Renewable Carbon Initiative sees Packaging and Packaging Waste Directive revision as central

In Belgium, on-going revision of the Packaging and Packaging Waste Directive is a central element of a wide variety of Green Deal objectives, such as climate neutrality, mobilizing industry for a clean and circular economy or the zero pollution ambition that offers opportunities to increase the ambitions for sustainable plastic packaging. As an organization, the Renewable Carbon Initiative argues that the inclusion of bio-based and CO2-based content as equal to recycled content would be an important step in the right direction. This “renewable content” quota will reduce the plastic packaging sector’s dependence on virgin fossil resources, which is an important step towards climate neutrality. Furthermore, opening the recyclate quota to include other renewable materials would offer flexibility to the industry and relax tight markets without compromising climate and circular economy ambitions. We are glad to note that this option is being discussed in earnest by the Commission stakeholders and offer our support in terms of providing evidence and strategic discussions.

The policy framework on bio-based, biodegradable and compostable plastics under the Circular Economy Package is expected to be published in November 2022 and is intended to provide support to these plastics where they offer true environmental benefits. RCI answered the comprehensive expert questionnaire, arguing for a well-balanced policy that treats innovative bio-based plastics fairly, while not forgetting recycled and CCU-based materials as equally positive options for de-fossilization. We are convinced that sustainability requirements for bio-based materials should be comparable to the rules set down in the Renewable Energy Directive for biofuels, of course with some adaptations where necessary and that they need to be paired with corresponding supportive measures (the same as for biofuels). The consultation also asked for input on the well-known and often discussed question of whether there should be a minimum bio-based content – such as 30% or 50% – before a product may be labelled as bio-based. We argue against a default minimum value, but suggest instead that any producer, who wants to label their product as bio-based, should be obligated to mention a certified bio-based content share on the said product. This will automatically lead to producers only labelling bio-based products if they can show a convincingly high bio-based content. For biodegradable products, we are proposing that any policy framework should only support those applications that cannot be effectively collected and recycled, or those whose use enables secondary benefits, such as higher collection of organic waste.