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
Date: 2018-01-16
Institutions: European Commission, Secretariat-General
Subjects: environmental impact, environmental protection, innovation, plastics, pollution, pollution control measures, storage of waste, waste, waste disposal, waste recycling

EN 

  EN 

   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 
2 

Introduction ............................................................................................................................. 3 
Taking the opportunity: re-inventing plastics ......................................................................... 5 
Importance of plastics and the plastics industry ............................................................. 5 

2.1 

2.1.1 

2.1.2 

2.1.3 

Current uses of plastics ........................................................................................... 5 

Feedstock for plastics .............................................................................................. 6 

The European plastics industry ............................................................................... 8 

2.2 

Environmental impacts ................................................................................................. 10 

2.2.1 

2.2.2 

Causes, pathways and figures ............................................................................... 10 

Impacts on the environment, health and economy .............................................. 15 

2.3  Moving towards more circular plastics ......................................................................... 17 

2.3.1 

2.3.2 

2.3.3 

Linear vs. circular: a new approach for the plastics life-cycle ............................... 17 

Plastics produced in a circular value chain ............................................................ 18 

Enhanced circularity of plastics improving reuse and recycling rates .................. 19 

3 

Improving the economics and quality of plastics recycling................................................... 22 
Design for recyclability .................................................................................................. 22 

3.1 

3.1.1 

3.1.2 

3.1.3 

Issues at stake ....................................................................................................... 22 

Existing EU measures............................................................................................. 29 

Actions to be taken ............................................................................................... 30 

3.2 

Boosting demand for recycled plastics ......................................................................... 32 

3.2.1 

3.2.2 

3.2.3 

Issues at stake ....................................................................................................... 32 

Existing EU measures............................................................................................. 39 

Actions to be taken ............................................................................................... 40 

3.3 

Better and more harmonised separate collection and sorting ..................................... 42 

3.3.1 

3.3.2 

3.3.3 

Issues at stake ....................................................................................................... 42 

Existing EU measures............................................................................................. 47 

Actions to be taken ............................................................................................... 48 

4 

Curbing plastic waste and littering ........................................................................................ 49 
Preventing plastic waste in our environment ............................................................... 49 

4.1 

4.1.1 

4.1.2 

4.1.3 

Single use plastics .................................................................................................. 49 

Over-packaging ...................................................................................................... 56 

Plastic waste from sea-based sources: shipping, fishing and aquaculture products
57 

4.1.4 

Agricultural plastics ............................................................................................... 64 

4.2 

Establishing a clear regulatory framework for biodegradable plastics ......................... 69 

4.2.1 

4.2.2 

Issues at stake ....................................................................................................... 69 

Actions to be taken ............................................................................................... 73 

4.3 

Oxo-degradable plastics: addressing the growing concerns ......................................... 74 

4.3.1 

Issues at stake ....................................................................................................... 74 

1 

 
 
 
4.3.2 

Actions to be taken ............................................................................................... 76 

4.4 

The rising problem of micro-plastics ............................................................................. 76 

4.4.1 

4.4.2 

Issues at stake ....................................................................................................... 76 

Actions to be taken ............................................................................................... 80 

5 

Driving investment and innovation towards circular solutions ............................................ 84 
Issues at stake ............................................................................................................... 84 

5.1 

5.1.1 

5.1.2 

5.1.3 

5.1.4 

5.1.5 

Support the necessary investments ...................................................................... 84 

EPR fee modulation and more transparency ........................................................ 86 

Deposit return schemes (DRS)............................................................................... 87 

Innovation for more circularity ............................................................................. 89 

Specific actions to diversify the feedstock ............................................................ 89 

5.2 

Existing EU measures .................................................................................................... 89 

5.2.1 

5.2.2 

Supporting the necessary investments ................................................................. 89 

Enhancing Public Procurement and Ecolabel ........................................................ 91 

5.2.3 
possibility for fee modulation for EPR schemes .................................................................... 92 

The Commission proposal to introduce minimum requirements and providing a 

5.2.4 

Deposit-return schemes (DRS) .............................................................................. 94 

5.3 

Actions to be taken ....................................................................................................... 94 

5.3.1 

5.3.2 

5.3.3 

Guidance on EPR fee modulation .......................................................................... 94 

Establishment of EPR schemes for a wider plastic product categories ................ 94 

Actions to support innovation and research ......................................................... 95 

6 

Harnessing global action ....................................................................................................... 99 
Issues at stake ............................................................................................................... 99 

6.1 

6.2 

Existing EU actions ......................................................................................................... 99 

6.2.1 
agreements ........................................................................................................................... 99 

Multilateral cooperation at the United Nations and through environmental 

6.2.2 

6.2.3 

6.2.4 

G7 and G20 .......................................................................................................... 102 

Bilateral and regional cooperation ...................................................................... 102 

Relevant EU policies and programmes with an international dimension ........... 103 

6.3 

Actions to be taken ..................................................................................................... 105 

6.3.1 

6.3.2 

6.3.3 

UN Level .............................................................................................................. 105 

G7 and G20 .......................................................................................................... 106 

EU international actions ...................................................................................... 107 

Annex I Problem and solution mapping .................................................................................. 110 

Annex II Standards for bio-based and biodegradable plastics ................................................ 118 

Annex III EU Cohesion Policy programs: examples of funded projects related to plastics ..... 122 

2 

 
 
 
 
 
1  Introduction   

Back  in  2013,  the  European  Commission  launched  a  broad  reflexion1  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"2. 

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 plastics3.    

The  recently  published  EU  Industrial  Policy  Strategy4  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 
intent5,  the  Commission  has  also  announced  that  such  strategy  "will  work  towards  all  plastic 
packaging being recyclable by 2030".  

This new initiative on plastics6 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 

1 Green Paper On a European Strategy on Plastic Waste in the Environment COM/2013/0123 final  

2 COM/2015/0614 final 

3 Roadmap "Analysis of the interface between chemicals, products and waste legislation"; 27 January 2017  

4 Investing in a smart, innovative and sustainable Industry A renewed EU Industrial Policy Strategy 

COM/2017/0479 final 

5 State of the Union 2017 Letter of intent to President Antonio Tajani and to Prime Minister Jüri Ratas; 

Strasbourg, 13 September 2017  

6 Roadmap "Strategy on Plastics in a Circular Economy"; 26 January 2017  

3 

 
 
                                                            
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 
studies7 were launched and contributed to gathering the knowledge gaps. Targeted stakeholder 
consultations,  workshops  and  a  major  stakeholders'  conference8  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 commitments9. 

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. 

7 "Intentionally added micro-plastics in products"; "Micro-plastics generated from but not intentionally added 

in products"; "Plastics: reuse, recycling and marine litter" (Draft final report available, the study carried out by 

Eunomia will be published in 2018)  

8 "Re-inventing Plastics Closing the circle" of 26 September 2017  

9 JOIN(2016) 49 final: International ocean governance: an agenda for the future of our oceans 

4 

 
 
 
 
                                                            
2  Taking the opportunity: re-inventing plastics   

2.1  Importance of plastics and the plastics industry  

2.1.1  Current 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 polymer10.  

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 products11.  

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  Europe12, 
different types of polymers respond to different type of needs.  

Figure 1. Plastic materials main fields of application. 

Source: Plastics Europe (2016). Plastics - the Facts 2016 

10 Source: Plastics Europe  

11 http://www.sciencedirect.com/science/article/pii/S0306374714701125  

12 http://www.plasticseurope.org/documents/document/20161014113313-

plastics_the_facts_2016_final_version.pdf  

5 

 
 
 
                                                            
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.13 

Figure 2. Distribution of European (EU-28+NO/CH) plastics demand by segment in 2015  

Source: Plastics Europe (2016). Plastics - the Facts 2016 

2.1.2  Feedstock 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

14.  

13 http://www.plasticseurope.org/documents/document/20161014113313-

plastics_the_facts_2016_final_version.pdf  

14 http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52007SC1730  

6 

 
 
 
 
                                                            
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)15.  Bio-based  plastics  have  the  same  properties  as 
conventional plastics but are derived from biomass16. 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 properties17.  

Additionally  to  these  two  sources  of  feedstock,  recently,  several  companies18  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 compounding19. 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.  

15 European Centre for Ecotoxicology and toxicology of chemicals, Technical report 123, Definitions according 

to OECD 

16 as defined in European Standard EN 16575 

17 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). 

18 See for example the German based company Covestro https://www.co2-dreams.covestro.com/  

19 http://www.plasticsrecyclers.eu/mechanical-recycling  
7 

 
 
                                                            
2.1.3  The 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%20.  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)21. 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  rapidly22.  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 
product23 (see  Figure 3). 

Figure 3. World production of plastic materials by region (2013) 

International  trade 
increasing.  With  global  production  of  plastics 
skyrocketing  and  a  continuing  shift  of  production  from  the  West  to  Asia  (more  than  40%  by 

in  waste  plastics 

is 

20 Reflection paper on harnessing globalisation, COM(2017) 240. 

21 Facts and figures about the EU and the G20, 7-8 July 2017, DG Communication – Spokesperson’s Service, 

European Commission. 

22 Vital Signs (2015), Global Plastic Production Rises, Recycling Lags http://vitalsigns.worldwatch.org/ 

sites/default/files/vital_signs_trend_plastic_full_pdf.pdf  

23 Plastics Europe, Plastics – the Facts 2015 – An Analysis of European plastics production, demand and waste 

data, note 65. 

8 

 
 
 
 
                                                            
weight of world production in 2013), the annual volume of transnationally traded waste plastics 
is 15 million tonnes24. 

Figure 4. Share in world imports of waste (parings and scrap) of plastic25 

labour-intensive, 

According to EU estimates, about half of the plastics waste collected in the EU for recycling is 
low-tech  processes  remain 
exported  to  third  countries,  where  more 
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 
waste26. 

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 

24 UNEP-ISWA Global Waste Management Outlook 2015, p.84. 

25 ITC calculations based on UN COMTRADE and ITC statistics. 

26 WTO Notification G/TBT/N/CHN/1211 of 18 July 2017, 

https://www.wto.org/english/news_e/news17_e/impl_03oct17_e.htm 

9 

 
 
 
                                                            
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 
i.e.  the  0.9%  of  total  EU 
factor  costs),  the  sector  generated  15  billion  EUR, 
manufacturing.27 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. 28   
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 added29. Information 
on the specific share of plastic however is not available. 

 

2.2  Environmental impacts  

2.2.1  Causes, 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.30 

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 environment31. 

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. 

27 Eurostat, Structural Business Statistics 

28 Eurostat, Structural Business Statistics 

29 Assuming the share of SMEs in chapter E383 is also valid for subchapter E3832.  
30 COM(2013) 123, GREEN PAPER on a European Strategy on Plastic Waste in the Environment 
31 European Commission (2017) Special Eurobarometer 468 Report Attitudes of European citizens  towards the 

environment 

10 

 
 
                                                            
A  frequently  quoted  study32  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 

Figure 5. Plastic waste available to enter the oceans (million tonnes) (2010)33 

A recent assessment concludes that 79% of the plastic waste generated since the beginning of 
plastic production has accumulated in landfills or the natural environment34, with uncontrolled 
disposal  still  being  a  major  problem,  predominantly  in  developing  countries35.  According  to 
Jambek  et  al.  (2015)36,  over  50%  of  the  global  leakage  into  the  marine  environment  currently 
comes from five emerging markets in Asia (see Error! Reference source not found.). 

32 Jenna R. Jambeck et al. (2015), Plastic waste inputs from land into the ocean, Science, 347 (6223), 768-771 

(DOI: 10.1126/science.1260352), http://science.sciencemag.org/content/347/6223/768 

33 Global map with each country shaded according to the estimated mass of mismanaged waste (million 

tonnes) generated in 2010. Countries not included in the study are shaded in white (Jambeck et al., 2015, p. 

769). 

34 Geyer et al. (2017), Production, use, and fate of all plastics ever made, Science Advances, 3 (7), e1700782 
(DOI: 10.1126/sciadv.1700782). 
35 According to Global Waste Management Outlook (2015), 2 billion people are still without access to solid 

waste collection, and 3 billion people lack access to controlled waste disposal facilities. 

36 Jenna R. Jambeck et al. (2015), Plastic waste inputs from land into the ocean, Science, 347 (6223), 768-771 

(DOI: 10.1126/science.1260352) 

11 

 
 
 
 
 
                                                            
Table 1. Waste estimates for 2010 for the top 20 countries ranked by mass of mismanaged plastic 
waste (in units of millions of metric tons per year)37 

Research shows that river networks can facilitate the transport of plastics thus connecting most 
of the global land surface to the ocean38. 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 
Regulation39. 

37 Jambek et al. (2015), op. cit. 

38 Christian Schmidt, Tobias Krauth, Stephan Wagner. Export of Plastic Debris by Rivers into the Sea. 

Environmental Science & Technology, 2017; DOI: 10.1021/acs.est.7b02368. 

39 Council Regulation (EC) No 1224/2009 of 20 November 2009 establishing a Community control system for 

ensuring compliance with the rules of the common fisheries policy 

12 

 
 
 
 
 
                                                            
Figure 6. The top-10 rivers for land-based contribution to marine litter40 

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  Ghent41  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  EU42. 

40 Source of the data: Christian Schmidt, Tobias Krauth, Stephan Wagner. Export of Plastic Debris by Rivers 

into the Sea. Environmental Science & Technology, 2017; DOI: 10.1021/acs.est.7b02368. Source of the map: 

European Commission. 

41 Unpublished study cited in http://news.sky.com/story/micro-plastics-in-seafood-could-be-a-health-risk-

experts-fear-10739835 

42 http://ec.europa.eu/environment/marine/good-environmental-status/descriptor-

10/pdf/MSFD%20Measures%20to%20Combat%20Marine%20Litter.pdf 

13 

 
 
 
                                                            
Updated calculations43 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)44.  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).   

Figure 7. Size distribution and aspect of the floating plastic debris collected in the Mediterranean Sea45 

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  term46.  See 
Figure 8 concentrations of plastic debris in surface waters of the Mediterranean Sea compared 
to the plastic concentrations reported for the global ocean47. 

43 EU microplastics. Ongoing study for the Commission : http://www.eumicroplastics.com/eumpwp/wp-

content/uploads/investigating-options-eunomia-draft-report-v4-main-report-public.pdf 

44 PLOS, A Cozar, Plastic Accumulation in the Mediterranean Sea, 2015. 

45 Ibidem 

46 Ibidem 

47 Ibidem 

14 

 
 
 
 
 
                                                            
Figure 8. Concentrations of plastic debris in surface waters of the Mediterranean Sea compared to the 
plastic concentrations reported for the global ocean48 

2.2.2 

Impacts 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  dump49,  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 entanglement50 (e.g. from ghost nets51) 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  structure52.  Most  plastic 
debris eventually comes to rest on the seabed53.  

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 

48 Ibidem 

49 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. 13. 

50 UNEP, 2009, Marine Litter: A global challenge, http://www.unep.org/pdf/unep_marine_litter-

a_global_challenge.pdf. 

51 A phenomenon by which large lumps of derelict fishing nets float in water, unintentionally catching large 

amounts of fish.  

52 Deudero S., Alomar C. (2015) "Mediterranean marine biodiversity under threat: Reviewing influence of 

marine litter on species" in Marine Pollution Bulletin, Volume 98, Issues 1–2: 58-68 

53 Near large cities and offshore canyons, the density could extend to 100,000 pieces per square kilometre. 

See further: Wurpel, G. loc.cit., p. 32, 35. 

15 

 
 
 
                                                            
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 harm54. 

Micro-plastics are ubiquitous and reach even the most remote areas55 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  quantities56  57.  Persistent  organic  pollutants  (POPs),  such  as 
pesticides like DDT and polychlorinated biphenyls (PCBs)58 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  harmful59  and  enter  the  food 
chain via marine fauna which ingest the plastics (Trojan horse effect)60. These POPs do not break 
down  naturally  very  easily  but  accumulate  in  body  tissue,  potentially  having  carcinogenic, 
mutagenic and other health effects61.  

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 
remains62.  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 projects63 have shown some progresses made regarding this issue.  

54 https://ec.europa.eu/jrc/en/publication/harm-caused-marine-litter 
55 BIOIS,Plastic waste in the Environment, loc.cit, p. 114. 
56 Most additives are fillers and reinforcements,, plasticizers, colorants, stabilizers, processing aids, flame 
retardants, peroxides and antistats, each representing a whole family of chemicals. 

57 COM(2013) 123, GREEN PAPER on a European Strategy on Plastic Waste in the Environment 
58 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. 
59 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. 
60 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. 
61 BIOIS (2010) Plastic waste in the Environment, final report, European Commission, p. 117 

http://ec.europa.eu/environment/waste/studies/pdf/plastics.pdf   

62 https://wedocs.unep.org/bitstream/handle/20.500.11822/7468/-

Biodegradable_Plastics_and_Marine_Litter_Misconceptions,_concerns_and_impacts_on_marine_environments-

2015BiodegradablePlasticsAndMarineLitter.pdf.pdf?sequence=3&isAllowed=y  

63 Bio-based biodegradable PHA/PHB EU FP7 Open-Bio project – Marine biodegradation work package 

16 

 
 
 
 
                                                            
Box 1. Economic impacts from environmental externalities 

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. 

2.3  Moving towards more circular plastics  

2.3.1  Linear 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 201564 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). 

64 Source: Eurostat: http://ec.europa.eu/eurostat/statistics-explained/index.php/Packaging_waste_statistics  
17 

 
 
 
                                                            
Figure 9. Waste treatment evolution 2006-2014 

Source: Plastics Europe (2016). Plastics - the Facts 2016 

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. 

2.3.2  Plastics 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.  

18 

 
 
 
Figure 10. Circular plastics value chain 

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. 

2.3.3  Enhanced 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 

19 

 
 
 
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 generated65. 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 

65 Source Eurostat http://ec.europa.eu/eurostat/web/circular-economy/indicators/monitoring-framework 

20 

 
 
                                                            
34% sent to landfill66. 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  yearly67,  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 tonnes68. The quantity of plastic recyclate from the EU WEEE collected is 
estimated to be around 0.5 million tonnes. 

66 Consultic (2014) Post-Consumer Plastic Waste Management in European Countries 2014, Report for 

PlasticsEurope, 15th October 2015 

67 Eurostat WEEE statistics http://appsso.eurostat.ec.europa.eu/nui/submitViewTableAction.do  

68 Eunomia 2017 and own calculations 

21 

 
 
 
 
                                                            
3  Improving  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.  

3.1  Design 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.  

3.1.1 

Issues 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 

22 

 
 
are  either  natural  or  synthetic  organic  compounds.  The  term  resin  is  sometimes  used  as 
synonym of a commercial polymer69.  

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 products70.  

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, 
formation  resistance,  or  behaviour  during 
manufacture),  some  additives  cause  some  problems  during  the  recycling  phase  or  may  be 
hazardous substances.  

flame 

Table 2. List of additives used in plastics 

Function 

Antioxidants 

Antistatic Agents 

Antimicrobials/ 
Biostabilisers 

Type 
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. 
Help prevent deterioration of plastic materials where part of the material might be 
to  microbiological  attack.  Such  attacks  can  cause  staining, 
susceptible 
discolouration, odour and loss of aesthetics but more importantly, loss of electrical 
insulating  properties,  hygiene  and  overall  loss  of  mechanical  properties  in  the 
material. 
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. 
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. 
Used to make plastics softer and more flexible and to enhance the degradability of 
the product. 
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. 
To  prevent  damage  to  plastics  or  the  mould  during  processing.  Applied  to  the 
material or directly to the machine to allow processing without damage. 
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. 
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 

Biodegradable 
Plasticisers 
Blowing Agents 

External Lubricants 

Flame Retardants 

Fillers/ Extenders 

69 Source: Plastics Europe  

70 http://www.sciencedirect.com/science/article/pii/S0306374714701125 

23 

 
 
                                                            
Fragrances 

Heat Stabilisers 

Impact Modifiers 

fire  safety  standards  either  by  mandatory  regulations  or  voluntary  standards.  
Flame retardants are added to plastics to meet these requirements. 
Fragrances  and  deodorants  for  plastics  are  used  in  a  variety  of  applications  and 
products for the home. 
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 
Enables  plastic  products  to  absorb  shocks  and  resist  impact  without  cracking. 
Particularly 
(PS)  and 
polypropylene (PP) materials. 

for  polyvinyl  chloride 

(PVC),  polystyrene 

relevant 

Light Stabilisers 

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). 
Used  to  inhibit  the  reactions  in  plastics  which  cause  undesirable  chemical 
degradation from exposure to UV light. 
Tiny particles used to create a particular colour. 
Used to make plastics softer and more flexible. 
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. 
Used to reinforce or improve tensile strength, flexural strength and stiffness of the 
material. Often fibre-based. 

Pigments 
Plasticisers 
Process Aids 

Reinforcements 

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 worldwide71, 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 market72.  

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 
polypropylene73.  

71 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. 

72 JRC Technical report "End-of-waste criteria for waste plastic for conversion" Technical proposals 2014  

73 http://www.sciencedirect.com/science/article/pii/S0306374712701306 

24 

 
 
                                                            
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  plant74  is  applying  this  technique  to 
flame  retardant 
recycle  polystyrene  waste  that 
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. 

is  contaminated  with  the  banned 

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. 

74 https://polystyreneloop.org/ 

25 

 
 
                                                            
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. 

Table 3. Examples of design choices and recyclability in plastics 

Examples  of  a  design 
choice  
(e.g.  chalck, 
Fillers 
powder and marble)  

talc 

of 

and 
non-
materials 
PE/aluminium 

Multilayers 
combination 
compatible 
(PE/paper, 
etc.) 
Dark pigments 
Direct  printing  on 
packaging  

the 

Use of inks  

Use of additives  

Negative effects on recyclability  

Fillers  will  increase  the  density  of  polymer.  This  will  lead  to 
material losses during the recycling process.  

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.  
Unpigmented is preferred. Dark recyclates have a lower value.  
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. 
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. 
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  estimated75  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 

75 The Ellen McArthur Foundation, The new Plastic Economy, Catalysing Action, 2017 

26 

 
 
 
                                                            
cutting  by  half  the  cost  of  recycling  plastic  packaging  waste76.  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 difficult77:  

  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 

76 BKV: Potenziale zur Steigerung der werkstofflichen Verwertung von Kunststoffverpackungen –

recyclinggerechtes Design, Sortiertechnik, 2016 quoted in Recycling Magazin 02/2017 

77 BKV: Potenziale zur Steigerung der werkstofflichen Verwertung von Kunststoffverpackungen –

recyclinggerechtes Design, Sortiertechnik, 2016 quoted in Recycling Magazin 02/2017 

27 

 
 
                                                            
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 2005/6478 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  Directive79  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  deconstruction80,  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 costs81. 

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.  

78 On the type-approval of motor vehicles with regard to their reusability, recyclability and recoverability 

79 Directive 2000/53/EC of the European Parliament and of the Council of 18 September 2000 on end-of-life 

vehicles 

80 Complex Waste Plastics Recycling Industry  ‘Wish List’ to promote a rapid transition to a Circular Economy 

81 Interview with EuRIC 

28 

 
 
                                                            
Closed-loop  plastic  recycling  in  automotive  sector  should  be  promoted.  A  further  uptake  of 
recycled plastics originating from cars could be envisaged82. While doing so, it has to be ensured 
that legislation on safety of vehicles is fully complied with83.    

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.   

3.1.2  Existing 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)84. It has also developed criteria to improve recyclability of plastics 
in its Ecolabel and Green Public Procurement criteria85. 

82 David Schönmayr, Automotive Recycling, Plastics, and Sustainability: The Recycling Renaissance, page 157 

(2017) 

83 Interview with European Automobile Manufacturers' Association – ACEA 

84 Assessment of separate collection schemes in the 28 capitals of the EU. Bipro 2015. 

85 For example, marking large plastic parts to facilitate sorting, designing plastic packaging for recyclability, 

and designing items for easy disassembly such as in furniture and computers 

29 

 
 
                                                            
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 economy86. 

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"87,  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. 

3.1.3  Actions 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 

86 for example Erasmus+ Sector Skills Alliance for the design and testing new management skills for the 

development of the Waste Electrical and Electronic Equipment Recycling and Re-use System: 

http://www.ewaster.eu/; 

other education & training projects related to the development of the circular economy can be found here: 

http://ec.europa.eu/programmes/erasmus-

plus/projects/#search/keyword=circular%2Beconomy&matchAllCountries=false 

87 COM(2016) 381 final "A New Skills Agenda for Europe - Working together to strengthen human capital, 

employability and competitiveness" 

30 

 
 
                                                            
recyclability  should  be  clarified.  Potential 
legislations, in particular revised Essential Requirements for Packaging.  

instruments 

include  revised  product  design 

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.  

31 

 
 
3.2  Boosting demand for recycled plastics 

3.2.1 

Issues 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)  88  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.  

88 https://plastics-converters-europe.prezly.com/eupc-publishes-results-of-its-survey-on-the-use-of-

recycled-plastics-materials?asset_type=attachment&asset_id=88881#  

32 

 
 
                                                            
 

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.  

33 

 
 
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  scrap89, 
glass  cullet90  and  copper  scrap91.  For  plastic  waste,  the  European  Commission92  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.   

89 http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32011R0333 

90 http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32012R1179  

91 http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32013R0715  

92 JRC report on end of waste criteria for plastics  

34 

 
 
                                                            
Currently, Food Packaging constitutes approximately 10% of the total plastic market93.  

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. 

93 Non-harmonised food contact materials in the EU: regulatory and market situation; JRC Report; 2016  

35 

 
 
 
 
                                                            
Table 4. Origin of some legacy substances 

Substance  
Toxic  heavy 
metals  

Flame 
retardants  

Plasticisers  

PCBs  

PAH 
(polycyclic 
aromatic 
hydrocarbon) 

Source of contamination  
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)  
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)   
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 
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) 
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 

36 

 
 
 
several  obligations,  including  the  performance  of  risk  assessment  and  the  implementation  of 
protective and preventive measures94.  

limited  (if  any) 

However,  there  are  very 
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 viable95 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 

94 Directive 89/391/EEC on the introduction of measures to encourage improvements in the safety and health 

of workers at work; Directive 98/24/EC - risks related to chemical agents at work of 7 April 1998 on the 

protection of the health and safety of workers from the risks related to chemical agents at work; Directive 

2004/37/EC on the protection of workers from the risks related to exposure to carcinogens or mutagens at 

work. 

95 Conclusions of a workshop on traceability  

37 

 
 
                                                            
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.  

38 

 
 
 
 
Box 2. The case of VinylPlus: long term sustainability framework96 

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 
 
 
 
  move towards a low-carbon circular economy 
  build sustainability awareness along the value chain and among stakeholders. 

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 

3.2.2  Existing 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  framework97  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 consumers98.  

Primary  plastic  materials  used  in  food  contact  materials  are  subject  to  compositional 
requirements set out in specific legislation99. From the legal point of view, there is a distinction 
between  materials  made  from  virgin  plastic  raw  materials  and  recycled  plastic  materials100. 
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 

96 https://vinylplus.eu/  

97 https://ec.europa.eu/food/safety/chemical_safety/food_contact_materials/legislation_en  

98 See Article 3 of Regulation (EC) No 1935/2004 and 

https://ec.europa.eu/food/safety/chemical_safety/food_contact_materials/legislation_en 

99 http://eur-lex.europa.eu/eli/reg/2011/10/oj  

100 http://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:32008R0282  

39 

 
 
 
                                                            
 
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 EFSA101 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  view102.    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 topic103. 

Tracking substances of concern  

The  role  of  enhanced  supply  chain  collaboration,  promoted  by  sectorial  platforms104,  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).  

3.2.3  Actions 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.  

101 https://ec.europa.eu/food/safety/chemical_safety/food_contact_materials/authorisations_en  

102 Vinyl Plus, a program developed by the PVC value chain is an example of such platforms.   

103 http://circulareconomy.europa.eu/platform/en 

104 Scientific and technical support for collecting information on and reviewing available tools to track 

hazardous substances in articles with a view to improve the implementation and enforcement of Article 33 of 

REACH. Published: 11/08/2017. https://publications.europa.eu/en/publication-detail/-

/publication/58f951af-809b-11e7-b5c6-01aa75ed71a1/language-en/format-PDF 

40 

 
 
                                                            
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 content105 (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 plants106. 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. 

105 Contrary to other applications, such as packaging, aesthetic requirements are less relevant and health and 

environmental exposure is usually lower. In addition, the European Committee for Standardisation has already 

developed assessment standards to identify hazardous substances which could be embedded in recycled 

materials. 

106 https://ec.europa.eu/growth/tools-databases/eip-raw-materials/en/system/files/ged/13%20recycling-

treatment-facilities-rpa2012-report_en.pdf 

41 

 
 
                                                            
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  to  track  those  substances  of  concern  in  plastics  (input  for 
recycling  and  recyclates).  It  could  be  done  through  support  innovation  such  as  introducing  in 
products or polymers information carriers e.g. tracers, digital watermarks or nano electronics. 
Technology to be developed depends on the intention and on the information to be collected. 
However  these  tracers  should  not  themselves  become  an  issue  in  terms  of  chemical  load  of 
plastics hampering the recyclability while they are supposed to help smart sorting and efficient 
recycling.  

Hence, Commission’s work on the Interface between chemicals, waste and product policy is set 
to address these issues and will therefore contribute directly to  a greater and safer uptake of 
recycled plastics. The EU will also finance research and innovation projects on decontamination 
of plastic waste through Horizon 2020. 

Continuous support efforts towards more circular plastics 

The Commission will accompany business in their efforts towards more circular plastics e.g. by 
supporting  financially  innovative  project  and  research.  If  additional  investments  in  order  to 
adapt the production processes for increased integration of recyclates in final products may be 
required, it will also offer more opportunities especially for high value applications. 

The Commission will continue to support Member States in their efforts to upgrade the existing 
waste management infrastructure accordingly to the waste hierarchy. Improved dialogue across 
the  value  chain  and  related  actions  will  also  help  to  identify  existing  barriers  e.g.  regulatory, 
economic, behavioural, and technical, to be lifted.  

3.3  Better and more harmonised separate collection and sorting 

3.3.1 

Issues at stake 

Collection and sorting of post-consumer plastic wastes is a complex issue and not always easy to 
implement.  Logistics,  infrastructure  capacity  and  waste  management  practices  are  diverse 
across  the  EU  for  technical,  economic  and  social  reasons,.  Setting  up  well  designed,  good 
functioning  waste  management  systems  and  ensuring  the  separate  collection  of  plastic  and 
organic  waste  is  a  prerequisite  for  maximising  the  recovery  of  resources  and  preventing  their 
escape  to  the  environment.  Upgrading  waste  management  infrastructure  (collection,  sorting 

42 

 
 
and recycling plants and capacity) will require additional investments also in relevant R&D and 
technology development.  

Plastic waste in municipal waste  

Current  estimates  show  that,  although  approx.  2/3  of  all  plastic  packaging  are  recyclable, 
approximately 40% is recycled in practice. Therefore, design for recycling alone cannot be the 
solution.  In  addition,  improved  collection,  as  well  as  further  improvements  in  treatment  and 
sorting plants, are needed.  

The  Waste  Framework  Directives  required  Member  States  to  establish  separate  collection  for 
plastics by 2015. The effects of this provision are still not very visible as many Member States 
may be late in implementing the obligation and it will appear in statistics with some delay (data 
are usually published 2 years later).  

A  study  undertaken  on  behalf  of  the  Commission  in  2015107  shows  that  plastic  was  collected 
within door-to-door systems in 18 countries, of which only four collected plastic as a separate 
fraction; all others apply co-mingling with one (metal), two or three other fractions. Six Member 
States  collect  plastic  (five  together  with  metals)  via  bring-points.  Four  Member  States  did  not 
collect  plastic  separately  from  residual  waste  within  the  main  collection  system,  however  this 
might be possible in civic amenity sites. The study also concludes that collection of plastic as a 
single fraction within door-to-door collection systems delivers the best outcome – both in terms 
of  quality  and  quantity  of  the  collected  waste.  Even  if  the  collection  costs  are  higher,  the 
treatment  costs  are  lower  as  it  results  in  fewer  rejects  that  must  be  disposed  of  and  higher 
revenues from the recyclables.  

Systems  for  separate  collection  are  being  increasingly  rolled  out  in  the  Member  States,  and 
there is a trend to move from bring systems to door-to-door systems, which is leading to better 
collection  and recycling results.  In  addition,  a  growing  number  of  municipalities  are  deploying 
pay-as-you-throw-schemes. This system provides strong incentives for waste prevention and for 
a correct separation of waste, providing for clean fractions that are easier to recycle. The trend 
towards separate collection is increasing as the year 2020 approaches and Member States are 
stepping up efforts to comply with the recycling targets for municipal waste. 

Plastic waste in the construction sector 

In  the  construction  sector,  a  distinction  has  to  be  made  between,  on  the  one  hand,  
construction  waste,  which  consists  of  clean  materials  that  can  be  easily  sorted  and  reused  or 
recycled,  and  demolition  waste,  on  the  other  hand,  which  arises  during  renovation  or 
demolition works.  

The quality of the materials depends on the demolition technique applied. Deconstruction is a 
different  process  from  conventional  demolition,  requiring  different  techniques  and  skills  that 
are  not  necessarily  widespread.  It  is  more  time  consuming,  and  requires  more  detailed 
assessment of the building and planning before work commences. Deconstruction for reuse and 
recycling  requires  larger  amounts  of  storage  space  to  be  allocated,  since  there  is  often  a  lag 

107 https://ec.europa.eu/docsroom/documents/24562/attachments/1/translations/ 

43 

 
 
                                                            
between  supply  and  demand,  and  related  logistics.  These  requirements  then  lead  to  reuse 
activities being more expensive than demolition.   

Where construction and demolition waste is sorted, identifying and sorting plastic polymers is 
generally  not  a  problem  as  few  different  polymers  are  used  for  a  given  application.  However, 
there  is  an  emerging  problem  as  regards  identification  of  plastic  waste  streams  that  are 
contaminated  with  legacy  additives.  This  is  the  case  for  PVC  products  (windows,  pipes) 
containing banned additives and for insulation foams made of Expanded Polystyrene (EPS) that 
may  contain  the  hazardous  brominated  flame  retardant  (HBCDD).  In  this  case,  assumptions 
about the presence of contaminants can be made when the regional use and period of use of 
HBCDD  may  help  to  establish  the  possible  contamination  of  a  waste.  In  case  the  presence  of 
HBCDD cannot be ruled out, scanning techniques (as used to detect bromine in products) may 
be applied.     

Plastic waste in end-of-life vehicles (ELV) 

As regards ELVs, the outcome of sorting of plastic waste from ELV depends very much on the 
type of dismantling technology that is applied. There are two main ways to remove plastics:  

1.  Manual  dismantling  is  time  consuming  and  costly  as  cars  are  not  design  to  facilitate 
dismantling (e.g components are bonded in place rather than fixed through removable 
screws, bolts etc). Plastic produced from recyclates originating from manual dismantling 
processes are usually of high quality and can allow up to 90% of the salvaged material to 
be recycled to polymer of the same grade. 

2.  Shredding is cheaper but is less efficient, especially at removing high quality plastics for 
reuse  and  recycling.  The  quality  of  plastics  recycled  from  shredder  residue  is,  today, 
likely to be very low due to contamination. As a result, the plastic  streams tend to be 
contaminated and it is not possible to further split out the polymers. Typically, only 30% 
of  the  products  can  be  recycled  and  it  is  into  a  much  lesser  grade  –  more  like 
recovery108. 

This  does  not  need  to  be  the  case,  however,  and  plastics  made  from  recycled  car  parts  can 
achieve high quality and are suitable for use in many areas of the car. Sorting needs to occur at 
source.  A  relatively  small  percentage  of  shredder  residue  goes  for  plastics  recycling,  most  of 
which  is  blended black  polypropylene  plastics  (PP)  used  in  pipes  and  automotive applications. 
Manual  dismantling  may  also  be  required  to  remove  parts  that  are  contaminated  with 
hazardous substances, such as POPs. 

Plastic Waste from electrical and electronic equipment (WEEE) 

Separate collection and treatment of WEEE is regulated under the WEEE Directive 2012/19/EU, 
which applies the ‘polluter pays’ principle to ensure EEE manufacturers and importers share in 
the obligations for financing. The WEEE Directive required the creation of collection schemes for 
the  recycling  and  preparation  for  re-use  of  WEEE.  Original  equipment  manufacturers  (OEMs) 
and importers share the financial burden of the cost of collection and recycling under this EPR 
legislation. The WEEE Directive establishes collection and recycling targets, which are increasing 

108 Interview with Multiport and Poly Recycling 

44 

 
 
                                                            
over  time.  The  RoHS  Directive  2011/65/EC  limits  the  presence  of  hazardous  materials  in  new 
EEE products. 

EEE are usually complex products which are difficult to disassemble and with polymers that are 
often  difficult  to  identify.  In  particular,  small  domestic  appliances  and  ICT  equipment  are 
increasingly technical, with complex plastic components and plastics bonded to other materials 
and  hazardous  components  which  present  challenges  for  recovery  through  existing  recycling 
systems. Hazardous substances within WEEE are considered to be a major obstacle to recycling. 
In  particular,  the  presence  of  POP-BDEs  is  challenging  as  wastes  containing  more  than  1000 
mg/kg of POP-BDEs have to be separated from the waste stream and treated in a way that the 
POP content is destroyed.  

Despite the efforts, a mere 35% (3.3 million tonnes of 9.5 million tonnes) of WEEE discarded by 
companies  and  consumers  in  2012  are  reported  under  the  official  collection  and  recycling 
systems.  The  other  discarded  electronics  was  not  reported,  exported,  recycled  under  non-
compliant conditions or simply thrown in waste bins.  

Waste  collection  infrastructure  varies  significantly  across  Member  States,  with  less  developed 
economies typified by less expansive formal collection systems for WEEE and, as a consequence, 
where  recovery  rates  are  much  lower.  In  some  Member  States  systems  for  the  collection  of 
WEEE are sub-optimal and need to be improved. 

Illegal  shipment  of  WEEE  from  Europe  represents  a  significant  challenge  to  the  recovery  of 
increased  quantifies  of  plastic  for  re-use  and  recycling.    These  shipments  represent  losses  of 
plastic  waste  from  WEEE  from  across  the  European  Union.  Inadequate  enforcement  of  waste 
shipment  regulations  also  means  that  good  quality  WEEE  plastics  that  might  be  recycled  by 
European  companies  leaves  the EU.  Variations  in  enforcement  of  criminal  sanctions  for  waste 
crime across European Member States is a factor in the high levels of illegal shipments of waste.  

Lack of investments in waste management infrastructure  

There are in the EU insufficiencies in collection systems, with low rate of plastic waste collected. 
In addition once collected, the complexity of the separation process makes their recycling quite 
challenging. There is as well less recycling capacity today in the EU than the amount of plastic 
waste  sent  to  recycling.  This  under-capacity  in  recycling  represents  around  50%  of  the  total 
plastic waste generated in the EU, while the remaining 50% is exported for recycling overseas. 
Additional  capacity  is  therefore  required  for  the  future  scenarios  in  order  to  cover  this  gap. 
Indeed,  amounts  of  plastic  waste  that  will  be  diverted  to  recycling  in  response  to  increased 
recycling  targets  at  EU  level  will  be  increasing  (e.g.  55%  recycling  target  by  2025  for  post-
consumer plastic wastes as proposed by Commission).  

Therefore, investment in collection, sorting and recycling installations will be key if the EU wants 
to  accelerate  the  move  towards  more  circular  plastics.  In  other  words,  the  investment  costs 
required  for  increasing  recycling  and  sorting  capacity  in  EU-28  is  within  the  range  of  0.7-1.3 
billion EUR per year. Considering an average plant capacity for sorting and recycling facilities, an 
estimation  of  the  number  of  new  plants  that  needs  to  be  constructed  in  EU-28  was  made: 
assuming an average processing capacity of 45 000 tonnes per year for a new sorting facility and 
35  000  tonnes  per  year  for  a  new  recycling  facility,  approximately  150  additional  sorting 

45 

 
 
facilities and  170 recycling facilities would be built by 2020 in the EU-28. These figures rise to 
250 sorting facilities and 300 recycling facilities by 2025.109 

The  Chinese  government  notified  the  World  Trade  Organisation  (WTO)  on  18  July  2017  its 
intention to ban imports of certain categories of plastic wastes110,111. The notification message 
informed that the ban would become operational on 1st January 2018. Plastics wastes exported 
to  China  (for  recycling)  are  1,75  Mio  tons/year  (2015).  This  figure  represents  11%  of  all  post-
consumer plastics wastes generated in EU or 3% of the EU plastics production. Approximately 
two thirds of the EU exports of plastic waste originate from the United Kingdom and Germany 
(at roughly equal shares).  

Table 5. Export to China of EU plastic and plastic waste production 

Wastes 

Post-Consumer 

Plastics Production in EU 
Plastics 
generated in EU 
Plastics wastes landfilled in EU 
Plastics wastes incinerated in EU 
Plastics wastes collected for recycling 
Plastics  wastes  exported  outside  EU  for 
recycling 
Plastics  wastes  exported  to  China  (for 
recycling) 

58 Mt/year 
26 Mt/year 

8,6 Mt/year (31 %) 
10,1 Mt/year (39%) 
7,8 Mt/year (30%) 
3 Mt/year (11,5% of EU wastes) 
(appr. 50% of plastic waste collected for recycling) 
1,75 Mt/y (6,6 % of EU wastes (equivalent to 22% of 
waste  collected)  corresponding  to  85%  of  wastes 
exported outside EU) 

The fact that China has enforced a ban on imports of solid wastes, including plastic wastes will 
have  an  impact  on  the  volumes  available  for  recycling.  In  the  long  term  the  ban  of  waste 
imports by China represents an opportunity for the European industry. In the short term though 
there might be adverse effect due to the way the ban has been introduced by China. The ban is 
expected to lower the prices of these commodities (according to industry, prices have already 
decreased  by  40%  on  some  categories  of  plastic  waste  in  September-October)  and  to  create 
stocks that cannot be absorbed by the export markets in the short term.  

Exports for recycling to other destinations (such as India and Turkey) may partially absorb the 
volumes but landfilling and incineration might increase.  

In the EU, the development of waste-to-energy and incineration capacity has been financed in 
the past mainly through the co-financing of the cohesion policy funds (the Cohesion Fund and 
the European Regional Development Fund). Other financing instruments such as the European 

109 

http://www.plasticsrecyclers.eu/sites/default/files/BIO_Deloitte_PRE_Plastics%20Recycling%20Impact_Assesm

ent_Final%20Report.pdf 

110 https://docs.wto.org/dol2fe/Pages/FE_Search/FE_S_S009-

DP.aspx?language=E&CatalogueIdList=237688&CurrentCatalogueIdIndex=0&FullTextHash=371857150&HasE

nglishRecord=True&HasFrenchRecord=True&HasSpanishRecord=True 

111 https://docs.wto.org/dol2fe/Pages/FE_Search/FE_S_S009-

DP.aspx?language=E&HasEnglishRecord=True&HasFrenchRecord=True&HasSpanishRecord=False&CatalogueI

dList=133390,236153,237679,237808,237688,237701,237670,235275,237804,237805&CurrentCatalogueI

dIndex=5&FullT 

46 

 
 
 
                                                            
Fund for Strategic Investment (EFSI) and the European Investment Bank (EIB) also play a role in 
this area, mainly through loans, guarantees, equity and other risk-bearing mechanisms. 

With the introduction of a more ambitious policy, as stated in the Circular Economy Action Plan, 
in the case of the 2014-2020 Cohesion Policy funds, ex-ante conditions had to be met to ensure 
that new investments in the waste sector are in line with waste management plans designed by 
Member States to meet their recycling targets. This means that investments in residual waste 
treatment  facilities  (e.g.  new  landfills  and  incineration  capacity)  should  only  be  granted  in 
limited and well justified cases in line with the waste hierarchy and avoiding overcapacities that 
could  jeopardise  the  fulfilment  of  the  EU  waste  recycling  targets.  The  same  principles  should 
apply to investments channelled through the other EU financing mechanisms (e.g. EFSI, EIB).  

As a matter of fact, a small percentage of incineration will be needed for a part of plastic wastes 
which  cannot  be  properly  recycled  into  secondary  plastic  raw  materials  of  commercial  quality 
grades or containing unacceptable level of substances of concern (i.e. the legacy substances). 

At  national  level,  the  use  of  State  aid112  is  important  for  the  development  of  sound  waste 
management.  However,  in  the  implementation  of  the  State  aid  guidelines113,  particularly  as 
regards  indirect  support  to  waste  incineration  with  energy  recovery  through  State  aid  to 
renewable  energy,  it  is  important  to  ensure  policy  coherence.  Support  schemes  need  to  be 
designed and applied in a manner consistent with the waste hierarchy taking into account other 
key  requirements  under  EU  waste  legislation  including  the  obligation  to  ensure  separate 
collection of waste and to pre-treat biodegradable waste114 prior to its disposal in landfill sites. 

3.3.2  Existing EU measures  

The Commission is continuously promoting and ensuring a proper implementation of the Waste 
Hierarchy where reuse and recycling should be preferred to incineration and landfilling. It also 
works on ensuring that Member States comply with the existing requirements regarding waste 
management, especially the municipal waste, set by the Waste Framework Directive. 

The European Commission will also continue to promote selective deconstruction. This will be 
further reinforced by the application of the newly published Construction and Demolition Waste 
Protocol115,  which  aims  to  improve  the  quality  of  construction  and  demolition  waste 
management and increase the trust in the quality of recycled materials. In addition, in its new 
Circular Economy package, the Commission envisages to require  'Member States (…) [to] take 
measures to promote sorting systems for construction and demolition waste and for at least the 
following: wood, aggregates, metal, glass and plaster. 

The guidelines that were issued for assessment of construction and demolition waste streams 
prior  to  demolition  or  renovation  of  buildings  and  infrastructures  will  enable  practioners  to 
identify  valuable  fractions  and  hazardous  materials  before  renovation  and  demolition  works 
start.  Their  implementation  will  also  be  beneficial  to  recycling  and  reuse  of  plastics  as  it  shall 
lead to a more organised and conscious management of demolition waste. Although plastics is 

112 http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52014XC0628(01) 

113 Ibid., page 3. 

114 Directive 2008/98/EC of the European Parliament and of the Council of 19 November 2008 on waste 

115 https://ec.europa.eu/growth/content/eu-construction-and-demolition-waste-protocol-0_en 

47 

 
 
                                                            
not among the fractions to be collected separately, this requirement will increase the chances 
of  construction  plastics  to  be  collected  and  hence  promote  their  recycling.    A  timely 
identification  of  reusable  and  recyclable  fractions  will  increasethe  chances  of  finding  suitable 
markets for them once the construction is actually renovated or demolished.   

3.3.3  Actions to be taken  

To  encourage  more  standardised  and  effective  practices  across  the  EU,  the  Commission  will 
issue new guidance on separate collection and sorting of waste. 

The revised PPWD will set a new target for plastic packaging waste to be collected and recycled. 
The revision will also improve separate plastic collection across the EU in order to help Member 
States  to  reaching  the  revised  targets.  The  volumes  of  good  plastic  waste  will  increase  and 
provide a sufficient input for recycling increasing in consequence the quality of recyclates. The 
Commission  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. 

Dismantling processes in ELV sector need to be harmonised. Once a good system has been put 
into place, producers will be able to work towards making cars that fit with these dismantling 
processes,  which  will  make  the  whole  system  more  useable.  Harmonisation  of  dismantling 
processes  and  dissemination  of  best  practices  in  the  ELV  sector  will  allow  to  increase  the 
recycling rates while improving the quality of the outlets. 

The Commission will also continue to work on improving and harmonising the WEEE collection 
and  management  schemas.  Improved  WEEE  management  and  more  harmonised  practice  of 
dismantling and handling will ensure better recycling rates and limit the risk of contamination of 
plastic waste. 

In order to ensure a proper implementation of the Waste Hierarchy where reuse and recycling 
should  be  preferred  to  incineration  and  landfilling,  investment  in  collection,  sorting  and 
recycling  installations  will  be  key  if  the  EU  wants  to  take  up  this  challenge  and  turn  it  into 
opportunity for European industry. The instruments related to stimulate investments are cross-
cutting; this is further explained in the relevant chapter. 

48 

 
 
 
 
4  Curbing plastic waste and littering  

4.1  Preventing plastic waste in our environment  

The  amount  and  sources  of  litter  entering  the  marine  environment  each  year  is  not  known. 
Recent  assessments  have  been  based  on  estimates  of  "mismanaged  plastic  waste"116  and  this 
correlates to some extent with measurements in rivers117. It is generally believed that most litter 
comes from the land and these river measurements indicate that the mass entering as micro-
plastics of the same order or greater than the mass entering as macro plastics. Other issues that 
need to be addressed are over-packaging, agricultural plastics which are used on huge surface, 
and micro-plastics. Biodegradable plastics form a specific challenge. Plastic may also enter the 
sea  through  offshore  activities  such  as  fishing,  shipping,  petroleum  exploitation  and 
aquaculture. 

4.1.1  Single use plastics 

Issues at stake  

In  a  recent  UNEP  report,  States  are  encouraged  to  "develop  and  implement  laws  to  ban  or 
diminish  the  production  of  single-use  trash  items  and  other  waste  that  is  commonly  found  in 
marine  litter"118.  All  the  beach  surveys  throughout  Europe119  (and  elsewhere  in  the  world) 
consistently  confirm  that  the  overwhelming  majority  of  items  found  on  beaches,  in  terms  of 
both numbers and mass, are waste plastic items or unidentifiable plastic pieces.  

Whether an item is a single use item or reusable, once it is littered in the environment, it has 
the same negative environmental impact. As it is explained below, plastic degradation in open 
environment  can  take  hundreds  of  years.  During  this  period  plastics  fragment  into  smaller 
pieces. Plastic debris causes sea species to suffer from entanglement or ingestion. Micro-plastics 
causing  harm  to  fauna  and  flora  are  generated and  are  potentially harmful  for  human health. 
This represents both a common and a transboundary challenge.  

In addition, waste littering may also have a big impact with tourism and other amenity activities, 
and therefore direct and substantial economic impact on these activities.  

A single use plastic item reaches its end-of-life in a very short time, which shows that resources 
are not efficiently used. Indeed, if this item were designed for reuse and effectively reused, this 
would save the resources and energy that were used in their production.   

Moreover, such items once disposed of, becomes waste that needs to be collected and sorted 
thereby implying costs for public authorities. Although such items could be recycled, most of the 
time  they  are  not.  Causes  are  multiple  and  often  interlinked:  insufficient  public  waste 
management infrastructure, food and organic material contamination once put in the right bin, 
etc.  Therefore,  this  leads  to  consider  that  not  only  resources  are  wasted  in  their  production 

116 Plastic waste inputs from land into the ocean  Jenna R. Jambeck et al,     

http://science.sciencemag.org/content/347/6223/768 

117 Export of Plastic Debris by Rivers into the Sea, Christian Schmidt,*,† Tobias Krauth,†,‡ and Stephan Wagner 

Environ. Sci. Technol. 2017, 51, 12246-12253 

118 UNEP : "Marine Litter Legislation: A Toolkit for Policymakers" 

119 http://ec.europa.eu/environment/marine/good-environmental-status/descriptor-10/pdf/final_report.pdf 
49 

 
 
                                                            
phase  but  the  value  of  materials  is  not  kept  in  the  loop  which  is  the  contrary  of  a  circular 
economy  concept  and  can  also  be  seen  as  contrary  to  the  waste  hierarchy  enshrined  in  the 
Waste  Framework  Directive  which  states  that  policy  should  also  aim  at  reducing  the  use  of 
resources,  and  favour  the  practical  application  of  the  waste  hierarchy  in  accordance  to  which 
prevention  should  be  considered  in  priority  to  other  waste  management  options  such  as 
recycling for instance.  

The impacts described above (contribution of SUPs in marine litter, the availability of reusable 
or  non-plastic  alternatives,  etc.) and  increased  public concerns  have prompted some Member 
States to act individually. Several Member States are already taking action regarding single use 
items by implementing the Marine Strategy Framework Directive120. France for example plans to 
restrict the use of several of these SUP by 2020, unless they are home-compostable and at least 
50%  bio-based  (pushing  thus  for  a  substitution  by  paper,  cardboard,  wood  and  others)121. 
United Kingdom and Ireland area also considering actions. Some regional and more local actions 
have been taken:  

 

 

 

In Navarra the sale of single-use plastic cutlery, trays and cups is to be banned by 2020, 
the provision of tap water in public spaces and in restaurants will be made obligatory, 
and the sale of bottled water prohibited in all public buildings except hospitals.  
In  Bristol,  consumers  can  refill  their  reusable  water  bottles  for  free  in  many  cafes, 
restaurants and others. An app locates the closest refill station. The project is expanded 
to five other cities.  
In  Vienna  and  Munich  portable  washing  stations  provide  a  specific  service  to  wash 
reusable containers in food markets.  

  Vienna introduced an obligation to use reusable items at big events.  
  Hamburg  bans  disposable  packaging  in  public  buildings,  which  includes  bottled  water 

and beer, plastic plates and cutlery. 

There is a concrete risk of different Member States actions addressing different items that could 
be a problem in terms of internal market.  

Definition of single use plastics for the purposes of the Plastics Strategy 

Currently  neither  legal  definition  nor  official  statistics  regarding  single  use  plastic  production 
and littering exist. Such a definition is however crucial in order to define measures to be taken 
in order to move towards more circular plastics and to address plastic waste and littering issues.  

Given that plastic packaging is almost exclusively single-use, especially in business-to-consumer 
applications,  that  such  items  could  be  defined  in  Packaging  and  Packaging  Waste  Directive 
(PPWD).  In  the  latter  a  distinction  is  made  between  packaging,  i.e.  all  products  made  of  any 
materials  of  any  nature  to  be  used  for  the  containment,  protection,  handling,  delivery  and 
presentation of goods, from raw materials to processed goods, from the producer to the user or 
the  consumer,  and  "non-returnable  items"  used  for  the  same  purposes.  One  could  consider 
therefore that "non-returnable items" are equivalent of single use items.   

120 Member States  have to monitor marine litter and draft/implement programs of measures notably to 

reduce marine litter in their marine waters    

121 Loi de Transition Energétique pour la Croissance Verte (LTECV) du 18/08/ 2015 

50 

 
 
                                                            
Acknowledging  that  single  use  items  are  not  currently  defined  from  a  legal  perspective,  the 
Commission worked with stakeholders to develop criteria. Criteria should be based on objective 
and verifiable criteria leaving as less a room as possible for interpretation given that consumers 
behaviour in this case if a major factor to be taken into account. Stakeholders gathered together 
during several workshops generally agreed that single-use items should fulfil at least one of the 
following criteria122: 

  Prone to littering and prevalently ending in the marine environment; 
  Short use phase; 
  Consumed predominantly away from home; 
  Reusable or non-plastic alternatives exist. 

Table 6. Contribution of single-use non-packaging and packaging plastics to marine litter 

Item 
Cigarette butts 
Drinks bottles, caps and lids 
Cotton bud sticks 
Crisps packets / sweets wrappers 
Sanitary applications  
Bags 
Cutlery, straws and stirrers 
Balloons and balloon sticks 
Food containers including fast food  
Cup and cup lids 
Total 

% of SUP 
19% 
18% 
10% 
8% 
7% 
5% 
4% 
2% 
2% 
3% 
77% 

Packaging 
No 
Yes 
No 
Yes 
No 
Yes 
No 
No 
Yes 
Yes 

Source: Eunomia (2017), based on JRC data 

Existing EU measures  

Plastic Bags Directive 
Plastic bags  is  a specific  case of  Single  Use Plastics.  The EU  has  already  taken steps  by  setting 
requirements for Member States to adopt measures to cut the consumption of plastic bags. This 
case can be seen as a good practice.  

Due  to  their  low  weight,  low  price  and  resistance  to  degradation,  plastic  carrier  bags123  are  a 
popular  and  convenient  product  widely  used  for  transporting  shopping  items  from  the  store 
back home. Their ever increasing, but unsustainable consumption and the fact that they often 
escape waste management have resulted in littering and an inefficient use of resources, which 
are underscored by environmental impacts, as well as economic and social consequences.  

Once  discarded,  after  having  been  used  in  most  cases  only  once,  many  of  these  lightweight 
plastic  carrier  bags  end  up  in  the  environment,  where  they  remain  as  micro-plastics  for 
hundreds  of  years.  This  represents  both  a  common  and  a  transboundary  challenge.  Indeed, 
especially  lightweight  plastic  carrier  bags  can  travel  over  large  distances  with  currents  and 

122 Workshops held by the Commission on 16th of June and 14th September 2017 in Brussels. 

123 A definition of the types of plastic carrier bags considered in this assessment is provided in Annex II. 

51 

 
 
 
                                                            
winds and even in Member States with well performing waste management infrastructure, high 
concentrations of marine plastic litter can be detected. 

In  2010,  an  estimated  98.6  billion  plastic  carrier  bags  were  placed  on  the  EU  market,  which 
amounts  to  every  EU  citizen  using  198  plastic  carrier  bags  per  year.  Out  of  these  almost  100 
billion  bags,  the  vast  majority  are  lightweight  bags,  which  are  less  frequently  re-used  than 
thicker ones.  Consumption figures  vary  greatly  between  Member  States,  with annual  use  per 
capita of lightweight plastic carrier bags ranging between an estimated 4 bags in some Member 
States and 466 bags in other Member States.  

Lightweight plastic carrier bags are considered to be packaging within the meaning of Directive 
94/62/EC124  on  packaging  and  packaging  waste  (PPWD).  This  Directive  lays  down  rules  on 
packaging  and  the  placing  on  the  EU  market  of  packaging  and  it  also  lays  down  rules  on  the 
management of packaging waste. It has a double objective: safeguarding the functioning of the 
internal market (article 18) and assuring a high level of environmental protection.  

Lightweight plastic carrier bags, are defined as plastic carrier bags with a wall thickness below 
50 microns. Member States may take a wide range of actions, which, shall include at least one 
of the following measures: 

  a national maximum consumption level of plastic carrier bags of maximum 90 bags per 
person per year by 31 December 2019 and maximum 40 bags per person per year by 31 
December 2025; 
instruments  ensuring  that,  by  31  December  2018,  lightweight  plastic  carrier  bags  are 
not provided free of charge to customers at a point of sale. 

 

Very lightweight plastic carrier bags (i.e. with wall thickness below 15 microns) which are mainly 
used  for  the  packaging  of  loose  fruits  and  vegetables  may  be  excluded  from  the  above  2 
measures.  

It is not yet possible to provide statistical data on reduction of consumption of these bags. By 
mid-October  2017, six Member  States  had not notified implementing measures, but informed 
that  measures  would  be  adopted  still  in  2017.  Nevertheless,  some  Member  States  currently 
apply measures ahead of the deadlines and these Member States find considerable reduction in 
the consumption of lightweight plastic carrier bags. 

The  implementing  measures  to  reduce  use  of  plastic  bags  have  met  little  resistance  from 
consumers,  and  are  rather  welcome  and  seen  as  an  effective  measure.  They  are  also  very 
efficient in reducing littering in coasts and seas. The tax on plastic shopping bags in Ireland, in 
2002, resulted not only in a 90% reduction of plastic bags provided in retail outlets (Convey et 
al., 2007) but also in a marked decline in bags found on beaches, according to Coastwatch beach 
monitoring data125. 

124 Directive 94/62/EC on packaging and packaging waste; OJ 1994 L.365 of 31.12.1994, p. 10 

125 From an average of 18 plastic bags/500m in 1999 to 5 in 2003. See p.32 of JRC report on sources of litter: 

http://ec.europa.eu/environment/marine/good-environmental-status/descriptor-

10/pdf/MSFD_identifying_sources_of_marine_litter.pdf 

52 

 
 
                                                            
Monitoring and measure of marine litter  
Beach litter has also been the object of awareness raising and clean-up campaigns throughout 
the world, with increasing dissemination during the last years. The Commission's services have 
also  participated  and  organised  several  beach  clean-up  campaigns  across  the  EU  and  in  other 
parts in the world.   

The  European  Environmental  Agency  EEA  has  developed  Marine  Litter  Watch126,  a  citizen 
science based tool that can help fill data gaps relevant for policy, while raising awareness about 
the  problem  of  litter  and  the  policy  response  to  it;  it  is  already  being  used  in  European-wide 
campaigns and complements many private initiative tools. 

The  Marine  Strategy  Framework  Directive  (MSFD)  requirement  to  ensure  that  properties  and 
quantities of litter do not cause harm to the environment implies that baselines and threshold 
values have to be set at EU level. This work is being coordinated at EU level and a related JRC 
report127 on the most frequently found litter items on beaches is available. This work is ongoing 
with  a  view  to  facilitate  reaching  the  aspirational  target  of  the  Circular  Economy  Package  to 
reduce by 30% the amount of beach litter and fishing gear lost at sea by 2020. The European 
Marine Observation and Data Network EMOD-net partnership in collaboration with regional sea 
conventions  are  assembling  and  harmonising  the  data  in  order  to  provide  a  better  overall 
picture  of  the  concentrations  in  European  seas  and  sea-beds  that  will  help  assess  progress  in 
meeting targets and support remedial action. These data will be made publicly available in the 
first half of 2018. 

EU funding is being deployed to understand and combat the rise of marine litter128, supporting 
global, national and regional action. 

Actions to be taken  

Taking  into  account  that  addressing  marine  litter  cannot  be  done  without  tackling  single  use 
plastics  the  European  Commission  will  take  action  to  address  single-use  plastics  that  will 
include the launch of an Impact Assessment and a public consultation, to determine scope of a 
legislative  initiative  on  single-use  plastics.  The  diversity  of  single  use  plastics  and  different 
objectives justify using a differentiated approach129: 

 

Items already captured today in separate collection schemes (mainly packaging: such as 
drink  bottles):  the  objective  is  to  improve  the  collection  rate.  This  could  be  done 
through  stricter  implementation  of  the  existing  and  future  legislation  on  waste  (e.g. 
separate  collection,  recycling  targets,  full  implementation  of  producer  responsibility 
schemes  and  fee  modulation,  prevention  measures  and  stimulation  of  deposit  return 
schemes).  

126 https://www.eea.europa.eu/themes/water/europes-seas-and-coasts/marine-litterwatch#tab-news-and-

articles  

127 Top Marine Beach Litter Items in Europe. JRC108181, Authors A.M.Addamo, P.Laroche and G.Hanke 
128 For instance, in the Arctic Region, the Circular Ocean INTERREG project is testing new opportunities for 

reusing old fishing nets, including a material to remove pollutants from water (http://www.circularocean.eu/). 

In the Baltic Sea Region, the BLASTIC project maps potential litter sources in urban areas and monitors litter 

levels in the aquatic environment (https://www.blastic.eu/). Both projects are supported by the European 

Regional Development Fund. 

129 These categories are indicative and could be adapted during the course of the assessment. 

53 

 
 
                                                            
 

 

Items  which  could  be  replaced  by  more  sustainable  alternatives  (e.g.  take-away  food 
containers,  disposable  cups,  possibly  caps  and  lids,  cotton  buds,  cutlery,  straws  and 
stirrers): the objective is to ensure they are captured or substituted by more sustainable 
alternatives  (e.g.  reusable  cups).  Options  may  include  reduction  targets,  design 
requirements  (e.g.  replacement  by  materials,  such  as  paper  or  wood,  which  degrade 
quickly in the natural environment, or design of lids and caps in a way that they cannot 
be  detached  from  the  bottle),  or  requirements  for  Member  States  to  implement  a 
charge at the point of sale. 
Items  for  which  there  are  no  readily  available  alternatives  (non-packaging:  cigarette 
butts,  sanitary  applications,  etc.):  the  objective  is  to  significantly  decrease  littering  of 
these items and this could be done by focusing on awareness campaigns, etc. Possible 
legal  action  could  include  applying  the  principle  of  Extended  Producer  Responsibility 
and/or labelling requirements targeting consumers.  

Complementary  to  legal  action,  voluntary  commitments  can  be  considered,  awareness  raising 
campaigns as well as research into alternative products and materials.  

In  addition,  through  its  legislative  proposal  for  a  review  of  the  Drinking  Water  Directive, 
adopted at the same time as this strategy130, the Commission is promoting access to tap water 
for EU citizens, therefore reducing packaging needs for bottled water. 

The  criteria  for  the  Ecolabel  and  Green  Public  Procurement  also  promote  reusable  items  and 
packaging131. 

Box 3. What citizens can do in order to help fighting against littering and improving recycling 

Policies  did  not  always  succeed  to  incentivize  consumers  towards  a  more  responsible  and 
sustainable  behavior,  but  according  to  Eurobarometer  studies  citizens  are  keen  on  recycling  - 
65% of respondents say they have separated most of their waste and 34% have avoided single-
use  plastic  goods  other  than  plastic  bags.  The  awareness  campaigns  should  mention  concrete 
action,  to  enhance  communication  efforts.  Simple  messages  like  prefer  durability  and 
reparability over consumer goods with short lifecycle i.e. that won't last for long or are intended 
for  a  single-use,  need  to  be  brought  to  the  consumers.  Therefore  it  is  necessary  that  the 
Commission and the MS provide consumers with sustainable alternatives in order to reduce the 
consumption  of  single  use  plastics  (e.g.  take  away  coffee  cups),  improve  the  quality  of 
collection, recyclability and better assess bio-degradability claims. 

Sorting  of  plastic  wastes  and  correct  disposal  at  post-consumption  stage  is  not  always  easy  to 
implement for the consumers due to various reasons like the lack of collection logistics, distance 
between  trash  bins,  lack  of  information  or  inadequate  education.  The  motivations  behind 
littering  include  social  norms  as  well  as  a  lack  of  awareness  about  the  consequences  and  the 
general impact of littering, especially when it comes to coastal areas and marine environment.  
Most  citizens  are  welcoming  the  idea  that  local  authorities  should  provide  more  and  better 
collection facilities for plastic waste. 

Consumer’s purchasing and consumption behavior also considered a key aspect which needs to 

130 http://ec.europa.eu/environment/water/water-drink/review_en.html 

131 Examples include the Ecolabel criteria for tourism and the Green Public Procurement criteria for food and 

catering restrict the use of single-use plastics in catering 
54 

 
 
                                                            
be changed in order to close the largest loopholes by which litter enters the environment. There 
is a key role here for retailers, as they are in direct contact with millions of consumers daily, the 
tourism  industry  to  address  coastal  tourists  and  residents,  local  authorities  and  waste 
management  companies  to  improve  consumer’s  disposal  behavior  and  to  provide  for  relevant 
informative,  economic,  administrative  and  infrastructural  measures132.  Retailers  can  make  an 
effort to reduce plastic packaging and give their consumers opportunity to buy fruits, nuts etc. 
from bulk bins instead of packed items. Retailers are closest to the consumers and thus are in a 
good position to alter their purchasing choices and at the same time making savings. 

Companies  that  provide  everyday  consumer  goods  can  also  contribute  to  the  behavior  of 
consumers related to waste by funding of education and awareness to prevent litter. Moreover 
according  to  Eurobarometer  studies  consumers  believe  that  products  should  be  designed  in  a 
way that facilitates the recycling of plastic (65%)133 and some of them are ready to pay more for 
that. The industry can also continue to work with regulatory authorities and NGOs to develop 
behavioral  campaigns  to  encourage  recycling  and  responsible  disposal  of  packaging  waste. 
Media  and  consumer  goods  companies  should  also  think  on  how  to  reduce  pro-consumption 
messaging,  and  to  internalise  environmental  costs  into  messaging,  like  it  has  been  done  with 
tobacco for health impacts. 

It should be noted that tourism, leisure and hotel industry as well as fast food chains, cafes and 
gas  stations  should  practice  more  sustainable  services  on  spot  leading  to  decreased  amount  of 
plastic  waste  due  to  the  use  of  single  use  items  and  better  information  of  citizens  about  the 
impacts of litter on the marine environment. 

Local  authorities  should  also  invest  in  the  education  of  citizens  organizing  information 
campaigns  on  sorting  of  plastic  wastes  at  post-consumption  stage.  They  are  generally 
responsible  for  street  (and  beach)  cleaning  and  waste  management,  spatial  planning, 
enforcement  of  regulations  on  littering  and  often  play  a  key  role  in  education  and  training134. 
They are also likely to have strong links with local stakeholder groups. This gives them a key 
role in litter prevention. 

Empowerment  of  the  society  can  be  done  in  many  different  ways.  Partnerships  between 
stakeholders  (e.g.  academia,  NGOs,  governments,  national  and  local  authorities,  media  and 
communications, tourism and retailers, industry) can create strong campaigns and initiatives to 
promote  wise  disposing,  reuse,  recycling.  Development  of  innovative  applications  like  Marine 
litter  watch  or  Beat  the  micro  bead  and  involvement  of  ICT  sector  could  be  crucial  when 
engaging  with  nowadays  society.    Citizens  however  are  responsive  to  price  signals  as  we  can 
see, for example, by the results of the taxes imposed on light plastic bags in some EU countries 
that decreased the consumption of these products and the amount of plastics bags found along 
the coastline.  

Overall  Europeans  are  supporting  environmental  policies.  More  than  eight  out  of  ten  consider 
that they can play a role in protecting the environment in their country. Therefore the solutions 
need  to  be  found  to  empower  the  society  and  engage  with  all  social  and  age  classes. 
Communication campaigns should focus on children are powerful agents of changes in society 

132 Risk & Policy Analysts Limited (2013) Feasibility study of introducing instruments to prevent littering, pg 17 

133 European Commission (2017) Special Eurobarometer 468 Report Attitudes of European citizens  towards 

the environment 

134 Risk & Policy Analysts Limited (2013) Feasibility study of introducing instruments to prevent littering for 

the European Commission, pg. 45 

55 

 
 
                                                            
by educating their parents and many studies show that "millennials generation" is the one that is 
driving  sustainability.  Lately  we  can  see  a  growing  number  of  start-ups  that  are  recycling 
different  sorts  or  products  and  making  value  added  products.  Sometimes  there  is  a  lack  of 
funding  for  that  type  of  creative  and  circular  economy  based  entrepreneurial  ideas.  Visibility 
should be given to such business cases that are offering alternative product design or services. 
Engagement  through  media  channels  especially  social  media  should  be  ensured  from  the 
authorities. 

All  business  and  industry  sectors  and  civil  society  can  contribute  to  the  reduction  of  litter, 
recycling  and  reuse  by  developing  effective  environmental  management  plans,  incorporating 
problem identification, development of best practices and staff training. More actions are needed 
from civil society to foster fundamental changes in citizen's behaviors and habits towards more 
sustainable lifestyles.   

4.1.2  Over-packaging 

Issues at stake   

Plastics  are  lightweight  materials.  In  addition  to  some  specific  properties  that  make  them  the 
material of choice in some uses, the use of plastic packaging usually contributes to a reduction 
of the weight of packaging, which in turn contributes to reduction of greenhouse gas emissions 
during transport.  

Whereas  over-packaging  has  no  legal  definition,  it  consists  in  excessive  packaging  that  would 
not be strictly necessary for the packaging to fulfil its tasks (i.e. protecting the packaged good 
from external agents to preserve its properties). Even though there are some indications that in 
general  the  specific  amount  of  packaging  used  for  each  product  has  decreased,  there  still  a 
number of products that is over-packed. Examples of over-packaging can be inter alia the use of 
excessively thick layers of packaging materials or the use of several packaging layers to wrap the 
products.  Multiple  packaging  is  typically  used  in  promotional  campaigns  (‘buy  3  pay  2’)  to 
ensure that the consumer takes actually several units of the product.  

There are a number of reasons for the persistent use of excessive packaging in many products. 
One  reason  is  that,  for  some  products,  the  level  of  the  packaging  fees  does  not  represent  a 
significant cost compared to the price of the product that is packaged. This is particularly true 
for expensive products (e.g. luxury products), for which sophisticated packaging can represent 
an  important  sales  argument.  Over-packaging  can  also  be  used  for  marketing  purposes  to 
suggest to consumers that the product has a high value.  In addition, the Essential Requirements 
in  the  Packaging  and  Packaging  Waste  Directive  do  not  include  very  precise  indications  about 
what can be considered 'excessive packaging', which makes them difficult to enforce in practice. 

Existing EU measures 

Waste prevention is the top priority of the waste hierarchy (Art. 6 of Directive 20008/98/EC on 
waste). In line with this general principle, Art. 4 of the Packaging and Packaging Waste Directive 
(PPWD) provides that 'Member States shall ensure that, in addition to the measures to prevent 
the formation of packaging waste in accordance with Article 9 [Essential requirements], other 
preventive  measures  are  implemented'.  In  addition,  Annex  II  to  the  PPWD  (on  the  Essential 

56 

 
 
Requirements) stipulates that packaging has to be 'manufactured in a way that the volume and 
weight are limited to the minimum'.  

On top of these legal requirements, in most Member States packaging is governed by Extended 
Producers Responsibility (EPR) schemes, and the fees to be paid by producers depend (at least, 
partially)  on  their  weight.  Therefore,  there  are  incentives  to  design  packaging  in  a  resource 
efficient  way.  Evidence  from  some  Member  States  (e.g.  Germany  after  the  adoption  of  the 
Packaging  Ordinance)  shows  that introduction  of  EPR  schemes  that  include fees  based on  the 
amount  of  packaging  placed  on  the  market  leads  to  a  reduction  in  the  specific  amount  of 
packaging i.e. the amount of packaging per packaged unit). Consumers can further reinforce the 
trend towards less packaging as they are increasingly aware of the need to use fewer resources 
and can reject excessively packaged goods.  

Actions to be taken  

The Commission  will also  examine  the  issue of  over-packaging as  part  of  the  future  review  of 
the essential requirements for packaging. 

4.1.3  Plastic  waste  from  sea-based  sources:  shipping,  fishing  and  aquaculture 

products  

Issues at stake  

Plastic  products  are  common  in  the  fishing,  aquaculture,  shipping  (cruise  ships,  merchant 
vessels,  fishing  and  recreational  craft)  and  other  offshore  activities  135.  These  industries  have 
become  reliant  on  plastic  material  to  provide  affordable,  lightweight  and  durable  equipment. 
Very  few  estimates  of  plastic  waste  generation  in  the  fishing  and  aquaculture  sector  exist 
though.   

Whilst on average the overall quantities of plastic waste discarded at sea are small compared to 
to waste not dealt with properly on land, the impact is significant because the pathway to the 
sea  is  direct,  and  in  some  sea  regions,  such  as  the  North  East  Atlantic  and  the  North  Sea,  is 
significant. Of these sources, the loss of fishing gear is easiest to identify and quantify because it 
is  instantly  recognisable.  Video  inspection  of  seafloors136  and  surveys  of  northern  beaches137 
indicate  that  fishing  gear  makes  up  a  high  proportion  of  distinguishable  objects.  This  plastic 
creates  the  same  problems  as  that  from  land  based-sources  as  it  breaks  down  into  smaller 
pieces  but  causes  an  additional  and  well-documented  harm  to  marine 
life  through 
entanglement in nets.  

Several  causes  of  discharging  litter  at  sea  were  identified  during  stakeholder  interviews138  as 
well  as  collating  information  on  reviews  on  the  causes  of  abandoned,  lost  or  otherwise 
discarded fishing gear:  

135 Eunomia (2016), Van Franeker (2010), UNEP (2009), GESAMP (2007) 

136 Pham et al. Marine Litter Distribution and Density in European Seas, from the Shelves to Deep Basins PLOS 

ONE, 1 April 2014, Volume 9, Issue 4 

137 Marine Pollution Bulletin Volume 107, Issue 1, 15 June 2016, Pages 52–58 

138 in the context of the impact assessment for the revision of the PRF Directive, which included a specific 

survey for the fishing sector and also built on the outcome of the 2016 Eunomia study on sea-based sources 

of marine litter 

57 

 
 
                                                            
  Accidental and sometimes irretrievable loss of material, limited life-span of some items 

and nature of fishing method; 

  Mismanagement of waste, including plastic waste e.g. dumping on land or sea, due to 
high  cost  of  waste  handling,  inadequate  facilities  and/or  handling  on  board  or  lack  of 
adequate  reception  facilities  in  ports  for  waste  storage  and  consignment,  lack  of 
operators willing to handle gear or waste;  
Lack of incentives to handle waste from ships, including recycling, reuse, retrieval of lost 
gear or consign end-of-life gear; 
Lack  of  end  markets  for  re-use  and  recycling  outputs  and  lack  of  operators  willing  to 
handle gear.  

 

 

Shipping and other offshore installations  

The shipping sector includes all seagoing vessels, from large cruise ships to small fishing vessels 
and  pleasure  craft.  There  are  no  indications  from  recent  studies  and  assessments  that  the 
amount  of  garbage  from  ships  (marine  litter)  has  decreased  in  recent  years.  On  the  contrary, 
time  series  of  marine  litter  on  European  shores  indicate  that  the  problem  has  persisted  since 
the implementation of the PRF Directive (Directive 2000/59/EC). Although garbage delivered in 
ports  has  increased  since  the  introduction  of  the  Directive,  a  significant  delivery  gap  remains, 
estimated between 60,000 and 300,000 tonnes, i.e. 7% to 34% of the total garbage waste to be 
delivered annually139. 

Abandoned, lost and otherwise discarded fishing gear (ALDFG) 

Commercial fishing gear lost, abandoned or discarded annually at sea or in the world’s oceans 
may continue to fish for years or even decades, a process referred to as “ghost fishing”. In an EU 
context, the extent and consequences have been subject to a number of EU funded studies140,141 
,142. In general terms, it appears likely that substantial lengths of netting are lost each year. Each 
nation's fleet may be losing several hundred kilometres. Most nets are lost as a result of events 
like storms or being towed away by trawlers. Indications are that a majority of nets lost in such 
circumstances  are  either  disabled  or  have  a  low  residual  catch  efficiency.  The  FAO  report 
concludes "that ghost fishing from ‘active’ fishing gears such as trawl nets and from ‘static’ pot 
fishing  is  not  significant  in  European  Union  (EU)  waters".  According  to  scientific  research  the 
remaining fishing capacity of ghost nets varies from 6-20% of their initial fishing capacity143. 

In  relation  to  the  total  number  of  nets  used  in  EU  waters,  the  rates  of  permanent  net  loss 
appear to be below one per cent of nets deployed. Most nets are deployed in shallow waters, 
and  a  significant  proportion  of  lost  nets  are  recovered  through  the  use  of  global  positioning 

139 Eunomia study 2016; and DG MOVE Impact Assessment for the revision of the PRF Directive, to be 

published in January 2018 together with the proposal for a new Directive 

140 Project Nº 94/095: Incidental impact of gill-nets (FANTARED) 

141 A study to identify, quantify and ameliorate the impacts of static gear lost at sea (FANTARED 2). EU Study 

Contract FAIR CT98-4338. 

142 FISH/2006/15/Lot No.5”, SI2.466030 “Recuperation of fishing nets lost or abandoned at sea” (DEEPCLEAN) 

143 Werner, S., Budziak, A., van Franeker, J., Galgani, F., Hanke, G., Maes, T., Matiddi, M., Nilsson, P., 

Oosterbaan, L., Priestland, E., Thompson, R., Veiga, J. and Vlachogianni, T.; 2016; Harm caused by Marine 

Litter. MSFD GES TG Marine Litter - Thematic Report; JRC Technical report; EUR 28317 EN; 

doi:10.2788/690366.  

http://publications.jrc.ec.europa.eu/repository/bitstream/JRC104308/lbna28317enn.pdf. 

58 

 
 
                                                            
systems (GPS); fishermen typically go  to considerable lengths to recover nets  given their cost. 
During the evaluation of the Control Regulation, only one Member State authority reported that 
it routinely collect notifications of lost gear144.  

A  number  of  Member  States  undertake  retrieval  surveys  based  on  reported  losses  and  other 
evidence.  Many  Producer  Organisations  report  the  position  of  static  gears  on  a  daily  basis  to 
minimise conflict between static and mobile fishing gears. Such initiatives can reduce the levels 
of  gear  loss  and  can  benefit  from  the  support  of  the  European  Maritime  and  Fisheries  Fund 
(EMFF).  In  response  to  the  studies  on  ghost  fishing,  the  EU  Control  Regulation145  and  the 
associated implementing regulation146 introduced mandatory requirements to report lost nets, 
and improvements and specifications for the marking of fishing gear in order to mitigate such 
losses. 

Aquaculture  

Aquaculture contributes to marine litter also, though to a minor extent, with the main sources 
associated  with  sea-based  farms,  such  as  cages,  longlines,  poles  and  other  floating  and  fixed 
structures used for the culture of marine animals and plants. There are no reliable estimates of 
the contribution of aquaculture to marine litter to date.  

The types of  material lost  would depend on  the type of culture systems, construction quality, 
vulnerability to damage, and management practices and could be nets and cage structures (for 
marine fish cages), lines or floating raft structures (for seaweed systems) or poles, bags, lines, 
and  plastic  sheeting  (for  mollusc  farming).  Because  many  of  these  items  are  expensive,  one 
might expect farmers to take considerable care to avoid losses.  

One Canadian study147 showed that greater concentrations of micro plastics were measured in 
farmed  mussels  than  in  wild  mussels,  which  may  be  a  result  of  farming  practices  that  use 
polypropylene  lines  to  anchor  the  mussels,  or  it  may  be  due  to  differences  in  micro  plastic 
concentrations  in  the  different  locations  from  which  the  farmed  mussels  and  wild  mussels 
originated.  

Another study148 found that mussel nets are among the most common items found in areas of 
the  Adriatic  and  Ionian  seas  with  intensive  and  extensive  aquaculture  activities.  Shellfish 

144  

Year 
number of reports of lost gear (Portugal) 
number of reports of lost gear (other Member States) 

2010  2011  2012  2013  2014 
89 
2 

180 
6 

65 
8 

79 
8 

93 
14 

145 Council Regulation (EC) No 1224/2009 of 20 November 2009 establishing a Community control system for 

ensuring compliance with the rules of the common fisheries policy 

146 Commission Implementing Regulation (EU) No 404/2011 of 8 April 2011 laying down detailed rules for the 

implementation of Council Regulation (EC) No 1224/2009 establishing a Community control system for 

ensuring compliance with the rules of the Common Fisheries Policy 

147 Mathalon A., P. Hill Microplastic fibers in the intertidal ecosystem surrounding Halifax Harbour, Nova Scotia 

Mar. Pollut. Bull., 81 (2014), pp. 69-79. 

148 On beaches located along the coastline of the Adriatic and Ionian Seas mussel nets were the seventh most 

frequent items found (Vlachogianni et al., 2016).  Furthermore, in surveys carried out along the Italian 

coastline, mussel and oyster nets were among the top three items recorded on beaches, while the results 

obtained from the seafloor surveys show that litter from aquaculture accounts for 15% of total items recorder 
59 

 
 
                                                            
 
farming techniques and any potential litter generated differ according to local conditions in the 
sea basin.  

However,  given  that  global  aquaculture  production  accounts  for  more  than  50%  and  marine 
aquaculture of fish and molluscs for nearly 15% of global seafood production, the contribution 
of the sector to marine litter may be rising in importance149.  

End-of-life recreational boats 

End-of-life  recreational  boats  could  become  a  significant  source  for  marine  litter.  Yachts' 
average lifespan has been estimated at 30 years, although in some instances this may stretch to 
40-45 years. This lifespan has further increased over time due to the use of stronger materials, 
such as fibre reinforced polymer (FRP). It is thought that between 1% and 2% of the 6 million 
boats kept in Europe, in other words at least 80,000 boats, reach their 'end of use' each year. 
However,  only  around  2,000  of  those  are  dismantled.  A  significant  number  of  the  remaining 
boats are left abandoned, potentially ending up in the ocean and becoming marine litter150.  

Tourism  

While tourism is a major source of littering on beaches, the proportion of this litter finding its 
way into the sea is unknown.  

Existing EU measures 

The  Commission  has  been  tackling  sea-based  sources  of  marine  litter  with  a  variety  of  policy 
instruments.  

Directive  2000/59/EC  on  port  reception  facilities  for  ship  generated  waste  and  cargo  residues 
aims  at  reducing  discharges  of  waste  from  ships  at  sea.  It  requires  the  provision  of  adequate 
waste reception facilities in ports, and ensures the use of those facilities through a mandatory 
delivery requirement for ships before departure from any EU port.  The Directive also requires 
the establishment of cost recovery systems which are based on the application on an indirect 
fee, to be paid irrespective of delivery, in order to  provide no incentive for ships to discharge 
their  waste  into  the  sea.  Since  the  adoption  of  the  PRF  Directive,  volumes  of  ship-generated 
waste and cargo residues delivered to EU ports have increased significantly151. However, waste 
continues  to  be  discharged  at  sea.  Other  waste  streams,  such  as  oily  waste  and  sewage,  also 
continue to be discharged at sea in contravention with existing discharge norms/prohibitions152. 
Important  underlying  drivers  of  these  problems  were  found  to  be:  the  unavailability  of 

(Pasquini et al., 2016). Indicatively some preliminary results from Fishing for Litter activities in the area show 

that mussel and oyster nets account for almost 30% of the total weight of the items collected. (JRS report: 

Sources of marine litter). 

149 Elaboration from FAO State of World Fisheries and Aquaculture 2016; Total global aquaculture production 

(including freshwater fish, aquatic plants, and marine fish and molluscs) accounts for more than 50% of world 

seafood production. Marine fish and mollusc aquaculture accounts for 26% of global aquaculture production 

or nearly 15% of total global seafood production. 

150 Commission Staff Working Document on Nautical Tourism, SWD(2017) 126 final. 

151 Ex-post evaluation of the PRF Directive, Panteia, 2015 

152 Ecorys (2017). Op. cit. 

60 

 
 
                                                                                                                                                                                 
adequate  reception  facilities  in  ports,  the  lack  of  enforcement  of  the  mandatory  delivery 
obligation for ships, and the lack of economic incentives for delivery153. 

Of  particular  relevance  to  the  fishing  and  aquaculture  sectors  are  instruments  preventing  or 
prohibiting  the  voluntary  discarding  of  plastic  waste,  in  particular  derelict  gear,  on  the  one 
hand,  and  instruments  mitigating  or  promoting  the  recovery  of  lost  gear  which  may  generate 
ghost fishing. While the former can be addressed through environmental protection measures, 
the  latter  has  led  the  Commission  to  undertaking  studies  on  estimating  the  magnitude  and 
impact of ghost fishing154 and on the recovery of ALDFG155. 

The Control Regulation156 requires the mandatory marking of gear as well as the notification and 
retrieval of lost gear. A more detailed assessment of the implementation of the requirements of 
the  Control  Regulation  will  provide  important  information  on  its  impacts  and  potential 
improvements.   

The  European  Maritime  and  Fisheries  Fund  (EMFF)  allows  for  finances  a  variety  of  activities 
combating  litter  from  sea-based  activities  and  especially  so-called  passive  fishing  for  litter,  
whereby fishers bring litter fished up in nets while fishing back ashore. Other potential activities 
are retrieving lost gear, the provision of litter bags for collection at sea,  investments in facilities 
for waste and marine litter collection and processing, recovery and recycling of nets. 

Over  the  seven  year  period  2014-2020,  14  Member  States  envisage  a  total  of  108  fishing  for 
litter  operations  that  are  supported  with  around  €22M  from  EU  funds,  equalling  2%  of  the 
EMFF.  While  the  allocation  is  still  rather  modest,  the  increase  in  comparison  to  the  previous 
funding period is significant with the planned EU financial contribution having more than tripled 
and the number of Member States funding marine litter activities with the EMFF as well as the 
number of projects having at least doubled. . A recent call for proposals will be complementing 
these activities with a number of transnational projects on the reduction, monitoring, removal 
and recycling of marine litter being supported 2019-2020 focussing on long term sustainability  
and buy in from stakeholders. 

Actions to be taken   

Several  and  differentiated  solutions  can  be  envisaged  to  address  the  issue  of  plastic  waste 
originated  from  marine  origin,  fishing  gear  and  aquaculture  products  such  as  developing  new 
policy,  best  practice,  outreach  and  education  to  incite  behavioural  changes,  enforcement  of 
relevant legislation and standard setting to improve the regulatory framework.  

To reduce waste from ships the Commission is putting forward a legislative proposal for a new 
Port Reception Facilities Directive with a two-fold objective:  

153 The REFIT Evaluation that was undertaken for the PRF Directive 2000/59/EC in 2015  

154 Ghost fishing by lost fishing gear (August 2005) DG FISH/2004/20 institute for European environmental 

policy, Poseidon aquatic resource management 

155 Recuperation of fishing nets lost or abandoned at sea (September 2009) Graham, N. 1*, Hareide, N-R.2, 

Large, P.A.3, MacMullen, P.4, Mulligan, M .5, Randall, P.J.3, Rihan, D.5, and Peach, D 

156 Council Regulation (EC) No 1224/2009 of 20 November 2009 establishing a Community control system for 

ensuring compliance with the rules of the common fisheries policy 

61 

 
 
                                                            
1.  Protection  of  the  marine  environment  through  a  reduction  of  discharges  of  ship-
generated  waste  at  sea  and  contributing  to  the  wider  objectives  of  the  circular 
economy;  

2.  Facilitation of maritime transport through a reduction of the administrative burden on 

ships, ports, and competent authorities.  

More specifically, the proposal for a new Directive aims at:  

  Ensuring the availability of adequate waste reception facilities for the use by ships in EU 

ports; 

  Providing effective cost incentives for ships to deliver waste to port reception facilities; 
  Removing barriers to enforcement of the mandatory delivery obligation; 
  Harmonising and update definitions and forms; 
  Harmonising the rules on exemptions for ships in scheduled (i.e. regular) traffic. 

The revision of the Directive aims to achieve the objectives through a combination of measures 
that  seek  further  alignment  with  the  IMO  MARPOL  Convention,  with  a  special  focus  on  the 
delivery of garbage from ships, the main component of marine litter found at sea. The proposed 
measures  also  offer  great  potential  for  supporting  the  circular  economy  in  the  context  of 
handling of waste from ships in ports. These positive effects can be realised at relatively limited 
operational and investment costs. 

The revision is expected to generate the following impacts: 

  Environmental impacts: a substantial part of the illegal waste discharges at sea can be 
important 
reduced  (oily  waste,  sewage,  garbage  and  scrubber  waste),  and  an 
contribution  can  be  made  to  the  circular  economy  (through  special  measures  focused 
on reducing marine litter and improving waste management in port). 

  Economic 

impacts:  Reduction  of  enforcement  costs  and  a  reduction  of  the 
administrative  burden  associated  with  the  process  of  waste  notification  and 
exemptions.  New  business  opportunities  should  be  created  for  PRF  operators.  Costs 
associated  with  separate  collection  of  waste  from  ships  in  ports  should  be  off-set  by 
expected revenues from increased recycling of garbage waste. 

The Commission will also examine options for reducing the loss or abandonment of fishing gear 
at  sea  such  as  via  the  introduction  of  deposit  or  extended  producers  responsibility    The 
potential  of  product  innovation  and/or  substitution  as  well  as  the  introduction  of  recycling 
targets to avoid the release of plastics in the environment and to enhance the recyclability and 
recycling  rates  of  fishing  gear  will  be  assessed.  To  that  end,  he  Commission  launched  a  study 
and a public consultation in December 2017.  

The  Commission  will  also  assess  in  more  detail  the  contribution  of  tourism,  shipping, 
aquaculture and other maritime activities to marine litter and examine a range of measures to 
minimise  plastic  loss  from  aquaculture157.  Furthermore  it  will  continue  its  work  to  improve 
understanding  and  measurement  of  marine  litter,  an  essential  but  often  neglected  way  to 

157 Including the possible adoption of a Best Available Technique reference document for aquaculture 

installations 

62 

 
 
                                                            
support  effective  prevention  and  recovery  measures.  EMODnet,  a  service  set  up  2012  by  the 
Commission  has  been  expanded  to  marine  litter  in  2017.  It  collects,  aggregates,  standardizes 
and  quality  checks  data  from  different  sources  and  facilitates  the  interoperable  sharing  of  
information, data and maps such as on beach, seafloor and microlitter. 

While preventing the leakage of plastic into the marine environment is the first priority, action 
to retrieve some of the plastics floating in the oceans can have a role to play, and is supported 
by EU funds under ‘fishing for litter’ programmes158. The Commission also supports innovative 
technologies  for  retrieval159.  In  this  regard,  fishing  vessels  can  also  make  a  significant 
contribution to solving the problem by picking up litter not only from sea-based sources but also 
from that coming from the land. They can do this by sorting, collecting and landing litter found 
in their nets during normal operations ("passive" fishing for litter) or by making special trips to 
pick  up  litter  ("active"  fishing  for  litter).  These  active  operations  normally  focus  on  lost, 
abandoned to otherwise discarded fishing gear from the seafloor, following identification of hot 
spots  but  there  have  been  some  pilot  or  demonstration  studies160  looking  at  floating  litter  in 
rivers or coasts. Guidelines for passive fishing for litter were discussed and developed within EU 
studies161.  If  many  of  these  operations  are  organized  by  local  authorities,  by  fishers' 
organisations  or  by  regional  sea  conventions,  some  are  financially  supported  by  the  EU162.  In 
total  108  operations  on  fishing  for  litter  are  foreseen163.  The  Commission  will  continue  to 
support  these  actions,  as  well  as  innovative  technologies  for  targeted  and  environmentally 
sound  retrieval  of  plastic  litter,  in  particular  fishing  gear,  taking  into  account  in  particular  the 
international dimension  of  the  issue.  The support to  fishing  for  litter  activities  such as  via  the 
European  Maritime  and  Fisheries  Fund  will  be  continued  and  potentially  stepped  up.  Future 
funding  architectures  will  ensure  that  information  about  the  effectiveness  and  efficiency  and 
environmental  performance  of  such  operations  will  be  provided  and  made  available  for 
experience exchange and the communication of best practice.  

in  the  oceans,  and  part  of  the 

Finally,  international  action  will  remain  key  to  tackling  the  most  significant  sources  of  plastics 
implementation  of  the  Ocean  Governance 
litter 
Communication164.  Ocean  partnerships  will  be  developed  with  a  number  of  countries  for 
enhanced  cooperation  to  ensure  effective  ocean  governance  for  the  conservation  and 
sustainable  use  of  the  oceans,  seas  and  marine  resources.  These  partnerships  will  promote 
cooperation to significantly reduce pollution of all kinds, including from land based sources, in 
the  oceans,  including  marine  plastic  litter  and  micro-plastics.  Cooperation  with  the  United 
Nations Food and Agriculture Organisation (FAO) will be continued with the aim of adopting of 

158 https://ec.europa.eu/easme/en/information-day-blue-growth-calls-under-emff  
159 See, for example, the call under Horizon 2020 to develop and scale up innovative processes to clear the 

sea of litter and pollutants: 

http://ec.europa.eu/research/participants/portal/desktop/en/opportunities/h2020/topics/bg-07-2017.html  

160 https://www.wastefreeoceans.org/ 

161 http://www.marelitt.eu/; https://www.marelittbaltic.eu/, http://ec.europa.eu/environment/marine/good-

environmental-status/descriptor-10/pdf/MSFD%20Measures%20to%20Combat%20Marine%20Litter.pdf  

(p.152-198)  

162 It included a total of €14 million's worth of such measures in their operational programs which define how 

they will spend their allocations from the European Maritime and Fisheries Fund (EMFF) in 2014-2020. 

163 Namely: BE (5), BG (7), CY(2), DE(8), ES(10), I(3), HR(15), IE(2), IT(20), PL(3), PT(6), RO(3), SE(19), UK(5) 

164 The Our Ocean 2017 conference hosted by the EU in Malta in October 2017 gathered more than 100 

commitments worth almost 3 billion EURO addressing marine pollution, including plastics.  

63 

 
 
                                                            
international  guidelines  on  the  reporting  and  recovery  of  abandoned,  lost  and  otherwise 
discarded fishing gear. The significant contribution of fish aggregating devices (FAD) to marine 
litter  will  be  addressed  by  supporting  the development of  biodegradable FADs  as  well as  cost 
effective  recovery  practices,  and,  finally,  awareness  and  compliance  of  MARPOL  rules  on  the 
disposal  of  plastics  at  sea  and  of  the  EU  rules  on  the  discharge  of  waste  at  port  reception 
facilities will be promoted amongst regional fisheries management organisations. 

4.1.4  Agricultural plastics 

Issues at stake   

Plastics  are  used  for  a  number  of  purposes  in  agriculture  (“ag-plastics”)  such  as  mulch  films, 
tunnels, pipes and irrigation systems for vegetable production and silage films, nets and twines 
for  storing  feed  for  livestock.  Pesticide  and  fertiliser  bags  and  containers  are  considered  as 
packaging.  Mulch  films  are  most  commonly  used  to  preserve  soil  moisture  and  suppress  the 
proliferation of weeds. They reduce the need for water and pesticide and protect against harsh 
climate conditions.  

In  2015,  36%  of  the  vegetable  production  in  EU  was  located  in  just  two  member  states:  Italy 
(19.5%) and Spain (16.6%)165, where these were grown under greenhouse cover (glass or mainly 
plastic) to control humidity: in Spain (17.2%) and Italy (13.3)166. These two Member States are 
part of the biggest agriculture plastics waste producers in the EU (see below).    

Agricultural  plastics  accounted  for  3.3%  of  the  total  plastics  market  in  Europe  in  2015  (1.6 
million  tonnes)167.  As  an  alternative  to  the  conventional  plastics,  also  biodegradable  and  oxo-
plastics, in particular for mulch films, are used  (see chapters on biodegradable plastics and on 
oxo-plastics).  

Greenhouses and tunnels allow for a longer growing season for a wider variety of plants168 LDPE 
films represent 78% of the total volume of agricultural plastics in Europe, with 27% being used 
for greenhouses and tunnels169.  

There  is  not  much  information  on  market  size.  In  the  case  of  mulch  films  APE  estimated  the 
market  size  was  80,000  tonnes  in  2013170.  European  Bioplastics  suggest  5%  of  these  are 
biodegradable (4,000 tonnes).  

Eunomia’s  research  into  oxo-plastics  estimated  that  10,000  tonnes  were  used171.  Although  a 
rather  small  part  of  the  plastic  applications,  oxo-plastics  present  a  risk.  If  left  on  the  ground, 

165 The fruit and vegetable sector in the EU - a statistical overview - Statistics Explained, accessed 6 July 2017, 

http://ec.europa.eu/eurostat/statistics-

explained/index.php?title=The_fruit_and_vegetable_sector_in_the_EU_-_a_statistical_overview&oldid=306933 

166 The fruit and vegetable sector in the EU - a statistical overview - Statistics Explained. op. cit.  

167 Plasteurope.com - AGRICULTURAL PLASTICS: European and worldwide markets / Collection schemes and 

technical developments / Bettering the image of recycled material, accessed 29 June 2017, 

https://www.plasteurope.com/news/AGRICULTURAL_PLASTICS_t236846/ 

168 Le Moine, B (2015). Plastics in agriculture: a contribution to Intensive Ecological Agriculture (IEA). 

http://www.plastiques-agricoles.com/wp-content/uploads/2016/06/Plasticulture-02.pdf 

169 CIPA & APE (2016), Plasticulture – Agriculture Ecologically Intensive, n°135 

170 http://www.apeeurope.eu/statistiques.php 

171 Eunomia 2017  

64 

 
 
                                                            
oxo-plastics  can  reduce  soil  fertility172  and  may  lead  to  micro-plastics  release  into  soil  and 
accumulation and the aquatic environment. 

In the  EU,  1,326  thousand tonnes  of  agriculture  plastics  waste  were  produced  in  2014173. The 
largest producers of agriculture plastics waste in Europe are Germany, Italy, Spain, UK, France 
(>150  thousand  tonnes  in  2014),  and  Poland  (89  thousand  tonnes)174.  Despite  agricultural 
plastics  having  a  high  potential  for  recycling—due  to  them  being  produced  in  large  quantities 
and  composed  of  relatively  homogeneous  material  -  only  28%  of  agricultural  plastics  are 
recycled in EU, while 30% are sent to energy recovery facilities and 42% to landfill175. Low rates 
of reuse and recycling in the agricultural sector is thought to be caused by a number of reasons. 
Reuse  is  impractical  as  the  plastic  materials  tend  to  be  heavily  weathered  and  can  be 
contaminated with pathogens176 and soil. In recycling, the following barriers are reported: 

 

In  the  absence  of  an  EU  wide  obligation  to  set  a  collection  scheme  for  agricultural 
plastics,  only  five  Member  States  have  established  collection  systems177.  In  other 
countries, there is a limited infrastructure in place that enables farmers and growers to 
easily recycle their plastics. 

  Agricultural  plastics  accumulate  large  amounts  of  contaminants  over  their  lifetime 
(water,  soil,  sand  and  organic  matter)  reaching  up  to  four  times  their  weight178.  The 
transport  and  treatment  is  therefore  costly  and  requires  careful  cleaning  before 
processing.  

  Plastics  films  have  to  attain  a  certain  thickness  as  otherwise  they  will  tear  while 

collecting. 

Five EU Member States179 currently have national collection schemes in place and mostly report 
much  higher  than  average  recycling  rates  whilst  ten  EU  member  states  currently  report  a  0% 
recycling rate.180 The highest levels are achieved in Sweden (68%) and Ireland (63%), while much 
lower  rates  are  observed  in  Eastern  European  countries  (0%  in  Bulgaria,  Romania,  Slovenia, 
Slovakia).  

Box 4. Examples of existing collection and recycling schemes for agricultural plastics 

Ireland  

In  1997,  Ireland  introduced  legislation  designed  to  assist  and  promote  the  recycling  of 
agricultural  plastics  (silage  wrap,  bags,  sheeting,  and  as  of  1st  October  2017,  netting  and 

172 Personnal communication with Bernard Le Moine at APE Europe 

173 Consultic (2014) Post-Consumer Plastic Waste Management in European Countries 2014, Report for 

PlasticsEurope, 15th October 2015 

174 Consultic (2014). Op. cit. 

175 Consultic (2014). Op. cit. 

176 Cameron, A. (2009) Problems with Plastics, Chronica Horticulturae-Subscription, Vol.49, No.1, p.8 

177 Agricultural plastics european regulation: APE Europe, accessed 29 June 2017, http://www.plastiques-

agricoles.com/ape-europe-missions/agricultural-plastics-european-regulation/ 

178 CIPA & APE (2016), Plasticulture – Agriculture Ecologically Intensive, n°135 

179 Member States with existing collection schemes are: France, Germany, Ireland, Spain and Sweden. Eunomia 

(2017) assumes that the Netherlands and Italy will also implement a scheme. 

180 Consultic (2014) op. cit. 

65 

 
 
                                                            
twine).181  The  Waste  Management  (Farm  Plastics)  Regulations  (2001)  is  mandatory.  As  a 
consequence  all  producers  are  members  of  the  IFFPG  (Irish  Farm  Film  Producers  Group), 
Ireland’s  sole,  government  approved,  farm  plastics  collection  /  recycling  compliance 
scheme.182 The IFFPG is funded through a recycling levy charged to producers; and a weight 
based collection fee charged to farmers. The IFFPG arranges the collection and recycling of 
farm  plastics  across  Ireland,  either  through  bookable  farmyard  collections  or  a  number  of 
local one-day bring-centres (it ran 237 in 2016).183   

The scheme is operating successfully. In  2016, the IFFPG collected 27,193 tonnes of farm 
plastics waste, a c.2000 tonne increase on the previous year184. The IFPPG recycled 74% of 
what  producers  placed  on  the  market  in  the  previous  year,  after  allowing  for  a  50% 
contamination  level  (mainly  moisture).  This  exceeded  the  target  of  70%185.  Of  the  plastics 
collected, over 60% was supplied to Irish recyclers, supporting the national economy.  

France 

Under French regulation there are no specific take back obligations for agricultural plastics, 
rather it is stipulated that producers, importers and distributors of waste generating products 
may,  in  accordance  with  the  principle  of  extended  producer  responsibility,  be  required  to 
manage their disposal.186 The French agri-plastics industry has created a national voluntary 
EPR initiative, managed by a private not-for-profit organisation called ADIVALOR, created 
in 2001. 187,188  

The  collection  and  treatment  of  the  waste  that  ADIVALOR  manages  is  largely  funded  by 
manufacturers and suppliers. They are charged an ‘eco-fee’ when they place product on the 
French market. The French Environment and Energy Management Agency provided  €2.8m 
of support over 5 years to help in the implementation of the recovery scheme for agricultural 
films.189 Farmers return any uncontaminated waste to one of c.6000 collections points across 
France.190 Farmers are not charged for this service.  

ADIVALOR’s statistics indicate that the scheme is  successful. As of 2015, there were 385 
producers,  1,200  distributors  and  280,000  farmers  participating  across  all  materials.191  The 
collection  rate  of  agricultural  film  increased  from  42%  in  2009  (the  first  year)  to  71%  in 

181 Waste Management (Farm Plastics) (Amendment) Regulations 2017 

http://opac.oireachtas.ie/AWData/Library3/CCAEdoclaid080917_122641.pdf  

182 Irish Farm Film Producers Group http://www.farmplastics.ie/farm-plastic-regulations/ Date accessed 

09/10/17 

183 IFFPG (2017) Environmental Report 2016 

184 The fruit and vegetable sector in the EU - a statistical overview - Statistics Explained. op. cit. 

185 Idem  

186 Environmental Code - Article L541 – 10  

187 Agriculture Plastic and Environment http://www.plastiques-agricoles.com/agriculture-plastique-et-

environnement-ape-commission-ape/ Date accessed 10/10/17 

188 ADIVALOR Used Agriplastic Film http://www.adivalor.fr/en/collectes/films_agricoles_usages.html Date 

accessed 10/10/17 

189 ADIVALOR 2014 Report http://www.adivalor.fr/en/adivalor/2014_report.html Date accessed 10/10/17 

190 ADIVALOR presentation 2015 

http://www.srsweb.sk/dokumenty/6RLD/1%20den/04%20%20Presentation%20of%20ADIVALOR%20-

%20EN.pdf 

191 ADIVALOR presentation 2015 

http://www.srsweb.sk/dokumenty/6RLD/1%20den/04%20%20Presentation%20of%20ADIVALOR%20-

%20EN.pdf 

66 

 
 
                                                            
 
2014, with almost 50,000 tonnes collected. ADIVALOR’s current objective is to collect 75% 
of all used agri-plastic film.192 

Spain (Andalusia) 

As  set  out  in  Decree  73/2012  (Waste  Regulation  of  Andalusia),  producers  of  agricultural 
plastic  in  Andalusia  (an  autonomous  region  which  consumes  large  amounts  of  agricultural 
plastics)  are  legally  required  to  participate  in  a  management  system  that  guarantees  the 
collection and management of any waste generated. Cicloagro, a public private partnership, 
was set up to help producers meet their obligations. The organisation covers non-packaging 
agricultural plastics e.g. films, tape, irrigation lines and mesh. 

Cicloagro  is  financed  by  an  ‘eco-protection’  tax  levied  on  the  sale  of  plastic  agricultural 
products.  Farmers  clean  and  sort  their  used  plastics,  before  delivering  it  to  an  authorised 
collection point – there is no charge for this service.  

Germany 

In  2013,  the  German  industry  association  for  plastic  packaging  in  partnership  with  waste 
disposal  specialist  RIGK,  created  a  national  recovery  system  for  agricultural  film.  The 
scheme,  called  ERDE,  started  to  collect  a  variety  of  film  types  in  2014.  Its  activities  are 
funded by member companies i.e. manufacturers and importers. ERDE’s success is reliant on 
voluntary  participation;  currently  there  are  7  participating  manufacturers  and  over  20 
collection partners193. 

Farmers are incentivised to return their used plastics to collection points by a bonus which 
can be redeemed against a future purchase. 

According  to  RIGK,  ERDE  collected  5412  tonnes  of  agricultural  film  in  2016,  a  16.6% 
increase  in  comparison  to  2015194.  It  planned  to  further  increase  this  figure  in  2017  by 
expanding its network of collection points. 

Eunomia (2017) modelled the waste growth for the coming year, indicating an overall increase 
in agricultural plastic waste growth of 26 thousand tonnes per year (2% increase). 

192 ADIVALOR missions and objectives http://www.adivalor.fr/en/filiere/presentation/objectifs.html Date 

accessed 10/10/17 

193 ERDE recycling http://www.erde-recycling.de/en/about-erde/what-is-erde.html Date accessed 11/10/17 

194Agricultural Film Recycling  

https://www.plasteurope.com/news/AGRICULTURAL_FILM_RECYCLING_t236996/ Date accessed 11/11/17 

67 

 
 
 
                                                            
Figure 11. Arising of plastic agricultural waste by Member State in 2014, kg per capita 

Source: Consultic195 

There  is  also  a  high  risk  for  plastic  films  to  be  left  on  agricultural  soils  in  amounts  that  may 
reduce soil fertility and that may run off into surface waters with associated impacts to riverine 
and marine life. 

There is no overarching European regulation on the management of agricultural plastics waste. 
Article  8  of  the  Waste  Framework  Directive  (2008/98/EC)  specifies  that  Member  States  may 
include  the  concept  of  extended  producer  responsibility  (EPR)  into  their  legislative  or  non-
legislative measures relating to waste management. 

Actions to be taken  

The main objectives related to agricultural plastics are: 

Low level of plastic films left on agricultural soils; 

 
  High rate of reuse; 
  High rates of collecting and recycling. 

 Agriculture  Plastic  Environment  (APE)  Europe  aims  for  an  increase  in  recycling  of  agricultural 
plastics  to  70%  across  Europe  by  2022196.  Stakeholder  suggested  the  following  potential 
solutions197 : 

  Facilitate the development of national collection systems. 
  Change in practices and investment by growers to adopt new practices around the 

collection of soiled mulched films in order to facilitate their recycling.  

More  specific  issues  include  solutions  for  the  better  collecting  and  decontamination  of 
agricultural mulches, in order to achieve higher recycling rates. 

195 Consultic (2014). Op. cit. 

196 APE Europe (2017) Ten Year Plan for Europe, Accessed 11th October 2017, http://www.plastiques-

agricoles.com/ape-europe-missions/ 

197 Eunomia (2017). Op. cit. 

68 

 
 
 
                                                            
The  Commission  will  consider  and  further  assess  how  to  improve  and  increase  recycling 
agricultural plastic waste rates across the EU. This stepwise approach will be based on positive 
examples  from  Member  States  having  set  deposit  refund  schemes  and  well-functioning 
collection and recycling schemes. The Commission will carefully assess the potential impact on 
the  environment  and  include  in  its  analysis  the  existing  alternatives  such  as  plastics  with 
biodegradable properties.  

4.2  Establishing  a  clear  regulatory  framework  for  biodegradable 

plastics 

4.2.1 

Issues at stake  

In response to the high degree of plastic leakage into our environment and its harmful effects 
for  a  very  long  period  of  time,  solutions  have  been  sought  to  design  biodegradable  and 
compostable plastics198. There is however considerable debate as to the extent to which plastics 
intended to be biodegradable do actually biodegrade in the natural environment. Although the 
current  situation  may  therefore  seem  challenging,  plastics  with  biodegradable  properties  can 
also bring additional benefits if the appropriate decisions are taken.  

Terminology  

In  the  first  place  attention  should  be  given  to  the  correct  use  of  terminology.  The  current 
situation  is  somehow  confusing  for  consumers  who  might  think  that  all  plastics  labelled 
biodegradable  are  capable  of  biodegrading  in  nature  without  any  human  intervention  as  it 
happening  for  organic  material.  It  is  of  utmost  importance  that  consumers  are  properly 
informed  and  aware  of  the  meaning  of  the  different  concepts  and  of  the  proper  handling  or 
end-of-life treatment, the risk being that plastic items are incorrectly handled or disposed of at 
the end of their useful life.  

In a biodegradation process, plastics are 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)199.  Biodegradability  depends  strongly  on  the 
environmental  conditions:  temperature,  presence  of  microorganisms,  presence  of  oxygen  and 
water.  So  both  the  biodegradability  and  the  biodegradation  rate  of  a  plastic  may  be  different 
depending on the environment e.g. in soil, on the soil, in humid or dry climate, on the surface 
water,  in  marine  ecosystems  or  in  human-made  systems  like  home  composting,  industrial 
composting or anaerobic digestion200. 

A distinction needs to be made between industrial and home composting. Industrial composting 
conditions  require  elevated  temperature  (55-60°C)  combined  with  high  relative  humidity  and 
the  presence  of  oxygen.  Industrial  composting  takes  place  under  given  and  predictable 
conditions.  Home-composting  is  characterised  by  typically  uncontrolled  conditions.  Home-
composting process takes much longer compared to industrial composting as the temperature 

198 https://wedocs.unep.org/bitstream/handle/20.500.11822/7468/-

Biodegradable_Plastics_and_Marine_Litter_Misconceptions,_concerns_and_impacts_on_marine_environments-

2015BiodegradablePlasticsAndMarineLitter.pdf.pdf?sequence=3&isAllowed=y  

199 European Centre for Ecotoxicology and toxicology of chemicals, Technical report 123, Definitions 

according to OECD 

200 Bio-based and biodegradable plastics – Facts and Figures, Wageningen, 2017 

69 

 
 
                                                            
in home-compost heaps is generally lower and other necessary conditions vary greatly between 
Member States, depending to a great extent on the geographical and climatological situation as 
well on individual actions taken by households.  

As  pointed  above,  biodegradability  and  the  biodegradation  rate  strongly  depend  on  the 
environmental  conditions201.  Although  every  plastic  will  eventually  biodegrade  at  some  point, 
even in the open environment, be it after hundreds of years, it only makes sense to speak about 
biodegradation  in  specific  environments  (e.g.  aquatic  environment,  marine  ecosystems,  soil 
industrial or home-composting installations) and with reference to the time frame.  

A distinction should also be made between bio-based and biodegradable plastics. They are not 
synonymous.  "Bio-based  plastics"  simply  means  that  they  are  wholly  or  partly  derived  from 
materials of biological origin and have the same properties as conventional plastics. Hence, one 
should keep in mind that although they can, not all bio-based plastics are biodegradable and not 
all biodegradable/compostable plastics are bio-based.  

The  use  of  appropriate  language  and  terminology  is  of  a  paramount  importance.  For  the 
purposes of the Plastics Strategy: 

 

 

 

 
 

"Biodegradable plastics"  means  plastics  that  can  be  bio-transformed and decomposed 
by  microorganisms  into  water,  occurring gases  like  carbon  dioxide (CO2)  and  methane 
(CH4) and biomass (e.g. growth of the microorganism population).  
"Compostable plastics" mean plastics with enhanced biodegradable properties that are 
intended to be decomposed in an industrial composting plant.  
"Home-compostable  plastics"  mean  biodegradable  plastics  that  are  capable  of  being 
biodegraded at lower temperatures and in less constant and controlled conditions than 
those  put  in  place  in  industrial  composting  plant  (e.g.  lower  turning  frequency,  less 
optimal moisture conditions) and which are usually present in compost heaps or bins or 
in small-scale closed systems for home-composting by private households.    
"Bio-based plastics" mean plastics wholly or partly derived biomass. 
"Bio-based biodegradable plastics" mean plastics wholly or partly derived from biomass 
and having biodegradable properties.  

Standards  

As  a  response  to  the  biodegradability  concerns,  standards  have  been  adopted  but  a  general 
standard for biodegradability of plastics in an open and uncontrolled environment has not been 
developed as biodegradability depending on specific and too diverse conditions.  

Standards  with  criteria  especially  acceptable  test  conditions  including  time  frames  mimicking 
the  different  natural  environmental  compartments  and  conditions  for  biodegradation  that 
doesn't  take  place  in  industrial  composting  facilities  are  still  lacking.  Such  standards  exist  for 
composting  of  plastics  and  plastic  packaging  both  at  international  level  (ISO  standard 
17088:2012 defining specifications for compostable plastics202) and European level (harmonized 
standard  EN  14995  defining  requirements  for  plastics  recoverable  through  composting  and 

201 CE Delft Bio-based Plastics in a Circular Economy; September 2017, p. 22 

202https://standards.cen.eu/dyn/www/f?p=204:110:0::::FSP_PROJECT,FSP_ORG_ID:21783,6230&cs=12459CC

C96FCD875A348D49110FF2D1BF 

70 

 
 
                                                            
biodegradation203;  and  harmonized  standard  EN  13432  defining  requirements  for  packaging 
recoverable through composting and biodegradation under industrial composting conditions204).  

A specific standard was also published in November 2017 for biodegradable mulch films for use 
in agriculture and horticulture205. It is applicable to films intended to biodegrade in soil without 
creating  any  adverse  impact  on  the  environment.  It  also  specifies  the  test  methods  to  assess 
these  requirements  as  well  as  requirements  for  the  packaging,  identification  and  marking  of 
films. For information, it defines a classification of biodegradable mulch films according to their 
service life on soil and gives a good practice guide for the use of the films. Films intended to be 
removed  after  use  and  not  incorporated  in  the  soil  are  not  in  the  scope  of  this  standard  (EN 
13655). 

is  not  biodegradable 

There is no EU harmonised standard for home-compostable plastics. Plastic packaging meeting 
the requirements of the standard EN 13432 is only biodegradable and compostable in industrial 
installations  and 
in  non-controlled 
environments  such  as  home-compost  heaps.  Italy  developed  already  in  2006  a  national 
in  home  composting  (requirements  and  test 
standard  for  plastic 
methods)206.  Such  national  standard  was  also  introduced  in  Australia  in  2010  (AS  5810)  and 
followed  in  2015  by  France207.  Currently,  even  without  a  European  standard  for  home 
composting  there  are  certification  schemes,  often  based  on  the  Australian  standard  (e.g. 
certified by Vinçotte "OK Home Compost").  

in  the  open  environment  or 

items  biodegradable 

Environmental impacts 

Current plastic offers functional benefits, but has an inherent design failure: its intended useful 
life is typically short but the material persists for centuries, which is particularly damaging if it 
leaks  outside  collection  systems.  Efforts  to  reduce  leakage  are  hence  paramount.  One  should 
also  keep  in  mind  that  even  though  plastics  are  marked  "biodegradable"  if  they  are  littered, 
they can still cause harm to the ecosystems before they are fully biodegraded. Most currently 
available  biodegradable  plastics  generally  degrade  under  specific  conditions  which  may  not 
always be easy to find in the natural environment. Biodegradation in the marine environment 
has not been proven. 

Labelling consumer plastics as  biodegradable without indicating the conditions under which it 
will biodegrade (e.g. industrial or home composting) may also deliver the wrong message as it 
might lead to think that in some cases it is acceptable for plastics being designed to be littered. 

However, biodegradable or compostable plastic may be the preferred option for some specific 
applications  where  their  benefits  outweigh  their  possible  disadvantages  keeping  in  mind  that 
recycling  of  plastics  is  generally  preferable,  because  the  material  is  kept  in  the  economy  and 
risks  for  the  environment  are  limited.  More  specifically  regarding  plastic  mulches  used  for 
agricultural  purposes,  there  is  also  a  high  risk  for  conventional  plastic  films  to  be  left  on 

203https://standards.cen.eu/dyn/www/f?p=204:110:0::::FSP_PROJECT,FSP_ORG_ID:13285,6242&cs=16419E07

9DF816FA31BA049B6F9169CF8 

204 UNEP  Vital Marine Graphics 2016 p.7 

205 EN 17033   

206 UNI 11183:2006 

207 NF T51-800 November 2015 

71 

 
 
                                                            
agricultural  soils  in  amounts  that  may  reduce  soil  fertility  and  that  may  run  off  into  surface 
waters  with  associated  impacts  to  riverine  and  marine  life.  For  this  reason,  the  use  of  plastic 
mulches  capable  of  biodegrading  in  soil  increased  over  the  last  years208.  There  is  not  much 
information  on  market  size.  However,  the  risk  of  accumulation  of  plastic  mulches  that  finally 
biodegrades  much  slower  given  the  differences  between  geographical  and  climatological 
situation across the EU.   

Another  good  example  is  the  use  of  biodegradable  plastic  bags  to  collect  organic  household 
waste (or bio-wastes) or catering food wastes. These bags can be composted together with this 
collected organic waste without running the risk of being mixed with other plastic or any other 
waste streams where they would disqualify the resulting composts due to plastics impurities or 
hamper  recycling  if  bio-degradable  plastics  are  not  sorted  from  other  plastic  wastes  streams. 
Another  example  might  be  the  use  of  biodegradable  packaging  for  food  where,  after 
consumption, the packaging remains with some food inside and is collected and kept separate 
for  composting  in  industrial/professional/certified  installations.  This  however  seems  to  be 
restricted to specific cases, where there would be a minimised risk for confusing the consumer. 
It  should  be  clear  that  such  packaging  has  still  to  be  disposed  of  in  appropriate  manner  and 
should not be littered.  

Most  biodegradable  and  compostable  plastics  are  only  compostable  if  they  are  mixed  with  a 
sufficient  amount  of  organic  material  and  under  specific  controlled  conditions,  such  as  a 
sufficiently  and  constantly  high  temperature,  humidity  specific  quantity  and  level  of  UV 
radiation, presence of specific level of oxygen, presence of specific micro-organisms in sufficient 
quantities. Contradictory messages on the capacity of  biodegradable plastics to disintegrate in 
industrial composting plants are also spread209. 

In  general,  as  pure  as  possible  plastic  streams  are  needed  for  plastic  mechanical  recycling. 
Biodegradable plastics when mixed with conventional plastics may also hamper the mechanical 
recycling  process.  According  to  plastic  recyclers,  the  presence  of  even  a  small  percentage 
(between  2%  and  5  %)  of  biodegradable  and  compostable  plastic,  whether  industrially 
compostable or home-compostable, in plastic waste that is collected for recycling, might have a 
negative impact on the quality of the recycled plastic210. On the other side the influence of bio-
based  biodegradable  plastics  on  the  quality  of  the  recyclates  was  also  studied  within  EU  FP7 
Open-Bio  project  in  film  plastic  recycling.  It  was  found  that  up  to  10%  biodegradable  plastic 
(starch  based  or  PLA)  does  not  have  a  negative  effect  of  the  properties  of  products.  PVC  (a 
conventional plastic) and PLA were studied as contaminants of recycled PET. It was concluded 
that it has a detrimental effect on the quality of recycled PET, whereas no specific threats were 
found in case of PLA contamination211.  

208 The estimated market size for all plastic mulching films was 80,000 tonnes in 2013 
(http://www.apeeurope.eu/statistiques.php) out of which 4,000 tonnes are thought to be biodegradable 

(http://ec.europa.eu/transparency/regdoc/?fuseaction=feedbackattachment&fb_id=72FDC5F4-0A1D-B942-
A363D85479EE9DEF) 
209 Parallel session on bio-based biodegradable organised on the frame of the Plastic Strategy conference 

September 2017 

210 http://www.plasticsrecyclers.eu/news/biodegradable-plastic-bags-are-myth  

211 Bio-based and biodegradable plastics – Facts and Figures, page 41,42 Wageningen, 2017 

72 

 
 
                                                            
Another concern might be that organic waste streams and input for composting might also be 
contaminated by the presence of non biodegradable/non compostable plastics where consumer 
might be misled to consider that bio-based plastics have also biodegradable properties. Hence, 
the use of currently labelled biodegradable and compostable plastics may be more suitable for 
closed waste streams.  

The  current  situation  is  somehow  confusing  for  consumers  who  might  think  that  plastics  are 
capable of biodegrading in nature without any human intervention as it happening for organic 
material.  It  is  of  utmost  importance  that  consumers  are  properly  informed  and  aware  of  the 
meaning of the different labels, concepts and of the proper handling or end-of-life treatment, 
the risk being that plastic items are incorrectly handled or disposed of at the end of their useful 
life.  

The  Commission  is  currently  developing  an  Implementing  Act  establishing  marks  or  labels  for 
different types of biodegradable and/or compostable plastic carrier bags, to inform consumers 
throughout the EU  how  to  properly  and without causing negative impact  on  the environment 
deal with the different plastic carrier bags when these are no longer suitable as carrier bag. 

4.2.2  Actions to be taken  

The  Commission  will  propose  harmonised  rules  for  defining  and  labelling  compostable  and 
biodegradable plastics.  

Plastics  with  biodegradable  properties  may  be  seen  as  a  way  forward  for  some  specific 
applications  where  their  benefits  outweigh  their  possible  disadvantages  of  naturally  slower 
degradation pace. Therefore, the following is needed: 

  Establish  criteria  under  which  the  use  of  biodegradable  plastics  is  appropriate  and 

 

justified; 
Identify  applications  that  would  fall  under  these  criteria  (e.g.  establishing  a 
positive/negative  list),  or  which  would  fall  under  these  criteria  if  clearly  defined 
measures are taken (e.g. separate collection e.g. biodegradable and non-biodegradable 
plastics); 

  Develop  tools  for  communication  towards  both  consumers  and  professionals  to 
reinforce  the  protection  against  false  green  claims  and  avoid  confusion.  Such  tools 
should provide in a clear, accessible and comprehensive manner the evidence on which 
is based the biodegradability claim.  

This assessment should be discussed with the actors representing the whole value chain from 
plastic producers to recyclers including civil society representatives. The discussion should take 
into  account  differences  across  the  EU.  It  should  be  clear  that  such  plastics  have  still  to  be 
disposed of in appropriate manner and should not be littered.  

The  Commission  will  develop  lifecycle  analysis  to  identify  the  conditions  where  the  use  of 
biodegradable or compostable plastics is beneficial, and criteria for such applications. This could 
also  help  to  decide  whether  new  standards  are  needed  and  which  ones  (e.g.  biodegradable 
plastics or home-compostable plastics).  

73 

 
 
Another  way  forward  could  be  developing  a  standard  for  biodegradability 
in  specific 
environmental  compartment  (water,  soil,  marine  environment).  While  establishing  such  a 
standard,  a  particular  attention  should  be  paid  to  consumers  understanding  of  different 
markings  and  labelling  and  the  way  to  handle  plastic  and  organic  waste  as  it  may  deliver  the 
wrong message as it might lead to think that in some cases it is acceptable to design plastics for 
being littered and even to litter the products made out of this plastic.  

A  standard  for  home-compostability  could  provide  an  alternative  for  people  living  in  places 
where a separate collection of organic waste has not yet been put in place or in places where it 
is  not  technically  feasible  while  also  delivering  a  message  that  plastics  are  designed  for  a 
purpose e.g. to keep valuable organic nutrients in the loop. It will be however insufficient on its 
own  and  should be accompanied by  the  obligation  to  collect separately organic waste.  At  the 
same time, one should also ensure that recyclability and recycling remains the preferred route 
for an appropriate end-of-life stage. 

Adequate and separate plastic and organic waste collection and sorting will ensure clean waste 
streams, will help to avoid contamination and will contribute to increase the recycling rates. In 
addition, these actions will to close the cycles of bio-wastes and help producing safe fertilising 
products based on composts and digestates in line with the recent Commission proposal for the 
placing on the market of CE-marked fertilising products. 

Regarding  the  biodegradability  of  plastic  mulching  films,  the  topic  is  to  be  further  considered 
and discussed in order to understand all the pros and cons, risks for the environment and the 
best  way  forward  in  line  with  the  circular  economy  principles  given  that  a  new  standard  has 
been published recently.  

4.3  Oxo-degradable plastics: addressing the growing concerns  

4.3.1 

Issues at stake 

So  called  oxo-plastics  or  oxo-degradable  plastics  are  conventional  plastics  which  include 
additives designed to promote the oxidation of the material to the point where it brittles and 
fragments212. The producers of the additives claim that the plastic to which they are added, are 
"oxo-biodegradable". Whether additives perform in the way in which their manufacturers claim 
they  will  and  whether  these  materials  have  an  added  value  from  the  environmental  point  of 
view, have been debated for some time now.  

In  early  November  2017  the  Ellen  MacArthur  Foundation  published  a  statement  of  150 
organisations calling for a global ban on oxo-degradable plastic packaging given the impacts of 
the fragmentation on the environment leading to more micro-plastics pollution and promoting 
the  idea  that  materials  and  products  should  be  designed  in  line  with  the  circular  economy 
principles213. Signatories include leading businesses, industry associations, NGOs, scientists, and 
elected officials.  

212 "The Impact of the Use of "Oxo-degradable" Plastic on the Environment", Eunomia, August 2016 

213 https://newplasticseconomy.org/news/over-150-organisations-back-call-to-ban-oxo-degradable-

plastic-packaging  

74 

 
 
                                                            
The  Commission,  taking  into  consideration  the  growing  concerns  about  the  use  of  such 
materials  and  based  on  the  existing  significant  evidence  and  the  studies  that  were  recently 
carried out214 has decided to pay a particular attention to the future use of these materials and 
the false green claims attached to it.  

The main applications of oxo-degradable plastics are  

  Agricultural  film  but  also  other  applications  are  quite  common,  e.g.  wrapping  hay, 

potting containers, tree ties and vegetable sacks; 

  Rubbish bags; 
  Carrier bags; 
  Food packaging (e.g. bread bags, food trays and films, freezer bags and drinks bottles); 
 
  Other miscellaneous applications such as disposable medical supplies (gloves), envelope 

Landfill cover; 

windows, plastic covers for mail items, etc. 

Several issues have been identified.  

In the first place, the so called oxo-degradable plastics do not biodegrade in open environment 
i.e.  are  not  decomposed  by  microorganisms  into  harmless  elements  that  are  found  in  nature, 
such as CO2, water and biomass, nor are recoverable through composting. These materials are 
to be considered to rather fragment in tiny pieces exacerbating the micro-plastics accumulation 
in  soils.  There  is  no  proof  of  oxo-degradable  plastics  capacity  to  biodegrade  in  the  marine 
environment.  The  additives  used  only  mimic  biodegradation.  Those  additives  make  the 
fragmentation process easier and quicker without leading to biodegradation 

The potential toxic effects on soils of any residual additives have been identified as a concern by 
some commentators. However, more research on this topic is needed.  

The appellation "oxo-degradable plastics" contributes to the existing consumers' confusion due 
to the use of wide range of similar terms (see above) where the use of "degradable" creates a 
belief  that  the  substance,  materials  or  article  cause  no  harm  to  the  environment  if  it  is  not 
properly disposed of or is littered. This is the case for plastics labelled oxo-degradable plastics. 
Moreover, based on what is pointed out above, there might also be an issue from the point of 
view  of  misleading  advertising.  False  green  claims  fall  within  its  scope.  The  expressions 
'environmental claims' or 'green claims' refer to the practice of suggesting or otherwise creating 
the impression − in the context of a commercial communication, marketing or advertising, that 
a  product  or  a  service,  is  environmentally  friendly,  i.e.  it  has  a  positive  impact  on  the 
environment, or is less damaging to the environment than competing goods or services215. The 
environmental  claim  is  misleading  because  it  contains  false  information  and  is  therefore 
untruthful  (e.g.  oxo-degradable  plastics  when  for  which  no  tests  of  their  capacity  of 
biodegradation  are  not  conclusive.  Consumers  need  to  have  clear  and  reliable  information  to 
make sustainable choices in order to be able to easily identify  the ‘right’ product or service to 

214 Study to provide information supplementing the study on the impact of the use of "oxo-degradable" plastic 

on the environment"; Final Report; April 2017 

215 http://ec.europa.eu/consumers/consumer_evidence/market_studies/docs/green-claims-report-

appendix-4.pdf  

75 

 
 
                                                            
purchase.  Information  of  this  nature  is  provided  by  business  by  means  of  a  range  of 
environmental/green claims.  

Oxo-degradable  plastics  can  also  affect  negatively  the  purity  of  plastic  waste  streams,  the 
quality  of  recycled  plastics  as  they  cannot  be  separated  and  sorted  out,  and  in  a  long  term 
significantly impair the physical qualities and service life of the recycled product.  

Some Member States have already taken action to restrict the use of oxo-degradable plastics:  

  ES, FR and IT already have a ban on oxo-plastics; 
  BE,  HU,  BG  have 
biodegradable;  
IT:  new  law  will  force  the  oxo-industry  to  give  info  on  the  negative  environmental 
impact of these plastics on the environment; 

legislation  that  forbids  oxo-plastics  to  claim  that  they  are 

 

  SW, UK: studying the issue and considering restrictive measures. 

4.3.2  Actions to be taken  

Actions  taken  by  Member  States  might  lead  to  a  fragmentation  of  the  internal  market. 
Therefore a harmonised EU wide approach is needed. The Commission will start work to restrict 
the use of oxo-plastics in the EU. 

4.4  The rising problem of micro-plastics   

4.4.1 

Issues at stake 

Rising concerns  

Micro-plastics are plastic particles of a size below 5 mm, 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. They are  dispersed and find their way into the 
environment by the wind or via sewage, rain drainage systems and/or rivers reaching coast side 
and  ending  up  in  the  marine  environment.  To  these  micro-plastics  one  should  add  all  plastic 
waste  so  called  macro  plastics  entering  the  sea  which,  if  not  removed,  ultimately  becomes, 
because of weathering and fragmentation, micro-plastics.   

The potential impacts of micro-plastics on the environment, associated with their intentional or 
incidental use in products, have generated a lot of concerns worldwide. The Council has invited 
the Commission to take measures on micro-plastics, in particular from cosmetics and detergents 
under the Strategy on Plastics. 

During the preparation of the Strategy on Plastics an Open Public Consultation on micro-plastics 
was  organised  with  almost  500  responses  (roughly  50%  from  individuals  vs  companies);  while 
the  results  have  not  been  fully  analysed  yet,  some  trends  are  obvious:  citizens  are  most 
concerned about harm to marine life,  there’s high awareness of cosmetics and textiles micro-
plastics, and with the highest concern for textiles, legislative measures are generally favoured at 
the European level with the cost burden put on the manufacturers and bans are favoured for all 
of the intentionally added ingredients. 

76 

 
 
A recent study216 estimated that the total number of floating macro- and micro-plastics in the 
open oceans is 5,25 trillion pieces, weighing 269,000 tonnes. Micro-plastics were calculated in 
the order of 200 thousand tonnes in the EU217. The updated calculations are given in the Figure 
12 and Error! Reference source not found. for all major sources of micro-plastics. It should be 
noted that data about the use of micro-plastics in products are scarce and studies and analysis 
depend for this to a large extent on the input from product manufacturers.  

Figure 12. Annual emissions of micro-plastics to surface waters from the EU, Norway and Switzerland  

Notes: These figures represent the upper and lower estimated range for the emission of microplastics in 
each  product  group  to  surface  waters  and  should  be  considered  in  conjunction  with  their  associated 
reports for context and calculation methodologies. 
Bars in blue have been calculated by the DG Env project focusing on ‘intentionally added’ microplastics by 
Amec  Foster  Wheeler  (AFW).  These  results  are  a  combination  of  reported  tonnages  by  associated 
industries and literature, as well as a range of assumptions regarding the release of the products to water 
and the efficiency of waste water treatment in removing microplastics. Where wastewater treatment is a 
pathway,  a  release  factor  of  16—43%  is  used  in  line  with  the  EU  microplastics  WWT  retention  model 
created by Eunomia. These release factors are used by AFW in their final report, along with a third release 
factor  of  8%  (not  represented  on  the  graph)  calculated  by  modelling  microplastics  flows  through  a 
theoretical WWT plant in the EUSES programme. Microplastics from oil and gas were also investigated as 
part of this project, but no concrete estimates could be made. Microplastics used as blasting media are 
estimated to be 1,000—5,000 tonnes per year, but with no emissions to surface waters. 
The ‘leave-on’ PCP figure is based on the assumption that these are 100% rinsed off. 
The orange bars represent microplastics created through wear and tear or accidental loss calculated by 
Eunomia  Research  and  Consulting  on  behalf  of  DG  Env.  In  all  cases  these  are  modelled  emissions  with 
varying levels of certainty attached (the full report will contain details of this).  
Marine  paint  has  no  range  associated  with  its  estimate  as  emissions  are  direct  to  the  marine 
environment.  
Building  paint  is  included  twice,  once  for  intentionally  added  losses  and  again  for  losses  due  to  wear 
during the life of the paint. 

216 Eriksen et al.2014 

217 EU micro-plastics. Ongoing study for the Commission: http://www.eumicro-plastics.com/eumpwp/wp-

content/uploads/investigating-options-eunomia-draft-report-v4-main-report-public.pdf 

77 

 
 
 
                                                            
Any microplastics captured in sludge after wastewater treatment may also be applied to agricultural land 
(50%  of  EU  sludge)  with  a  chance  of  leaching  into  waterways.  There  is  no  data  to  model  this  effect  at 
present. Similarly, microplastics entering rivers far up stream of an estuary can, at varying levels due to 
size and density, be retained in sediment. There is also not enough information to accurately model this 
effect at present, although it is likely that particles from automotive tyres will settle out far more readily 
than other microplastic types. 

Table 7. Annual micro-plastics emissions to surface waters from the EU (+Norway and Switzerland)  

 Source 

Upper (tonnes) 

Midpoint 

Lower (tonnes) 

94,000 
47,000 
13,000 
15,000 
5,000 
5,000 
2,000 
2,000 
400 
- 
- 
- 
- 
- 

136,000 
91,000 
23,000 
21,000 
8,000 
9,000 
5,000 
3,000 
400 
526 
400 
373 
141 
94 
300,000 

Automotive Tyres 
Pellets 
Washing of Clothing 
Road Markings 
Building Paint 
Fishing Gear 
Automotive Brakes 
Artificial Turf 
Marine Paint 
Leave on PCP 
Fertilisers 
Rinse off PCP 
Building Paint 
Detergents 
Total 
Note: Data for the calculation of emissions comes from different years for each emission source. 
The results are normalised to 2017 for the baseline calculations using the midpoint. 
All Figures except for those from ‘intentionally added’ products (highlighted in red) are rounded 
therefore totals may not add up 

52,000 
3,000 
4,000 
10,000 
2,000 
1,000 
100 
300 
400 
86 
85 
114 
0.40 
30 
72,500 

Source 
Data 
Year 
2012 
2015 
2016 
2015 
2013 
2015 
2012 
2012 
2013 
- 
- 
- 
- 
- 

Some  companies  have  already  taken  measures  to  phase  out  progressively  the  use  of  certain 
microbeads in some of their products.  

Impacts on the environment and human health  

As  a  specific  category  of  plastic  litter,  micro-plastics  are  of  particular  concern  due  to  the 
negative  effects  on  both  marine  and  freshwater  environments,  aquatic  life,  biodiversity,  and 
possibly to human health. Their small size facilitates uptake and bioaccumulation by organisms, 
causing physical effects, such as reduced nutrition, or toxic effects from the complex mixture of 
chemicals these particles consist of.  

A  recent  study218  confirmed  the  evidence  for  a  potential  risk  to  organisms  from  the  toxic  and 
physical effects linked to  the exposure to micro-plastics. The study concluded that  a potential 
risk  to  the  environment  may  arise  from  the  presence  of  microplastic  particles  used  in  the 

218 Intentionally added microplastics in products; Final Report October 2017; Amec Foster Wheeler 

Environment  

78 

 
 
 
  
 
 
                                                            
production  of  various  products  for  consumer  and  professional  use  that  get  into  the  aquatic 
environment, and that these risks need to be addressed on a Union wide basis. 

Closing the knowledge gaps  

Whether micro-plastics are intentionally added in products or generated during the lifecycle of 
products containing plastics as a result of their fragmentation and abrasion, the Commission is 
working on gathering evidence, closing the knowledge gaps and assessing the most appropriate 
measures to be taken.  

The Commission is aware of several recent publications that traced micro-plastics ubiquity and 
detected  particles  even  in  drinking  water.  According  to  a  study  carried  out  by  Orb  Media219, 
having  analysed  the  scores  of  tap  water  samples  from  more  than  a  dozen  nations,  in  Europe 
with at least 72 % of the samples were contaminated with plastic fibres. Although micro-plastics 
are  not  a  parameter  listed  in  the  Drinking  Water  Directive  98/83/EC,  Member  States  have  to 
take  all  actions  to  ensure  that  drinking  water  does  not  pose  a  risk  to  human  health.  It  is 
therefore  for  the  Member  State  to  decide  on  appropriate  actions  to  be  taken,  in  light  of  the 
precautionary  principle  if  relevant.  As  the  pathways  into  drinking  water  and  possible  health 
effects  through  drinking  water  are  not  well  known,  further  information  on  their  existence  in 
source water should be gathered i.e. by hazard assessments of abstraction zones.  

The same logic should apply to food. The Commission's Food Safety policy is  to ensure a  high 
level  of  protection  of  human  health.  As  a  result,  possible  adverse  health  effects  from  the 
potential presence of micro-plastics in the food chain should also be examined. 

Actions taken by the industry, at Member States level and worldwide  

Micro-plastics are generated across all Member States and worldwide by a variety of sources. In 
the  EU  once  in  the  aquatic  environment,  there  is  clear  potential  for  movement  between 
Member  States.  Once  emitted  into  a  watercourse,  for  example,  they  can  easily  end  up  in 
another  Member  State  to  the  extent  that  the  marine  environment  is  a  shared  resource  in 
respect of fisheries, plastics pollution from one Member State may end up in seafood that will 
be consumed in another Member State. Pollution of the marine environment by plastic waste 
and micro-plastics exhibits therefore cross-border effects and is a transboundary environmental 
issue. Accordingly, action taken by an individual Member State would not be sufficient to deal 
with the problem on its territory due to these ‘spill over’ effects. 

Bans on the use of microbeads220 in specific rinse-off personal care products and cosmetics are 
in place in the US and Canada and are considered also in Australia and New Zealand. In the EU, 
France,  Sweden  and  UK  have  notified  to  the  Commission  draft 
laws  to  ban  micro-
plastics/microbeads in certain rinse-off cosmetics, while Ireland and Italy are considering similar 
measures.  Belgium  notified  in  October  2017  a  sector  agreement  for  the  gradual  removal  of 
microbeads from a series of consumer products.  

Further to restrictions or bans, measures concerning the design of products (such as standards 
for  tyres,  clothes  washing,  washing  machines,  waste  water  treatment  and  filter  systems)  are 

219 Risk Assessment and socio economic analyses: 'Intentionally added micro-plastics in products' - August 

2017  

220 synthetic, solid plastic particles used for exfoliating and cleansing 

79 

 
 
                                                            
better taken at EU level thus facilitating, instead of impeding the free movement of goods and 
the proliferation of trade flows. The sources of the micro-plastics for which policy options (see 
below)  are  developed  are  traded  internationally  e.g.  tyres  and  clothing.  Nationally  developed 
and  implemented  standards  and  other  type  of  actions  would  be  an  obstacle  to  the  free 
movement  of  goods  within  the  Union  and  would  have  an  impact  on  the  development  of  the 
single market.  

Looking at the global dimension, measures intended to curb plastic littering and micro-plastics 
releases into the environment shall be taken at the EU level will give a competitive advantage 
for  the  industry  while  consolidating  at  the  political  and  diplomatic  front  its  environmental 
leadership. 

Box 5. Voluntary commitments by the industry to phase out certain types of microbeads in some 
cosmetics and detergents 

International cosmetic manufacturers have eliminated or are moving to  eliminate microbeads in 
their products.  

  Unilever,  Beiersdorf  AG  and  Colgate-Palmolive  declare  themselves  microbead-free. 
Others  including,  Johnson  &  Johnson,  L’Oréal  and  Procter  &  Gamble  have  announced 
their plans to remove microbeads globally by 2017.   

  Clarins, Clearasil and Ella Baché have pledged to rid their body and facial scrub products 

of plastic microbeads. 

  Tesco has asked its suppliers in the UK to remove microbeads. UK retailers  Superdrug 

and Boots order firms to ban the toxic beads.  

  Supermarket  chain  Aldi  announced  that  plastic  microbeads  will  be  removed  from  its 

personal care products by 2017. 

  Coles  and  Woolworths  (Australia's  two  biggest  supermarket  chains)  promised  to  stop 
using microbeads in their own products from 2017. The voluntary phase-out by industry 
is  supported  by  state-level  environment  ministers.  This  follows  the  intention  of  the 
federal government to implement a ban on plastic microbeads in 2018, if it is clear by 1 
July 2017 that the voluntary phase-out will not be effective.  

Cosmetics  Europe  recommended  to  its  membership  to  discontinue,  in  wash-off  cosmetic  and 
personal  care  products  placed  on  the  market  as  of  2020:  the  use  of  synthetic,  solid  plastic 
particles  used  for  exfoliating  and  cleansing  (i.e.  microbeads)  that  are  non-biodegradable  in  the 
marine  environment.  Cosmetics  Europe  survey  shows  an  82%  reduction  in  use  of  plastic 
microbeads in those products. 

Microbeads  are  in  some  cases  added  in  detergents  and  maintenance  products.  The  industry has 
pointed  out  that  the  trend  in  the  use  of  micro-plastics  is  clearly  decreasing  as  a  number  of 
companies have already announced their intention to invest in the reformulation of their products, 
considering the use of alternatives where available. 

4.4.2  Actions to be taken  

Several  EU  policies  and  instruments  (e.g.  eco-design,  chemicals  (REACH),  waste  management, 
waste  water  treatment,  marine  environment  protection,  air  quality  legislation,  industrial 
emissions legislation) regulate or could intervene regarding the generation and release of micro-
plastics into the environment, but there is no specific EU instrument regulating their intentional 
80 

 
 
 
use in products or aiming to limit/minimise their generation or mitigate the impacts from their 
presence in the environment.  

The Commission also considers that given the wide and, to date, uncontrollable dissemination 
of  micro-plastics  and  the  scientific  evidence,  albeit  inconclusive,  pointing  to  a  serious  risk  of 
harm to the aquatic environment and the human health, the precautionary principle could be 
considered and might provide a valid basis for restrictions of the use of micro-plastics.  

Measures for micro-plastics should be examined in a comprehensive way so that all sources of 
micro-plastics will be addressed in the light of their demonstrated impacts independently from 
their origin.  

Measures  taken  at  the  EU  level  would  provide  a  clear  answer  to  public  concerns,  help  to 
prevent uncontrollable environmental and human health impacts, but also contribute to avoid 
fragmentation of the EU internal market. On the other hand, the effort (financial, research, etc.) 
invested  in  innovating  and  substituting  micro-plastics  in  products  could  provide  a  competitive 
advantage  to  EU  economic  stakeholders  on  an  issue  which  is  high  in  the  international 
environmental and socioeconomic agenda. 

The  proposed  options  present  a  stepwise  approach  and  are  proportional  to  the  available 
knowledge  and  information  supplied  by  industry  (quite  limited,  in  some  cases)  and  integrate 
voluntary initiatives by industry, where such initiatives are developed enough so as to provide a 
basis for progress.  

Unintentional release of micro-plastics  

Preliminary  results  of  the  abovementioned  ongoing  study  on  micro-plastics  generated  during 
products' lifecycles, reveals that automotive tyres, pre-production plastic pellets and washing of 
clothing could be the sources accounting for the highest quantities of micro-plastics releases to 
the environment221.  More research is needed to improve our understanding of the sources and 
impacts of micro-plastics, including their effects on the environment and health. Based on this 
improved  knowledge,  measures  could  then  be  envisaged  to  develop  innovative  solutions  to 
prevent their dissemination.  

Concerning  micro-plastics  emissions  from  automotive  tyres,  options  envisaged 
include 
development of a harmonised testing standard of tyre tread abrasion to determine the rate at 
which  micro-plastics  are  release  during  the  use  phase  of  tyres.  Several  policy  options  for 
reducing  the  release  of  micro-plastics  from  tyres  will  be  assessed  (e.g.  including  minimum 
requirements  for  tyre  design  (tyre  abrasion  and  durability  if  appropriate) and/or  information 
requirements  on  this  issue  including  if  appropriate  labelling,  methods  to  assess  micro-plastic 
losses from tyres,  targeted research and development funding). 

In  a  similar  way,  the  Commission  will  consider  measures  on  the  release  of  microfibers  from 
textiles as well as measures to reduce plastic pellet losses222.  

221 For example to be included under the Regulation for labelling and marking of the fibre composition of 

textile products (EU/1007/2011). 

222 including methods to assess micro-plastic losses from textiles, combined with information (including 

possibly labelling)/minimum requirements, targeted research and development funding 

81 

 
 
                                                            
For textiles, options include, in a similar way, development of a test standard to determine in a 
consistent  manner  the  rate  of  plastic  fibre  release  from  clothing  during  washing  and  tumble 
drying, It will enable a thorough analysis of the issue through well-identified criterion and the 
identification of the most suitable and appropriate measures to tackle the release. On the basis 
of the results of this analysis, other options could also be explored, such as the development of 
a  label  for  fibre  release  from  clothing223.    Before  starting  to  reflect  on  an  eventual  Maximum 
Threshold  for  Fibre  Release,  one  must  ensure  that  there  is  sound  evidence  and  reliable  data 
regarding amounts of plastic microfibers emitted in the environment, pathways, and their fate 
in the environment, the overall magnitude of the issue and the availability of effective tools to 
tackle it.  

For  pellet  losses,  options  envisaged  include  the  work  on  elaboration  of  new  Best  Available 
Technics  (BAT)  in  respect  of  preventing  pellet  loss  (eventually  on  the  basis  of  Clean  Sweep 
guidance) and to be implemented by all polymer producers in Europe. BAT would be subject to 
regulation and potential enforcement action as per other aspects of their Environmental Permit, 
through  activities  at  EU  and  MS  level  on  amendment  and  implementation  of  relevant  BREFs 
under the Industrial Emission Directive (IED) 224. A regulation specifically covering the transport 
of  pellets  from  and  to  facilities  aiming  to  avoid  losses  through  the  use  of  best  practice 
standards,  again  derived  from  expert  knowledge,  and  further  developing  the  approaches 
already pioneered by industry via Operation Clean Sweep could be another way forward. Other 
options  are  regulatory  initiatives  requiring  Supply  Chain  Accreditation  of  Adherence  to  Best 
Practice, requiring those placing plastics on the market (large businesses in the first instance) to 
ensure  their  entire  supply  chain  demonstrates  best  practice  in  the  prevention  of  pellet  loss, 
regulatory initiatives on plastic converters not covered by the BREFs to implement best practice 
measures to prevent pellet loss. 

Extended producer responsibility schemes can also be envisaged, where relevant, to cover the 
cost of remedial action.   

Finally, the development of a test standard for the quantification (both in mass and number) of 
the  micro-plastics  in  the  influent,  effluent  and  sludge  output  of  wastewater  treatment  plants 
seems a necessary basis for more subsequent measures such as the development of a new EPR 
scheme.  It  could  be  designed  in  a  way  that  the  sources  predominantly  responsible  for  micro-
plastics in waste water treatment cover the costs of remedial action to increase micro-plastics 
capture. The feasibility and cost-benefit assessment is however needed. Further measures could 
follow  in  the  context  of  a  future  review  of  the  Urban  Waste  Water  Treatment  (UWWT) 
Directive.  

For  other  sources  of  micro-plastics  unintentionally  released  during  the  life  cycle  of  products 
where the lack of data makes the development of policy options impossible at this stage, such 
as paints, road markings and fishing gear, the knowledge gaps and the need for specific research 
need to be fully understood and described so as to develop appropriate measures.  

223 possibly with a new Regulation in line with the Ecodesign Directive (2009/125/EC)   

224 Directive 2010/75/EU of the European Parliament and of the Council of 24 November 2010 on industrial 

emissions (integrated pollution prevention and control) 

82 

 
 
                                                            
It  should  be  noted  that  more  accurate  estimations  about  the  expected  impacts  of  the 
abovementioned options will be available when the related ongoing study is concluded. 

Extended producer responsibility schemes can also be envisaged, where relevant, to cover the 
cost of remedial action.  

Micro-plastics need to be monitored in drinking water, where their impact on human health is 
still  unknown,  and  the  Commission  proposal  on  the  review  of  the  Drinking  Water  Directive225 
includes a provision on such monitoring. 

Intentionally added micro-plastics 

There is an urgent need to address the problem of intentionally added micro plastics as these 
add  unnecessarily  to  the  overall  high  load  of  micro-plastics  resulting  from  degradation  and 
abrasion  of  macro-plastic  entering  the  marine  environment  every  year,  a  considerable 
proportion of which turns into micro-plastics.  

The  need  to  address  intentionally  added  micro  plastics  is  acerbated  by  the  fact  that  different 
Member States have already started a process of banning micro-plastics/microbeads in rinse-off 
personal  care  products  and  cosmetics  have  notified  the  Commission  thereof.  It  is  therefore 
necessary to avoid a situation in which the Commission might be forced to open infringement 
proceedings  or  where  an  increasing  market  fragmentation  would  put  the  internal  market  in 
jeopardy.  

There are several options to address this problem:  

1.  Setting up of a dedicated legal instrument banning micro-plastics in products.   
2.  Using  REACH  as  an  instrument  to  restrict  the  use  of  micro-plastics  in  products, 
regardless of the polymer type as long as water insoluble polymers of a size up to 5 mm 
are concerned.  

3.  The phasing out on voluntary basis.  

To this end and considering the above the Commission has asked to ECHA to prepare an Annex 
XV dossier with the view to restrict the intentional use of micro-plastics particles to consumer or 
professional use products of any kind under REACH. Should a restriction be the result of ECHA's 
investigation in preparation of the Annex XV dossier, micro-plastics of the said nature could no 
longer be added from the time of entry into force of respective act. 

The  potential  restriction  of  micro  plastics  in  products  is  proportional  and  does  not  go  beyond 
what needs to be done in order to control the risk from uncontrolled release of micro-plastics to 
the  aquatic  environment.  There  are  no  other  less  intrusive  measures  at  hand  allowing  an 
adequate risk control. In particular is it not sufficient to build only on voluntary action, because 
such action would not be binding for all actors on the market.  

225 http://ec.europa.eu/environment/water/water-drink/review_en.html 

83 

 
 
 
                                                            
5  Driving  investment  and  innovation  towards  circular 

solutions  

5.1  Issues at stake 

Reaching most of the  objectives and actions that are described throughout the document will 
require  innovation  and  research  and  therefore  major  additional  investments.  In  several  areas 
knowledge gaps must be closed e.g. micro-plastics release in the environment and the impact 
on human health. Innovation shall also be supported in order to reach the EU circular economy 
goals,  to  provide  smart  and  sustainable  alternatives  to  consumers  and  business  and  to  fulfil 
other  commitments  such  as  those  linked  to  CO2  emissions  and  climate  change.  It  will  also 
contribute to improving the quality of plastic waste for recycling (e.g. developing a technology 
for  markers  and  tracers  in  polymers)  or  to  scale  up  and  develop  recycling  technologies  (e.g. 
chemical recycling) where proven beneficial for the environment and climate. 

However  and  in  order  to  achieve  this  goal,  it  is  required  to  implement  EU  funding  and 
investment approaches supporting specific innovation, industrialisation and policy needs. 

5.1.1 

 Support the necessary investments  

Investing in new technologies, products or production processes is risky and costly. It risky since 
the profitability and take-up of innovations is inherently tied to unpredictable events. It is costly 
since  it  often  requires  external  financial  resources  (banks,  venture  capitalists),  it  generates 
opportunity costs and often requires radical reorganisation of the value chain. When the risks 
and/or the (opportunity) costs are relevant, there might be scope for policy intervention. In the 
case  plastic,  there  is  evidence  that  both  risks  and  opportunity  costs  are  an  important 
detrimental  factor  in  terms  of  incentives  to  invest  in  innovation.  Error!  Reference  source  not 
found. summarises the most relevant obstacles hampering investments. 

Table 8. Examples of obstacles identified hindering the shift towards more circular plastics 

RAW 
PRODUCTION PHASE 

MATERIAL 

NATURE OF OBSTACLES  
Technological constraints 

Economic factors 

Behavioural factors 

Legal barriers 

Lack  or 
infrastructure 

insufficiency  of 

MANUFACTURING  OF  Technological constraints 

84 

EXAMPLES  
For  secondary  raw  materials,  new  recycling 
technologies  currently  under  development 
(e.g. chemical recycling)  
Fossil  plastic  raw  materials  are  cheaper  than 
recycled  plastics  of  the  same  quality  and 
availability (volumes and quality) is certain   
Uncertainty  about  the  uptake  of  the  recycled 
plastics 
Misgivings  about  the  quality  and  safety  of 
recycled plastics  
Lack  of  dialogue  across  the  value  chain  (e.g. 
design for recyclability) 
Legal uncertainty in the absence of end of life 
criteria for plastic waste  
Separate  collection  and 
reinforced and upgraded  
Traceability  of 

recycled  plastics 

to  be 

(origin, 

sorting 

 
 
 
presence  of  hazardous  substances,  possible 
future uses)   
Investments  needed  to  switch  from  linear  to 
more circular model  
Non-existent  alternatives  of  substitution  (e.g. 
substances; materials) 
No real incentives to take circularity of plastics 
into account  
Responsibility  to  provide  safe  and  fit  for 
purpose materials  

on 

reasons 

framework 

is  not  clear 

Regulatory 
(e.g. 
Interface  CWP)  or  necessarily  sets  restrictions 
(food contact materials) 
Infrastructure to  be  upgraded  to  take  up  new 
challenges (e.g. increased and improved plastic 
waste  recycling)  or  with  a  lot  of  blind  spots 
(e.g.  filters  waste  water  treatment  plants 
microfibers from textiles or microbeads) 
Price  is  a  key  factor  for  both  businesses  and 
consumers 
Choices  are  often  based  on  the  price  of 
products, 
or 
aesthetical 
functionality/performance of  a  product  rather 
than on the "circularity" of it  
Littering and inappropriate disposal of waste is 
sometimes  due  to  insufficient  public  waste 
management infrastructure (e.g. lack of bins in 
often crowded places or during public events)  
Volumes  for  some  plastic  waste  streams  are 
currently too low (e.g. demolition waste) 
Recycling  is  costly  but  the  market  prices  are 
not  taking  into  account  the  environmental 
benefits  
Current  design  of  products  is  not  taking  into 
account end of life  
Recycling targets are not high enough 
The  interaction  between  health,  safety,  trade 
and  environmental  regulation  create  a  too 
complex, always evolving and burdensome 
Collection schemes do not exist for every type 
of plastics or are organised on voluntary basis 
in some countries (e.g. plastic mulches)  
Lack  of  reliable  data  and  scientific  based 
evidence  for  some  issues  (e.g.  microfibers, 
microplastics) 

PLASTIC ARTICLES AND 
PRODUCTS PHASE 

Economic factors 

Behavioural factors 

Legal barriers 

Lack  or 
infrastructure 

insufficiency  of 

USE PHASE 

Economic factors 

Behavioural factors 

Lack  or 
infrastructure 

insufficiency  of 

END OF LIFE 

Economic factors 

Behavioural factors 

Legal barriers 

Lack  or 
infrastructure 

insufficiency  of 

Knowledge  and  information 
lack  of  dialogue, 
gaps, 
and 
misgivings 
misunderstandings 
that 
prevent taking actions 

85 

 
 
 
 
In  general,  the  complexity  and  the  number  of  the  value  chains  involving  plastic  can  be 
considered  as  one  of  the  most  important  obstacles  for  investments.  A  more  efficient 
organisation  of  the  value  chains,  taking  into  account  circularity  objective,  is  a  precondition  to 
generate  an  ecosystem  conducive  of  more  investments.  Coordination  is  essential  to  avoid 
duplication  of  infrastructures  and  processes  and  to  channel  limited  resources  where  they  are 
needed  the  most,  as  for  instance  to  develop  innovative  sorting  technologies  such  as  tracers. 
However,  coordination  is  costly  and  there  might  be  strong  incentives  to  free  ride  on  the 
initiatives of other firms.  

An additional issue is related to the potential limited profitability of investments due to the risk 
of limited take up of innovative secondary materials. According to the stakeholder consulted in 
the  last  months  the  demand  for  secondary  plastic  is  too  low.  Weak  demand  causes  weak 
investments, which in turns contribute to keep demand low.  This is mostly due to the fact that 
prices  of  secondary  plastics  are  often  relatively  high  compared  to  virgin  feedstock.  Moreover, 
the quality of secondary plastics is often perceived as insufficient.  

Finally,  the  outcome  of  innovation  effort  is  difficult  to  predict  –  and  hence  risky  -  not  only  in 
terms of the quality of innovation, but also in terms of timing. In the case of plastic, for some 
particular  polymers,  there  are  no  adequate  technologies  available  that  would  allow  for  full 
circularity. Investing today in R&D to develop such technologies might bring to significant results 
only  in  some  years.  Deploy  the  innovations  to  the  market  might  require  additional  time.  This 
increases  substantially  the  investment  risk,  especially  when  lacking  strong  demand  and/or 
adequate regulatory framework. 

It  is  very  hard  to  estimate  the  size  of  the  investment  gap.  For  instance,  for  France,  2ACR 
estimates a  profitability gap in the range of 120 million EUR  (over a 5 year period) needed to 
achieve  a  50%  increase  in  the  uptake  of  secondary  plastics226.  This  figure  suggests  that 
substantial investment might be needed.   

The issues identified above are of concern for a number of different types of innovations that 
would  be  required  to  attain  a  real  circular  economy  for  plastic:  innovative  and  smart  design, 
upgraded waste management infrastructure, traceability of materials and substances, emissions 
of micro-plastics in the environment etc.  

Important  investments  are  needed,  but  because  of  the  current  market  conditions,  and  since 
producers and users of plastic fail to internalize the environmental costs of their products such 
investment are unlikely to materialise spontaneously.  

5.1.2  EPR fee modulation and more transparency  

Extended  Producer  Responsibility  (EPR)  is  defined  as  “an  environmental  policy  approach  in 
which  a  producer’s  responsibility  for  a  product  is  extended  to  the  post-consumer  stage  of  a 

226 2ACR (2017), Developing the circular economy in Europe through the "Economy of resources", Proposal for 

experimentation with "plastics", policy note circulated by 2ACR; or Faisabilité de mécanismes de sécurisation 

du modèle économique des filières du recyclage: application aux plastiques et élastomères, Ministere de 

l'Économie et des Finances, République Française, 2017. The figure refers to only few plastic types, namely 

packaging, WEEE, agricultural plastic and PVC window frames. 

86 

 
 
                                                            
product’s life cycle”227. There are a variety of EPR policy measures and instruments that aim to 
shift the negative environmental externalities of products  from taxpayers to producers and to 
incentivise producers to take environmental considerations into account at the product design 
phase.  

Such measures can also take the form of EPR schemes whereby producers are made responsible 
for the financing and organisation of the waste management of their end-of-life products. The 
objectives of such EPR schemes are to  

 

 

relieve  public  authorities  (partially)  of  the  cost  of  managing  a  specific  waste  stream, 
transferring the financial burden from taxpayers to consumers,  
internalise  the  cost  of  end-of-life  management  of  a  product  in  the  price  of  new 
products, thus providing an incentive for ecodesign approach and  

  ensure  effective  and  environmentally  sound  collection  and  treatment  of  that  waste 

stream.  

By internalising costs and establishing a well-designed fee system, EPR can encourage a change 
in behaviour of relevant actors involved in the product value chain from plastic  manufacturers 
to consumers and recyclers. Design for reuse and for recycling and more sustainable products 
are awarded. 

Targeted  and  meaningful  fee  differentiation  allows  rewarding  or  penalizing  the  producers 
impact  on  the  end-of-life  performance 
regarding  design-related  factors  that  have  an 
(reusability,  dismantlability,  recyclability…).  For  products  containing  plastic  or  made  of  plastic, 
fees  have  therefore  a  potential  to  be  an  effective  instrument  in  promoting  better  product 
design, labelling, improved collection and treatment of waste in line with the waste hierarchy 
and more resource efficient use of plastic. Differentiated product fees with a notable economic 
impact have been identified as being capable of bringing a real change in practices and product 
design although it is too early to establish a generalised appreciation of such an impact. There 
are  some  limitations  to  the  scope  of  this  principle.  Fee  modulation  may  not  be  feasible  or 
possible  for  all  materials  or  design  practices  for  numerous  reasons  such  as  the  availability  of 
waste  management  infrastructure  and  the  technical  feasibility  of  an  alternative  design  fit  for 
purpose or substitution of certain materials.  

It  is  to  be  noted  that  the  existing  EPR  schemes,  including  for  packaging,  already  provide  for 
some fee modulation based on simple criteria such as type, material or weight of packaging. 

5.1.3  Deposit return schemes (DRS) 

DRS are based on additional fees on some products, which have to be paid by the consumer at 
the  sales  point  of  a  given  item  in  the  form  of  a  deposit.  The  deposit  fee  is  returned  to  the 
consumer when bringing back the item. Most deposit schemes have been set up for packaging 
waste, especially for drinking bottles, but also for transport packaging (boxes and pallets). They 
are  usually  established  at  national  level,  although  there  are  some  deposit  systems  with  a 
regional or local scope. In the case of packaging, the fee is usually determined by the packaging 
material and the container size and is indicated via a label on the packaging.  

227 Source RELOOP: http://www.cmconsultinginc.com/wp-content/uploads/2017/10/Fact-Sheet-Economic-

Impacts-to-Municis-New.pdf 

87 

 
 
                                                            
Deposit schemes provide an economic incentive to waste holders to bring their waste back to 
return points. This ensures usually high return rates (above 95% or more in Germany and the 
Netherlands) and are thus an effective means to combat littering. In addition, the items that are 
returned  are  clean  sorted  fractions  with  very  little  contamination,  and  are  therefore  perfectly 
suitable  for  their  reuse  or  recycling.  The  best  documented  case  is  the  introduction  of  DRS  for 
beverage  containers,  where  the  littering  reduction  potential  usually  exceeds  80%  and  the 
recycling levels for the beverage containers covered by the scheme attain 90-98%228. 

Table 9. Total return rate of deposit schemes in the EU229, 230 

Country 

Croatia 

Denmark 

Estonia 

Finland 

Germany 

Lithuania 

Netherlands 

Sweden 

Data year 

Total return rate 

2015 

2014 

2014 

2014 

2014 

2016 

2014 

2014 

Up to 90% 

89% 

78,6% 

92,6% 

97% 

74% 

95% 

88,25% 

DRS  can  be  applied  to  a  number  of  waste  streams.  They  usually  are  effective  in  achieving  a 
massive  reduction  of  littering  and  in  increasing  recycling  to  very  high  levels.    In  addition,  DRS 
provide an excellent basis for reuse of these materials (as is the case e.g. for refillable bottles in 
Germany),  which  generally  constitutes  a  better  option  from  an  environmental  point  of  view 
than recycling, as in line with the waste hierarchy.  

The  level  and  the  structure  of  the  costs  will  depend  on  a  number  of  social  and  geographical 
factors of the area, the initial situation as regards the framework for collection and recycling of 
this  waste  stream,  as  well  as  the  types  of  beverage  containers  covered  by  the  DRS.  DRS  are 
usually financed by unclaimed deposits (i.e. bottles which the consumers forget to return or are 
disposed  of  via  conventional  collection  schemes)  and  result  in  net  savings  for  municipalities. 
Several  studies231 
  reported  significant  net  cost  savings  from  the  municipalities  that 
implemented  DRS  resulting  from  the  reduced  or  avoided  costs  of  collection,  treatment,  and 
disposal by the municipal waste management systems. However, DRS may result in additional 
costs  to  producers232  as  the  level  of  the  fees  usually  exceeds  the  level  of  the  fees  in  the 
previously existing EPR scheme. 

228 Technical, environmental and economic viability study of the implementation of a deposit refund scheme 

(DRS) for single-use beverage in Catalonia, 2017 

229 Source Reloop: http://www.cmconsultinginc.com/wp-content/uploads/2017/09/Fact-Sheet-Performance-

New2.pdf 

230 Waste Framework Directive, Article 8.1 

231 Technical, environmental and economic viability study of the implementation of a deposit refund scheme 

(DRS) for single-use beverage in Catalonia, 2017 
232 In the case of the planned DRS for Catalonia, the net savings for municipalities are projected to amount to 
€14.9 million (approx. 2 € per inhabitant)232.  This is expected to result in additional costs to producers 

88 

 
 
 
                                                            
5.1.4 

Innovation for more circularity  

The  plastics  industry  is  highly  important  for  the  European  economy,  and  it  is  also  faced  with 
critical  environmental  and  health  challenges  at  European  and  global  levels.  Increasing  its 
'circularity'  can  bring  new  opportunities  for  innovation,  competitiveness  and  job  creation. 
Plastic  materials  can  also  help  us  address  a  number  of  future  sustainability  challenges. 
Rethinking  and  improving  the  functioning  of  such  a  complex  value  chain  requires  efforts  and 
greater  cooperation  by  all  its  key  players,  from  the  plastic  production  industry  to  recyclers.  It 
also requires innovation and a common vision to drive investments in the right direction. These 
are the primary goals of this strategy.  

5.1.5  Specific actions to diversify the feedstock 

More  than  90%  of  plastics  today  are  produced  from  fossil  feedstock  and  plastics  production 
gives  rise  to approximately  400  million tonnes  of  GHG  emissions  per  year  globally  (2012)233. If 
current trends continue, by 2050 it could rise to 20% of global oil consumption and 15% of the 
global annual carbon emissions.  

Oil and natural gas are the main feedstocks and the EU has a dependency on foreign suppliers 
while alternative feedstock is available domestically. The Plastic Strategy covers issues such as 
shifting from fossil feedstock to alternative feedstock234, more sustainable production ways (e.g. 
industrial  symbiosis,  resource  efficiency),  more  sustainable  ways  of  producing  plastic  articles 
(e.g.  new  designs,  longer  life,  easy  to  recycle,  biodegradability)  and  more  sustainable 
consumption and use of plastics. In the long-term, plastics production must be decoupled from 
fossil  feedstock  and  reduce  life-cycle  GHG  impacts.  There  is  therefore  room  for  reducing  CO2 
footprint of plastics consumed in the EU. 

Plastic materials can indeed alternatively be manufactured from bio-mass, from plastic wastes 
and  from  organic  waste  and  residues  as  well  as  from  effluent  gases  (e.g.  CO2).  Alternative 
feedstock  is  however  currently  facing  serious  competitive  pressure  due,  among  others,  to  the 
low oil prices and lack of level playing field as certain externalities are not considered. There are 
not  enough  incentives  to  diversify  feedstock  used  in  plastic  products  or  products  containing 
plastics  manufacturing  and  their  environmental  impacts  still  need  to  be  better  assessed  and 
compared with plastic production from fossil feedstock. 

5.2  Existing EU measures  

5.2.1  Supporting the necessary investments  

Structural funds to recycling  

The Europe 2020 strategy235 is the EU's Agenda for growth and jobs. The aim is to turn the EU 
into  a  smart,  sustainable  and  inclusive  economy  delivering  high  levels  of  employment, 

worth €8.3 million (or €1.1 per inhabitant). Additional costs appear to be very low and justifiable in view of 

the achievable environmental and resource efficiency benefits. Source Reloop 
http://www.cmconsultinginc.com/wp-content/uploads/2017/09/Fact-Sheet-Performance-New2.pdf  
233 Roadmap "Strategy on Plastics in a Circular Economy"; 26 January 2017 

234 COM(2015) 614. Closing the loop – An EU action plan for the circular economy  

235 Europe 2020 A Strategy for smart, sustainable and inclusive growth; COM/2010/2020 final  

89 

 
 
                                                                                                                                                                                 
productivity  and  social cohesion. One  of  the Strategy's priorities  is  to  promote more  resource 
efficient,  greener  and  more  competitive  economy.  To  this  regard,  it  is  complementary  to  the 
Circular  Economy  Action  Plan  and  the  Plastics  Strategy  as  one  of  its  key  deliverables.  The 
European Structural and Investment Funds (ESI Funds) are part of the instruments that can be 
used  to  achieve  the  Circular  Economy  objectives  in  terms  of  smart,  sustainable  and  inclusive 
growth in Member States and regions, in particular in the context of cohesion policy.  

The five ESI Funds work together to support economic development across all EU countries, in 
line with the objectives of the Europe 2020 strategy:  

1.  European Regional Development Fund (ERDF); 
2.  European Social fund (ESF); 
3.  Cohesion Fund (CF); 
4.  European Agricultural Fund for Rural Development (EAFRD); and 
5.  European Maritime and Fisheries Fund (EMFF).  

When it comes to improved waste management, including recycling, funding comes mainly from 
ERDF and CF (see examples of already funded projects relating to plastics in ANNEX). It supports 
investments  in  innovation,  constructing  new  and  upgrading  existing  infrastructure,  increasing 
recycling  capacity  of  usually  non  recycled  plastics  and  promoting  cooperation,  and  other 
priorities as specified in national and regional programs. For 2014-2020 period, Member States 
have allocated a total of EUR 36 billion of EU co-financing from these two funds to environment 
and resource efficiency budget, and EUR 41 billion to research and innovation. Part of it is to be 
used to finance additional waste recycling capacity of 5.79 million tonnes / year (overall and per 
Member State)236.  

European Fund for Strategic Investments (EFSI) 

The European Fund for Strategic Investments (EFSI) is an initiative to help overcome the current 
investment gap in the EU. Jointly launched by the European Investment Bank (EIB) Group and 
the  European  Commission,  it  aims  to  mobilise  private  investment  in  projects  which  are 
strategically important for the EU.  

The  EIB  has  been  a  natural  financing  partner  for  the  EU  institutions  since  1958.  It  helps  to 
catalyse  investments.  In  order  to  do  so,  it  offers  loans,  guarantees,  equity  participation  and 
blending  and  advising  measures.  Generally  speaking,  a  project  may  be  given  support  if  it  is 
considered  sound  and  sustainable.  In  order  to  assess  its  suitability,  a  project  appraisal  is 
conducted wherein all relevant factors, i.e. financial, economic, social, environmental, technical, 
are  examined.  2015  an  informal  meeting  concerning  plastics  was  organised  with  the  plastics 
value chain and the EIB. 

Overall, the EFSI is  expected  to facilitate additional  investments  at a level of  315 billion euros 
within  Europe.  There  is  a  wide  eligibility  criterion  for  sectors  which  are  candidate  for  the 
supporting measures by the EIB and which need to be verified by the EIB. One special objective, 
in  the  area  of  sustainability,  is  the  development  and  modernisation  of  the  energy  sector, 
renewable  energy,  security  of  energy  supply  and  resource  efficiency.  EIB  recognised  that 

236 https://cohesiondata.ec.europa.eu/overview  

90 

 
 
 
 
                                                            
recycling of plastic materials falls under the scope of the eligibility criterion. These EFSI and EIB 
measures  are  meant  to  support  SMEs  (below  250  employees)  or  MidCaps  (below  3000 
employees), public sector entities and corporations of all sizes. Besides recycling capacities to be 
built (as explained above, approximately 250 new sorting plants and 300 recycling plants costing 
approximately 8.4-16.6 billion euros by 2020), EIB was also informed of several EU companies' 
investment  projects  amounting  to  approximately  381  million  euros  in  these  sectors,  including 
plastics and recycling.  

Circular Economy Finance Support Platform 

Taking  into  account  that  the  transition  to  a  Circular  Economy  will  need  innovative  business 
models,  and  financing  instruments,  the  Commission,  together  with  the  European  Investment 
Bank,  launched  in  January  2017  the  Circular  Economy  Finance  Support  Platform,  inviting  key 
stakeholders such as national promotional banks.  

5.2.2  Enhancing Public Procurement and Ecolabel 

One of the instruments to create a supportive economic framework for businesses and to move 
towards  more  circular  plastics  is  public  procurement.  The  Communication  "Making  Public 
Procurement  work  in  and  for  Europe"237  that  was  published  in  October,  aims  to  "encouraging 
the use of innovative, green and social criteria" to make the most out of public procurement. A 
guidance  document  on  innovation  procurement  will  be  provided  in  2018  and  could  include 
topics  such  as  plastic  recycling  and  recycled  content.  The  EU  Ecolabel  and  Green  Public 
Procurement (GPP) can contribute to different goals of the Plastics Strategy, covering also the 
challenges of plastic waste littering and more sustainable use of resources.   

Table 10. EU Ecolabel and Green Public Procurement contribution to the Plastics Strategy 

Improve 
recyclability 

Avoid  single-
use items 

In  several  EU  Ecolabel  and  GPP  product  groups  where  products  are  likely  to  contain  a 
substantial  amount  of  plastics,  the  criteria  are  requiring  the  marking  of  bigger  plastic 
parts  so  that,  at  the  end  of  its  useful  life,  sorting  of  plastics  is  easier.  A  criterion  on 
design  of  plastic  packaging  to  facilitate  effective  recycling  by  avoiding  potential 
contaminants  and  incompatible  materials  that  are  known  to  impede  separation  or 
reprocessing or to reduce the quality of recyclate can be found in EU Ecolabel criteria for 
Rinse-off cosmetics and in all 6 criteria sets for Detergents. Both in EU Ecolabel and GPP 
and  for  some  product  groups,  criteria  for  design  for  easy  disassembly  of  different 
components (e.g. furniture or computers) can be included in order to facilitate recycling. 
With  the  same  aim,  specific  hazardous  substances  are  restricted  from  plastic 
components of some product groups. 
In several product groups, the criteria are promoting reusable items:  
In  the  Food  and  catering  criteria  for  GPP,  public  authorities  should  give  preference  to 
reusable cutlery, glassware, crockery and tablecloths in order to avoid plastic (and other) 
waste, as well as require the contractor to provide tap water in order to avoid the use of 
bottled water. 
In EU Ecolabel Tourism services no single dose packages for non-perishable food stuffs 
(e.g. coffee, sugar, chocolate powder (except tea bags)) shall be used for food services; 
disposable  toiletries  items  (shower  caps,  brushes,  nail  files,  shampoos,  soaps  etc.)  are 
not allowed except in certain cases; disposable food service items (crockery, cutlery, and 

237 COM/2017/0572 final  

91 

 
 
                                                            
Recycled 
Content (RC)  

water jugs) shall not be available to guests in rooms and restaurant/bar service unless 
the applicant has an agreement with a recycler for such items. 
Refillable and proportionate-to-its-content packaging is promoted in EU Ecolabel criteria 
for Rinse-off cosmetics and in all 6 criteria sets for Detergents through the Weight/utility 
ratio formula that product packaging has to comply with. The "Packaging Impact Ratio" 
used  in  Rinse-off  cosmetics  ensures  that  the  products  have  a  proportionate  to  their 
content  use  of  plastic  packaging.  Furthermore,  superfluous  secondary  packaging  is  not 
allowed. 
There is not yet a systematic approach to push for RC in plastics in EU GPP or Ecolabel 
products. EU Ecolabel criteria for Textiles, Computers and Furniture and GPP criteria for 
Textiles have made the first attempt, recently included requirements on this. Moreover 
recycled  materials  in  packaging  are  promoted  in  EU  Ecolabel  criteria  for  rinse-off 
cosmetics, and in all 6 criteria sets for Detergents and Footwear. However, the reliability 
of the verification can be improved; in the case of Computers and Furniture the average 
content claims can be calculated on periodic or annual basis for the model, something 
that might not be possible in the case of GPP criteria for legal reasons.   
EU GPP criteria have, in recent years, abstained from such requirements for Computers 
and Furniture, because of verification issues (so does Ecodesign). The mandatory Italian 
GPP law sets requirements for a minimum amount of recycled content in some products, 
such  as  street  furniture,  packaging  of  cleaning  products,  materials  for  buildings 
construction. According to the Italian experience, from a functionality point of view, it is 
in  most  cases  possible  to  ask  for  a  recycled  content  up  to  30%  without  observing 
decreases  in  functionality  levels,  while  exceeding  this  threshold  generally  leads  to  a 
reduction in the strength of the material.  

Micro-plastics  Micro-plastics are banned in EU Ecolabel Rinse-off cosmetics and Detergents 
Littering  

In EU Ecolabel Tourism Accommodations and indoor cleaning services criteria there is a 
requirement on Waste sorting and sending for recycling. Under the Plastics Strategy, 
this approach will continue wherever relevant. 

5.2.3  The Commission proposal to introduce minimum requirements and providing 

a possibility for fee modulation for EPR schemes 

Mandatory  EPR  schemes  are  established  in  EU  legislation  for  end-of  life  vehicles  (Directive 
2000/53/EC),  for  waste  electrical  and  electronic  equipment  (Directive  2012/19/EU)  and 
batteries  and  waste  batteries  (Directive  2006/66/EC).  Most  Member  States  have  established 
EPR  schemes  for  packaging  in  support  of  the  implementation  of  the  packaging  and  packaging 
waste  Directive  (Directive  94/62/EC),  even  if  this  is  not  required  by  the  Directive.  In  the  EU, 
Member States have set up more than 200 schemes covering these and other products, such as 
expired medicines, lubricants, pharmaceuticals, tyres, chemicals, agricultural foil etc.  

The  Waste  Framework  Directive  (Art.  8) 
lays  down  some  general  principles  for  the 
implementation of EPR. This directive is currently under review with the objective to introduce 
minimum  requirements  for  EPR  schemes  to  improve  their  governance,  transparency,  cost-
efficiency and a level playing among the different schemes across the EU.   

One of  the  minimum requirements  proposed by the Commission is to introduce an obligation 
on  the  Member  States  to  ensure  that  the  fees  paid  by  the  producers  fulfilling  their  EPR 
obligation are modulated based on the product’s environmental impact. Such 'modulated fees' 

92 

 
 
 
hence take into account the actual end-of-life costs of individual products or groups of products, 
in  particular,  by  taking  into  account  their  recyclability  and  re-usability.  These  minimum 
requirements  on  fee  modulation  would  also  apply  to  WEEE,  ELV  and  batteries  where  EPR  is 
obligatory  under  EU  legislation,  and  some  MS  have  already  applied  it  even  if  not  required 
specifically  (e.g.  France  on  electronics,  packaging  and  printed  paper).  Also,  existing  EPR 
schemes,  including  for  packaging,  already  provide  for  some  fee  modulation  based  on  simple 
criteria such as type, material or weight of packaging. 

Targeted  and  meaningful  fee  differentiation  allows  rewarding  or  penalizing  the  producers 
regarding  design-related  factors  that  have  an 
impact  on  the  end-of-life  performance 
(reusability,  dismantlability,  recyclability…).  For  products  containing  plastic  or  made  of  plastic, 
fees  have  therefore  a  potential  to  be  an  effective  instrument  in  promoting  better  product 
design, labelling, improved collection and treatment of waste in line with the waste hierarchy 
and more resource efficient use of plastic. Differentiated product fees with a notable economic 
impact have been identified as being capable of bringing a real change in practices and product 
design although it is too early to establish a generalised appreciation of such an impact. There 
are  some  limitations  to  the  scope  of  this  principle.  Fee  modulation  may  not  be  feasible  or 
possible  for  all  materials  or  design  practices  for  numerous  reasons  such  as  the  availability  of 
waste  management  infrastructure  and  the  technical  feasibility  of  an  alternative  design  fit  for 
purpose or substitution of certain materials.  

It  is  to  be  noted  that  the  existing  EPR  schemes,  including  for  packaging,  already  provide  for 
some fee modulation based on simple criteria such as type, material or weight of packaging. 

One of  the  minimum requirements  proposed by the Commission is to introduce an obligation 
for  the  Member  States  to  ensure  that  the  EPR  fees  paid  by  the  producers  are  modulated 
accordingly  to  the  product’s  environmental  impact.  Such  'modulated  fees'  hence  take  into 
account  in  principle  the  real  end-of-life  costs  of  individual  products  or  groups  of  products,  in 
into  account  their  recyclability  and  re-usability.  These  minimum 
particular,  by  taking 
requirements on fee modulation would also apply to WEEE, ELV and batteries i.e. where EPR is 
obligatory under EU legislation, as well as some MS have already applied it even if not required 
specifically (e.g. France on electronics, packaging and printed paper.  

By internalising costs and establishing a well-designed fee system, EPR can encourage a change 
in behaviour of relevant actors involved in the product value chain from plastic manufacturers 
to consumers and recyclers. Design for reuse and for recycling and more sustainable products 
are awarded. 

A variety of practices on fee modulation are already available in the EU and the Commission can 
assist  Member  States  by  facilitating  the  exchange  of  best  practices  and  by  developing 
guidelines.  For  instance,  feedback  from  'eco-modulation  of  fees'  as  applied  in  France  in  the 
implementation  of  EPR  under  the  WEEE  Directive238  has  also  pointed  to  factors  of  success. 
Amongst  these  factors  the  setting  of  eco-modulated  criteria  in  a  process  that  involves  public 
authorities, producers as well as non-governmental consumer and environment organisations. 

238 The French Eco-modulation on electric equipment was updated in July 2015; now comprising 17 product 

types : fridge, freezer, washing machine, dishwasher, vacuum cleaner, coffee machine, kettle, tea machine, 

computer, notebooks, tablet, printer, phone, drilling machine, screwer, games console, lamps). 

93 

 
 
                                                            
The necessity for the approach and criteria to apply it at the EU level to become fully effective 
was also identified as a key element. Moreover, in the case of electronics, modulated fees also 
have the potential to support design changes for products for a global market. 

In addition, In its proposed waste review, the Commission has emphasised the use of economic 
instruments to prioritise waste prevention and recycling at national level. For instance, high or 
gradually  rising  fees  or  taxes  on  landfilling  and  incineration  could  improve  the  economics  of 
plastic recycling by clearly internalising the environmental costs of alternatives. 

5.2.4  Deposit-return schemes (DRS) 

Such schemes already exist across the EU and are regulated under national laws. Successful and 
efficient  deposit  systems  require  a  careful  planning,  especially  as  regards  information  of 
consumers and logistics. Guidance on aspects to be taken into account when planning a DRS for 
packaging is provided in Communication 2009/C 107/01. 

These schemes can be part of EPR schemes or complement them. DRS can increase the quantity 
and quality of plastic waste collected and reduce litter. Therefore, the Commission recommends 
Member States to introduce DRS for waste types that have either a high polluting potential (e.g. 
fishing  gear  and  agricultural  plastics)  or  are  managed  in  a  sub-optimal  way  (low  separate 
collection  rates),  which  does  not  allow  exploiting  the  recycling  potential  of  that  waste  (e.g. 
plastic packaging in some Member States).   

5.3  Actions to be taken 

5.3.1  Guidance on EPR fee modulation 

Hence,  to  ensure  that  EPR  schemes  run  smoothly  and  support  investment,  including  those  in 
plastic  recycling,  the  Commission  will  provide  guidance  (or  implementing  rules)239  on  how  to 
ensure effective modulation of fees paid by the producers, in particular for packaging. 

5.3.2  Establishment of EPR schemes for a wider plastic product categories  

The  establishment  of  EPR  schemes  for  a  wider  plastic  product  category  and  for  products 
containing  plastics  can  lead  to  improved  separate  collection  and  treatment  of  the  respective 
waste stream. It can lead to improvements in the entire lifecycle of those waste streams that 
are currently not well managed and for which currently no sufficient incentives exist to enhance 
their performance.  Therefore, the option to cover more products by EPR schemes including the 
requirement  of  modulated  fees  reflecting  different  environmental 
impacts  should  be 
considered. This could be envisaged in particular to plastic products such as agricultural plastics 
and foils, fishing gear, disposable plastic utensils and plastic used in construction, with the aim 
to cover a wider range of product characteristics that have a negative impact on the product's 
management at the end-of-life stage. 

In  particular  ,  in  the  case  of  products  with  a  high  littering  potential  (fishing  gear,  disposable 
plastic utensils) or in the case of products with a significant environmental impact if left in the 
nature  (agricultural  plastics),  the  EPR  should  include  a  deposit  return  system  or  a  buy-back 
system to ensure high return rates and reduce significantly the littering.   

239 currently discussed in the co-decision for the waste package 

94 

 
 
                                                            
The principle of extended producer responsibility could also be applied to create a private fund 
for financing investment and innovation aimed at reducing the environmental impact of primary 
plastic  production.  This  could,  for  instance,  support  the  uptake  of  recycled  plastics.  By  mid-
2019,  the  Commission,  in  cooperation  with  stakeholders,  will  analyse  the  potential  design 
features of such fund, including as regards technological and material neutrality, and will closely 
examine its technical, economic and legal feasibility. 

5.3.3  Actions to support innovation and research  

Innovation for more circularity  
In order to achieve this goal, it is required to implement EU funding and investment approaches 
supporting specific innovation, industrialisation and policy needs. First, research needs through 
RTD  FP9  calls  shall  address  technological  failures  with  a  view  to  increase  the  actual  recycling 
rate in the EU. This would concern: 

 

innovative  design  of  plastics  for  recyclability,  novel  sorting  and  recycling  techniques, 
new  feedstock  (e.g.  bio-waste,  CO2,  microbial  biomass)  and  optimisation  of  the 
integration of new materials in the manufacturing process,  

  development  of  new  functionalities,  including  aspects  helping  to  solve  end-of-life 
concerns  (new  biological  or  biochemical  ways  to  degrade  plastics  in  purpose-built 
facilities,  using  e.g.  worms,  bacteria  or  enzymes  engineered  through  synthetic 
biology),  (1)  by  increasing  reusability  of  plastics,  (2)  by  exploring  compostability  for 
relevant applications –  where plastic packaging are associated with food or bio-wastes 
subject to separate collection and industrial composting handling, and where the risks 
for  confusing  consumers  are  minimised  –  and  biodegradability  features  for 
applications  where  leaking  in  the  environment  is  unavoidable,  (3)  by  increasing 
recyclability  of  multi-materials  and  multi-layer  plastics,  (4)  by  minimising  the 
production of micro-plastics, (5) by developing smart traceability tools for plastics and 
some additives of concern, etc.  

  projects  regarding  (bio)chemical  recycling  as  it  could  more  than  double  the  present 

recycling rate which is mainly based to mechanical recycling. 

Second,  these  newly  found  technologies  should  be  transferred  to  the  in-field  operators  by 
financing  large-scale  demonstration  projects.  This  can  be  done  through  EU  research  and 
innovation  funding  (Horizon  2020  and  the  future  framework  programme),  including  public-
private partnerships, coordinated where appropriate and possible with the European Structural 
and Investment Funds and National and Regional State Aid, addressing drivers and contributing 
to eliminate bottlenecks e.g. financial bottlenecks.  

The Commission will continue to use the smart specialisation approach to engage industry and 
research to facilitate investments along the value chain. The approach is based on a bottom-up 
process within regions and Member States, engaging industry and researchers to identify areas 
of regional competitiveness. Smart specialisation strategies are a precondition for funding from 
the  ERDF.  Several  of  those  strategies  include  plastics-related  innovation  priorities.  The 
Commission supports the development of interregional partnerships in all smart specialisation 
areas. 

95 

 
 
Furthermore,  these  large-scale  demonstration  projects  need  to  be  firmly  embedded  into  a 
systemic approach that also  involves  the analyses  of  different local and  regional  factors. This 
will enable the materialisation of industrialised manufacturing installations generating growth 
and jobs. 

This will facilitate and flank the plastic secondary raw materials development and the needed 
standardisation  work  via  pre-and  co-normative  research  and  development.  Regions  and 
municipalities  can  benefit  from  the  Commission  European  Sustainable  Chemicals  Support 
Service Initiative in the  true alignment  with the Smart  Specialisation  Strategies  at  national or 
regional level. The Commission will develop a Strategic Research Innovation Agenda (SRIA) for 
plastics  that  will  provide  orientation  for  future  Research  and  Innovation  funding  in  the  post 
2020 period. This agenda will strive to take a holistic approach to address all issues related to 
plastics production and use, including environmental and human health impacts. 

EU  research  funds  will  support  all  these  efforts  by  funding  projects  that  will  close  the 
knowledge  gap,  and  develop  and  demonstrate  innovative  solutions  that  will  facilitate  the 
implementation  of  this  Strategy.  Between  2018  and  2020,  the  EU  Research  and  Innovation 
Programme  Horizon  2020  will  invest  more  than  200  million  Euro  in  plastics  research  and 
innovation,  part  of  which  will  be  provided  through  the  Bio-based  Industries  Public  Private 
Partnership.  By  developing  a  Strategic  Research  Innovation  Agenda  for  Plastics  in  2018,  the 
Commission will analyse research needs which will provide a basis to focus EU R&I funding on 
in the remaining period of Horizon 2020 and in the post-2020 period. Priority actions under this 
Strategy  are  such  as  the  development  of  smarter  and  more  recyclable  plastic  materials  and 
products,  more  efficient  recycling  processes,  removal  of  hazardous  substances  and 
contaminants from recycled plastics, and solutions addressing the problem of micro-plastics.  

Innovative technologies should also be developed for processing alternative feedstock, such as 
converting mixed plastic waste into virgin polymers (chemical or feedstock recycling), and for 
addressing  the  presence  of  substances  of  concern  in  plastics  that  hinder  recycling.  Plastics 
Recyclers  Europe defines  chemical recycling  (feedstock  recycling) as  "the operations  that aim 
to chemically degrade the collected plastics waste into its monomers or other basic chemicals. 
The  output  may  be  reused  for  polymerisation  into  new  plastics  for  the  production  of  other 
chemicals or as an alternative fuel." 

Several  technologies  have  been  or  are  being  developed  by  major  chemical  companies.  In 
general, investment levels and energy consumption are such that only very large-scale plants 
are expected to be economically viable. Therefore, another key factor is ensuring the supply of 
sufficient  input  materials  of  the  right  quality.  Chemical  recycling  if  economically  viable  may 
allow increasing both quantity and quality of plastic recyclates. 

Box 6. Polystyrene Loop project 

96 

 
 
The  closed-loop  recycling  of  polystyrene  foam  waste  and  the  destruction  of  the  legacy  flame 
retardant it contains (i.e. HBCDD), allowing the recovery of bromine, is under testing in a pilot 
plant  managed  under  the  PolystyreneLoop  project240  (benefitting  from  Life+  funds).  It  is 
announced  as  a  breakthrough  technological  improvement  which  will  be  able  to  deal  with  the 
growing  volumes  of  construction  Polystyrene  foam  waste  in  the  coming  decades.  The 
PolyStyreneLoop  project  has  been  assessing  the  economic  feasibility  of  such  a  process, 
including all project steps from collection and transportation of PS foams to the plant, its sorting 
and compaction, as well as a physico-chemical recycling process. 

Specific actions to diversify the feedstock 
In view of the need to decouple plastic production from fossil feedstock in order to achieve the 
COP21  agreement  and  the  legal  climate  and  energy  targets,  it  is  important  to  accelerate  the 
production of as much non fossil-based and recyclable plastic as possible, from mechanical and 
chemical-feedstock recycling, from CO2 and other industrial gaseous feedstock, as well as from 
other alternative feedstock. This will also allow a greater independence from largely imported 
fossil feedstock, boost resource efficiency and circularity as well as contribute to the reduction 
and avoidance of CO2 and other gaseous emissions.  

The  European  Commission  has  launched  a  Life  Cycle  Assessment  (LCA)  study  to  assess 
alternative plastic production and end-of-life scenarios. Each of this alternative feedstock has its 
specific carbon footprint that is not subject to a fair comparison when it comes to establishing 
the best CO2 foot print solution. The LCA study will quantify environmental impacts and support, 
on scientific  grounds, if and how these alternative  pathways might  contribute to reducing the 
dependence on fossil feedstock and the emissions of GHGs.  

The methodology will take into account wider sources produced for the Commission241 and as 
much as possible different policy and regulatory scenarios. The study will also look at some of 
the  potential  indirect  effects  linked  to  the  use  of  land-based  biomass  (e.g.  indirect  land  use 
change  and  other  potential  market-mediated  impacts)  and  their  indirect  effects  on  other 
biomass uses (food and feed, wood industry, etc.).  

At least five stages of the lifecycle will be considered:  

1.  Extraction/supply of feedstocks (i.e. petrol based, biomass (crops, agricultural residues, 

bio-waste), CO2, plastic waste etc);  

2.  Feedstock processing into intermediate chemicals  -where applicable- and plastics (e.g. 

granulate);  

3.  Production of articles made with plastics;  

4.  Use phase of articles; and  

5.  End of life options on the management of plastic waste, including biodegradability. 

240 https://polystyreneloop.org/technology  

241 "Biomass supply and demand" https://ec.europa.eu/jrc/en/science-update/biomass-flows-european-

union; S2Biom project http://www.s2biom.eu/en/ 

97 

 
 
                                                            
The  final  report  will  include  guidance  for  conducting  LCAs  in  this  area  beyond  the  contained 
case studies, highlighting key methodology requirements, data needs and assumptions but also 
limitations. 

98 

 
 
 
 
6  Harnessing global action  

6.1  Issues at stake 

Plastic  leakage  in  the  environment,  its  impacts  on  biodiversity,  human  health  and  economical 
activities have created an international momentum. The issues described above are of a large 
scale and requires a global response.  

6.2  Existing EU actions 

6.2.1  Multilateral  cooperation  at  the  United  Nations  and  through  environmental 

agreements     

In 2015,  UN  member  countries  adopted  the 2030  Agenda for  Sustainable Development which 
includes  17  Sustainable Development Goals  (SDGs)242.  The EU and  its  Member  States  are  fully 
committed  to  the  2030  Agenda  and  attach  great 
its 
implementation243Several of the Sustainable Development Goals  and associated targets are of 
particular relevance to the Plastic Strategy244. Meeting the objectives of the 2030 Agenda and its 
SDGs will require commitment at local, regional and global levels, including though partnerships 
with  relevant  stakeholders.  The  EU  can  play  an  important  role  in  fostering  such  co-operation, 
building  on  its  experience  in  resource  efficiency  and  circular  economy,  including  waste 
management aspects. 

importance  to  driving  forward 

The  United  Nations  Environment  Assembly  (UNEA)  has  consistently  highlighted  marine  plastic 
debris and micro-plastics amongst the issues of global importance. At the second UNEA session 
(UNEA-2) in 2016, resolution UNEP/EA.2/Res.11 on marine plastic litter and micro-plastics was 
adopted,  in  which  governments  requested  an  assessment  by  the  United  Nations  Environment 
Programme  (UNEP)  of  the  effectiveness  of  relevant  international,  regional  and  sub-regional 
governance strategies and approaches to combat marine plastic litter and micro-plastics, taking 
into consideration the relevant international, regional and sub-regional regulatory frameworks. 
The  resolution  called  for  identification  of  possible  gaps  a  well  as  options  for  addressing  these 
gaps. 

242 https://sustainabledevelopment.un.org/post2015/transformingourworld 

243 Council conclusions 'A sustainable European future: The EU response to the 2030 Agenda for Sustainable 

Development' (General Affairs Council, 20 June 2017); 'Next steps for a sustainable European future – 

European action for sustainability' (COM(2016) 739). 

244 for example Goal 8 'Promote sustained, inclusive and sustainable economic growth, full and productive 

employment and decent work for all' calls for improving progressively, through 2030, global resource 

efficiency in consumption and production and endeavour to decouple economic growth from environmental 

degradation; Goal 12 'Ensure sustainable consumption and production patterns' calls for achieving the 

environmentally sound management of chemicals and all wastes throughout their life cycles and to 

substantially reduce waste generation through prevention, reduction, recycling and reuse; Goal 6 'Ensure 

availability and sustainable management of water and sanitation for all' calls for improving water quality by 

reducing pollution, eliminating dumping and minimizing release of hazardous chemicals and materials, and 

halving the proportion of untreated wastewater; finally, Goal 14 'Conserve and sustainably use the oceans, 

seas and marine resources for sustainable development' calls for preventing and significantly reducing marine 

pollution of all kinds, in particular from land-based activities, including marine debris and nutrient pollution 
99 

 
 
                                                            
The  UNEP  assessment245,  prepared  in  response  to  the  aforementioned  UNEA-2  resolution, 
highlights  that  in  the  current  set-up  there  is  no  global  institution  with  the  mandate  to 
coordinate current efforts and manage the issue upstream from the extraction of raw materials, 
design and use phases of  plastic  polymers and additives to final treatment and disposal. Also, 
among a number of other conclusions, it notes the lack of harmonised binding standards at the 
global  level  for  the  mitigation  of  pollution  by  plastic  waste,  particularly  from  land-based 
sources; a lack of global standards for national monitoring and reporting on consumption, use, 
final  treatment  and  trade  of  plastic  waste,  as  well  as  a  lack  of  global  industry  standards  for 
environmental  controls  and  quality  specifications  of  plastics.  Concerning  in  particular  liability 
and compensation from damages resulting from marine litter, the UNEP assessment notes that, 
despite  the  widespread  damage  resulting  from  marine  litter,  liability  and  compensation  for 
damage to the marine environment from accidental or intentional discharge of solid material in 
the sea  is not covered by  any international instrument. The existing instruments that apply in 
the context of marine litter and micro-plastics have geographical limitations as they fail to cover 
internal waters and watersheds. The costs of remediation for environmental damage by marine 
plastic  litter  and  micro-plastics  are  not  currently  represented  in  any  product  or  any  other 
liability  legislation  with  potential  compensatory  arrangements  for  environmental  damage. 
Furthermore,  the  assessment  underlines  that  extended  producer  liability  and  any  other 
appropriate schemes (e.g. liability and financial compensation schemes for the shipping sector) 
would need to be used to induce change in the plastic producing industries. Next to suggesting 
consideration of the overall governance set-up to UNEA, the assessment proposes a number of 
areas  and  steps  in  need  of  immediate  progress.  This  comprises  to  give  consideration,  in  the 
context of marine plastic litter and micro-plastics, to the definition of damage, the measure of 
damage, responsibility, who can claim and what remedial activities can be claimed for. 

Moreover  several  initiatives  have  been  launched  to  address  specifically  the  impacts  of  plastic 
waste entering the sea from land and include inter alia: UNEP’s Global Programme of Action for 
the  Protection  of  the  Marine  Environment  from  Land-based  Activities  (GPA)  and  the  Global 
Partnership on Marine Litter (GPML)246, the 2015 G7 Action Plan to Combat Marine Litter247, and 
the 2017 G20 Marine Litter Action Plan248.  

Concerning  plastic  waste  and  other  types  of  waste  discarded  from  ships,  the  International 
Maritime  Organisation  (IMO)  has  also  developed  action  to  address  the  issue,  in  particular  by 
further  regulating  the  discharges  of  garbage  from  ships  in  the  context  of  the  MARPOL 
Convention249. Annex V to MARPOL prohibits the discharge of all types of garbage into the sea 
from ships, except in the cases explicitly permitted under the Annex (such as food waste, cargo 
residues, cleaning agents/additives that are not harmful to the marine environment). MARPOL 
also recognizes that some sea areas require higher degrees of protection and can be designated 
as  Special  Areas  under  MARPOL.  Garbage  from  ships  includes  all  kinds  of  food,  domestic  and 
operational waste, and comprises all plastics as well as fishing gear. Annex V applies to all types 

245 UNEP (2017), Combating marine plastic litter and micro-plastics: An assessment of the effectiveness of 

relevant international, regional and subregional governance strategies and approaches (EA.3/INF/5). 

246 https://www.unep.org/gpa/what-we-do/global-partnership-marine-litter 

247 https://www.g7germany.de/Content/EN/_Anlagen/G7/2015-06-08-g7-abschluss-eng_en.html 

248 https://www.g20.org/Content/DE/_Anlagen/G7_G20/2017-g20-marine-litter-en.html?nn=2186554 

249 http://www.imo.org/en/about/conventions/listofconventions/pages/international-convention-for-the-

prevention-of-pollution-from-ships-(marpol).aspx 

100 

 
 
                                                            
of  ships  operating  in  the  marine  environment,  including  fishing  vessels  and  recreational  craft. 
Yet,  although  MARPOL  provides  comprehensive  framework  addressing  ship-source  pollution 
from  different  polluting  substances,  it  does  not  provide  for  a  compliance  mechanism.  The 
success  of  compliance  with  the  MARPOL  discharge  norms  depends  on  the  availability  of 
adequate  port  reception  facilities  where  the  garbage  can  be  delivered  and  managed 
appropriately.  The  EU  Port  Reception  Facilities  Directive250,  currently  under  review,  which 
transposes these requirements into EU law through a ports based approach, is instrumental for 
implementing and enforcing the MARPOL regime, including its ban on plastic discharges. 

The  EU  takes  an  active  part  in  the  decision-making  processes  under  the  relevant  multilateral 
environmental  agreements  (MEAs)  and  processes  that  set  legally  binding  requirements    and 
provide  guidance  for  all  countries,  e.g.  on  chemicals  and  waste  management251.  In  particular, 
under  the  Basel  Convention252,  Parties  have  adopted  a  number  of  measures  including  an 
Environmentally  Sound  Management  (ESM)  toolkit  that  they  can  use  in  shaping  their  national 
policies  to  ensure  a  sound  management  of  waste,  so  contributing  to  achieving  the  SDGs.  The 
ESM  toolkit  consists  of  practical  manuals  on  waste  management  and  fact  sheets  covering 
specific waste streams; and guidance for developing efficient strategies on waste prevention253. 
It includes incentives to encourage private sector investments, training materials, checklist for 
self-assessment  of  national  capacity,  pilot  projects,  ESM  criteria  and  case  studies  on  the 
promotion of ESM in the informal sector. At the 13th meeting of the Conference of the Parties 
to  the  Basel  Convention  (COP13  held  in  April  2017),  Parties  have  engaged  in  developing  new 
tools, such as a practical manual on extended producer responsibility (EPR), guidance on waste 
prevention  and  minimisation,  factsheets  on  specific  waste  streams  and  manuals  on  EPR  and 
financing  systems  for  ESM.  Another  outcome  of  COP13  was  the  establishment  of  a  new 
household  waste  partnership254  and  the  inclusion  of  marine  plastic  litter  and  micro-plastics  in 
the work programme of the Basel Convention's Open-ended Working Group255 for 2018-2019. 

Parties  under  the  Convention  on  Biological  Diversity  have  adopted  decision  XIII/10  to  prevent 
and mitigate the potential adverse impacts of marine debris on marine and coastal biodiversity 
and  habitats256.  The  decision  invites  Parties  and  other  governments  to  consider  extended 
producer  responsibility  for  providing  response  measures  where  there  is  damage  or  sufficient 
likelihood of damage to marine and coastal biodiversity and habitats from marine debris. 

250 Directive 2000/59/EC on port reception facilities for ship-generated waste and cargo residues 

251 London Convention on the Prevention of Marine Pollution by Dumping of Wastes and Other Matter; Basel 

Convention on the Control of Transboundary movements of Hazardous Wastes and their Disposal; Stockholm 

Convention on Persistent Organic Pollutants; Rotterdam Convention on the Prior Informed Consent Procedure 

for Certain Hazardous Chemicals and Pesticides in International Trade; etc. 

252 Basel Convention on the Control of Transboundary movements of Hazardous Wastes and their Disposal. 

253http://www.basel.int/Implementation/CountryLedInitiative/EnvironmentallySoundManagement/Overview/ta

bid/3615/Default.aspx 

254 http://www.brsmeas.org/?tabid=4332&blogId=5148  

255 For more info on the Basel Convention's Open-ended Working Group see: 

http://www.basel.int/TheConvention/OpenendedWorkingGroup(OEWG)/OverviewandMandate/tabid/2295/Def

ault.aspx 

256 https://www.cbd.int/doc/decisions/cop-13/cop-13-dec-10-en.pdf 

101 

 
 
                                                            
6.2.2  G7 and G20  

Both the G7 and now also the G20 have addressed the issues of resource efficiency and marine 
litter.  Concerning  resource  efficiency,  the  G7  Alliance  on  Resource  Efficiency257  is  a  forum  to 
share knowledge and create information networks, in collaboration with businesses, SMEs, and 
other  relevant  stakeholders.  The  objective  is  to  advance  opportunities  offered  by  resource 
efficiency,  promote  best  practices  and  foster  innovation,  including  through  innovative  public 
private partnerships and by collaborating with developing countries. The Toyama Framework on 
Material Cycles258 provides a common vision and a guide for future actions to deepen G7 efforts 
on resource efficiency and the 3Rs (reduce, reuse, recycle). The Five-year Bologna Roadmap on 
resource  efficiency259  was  a  key  deliverable  of  the  2017  G7  Environment  Ministers'  Meeting 
drafted  with  the  active  involvement  of  all  G7  countries  and  the  EU.  It  contains  a  specific 
reference  to  plastics260.  The  G20  Resource  Efficiency  Dialogue261  aims  at  supporting  the 
transition to a sustainable and efficient use of all natural resources and contributing to poverty 
eradication, acknowledging that an efficient and sustainable use of natural resources is vital for 
implementing  the  SDGs.  The  work  on  resource  efficiency  in  both  the  G7  and  the  G20  is  of 
particular  interest  to  the  EU  because  of  its  own  domestic  action  on  a  transition  towards  a 
circular economy. As to marine litter, the G7 Action Plan to Combat Marine Litter262 commits G7 
members  to  priority  actions  and  solutions  to  combat  marine  litter  and  stresses  the  need  to 
address  land-  and  sea-based  sources,  removal  actions,  as  well  as  education,  research  and 
outreach.  A  similar  approach  has  recently  been  adopted  by  the  G20  through  the  G20  Action 
Plan on Marine Litter263, where the G20 recognised the urgent need for action to prevent and 
reduce marine litter in order to preserve human health and marine and coastal ecosystems, and 
mitigate marine litter's economic costs and impacts. 

6.2.3  Bilateral and regional cooperation  

Prevention  at  source  will  be  key  to  tackling  the  rising  plastic  waste  tide,  in  line  with  the  EU's 
circular  economy  approach.  This  will  require  the  promotion  of  a  circular  plastics  economy  in 
third countries through policy dialogues on environment, industry and  trade. The Commission 
has  regular  policy  dialogues  on  e.g.  environment264  with  partner  countries  (notably  those 
members  of  the  G20,  including  China  and  India)  and  is  in  the  process  of  developing  such 
dialogues  also  with  key  regional  organisations,  such  as  the  Association  of  South  East  Asia 
Nations (ASEAN). Beyond policy dialogues, the cooperation mechanisms established under Free 

257 https://www.g7germany.de/Content/EN/_Anlagen/G7/2015-06-08-g7-abschluss-annex-

eng_en.pdf?__blob=publicationFile&v=2 (pp. 6-8) 

258 http://www.mofa.go.jp/files/000159928.pdf 

259 http://www.g7italy.it/sites/default/files/documents/Communiqu%C3%A9%20G7%20Environment%20-

%20Bologna_0.pdf (pp. 13-15) 

260 'Assess the economic benefits and opportunities for improved product design and address barriers to 

recycling and reuse of plastic, in view of reducing the use of primary resources, the negative environmental 

and economic impacts over its life-cycle and avoid plastics leakage into the environment, in particular the 

seas and oceans (in coordination with relevant G7 work)'. 

261 https://www.g20.org/Content/DE/_Anlagen/G7_G20/2017-g20-resource-efficiency-dialogue-

en.pdf?__blob=publicationFile&v=4 

262 https://www.g7germany.de/Content/EN/_Anlagen/G7/2015-06-08-g7-abschluss-eng_en.html 

263 https://www.g20.org/Content/DE/_Anlagen/G7_G20/2017-g20-marine-litter-en.html?nn=2186554 

264 http://ec.europa.eu/environment/international_issues/index_en.htm 

102 

 
 
                                                            
Trade Agreements and in particular their Trade and Sustainable Development Chapters  265 and 
the Generalised Scheme of Preferences266 can also be used for these purposes. 

6.2.4  Relevant EU policies and programmes with an international dimension  

The EU organised events  

The European Union hosted the fourth high-level Our Ocean Conference267 in Malta on 5 and 6 
October 2017. The Conference has generated 437 concrete and tangible commitments for safe, 
secure, clean and sustainably managed oceans. Out of the 437 commitments in total, more than 
one  hundred  commitments  (worth  almost  €3bn),  were  related  to  marine  pollution  including 
actions targeting plastics, which was one of the main themes of the event. 

Development Cooperation 

The EU supports improved and sound waste management in third countries through its bilateral 
and  regional  funds.  From  2006  till  2013,  the  EU  has  dedicated  238  million  euros  to  finance 
projects  for  water  treatment,  sanitation  and  waste  management,  a  large  part  of  which 
contributes  to  the  circular  economy.  Building  on  this,  the  EU  has  committed  to  further  202 
million euros for the timeframe 2014-2018. 

The  EU  SWITCH  to  Green  programmes  (Switch  Asia,  Switch  Africa  Green  and  SwitchMed268) 
supporting  sustainable  consumption  and  production  (SCP)  practices  are  one  of  the  main  EU 
contributions  to  the  circular  economy  in  partner  countries.  They  also  contribute  to  SDG  12 
('Ensure  sustainable  consumption  and  production  patterns')  and  a  number  of  other  relevant 
SDGs.  They  cover  a  large  range  of  key  economic  sectors  in  developing  countries,  for  example 
agri-business,  garments,  manufacturing,  construction  materials,  and  SCP  practices,  including 
resource efficiency, eco-innovation, green products design, green products consumer demand, 
and  green  public  procurement.  They  deliver  policy  support,  promote  green  business 
development and facilitate networking among green businesses and with policy makers. 

The  programmes  contribute  to  address  plastic  issues.  The  NEERE  project  in  Burkina  Faso  for 
example,  under  SWITCH  Africa269  promotes  eco-entrepreneurship  through  better  waste 
management.  Among  others,  it  raises  awareness  on  the  impact  of  plastics  pollution,  supports 
plastic waste collection, and supports recycled plastics-based business development. 

Enlargement and Neighbourhood Policies 

Countries covered by the Enlargement and Neighbourhood policies are very  valuable partners 
to  promote  circular  economy  and  the  Plastics  Strategy,  due  to  their  political  and  historical 
proximity.  EU  action  in  these  regions  combines  privileged  political  dialogues  (e.g.  sub-
committee meetings) and assistance at regional and national level through institution building 
and financial instruments, including blending facilities. All these means could be further used to 
promote the circular economy objectives such as more recycling as well as a cost-efficient and 

265 http://ec.europa.eu/trade/policy/countries-and-regions/negotiations-and-agreements/ 

266 http://ec.europa.eu/trade/policy/countries-and-regions/development/generalised-scheme-of-

preferences/ 

267 http://ourocean2017.org/ 

268 On Switch-Med, see also section 0. 

269 www.switchafricagreen.org 

103 

 
 
                                                            
effective  waste  management.  This  is  all  the  more  relevant  for  the  candidates  and  potential 
candidate  countries  in  the  Western  Balkans  and  Turkey,  who  have  to  comply  with  the  EU 
environmental acquis, including revised legislative proposals on waste, upon accession.  

Examples of EU action in these regions are: 

  The regional ECRAN Programme has also helped the Balkan countries to transpose and 
implement  the  EU  waste  management  acquis 
(Waste  Framework  Directive's 
requirements)  and  gradually  move  from  dependence  on  landfills  to  separate  waste 
collection and integrated waste management; 

  A  project  on  “Eco  Awareness  Campaign  in  Montenegro”,  took  place  from  April  to 

December 2017, tackling the use of plastic bags and related pollution issues;  

  There  are  also  two  flagship  projects  of  EU  regional  cooperation  with  neighbourhood 
countries  on  the  promotion  and  support  of  sustainable  consumption  and  production 
patterns  in  beneficiary  countries:  SWITCH  Med  (EUR  20  million;  2013-2018)  and  EaP 
GREEN (EUR 10M; 2013-2017); 

  The programme Horizon 2020270 aims at depolluting the Mediterranean Sea, addressing 

municipal waste, urban waste water and industrial pollution. 

  The Commission services organised high level dialogues, to raise awareness on circular 

economy (Casablanca in October and Kiev in November 2017). 

Since  2014  bilateral  and  regional  funding  for  waste  and  water  management  in  these  regions 
amount  to  about  970  million  euros.  Projects  include  regional  assistance  as  well  as  blending 
facilities.  Large  part  of  these  resources  is  dedicated  to  the  Instrument  for  Pre-Accession 
Assistance (IPA)271. 

The  Commission  services  have  organised  or  are  organising  some  high  level  dialogues,  to  raise 
awareness  on  circular  economy  (Casablanca  in  October,  Kiev  in  November,  and  Belgrade  in 
December 2017).  

Policy Dialogues  

Prevention  at  source  will  be  key  to  tackling  the  rising  plastic  waste  tide,  in  line  with  the  EU's 
circular  economy  approach.  This  will  require  the  promotion  of  a  circular  plastics  economy  in 
third countries through policy dialogues on environment, industry and  trade. The Commission 
has  regular  policy  dialogues  on  e.g.  environment272  with  partner  countries  (notably  those 
members  of  the  G20)  and  world  regions,  such  as  the  Association  of  South  East  Asia  Nations 
(ASEAN). Trade partners can also be used to this end, in the context of free trade agreements273 
and the Generalised Scheme of Preferences274. 

270 http://www.euneighbours.eu/en/south/eu-in-action/projects/horizon-2020-capacity-

buildingmediterranean-environment-programme-h2020 

271 The Instrument for Pre-accession Assistance (IPA) is the means by which the EU supports reforms in the 

'enlargement countries' with financial and technical help 

272 http://ec.europa.eu/environment/international_issues/index_en.htm 

273 http://ec.europa.eu/trade/policy/countries-and-regions/negotiations-and-agreements/ 

274 http://ec.europa.eu/trade/policy/countries-and-regions/development/generalised-scheme-of-

preferences/ 

104 

 
 
 
                                                            
The Partnership Instrument 

The  EU's  ambitious  Circular  Economy  Action  Plan  fully  corresponds  to  the  objectives  of  the 
Partnership  Instrument275,  namely  to  support  EU  action  on  global  challenges  including  by 
promoting EU innovative solutions, thereby supporting market access and jobs in the Union. 

The circular economy creates the right conditions for the EU to accelerate the global transition 
to a resource efficient, low-carbon and circular economy, and boost the competitiveness of our 
businesses. Actions can include improving access to the country’s markets by enhancing trade, 
investment  and  business  opportunities  for  European  companies  who  have  already  adopted 
circular design and business models.  

In that respect, the EU has adopted, under the Partnership Instrument, a number of actions that 
support the circular economy and, indirectly, the EU Plastics Strategy. These include the China 
EU Water Platform (CEWP), the India-EU Water Partnership (IEWP), and the Resource Efficiency 
Initiative  (REI)  in  India  which  bring  together  expertise  from  the  EU  and  its  Member  States 
experts, and strongly engage with the private sector. 

Regional Seas Conventions 

The  EU  is  already  actively  cooperating  with  the  Regional  Seas  Conventions  protecting  the 
marine and coastal environment in the four marine regions around Europe276. Regional marine 
litter action plans are in place in three regions, and under preparation in the Black Sea; their aim 
is to ensure coherent and efficient actions of the riverine countries to reduce marine litter and 
its impacts. Efforts will be made with each of the Conventions to ensure a synergetic application 
of  the  EU  plastic  strategy.  A  project  supporting  implementation  of  the  Regional  Plan  against 
marine litter of the Barcelona Convention is ongoing277. 

6.3  Actions to be taken  

6.3.1  UN Level  

The EU will continue to support its international partners in their efforts towards more circular 
economy  and  drive  integration  of  circular  economy  considerations  to  the  appropriate 
international  processes,  frameworks,  platforms  and  events.  It  will  continue  lead  in  finding 
industrial  and  societal  solutions  to  address  plastics  management  issues  domestically  (e.g.  by 
favouring  the  development  of  new  types  of  more  sustainable  plastics  or  products,  as  well  as 
new  sorting  and  recycling  technologies).  The  EU  will  actively  take  part  in  setting  the 
international agenda in this field. 

This  year's  third  session  of  the  United  Nations  Environment  Assembly  held  in  Nairobi  on  4-6 
December 2017, addressed the theme 'Towards a pollution-free planet'. UNEA-3 adopted inter 
alia  a  resolution  tabled  by  Norway  on  marine  litter  micro-plastics  and  building  on  the  above-

275 http://ec.europa.eu/dgs/fpi/what-we-do/partnership_instrument_en.htm. 

276 The EU is member of the OSPAR (Northeast Atlantic), HELCOM (Baltic) and Barcelona Conventions 

(Mediterranean) and provides support to the Bucharest Convention (Black Sea). 

277 http://ec.europa.eu/environment/marine/good-environmental-status/descriptor-

10/pdf/Marine_litter_med_project_20_4_2016.pdf. 

105 

 
 
                                                            
mentioned UNEP assessment278. The resolution decided the establishment of an Ad Hoc Open 
Ended  Expert  Group  to  further  examine  the  barriers  to,  and  options  for,  combating  marine 
plastic litter and micro-plastics from all sources, especially land based sources. 

Under the Global Public Goods and Challenges (GPGC) thematic component of the Development 
Cooperation  Instrument  (DCI),  the  EU  supports  financially  the  completion  by  United  Nations 
Environment  Programme  (UNEP)  of  a  Regional  Waste  Management  Outlook  for  Small  Island 
Developing States (SIDS) to be completed by end 2018. The SIDS Waste Management Outlook 
will draw attention to priority issues and identify recommendations and potential solutions for 
waste  management  issues,  from  the  perspective  of  small  islands  developing  states,  so  to 
propose  solutions  and  opportunities  for  governments,  businesses  and  industries,  and  civil 
society  organisations  to  implement  sound  waste  management  and  the  related  multilateral 
environmental agreements. 

The  EU  will  support  the  adoption  and  implementation  by  third  countries  of  environmentally 
sound  waste  management  approaches  (ESM)  and  strategies,  inspired  by  the  waste  hierarchy 
and  by  extended  producer  responsibility  (EPR)  approaches.  Both  have  proven  to  be  essential 
elements in EU Waste Policy and have international backing (the waste hierarchy is embedded 
in the Basel Convention and the EPR schemes are recommended by the OECD and guidance is 
also  being  worked  out  under  the  Basel  Convention  and  is  now  used  by  a  majority  of  OECD 
countries for electric and electronic equipment, packaging and tyres. The ESM toolkit adopted 
under  the  Basel  Convention  and  other  guidance  developed  by  the  OECD  will  be  useful 
instruments  to  favour  plastic  waste  and  litter  prevention  and  the  promotion  of  material 
recycling. This support would be facilitated by the identification of a pool of experts on EPR in 
EU Member States on whom to draw for backing relevant EPR initiatives in dialogue with third 
countries  and  at  international  and  global  level,  including  participation  to  international 
conferences and workshops. 

6.3.2  G7 and G20  

The  EU  ought  to  continue  its  engagement  with  the  G7  Alliance  on  Resource  Efficiency  and  in 
particular  the  work  on  plastic  identified  in  the  Bologna  Roadmap  adopted  by  the  G7 
Environment  Ministers'  Meeting  in  June  2017,  the  G20  Resource  Efficiency  Dialogue,  and 
support  current  and  upcoming  G7/G20  Presidencies  in  implementing  the  G7  Action  Plan  to 
Combat Marine Litter and the G20 Marine Litter Action Plan, respectively.  

In particular, the Commission services plan to organise a G7 workshop on plastic management 
in  Brussels  in  the  first  half  of  2018,  open  to  G20  experts,  to  assess  the  opportunities  for 
improved product design, address barriers to recycling and reuse of plastic, and avoid plastics 
leakage into the environment, in particular the seas and oceans. 

278 UNEP (2017), Combating marine plastic litter and micro-plastics: An assessment of the effectiveness of 

relevant international, regional and subregional governance strategies and approaches. 

106 

 
 
                                                            
6.3.3  EU international actions  

Reducing plastic waste and marine litter in the Mediterranean  and  in East and South 
East Asia 

The  Commission  services  are  working  on  a  Partnership  Instrument  project  for  contributing  to 
reducing plastic waste and marine litter in East and South East Asia to be adopted by the end of 
2018. The project will contribute to reducing plastic waste, including marine litter (e.g. fishing 
gear),  via  a  set  of  activities  in  hot  spot  countries  in  the  region  (China,  Indonesia,  Philippines, 
Thailand,  Viet  Nam),  as  well  as  Singapore    and  Japan,  including  relevant  major  rivers.  These 
activities  will  take  place  in  the  context  of  the  circular  economy  concept,  promote  the  waste 
hierarchy  and  extended  producer  responsibility;  address  abandoned,  lost  and  otherwise 
discarded  fishing  gears  (ALDFG),  and  support  sustainable  plastic  production  and  green  public 
procurement.  

Concerning the Mediterranean, there is need to reinforce existing activities or launch new ones 
to  promote  the  waste  hierarchy  and  extended  producer  responsibility,  prevent  plastic  waste, 
and  monitor  marine  litter  in  support  of  the  implementation  of  the  Barcelona  Convention, 
including  its  relevant  policy  instruments,  monitoring  and  assessment  linked  to  the  Ecological 
Objectives of Ecosystem Approach. 

The  Schmidt  et  al.  (2017)  study  referred  to  above,  even  with  some  important  limitations,  has 
identified the top-10 rivers for land-based contribution to marine litter. The catchment areas of 
these  rivers  involve  a  small  number  of  countries279.  In  order  to  better  focus  efforts  where  it 
makes sense, the Commission will propose, in its policy dialogues with these riverine countries, 
its  expertise,  notably  on  waste  management  and  waste  water  treatment.  The  Partnership 
Instrument project in East and South-East Asia and  the specific actions for the Mediterranean 
mentioned  above  will  also  contribute  addressing  mismanagement  issues  in  these  countries, 
particularly in relation to areas along the major rivers identified for carrying litter to the oceans 
(see Error! Reference source not found.).  

In  addition,  a  database  inventorying  the  best  practices  around  the  world  will  be  developed 
accompanied  with  a  repertoire  of  experts  having  contributed  to  the  development  and 
application  of  these  best  practices.  On  that  basis,  specific  seminars  focused  on  concrete 
solutions  having  proven  to  be  efficient  whether  in  or  outside  the  European  Union  will  be 
proposed. This will open the path for additional concrete cooperation and financing of activities 
identified  as  best  practice  to  reduce  plastic  releases  in  these  priority  countries.  Additional 
financial support, where relevant and needed, could be considered. 

Managing and recycling plastic waste in the Caribbean sea, the Atlantic and the Indian 
Oceans 

Managing and reducing plastic waste is particularly challenging for the outermost regions, due 
to the limited size of their markets making it difficult to develop profitable recycling industries. 
The Commission adopted a Communication on "A stronger and renewed strategic partnership 

279 Twenty-three countries are riverine to the top 10 rivers identified in the study: Guinea, Mali, Benin, Niger, 

Nigeria, Burundi, Kenya, Rwanda, Uganda, Sudan, Ethiopia, Eritrea, Egypt, China, India, Pakistan, Russia, 

Mongolia, Laos, Burma, Vietnam, Cambodia and Thailand. 
107 

 
 
                                                            
with  the  EU's  outermost  regions"280.  This  strategy  aims  to  scale  up  outermost  regions' 
cooperation  with their neighbouring countries in order to  develop common important project 
including  waste  management  and  recycling.  Exchange  of  practices  and  experience  will  be 
intensified  between  these  regions,  regional  and  international  organisations  or  fora  on  global 
issues  such  as  international  ocean  governance.  There  are  already  promising  initiatives  and  EU 
funded-projects281. 

In Regional Fisheries Management Organisations (RFMOs) 

With the EU support, the Inter-American Tropical Tuna Commission (IATTC) has become the first 
fisheries organization  to adopt binding provisions on the recovery of Fish Aggregating Devices 
(FADs).  FADs,  float  and  drift  with  currents  and  are  therefore  difficult  to  locate  and  recover. 
RFMO contribution could consist not only in implementing cost-effective recovery practices to 
prevent  and  reduce  plastic  waste  from  fishing  and  aquaculture  but  also  in  developing  an 
innovative  design  introducing  biodegradable  devices.  The  Commission  is  currently  funding 
several  projects  to  test  biodegradable  FADs.  In  addition  to  those  initiatives,  the  EU  will  to 
promote  other  measures  to  prevent  plastic  waste  and  marine  litter  from  fishing  and 
aquaculture and to promote awareness and compliance of the MARPOL rules and of the EU PRF 
Directive on the disposal of plastics at sea.  

Involving the private sector  

The  EU  will  support  a  transition  to  a  global  circular  economy,  simultaneously  benefitting  the 
global environment and creating job and growth opportunities in Europe.  Showcasing European 
industrial and societal solutions to address plastics management, e.g. through circular economy 
missions  (CEMs)282,  will  provide  international  market  opportunities  not  only  to  the  European 
plastics industry but also to European clean-tech solutions and waste management approaches 
in line with the waste hierarchy. 

One  of  the  areas  where  this  can  be  done  concerns  the  development  of  international  industry 
standards on sorted plastic waste and recycled plastics to facilitate trade in these secondary raw 
materials, while at the same time protecting workers' health and the environment (see above). 
Moreover, this will further allow for the development of a stronger EU position during coming 
discussions at international level given the existing Vienna Agreement between CEN and ISO.  

The  engagement  of  the  private  sector  to  support  an  integrated,  cross-border  circular  plastics 
economy will be needed to deliver on the international objectives of the strategy. Opportunities 
to interact with and possibly support global private sector led initiatives should be explored. In 
particular,  relevant  industry  associations  and  leading  businesses  in  e.g.  the  EU  and  the  G20 
could consider the elaboration of a global protocol to prevent plastic waste arising, favour the 
recycling  of  plastic  waste  by  minimising  the  use  of  additives  and  micro-plastics,  and  support 
improved collection and recycling of plastic waste, including in developing countries. 

280 COM(2017)623 final 

281 A project on marine litter in Northern Periphery & Arctic region, dealing with the re-use of the lost fishnets 

is another example http://www.circularocean.eu/ 

282 http://ec.europa.eu/environment/international_issues/missions_en.htm 

108 

 
 
                                                            
Better enforcement of the EU Waste Shipment Regulation 

In  order  to  better  integrate  plastics  recycling  globally,  and  thus  create  a  circular  value  chain 
across borders, measures that increase the trust of operators and public authorities are needed. 
It will thus be important to ensure that plastics sent abroad for recycling are treated in similar 
conditions  as  within  the  EU,  through  a  better  enforcement  of  the  EU  Waste  Shipment 
Regulation283. According to the new inspection rules284, Member States' inspectors may reverse 
the burden of proof on exporters to show that the waste will be managed in an environmentally 
sound  manner  by  the  receiving  facility  in  the  destination  country.  In  the  absence  of  sufficient 
evidence, the shipment shall be considered illegal. 

Actions taken at the EU level with international impacts 

Liability  and  compensation285  arrangements  for  damage  to  the  marine  environment  from 
accidental or intentional discharge of solid material in the sea (e.g. the loss of cargo or fishing 
gear  by  a  ship  which  are  sources  of  marine  plastic  litter)  are  currently  not  covered  by  any 
international instrument.  

In  the  EU,  Article  2(1)(b)(ii)  of  the  Environment  Liability  Directive286  (ELD)  defines  'water 
damage'  as  "any  damage  that  significantly  adversely  affects  the  environmental  status  of  the 
marine  waters  concerned,  as  defined  in  Directive  2008/56/EC".  The  relevant  activity  falling 
under the scope of strict liability of the ELD could be "waste management operations, including 
collection,  transport,  recovery  and  disposal  of  waste"  in  Annex  III.2  but  perhaps  also  another 
activity  in Annex  III  (transport by  sea  of  dangerous  or  polluting  goods  in Annex III.8)  could be 
relevant (although applicable instruments and gaps remain to be clarified). Pursuant to Article 
13 of the Marine Strategy Framework Directive287 (MSFD), EU Member States have to identify 
the  measures  which  need  to  be  taken  in  order  to  achieve  or  maintain  good  environmental 
status of their marine waters and minimise the risk of damage beyond their marine waters.  

In  this  context,  the  Commission  intends  to  organise  a  workshop  by  the  end  of  2018  where 
participants  such  as  international  legal  experts,  marine  ecologists,  the  shipping  industry  and 
regulators would discuss international, regional and sub-regional legal and policy frameworks to 
combat marine plastic litter and micro-plastics, with a focus on the determination of damage to 
the environmental status of marine waters. 

283 Regulation (EC) No 1013/2006 of the European Parliament and of the Council of 14 June 2006 on 

shipments of waste (OJ L 190, 12.7.2006, p. 1). 

284 Regulation (EU) No 660/2014 of the European Parliament and of the Council of 15 May 2014 amending 

Regulation (EC) No 1013/2006 on shipments of waste (OJ L 189, 27.6.2014, p. 135). 

285 Compensation should not be limited to monetary measures but could also include reinstatement of the 

damaged natural environment. 

286 Directive 2004/35/CE of the European Parliament and of the Council of 21 April 2004 on environmental 

liability with regard to the prevention and remedying of environmental damage (OJ L 143, 30.4.2004, p. 56–

75), as amended three times. 

287 Directive 2008/56/EC of the European Parliament and of the Council of 17 June 2008 establishing a 

framework for community action in the field of marine environmental policy (OJ L 164, 25.6.2008, p. 19–40). 
109 

 
 
                                                            
Annex I Problem and solution mapping 

RAW MATERIAL PRODUCTION PHASE 

based 
Fossil 
plastics producers 

Alternative 
feedstock  based 
plastics producers 
(other 
than 
recycled 
materials) 

Recycled  plastics 
producers 

Technological constraints 

Economic factors 

Behavioural factors 

Legal barriers 

Infrastructure 

fossil 
Main  advantage: 
based 
raw 
plastic 
materials  are  cheap  and 
availability  (volumes  and 
quality) is certain   

Pricing  
Fossil  based  plastics  are  seen  as 
more  safe  and  fit  for  purpose  for 
whatever is the intended use 
Fossil 
built on linear model  

industry  was  historically 

technologies  under 
research 

New 
development: 
needs more investments  
For  biobased  plastics,  the 
issue  is  the  access  to  the 
feedstock (e.g. biomass)   

New  recycling  technologies 
under  development 
(e.g. 
chemical recycling)  
Traceability  of 
recycling  
Quality of input for recycling  
Not  everything  is  recyclable 

input 

for 

in 
innovation 

Market  underdeveloped: 
no  incentives  to  prefer  to 
use  plastics  other  than 
fossil based  
Investments  needed 
research  and 
(e.g. CO2 recycling) 
Pricing  
For  biobased  plastics,  the 
issue is equal access to the 
feedstock  in  concurrence 
to  other  sectors  using 
biomass (e.g. biofuels)  
Disadvantage:  price  of 
recyclates  
Market 
and lack of incentives  
Exports  
Recycling 
with 

competing 
for 

underdeveloped 

incineration 

is 

No  legal  framework 
for bioeconomy 

plastics: 
Biobased 
development 
linked 
also  to  existence  of 
separate  collection  of 
organic waste 

(also 
technological 

is  preferred 
of 

Downcycling 
because 
constraints)  
There  is  no  certification  scheme 
for  recycling  plants  which  in  the 
reassure 
opposite  case  could 
potential  clients  on  the  quality  of 

110 

End of life criteria for 
recycled plastics  
Lack  of  standards  for 
plastics 
be 
recycled 
of 
Lack 
standards 

quality 
for 

to 

sorting 

Separate 
and 
reinforced 
upgraded  
Risk 
contamination 
plastic  waste 

of 

collection 
to  be 
and 

cross 
if 
is  not 

Knowledge 
and 
information  gaps,  lack  of 
dialogue,  misgivings  and 
  that 
misunderstandings 
prevent taking actions 
Fossil  based  plastics  are 
seen  as  more  safe  and  fit 
for  purpose  for  whatever 
is the intended use 

"Bad reputation": 
-confusion 
created 
amongst consumers by the 
use of similar wording (e.g. 
bioplastics / biodegradable 
/ biobased) 
-in  terms  of  recyclability 
and 
impact  on  recycling 
infrastructure 
a 
Needs 
comparative LCA   

proper 

Some misgivings about the 
quality  and 
safety  of 
recycled plastics  
Lack of dialogue across the 
value chain 
Access to information (e.g. 
hazardous 
regarding 

Negative externalities 

climate 

CO2 emissions 
Use  of  limited  fossil 
resources  
Impact  on 
change  
Dependence 
imports  
Necessary 
(e.g.  use  of 
agriculture)  

trade-offs 
in 
land 

on 

is  an 

Non  recycling 
environmental 
negative externality as 
such  

 
 
 
 
 
 
 
 
 
substances used)  
Lack  of  information  (e.g. 
origin, 
components, 
contamination)  

Setting a High Level Group 
or  a  Working  Group  to 
encourage  dialogue  across 
the  value  chain  ensuring 
that  different  aspects  are 
into  account  (e.g. 
taken 
life, 
traceability,  end  of 
recyclability  and  recycling, 
product 
functionalities 
etc.)  

the 

some 

managed  and  stored 
properly  
For 
plastics 
closed loop system are 
preferred  (the  same 
application 
after 
recycling) 
Upgrading 
infrastructure: 
(1)Targeted 
investments  in  waste 
management 
infrastructure 
(separate  collection  of 
plastic  and  organic 
waste; 
sorting; 
recycling)  
(2) 
demonstrating 
projects as a showcase 
to  demonstrate 
the 
potential for local jobs 
and growth  

Regional 

at reasonable costs  
Design 
issues 
composites or multilayer)  

(e.g. 

energy 
landfilling  

recovery 

and 

recycled materials  
Uncertainty  about  the  uptake  of 
the recycled plastics 

recycled plastics  

sorting 

for 
and 

Research and innovation:  
(1)  Financial  support 
innovative 
recycling technics  
(2)  Eco-design  to  make  all 
plastic  packaging  recyclable 
by 2030  
(3) 
Identify  other  sectors 
beyond  plastic  packaging 
where  improved  design  or 
specific 
requirements  or 
guidelines  are  needed  to 
ensure availability of a good 
quality input for recycling  
(4) 
Investigate  possibilities 
to  have  a  data  base  with 
comprehensive  and  relevant 
to 
information 
Interface 
and 
tracers/markers)  

(linked 

Solutions 

type 

other 

other 
plastics 

Put  it  place  economical 
and 
of 
instruments  boosting  the 
market  for  plastics  made 
from 
alternative 
feedstock.  Aim  is  to  make 
prices  take  into  account 
environmental benefice.  
(1)  Regarding  alternative 
than 
feedstock 
recycled 
(e.g. 
biobased plastics) …  
(2)  Regarding  recyclates, 
recycling fund + EPR 
(3)  Update  guidance  on 
social 
and 
green 
procurement  and  provide 
guidance  on 
innovation 
procurement  
"model 
(4) 
Through 
region" 
demonstrator 
addressing 
show 
plastic 
and 
recycling issues can foster 
economic growth 
+  see  action  "Providing 
more  legal  certainty  for 
investments" 

waste 

that 

Voluntary agreements:  
(1)  to  ensure  a  more  certain 
uptake of recyclates 
(2)  set  up  new  closed 
collection-recycling schemes  

loop 

Providing  more  legal 
certainty 
for 
investments: 
Develop 
(1) 
for 
standards 
recycled 
plastics 
(input  for  recycling 
and out of recycling) 
(2)  Provide  more 
legal  and  investment 
certainty 
for  FMC 
made  from  recycled 
plastics 
while 
complying  with  the 
safety standards (e.g. 
improve 
authorisation 
procedures)   

111 

 
 
 
 
 
 
 
 
 
MANUFACTURING OF PLASTIC ARTICLES AND PRODUCTS PHASE 

Technological constraints  

Economic factors 

Behavioural factors 

Legal barriers 

Lack of infrastructure  

of 

needs 

to 
necessary 

Price 
recyclates 
compared  to  the  one  of 
virgin materials is higher 
and 
volume 
Scale, 
quantity  issues  regarding 
recycled plastics  
Investments 
the 
make 
changes  
Investments  needed 
to 
switch from linear to more 
circular model 
No  real  incentives  to  take 
circularity  of  plastics  into 
account  
EPR  (not  harmonised;  not 
full cost cover)  
Switching  to  more  circular 
plastics  has  a  cost  and 
takes time 

Converters  

Traceability  of 
recycled 
plastics  (origin,  presence 
of  hazardous  substances, 
possible future uses)   
Quality  of  recyclates  and 
their  capacity  to  meet 
aesthetical 
other 
requirements    compared 
to virgin raw materials  

and 

users 
Professional 
(big  brand  owners, 
companies, etc.) 

Plastics  (made  from  virgin 
materials 
recycled 
or 
plastics)  have  to  comply 
with certain requirements, 
be  fit  for  purpose  and 
meet 
consumer 
expectations 
Design for recyclability  
Trade-offs 
to 
in  order 
reach  different  objectives 
(e.g. 
lightweight,  energy 
and resource savings)  
Recyclates 
don't 
quality/functionality 
standards  

sometimes 
the 

meet 

Use  of  one  material  instead  of 
another  is  determined  by  what  is 
expected by their clients  
Responsibility  to  provide  safe  and 
fit for purpose materials  
Not  taking  into  account  the  fact 
that  one  material  will  come  back 
as a recyclate (not contributing to 
solve the traceability issue)  

to 

in  order 

objectives 

Prefers  cheap  and  "safe"  raw 
materials (fossil based plastics)   
reach 
Trade-offs 
different 
(e.g. 
lightweight,  energy  and  resource 
savings) 
Not  taking  into  account  the  fact 
that  one  material  will  come  back 
as a recyclate (not contributing to 
solve the traceability issue) 

112 

Switching 
to  more 
circular  plastics  has  a 
cost and takes time 

quality 
for 

Lack 
of 
standards 
recycled plastics 
Regulatory 
framework 
is  not 
clear  (e.g.  Interface 
CWP)  or  application 
of  it  is too  restrictive 
(food 
contact 
materials) 

for 
Responsibility 
products  put  on  the 
market  (e.g.  risks  for 
if  products 
image 
from 
made 
recyclates 
contain 
hazardous 
substances)  
Lack 
of 
definitions 
concepts 
recyclability 
design 
recyclability) 
Lack 
clear 
of 
guidelines  and  tools 
to  understand  what 
is  the  goal  to  reach 
(e.g. according to ERs 
is  to  be 
packaging 

clear 
of 
(e.g. 
or 
for 

Negative externalities  

CO2 emissions 
Use  of  limited  fossil 
resources  
Impact  on 
change  
Dependence 
imports 

climate 

on 

Knowledge 
and 
information  gaps,  lack  of 
dialogue,  misgivings  and 
  that 
misunderstandings 
prevent taking actions  
Traceability  of 
recycled 
plastics  (origin,  presence 
of  hazardous  substances, 
possible future uses): what 
technics  could  be  used  to 
ensure 
future, 
information  this  available 
of 
(for  what 
applications 
/uses 
/materials  /products)  and 
available to whom? 

kind 

that 

in 

climate 

CO2 emissions 
Use  of  limited  fossil 
resources  
Impact  on 
change  
Dependence 
imports 
Bad  image  (e.g.  public 
opinion)  

on 

Prefers  virgin  fossil  based 
materials  because  have 
some  misgivings  about 
safety  and  quality  of 
recycled plastics  
Better  understanding  of 
of 
the 
benefits 
implementing 
more 
circular model  
Lack of dialogue 
Not 
consider 
themselves  as  a  driver  for 
change  in  the  whole  value 
chain or don't want to take 
the  lead  or  is  not  very 
clear  who  should  take  the 
lead  
recycled 
Traceability  of 
plastics  (origin,  presence 
of  hazardous  substances, 

always 

 
 
 
 
 
in 

that 

kind 

possible future uses): what 
technics  could  be  used  to 
ensure 
future, 
information  this  available 
of 
(for  what 
applications 
/uses 
/materials  /products)  and 
available to whom? 
New 
that 
challenges 
companies were not aware 
of  and  with  a  lot  of  blind 
(e.g.  microfibers 
spots 
from 
or 
microbeads) 
Provide  funds  for  more 
research and development 
of  common  methodology, 
testing 
measuring 
(e.g. 
standards 
microtextiles) 

textiles 

and 

recyclable 
designed 
or  recoverable  but  is 
not  clear  which  one 
should be preferred)  

for 

(input 

recycled 
for 
and 

Develop standards  
(1) 
plastics 
recycling 
recyclates) 
(2)  plastics  claiming 
environmental 
benefit 
biodegradable 
plastics)  

(e.g. 

Solutions 

LCA 

choices 

technical 

Overcome 
barriers: 
(1) 
study  will 
contribute  to  the  toolbox 
in  order  to  make  the  best 
design 
for 
materials  
(2)  Quality  standards  for 
to 
recyclates 
comply with requirements 
and to be fit for purpose  
Investigating  possibilities 
to  have  markers  (tracers 
or other technics) in order 
to  improve  in  future  the 
traceability  of  substances 
of 
and 
materials 
information flows   

in  order 

Setting  a  High  Level  Group  or  a 
Working Group  
Providing  tools  (such  as  standards 
and 
to 
reassure and incentivise the use of 
recyclates  

certification 

systems) 

Financial incentives: 
(1)  Voluntary  agreements 
within the plastics industry 
to  ensure  a  more  certain 
uptake of recyclates  
(2)  Fund  for  recyclability 
to  benefit  to  those  who 
want  to  invest  in  order  to 
circular 
produce  more 
plastics 
coupled  with 
harmonised EPR schemes  
public 
(3) 
procurement 
incentivise 
innovation  

Through 

113 

 
 
 
 
 
 
 
USE PHASE 

Consumers 

Public authorities 

Solutions 

Technological constraints 

Economic factors 

Behavioural factors 

Legal barriers 

Infrastructure 

No  incentives  to  go  for 
more circular plastics 
Price is a key factor   

No  incentives  to  go  for 
more circular plastics 
Price is a key factor   

Choices  are  often  based  on  the 
price  of  products,  on  aesthetical 
reasons 
or 
functionality/performance  of  a 
product 
the 
rather 
"circularity" of it  
Without  intention  consumers  are 
causing  harm  to  the  environment 
(e.g.  micro-plastics 
(textiles, 
cosmetics, automotive)  

than  on 

One of the awareness raising tools 
for  public  authorities  could  be 
public 
(see 
procurement 
Communication  "Making  Public 
Procurement  work 
for 
Europe" October 2017)  

in  and 

114 

Negative externalities 

Waste generation  
to  missed 
Leads 
opportunities 
for 
businesses  (recyclers, 
converters)  

Costs 
of 
management 
cleaning up  

waste 
and 

Knowledge 
and 
information  gaps,  lack  of 
dialogue,  misgivings  and 
  that 
misunderstandings 
prevent taking actions 
Not  aware  of  economic 
and 
environmental 
benefits  of  the  use  of 
easily 
recycled 
recyclable plastic  
Not 
aware 
environmental 
some uses  

of 
impact  of 

or 

or 

Not  aware  of  economic 
and 
environmental 
benefits  of  the  use  of 
recycled 
easily 
recyclable plastic  
Include  public  authorities 
in  discussion  groups  on 
(e.g. 
emerging 
microfibers 
and  waste 
water treatment plants)  

issues 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
REUSE AND REPAIR 

Consumers 

Businesses 

Solutions 

Technological constraints 

Economic factors 

Behavioural factors 

Legal barriers 

Infrastructure 

No  incentives  to  choose 
reusable rather than single 
use items  
repairing 
Costs 
products  are  often  higher 
than buying new ones  

of 

Bad habits and prices are lower to 
buy  new  things  rather  than  to 
repair 
Lack  of  choice  between  single 
use/reusable  

No  incentive  to  put  forward  the 
repair 
possibility 
(depends  on  the  willingness  and 
awareness level of consumers)  

reuse  or 

to 

Information 
and 
disclosure 
intellectual  property 
issues 

of 

in 
a 
Infrastructure 
certified 
sense 
network  of 
repair/ 
refill  places  +  need  to 
have 
qualified 
employees  with  such 
skills  
Funding 
and 
investments  to  set  up 
repair/reuse 
local 
(including 
networks 
support  to  developing 
skills  and  employment 
actions) 

Negative externalities 

Waste generation  
Non  efficient  use  of 
resources  

Missed 
opportunity  

business 

Knowledge 
and 
information  gaps,  lack  of 
dialogue,  misgivings  and 
  that 
misunderstandings 
prevent taking actions 
Lack  of  information  about 
how/where to repair  

What  kind  of  information 
should  be  made  available 
(very  different  from  one 
sector 
to  another  e.g. 
automotive and EEE)  

Related 
Interface 
to 
Chemicals-Waste-Products 
communication 
and 
tracers/markers issue  

115 

 
 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
END OF LIFE 

Consumers 

National 
public 
authorities 

Businesses 

Technological constraints 

Economic factors 

Behavioural factors 

Legal barriers 

Infrastructure 

Lack  of  real  choice  (problem  of 
information  available  or  of  the 
price)   

to 

and 

linked 

the 
on 
is 

level  of 
how 
the 

Behaviour 
awareness 
complicate/developed 
collection-sorting-recycling schema  
Bad habits that leads to littering  
Victims  of  false  green  claims  (e.g. 
regarding 
full 
compostability 
biodegradability,  including  in  marine 
oxo-degradable 
environment 
plastics)  

or 

of 

Innovative  technics  of  collection, 
sorting  and/or  recycling 
take 
time and money to be developed 
and to be operational  

Upgrading 
public 
infrastructure  needs 
investment  

it  doesn't  take 

Legal framework is always up to date in 
a  sense  that 
into 
account  the  new  issues  (e.g.  micro-
in  waste  water  treatment 
plastics 
facilities  and  sludge  or 
in  drinking 
water)  

Implementing 
of 
the  WFD  depends 
on the MS  
Fees  and  penalties 
for littering depend 
on the MS national 
laws  

littering 

Recyclability is not a goal as such  
(e.g. 
Unintentional 
micro-plastics 
from  cosmetics 
and detergents; microfibers from 
textiles) 

No  incentive  to  take 
into  account  the  end 
of life phase  
Switching 
to  more 
circular  plastics  has  a 
cost 

incentives 

No 
from  consumers  to 
switch  more  sustainable  (recyclable, 
recycled, reusable etc.) plastics   
Design  for  recyclability  taking 
account end of life  
Lack  of  awareness  regarding 
such as littering (e.g. pellet losses)  

issues 

into 

of 

Lack 
public  waste 
management  facilities  (e.g. 
bins)  

sorting, 

Lack  of  waste  management 
(collecting  (including  public 
bins), 
recycling) 
infrastructure 
Investments have been made 
over  these  past  years 
in 
incineration capacity  
Littering  (e.g.  plastic  pellet 
losses)  and  waste/resource 
management within plants  

Recycling 
industry 

if  are 
Some  plastics  even 
collected, 
can't  be  properly 
sorted or are not recyclable (e.g. 

Recycling is costly but 
the market prices are 
into 
taking 
not 

Lack  of  end  of 
waste 
criteria 
(including 

management 
Waste 
infrastructure to be upgraded 
Collection  schemes  do  not 

116 

Knowledge 
and 
information  gaps,  lack  of 
dialogue,  misgivings  and 
misunderstandings 
Misunderstanding  about 
what 
is  recyclable  and 
how should be recycled  
The  use  of  similar  terms 
(biodegradable;  
compostable  and  home-
compostable; 
biobased 
plastic)  confusing  for  the 
consumer  
Not  aware  of  what  are 
the  real  costs  of  waste 
management and littering 
and  what  can  be  the 
environmental benefits 

Negative 
externalities 

Waste generation  
Waste of resources if 
waste is not recycled 
(and 
other 
environmental 
externalities 
linked 
to  this  such  as  CO2 
emissions)  

Waste  and  littering 
that  need 
to  be 
collected (extra costs 
for public funds)  

Lack  of  dialogue  across 
the  value  chain  to  take 
into  account  the  end  of 
life phase 
Lack  of  reliable  data  and 
scientific  based  evidence 
(e.g. 
for  some 
microfibers, 
micro-
plastics)  
about 
Information 
hazardous  substances  in 
plastics to be recycled   

issues 

"Plastic  leakage"  to 
third countries  

 
 
 
 
 
 
 
 
 
 
plastic waste from demolition) 
Traceability  
The 
technologies 
available  do  not  allow 
recycling of all plastic types 
Volumes  for  some  plastic  waste 
streams  are  currently  too  low 
(e.g. demolition waste)  

currently 
for 

the 

account 
environmental 
benefits  
Excessive  transaction 
in  the  waste 
costs 
market 

Solutions 

to 

Harmonise 
the 
internal  market  for 
recovered  materials 
or  material 
flows 
from  which  they  can 
be recovered: 
(1)Investments 
upgrade 
infrastructure  
(2)Put in place a fund 
allowing  to  take  into 
account  the  negative 
environmental 
externalities  induced 
by 
based 
plastics  

fossil 

for 

and 

(e.g. 

flexible 

innovation 

to 
(linked 
Waste-Chemicals-

Support 
cooperation: 
(1) 
collection-sorting-recycling 
technologies 
chemical 
and 
recycling; 
multilayer packaging) and to help 
to  scale  up  volumes  of  high 
quality plastics that can  
Traceability 
(2) 
Interface 
Products) 
(3)Provide  a  framework  (to  be 
implemented  on voluntary basis) 
to  reduce  unintentional  littering 
(e.g.  plastic  pellet  losses)  and 
improve  waste  management 
(including setting up local B2B to 
platforms to improve reuse rates 
and create business cases for the 
uptake  of  potentially  reusable 
(e.g. 
recyclable 
materials)  

cut-offs)  or 

to 

Awareness raising:  
(1)  Work  on  consumers'  awareness 
raising  e.g.  littering,  proper  sorting, 
recycling  etc. 
is  more  ENV  action. 
raise 
GROW  could  contribute 
awareness amongst industry (via BREFs 
and  best  available  technics  (BATs) 
voluntary 
where 
a 
agreements 
certification scheme)  
(2 ) If a High Level Group or a Working 
Group  is  set,  ensure  that  end  of  life  is 
properly 
in 
taken 
discussions on eco-design  

into  account 

appropriate, 

setting 

up 

or 

Improved framework for plastics: 
(1) Provide an improved framework for 
including  a 
biodegradable  plastics, 
reflection  on  how  to  avoid  false  green 
claims  and  follow  up  actions  on  oxo-
degradables (ENV) 
(2)  Could  be  done  through  a  recycling 
plant certification  system  

117 

Lack of dialogue 

If a High Level Group or a 
Working  Group 
is  set, 
ensure  that  information 
channels  and  traceability 
are part of the discussion   

in 

(e.g. 

for  every 

type  of 
exist 
plastics  or  are  organised  on 
some 
voluntary  basis 
countries 
plastic 
mulches)  
In  some  sectors,  separate 
plastic  waste  collection 
is 
often 
technically 
either 
impossible  (e.g.  demolition 
waste)  or  would  have  a 
environmental 
negative 
impact 
from 
demolition waste)   

(e.g. 

EPS 

the 

investments 

Upgrading 
infrastructure: 
(1)Targeted 
in 
waste 
management 
(separate 
infrastructure 
collection  of  plastic  and 
organic  waste; 
sorting; 
recycling)  
(2) Encourage industry to set 
collection 
closed 
schemes 
plastic 
mulches)  

loop 

(e.g. 

not 

legal 

targets 
high 

standards  for  input 
for  recycling  and 
recyclates) 
Recycling 
are 
enough 
interaction 
The 
between 
health, 
safety,  trade  and 
environmental 
regulation  create  a 
complex, 
too 
always 
evolving 
and burdensome 
Overcome 
barriers:  
(1)  Setting  quality 
standards 
for 
plastic  waste  as 
input  for  recycling 
and 
recycled 
plastics  (as  part  of 
reflection  of  end-
of-waste  criteria  or 
not) 
(2)  Reflect  on  how 
to 
limit  or  ban 
of 
landfill 
recyclable  plastics 
and 
limit 
to 
incineration  
(3)  Establish  clear 
requirements  and 
standards 
for 
collection 
systems in EU  

 
 
 
 
 
 
  
 
Annex II Standards for bio-based and biodegradable plastics  

Topic 

is  no  standard  for  plastics  with 

Standard 
Currently  there 
biodegradability properties  
ISO  14851:  Determination  of  the  ultimate  aerobic 
biodegradability  of  plastic  materials  in  an  aqueous 
medium- Method by measuring the oxygen demand in 
a closed respirometer 
+ EN ISO 14851:2004 

Biodegradable 
plastics 

ISO  14852:  Determination  of  the  ultimate  aerobic 
biodegradability  of  plastic  materials  in  an  aqueous 
medium- Method by analysis of evolved carbon dioxide 
+ EN ISO 14852:2004 

Technical report / specifications 

Description 

This  International  Standard  specifies  a  method,  by  measuring  the  oxygen  demand  in  a  closed 
respirometer,  for  the  determination  of  the  degree  of  aerobic  biodegradability  of  plastic  materials, 
including  those  containing  formulation  additives.  The  test  material  is  exposed  in  an  aqueous  medium 
under laboratory conditions to an inoculum from activated sludge, compost or soil. 
If an unadapted activated sludge is used as the inoculum, the test simulates the biodegradation processes 
which occur in a natural aqueous environment; if a mixed or pre-exposed inoculum is used, the method 
can be used to investigate the potential biodegradability of a test material. 
The  conditions  used  in  this  International  Standard  do  not  necessarily  correspond  to  the  optimum 
conditions  allowing  maximum  biodegradation  to  occur,  but  the  standard  is  designed  to  determine  the 
potential  biodegradability  of  plastic  materials  or  give  an  indication  of  their  biodegradability  in  natural 
environments. 
The  method  enables  the  assessment  of  the  biodegradability  to  be  improved  by  calculating  a  carbon 
balance (optional, see annex E). 
The method applies to the following materials: 
— Natural and/or synthetic polymers, copolymers or mixtures thereof. 
— Plastic materials which contain additives such as plasticizers, colorants or other compounds. 
— Water-soluble polymers. 
— Materials which, under the test conditions, do not inhibit the microorganisms present in the inoculum. 
Inhibitory  effects  can  be  determined  using  an  inhibition  control  or  by  another  appropriate  method 
(see e.g. ISO 8192[3]. If the test material is inhibitory to the inoculum, a lower test concentration, another 
inoculum or a pre-exposed inoculum can be used. 
This International Standard specifies a method, by measuring the amount of carbon dioxide evolved, for 
the  determination  of  the  degree  of  aerobic  biodegradability  of  plastic  materials,  including  those 
containing  formulation  additives.  The  test  material  is  exposed  in  a  synthetic  medium  under  laboratory 
conditions to an inoculum from activated sludge, compost or soil. 
If an unadapted activated sludge is used as the inoculum, the test simulates the biodegradation processes 
which occur in a natural aqueous environment; if a mixed or pre-exposed inoculum is used, the method 
can be used to investigate the potential biodegradability of a test material. 
The  conditions  used  in  this  International  Standard  do  not  necessarily  correspond  to  the  optimum 
conditions  allowing  maximum  biodegradation  to  occur,  but  the  standard  is  designed  to  determine  the 

118 

 
 
 
 
 
 
 
potential  biodegradability  of  plastic  materials  or  give  an  indication  of  their  biodegradability  in  natural 
environments. 
The  method  enables  the  assessment  of  the  biodegradability  to  be  improved  by  calculating  a  carbon 
balance (optional, see Annex C). 
The method applies to the following materials: 
— Natural and/or synthetic polymers, copolymers or mixtures thereof. 
— Plastic materials which contain additives such as plasticizers, colorants or other compounds. 
— Water-soluble polymers. 
— Materials which, under the test conditions, do not inhibit the microorganisms present in the inoculum. 
Inhibitory effects can be determined using an inhibition control or by another appropriate method (see 
e.g.  ISO 8192[2]).  If  the  test  material  is  inhibitory  to  the  inoculum,  a  lower  test  concentration,  another 
inoculum or a pre-exposed inoculum can be used 
Standard specifies the requirements for biodegradable films, manufactured from thermoplastic materials, 
to  be  used  for  mulch  applications  in  agriculture  and  horticulture.  This  document  is  applicable  to  films 
intended to biodegrade in soil without creating any adverse impact on the environment. It also specifies 
the test methods to assess these requirements as well as requirements for the packaging, identification 
and marking of films. For information, it defines a classification of biodegradable mulch films according to 
their service life on soil and gives a good practice guide for the use of the films. NOTE Films intended to 
be removed after use and not incorporated in the soil are not in the scope of this standard (EN 13655).   
This Technical Report gives guidance for the quantification of alteration of biodegradable thermoplastic 
mulch films for use in agriculture and horticulture. It may be used for biodegradable thermoplastic mulch 
films in conformance with prEN 17033.  

The method is designed to yield an optimum degree of biodegradation by adjusting the humidity of the 
test  soil.  If  a  non-adapted  soil  is  used  as  an  inoculum,  the  test  simulates  the  biodegradation  processes 
which  take  place  in  a  natural  environment;  if  a  pre-exposed  soil  is  used,  the  method  can  be  used  to 
investigate the potential biodegradability of a test material. 
This guide provides the vocabulary to be used in the field of polymers and plastic materials and items. The 
proposed terms and definitions are directly issued from a scientific and technical analysis of the various 
stages  and  mechanisms  involved  in  the  alteration  of  plastics  up  to  mineralization,  bioassimilation  and 
biorecycling of macromolecular compounds and polymeric products; i.e polymeric items. 
This Technical Report is intended to summarise the current state of knowledge and experience in the field 
of biodegradable plastics which are used on soil or end up in soil. It also addresses the links between use, 
disposal after use, degradation mechanisms and the environment. Therefore, this document is intended 
to  provide  a  basis  for  the  development  of  future  standards.  Its  aim  is  to  clarify  the  ideas  and  ensure  a 
level  playing  field,  without  hiding  possible  needs  for  further  research  or  areas  of  disagreement  among 
experts. 

EN  17033  Biodegradable  mulch  films  for  use 
in 
agriculture  and  horticulture  –  Requirements  and  test 
methods 

EN  ISO  17556:2012  Plastics  -  Determination  of  the 
ultimate aerobic biodegradability of plastic materials in 
soil by measuring the oxygen demand in a respirometer 
or the amount of carbon dioxide evolved  

17219 

FprCEN/TR 
(WI=00249989) 
Plastics  -  Biodegradable  thermoplastic 
mulch  films  for  use  in  agriculture  and 
the 
- 
horticulture 
quantification of alteration of films 

Guide 

for 

CEN/TR 
15351:2006  
Plastics  -  Guide  for  vocabulary  in  the 
field  of  degradable  and  biodegradable 
polymers and plastic items 
CEN/TR 
15822:2009  
Plastics - Biodegradable plastics in or on 
soil  -  Recovery,  disposal  and  related 
environmental issues 

119 

 
 
 
 
 
 
 
ISO 17088:2012 Specifications for compostable plastics  

EN  13432  Requirements  for  packaging  recoverable 
through composting and biodegradation 

Compostable 
plastics 

EN  14995  Requirements 
through composting and biodegradation 

for  plastics  recoverable 

EN  ISO  20200:2015  Plastics  -  Determination  of  the 
degree  of  disintegration  of  plastic  materials  under 
simulated  composting  conditions  in  a  laboratory-scale 
test  
EN  ISO  14855-1:2012  Determination  of  the  ultimate 
aerobic  biodegradability  of  plastic  materials  under 
controlled composting conditions - Method by analysis 
of  evolved  carbon  dioxide  -  Part  1:  General  method 
(ISO 14855-1:2012) 

EN  ISO  14855-2:2009  Determination  of  the  ultimate 
aerobic  biodegradability  of  plastic  materials  under 
controlled composting conditions - Method by analysis 
of  evolved  carbon  dioxide  -  Part  2:  Gravimetric 

120 

Currently under review 
It  specifies  procedures  and  requirements  for  the  identification  and  labelling  of  plastics,  and  products 
made from plastics, that are suitable for recovery through aerobic composting (including biodegradation 
and disintegration during composting). This specification is intended to establish the requirements for the 
labelling of plastic products and materials, including packaging made from plastics, as “compostable” or 
“compostable  in  municipal  and  industrial  composting  facilities”  or  “biodegradable  during  composting” 
(for the purposes of this International Standard, these three expressions are considered to be equivalent). 
The labelling will, in addition, have to conform to any international, regional, national or local regulations.  
This  European  Standard  specifies  requirements  and  procedures  to  determine  the  compostability  and 
anaerobic  treatability  of  packaging  and  packaging  materials  by  addressing  four  characteristics:  1) 
biodegradability;  2)  disintegration  during  biological  treatment;  3)  effect  on  the  biological  treatment 
process;  4)  effect  on  the  quality  of  the  resulting  compost.  In  case  of  a  packaging  formed  by  different 
components, some of which are compostable and some other not, the packaging itself, as a whole is not 
compostable. 
This  European  Standard  specifies  requirements  and  procedures  to  determine  the  compostability  or 
anaerobic  treatability  of  plastic  materials  by  addressing  four  characteristics:  I)  biodegradability,  II) 
disintegration during biological treatment, III) effect on the biological treatment process and IV) effect on 
the quality of the resulting compost. 
It specifies a method of determining the degree of disintegration of plastic materials when exposed to a 
laboratory-scale  composting  environment.  The  method  is  not  applicable  to  the  determination  of  the 
biodegradability of plastic materials under composting conditions. Further testing is necessary to be able 
to claim compostability. 
It specifies a method for the determination of the ultimate aerobic biodegradability of plastics, based on 
organic compounds, under controlled composting conditions by measurement of the amount of carbon 
dioxide  evolved  and  the  degree  of  disintegration  of  the  plastic  at  the  end  of  the  test.  This  method  is 
designed  to  simulate  typical  aerobic  composting  conditions  for  the  organic  fraction  of  solid  mixed 
municipal  waste.  The  test  material  is  exposed  to  an  inoculum  which  is  derived  from  compost.  The 
composting  takes  place  in  an  environment  wherein  temperature,  aeration  and  humidity  are  closely 
monitored and controlled. The test method is designed to yield the percentage conversion of the carbon 
in the test material to evolved carbon dioxide as well as the rate of conversion. Also specified is a variant 
of the method, using a mineral bed (vermiculite) inoculated with thermophilic microorganisms obtained 
from  compost  with  a  specific  activation  phase,  instead  of  mature  compost.  This  variant  is  designed  to 
yield  the  percentage  of  carbon  in  the  test  substance  converted  to  carbon  dioxide  and  the  rate  of 
conversion. 
ISO  14855-2:2007  specifies  a  method  for  determining  the  ultimate  aerobic  biodegradability  of  plastic 
materials under controlled composting conditions by gravimetric measurement of the amount of carbon 
dioxide  evolved.  The  method  is  designed  to  yield  an  optimum  rate  of  biodegradation  by  adjusting  the 
humidity,  aeration  and  temperature  of  the  composting  vessel.  The  method  applies  to  the  following 

 
 
 
 
 
 
 
 
in  a 
measurement  of  carbon  dioxide  evolved 
laboratory-scale  test  (ISO  14855-2:2007,  including  Cor 
1:2009) 
No standard exists for home compostability of plastics 
with biodegradable properties  
ISO 16620-4:2016 Plastics – Bio-based content 

Bio-based 
plastics 

materials:  natural  and/or  synthetic  polymers  and  copolymers,  and  mixtures  of  these;  plastic  materials 
that contain additives such as plasticizers or colorants; water-soluble polymers; materials that, under the 
test conditions, do not inhibit the activity of micro-organisms present in the inoculum. 

“Biobased plastics” refer to plastics that contain materials wholly or partly of biogenic origin. It specifies a 
method of determining the biobased mass content in plastics products, based on the radiocarbon analysis 
and elemental analysis. ISO 16620-4:2016 is applicable to plastic products and plastic materials, polymer 
resins, monomers or additives, which are made from biobased or fossil-based constituents.  
This Technical report gives recommendations for bioplastics and biopolymers related terminology. These 
recommendations are based on a discussion of commonly used terms in this field. This Technical Report 
also  briefly  describes  the  current  test  methods  state  of  the  art  in  relation  to  the  characterization  of 
bioplastics and products made thereof. 
This Technical Specification specifies a calculation method for the determination of the bio-based carbon 
content  in  monomers,  polymers  and  plastic  materials  and  products,  based  on  the  14C  content 
measurement. It also specifies three test methods to be used for the determination of the 14C content 
from which the bio-based carbon content is calculated. The bio-based carbon content is expressed by a 
fraction  of  sample  mass,  as  a  fraction  of  the  total  carbon  content  or  as  a  fraction  of  the  total  organic 
carbon  content.  This  calculation  method  is  applicable  to  any  polymers  containing  organic  carbon, 
including biocomposites.  
This Technical Specification provides requirements for the declaration, including statements and labels, of 
the bio-based carbon content of items, such as polymers, plastic materials, semi-finished plastic products 
and finished plastic products, including composites. 
This  Technical  Specification  specifies  a  template  for  reporting  and  communication  of  characteristics 
covering  bio-based  carbon  content  and  recovery  options  (i.e.  organic  recycling,  material  recycling  and 
energy recovery) of a given item in commercial business-to-business transactions by means of a specific 
data sheet for biopolymers and bioplastics. This Technical Specification also gives the relevant methods 
for the evaluation and verification of the claims. This Technical Specification provides the principles and 
requirements  for  the  communication  of  selected  claims  in  the  field  of  environmental  performance  and 
characteristics to be used with reference to items such as biopolymers, bioplastic materials, semi-finished 
bioplastic  products  and  finished  bioplastic  products,  including  composites,  before  it  is  available  to  the 
end-user  or  consumer.  This  Technical  Specification  is  not  intended  for  use  in  communicating  biobased-
content  and  recovery  options  in  business  to  consumer  communications  Biocompatible  polymers  and 
plastics for medical applications, covered by specific provisions, are out of the scope of this document. 

- 

Recommendation 

15932:2010  
CEN/TR 
Plastics 
for 
terminology  and  characterisation  of 
biopolymers and bioplastics 
16137:2011  
CEN/TS 
Plastics  -  Determination  of  bio-based 
carbon content 

CEN/TS 
16295:2012  
Plastics  -  Declaration  of  the  bio-based 
carbon content 
CEN/TS 
16398:2012  
Plastics  -  Template  for  reporting  and 
communication  of  bio-based  carbon 
recovery  options  of 
content  and 
biopolymers and bioplastics - Data sheet 

121 

 
 
 
 
 
 
 
 
 
 
 
Annex III EU Cohesion Policy programs: examples of funded projects related to plastics  

Topic 

Title 

Description 

Reducing 
waste 

plastic 

BLASTIC (Baltic Sea)  
https://www.blastic.eu/  

Repair  and  re-use 
networks 
and 
centres  in  Central 
Europe states 

CERREC  
(central Europe)  
http://ec.europa.eu/regional_policy/fr/projects/austria/reducing-waste-
through-the-re-use-and-repair-of-old-products  
http://cerrec.eu/  

BLASTIC  aims  at  reducing  plastic  waste  and  thereby  hazardous 
substances  inflow  into  the  Baltic  Sea  by  mapping  potential  litter 
sources  in  urban  areas  and  monitoring  litter  levels  in  the  aquatic 
environment 
CERREC aims at implementing repair and re-use networks and centres 
adapted to the specific conditions of the participating Central Europe 
states.  For  that  several  tools  will  be  developed  like  concepts  and  a 
handbook  for  re-use  networks  and  centres,  a  quality  standard 
guideline, knowledge transfer describing and an accreditation system. 

Time 
period 

2014-
2020 

Funding 
Total 
Amount 
EUR 
1,016,556 

2007-
2013 

EUR 
2,898,288  

Recycling 
plastic waste  

rigid 

Technopoly 
(Belgium)  
http://ec.europa.eu/regional_policy/fr/projects/belgium/belgiums-walloon-
region-creates-innovative-process-for-recycling-bulky-plastics  

In the Walloon Region of Belgium, the Technopoly Recyclage project 
has  implemented  an  innovative  process  for  recycling  post-consumer 
rigid  plastic  waste  at  the  landfill  itself.  The  recycling  loop  covers 
selective collection, waste treatment and processing – converting the 
rigid plastic into valuable secondary raw materials. 

2007-
2013  

EUR 
5,268,594 

Recycling  and  re-
use of bulky waste 

Bruxelles-Ecopôle  
(Belgium)  
http://ec.europa.eu/regional_policy/fr/projects/belgium/bruxelles-ecopole-
brussels-ecopole-gives-bulky-waste-a-new-lease-of-life  

Closed-loop 
circular 
synergies  

or 
model 

Envi Grow Park (Finland)  
http://ec.europa.eu/regional_policy/en/projects/finland/envi-grow-park-a-
virtuous-circle-of-recycling-and-waste-management-in-southern-finland  

By  creating  a  regional  platform  for  waste  recovery,  the  Bruxelles-
Ecopôle project will enable the recycling or reuse of more than 4,000 
tonnes of bulky waste per year that would otherwise be disposed of. 
The  project  aims  to  raise  awareness  and  provide  a  social  setting 
through  the  creation  of  a  showroom,  the  sale  of  recycled  products 
and tours of its facilities, predominantly aimed at schools. The project 
will also enable low-skilled job creation. 
This  category  of  waste  includes  standard  bulky  waste  as  well  as 
electrical and electronic waste and some construction materials. 
Efficient  zoning  solutions  and  a  compact  industrial  development 
model  are  boosting  innovation  and  sustainable  growth  in  southern 
is  currently  home  to  more  than  20 
Finland.  Envi  Grow  Park 

122 

2007-
2013  

EUR 
9,481,576  

2007-
2013 

EUR 
285,600  

EUR 114 240 
EU’s 
The 
Regional 

European 
Development 

EU participation 

EUR 784 522 
ERDF 
Programme 

Central 

Baltic 

EU’s 

EU’s 

EUR 2 269 713 
European 
The 
Development 
Regional 
Fund  is  contributing  from 
Operational 
the 
Programme 
“CENTRAL 
EUROPE” 
EUR 1 574 198 
The 
Regional 
Fund 
through 
(Hainaut)” 
Programme 
EUR 4,470,046 
The  European  Regional 
Fund 
Development 
(ERDF) 
the 
Operational  Programme 
"Brussels Capital Region" 

European 
Development 
contributing 
the  “Wallonia 
Operational 

is  under 

 
 
 
 
 
Recycled  plastics 
and tyres  

Ecodec,  a  Guadeloupe-based  company  specialising 
industrial waste processing (France)  
http://ec.europa.eu/regional_policy/en/projects/france/world-class-
recycling-centre  

in  household  and 

Waste 
management  

Ecoparc (Spain)  
http://ec.europa.eu/regional_policy/en/projects/spain/a-window-of-
opportunity-for-waste  

Reducing 
rates  and 
dumping 

landfill 
illegal 

Suceava County (Romania) 
http://ec.europa.eu/regional_policy/en/projects/romania/county-looks-
forward-to-new-waste-management-facilities  

latest  addition  to  the  Park 

companies,  employing  200 experts,  that  specialise  in  recycling  and 
waste  management  or  operate  with  recycled  materials  and 
renewable  energy.  The 
is  a  new 
biomethane  filling  station  for  cars  and  trucks.  Biomethane  is  also 
used in the manufacture of glass wool-based insulation materials, and 
the  green  electricity  produced  from  biogas  by  the  local  CHP  unit  is 
used in a printing house. 
The archipelago of Guadeloupe is a French overseas  region. Located 
in the Caribbean, it has a population of around 405 000 and produces 
more  waste  per  inhabitant  on  average  than  mainland  France.  Until 
the construction of the Ecodec facility, almost none of this waste was 
collected or sorted for recycling. 
Completed 
in  2009,  the  project  created  much-needed  waste 
collection  and  processing  facilities  for  the  archipelago.  These  meet 
the latest European waste disposal standards. Plastics and used-tyres 
waste passing through the facilities can now be reused immediately, 
rather than being incinerated or dumped in landfill sites with the risk 
of creating pollution. At full capacity, the facilities can process several 
hundred  tonnes  of  plastics  and  old  tyres  a  week.  These  are  turned 
into granulates with a certificate guaranteeing their quality. Recycled 
material like this can be sold worldwide to make anything from tubes 
to garden furniture – and all for a cost of around 20% less than virgin 
material. 
The  project  also  resulted  in  the  building  of  a  new  collection  and 
sorting  centre  for  household  waste,  agricultural  plastic  waste  and 
non-hazardous  industrial  waste.  The  centre  is  continually  fed  by 
deliveries from local authorities and companies. 
The  Ecoparque  has  two  main  waste  treatment  processes  –  solid 
urban  waste  and  light  packaging.  Larger  items  such  as  furniture, 
personal  effects  and  garden  waste  are  also  treated  at  the  site.  Any 
organic  matter  is  separated  from  recyclable  matter  such  as  plastic, 
paper, cardboard, glass and metal. The organic matter goes  through 
two  processes.  In  the  biomethanisation  process,  the  organic  part  is 
degraded  to  produce  thermal  energy  and  electricity  for  use  at  the 
Ecoparque itself (25%) and also locally. 
The  objective  of  this  project  is  to  provide  solid  waste  management 
facilities  and  activities  which  will 
integrate  waste  separation, 
collection,  transport,  treatment,  recycling  and  disposal.  At  the  same 

123 

Fund  from  the  “Southern 
Finland 
ERDF 
Programme” 

2007-
2013 

EUR 
14,808,100 

EU’s 

EUR 5,356900 
The 
Regional 
Fund  

European 
Development 

2007-
2013 

EUR 
12,500,000 

EUR  12,500,000  through 
Cohesion Fund  

2007-
2013 

EUR 
48,000,000 

EUR 36 000 000 
the  European  Regional 
Development Fund 

 
 
Material  Recycling 
Facility 
for 
household 
recyclables 

Upgrading the Sant'Antnin waste treatment plant and material recycling and 
recovery facility 
http://ec.europa.eu/regional_policy/en/projects/malta/malta-curbs-the-
cycle-of-waste  

solid 

Integrated 
waste 
management 
system 

County of Sibiu (Romania) 
http://ec.europa.eu/regional_policy/en/projects/romania/sorting-out-
waste-for-clean-future   

in 

time,  several  urban  landfills  will  be  closed  and  rehabilitated  and  a 
public awareness campaign will promote the benefits of recycling. 
Under the new waste management system, collection rates for mixed 
waste will cover 100 % of the urban population and 95 % of the rural 
population.  In  2013  the  scheme  should  lead  to  a  50  %  reduction  in 
the  amount  of  biodegradable  waste  that  ends  up 
landfill 
(compared  to  1995).  This  will  be  made  possible  thanks  to  the 
improved  waste  collection  rates  and  the  promotion  of  home 
composting and the in-situ composting of park and garden waste. 
A  separate  collection  of  packaging  waste  will  be  provided  to  the 
entire urban population and 95 % of the rural population. Therefore, 
by 2013, the county will have a total waste recovery rate of 60 % and 
a recycling rate of 55 %. Projected recycling rates can be broken down 
as follows: glass 60 %; paper and cardboard 60 %; metal 50 %; plastic 
22.5 %; and 15 % for wood. 
The  Material  Recovery  Facility  (MRF),  opened  in  2008,  is  now  fully 
operational,  processing  selectively  collected 
from 
households, such as glass, paper, metals and plastics. The MRF is just 
one of several components of the Sant’Antnin upgrade that by 2010 
are  expected  to  process  and  treat  some  36  000  tonnes  of  dry 
recyclables every year. Sant’Antnin will also include a digestion plant 
to  treat  clean,  biodegradable  waste  and  recover  energy  from  the 
biogas  produced.  This  biogas  facility  can  produce  ‘green  electricity’ 
and  compost.  The  digestion  plant  will  incorporate  a  number  of 
modules  to  post-treat  the  digestate  emerging  from  the  digestion 
plant – the final aerobic stage will stabilise this digestate and create 
compost. 
The  focus  of  the  project  investments  is  the  solid  waste  sector.  The 
following  are  the  main  components  of  the  project:  supply  of 
collecting  equipment,  including  euro-containers  and  euro-bins,  as 
well as home composting units; constructing a sorting plant (20 000 
t/year) and two composting plants; closing and rehabilitating 5 urban 
landfills; and public awareness campaigns aimed at reducing waste at 
source or source separation of recyclable materials. 

recyclables 

124 

2007-
2013 

EUR 
11,700,000 

EUR 11,700,000 
Cohesion Fund  

2007-
2013 

EUR 
22,571,500 

EUR 16,053,700 
the  European  Regional 
Development Fund