EXPAND THE CRITERIA FOR CIRCULARITY

Regenerative solutions offer many benefits for the environment and society. They use natural materials that can restore ecosystems, prevent pollution and reduce resource consumption. 

To support these solutions, we need policies and guidance on sustainability and circularity criteria of packaging products to include impact indicators that account for the advantages of non-plastic substitutes. Current circularity guidelines still focus on minimising impacts of plastic products and do not support the switch to non-plastic substitutes. We call for the following sustainability and circularity criteria for design and production of products across their life cycle:

1. No forever waste: Environmental advantages of natural polymers based products throughout the life cycle of the products, especially at their end-of-life.
2. Regenerative biomass: Sustainability credentials with input materials deriving from responsibly sourced biomass and renewable resources such as seaweeds and plants.
3. Health: No harm to humans and other living organisms.
4. Low production footprint (GHG emissions, energy demand): Deriving existing natural polymers with energy efficient processes, avoiding high-impact polymerisation processes.

These indicators will help to level the playing field for natural polymers and other non-plastic substitutes, which are often disadvantaged by the current policies and regulations that favour conventional plastics. By using a holistic approach, we can encourage solutions that are circular and regenerative by design.

Natural polymers are regenerative materials that can be organically recycled (composted or anaerobically digested) at the end of their life cycle, producing compost/ digestate and biogas. Both options are nearly carbon neutral and compatible with existing infrastructure that is used to deal with food waste.

However, the current waste hierarchy does not always acknowledge these benefits, and may favour chemical recycling of plastics over natural polymers. Chemical recycling is a process that converts plastics into their basic components, which can then be used to make new plastics or other products. However, this process is not sustainable, as it consumes a lot of energy and resources, and may emit harmful substances or greenhouse gases. 

Moreover, it does not solve the root problem of plastic pollution, which is the excessive production and consumption of plastic products. Therefore, we should prioritise non-plastic substitutes that avoid and reduce the production of plastics over chemical recycling of plastics.

We urge the recognition of the advantages of natural polymers end-of-life scenarios (such as organic recycling) in the waste hierarchy, to ensure that they are not ranked lower than conventional materials such as the resource intensive chemical recycling of plastics.

We acknowledge the growing public scepticism towards biodegradability due to the misuse of the terms biodegradable and compostable for synthetic polymers such as PLA and PVA which do not truly biodegrade but only fragment into smaller pieces. We also recognise that the current compostability certification schemes are not trustworthy or effective, as they favour materials that degrade faster rather than those that return to nature. We therefore call on policy makers to adopt stricter and more consistent standards based on the model of the ILT in the Netherlands.