts in cars are large and easy to remove such as bumpers. Increase in removing these parts might even be achieved without a large increase of costs. The plastic quantity from ELVs available for recycling is significant, yet the recycling process itself is still a challenge. After these big plastic parts are removed or where an easy dismantling process is not possible, ELV processors will opt for shredding the vehicles, instead of manual dismantling, to save costs. Plastic coming from the shredding process is of a much lesser quality and more difficult to recycle. Design for recyclability of plastic parts in vehicles has also to taken into consideration the use and presence of chemicals as the average lifespan of a car is of 20 years. This might be an issue for cars that were produced in the past and have now come to the end of their life. Cross contamination of plastics by hazardous substances is hence a potential risk and must be limited to maximum following the rules put in place by ELV Directive. Closed-loop plastic recycling in automotive sector should be promoted. A further uptake of recycled plastics originating from cars could be envisaged. While doing so, it has to be ensured that legislation on safety of vehicles is fully complied with. Electrical and electronic equipment (EEE)

Design for reuse and recycling has not been a priority for the EEE industry. The Eco-design Directive for Energy related Products 2009/125/EC focuses on improving the energy performance of products, but has not introduced any significant impacts on material use (and hence impacted on plastic material resource efficiency considerations). Legislation and regulation aimed at addressing hazardous substances in electrical and electronic equipment has resulted in improvements to product design, with a high proportion of hazardous additives, such as brominated flame retardants (e.g. PBDE and PBB), being phased out from new products on the market and hence, improving recycling opportunity for polymers (and reducing the impact of the thermal treatment of such plastics where this takes place). Reuse of WEEE plastic parts on a large scale is not feasible due to the lack of standardisation in part types, although it would be possible to reuse cases and other plastic parts for repairs. Furthermore, it is claimed that drivers for repair and preparation for reuse (over recycling) are lacking, which result in a lack of demand for low cost spare parts, such as reused plastic casings. 3.1.2Existing EU measures The European Commission adopted an ambitious Circular Economy Package , which includes revised legislative proposals on waste. The revised legislative proposal on waste sets clear targets for reduction of waste and establishes an ambitious and credible long-term path for waste management and recycling. To ensure effective implementation, the waste reduction targets in the new proposal are accompanied by concrete measures to address obstacles on the ground and the different situations across EU Member States. Within the Eco-design Working Plan (2016-2019) the Commission remains committed to developing, where appropriate, product requirements under the Ecodesign Directive that take account of circular economy aspects, including recyclability and durability, reparability, upgradeability, design for disassembly, information, and ease of reuse and recycling for Electric and Electronic Equipment (EEE). This includes the development of mandatory product design and marking requirements, with the intention of making it simpler and safer to dismantle, reuse and recycle electronic displays (e.g. computer monitors, televisions and electronic display integrated in other products). It has also developed criteria to improve recyclability of plastics in its Ecolabel and Green Public Procurement criteria In order to address skills gaps the European Commission has supported, through the Erasmus+ programme, several projects that have developed vocational training content relevant to the circular economy. The development of a new scheme for "Design for Deconstruction", a close collaboration with construction stakeholders and national/regional administrations, will analyse the implications of Design for Deconstruction for the various segments of the construction value chain, i.e. what does it mean in terms of engineering and architecture of buildings, selection of materials and their properties, construction techniques, disassembly of buildings (instead of demolition). This exploratory phase will also address the potential needs regarding the evolution of construction codes and regulations. A second phase is the materialisation of a voluntary framework addressing the principles and rules of design for construction for the various parts of the construction value chain, including the contractual and liability issues. The Commission Communication "New Skills Agenda for Europe", adopted on 10/6/2016, launched the "Blueprint for Sectoral Cooperation on Skills" to improve skills intelligence and address skills shortages in specific economic sectors. The Blueprint is a new framework for strategic cooperation between key stakeholders (e.g. business, trade unions, research, education and training institutions, public authorities) in a given economic sector. Erasmus+ Sectoral Skills Alliances will be set up at EU level and then rolled out at national or regional level. As of 2017/2018 a second wave of sectors will be eligible for implementing the Blueprint, including green technologies and circular economy including bio-based and secondary recycled products in construction. 3.1.3Actions to be taken One of the objectives of the Plastics Strategy is to encourage and support product design choices that take into account their entire life cycle and that make them more durable, circular and easily recyclable. A precise and agreed definition of design for recyclability is needed. It should be established taking into account the context of existing waste streams and treatment plants and aligned, as far as possible, with sorting performance of existing facilities, in particular for plastic packaging. Alternatively, sorting of plastic waste is to be improved through innovative technologies e.g. scanners for watermarks or tracers/markers of polymers. As packaging is one of the main applications of plastics, all plastic packaging should be designed recyclable by 2030. To achieve this, the Commission will work on a revision of the essential requirements for placing packaging on the market. To this regard, the concept of design for recyclability should be clarified. Potential instruments include revised product design legislations, in particular revised Essential Requirements for Packaging. Design for recyclability of plastics should also take a look on removing regulatory barriers if they exist, through more harmonised and efficient EPR schemes, supportive framework for innovation and investments in more circular business models and a better understanding of the needs of actors of the plastics value chain. In this context, the Commission will also look into ways of maximising the impact of new rules on Extended Producers Responsibility (EPR), and support the development of economic incentives to reward the most sustainable design choices. It will also assess the potential for setting a 2030 recycling target for plastic packaging, similar to those put forward in 2015 for other packaging materials. Any action should be based on a proper lifecycle analysis and taking into account the waste hierarchy (repair, reuse and remanufacturing are to be preferred over recycling, incineration with energy recovery or landfilling as the least preferred option). However, several objectives can be pursued simultaneously. Research in innovative polymers that can be more durable and suitable for recycling while offering the desired functionality (e.g. protecting the packaged products) could also contribute to an increased recycling (see section on innovation). A reflexion on additives used in materials is also needed. The objective is to ensure a less toxic material stream and that recycled plastics are compliant with general requirements for products in terms of safety and non-hazardousness. Substitutions of substances of concern should be made, where possible, therefore allowing to limit the risk of presence of legacy substances in recyclates. This is one of the topics to be taken into account in the work on Interface between chemicals, products and waste policy (see section on legacy substances). As part of this work, the Commission is proposing possible ways to make chemicals easier to trace and to tackle the problem of legacy substances in recycled streams. As more and more plastics are used in construction, design for deconstruction is also important. This should however not specifically relate to plastic but consider all materials that are used. A new scheme for "Design for Deconstruction" will be launched. In automotive sector, there is a need to improve the design for disassembly and recycling of plastic parts. The overall environmental impact and compliance with other objectives have to be taken into account. A better implementation and/or the revision the ELV directive might be therefore needed. Greater collaboration is also required throughout the entire value chain. This can be achieved, inter alia, by producing design guidance to ensure recycling is fully taken into account. From a different perspective, actors involved in the design phase may also contribute to creating comprehensive and easily accessible information channels on substances used in materials and articles. The right balance between access to the relevant information and protection of intellectual property and industrial secrets needs to be ensured. 3.2Boosting demand for recycled plastics

3.2.1Issues at stake Obstacles hampering the market for recycled plastics Recycled plastics today only account for about 4-6% of the EU demand for new plastics materials, representing appr. 3.5 million tonnes / year. Different reasons may lead businesses to use more recycled plastics. Demand for more sustainable products and circular consumption has also increased over the last years. Recycled plastics can already be used in different types of applications depending on the quality of recyclates which has gradually and constantly increased. However, the uptake of plastic recyclates remains relatively low. A recent survey carried out by the European Plastics Converters Association (EuPC) in cooperation with Polymer Comply Europe (PCE) on the current and future use of recycled plastics materials in the Europe’s plastics converting industry found out that only 27% of the European plastics converting companies state that their customers are sufficiently aware of the benefits and needs to use recycled plastic materials. The survey also found out that the quality of recycled plastic materials remains the biggest barrier to stronger use of recyclates as raw materials. Almost 60% of the European plastics converting companies find it hard or very had to get a supply of recycled plastic materials in an acceptable quality. The EuPC survey shows that "a vast majority of 76% of the respondents currently is using recycled plastic materials, and regarding the future use, 75% of the participants plan to increase their usage of recyclates. Of the companies not currently using recycled plastic materials, 64% plan to do so in the future. The survey concludes by stating that "in the future, this number will further increase to more than 90%". Hence, we can observe both potential and willingness to take up this challenge. Several good examples can be listed: ·In the automotive sector, Renault uses already approximately 42,000 metric tons of recycled plastic per year, and intends to increase this figure to more than 50,000 tons in the coming 3 to 5 years. The Mercedes B Class Electric Drive contains 58 parts (31.9 kg) of recycled and high quality plastics. ·In the area of electronic devices, products benchmarked Sony SORPLAS (Sony Recycled Plastics) are made from up to 99% of recycled plastics. Sony also uses plastic which is a mix of virgin plastics (33%) and recycled content. The Philips PerfectCare Eco Steam Generator and Senseo coffee machine also contain recycled plastics. SEB has also developed a special brand of domestic appliances containing recycled plastics. ·In 2016 Werner & Mertz in collaboration with the bottle manufacturer Alpla-Werke Alwin Lehner GmbH & Co KG and the Green Dot, developed a new type of bottle for cleaning products which is made of 100% recycled plastic obtained from the Yellow Bag. Previously no translucent and white material had ever been produced from recyclable domestic refuse. ·In 2017, P&G in partnership with TerraCycle launched its new detergent bottle made from 100 per cent recycled plastic, including 10 % of plastic waste from the ocean. However, the whole value chain will need to work hand in hand in order to seize this opportunity. In all cases, specific discussions on design with recycled plastics should take place in order also to clarify, raise awareness amongst industry and end some misgivings regarding the integration of recycled content. A number of specific considerations need to be taken into account. The fact that China's notified the ban on plastic waste imports in July 2017 will have an impact on the European recycling industry in a sense that there will be more plastic waste to be recycled risking an oversupply of unsorted or poorly sorted plastics waste, which are not., fit for high quality and safe recycling. It is also important to highlight that market prices for recycled plastics in the EU depend on the market prices worldwide. With the Chinese's ban, there is a risk that prices of waste go down hand in hand with quality while quantities available increase. If its quality is poor, plastic waste is more expensive to be recycle. and usually leads to less qualitative recyclates (including safety concerns) that may not find a buyer. In view of this, there is a case for improving the quality of sorting plastics waste in distinct, more homogenous plastic fractions. Lack of quality standards for sorted plastic waste and recycled plastics Recycling of plastic waste and the uptake of recyclates remain very low, in particular when compared to other waste streams e.g. paper, glass and cardboard. It is however generally admitted that there is room for improvements when it comes to increase the uptake of recycled plastic. Downcycling, i.e. recycling of waste in cases where the recycled material is of a lower quality and functionality than the original material is also sometimes the preferred option because of some misgivings on the converters' side regarding the quality, safety and fitness-for-purpose of recycled materials, induced by the lack of dialogue across the value chain. A market for plastic recyclates (from mechanical and chemical recycling) and other secondary raw materials will only develop if such secondary raw materials can fulfil specific quality standards. Recycled plastics shall be demonstrated as safe. Moreover, collection of plastics, which makes up a large part of post-consumer waste, still does not generate sufficiently clean and homogenous streams that could enable recyclers to have the purity and scale that could result in improved material streams. Materials with significant recycling potential, for example clean plastic films are not at all collected in most Member States. If they were, it would contribute to increasing volumes of available plastic waste for recycling and in consequence the use of recyclates. Beyond the idea to give more certainty to recyclers regarding return on investment, recycling should also be supported by creating legal certainty and a level playing field compared to virgin material production. Indeed, there are indications that uncertainties concerning the legal status and regulatory acceptance of plastic waste stifle investments in plastic recycling, This relates both to the waste management conditions for certain plastic waste which may or may not be considered as hazardous, and to the conditions for recovered plastics to cease to be waste and become a product. The general end-of-waste criteria, i.e. criteria according to which waste ceases to be waste, and the ways how this can take place, are defined in Article 6 of the Waste Framework Directive (WFD). Such criteria have been set by the Commission for iron, steel and aluminium scrap, glass cullet and copper scrap. For plastic waste, the European Commission carried out a review, but end-of waste criteria have not been set because of the complexity and diversity of polymers and variety of potential applications. There would be a merit to provide businesses with harmonised quality standards for recycling practices and for recyclates in order to provide supportive business environment. Moreover, none of the existing standards and technical specifications fits the purpose of end-of-waste criteria and only business to business specifications define in practice the technical characteristics of waste plastics and recyclates. Hence, to support all actors in their efforts to increase quality and safety in the plastic value and in order to prepare the ground for such a standard, a first mapping exercise was launched by the Commission in the field of sustainable chemicals (plastics included) with the standardisation bodies (CEN, Cenelec and ETSI ) in December 2016. It will last until the end of 2018 when a mandate for standardisation bodies will be defined. For the purpose of this activity the concept of "sustainable chemicals" plastics included shall refer to the full lifecycle of chemicals and assess for each stage how standardisation can contribute to better sustainability. More recycling of secondary raw materials could be achieved through better waste collection and sorting systems, establishing end of waste criteria for plastic recycling and quality standards for secondary raw materials. Whereas some of these areas are covered by legislation, others are not, which leads to different requirements for standards. This work will recognise the distinction between standardisation documents as a support to markets (voluntary standards) and standardisation documents in support to legislation (harmonised standards). Hence, in areas where legislation is present or under preparation, it will verify whether existing standardisation documents can support legislation (harmonised standards) or whether possible gaps exist and how to close them by also considering pre-and co-normative research. Recycled plastic in food contact materials Materials used in food packaging whether they are virgin materials or recycled, have to comply with legal requirements in order to ensure food safety. Beyond the food safety issues, operators may be hesitant to use recycled materials for the packaging because of some material quality concerns e.g. aesthetical aspects, smell, etc..

There might also be concerns about the composition of recycled plastics intended to be used in food packaging as their composition is difficult to control and their origin is sometimes unknown in comparison to virgin raw materials. Recycled plastics may contain incidental contaminants that can originate from multiple sources (e.g. impurities, the use-phase, misuse, degradation, improper separation of materials, legacy substances or cross contamination during waste collection). Such incidental contaminants can affect the quality and safety of recyclates and the trust of operators in fitness for purpose of such materials. Currently, Food Packaging constitutes approximately 10% of the total plastic market. Legacy substances in waste streams and recyclates One of the Circular Economy Action Plan's objectives is to address the presence of substances of concern, limit unnecessary burden for recyclers and facilitate the traceability and risk management of chemicals in the recycling process. It also states that "the Commission will therefore develop its analysis and propose options for action to overcome unnecessary barriers while preserving the high level of protection of human health and the environment." This double goal (a boosted market for secondary raw materials and high level of protection of human health and the environment) cannot be achieved without addressing some issues related to how chemicals, products and waste legislation work or do not work together. It is therefore necessary to clarify how to deal with legacy substances, carefully weighting pros and cons of allowing recycling of certain materials versus elimination of the chemicals of concern these may contain. No such suitable assessment techniques, which take into account all relevant aspects - environmental footprint, risk assessment and socio-economic assessment - to determine the best overall outcome for society, have yet been agreed. The perception of the different operators on the market on the sourcing of recycled materials containing substances of concern, or eve n of the direct use of materials that have not ceased to be waste in production, varies depending on the materials and the operators and deserves consideration as it may play an important role in determining the viability of different alternative solution to the problem. There is an important knowledge gap about substances in materials and products and how they circulate from one stage of their life to another, which material or waste streams are concerned and to what extent. It is of particular importance that the time factor is kept in mind. Time factor should be read as past-present-future but also as lifespan and lifecycle of products, when products were manufactured, when products will become waste.



Substance Source of contamination Toxic heavy metals Cross contamination if not disposed of properly Can occur in recycled materials if not recycled properly (because recycler ignored that those substances are in materials or it is just impossible to take those substances out) Flame retardants Initially added during manufacturing process Can occur in recycled materials if not recycled properly (because recycler ignored that those substances are in materials or just didn't / could not de-pollute materials) Could also be added after recycling process as such in order to increase resistance to catching fire (but not always needed) Plasticisers Initially added during manufacturing process (e.g. PVS) and occurs in recycled materials if not recycled properly (because recycler ignored that those substances are in materials or it is just impossible to take those substances out) Could also be added during or after recycling process in order to increase functionality or to improve quality when mixed with virgin raw materials PCBs Cross contamination if not disposed of properly Can occur in recycled materials if not recycled properly (because recycler ignored that those substances are in materials or it is just impossible to take those substances out) PAH (polycyclic aromatic hydrocarbon) This group of substances is a natural component of fossil raw materials, specifically coal and petroleum. Refining processes1 such as coking for coal and cracking for petroleum generate products such as coke, tar, petrols, waxes, or oils. The slags generated in these processes are incinerated or used as a construction material in road building. If PAHs are not removed from slag or from coke oven and refinery products, they will enter the environment due to their persistence. Tar oils and specific oils from petroleum refining can be added as softeners to rubbers and plastics. The largest portion of the PAHs that reach consumers comes from these applications. Can also occur in recycled materials if virgin raw materials (e.g. rubber) are mixed with recycled materials containing PAH Perchlorates Additives in plastics The information flow along the value chain should be ensured. Currently, it is the case to a certain extent and for a certain type of substances, i.e. regulated under CLP and REACH. REACH for example specifies certain obligations for article producers who may be obliged to submit a registration or notify ECHA of the presence of substances of very high concern (SVHCs) in articles or pass information on those SVHCs down the supply chain in accordance with Articles 7 and 33 of REACH. Dangerous chemical substances have also an impact on the health and safety of workers involved in the recycling operations. The EU legal framework in this field establishes minimum requirements for the protection of workers' health and safety, imposing on the employer several obligations, including the performance of risk assessment and the implementation of protective and preventive measures. However, there are very limited (if any) information channels between producers of materials/products and recyclers. Users of articles, particularly consumers, are the first concerned as they have only limited information about the presence of substances of concern in articles. Waste managers, particularly recyclers, are affected as they will generally have only limited information about the presence of substances of concern in the input waste material they treat (especially in the case of waste originating from articles). Testing all recyclates for all potential contaminants and substances is not feasible and is not economically viable although the Commission may consider monitoring obligations for sensitive applications. From the legal perspective and from the point of view of recyclers, lack of knowledge of the (relevant) composition of the treated waste stream and the potential recycled material may hinder the decision-making process to allow the transition of that recycled material from waste to product status. From the market and business perspective, not knowing if recycled plastics are fit-for-purpose and safe for the intended future use may have a dramatic impact on the reputation and liability of the company. The mere presence of a substance of concern in an article does not however necessarily equate to the existence of a risk. In that regard the issue of recycling hazardous waste should also be taken into consideration. Waste can be hazardous from the moment it becomes waste. It also seems possible that a waste that did not have hazardous properties acquired them later in its lifetime because of improper management. The fact that waste is hazardous does not necessarily mean that it cannot be recycled. EU harmonised End of Waste criteria were established for glass cullet, iron, steel and aluminium scrap and copper scrap. In these three cases it is stated that hazardous waste shall not be used as an input except where proof is provided that the specified processes and techniques to remove all hazardous properties have been applied. The output from recycling operation shall be graded according to a customer specification, an industry specification or a standard for direct use in the production of substances or objects. Lack of information flow and cooperation across the value chain Improving the circularity of plastics and in particular the uptake of recyclates can also be enhanced through the appropriate information channels (producers of raw materials – converters – retailers - producers of goods – waste stage – recyclers). Enhanced supply chain collaboration, promoted by sectorial platforms and their associations has also a role to play (see the case of VinylPlus as an example). If it is clearly established that there is a need for information sharing, more reflexion is needed in order to define what kind of information is to be/can be gathered and for which kind of products and applications (packaging, construction, EEE, automotive, etc.). Gather too much information might have an adverse effect e.g. recyclers cannot test plastic recyclates for every potentially hazardous substance. Information should be available, up to date and organised in a comprehensive manner, which seems to be challenging for the time being and depends on the willingness to cooperate among relevant actors e.g. problem of information disclosure that varies from one sector to another (EEE,ELV,packaging, construction etc.). Another question is what are the technics already available or sufficiently advanced that can allow not only access the information gathered e.g. shared plate-forms, digital data basis, but also ensure that its flow is continuously maintained. In other words, how to trace materials and substances and how to ensure that the information follows them wherever they go and is still relevant in future.

In addition, traceability has the potential to : ·increase recycling rates by leading to a better sorting of different types of plastics and polymers; ·improve the quality of the recyclates by a better separation of different types of plastics and polymers and/or allowing to trace substances of concern; ·and, where required, allow product and material identification if traceability is assimilated to a "product passport" mainly for complex products such as electronic devices made from different type of materials. Traceability of plastics and plastic polymers can be achieved with the help of: 1.markers in plastic polymers and 2.digital watermarks in products. Both can be combined but they are just one of the measures to be taken and are interlinked with others (innovation, design for recyclability, collection-sorting-recycling) Every technic available has its purpose and limits. Tracers lead to add chemical substances into polymers. There also might be an issue when plastics are recycled because of the accumulation of previous tracers. The number of tracers that can be used is limited. When plastics are shredded, those pellets might be composed of different polymers and hence have different tracers in them. On the other hand, watermarks are useful only when products are entire (e.g. not shredded) and when materials can be recognised by a scanner and easily sorted in their real conditions.



VinylPlus is the 10-year Voluntary Commitment to sustainable development by the European PVC industry. The VinylPlus programme was developed through open dialogue with stakeholders, including industry, NGOs, regulators, civil society representatives and PVC users. The regional scope of the programme is the EU-28 plus Norway and Switzerland. Through the VinylPlus initiative, the European PVC industry plans to create a long-term sustainability framework for the entire PVC value chain. It aims to: ·recycle 800,000 tonnes of PVC per year by 2020 (570.000 tons achieved in 2016) ·promote a sustainable use of additives ·improve PVC products sustainability and their contribution to sustainable development ·reduce progressively GHG (greenhouse gas) emissions as well as energy and ·resource consumption along the entire production chain ·move towards a low-carbon circular economy ·build sustainability awareness along the value chain and among stakeholders. 3.2.2Existing EU measures Quality standards for sorted plastic waste and recycled plastics As a preliminary step in establishing quality standards a mapping exercise regarding sorted plastic waste and recycled plastics is needed, with the objective to have a general and full overview of needs and gaps in this area. The European Commission launched a preliminary study in this regard. It will prepare the ground for the upcoming standard by identifying and prioritising standardisation work. Developing quality standards for recycled plastics will ensure that where recyclates are replacing virgin raw materials, same requirements and technical specifications e.g. safety, fitness-for-purpose are met. The Food contact materials (FCMs) legal framework The Food contact materials (FCMs) legal framework is very protective of human health. Materials used in contact with food cannot release their constituents to the food in amounts that could adversely affect the health of consumers. Primary plastic materials used in food contact materials are subject to compositional requirements set out in specific legislation. From the legal point of view, there is a distinction between materials made from virgin plastic raw materials and recycled plastic materials. Recycled plastic materials and articles shall only be placed on the market if they contain recycled plastic obtained from an authorised recycling process. The quality of recycled plastic used for food packaging must be characterised and controlled. It must originate from plastic materials and articles that have been manufactured in accordance with Community legislation on plastic food contact materials and articles (general requirements for FCMs). It must originate from a product loop which is in a closed and controlled chain ensuring that only materials and articles which have been intended for food contact are used and any contamination can be prevented; or it must be demonstrated in a challenge test, or by other appropriate scientific evidence that the process is able to reduce any contamination of the plastic input to a concentration that does not pose a risk to human health. Plus, there must be established conditions of use of the recycled plastic. Opinion is delivered by EFSA which forms the basis for authorisation at EU level prepared by the Commission and submitted to Comitology procedure. Presently the authorisation decisions are under preparation. Until the Decisions have been adopted, the recyclers may place recycled plastic FCMs on the market subject to national rules. About 140 requests for authorisation for PET under this Regulation are still pending, while having received positive opinions by EFSA.

Enhancing supply chain collaboration Dialogues across the value chain need to be stimulated to raise awareness especially amongst plastics converters and brand owners and participate to fully integrating recycling activities into the plastics value chain from a different point of view. The Commission is already working with the stakeholders to improve the flow of information across the value chain in the framework of the Circular Economy Stakeholder Platform, launched in 2017, that promotes the share of information and of good practises between stakeholders. Stakeholders will also have access to studies and reports and policy commitments from other sectors or/and along the value chain. The Platform aims to be a place for dialogue as well, allowing for interactive discussions by topic. Tracking substances of concern The role of enhanced supply chain collaboration, promoted by sectorial platforms, their associations or existing extended producer responsibility schemes will contribute to this objective. Certain industries have recognised the necessity to track certain substances in their supply chains. A compilation of existing tracking systems has been published (see above). 3.2.3Actions to be taken Introducing a systemic approach By deciding actions to be taken the Commission will follow a systemic approach. Other measures such as developing quality standards, ensuring traceability, improving design for recyclability, enforcing the obligation of separate plastic waste collection and sorting, certification, etc. need to be enhanced in order to strengthen and make the whole plastic value chain more circular. Uptake of recycled plastics From a technical perspective, it is possible to include recycled plastics in the production of various applications. In the future, chemical recycling and advanced sorting could open the door for higher use in this market segment. The Commission will explore, in collaboration with different stakeholders, the potential for increased sector and application specific uptake of recycled plastics. To help tackle these barriers, and before considering regulatory action, the Commission is launching an EU-wide pledging exercise to ensure that by 2025, [X] million tonnes of recycled plastics find their way into new products on the EU market. Design products to be more fit-for-recycling (see the section on specific design choices and how they can negatively affect the value of recyclates) and design for products with recycled content should be analysed together and lead to a better perception of bottlenecks and how these obstacles could be tackled. The objective is also to ensure that articles made of or containing recycled plastics can be kept in the loop for more than just one circle. As regards the use of recycled plastics in food-contact applications (e.g. beverage bottles), the current regulatory regime needs to be re-examined to make sure it can deliver high food safety standards, while also providing a clear and reliable framework for investment and innovation in circular economy solutions. Together with EFSA, the Commission will assess options to improve the current system of authorising recycled plastics for food-contact uses. To further support the integration of recycled plastics in the market, the Commission will also explore more targeted sectoral interventions. For instance, certain applications in the construction and automotive sectors show good potential for uptake of recycled content (e.g. insulation materials or dashboards). In the context of ongoing and upcoming evaluations of EU rules on construction products and on end-of-life vehicles, the Commission will look into specific ways of promoting this. In the context of future work on the Packaging and Packaging Waste Directive, thought will also be given to using economic instruments to reward the use of recycled content in the packaging sector. Setting quality standards for sorted plastic waste and recycled plastics The Commission is committed to working with the European Committee for Standardisation and the industry to develop quality standards for sorted plastic waste and recycled plastics. Setting certification schemes of recycling plants Setting standards for plastic waste input for recycling and recyclates could be coupled with certification schemes of recycling plants. A certification scheme for plastic recycling plants as an additional benefit to increasing the quality of the supply, will also allow the demonstration that waste exported from Europe to non-OECD countries is treated in an environmentally sound manner. Links to the Interface between chemicals, waste and product policies "Non-toxic" and resource efficient life-cycles need to be put in place as much as technically possible and with as limited a risk as possible. The objective is to ensure that the circularity of today will not have adverse effects on the human health and the environment of tomorrow and, where the presence of substances of concern cannot be eliminated from recycled materials that those substances are able to be better tracked and monitored. It is necessary to clarify how to deal with legacy substances, carefully weighting pros and cons of allowing recycling of certain materials versus elimination of the chemicals of concern these may contain. No such suitable assessment techniques, which take into account all relevant aspects - environmental footprint, risk assessment and socio-economic assessment - to determine the best overall outcome for society, have yet been agreed.

The first challenge challenge is t