Interview with Hasso von Pogrell, Managing Director at European Bioplastics, on PPWR Design for Recycling for biodegradable plastics
Q. European Bioplastics has long advocated integrating biobased and biodegradable materials into EU policy frameworks. From your perspective, how does the current draft of the PPWR reflect (or fall short of) that ambition?
A. Obviously, this question requires a differentiated approach. For biobased plastics packaging, the Packaging and Packaging Waste Regulation (PPWR) foresees in Art. 8 for the Commission to, among others, present within the next three years a legislative proposal in order to lay down sustainability requirements for biobased feedstock in plastic packaging based on Art. 29 of the RED. While European Bioplastics (EUBP) supports this approach in general, we request that the future sustainability requirements adequately reflect the situation specific to bioplastics, which is far more complicated than that for biofuels. For one, biofuels are heavily subsidised, therefore meriting a considerable GHG emission reduction target vis-à-vis fossil fuels. Biobased plastics demonstrating GHG emissions equal to or lower than their conventional counterparts should be deemed environmentally superior and, therefore, their uptake incentivised.
Furthermore, the Commission shall assess the possibility of using biobased plastic feedstock instead of recycled content recovered from post-consumer waste to achieve the recycled content targets for plastic packaging set out in Art. 7(1) and (2) in the PPWR if suitable recycling techniques for food-contact packaging are unavailable. EUBP would have appreciated a less restrictive approach where biobased and recycled content targets would have received the same or, at least, similar support.
As regards biodegradable and compostable plastic packaging, the PPWR falls short of adequately supporting compostable plastic packaging by limiting the applications to be mandatorily compostable across the EU Member States (MS) to tea bags, coffee pads, and fruit stickers only (Art. 9(1) of the PPWR). While MS with adequate biowaste infrastructure in place may extend the mandatory compostability requirement on their territory also to non-metal coffee capsules and lightweight and very lightweight carrier bags (Art. 9(2a)), the list of applications meriting to be mandatorily compostable goes well beyond the ones listed above, as many other applications that are likely to be contaminated with food waste after use will have little to no chance of ever being materially recycled.
Q. One of the PPWR’s key pillars is “design for recycling.” How does European Bioplastics view the compatibility of biodegradable plastic packaging with this principle? Are we facing a contradiction or a complementary pathway?
A. Art. 9(3) of the PPWR foresees that all other (biodegradable) packaging not referred to in Art. 9(1) and (2) shall be designed for material recycling. This means that many packaging applications initially intended and designed for organic recycling – for the very reason that they would otherwise not be recycled and end up in landfill or incineration – will now have to be (re-) designed for material recycling. While material recycling for biodegradable packaging per se is, in most cases, technically feasible, and existing sorting technologies can efficiently separate them, their low volumes on the market provide little incentive for sorters and recyclers to allocate dedicated sorting lines for biodegradable packaging in their facilities.
Q. In what types of packaging applications do biodegradable plastics provide a real added value in terms of end-of-life performance? How do you see these applications fitting into the broader recyclability goals under PPWR?
A. All packaging that is prone to be contaminated with food waste after use, and especially small flexible applications that are currently sorted out and regularly end up in the mixed waste fraction of sorting and recycling facilities, provide an immense added value when designed to be industrially compostable as they facilitate the collection of biowaste without endangering the quality of the biowaste stream, which otherwise is prone to be contaminated with non-biodegradable packaging. Not using their value proposition by forcing them to become material recyclable ignores the relevance and benefits of organic recycling. Organic recycling, however, contrary to popular belief, is a form of recycling equivalent to mechanical and chemical (material) recycling, as Art. 3 of the Waste Framework Directive (WFD) clearly stipulates. Biodegradable packaging is unique in that it has several end-of-life options.
Q. What are the current barriers to effectively integrating compostable packaging into EU-wide collection and treatment systems? What needs to happen—at policy, industry, and municipal levels—for compostable packaging to scale responsibly?
A. One issue is that composters allege that compostable packaging may not disintegrate and biodegrade quickly enough in their facilities. However, this fear is unfounded, as certified compostable products on the market are usually 10 to 20 times thinner than they could be to still pass the requirements of the standard EN 13432. Therefore, these products will biodegrade perfectly well even in facilities that run on much shorter cycles than foreseen in the standard.
Another is the fact that it’s nearly impossible for the naked eye to distinguish compostable from non-compostable packaging. Therefore, many composters fear that non-compostable packaging may end up in their waste stream alongside compostable packaging. This problem would best be overcome by extending the list of packaging to be mandatorily certified compostable across the European Union. This would significantly reduce the risk of misthrows and contamination of the biowaste with non-compostable packaging. The effectiveness of such measures is well proven and documented in Italy, where non-compostable lightweight and very lightweight carrier bags are banned. This has led to extremely low contamination rates of the biowaste streams with non-compostable bags in Italy and should, therefore, serve as a benchmark for the European Union.
Q. There’s a lot of confusion around biodegradability versus compostability, especially in public and policy discourse. What is European Bioplastics doing to clarify these distinctions, and what would you like to see from policymakers in that regard?
A. Strictly speaking, compostability is a sub-category of biodegradability. Formulated pointedly, biodegradability per se doesn’t really mean anything. At the end of the day, everything is biodegradable – even though it may take a few million years to degrade completely. Compostability, on the other hand, is a property attributed to a material or application that completely disintegrates and biodegrades in a limited time frame under specific controlled conditions. This is why standards and certifications exist for compostability but not for biodegradability.
As EUBP, we strongly advocate for the certification of compostability according to recognised and well-established standards like EN 13432 for industrial compostability and object to anyone claiming their product to be biodegradable without any further specification as to in which environment and in which time frame. Any such claims should be backed by independent third-party certification. We encourage consumers to look for trusted certification labels, such as the seedling logo or the OK compost mark, indicating that a product meets strict requirements for industrial or home compostability. These labels are a reliable guide for environmentally conscious purchasing decisions and help prevent waste sorting and disposal confusion.
Q. What role do you see for collaboration across sectors—waste managers, municipalities, brands, and consumers—in ensuring that biodegradable packaging is both effective and responsibly used?
A. Collaboration across sectors is critical to making biodegradable packaging effective and responsibly used. Waste managers, municipalities, brands, and consumers play a role, but it only works when those efforts align. Waste managers must be equipped to process these materials properly. Municipalities help by setting policies and investing in the proper infrastructure. Brands have a responsibility to design packaging that fits existing waste systems and to clearly communicate disposal instructions. And consumers need simple, consistent guidance to make the right choices.
Thank you, Hasso, for this interview.
