The proposed plastics strategy, together with the accompanying policy papers, is an important part of the EU Circular Economy policy and signals the commitment of the European Union to address and act on issues that are increasingly a concern for European citizens.
Fortum supports the vision and the expressed political target to ensure that by 2030 all plastic packaging is recyclable and more than half of the plastic waste that is generated in Europe is recycled. It is important that all actors commit to the target. From that perspective, we find the strategy to be well defined as it covers all relevant issues and actors connected to the plastics economy. The dynamics of plastic recycling, its potential and obstacles, opportunities and challenges are also well described in the strategy.
From landfilling to recycling
Fortum agrees that some kind of incentives might be needed in order to achieve high recycling targets for mixed and low-quality plastic waste. The main objective should be to prevent the landfilling of plastics because landfilling is a major cause of littering, microplastics and the leaching of harmful substances. Therefore, in order to prevent low-quality and possibly also contaminated plastics from causing environmental problems, the role of such plastic waste as a fuel for energy production should be recognised.
Fortum welcomes the proposed end-of-waste criteria information exchange in the Interface Communication. Unfortunately, this important element has not been adequately recognised in the plastics strategy. Introducing EU-wide end-of-waste criteria for each of the most common types of plastic would create common markets of recycled plastics both in the EU and on the global market. The global goal should be a responsible, resource-effective, value-creating and safe circularity of plastics, and the EU should be the forerunner towards this goal.
Decontamination procedure should be strengthened
It is important to acknowledge the clear link between the proposed plastics strategy and policy papers that have been presented earlier. For example, a study by the EU Commission, published in autumn 2017, concerning a non-toxic environment1 contains measures that are vitally important when proceeding with implementation of the plastics strategy, especially in the recycling and re-use of plastics. Plastic waste can contain unwanted substances, which have to be removed and destroyed in order to keep the circulating plastics clean and safe. Unfortunately, the recently adopted Council position on the EU Waste Directive lacks a proper decontamination procedure. A lack of confidence in the safety of recycled plastic raw materials can have a negative impact on the demand and willingness to use recycled plastic.
EU to take a strong role in saving the oceans
The strategy rightly recognises the importance of international actions to curb plastic waste and plastic littering in the oceans, and the need for environmentally sound waste management in developing countries and economies. Innovative technologies targeting preventive measures and supported by EU funds are mentioned, and Fortum supports these actions. We also underline the need to close the worst dumpsites that still exist, as well as to eliminate the dumping of waste into waterways and seas.
In summary, Fortum regards the following issues as key development points when moving forward with concrete measures to implement the political vision of the EU Plastics Strategy:
The coherence between the objectives of the plastics strategy and other targets relating to the EU circular economy initiative should be ensured.
More emphasis should be put on the decontamination of plastic cycles. The EU should establish a clear definition of decontamination, including decontamination of material cycles.
Common end-of-waste criteria should be developed for certain types of plastic in order to create a common market of recycled plastics.
Measures are needed to change consumer patterns and attitudes towards recycling and the re-use of plastic. At the same time, the recyclability of products should be improved.
Waste-to-energy should be recognised as an important element in plastic waste management and in preventing littering.
Strict restrictions are needed to prevent the landfilling of plastic waste, and support is needed for international efforts to close dumpsites and develop proper waste management systems.
Instead of putting a tax on plastic (as has been mentioned as one option), the focus should be placed on developing incentives to get as much of the plastics as possible into recycling (e.g. through a deposit system).
EU R&D funding should be channeled to efforts to innovate new applications for recycled plastic materials.
On 17 January 2018, the European Commission released a Communication on the European Plastics Strategy together with two accompanying documents dealing with 1) options to address the interface between chemical, product and waste legislation in the context of the circular economy, and 2) a monitoring framework for the circular economy. This package dealing with plastics is part of the broader EU policy initiative dealing with the Circular Economy.
Study for the strategy for a non-toxic environment of the 7th Environment Action Programme, Final Report, August 2017
Fortum´s view on waste hierarchy in a safe Circular Economy