COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS EU policy framework on biobased, biodegradable and compostable plastics
Date: 2022-11-30
Institutions: Directorate-General for Environment, European Commission
Subjects: action programme, biodegradability, carbon neutrality, circular economy, plastic waste, plastics, sustainable development, waste recycling

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 30.11.2022  COM(2022) 682 final  COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS EU policy framework on biobased, biodegradable and compostable plastics  
 
 
1.  Introduction 

The  EU’s  transition  to  a  circular,  resource-efficient  and  climate  neutral  economy,  together 
with  the  ambition  to  reach  zero  pollution  and  the  need  to  protect  and  enhance  biodiversity 
have  triggered  an  overall  rethinking  of  how  plastics  are  produced,  used  and  disposed  of. 
Despite efforts made to increase the sustainability and circularity of plastics, in Europe only 
14%  of  plastic  waste  was  recycled  in  2020  domestically,  the  remaining  being  either 
incinerated with energy recovery, landfilled, littered, or exported1. Given this predominantly 
linear model and indications that production is going to double in the next 20 years2, there is 
an  urgent  need  to  improve  the  overall  environmental  sustainability  of  plastics.  However, 
significantly  reducing  greenhouse  gas  (GHG)  emissions,  waste  generation,  littering  and 
plastic pollution presents a complex set of challenges3. 

In  the  search  for  solutions  to  these  challenges,  biobased,  biodegradable  and  compostable 
plastics  are  emerging  in  our  daily  lives  as  alternatives  to  currently  dominant,  conventional 
plastics. They are used in applications such as packaging, which accounts for almost half the 
demand for such plastics, followed by consumer goods and textiles, as well as in sectors like 
agriculture,  transport  and  construction.  Globally,  these  plastics  represent  1%  of  total  plastic 
production capacity, for a volume of over 2 million tonnes per year. Europe hosts a quarter of 
the  production  capacity,  and  Asia  accounts  for  nearly  half.  Their  production  is  expected  to 
grow  faster  than  in  previous  years  and  to  double  their  share  of  total  plastic  production 
capacity by 20254. 

Biobased,  biodegradable  and  compostable  plastics  are  widely  perceived,  in  Europe  and 
internationally, as more environmentally friendly than conventional plastics, which are fossil-
based  and  non-biodegradable.  At  the  same  time,  there  is  increasing  scientific  evidence  and 
awareness that a number of conditions have to be met to ensure that the production and use of 
these  plastics  result  in  overall  positive  environmental  outcomes  and  do  not  exacerbate 
problems  of  plastic  pollution,  climate  change  and  biodiversity  loss.  While  making  plastics 
from  biomass  or  ensuring  that  plastic  products  can  biodegrade  in  some  receiving 
environments  can  bring  a  number  of  benefits  compared  to  conventional  plastics,  these 
solutions  have  their  own  sustainability  challenges  and  trade-offs  that  should  be  well 
understood and duly taken into account. They should also not detract from the need to align 
the lifecycle of plastics with the circular economy and to ensure, as a priority, that resource 
use  is  reduced  in  the  first  place,  that  materials  of  all  feedstocks,  including  biobased 
feedstocks, are kept in the loop for as long as possible, and that secondary raw materials are 
preferred to primary raw materials.  

Though  EU  policies  and  legislation  address  some  aspects  and  applications  of  biobased, 
biodegradable and compostable plastics, it would be better to take a more systemic approach 
to underpin decisions by both the public and private sector. This approach should be based on 

‘Reshaping Plastics’, Systemiq (2022), based on best available academic and industry data. 

1 
2  World Economic Forum, Ellen MacArthur Foundation, and McKinsey & Co., ‘The New Plastics Economy: 

Rethinking the Future of Plastics’ (2016). 

3      Plastics, the circular economy and Europe′s environment — European Environment Agency (europa.eu) 
4  European Bioplastics/nova-Institute Market Update 2021. The EU market share of these plastics is also 1%. 

1 

 
 
                                                           
the  European  Green  Deal5,  the  circular  economy  action  plan6  and  the  EU  plastics  strategy7. 
Furthermore, the zero pollution action plan8 aims to reduce plastic litter at sea by 50%, and 
microplastics  released  into  the  environment  by  30%  by  2030.  The  focus  of  the  EU  soil 
strategy9 is to prevent soil contamination at source. 

These policies foster the following goals, in order of priority: reducing, reusing and recycling 
plastics to minimise the use of energy and resources and keep materials in the economy for as 
long as possible, while pursuing a toxic-free environment.  

A  more  systemic  approach  will  seek  to  strike  a  careful  balance  between  the  need  to  reduce 
dependency on fossil  resources, the impacts  of which are strongly felt in  the current  energy 
crisis  caused  by  Russia’s  brutal  war  on  Ukraine,  and  to  ensure  food  security,  which  is 
impacted by the use of land for biomass production that has to meet competing demands. 

The aim of this policy framework for biobased, biodegradable and compostable plastics is to 
provide better understanding of the  challenges and benefits  that stem  from  their use.  It  also 
sets out the conditions to ensure that overall, the environmental impact of their production and 
consumption is positive. It aims to fill policy  gaps, guide future EU policy or legislation on 
such matters and provide orientation for the market with a view to avoiding any unsustainable 
developments. A common understanding across the EU on the use of these plastic materials 
will also facilitate the single market and prevent differences at national level fragmenting the 
market. 

2.  The concepts: biobased, biodegradable or compostable plastics? 

Referring to plastics as ‘biobased’ points to the raw materials, or feedstock, used for their 
production. While conventional plastics are made from fossil resources (oil and natural gas), 
biobased  plastics  are  made  from  biomass.  The  biomass  currently  originates  mainly  from 
plants  grown  specifically  to  be  used  as  feedstock  to  substitute  fossil  resources,  such  as 
sugarcane, cereal crops, oil crops or non-food sources like wood10. Other sources are organic 
waste and by-products, such as used cooking oil, bagasse and tall oil. Plastics can be fully or 
partially made from biobased feedstock. As shown in the figure below, biobased plastics 
can be both biodegradable and non-biodegradable. 

While conventional plastics do not decompose at the end of their life, plastics referred to as 
‘biodegradable’ are designed to decompose at the end of their life by the conversion of all 
their  organic  constituents  (polymers  and  organic  additives)  mainly  into  carbon  dioxide  and 
water,,  new  microbial  biomass,  mineral  salts  and,  in  the  absence  of  oxygen,  methane11.  For 

5  COM(2019) 640. 
6  COM(2020) 98 final. 
7  COM(2018) 28. 
8  COM(2021) 400. 
9  COM(2021) 699 final. 
10  Renewable Carbon – Biobased Building Blocks and Polymers 
11  Commission’s  Group  of  Chief  Scientific  Advisors,  Biodegradability  of  plastics  in  the  open  environment  | 

European Commission (europa.eu). 

2 

 
 
 
                                                           
that to happen, in addition to the characteristics of the plastic material, suitable conditions in 
the  receiving  environment  and  sufficient  time  are  necessary.  This  is  why  plastic 
biodegradation  must  be  considered  not  only  in  terms  of  the  properties  of  the  material,  but 
above  all  in  terms  of  a  ‘system-property’  where  material-related  and  environment-related 
factors are equally important. As shown below, plastics designed to biodegrade can be both 
biobased and fossil-based. 

‘Compostable  plastics’  are  a  subset  of  biodegradable  plastics  designed  to  biodegrade 
under controlled conditions, typically through industrial composting in special facilities for 
composting  or  anaerobic  digestion.  The  biodegradable  plastics  waste  sent  for  industrial 
composting  first  needs  to  be  collected.  There  is  a  European  standard  for  industrially 
compostable  packaging12  but  not  for  home  composting  as  the  conditions  for  the  latter  can 
differ significantly. 

Figure 1: Alternatives to conventional plastics (Source: European Environmental Agency)13  

Non-biodegradable 

Conventional plastics: 
fossil-based and  
non-biodegradable  

Biobased and  
non- biodegradable 

d
e
s
a
b
o
i
B

d
e
s
a
b
-
l
i
s
s
o
F

Biodegradable  
and fossil-based  

Biodegradable  
and biobased 

  Biodegradable 

3.  Biobased plastics 

The  circular  economy  action  plan  identifies  the  need  to  address  emerging  sustainability 
challenges related to sourcing, labelling and the use of biobased plastics, based on assessing 

12  European standard EN 13432:2000. 
13    Biodegradable and compostable plastics — challenges and opportunities — European Environment Agency 

(europa.eu) 

3 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                           
 
 
where the use of bio-based feedstock results in genuine environmental benefits, going beyond 
reduction  in  using  fossil  resources.  This  means  also  ensuring  that  the  use  of  biobased 
feedstock does not have negative impacts on biodiversity, ecosystems or land and water use. 

The  chemicals  sector  will  continue  to  need  carbon  as  a  feedstock  for  materials  such  as 
plastics. To reduce GHG emissions, the EU circular economy agenda sets out as a priority to 
reduce  the  consumption  of  short-lived  products  and  waste,  and  to  increase  plastic  recycling 
and the use of recycled content to make new products.  

As carbon feedstock will continue to be needed, renewable carbon from sustainably sourced 
biomass is an alternative to fossil carbon. In particular, using organic waste and by-products 
to  produce  biobased  plastics  can  offer  a  partial  decoupling  from  fossil  resources  and  help 
meet climate neutrality targets while also reducing the use of primary biological resources and 
avoiding  harm  to  biodiversity.  The  role  of  sustainably  sourced  biomass  has  also  been 
recognised14  and  there  are  policy  and  market  developments  encouraging  the  increase  of 
biobased  content15.  The  Communication  on  ‘Sustainable  Carbon  Cycles’16  sets  out  the 
aspirational objective that at least 20%17 of the carbon used in chemical and plastic products 
should  be  from  sustainable  non-fossil  resources  to  help  reaching  climate  neutrality.  The 
updated bioeconomy strategy18 emphasises the importance of finding nature-friendly biobased 
solutions. Biobased plastics can also  stimulate the creation of jobs,  especially  by increasing 
the  role  of  primary  producers  in  local  bioeconomies.  To  ensure  such  positive  impact,  the 
biobased  plastic  industry  will  need  skilled  labour  force.  To  that  end,  the  European  Skills 
Agenda19 helps to operate a shift in skill sets to reap full potential. 

3.1 Biobased plastic content 

There is currently no mandatory minimum biobased content nor agreed certification scheme 
or  label  for  a  plastic  product  to  be  labelled  as  biobased.  The  crosscutting  standards 
developed  by  the  European  Technical  Committee  for  Standardisation  for  biobased 
products  (CEN/TC411)  offer  guidance  on  aspects  such  as  measuring  methods  of  biobased 
content,  business-to-business  and  business-to-consumer  communication.  These  voluntary 
standards are widely used by the market and their application is recommended as it ensures 
a consistent approach. 

To fight greenwashing and avoid misleading consumers, generic claims on plastic products 
such as  ‘bioplastics’ and ‘biobased’ should not be made. The Commission’s proposal  on 
empowering consumers for the green transition20 puts forward a ban on such practices unless 

14  European Commission study on ‘Biobased plastics: sustainable sourcing and content’ (2022). Link to come. 
15  The Dutch government plans to increase the percentage of recycled and biobased plastics to 41% and 15% 
respectively by 2030 and is currently looking at mandatory targets. As a pre-requisite for support, biobased 
plastics  must  meet  sustainability  criteria  including  sustainable  agricultural  production  and  a  30%  CO2 
emission  reduction.  Mandatory  percentage  of  recycled  or  bio-based  plastic.  In  the  European  Union  -  CE 
Delft - EN 
16  COM(2021) 800. 
17   Current level is 10%. The part used to make plastics is 1 to 2%. 
18  COM(2018) 673. 
19   https://ec.europa.eu/social/BlobServlet?docId=22832&langId=en 
20  Proposal for a Directive on Empowering Consumers for the green transition. 

4 

 
 
                                                           
they  are  underpinned  by  recognised  excellent  environmental  performance  or  whenever  the 
specification of the claim is not provided in clear and prominent terms on the same medium. 
In  order  to  avoid  misleading  consumers,  claims  should  only  refer  to  the  exact  and 
measurable share of biobased plastic content in the product, stating for instance, that the 
‘product contains 50% biobased plastic content’. 

It  is  also  important  to  ensure  that  biobased  content  is  measured  precisely.  Radiocarbon-
based  methods21  should  be  preferred  as  their  results  are  robust  and  their  use  is  widely 
accepted. Documenting the use of biomass through a chain of custody and attributing a share 
to end-products through mass balance accounting is a method which is not considered suitable 
for confirming the actual share of biobased content. Such method should be used only when it 
ensures  a  high  level  of  transparency  and  accountability,  and  is  underpinned  by  agreed 
standards to avoid greenwashing. 

3.2 Feedstock sustainability 

In most cases, the production of biomass requires the use of natural resources such as land and 
water and the use of chemicals such as fertilisers and pesticides. Therefore, producing plastics 
from primary biomass can lead to direct or indirect land-use change, which in turn can result 
in  biodiversity  loss,  ecosystem  degradation,  deforestation  and  water  scarcity,  as  well  as 
competition with crops intended for human consumption. 

 In line with the circular economy principles, producers should prioritise the use of organic 
waste  and  by-products  as  feedstock,  by  thus  minimising  the  use  of  primary  biomass  and 
avoiding significant environmental impacts. 

When  primary  biomass  is  used,  it  is  important  to  ensure  that  it  is  environmentally 
sustainable  and  does  not  harm  biodiversity  or  ecosystem  health.  As  consumers  expect 
biobased plastics to be genuinely sustainable, whenever a product is made of biobased content 
and carries a claim on biobased content, the content must originate from sustainably sourced 
biomass. 

In line with the EU forest strategy for 2030, as  part of the review of the Renewable Energy 
Directive  (REDIII)  of  July  202122,  the  Commission  proposes  to  integrate  in  national 
supporting  schemes  the  cascading  use  of  biomass  principle,  according  to  which  biomass 
should be used where it has higher economic added value. In line with this principle, biomass 
should  be  preferably  used  to  produce  materials,  including  plastics,  and  only  in 
subsidiary order, as a source of bioenergy.  

Furthermore,  priority  should  be  given  to  long-lived  products  over  short-lived  products, 
including  single-use  products.  This  priority  order  applies  to  waste,  to  by-products  and  to 
primary  biomass  coming,  for  instance,  from  agriculture,  forestry  or  aquaculture.  Organic 

21   These methods use 14C as a marker for biobased carbon content. 
22  Proposal  for  a  Directive  amending  Directive  (EU)  2018/2001 on  promotion  of  energy  from  renewable 

sources 

5 

 
 
                                                           
waste  and  by-products  should  be  preferred  over  primary  biomass,  especially  for  short-lived 
products. 

Biomass used to produce biobased plastics must meet the EU sustainability criteria for 
bioenergy23.  As  proposed  by  the  Commission  under  the  review  of  the  Renewable  Energy 
Directive (REDIII) of July 2021, these criteria include measures related to forest biomass and 
to biofuels with high risk of direct and indirect land-use change, such as those derived from 
palm oil24. Pending finalisation of REDIII  negotiations, the REDII  sustainability  criteria for 
bioenergy  should  be  applied.  This  is  also  the  approach  taken  in  the  EU  Taxonomy  for 
sustainable  investments  for  "agricultural  biomass  used  for  the  manufacture  of  plastics  in  its 
primary form”25. 

With  regard  to  greenhouse  gas  emissions,  the  bioenergy  framework  cannot  be  directly 
applied  to  biobased  plastics  as  these  are  not  used  to  generate  energy.  Methodologies  to 
assess  the  impacts  of  biobased  plastics  compared  to  fossil-based  plastics  from  a  life-cycle 
perspective  are  still  under  development.  The  most  harmonised  methodology  currently 
available is the framework developed by the Commission’s Joint Research Centre, referred to 
as the ‘Plastics LCA method’26, which builds upon the EU Product Environmental Footprint 
(PEF)  method27.  Moreover,  innovations  should  be  assessed  at  an  early  stage  to  ensure  the 
development of safe and sustainable alternatives28.  

Further scientific advancement is  needed to  incorporate in  the assessment the accounting of 
biogenic  carbon  uptake  and  release  from  products  during  their  lifespan.  Discussions  to  this 
end  are  ongoing  in  the  context  of  the  UN  Life  Cycle  Initiative29.  Only  biobased  plastic 
products with long lifetime  that are not incinerated when they become waste can have 
beneficial  carbon  storage  effects.  For  short-lived  products,  i.e.  most  of  today’s  biobased 
plastic  products  such  as  single-use  packaging,  the  carbon  initially  taken  up  from  the 
atmosphere is quickly released back. 

4.  Biodegradable and compostable plastics 

23   Except for GHG emissions. 
24  Renewable Energy Directive 
25  https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32021R2139 
26  The Commission’s JRC’s Life Cycle  Assessment of alternative feedstock for plastics production. Whether 
the  impacts of biobased plastics compared to those of conventional ones  turned out  to  be higher or lower 
depended on the application, the polymer, the feedstock, the reference material, the manufacturing process 
and  the  specific  environmental  impact  category  considered.  Generally,  methodological  challenges  to 
calculate impacts from biomass sourcing include indirect land-use changes, biotic resource-depletion effects, 
biodiversity  impacts,  end-of-life  aspects,  comparison  of  new  biobased  technologies  with  well-established, 
conventional ones and, finally, data sources. 

27     Commission Recommendation on the use of the Environmental Footprint methods. 
28   On such purpose, the JRC has recently published a framework for the assessment of Safe and Sustainable by 
Design  chemical  and  materials,  and  is  developing  guidelines  to  support  the  environmental  assessment  of 
early  stage  technologies  for  biobased  products.  Joint  Research  Centre,  Prospective  LCA  for  Novel  and 
Emerging Technologies for BIO-based products 

29  Home - Life Cycle Initiative 

6 

 
 
 
                                                           
The circular  economy  action  plan highlights  the  need to  give policy  direction  on the use of 
biodegradable or compostable plastics, based on an assessment of the applications where such 
use  can  be  beneficial  to  the  environment,  and  of  the  criteria  for  such  applications.  It  also 
underlines  the  need  to  ensure  that  labelling  a  product  as  ‘biodegradable’  or  ‘compostable’ 
does not mislead consumers and does not encourage them to dispose of it in a way that causes 
plastic  littering  or  pollution  due  to  unsuitable  environmental  conditions  or  insufficient  time 
for degradation. 

Biodegradation is indeed an important characteristic of plastics as it determines whether they 
will  persist  and  accumulate  in  the  environment,  breaking  down  to  smaller  and  smaller 
fragments,  microplastics  and  nanoplastics,  and  become  an  increasing  source  of  pollution, 
harmful to human health and the environment. Biodegradable plastics are not likely to persist 
and  accumulate  provided  that  they  decompose  fully  in  the  receiving  environment  they  are 
intended  for  and  do  not  spill  into  an  environment  where  they  cannot  biodegrade.  This  can 
happen,  for  instance,  if  a  plastic  which  is  biodegradable  in  soil  is  transferred  by  wind  or 
runoff from soil into riverine or marine waters. The timescale for biodegradation must also be 
short  enough  not  to  harm  ecosystems  and  marine  life,  for  instance  through  ingestion  by 
marine animals. 

Plastics biodegradation is an area that has received considerable attention in terms of research 
and  innovation.  It  is  increasingly  subject  to  policy  measures  designed  to  ensure  that 
biodegradable plastics do not cause harm, that they do bring environmental benefits and that 
consumers  are  not  given  the  impression  that  biodegradable  plastics  can  be  littered.  The 
Directive  on  the  reduction  of  the  impact  of  certain  plastic  products  on  the  environment30 
includes in its scope plastic products made of biodegradable plastics because if these products 
are  littered,  there  is  no  guarantee  that  they  can  biodegrade  in  the  open  environment.  In 
addition,  it  bans  oxo-degradable  plastics  as  they  fail  to  deliver  a  proven  environmental 
benefit,  do  not  biodegrade  completely,  and  have  a  negative  impact  on  the  recycling  of 
conventional plastic. 

The  Fertilising  Products  Regulation31  states  that  by  16 July  2026,  coating  agents  and 
formulation  additives  must  meet  set  biodegradability  criteria.  It  also  requires  assessing  the 
ability  of  agricultural  mulch  films  to  biodegrade  in  natural  soil  conditions  and  aquatic 
environments  across  the  EU.  Furthermore,  the  proposed  restriction  on  intentionally  added 
microplastics  under  REACH32  exempts  biodegradable  polymers  if  they  meet  specific 
biodegradability  criteria,  proven  either  according  to  one  of  three  test  method  groups  with 
stringent  screening  tests  measuring  ready  biodegradation  or  inherent  biodegradation,  or 
according  to  simulation  studies  where  biodegradability  criteria  should  be  met  in  three 
environmental  compartments  of  water,  soil  and  sediment  (or  two,  for  agricultural  and 
horticultural uses). Concerning polymers, including biodegradable ones, as announced in the 

30  EUR-Lex - 32019L0904 - EN - EUR-Lex (europa.eu) 
31  EUR-Lex  -  02019R1009-20220716  -  EN  -  EUR-Lex  (europa.eu).  In  the  absence  of  such  criteria,  an  EU 

fertilising product placed on the market after that date shall not contain such polymers. 

32  Commission’s restriction proposal on intentionally added microplastics. 

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EU chemicals strategy for sustainability33, the Commission is considering extending the duty 
of  registration  to  certain  polymers  of  concern  in  the  context  of  the  targeted  revision  of 
REACH.  

4.1 Biodegradable plastics 

To  provide  further  guidance  to  policy  development,  the  Commission  tasked  its  Group  of 
Chief Scientific Advisors to assess the biodegradability of plastics in the open environment. 
Their  opinion34  highlights  the  need  to  limit  the  use  of  biodegradable  plastics  in  the  open 
environment  only  to  specific  applications  for  which  reduction,  reuse  or  recycling  are  not 
feasible. Furthermore, it emphasises that such plastics should not be considered as a solution 
for  inappropriate  waste  management  or  littering.  To  realise  the  potential  environmental 
benefits  of  biodegradable  plastics  over  non-biodegradable  plastics,  the  Group  recommends 
supporting  the  development  of  coherent  testing  and  certification  standards.  It  also  identifies 
the need to promote accurate information on the properties, appropriate use and disposal, and 
the  limitations  of  biodegradable  plastics  and  their  applications  to  specific  user  groups.  The 
opinion  issued by the Group  identifies  the material properties, the environment the material 
ends up in, the likelihood of spilling into other environments, and the behaviour of consumers 
as important factors. 

In light of these considerations, as a first principle for the purposes of designing new plastics 
or  for  developing  policy  measures,  biodegradation  must  be  regarded  as  a  ‘system 
property’ that takes  into account  material  properties,  specific environmental conditions  and 
risks. 

Secondly, the use of plastics that biodegrade in the open environment must be limited to 
materials  for  which  full  bio-degradability  has  proven  to  be  below  a  specific  and  evidence-
based  timeframe  to  avoid  environmental  harm,  and  to  specific  applications  where 
consumption reduction or reuse are not viable options and where the full removal, collection 
and recycling of plastic products is not feasible. As biodegradable plastics are predominantly 
used in relatively short-lived applications such as food and beverage packaging, the resources 
used  to  produce  these  products  are  rapidly  lost.  Substituting  conventional  plastics  by 
biodegradable  plastics  risks  slowing  down  the  development  of  circular  economy  solutions 
based on reducing waste and reuse of such products. It also risks disincentivising designs to 
recycle plastics to keep materials in the loop for as long as possible, as well as the use of more 
sustainable  alternatives  that  do  not  contain  plastics.  Therefore,  substitutions  should  not be 
considered as a solution for inappropriate waste management or littering. 

Mulch  films  used  in  agriculture  are  good  examples  of  suitable  applications  of  plastics 
that biodegrade in the open environment, provided that they are certified compliant against 
appropriate  standards.  For  this  purpose,  the  Commission  will  request  the  revision  of  the 
existing  European  standard35  with  the  view  to  taking  into  account,  in  particular,  the  risk  of 

33  The EU’s Chemical Strategy 
34  Biodegradability of plastics in the open environment | European Commission (europa.eu) 
35   European standard EN 17033:2018 

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plastic  residues  that  biodegrade  in  soil  entering  water  systems36.  For  other  applications  of 
biodegradable plastics to be considered suitable, such as dolly ropes used in fishery, products 
used  for  tree  protection,  plant  fixing  clips  or  lawn  trimmer  threads,  new  standards  on  test 
methods should be developed. 

36      Issues  for  improvement  are  the  practice  of  tilling,  not  always  followed  by  growers,  the  variety  of  EU 
agricultural environments and occurrence and risks of runoff, and the presence of hazardous biodegradable and 
non-biodegradable additives. 

9 

 
 
 
                                                           
Example box: Mulch films 

Conventional  –  fossil-based  and  non-biodegradable  –  plastics  are  widely  used  to  promote 
higher  yields,  earlier  harvests,  less  reliance  on  herbicides  and  pesticides,  to  protect  against 
frost  and  to  conserve  water.  But  proper  management  of  these  plastics  in  agriculture  at  their 
end  of  life  is  problematic.  In  2019,  only  around  63%  of  agri-plastic  (non-packaging)  waste 
generated in the EU was collected, while the destination of the remaining 37% is unknown – 
either  stored,  burnt,  buried  or  collected  with  other  waste.  Despite  their  high  potential  for 
recycling,  only  24%  of  agri-plastic  plastics  placed  on  the  market  every  year  in  the  EU  is 
currently recycled. If mulch films are not removed or not completely, which cannot be always 
ensured,  they  release  plastics  that  accumulate  in  soils,  fragment  into  microplastics  or  are 
spread by wind or runoff. Mindful that soil plastic pollution is  difficult to reverse, certified 
biodegradable mulch films can offer a beneficial alternative. Farmers have a direct interest 
in maintaining soil health and can be expected to check the labelling and instructions on how 
to use and dispose of these products correctly. Non-biodegradable plastics should be removed, 
collected  and  recycled.  Member  States  can  help  by  setting  up  relevant  Extended  Product 
Responsibility systems. 

Consistent  and  science-based  testing  and  certification  standards  for  biodegradation  of 
plastic  in  the  open  environment  are  essential  for  these  limited  applications  where 
biodegradable  plastics  could  be  useful.  Biodegradation  tests  are  generally  conducted  in 
artificial  environments  to  ensure  the  testing  conditions  are  replicable,  but  there  is  a  need  to 
observe the processes occurring in natural environments under real conditions37. Standards are 
particularly  challenging  to  develop  for  biodegradation  in  the  marine  environment,  as 
biodegradation  at  the  bottom  of  the  ocean  is  unlikely  due  to  the  specificities  of  the  marine 
environment38.  The  Commission  has  been  tasked  with  carrying  out  an  assessment  of  the 
scientific and technical progress concerning possible criteria or a standard for biodegradability 
in the marine environment under the Single-Use Plastics Directive 39. 

Further  challenges  are  presented  by  additives  that  are  used  for  the  manufacturing  of 
biodegradable  plastics,  which  should  equally  biodegrade.  With  regard  to  the  complex 
chemical  mixture contained in  plastics, including additives, and their  toxicity,  a comparison 
with  conventional  plastics  indicates  that  biodegradable  plastics  can  be  similarly  toxic40. 
Moreover, biodegradable plastics can release these additives directly to the environment and 
do  so  quicker  than  conventional  plastics41.  Additives  used  to  manufacture  biodegradable 
or  compostable  plastics  should  biodegrade  safely  and  not  be  harmful  for  the 
environment. They should also be disclosed to retailers, users and the public. 

37   Haider et al. 2018. 
38   Biodegradation depends on a combination of abiotic (UV, temperature, moisture, pH) and biotic processes 

and parameters (microbial activity), often not present in the deep sea. 

39  EUR-Lex - 32019L0904 - EN - EUR-Lex (europa.eu) 
40  Zimmermann L., Dombrowski A., Völker C. & Wagner M. (2020) Are bioplastics and plant-based materials 
safer than conventional plastics? In vitro toxicity and chemical composition. Environment International. 
41   Meng Qin et al. (2021) A review of biodegradable plastics to biodegradable microplastics: another ecological 
threat to soil environments? Journal of Cleaner Production. 

10 

 
 
                                                           
Thirdly,  consumer  or  user  behaviour  concerning  biodegradable  plastics  is  another  key  area 
that requires a careful approach. In order to avoid misleading consumers, plastics labelled as 
‘biodegradable’ must always specify the receiving open environment for which they are 
intended  and  the  required  timeframe  for  their  biodegradation,  in  terms  of  weeks, 
months  or  years.  The  indicated  timeframe  should  ensure  that  environmental  impacts  are 
minimal. Such claims should be based on existing standards or certification schemes.  

Claims,  including  in  the  form  of  labels,  should  not  be  made  on  the  biodegradation  of 
litter-prone products, including products covered by the Single-Use Plastics Directive. 

4.2 Industrially compostable plastics 

Although the framework rules to ensure the overall environmental benefits of biodegradable 
plastics also apply to compostable plastics, these materials require additional attention given 
the specificities of composting. Consumers often play a key role in channelling these plastics 
to controlled waste treatment systems. 

Industrially compostable plastics should only be used for specific applications when the 
environmental benefits are higher than their alternatives and when they do not have a negative 
impact  on  the  quality  of  the  compost,  taking  into  account  consumer  behaviour.  In  addition, 
there  needs  to  be  a  compatible  biowaste  collection  and  treatment  system  in  place.  The 
potential benefits  of using industrially compostable plastics are  higher biowaste capture and 
lower contamination of compost by non-biodegradable plastics. Compost of a higher quality 
is more beneficial for use as organic fertiliser in agriculture and does not become a source of 
plastics pollution in soils and groundwater. 

Industrially  compostable  plastic  bags  for  the  separate  collection  of  biowaste  are  a 
beneficial  application.  These  bags  can  reduce  the  plastics  pollution  of  compost  as 
conventional plastic bags, including fragments that remain even after action to remove them, 
are  a  contamination  problem  in  current  biowaste  treatment  systems  in  use  throughout  the 
EU42. As of 31 December 2023, biowaste must be separately collected or recycled at source43, 
and  the  introduction  of  industrially  compostable  plastic  bags  for  the  separate  collection  of 
biowaste  in  countries  such  as  Italy  and  Spain  has  led  to  less  pollution  in  biowaste  and 
increased capture of biowaste. However, not all Member States or regions support the use of 
such  bags  as  specific  composting  methods  are  required  and  cross-contamination  of  waste 
streams may occur.  

Examples of suitable applications in packaging are fruit and vegetable stickers, tea bags 
and filter coffee pods, as well as very light plastic carrier bags although alternatives with 
no packaging or  reusable  alternatives  are to  be  preferred. Where both  conventional  and 
compostable  plastics  are  available  on  the  market  for  similar  applications,  consumers 
increasingly lack clarity on how to properly dispose of compostable plastic packaging44. The 

42  European  Commission  study  on  ‘Relevance  of  compostable  plastic  products  and  packaging  in  a  circular 

economy’ (2020). Bio-based, biodegradable and compostable plastics (europa.eu) 

43  EUR-Lex - 02008L0098-20180705 - EN - EUR-Lex (europa.eu) 
44  European  Commission  study  on  ‘Relevance  of  compostable  plastic  products  and  packaging  in  a  circular 

economy’ (2020). Bio-based, biodegradable and compostable plastics (europa.eu) 

11 

 
 
                                                           
resulting  cross-contamination  of  conventional  and  compostable  plastic  packaging  waste 
reduces  the  quality  of  resulting  secondary  raw  materials  and  should  be  prevented  at  source. 
Therefore,  the  Commission  proposal  for  a  Packaging  and  Packaging  Waste  Regulation45 
mandates the use of compostable plastic packaging for these products and foresees that other 
packaging,  including  packaging  made  of  biodegradable  plastic  polymers,  has  to  allow  for 
material recycling without affecting the recyclability of other waste streams. Under the new 
rules, the Commission is empowered to amend this list in light of technological and regulatory 
developments  that  affect  the  disposal  of  compostable  plastics  and  provided  that  the  use  of 
such materials is beneficial to environmental and human health. 

To address consumer confusion, the use of labels does not help sufficiently, as they may not 
always  work  as  intended46.  In  order  to  avoid  misleading  consumers,  only  certified 
industrially  compostable  plastics  should  be  qualified  as  ‘compostable’  and  it  should 
always be specified that they are intended for industrial composting. 

Industrially  compostable  packaging  should  display  the  way  in  which  they  should  be 
disposed  of  using  pictograms,  as  proposed  by  the  Commission  in  its  proposal  for  a 
Packaging  and  Packaging  Waste  Regulation47.  Rather  than  simply  raising  awareness, 
information campaigns should seek to promote effective and correct disposal action. 

Industrially  compostable  packaging  should  be  certified  compliant  against  appropriate 
standards.  For  this  purpose,  the  Commission  will  request  the  revision  of  the  existing 
European  standard48  with  a  view  to  clarifying  the  concepts  of  biodegradability  and 
compostability;  reflecting  the  current  industrial  composting  conditions  in  EU  biowaste 
treatment  facilities,  addressing  the  presence  of  toxic  or  adverse  effects  on  the  environment; 
and addressing the product as a whole, including additives. 

Home  composting  is  more  challenging  in  terms  of  ensuring  full  biodegradation  of 
compostable plastics and requires a greater degree of precaution. Compliance with standards 
for  industrial  composting  does  not  imply  decomposition  also  under  home  composting.  In 
industrial  composting,  the  required  conditions  are  often  high  temperatures  (55°C-60°C)  and 
high humidity levels. In home composting, the required conditions very much depend on local 
climate  circumstances  and  consumer  practices,  biodegradation  risks  to  be  slower  than  in 
industrial  composting  or  uncompleted,  and  results  are  often  closer  to  biodegradation  in  the 
open environment than to industrial  composting. Home  composting for plastics not  covered 
by EU rules should  only be  considered in  the context  of specific local  conditions  under the 
supervision  of  the  relevant  authorities  and  provided  that  the  use  of  such  plastics  has  clear 
added value.  

5.  Continued support for research, innovation and investment 

45  COM(2022)677 final. 
46  SAPEA  Evidence  Review  Report  on  ‘Biodegradability  of  plastics  in  the  open  environment’,  Chapter  6 
‘Social, behavioural and policy aspects’. Influencing factors include lack of understanding,  complexity and 
proliferation  of  labels  as  well  as  waste  infrastructure-related  factors  (e.g.  availability  and  proximity  of 
enabling waste infrastructure). 

47  COM(2022)677 final. 
48   European standard EN 13432:2000 

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EU-funded  programmes  already  support  research  and  innovation  related  to  biobased, 
biodegradable and compostable plastics. The objectives focus on ensuring the environmental 
sustainability of the sourcing and production processes and of the use and disposal of the final 
products. 

The  Commission  will  promote  research  and  innovation  with  the  aim  of  designing 
circular  biobased  plastics  that  are  safe  and  sustainable  by  design  and  that  allow  for 
reusability,  recyclability  and  biodegradability.  This  includes  assessing  the  benefits  of 
applications  where  biobased  materials  and  products  are  both  biodegradable  and  recyclable. 
More work is also needed to assess and reduce the net greenhouse gas emissions of biobased 
plastics  compared  to  their  fossil-based  equivalents,  taking  into  account  the  lifetime  of 
application and the possibility of multiple recycling49.  

Biodegradation  processes  need  to  be  further  explored.  This  includes  work  to  ensure  that 
biobased plastics for agricultural and other uses can biodegrade safely, taking in account the 
possible transfer to  other environments,  biodegradation timeframes  and long-term effects.  It 
also includes work to minimise any negative effects, including long-term effects, of additives 
used  in  biodegradable  and  plastic  products.  Among  the  range  of  potential  non-packaging 
applications for compostable plastics, absorbent hygienic products merit particular attention. 
Research  is  also  needed  into  consumer  behaviour  and  the  claims  of  biodegradability  as  a 
factor that may have an influence on littering behaviour. 

6.  International aspects 

Plastics  are  part  of  integrated,  global  value  chains.  Decisions  and  strategic  guidance  on 
biobased,  biodegradable  and  compostable  plastics  in  international  and  multilateral  fora  and 
non-EU  countries  will  have  a  significant  impact  on  the  EU’s  ability  to  fully  implement  its 
policy objectives and on the impact of identified measures on the ground. 

The Commission will pursue the objectives of this communication, while taking into account 
the views of the EU Member States, the Council and the European Parliament, in discussions 
under relevant  existing multilateral environmental agreements such as the Basel Convention 
on hazardous waste and their disposal; negotiations of legally binding instruments on plastic 
pollution,  in  particular  those  initiated  by  the  UNEA  Resolution  5/14;  discussions  in  the 
context of the WTO, including the WTO Dialogue on Plastics Pollution and Environmentally 
Sustainable Plastics Trade, and future free trade agreements to be concluded or enhanced by 
the EU; as well as dialogues  and cooperation with  non-EU  countries. The Commission  will 
also  strengthen  the  EU’s  approach  to  international  standardisation  on  these  plastics,  which 
will help to achieve consistent standards at global level. 

49   ETC/WMGE  Report  3/2021:  Greenhouse  gas  emissions  and  natural  capital  implications  of  plastics 

(including biobased plastics) — Eionet Portal (europa.eu) 

13 

 
 
 
 
                                                           
Conclusion 

Many  new  plastic  materials  are  emerging  on  the  market.  Biobased,  biodegradable  and 
compostable plastics can bring advantages over conventional ones if designed for circularity, 
produced  safely  and  from  sustainably  sourced  feedstock,  prioritising  the  efficient  use  of 
secondary  biomass,  and  compliant  with  relevant  standards.  However,  these  plastics  also 
present  challenges.  It  is  important  to  ensure  that  they  contribute  to  the  circular  economy, 
which aims to keep the value of resources, materials and products in the economy for as long 
as possible and to avoid waste. 

The aim of this policy framework is to bring clarity and understanding of these plastics and to 
guide  future  policy  developments  at  EU  level  such  as  under  ecodesign  requirements  for 
sustainable  products50,  the  EU  Taxonomy  for  sustainable  investments,  funding  programmes 
and related discussions in international fora.  

The Commission encourages citizens, public authorities and businesses to use this framework 
in their policy, investment or purchasing decisions. 

50  Ecodesign for sustainable products | European Commission (europa.eu) 

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