03 June 2021

Definitions for recycled plastics must be legally binding and decided democratically, not set by companies – ECOS letter to European Commission

By Fanny Rateau

In May 2021, ECOS, Zero Waste Europe and the Rethink Plastic alliance sent a letter calling on the European Commission to put on hold the development of overarching standards on plastics recyclability until related EU laws are adopted. Going ahead with this standardisation process now would give companies the opportunity to set the ambition of definitions of recyclability-related terms, potentially weakening effective recyclability rates in Europe for the years to come.

There is still time: the European Commission plans to issue a standardisation request to CEN and CENELEC in September 2021, aiming to set definitions, test and calculation methods for a wide range of terms regarding plastics recycling and recycled plastics. This will impact a number of crucial sectors such as packaging, buildings and construction, electronics, agriculture and automotive.

The planned standardisation request is currently set to contain a very long list of definitions and methods dominated by proposals put forward by the industry’s Circular Plastics Alliance (CPA), focusing primarily on industry needs, without sufficient consideration for long-term EU policy goals or ongoing legislative processes.

However, several similar technical terms are to be established soon in EU legislation, as part of the upcoming revised essential requirements for packaging waste, and the implementing measures relating to the uptake of recycled content. These specifications include, for instance, the official EU method to count, verify and report the recycled content of beverage bottles, which is being developed under the Single-Use Plastics Directive. This particular method will be key to ensure that companies do not take advantage of methodological loopholes and comply with EU recycling goals.

If industry-led definitions for recyclability are set in standards before they are defined in laws, future legislative efforts could be effectively halted or even watered down, with important practical consequences in making recycling targets less reliable

This could, for example, happen for the packaging sector, where the regulation clearly states that all plastic packaging should be recyclable or reusable by default as from 2030. The Commission is currently deciding how to define recyclability and reusability, to make sure there are no loopholes. It is crucial that the development of standards does not compete with the policy process: it should rather aim to support it as effectively as possible.

Once technical terms are set in legislation, standards can be a powerful tool in support of legislation to improve the recyclability of plastic materials even further. For example, they could provide homogeneous packaging specifications, thus boosting recyclate quality and making it easier to effectively introduce old plastics into new products.

Together with Zero Waste Europe and the Rethink Plastic alliance we voiced our concerns in a letter sent to the European Commission officials on 26 May. We requested the suspension of the standardisation process until the ongoing efforts to establish recyclability and reusability definitions are decided by democratically elected policymakers in the European Parliament and the EU Council.

ECOS is co-funded by the European Commission and EFTA

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