GREEN PAPER On a European Strategy on Plastic Waste in the Environment
Date: 2013-03-07
Institutions: European Commission
Subjects: biodegradability, coastal pollution, domestic waste, plastics, sustainable development, waste recycling

EUROPEAN 
COMMISSION 

Brussels, 7.3.2013  
COM(2013) 123 final 

GREEN PAPER 

On a European Strategy on Plastic Waste in the Environment 

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TABLE OF CONTENTS 

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

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5.1. 

5.2. 

5.3. 

5.4. 

5.5. 

5.6. 

5.7. 

5.8. 

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

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

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

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

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

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

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

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

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

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

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

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

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

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GREEN PAPER 

On a European Strategy on Plastic Waste in the Environment 

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

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

There  are  not  only  challenges,  but  also  opportunities  arising  from  better  management  of 
plastic waste. Although plastic is a fully recyclable material, only a small fraction of plastic 
waste is at present recycled. Enhanced recycling would contribute to the aims of the Roadmap 
to a Resource Efficient Europe adopted in 20111 and help to reduce greenhouse gas emissions 
and  imports  of  raw  materials  and  fossil  fuels.  Appropriately  designed  measures  to  recycle 
plastic can also improve competitiveness and create new economic activities and jobs. 

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

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

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

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

June 

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

1 

COM(2011) 571. 

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1. 

PLASTIC WASTE, DESCRIPTION OF A GROWING PROBLEM 

Plastic production 
Plastic is a relatively new material which went into industrial production only in 19072. It now 
pervades  industrial  and  consumer  goods,  and  modern  life  is  unthinkable  without  it.  At  the 
same time the characteristics that make plastic so useful, such as its durability, light weight 
and low cost, also make its disposal problematic3. 

Global plastics production grew from 1.5 million tonnes (Mt) per annum in 1950 to 245 Mt in 
2008, with 60 Mt4 in Europe alone. Production during the last 10 years equalled production 
during  the  whole  of  the  20th  century  combined5.  It  is  estimated  (under  a  business  as  usual 
scenario) that 66.5 Mt6 of plastic will be placed on the EU market in 2020 and global plastic 
production could triple by 20507. 

Plastic waste 

In  the  European  Union  (EU  27),  it  is  estimated  that  around  25  Mt  of  plastic  waste  was 
generated  in  2008.  Of  this  12.1  Mt  (48.7%)  was  landfilled  while  12.8  Mt  (51.3%)  went  to 
recovery8,  and  only  5.3  Mt  (21.3%)  was  recycled9.  While  a  projection  to  2015  assumes  an 
overall  increase  of  30  %  in  the  level  of  mechanical  recycling  (from  5.3  Mt  to  6.9  Mt), 
landfilling  and  incineration  with  energy  recovery10  are  expected  to  remain  the  predominant 
waste management pathways11.  
Plastic production is going up with GDP12 and an associated overall increase in the generation 
of plastic waste between 2008 and 2015 of 5.7 Mt (23%)13. This is largely driven by a 24% 
rise  in  the  packaging  sector  and  is  part  of  an  unbroken  trend  of  increasing  plastic  waste  in 
Europe.  In  the  absence  of  improved  product  design  and  improved  waste  management 
measures, plastic waste will increase in the EU as production increases.  

Trends  observed  in  the  EU  are  likely  to  be  stronger  in  fast-growing  economies  like  India, 
China,  Brazil  and  Indonesia,  but  also  in  developing  countries.  The  world's  population  is 
forecast to grow  by 790 million every decade and  may  reach  over  9  billion  by  2050  with  a 
new middle class of around 2 billion14. This is likely to increase demand for plastic and the 
amount of plastic waste worldwide.  

The plastics industry 

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Gerhard Pretting/Werner Boote, Plastic Planet, Ornage Press, Freiburg 2010, p.8. 
In depth report Plastic Waste: Ecological and Human Health Impacts, Science for Environment Policy, 
November 2011, p.1. 
(BIOIS)  Plastic  waste  in  the  Environment,  final  report,  European  Commission,  November  2010, 
http://ec.europa.eu/environment/waste/studies/pdf/plastics.pdf.  
KPMG International (2010). The future of the chemical industry. 
Plastic waste in the Environment, loc.cit, p. 163. 
Wurpel  G.,Van  den  Akker  J.,Pors  J.,  Ten  Wolde,  Plastics  do  not  belong  in  the  ocean.  Towards  a 
roadmap for a clean North Sea. IMSA Amsterdam (2011), p. 39. 
Member  State's  statistics  do  generally  only  report  on  plastic  packaging.  The  actual  amount  of  plastic 
waste  can  be  assumed  to  be  higher.  See:  FORWAST,  2010,  Policy  recommendations,  p.  43. 
(http://forwast.brgm.fr/Documents/Deliverables/Forwast_D63.pdf). 
(BIOIS) Plastic waste in the Environment, loc.cit., p. 73. 
R 1 recovery operation under Annex II of the Directive on Waste 2008/98/EC. 
(BIOIS) Plastic waste in the Environment, loc.cit, p. 123. 
(BIOIS) Plastic waste in the Environment, op.cit., p. 122 ff. 
(BIOIS) Plastic waste in the Environment, loc.cit., p. 123. 
WBCSD, Vision 2050, ttp://www.wbcsd.org/templates/TemplateWBCSD5/layout.asp?type=p&MenuId 
=MTYxNg&doOpe. 

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The plastic industry plays an important economic role in Europe, employing in total around 
1.45 million people in over 59 000 companies and generating turnover in the region of around 
€ 300 billion per year. The producing sector  provides 167 000 and the converters 1.23 million 
jobs (EU 27, 2005-2011, ESTAT) mostly in SMEs15. 

On  the  waste  management  side,  collection  and  sorting of waste from electric and electronic 
equipment (WEEE) and plastics provide the greatest job opportunities, with a total of 40 and 
15.6 jobs respectively being created per 1 000 tonnes of material processed. Plastic recycling 
alone has the potential to create 162 018 jobs in the EU 27 if the recycling rate increases up to 
a level of 70% by 202016.  

Plastic  is  mostly  used  in  packaging  as  a  low-cost  one-way  product  that  is  most  often  not 
reusable  or  not  foreseen  for  reuse.  The  plastics  converting  market  is  dominated  by  plastic 
packaging  (40.1%)  followed  by  the  building  and  construction  sector  (20.4%).  The  Plastics 
industry  expects  a  long-term  growth  of  around  4%  globally,  well  ahead  of  expected  global 
GDP growth17. Europe is still a net exporter of plastic products with a value of €13 billion in 
2009, but Chinese production has reached similar levels since 200818.  

Fate in the environment 

Once in the environment - particularly in the marine environment - plastic waste can persist 
for  hundreds  of  years19.  Harm  to  the  coastal  and  marine  environment  and  to  aquatic  life 
follows from the 10 million tonnes of litter, mostly plastic, which end up in the world's oceans 
and seas  annually,  turning them  into  the world's  biggest  plastic  dump.  Waste  patches  in  the 
Atlantic  and  the  Pacific  oceans  are  estimated  to  be  in  the  order  of  100  Mt,  about  80%  of 
which is plastic. Plastic debris causes sea species to suffer from entanglement or ingestion20. 
"Ghost  fishing"21  through  derelict  plastic  fishing  gear  causes  high  economic  cost  and 
substantial environmental harm. Invasive species use plastic debris to travel long distances in 
oceans. Most plastic debris eventually comes to rest on the seabed22. 

Plastic  is  not  inert.  Conventional  plastic  contains  a  large  number,  and  sometimes  a  large 
proportion, of chemical additives which can be endocrine disruptors, carcinogenic or provoke 
other  toxic  reactions  and  can,  in  principle,  migrate  into  the  environment,  though  in  small 
quantities23.  Persistent  organic  pollutants  (POPs),  such  as  pesticides  like  DDT  and 
polychlorinated  biphenyls  (PCBs)24,  can  attach  themselves  from  the  surrounding  water  to 
plastic  fragments  which  can  be  harmful25  and  enter  the  food  chain  via  marine  fauna  which 

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Plastics Europe, plastics – the facts, 2012, p.5. 
Friends of the Earth, Report of September 2010, more jobs, less waste, p. 16, p. 31. 
Plastics Europe, loc.cit., p 5. 
Plastics Europe, loc.cit., p. 12. 
Wurpel G. et al, loc cit., p. 13. 
UNEP,  2009,  Marine  Litter:  A  global  challenge,  http://www.unep.org/pdf/unep_marine_litter-
a_global_challenge.pdf. 
A  phenomenon  by  which  large  lumps  of  derelict  fishing  nets  float  in  water,  unintentionally  catching 
large amounts of fish.  
Near  large  cities  and  offshore  canyons,  the  density  could  extend  to  100.000  pieces  per  /km2.  See 
further: Wurpel,G. loc.cit., p. 32, 35. 
Most additives are fillers and reinforcements,, plasticizers, colorants, stabilizers, processing aids, flame 
retardants, peroxides and antistats, each representing a whole family of chemicals. 
Mato Y., Isobe T., Takada H., Kanehiro H., Ohtake C. and Kaminuma T. (2001) “Plastic resin pellets as 
a  transport  medium  for  toxic  chemicals  in  the  marine  environment”  in  Environmental  Science  and 
Technology 35(2): 318-324. 
Rios,  L.M.,  Moore,  C.  and  P.R.  Jones  (2007)  “Persistent  organic  pollutants  carried  by  synthetic 
polymers in the ocean environment” in Marine Pollution Bulletin 54: 1230-1237. 

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ingest the plastics (Trojan horse effect)26. These POPs do not break down naturally very easily 
but  accumulate  in  body  tissue,  potentially  having  carcinogenic,  mutagenic  and  other  health 
effects27. 

Small and fine particles (so called micro plastics), result from decades of photo degradation 
and  mechanical  abrasion  and  are  of  particular  concern.  They  are  ubiquitous  and  reach  even 
the most remote areas28 with a concentration in water sometimes higher than that of plankton. 
These micro plastics, and the chemical additives they contain, if ingested in large quantities 
by marine fauna may have a high potential for contaminating the food chain through predator-
prey interaction.  

Poor  waste  management  on  land,  in  particular  only  marginal  plastic  waste  recovery  rates, 
aggravate  the  problem  of  plastic  marine  pollution  which  is  one  of  the  most  important 
emerging  global  environmental  issues29.  Experts  judge  that  around  80%  of  marine  plastic 
waste is coming from land30.  

Major land based sources of plastic marine litter appear to be: storm water discharges, sewer 
overflows,  tourism-related  litter,  illegal  dumping31,  industrial  activities,  improper  transport, 
consumer  cosmetic  products,  synthetic  sandblasting  media  or  polyester  and  acrylic  fibres 
from  washing  clothes32.  Plastic  pellets  can  be  found  in  most  of  the  world’s  oceans,  even  in 
non-industrialised areas such as the Southwest Pacific33.  

2. 

REGULATION ADDRESSING PLASTIC WASTE IN EUROPE 

Waste legislation 

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

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issues 

in  global 

Rios,  L.M.,  Jones,  P.R.,  Moore,  C.  and  U.  Narayan  (2010)  “Quantification  of  persistent  organic 
pollutants  adsorbed  on  plastic  debris  from  the  Northern  Pacific  Gyres’  “Eastern  Garbage  Patch””, 
accepted in Journal of Environment Monitoring. 
(BIOIS) Plastic waste in the Environment, loc.cit, p. 117. 
(BIOIS) Plastic waste in the Environment, loc.cit, p. 114. 
UNEP  yearbook;  Emerging 
environment,  Nairobi  2011;  GESAMP 
(2010,IMO/FAO/UNESCO-IOC/UNIDO/WMO/IAEA/UN/UNEP  Joint  Group  of  Experts  on  the 
Scientific  Aspects  of  Marine  Environmental  Protection); Bowmer,  T.  and  Kershaw,  P.J.,  2010  (Eds.), 
Proceedings  of  the  GESAMP  International  Workshop  on  plastic  particles  as  a  vector  in  transporting 
persistent, bio-accumulating and toxic substances in the oceans. GESAMP Rep. Stud. No. 82, 68 pp., 
p.8. 
UNEP (2005). Marine litter, an analytical overview: 
http://www.unep.org/regionalseas/marinelitter/publications/docs/anl_oview.pdf. 
Liffman  M.  and  Boogaerts  (1997)  “Linkages  between  land-based  sources  of  pollution  and  marine 
debris” in Marine Debris. Sources, Impacts, Solutions pp. 359-366. 
Browne, M.A., Crump, P., Niven, S.J., Teuten, E., Tonkin, A., Galloway, T., Thompson, R. (2011). 
Accumulation of microplastics on shorelines worldwide: sources and sinks. Environ Sci Technol, 
45(21), 9175-9179. 
Derraik J.G.B (2002) “The pollution of the marine environment by plastic debris: a review” in Marine 
Pollution Bulletin 44:842-852. 

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

The Commission has decided that it will conduct a wide ranging review of the existing waste 
legislation and the various targets which will be completed in 2014. This review also involves 
an  ex-post  evaluation  ("fitness  check")  of  five  existing  waste  stream  Directives34  that  will 
assess effectiveness, efficiency, coherence and relevance. The follow-up to this Green Paper 
will form an integral part of this wide ranging review of the waste legislation. 

Chemicals legislation 

The REACH Regulation 1907/2006/EC is of some relevance for plastics recycling. While the 
Regulation contains specific provisions35 that facilitate the placing on the market of recycled 
materials,  in  some  cases,  the  use  of  additives  in  plastics  may  hinder  compliance  within 
REACH if the additives are not allowed in new products. Some REACH processes are also 
relevant for improving the resource efficiency of plastics, including its recyclability, and the 
risks associated with plastic in the environment. In particular, restrictions remain key tools to 
reduce the hazards associated with certain plastics. Authorisation could be used to achieve the 
progressive substitution of those plastic additives posing the highest concern in EU-produced 
plastics.  

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

The  hazards  of  plastic  waste  in  the  environment  would  be  significantly  lower  if  existing 
European  waste  legislation  was  properly  implemented.  Landfilling  remains  the  predominant 
disposal route for plastic waste36 in many Member States. Moreover, illegal dumping has not 
been  fully  eradicated  and  many  landfills  are  illegal  or  are  badly  managed37.  More  worrying 
still are the number of households not covered by any municipal waste collection system38; a 
situation  where  plastic  waste  is  under  no  control  increasing  the  likelihood  of  lightweight 
plastic reaching water bodies and finding its way to the sea. 

Implementation of waste legislation 

Compliance with waste legislation can significantly contribute to fostering economic growth 
and job creation.  A recent study suggested that full implementation of  EU waste  legislation 

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Batteries  Directive  2006/66/EC,,OJL  266,  26.0.2006,  p.  1-14,  End  of  Life  Vehicles  Directive 
2000/53/EC. OJ L 269, 21.10.2000, p.34; Packaging and Packaging Waste Directive 1994/62/EC, OJ L 
365,  31.12.1994,  p.  10–23;PCB/PCT  Directive,  1996/59/EC,  OJ  L  243,  24.9.1996,  p.  31–35;Sewage 
Sludge Directive , 1986/278/EEC; OJ L 181, 4.7.1986, p. 6–12. 
Especially, Article 2.7 (d). 
(BIOIS) Plastic waste in the Environment, loc.cit., p. 74. 
Follow-up  study  on  the  implementation  of  Directive  1999/31/EC  on  the  landfill  of  waste  in  EU-25, 
COWI consultants, June 2007, p. 79. 
COWI study, loc. cit., p. 5. In some EU 10 MS 50% of households are concerned. 

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could save €72 billion a year, increase the a nnual turnover of the EU waste management and 
recycling sector by €42 billion  and create over 400,000 jobs by 202039. 

Since plastic waste is categorized non-hazardous, it can be exported to non-OECD countries 
following the procedure of the Waste Shipment Regulation (WSR) and provided the import is 
not prohibited by the country of destination. Total exports of plastic waste from EU Member 
States increased by a factor of five between 1999 and 2011. Most exports went to Asia40. 

Insufficient  enforcement  of  the  WSR  results  in  illegal  shipment  of  high  quantities  of  waste 
outside the EU41. One of the most common types of waste involved is e-waste, rich in plastic. 
Such  exports  contribute  to  environmental  pressures,  particularly  in  countries  with  poorly 
developed  waste  management  systems.  Illegal  shipments  of  plastic  waste  also  represent  an 
important loss of potential resources and lost opportunities for recycling in Europe.  
The  Commission  has  recently  published  a  communication42  stressing  the  need  to  improve 
responsiveness  at  national,  regional  and  local  level  for  implementation  of  environmental 
legislation. This communication recognises that improvements may be available by upgrading 
the existing framework for inspections and surveillance. 

3. 

PLASTIC WASTE MANAGEMENT AND RESOURCE EFFICIENCY 

More  sustainable  patterns  of  plastic  production  and  better  plastic  waste  management  - 
particularly  higher  recycling  rates  -  offer  considerable  potential  for  improving  resource 
efficiency. At the same time, they would help to reduce imports of raw materials as well as 
greenhouse  gas  emissions.  Resource  savings  can  be  significant.  Plastic  is  produced  almost 
exclusively  from  oil  and,  at  present,  plastic  production  accounts  for  approximately  8%  of 
world oil production, of which 4% as a raw material and 3-4% as energy for manufacturing 
processes43. 

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

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

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(BIOIS), implementing EU waste legislation for green growth, final report 2011, pp. 11-13, 88. 
EEA Report No.7/2012, Copenhagen 2012, “movements of waste across the EU’s internal and external 
borders“, p. 20. 
BiPRO/Umweltbundesamt,  "Services  to  support  the  IMPEL  network  in  connection  with  joint 
enforcement  actions  on  waste  shipment  inspections  and  to  co-ordinate  such  actions,  Final  Report  15 
July 2009. 
('Improving  the  delivery  of  benefits  from  EU  environmental  measures;  building  confidence  through 
better knowledge and responsiveness') COM (2012) 95 final of 07 March 2012. 
Hopewell, Dvorak, R. & Kosior, E. (2009). Plastics recycling: challenges and opportunities. 
Philosophical transactions of the Royal Society N 364: 2115-2126. 

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Recycling  already  starts  in  the  product  design  phase.  Therefore,  product  design  has  the 
potential  to  become  one  of  the  essential  tools  to  implement  the  recently  adopted  Resource 
Efficiency Roadmap44.  

Low  recycling  rates  and  exports  of  plastic  waste  for  reprocessing  in  third  countries  are  an 
important loss of non-renewable resources, and of jobs, for Europe. The potential for plastic 
recycling  is  still  significantly  under-utilized.  For  example,  the  Irish  Marked  Development 
Programme for waste resources identified (inter alia) plastics as offering the greatest potential 
for  recycling  activity  in  Ireland45.  In  Germany,  with  60%  of  plastic  waste  presently  being 
incinerated, there is also wide scope to increase the rate of plastic recycling46. 

In  a  recent  study,  plastic  recycling  and  material  savings  were  found  as  having  the  highest 
contribution  to  impact  savings  in  climate  change,  abiotic  resource  depletion  and  freshwater 
aquatic  ecotoxicity.  Greater  material  productivity  in  plastics  would  deliver  the  highest 
contribution  to  reduced  environmental  impacts.  In  relation  to  greenhouse  gases,  plastic 
showed the highest potential for reductions, together with biomass and metals47.  

4. 

THE INTERNATIONAL DIMENSION 

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

Recent  UN  resolutions,  global  environmental  agreements  and  decisions  of  international 
agencies  have  raised  international  attention  to  the  problem.  The  5th  international  Marine 
Debris  Conference  in  Honolulu,  co-organised  by  UNEP  and  the  NOAA48  in  March  2011, 
could be a first step towards a global strategy and action plans on plastic marine pollution. It 
identified  poorly  developed  waste  management  systems  in  large  parts  of  the  world  as  an 
overriding issue because they are the major factor affecting the transfer of land based plastic 
litter into the marine environment. Capacity building in waste management is an area where 
more efforts are needed49.  

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

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

44 

45 
46 

47 
48 
49 

Roadmap to a resource efficient Europe COM (2011) 571 final; for accompanying staff working papers, 
see: http://ec.europa.eu/environment/resource_efficiency/pdf/com2011_571.pdf. 
(BIOIS) implementing EU waste legislation for green growth, final report, p. 187. 
Trendresearch:  Der  Markt  für  das  Recycling  von  Kunststoffen  in  Mitteleuropa,  Marktentwicklung, 
technische Machbarkeit und ökologischer Nutzen, Bremen, 2011. 
(BIOIS) (2011) Analysis of the Key Contributions to Resource Efficiency, final report, p. 101. 
National Oceanic and Atmospheric Administration. 
GESAMP (2010), loc.cit., Rep. Stud. No. 82, 68 pp., p.31. 

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5. 

POLICY OPTIONS FOR IMPROVING MANAGEMENT OF PLASTIC WASTE IN EUROPE 

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

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

5.1. 

Application of the waste hierarchy to plastic waste management 

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

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

However,  some  Member  States  with  high  recovery  rates  and  landfill  bans  still  have  modest 
plastic  recycling  rates  of  around  28%  on  average50.  The  present  ratio  between  plastic 
recycling  and  plastic  waste  energy  recovery  could  be  improved  via  measures  on  separate 
collection,  sorting  and  material  recovery.  A 
landfill  ban  generating  an  automatic 
preponderance  of  energy  recovery  over  recycling  would  not  be  in  line  with  the  waste 
hierarchy. It may be useful to reflect on how economic instruments could be used to steer the 
waste  flow  through  the  waste  hierarchy,  avoiding  a  "vacuum  cleaner  effect"  in  favour  of 
waste to energy. 

Nearly  50%  on  average  of  all  plastic  in  the  EU  goes  to  landfill,  most  of  it  packaging.  The 
widespread  absence  of  separate  waste  collection  and  the  lack  of  other  alternatives  in  many 

50 

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

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Member States help explain the high disposal rate of plastic in landfills51. Landfilled plastic 
contributes nothing to material recovery and energy recovery and is therefore highly resource 
inefficient.  A  study  on  European  waste  generation  projections  to  2035  assessed  the 
introduction  of  strong  policies  to  extend  recycling,  and  found  plastic  to  have  the  largest 
potential for reducing the environmental impacts of waste52.  

Questions: 

(1) 

(2) 

(3) 

(4) 

(5) 

(6) 

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

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

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

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

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

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

5.2. 

Achievement of targets, plastic recycling and voluntary initiatives 

Targets and exports of plastic waste 

Approximately 16 Mt/year of plastic waste could be recycled if all current recycling targets 
were  met  for  municipal  solid  waste,  construction  and  demolition  (C&D)  waste,  end-of-life 
vehicles  (ELV),  Packaging,  Battery  and  WEEE.  This  figure  suggests  that  there  is 
approximately another 9 Mt of plastic waste (out of the total 24.9 Mt) not specifically covered 
by  mandatory  reuse/recovery  targets;  mainly  plastic  in  furniture  and  equipment  other  than 
EEE53.  The  Packaging  Directive  is  the  only  EU  legal  instrument  establishing  a  specific 
recycling  target  for  plastic  packaging.  It  could  be  considered  to  set  further  specific  plastic 
waste recycling targets beyond plastic packaging waste. 

Recycling  targets  in  European  waste  legislation  may  also  have  boosted  the  supply  of 
recyclable waste, as the EEA concludes54. This, together with high prices paid by the booming 
Asian  economy  let  plastic  waste  exports  to  Asia  exponentially  increase  during  the  last  10 
years. While this is not objectionable in itself, it may be argued that recycling plastic waste in 
Europe is, in environmental terms, a better option and that plastic waste exported to non-EU 
countries should be recycled in facilities complying with standards equivalent to those applied 

51 

52 
53 
54 

BiPRO,  Organisation  of  awareness  raising  events  concerning  the  implementation  of  Directive 
1999/31/EC on the landfill of waste, Final Report, 30 May 2007, p. 17. 
FORWAST,2010, Policy recommendations, loc.cit.  
(BIOIS)(2011), Study on coherence of waste legislation , loc.cit., p. 30. 
EEA Report No.7/2012, Copenhagen 2012, “movements of waste across the EU’s internal and external 
borders“, p. 21. 

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in the EU. Export of plastic waste ending up in substandard facilities or being disposed could 
contravene the environmental objective of resource conservation spelled out in the WFD.  

(7) 

(8) 

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

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

Voluntary Action 

Voluntary  action  could  also  help  significantly  ease  the  problem  of  plastic  waste  in  the 
environment and contribute to minimising resource use. An obvious low hanging fruit would 
be plastic packaging waste, contributing to 63% of the total plastic waste generated. Setting 
up "sustainable packaging guidelines" to which producers and retailers would commit could 
be  a  step  in  the  right  direction.  Such  an  initiative  could  comprise  setting  parameters  for 
measuring  sustainability  of  packaging,  best  available  techniques  for  plastic  packaging 
producers,  an  independent  labelling  system  to  measure  consumers'  individual  footprints, 
information  campaigns  raising  consumer  awareness  for  plastic  hazards  and  plastic  disposal 
and  organising  separate  collection.  Existing  initiatives  such  as  the  European  Retail  Forum, 
EUROPEN, the PET bottle platform and Vinyl 2010+ could bundle their initiatives towards 
more  sustainable  plastic  production  and  disposal.  Similar  schemes  could  be  set  up  for 
collection and recovery of non-packaging agricultural plastics which are easy to recycle due 
to their uniform chemical composition. The UK "Agricultural Waste Plastics Collection and 
Recovery Programme" could serve as an example55. Similar initiatives could concentrate on 
WEEE  and  ELV  plastic,  which  account  for  10%  of  European  plastic  waste.  Finally, 
producers'  investment  in  improved  product  design  will  become  a  more  important  driver  to 
reduce  plastic  waste.  Article  8  of  the  WFD  points  in  that  direction  and  early  voluntary 
adaptation might lead to better results than change imposed by legislation.  

(9) 

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

5.3. 

Targeting consumer behaviour 

Giving plastic a value 

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

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

Questions: 

55 

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

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(10) 

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

Empowering consumers to know what they buy 

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

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

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

Question: 

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

Towards more sustainable plastics  

5.4. 
Plastic design for easy and economic cradle-to-cradle recycling56 

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

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

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

56 

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

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Question: 

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

recyclability?  

(13) 

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

New challenges through innovative materials 

New risks may arise from the use of innovative materials such as nano-materials, for example 
in bottles made from polyethylene terephthalate (PET)57 or packaging in general, or providing 
selective  gas  penetration  in  food  packaging,  or  from  nano-sensors  to  detect  food  spoilage58. 
The EU's approach is to assess the risks of individual nano-materials on a case by case basis. 
The  assessment  of  potential  environmental  and  health  risks  is,  however,  difficult  due  to  the 
scarcity  of  environmental  and  toxicological  data.  A  now  existing  common  European 
definition  of  nano-materials  may  facilitate  more  effective  generation  and  collection  of  such 
relevant data59.  

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

Question: 

(14) 

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

5.5. 

Durability of plastics and plastic products  

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

Product design for a longer life, reuse and repair 

To ensure sustainability in production and consumption of plastic goods, and to avoid the loss 
of non-renewable natural resources, plastic goods should be designed to maximize durability. 
There are several adverse functions making this a difficult goal to attain, such as planned or 
technical obsolescence60, as well as designs that make repair of plastic products uneconomic 
or even technically impossible.  

57 

58 

59 

60 

Centre  for  Technology  Assessment.  Dinner  is  served!  Nanotechnology  in  the  kitchen  and  in  the 
shopping  basket  –  Abstract  of  the  TA-SWISS  study  “Nanotechnology  in  the  food  sector”.  2009:  
www.ta-swiss.ch/a/nano_nafo/KF_Nano_im_Lebensmittelbereich.pdf. 
Busch  L.  Nanotechnologies,  food,  and  agriculture:  next  big  thing  or  flash  in  the  pan?  Agric  Hum 
Values. 2008;25:215–218; Sozer N., Kokini JL. Nanotechnology and its applications in the food sector. 
Trends Biotechnol. 2009; 27(2): 82-9. 
Commission  Recommendation  of  18  October  2011  on  the  definition  of  nanomaterial  2011/696/EU; 
http://eurlex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2011:275:0038:0040:EN:PDF. 
Planned  obsolescence  is  a  business  strategy  in  which  the  obsolescence  (the  process  of  becoming 
obsolete—that is, unfashionable or no longer usable) of a product is planned and built into it from its 

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

Any design that deliberately makes plastic products impossible to repair should be avoided61. 
Developing requirements or guidelines for reusability and reparability of plastic products is an 
option  to  be  explored.  Some  work  on  the  development  of  methodologies  to  measure 
reusability of products has already started62. One solution might be the development of eco-
design  rules,  setting  particular  criteria  on  reusability,  durability,  reparability  and  modular 
construction, as already envisaged in Art. 9(1) WFD. 

(15) 

(16) 

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

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

Single-use and short-lived plastic products 

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

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

Plastic  carrier  bags  are  emblematic  of  modern  consumer  society,  light,  practical,  with  no 
value, often thrown away after single use. Yet the environmental pressure from plastic carrier 
bags is considerable. In 2010 there were 95.5 billion plastic carrier bags (1.42 Mt) placed on 
the  EU  market,  most  of  them  (92%)  are  for  single  use.  More  worryingly,  plastic  bags 
unnecessarily  add  to  the  plastic  waste  load  in  the  marine  environment,  having  the  same 
detrimental  effect  as  other  plastic  waste.  As  a  striking  example,  plastic  bags  accounted  for 
73% of the waste collected by trawlers along the Tuscany coast64. Subsequent to the public 
consultation on plastic carrier bags held in summer 2011, the European Commission is (as a 
separate initiative) assessing options to reduce single-use plastic carrier bags.  

conception,  see:  Slade,  G.,  “Made  to  Break:  Technology  and  Obsolescence  in  America”,  Harvard 
University Press, 2006. 
Countless electrical appliances such as mobile phone chargers, are hermetically sealed, and cannot be 
opened for repair. 
By the International Electrotechnical Commission (IEC) and Commission services. See: JRC study and 
reports:  "Integration  of  resource  efficiency  and  waste  management  criteria  in  European  product 
policies": http://lct.jrc.ec.europa.eu/assessment/projects#d. 
See http://ec.europa.eu/environment/eussd/product_footprint.htm. 
ARPA, ARPAT, DAPHNE II (2011), L’impatto della plastica e dei sacchetti sull’ambiente marino. 

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63 
64 

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

More  generally,  prices  may  be  distorted  and  discriminate  against  sound  environmental 
practice65. A system reflecting the true environmental costs from extraction of raw materials 
to  production,  distribution  and  disposal  would  encourage  more  sustainable  production  and 
compensate for market failures. Green public procurement and financial instruments such as 
environmental taxes could also help to improve this situation. 

Questions: 

(17) 

(18) 

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

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

5.6. 

Promotion of biodegradable plastics and bio-based plastics 

Biodegradable plastics 

Biodegradable plastic66 products are often perceived as a potential solution to plastic littering 
and  have  attracted  increasing  public  attention.  Although  it  is  still  a  small  segment  of  the 
market, production of biodegradable plastics operates today at industrial scale capacity, with a 
projected increase in Europe from 0.23 Mt/pa in 2007 to 0.93 Mt/pa in 201167.  

The  term  "biodegradable"  itself  may  be  misunderstood  by  customers.  While  they  might 
interpret the labelling "biodegradable" to mean fit for home composting, in reality, the large 
majority  of  biodegradable  plastics  can  only  biodegrade  under  very  specific  conditions  of 
constantly  high  temperature  and  humidity  in  industrial  composting  installations  and  are 
neither fit for home composting nor do they decompose in reasonable time when littered68. A 
clear  distinction  between  home-compostable  and  industrially-compostable  plastics  may  be 
required,  along  with  consumer  education  about  proper  disposal  channels.  Confusion  could 
cause  consumers  to  take  insufficient  care  in  their  disposal  out  of  a  misunderstanding  that 
objects  labelled  as  biodegradable  would  decay  within  short  time  periods  under  natural 
conditions.  

There are also biodegradability claims that should be scrutinized. For example, fragmentation 
of plastic enhanced with an oxidising agent (usually a metal salt) in the presence of oxygen, 
heat and UV light results in microscopic plastic fragments with similar properties as the bulk 
plastic. Oxo-degradation residues may have unclear impacts69. Oxo-degradable plastics might 
risk  contributing  to  the  microplastics  load  reaching  the  marine  environment  and  therefore 

65 
66 

67 

68 
69 

OECD, Environmentally harmful subsidies: challenges for reform, 2005. 
Biodegradable  plastics  shall  be  understood  as  plastics  that  can  be  degraded  by  living  organisms  –  in 
particular  microorganisms  into  water,  CO2,  methane  (CH4)  and  possibly  non-toxic  residues  (i.e. 
biomass). 
(BIOIS)  (2012),  Options  to  improve  the  biodegradability  requirements  in  the  packaging  Directive,  p. 
30. 
(BIOIS) (2012), Options to improve…, loc.cit., p. 21, 34. 
(BIOIS) (2012), Options to improve …, loc.cit., p. 15, 16, 23, 37 

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might  significantly  increase  the  risk  of  ingestion  by  animals70.  The  presence  of  oxidising 
agents in the plastic waste streams may also make plastic recycling more difficult71. It should 
be assessed whether the use of the term biodegradable is at all permissible in this case. 

Another open question is the extent to which biodegradable plastic can be a solution to plastic 
marine pollution. Decomposition in the marine environment depends on many factors, such as 
the  type  of  product,  the  sufficient  presence  of  relevant  micro-organisms,  the  water 
temperature  and  the  density  of  the  product.  In  some  Plastral  Fidene  trials,  a  starch-PCL72 
blend  was  found  to  degrade  in  20  to  30  weeks  in  Australian  waters  while  being  able  to 
degrade in 20-30 days in compost73. Moreover, many biodegradable plastics may not degrade 
in the intestines of marine species and injury is likely to remain an issue.  

There  are  several  barriers  for  biodegradable  plastics  to  achieve  quick  market  penetration. 
Without  further  technical  progress  in  terms  of  their  functional  properties,  they  may  not  be 
suitable  for  some  types  of  packaging  applications,  such  as  for  fresh  food74.  Existing 
manufacturing  chains,  used  to  petro-plastics,  may  need  costly  adaptation  to  function  with 
biodegradable  plastics75.  The  exact 
influence  of  biodegradable  plastic  on  aquatic 
environments, as well as compost toxicity, is yet further to be investigated76. Waste treatment 
systems  already  in  place  are  not  yet  capable  of  separating  sufficiently  biodegradable  plastic 
from  conventional  plastic  which  can  jeopardize  recycling  processes.  Technical  adaptation 
might increase separation costs because more sophisticated equipment is likely to be required.  

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

(19)  What  are  the  applications  for  which  biodegradable  plastics  deserve  to  be 

promoted, what framework conditions should apply? 

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

(21)  Would the use of oxo-degradable plastic require any kind of intervention with a 

view to safeguarding recycling processes, and if so, on which level?  

Bio-based plastics 

While  the  market  is  still  dominated  for  over  99%  by  petroleum-based  plastic77,  there  is  an 
emerging  and  growing  market  for  bio-based  plastic  produced  from  renewable  resources78. 
Current bio-based plastics are usually made from starch extracted from maize, rice, sugar cane 
or potatoes. 

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Gregory,M.R.,  &  Andrady,  A.L.(2003)  Plastics  in  the  marine  environment,  in:  A.L.Andrady  (Ed.), 
Plastics in the Environment, Hoboken, N.J.:Wiley-Interscience, pp. 379-402. 
STAP  (2011).  Marine  Debris  as  a  Global  Environmental  Problem.  Global  Environmental  Facility, 
Washington, DC. 2011, p.21. 
Polycaprolactone (PCL). 
Nolan-ITUPty,  Ltd,  2002,  Report  on  Biodegradable  Plastics  –  Developments  and  Environmental 
Impacts. 
(BIOIS) Plastic waste in the Environment, loc.cit., p. 61. 
(BIOIS) (2012), Options to improve…, loc.cit., p. 47/48. 
For further reference, see: BIOIS (2012), Options to improve…, loc.cit., p. 43. 
EUROPEN, 2011, Packaging and Packaging Waste Statistics in Europe: 1998-2008. 
Plastic waste in the Environment, loc.cit, p. 13. 

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The  prefix  "bio-based",  is  clearly  defined  by  the  European  Committee  for  Standardization 
(CEN)79.  Yet,  consumers  need  to  be  fully  informed  that  this  relates  to  the  origin  of  the 
resource and not to end of life management. Although the majority of biodegradable plastics 
are  currently  bio-based  plastics,  biodegradable  plastics  can  also  be  made  from  petroleum 
based  or  a  combination  of  petroleum  and  bio-based  resources.  Moreover,  some  bio-based 
polymers,  such  as  polyethylene  (PE)  from  bio-ethanol  are  not  biodegradable.  Competition 
with  food  production,  already  broadly  discussed  in  the  context  of  biofuels,  is  a  problematic 
and highly  disputed issue  for bio-based plastics. A significant increase in bio-based plastics 
production  to  a  level  comparable  to  conventional  plastics  might  negatively  impact  on  the 
production of food crops used to make bio-based plastics. This could have a negative impact 
on developing economies and economies in transition. A link between the rises in corn prices 
subsequent  to  the  rise  in  ethanol  production  2008  in  the  US  has  been  documented80.  An 
increase  in  land  use  and  raw  material  prices  might  result,  as  well  as  a  loss  of  biodiversity 
through  transformation  of  idle  land  and  forests  into  fields,  increasing  agricultural 
consumption  of  water  and  fertilizers.  Such  concerns  would  not  apply  to  bio-based  plastics 
made from agricultural waste and food-crops by-products or saltwater algae.  

Question: 

(22) 

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

5.7. 

EU initiatives dealing with marine litter including plastic waste  

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

In  2010  the  Commission  outlined  criteria  for  Member  States  to  assess  the  environmental 
status of their seas in the context of MSFD81. Several of these criteria relate to marine litter. A 
Working  Group  on  marine  litter  has  developed  an  overview  of  existing  data  and 
methodologies  for  the  monitoring  of  marine  litter,  as  required  by  the  MSFD.  It  underlined 
both the seriousness of the issue and the urgent need for further coordinated research to ensure 
a common approach to monitoring and mitigation. The group continues to work on (inter alia) 
the harmonisation of monitoring, estimating the costs involved and assessing the harm done 
by marine litter82. 
In  parallel,  the  Commission  has  started  a  dialogue  with  stakeholders  (plastic  producers, 
recyclers,  retailers,  packing  industry,  port  and  shipping  authorities,  NGO's)  to  develop 
partnerships and voluntary actions to address marine litter. Furthermore, there are a number of 
projects and initiatives on-going which aim at understanding better the sources and impacts of 
marine  litter  as  well  as  the  possible  solutions.  An  overview  of  all  initiatives  and  potential 

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ftp://ftp.cen.eu/CEN/Sectors/List/bio_basedproducts/BTWG209finalreport.pdf 
Fortenbery, Randall T. and Park, Hwanil (2008). The Effect of Ethanol Production on the U.S. National 
Corn Price, Staff Paper Series, University of Wisconsin-Madison.  
2010/477/EU of 1st September 2010. 
JRC,  Marine  Litter  –  Technical  Recommendations  for  the  Implementation  of  MSFD  Requirements, 
EUR 25009 EN, Luxemburg 2011. 

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measures  that  address  this  problem  is  given  in  a  separate  Commission  Staff  Working 
Document SWD (2012) 365. 

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

Within some Regional Seas Conventions, action plans on marine litter are under development. 
For  the  Mediterranean,  strategy  on  marine  litter  was  endorsed  in  February  201283.  For  the 
North East Atlantic, next to its marine action plan, 'Fishing for Litter' will be implemented in 
more  areas  of  the  Convention.  In  addition,  there  are  many  initiatives  at  EU  level  including 
policy developments which take increasing account of the marine litter impacts, such as the 
revision  of  the  Port  Reception  Facility  Directive  (see  CSWD  for  more  complete  overview). 
EU waste policy already provides many provisions which, if fully implemented, would reduce 
the marine litter problem significantly. This Green Paper sets out a number of further policy 
options  which  would  help  to  reduce  marine  litter.  However,  there  are  many  other  actions 
outside  the  scope  of  this  Green  Paper  which  would  need  to  be  taken,  such  as  conducting 
behavioural  studies  for  improving  the  understanding  for  how  to  go  about  raising  consumer 
awareness.  

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

Questions: 

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

(24) 

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

5.8. 

International action 

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

The  “new  strategic  framework”  for  2012  –  2021,  adopted  at  the  10th  Conference  of  the 
Parties (CoP) of the Basel Convention in 2011 includes environmentally sound management 
(ESM) in waste prevention and minimization in its strategic goals. The CoP also decided to 

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

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mandate  a  technical  expert  group  to  develop  a  framework  for  the  environmentally  sound 
management of waste on the international level84.  

More  recently,  the  Global  Partnership  on  Waste  Management  (GPWM)  UNEP  IETC85 
established  in  2010,  tries  to  promote  internationally  a  holistic  approach  on  waste 
management, serving as a platform to enhance international cooperation among stakeholders. 
Work plans for sponsored focal areas such as solid waste management, marine litter and waste 
minimization,  all  of  crucial  importance  for  plastic  waste  management  internationally,  are 
being developed. A focal area for plastic waste could be envisaged. 

The  EU’s  “new  neighbourhood  policy”  (ENP)  and  pre-accession  policy  may  play  a  useful 
role in promoting action to improve plastic waste management and address current challenges. 
For  instance,  the  involvement  of  neighbouring  states  in  the  southern  Mediterranean  and  the 
Black Sea region are very essential to achieve the -plastic free - good environmental status of 
the Mediterranean and the Black Sea86.  

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

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

Questions: 

(25) 

(26) 

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

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

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UNEP/CHW.10/CRP.25 of 20 October 2011. 
http://www.unep.or.jp/Ietc/SPC/activities/GPWM/GPWMFrameworkDocumentv.11282011.pdf. 
56% of municipal solid waste is landfilled in unregulated dump sites in Turkey. 

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