Summary report EU Plastics Strategy

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1 Summary report EU Plastics Strategy April The EU Plastics Strategy was released by the European Commission on 16 January. The Strategy contains over 50 actions. The toy sector has not been singled-out as a priority for further actions, but some of the actions can have an impact on the sector. This report provides an overview of the most important actions for the toy sector and recommends action for TIE and members. Commissioner Vella (Environment): The Commission does not intend to focus on a single product (plastics toys), rather the Plastics Strategy presents a vision for a smart, innovative and sustainable plastics industry, with reuse and recycling activities integrated into production chains to bring growth, jobs and added value to the EU. The strategy places a strong emphasis on increasing recycling and builds on the proposal already made as regards waste management. Therefore, follow-up actions will focus on production and design of plastics and plastics products and the market for recycled plastics. The key initiatives of the Strategy include: All plastics packaging in the EU will need to be recyclable by 2030; Restrict/ban intentional addition of microplastics in products Legislative proposal to curb single-use plastics consumption The European Parliament and Council are now working on their reaction to the Plastics Strategy, which will further shape future actions from the Commission. TIE is monitoring those activities to be able to react in case toys are specifically addressed.

2 Key messaging The sector s responses can be grouped around the following: Strict safety requirements: o Strict chemical limits in Toy Safety Directive (TSD) and other legislation e.g. REACH make it difficult to use recycled plastics (constant, compliant supply of materials) o Toys should not be easily tared apart. This can bring difficulties when recycling. The complexity of plastic materials in toys prevents it often from being recycled Durability is important: Toys often have a second life of re-use, passing to relatives and friends, or through a charity or resale. Their average lifetime + 10 years (TIE Brandface study) Toys not a key waste stream: o toy waste is 0.21% of household waste (TIE Valpak Study) o the estimation is that 17.5% of all toys do not enter the waste stream (TIE Brandface Study) Toys packaging not a key waste stream: In the UK, the amount of plastic packaging believed to be used in the household but not recycled is 1,058,000 tonnes, toy waste is only 3% of this, and only 2% of the total consumer plastic packaging waste generate (TIE Valpak Study) Good practices: TIE collecting good practices from members The remainder of this report addresses the most important next steps under the plastics strategy for the toy sector: European Parliament position Environment Council position Issue 1: Packaging: Revision of Packaging & Packaging Waste Directive Issue 2: Single Use Plastics legislative initiative Issue 3: Restrict intentional addition of microplastics Issue 4; Industry pledges Issue 5: Interface Chemical, Waste & Product rules Issue 6: Quality standard for recycled plastics Issue 7: New eco-design measures Issue 8: EU Plastics tax List of all actions included in the Plastics Strategy

3 European Parliament 27 March: draft ENVI report 9 July: ENVI Committee vote Monitoring (TIE) National associations: none 3 May: Deadline for amendments 3 September: EP Plenary Vote The Parliament s Environment Committee is leading on the file. The Rapporteur Mark Demesmaeker (ECR Belgium) released his draft report on 27 March and provided broad support for the Commission s approach. It suggests that the Commission s ambitious recycling targets for packaging should be achieved through voluntary business initiatives. The rapporteur also specifically opposes the introduction of an EU-wide plastics tax. Council Member States have so far welcomed the Plastics Strategy. 19 February: Presidency background document 25 June: Council conclusions Monitoring (TIE) National associations: none 5 March: Environment Council exchange of view All Ministers welcomed the Commission package and called for an urgent implementation of concrete measures, in particular to increase the recycling of plastics, find solutions to the widespread use of single-use plastic and to find a holistic approach to the value chain of plastic production. In their exchange of views, ministers mentioned several other possible actions to be taken at EU or at national levels: campaigns for raising consumer awareness increasing the quality of recycled products through setting standards green public procurement the use of the rules on Extended Producer Responsibility (EPR), similar to the one which was agreed recently in the waste package

4 Issue 1: Packaging - Revision of the Packaging and Packaging Waste Directive Goal: Ensure that by 2030 all plastics packaging placed on the EU market can be reused or recycled in a cost-effective manner (now 40.9%) Mid-- Launch study by Commission - monitor possible contact with consultant 2020: Commisison proposal 2022 (?) entry into force - standard development - involvement standardisation process Mid Development of legal proposal - more extensive contact with Commisison + Member States Legislative process - outreach EP & Council Policy options: Design requirements to enable recycling, to address: Designs confusing consumer not to separate waste Plastic components in packaging that are difficult to separate manually from other materials Coloured plastic materials that are difficult to separate in sorting plants Plastics made of uncommon materials and for which no automatic sorting is foreseen in most of the sorting plants Compound materials, such as multi-layer materials or multi material materials Presence of incompatible materials in the same waste stream (e.g. different types of PET) Thin PET foils and semi-rigid PET foils Incentives to stimulate uptake of recycled content Requirements against over packaging Prioritize different components (TIE PSEC Committee) Compile best practices from members (TIE national associations) Remain in close contact with packaging value chain (TIE) + recyclers Monitor Commission activities + contracted consultant (TIE) Keep abreast of any national development + possible national outreach 2019 (National Associations) Key Arguments: Toy packaging not a major contributor to waste: Retail packaging around toys is 0.16% of all packaging, across the EU28. Over 90 % of this packaging is paper based, which is already recycled at around 80% (Valpak Study) Best practices: Initiatives from toy companies + national associations

5 Issue 2: Legislative initiative on single-use plastics Goal: Significant reduction of the environmental damage/ health impacts caused by littering by Single Use Plastics (SUP) Indicative list: Product Packaging: drinking bottles Food containers Disposable cups Crisps packets and sweets wrappers Caps and lids Straws and stirrers Cotton buds Disposable cutlery Cigarette butts, Sanitary towels Balloons Requirements considered (subject to change) Improve collection rate in existing collection schemes / minimum design requirements Reduction targets, design requirements (materials, design lids and caps in a way they cannot be detached from bottle ), charge at point of sale Awareness campaigns, EPR schemes, labelling requirements (mass-release) At the moment, the Commisison is focussing most of its work on a proposal on Single Use Plastics, It is expected to address a closed list of Toys are not included in the product list, but balloons could be included. If included, the Commission foresees soft meassures for balloons, like information/labelling requirements or public awareness campaigns. Commisision preparation - monitoring May - March 2019: European Parliament & Council - monitoring 16 May : European Commisison legislative proposal Monitor (TIE) National associations: none Key messages: - Toys no key concern for (marine) littering (EU Plastics Strategy, JRC study)

6 Issue 3: Restrict the intentional addition of microplastics to products Definition microplastics: synthetic, water-insoluble polymer items smaller than 5 mm Objective: ban/restrict intentionally added microplastic particles. The potential impact of microplastics on the (aquatic) environment and human health have generated concerns ECHA Consultation: 11 May Restriction proposal: January 2019 ECHA work Impact: TIE is currently collecting information from TIE members on which products could be affected It seems members could have products using microplastics, with no substitutes available. Suggested actions: Information gathering (PSEC) Submission of response to consultation (TIE) National associations: investigate with members on impact Key messages / product specific: No release to environment Required for certain functionalities Socio-economic impact

7 Issue 4: Launching an EU-wide pledging campaign targeting industry and public authorities The European Commission calls on stakeholders to come forward with voluntary pledges to boost the uptake of recycled plastics. Goals 10 million tonnes must find their way to new products by 2025 June - industry pledges 2025: 10 million tonnes recycled plastics used in new products on the EU market October - Commisison publication of pledges To divert pressure on mandatory requirements for uptake of recycled materials, the Commission is pursuing voluntary approach with pledges from business sectors. The focus is on 4 largest plastic consuming sectors: Packaging Building & Construction Automotive Electronics For toy sector: Individual company commitments are possible: o Toys: pledge on uptake recycled materials difficult to combine with requirements TSD but possible pledge could address recyclability o Packaging: possibility for toy companies to make commitments TIE to promote possibility of pledges and relevant procedures within membership

8 Issue 5: Interface between chemical, product and waste legislation Goal two-fold: enabling recycling and improving the uptake of secondary raw materials substituting substances of concern How? address bottlenecks in chemicals, products and waste legislation Jan : Communication on interface : Council and possibly EP position - monitor 2020: Possible changes to Chemical, Waste or Product (incl. toys) rules April/May : 3 months Public Consultation - respond Studies monitor Final outcomes very unclear, could include: Different requirements for recycled products; Information system/traceability on substances of concern Following Communication, Commission looks at: Public consultation to be launched soon Other EU institutions view Studies on: o Traceability/information system on substances of concern o Member States' practices on end-of-waste status Recommended action: Monitor studies, Council, EP (TIE) Respond to public consultation (TIE/PSEC) National associations: none Key messages, so far Toy specific requirements difficult to take-up recycled material Low level of substances of concern in toys due to TSD requirements but need for effective enforcement Diverging requirements on recycling, make it difficult to inform/empower consumers

9 Issue 6: Development of quality standards for sorted plastics waste and recycled plastics The European Commission will ask CEN to develop standards for recycled plastics and sorted plastic waste Through such standards, manufacturers might be able to identify suitable streams of recycled materials including for toys The standardization request to CEN is currently pending. This request will provide a budget and mandate to CEN to develop such a standard : budget + mandate to CEN applicability /2022 (?) Development standard Monitor (TIE) National associations: none Key messages Sector needs such a standard to use recycled materials

10 Issue 7: New eco-design measures New requirements for electrical and electronic products to support the recyclability of plastics Ongoing: update on product categories already covered - monitor 2020: possibly new product categories End-/early 2019: COM work on work programme post monitor State of play: Ecodesign=Requirements on energy efficiency, reparability, durability, recyclability. Implemented for specific products At the moment, 24 product categories are included, such as TVs, vacuum cleaners, computers. Toys not included and not targeted for Toys can be included if: Scope of current product groups change (e.g. products covered by requirements for computers, requirements for screens instead of for TVs) New product categories are identified for the next Ecodesign work Programme post-2020 Key requirements plastics strategy could push for: Easy dismantling to facilitate recycling Minimum recycled content requirements (e.g. 5% has been proposed for printers) Monitor (TIE) National associations: none Key arguments exclusion toys: Toys not identified as high energy saving potential product category (previous Ecodesign work programs) Safety first dismantling requirements can be in conflict with safety requirements TSD Safety first recycled content in toys can be in conflict with chemical requirements TSD

11 Issue 8: EU-Plastics tax To provide EU with own resources To curb-down on use of plastics Commission cabinet level debates - ongoing Need for approval EP + unanimity member states - lobby policy makers 29 May : Commission proposal on EU Multi-annual financial framework 2020: entry into force Would be part of EU budget proposal for after 2020 (Multi-Financial Framework): requires unanimous support from Member States Several options: EU tax on plastic production EU tax on (specific) plastic products EU tax on Single Use Plastics.. Now: Monitoring (TIE) Contact with Plastics Europe (TIE) Outreach if included in proposal after May (TIE, National Associations) Key messages Plastic required for certain functionalities, durability (need to consider re-use and durability) Toys low source of waste Valpak figures Need to protect buying power of families + promotion of play

12 List of Actions Plastics Strategy (highlighted in yellow = included in this report) Improving the economics and quality of plastics recycling Actions to improve product design: Preparatory work for future revision of the Packaging and Packaging Waste Directive: Commission to initiate work on new harmonised rules to ensure that by 2030 all plastics packaging placed on the EU market can be reused or recycled in a cost-effective manner. new eco-design measures: consider requirements to support the recyclability of plastics Q1 ongoing follow-up to COM () 32 "Communication on the implementation of the circular economy package: options to address the interface between chemical, product and waste legislation": improve the traceability of chemicals and address the issue of legacy substances in recycled streams Actions to boost recycled content: launching an EU-wide pledging campaign targeting industry and public authorities Q1-Q3 development of quality standards for sorted plastics waste and recycled plastics in cooperation with the European Standardisation Committee assessment of regulatory or economic incentives for the uptake of recycled Q1 content, in particular in the context of the: Revision of the Packaging and Packaging Waste Directive (see above) Evaluation/review of the Construction Products Regulation Evaluation/review of End-of-life Vehicles Directive as regards food-contact materials: swift finalisation of pending authorisation ongoing procedures for plastics recycling processes, better characterisation of contaminants and introduction of monitoring system Actions to improve separate collection of plastic waste: issue new guidelines on separate collection and sorting of waste 2019 ensure better implementation of existing obligations on separate collection, Curbing plastic waste and littering Actions to reduce single-use plastics: analytical work, including the launch of a public consultation, to determine the ongoing scope of a legislative initiative on single-use plastics Actions to tackle sea-based sources of marine litter adoption of a legislative proposal on port reception facilities for the delivery of waste from ships ongoing development of measures to limit plastic loss from aquaculture (e.g. possible Best Available Techniques Reference Document) development of measures to reduce loss or abandonment at sea of fishing gear Q1 (e.g. including recycling targets, EPR schemes, recycling funds or deposit schemes) Actions to monitor and curb marine litter more effectively: Q1

13 improved monitoring and mapping of marine litter, including microplastics, on the basis of EU harmonised methods support to Member States on the implementation of their programmes of measures on marine litter under the Marine Strategy Framework Directive, including the link with their waste/litter management plans under the Waste Framework Directive Actions on compostable and biodegradable plastics: start work to develop harmonised rules on defining and labelling compostable and biodegradable plastics Q1 start the process to restrict the use of oxo-plastics via REACH conduct a lifecycle assessment to identify conditions where their use is beneficial, Q1 and criteria for such application Actions to curb microplastics pollution: start the process to restrict the intentional addition of microplastics to products ongoing development of measures to reduce plastic pellet spillage (e.g. certification scheme via REACH along the plastic supply chain and/or Best Available Techniques reference document under the Industrial Emissions Directive) examination of policy options for reducing unintentional release of microplastics from tyres, textiles and paint (e.g. including minimum requirements for tyre design (tyre abrasion and durability if appropriate) and/or information requirement (including labelling if appropriate), methods to assess microplastic losses from textiles and tyres, combined with information (including possibly labelling)/minimum requirements, targeted research and development funding) ongoing evaluation of the Urban Waste Water Treatment Directive: assessing effectiveness as regards microplastics capture and removal Driving investment and innovation towards circular solutions Actions to promote investment and innovation in the value chain: Commission guidance on the eco-modulation of EPR fees 2019 direct financial support for infrastructure and innovation through the European ongoing Fund for Strategic Investment and other EU funding instruments (e.g. structural funds and smart specialisation strategies, Horizon 2020) Recommendations by the recently launched Circular Economy Finance Support Platform in mid- pursue work on life-cycle impacts of alternative feedstocks for plastics production examine the feasibility of a private-led investment fund to finance investments in innovative solutions and new technologies aimed at reducing the environmental impacts of primary plastic production project to reduce plastic waste and marine litter in East and South-East Asia to support sustainable consumption and production, the promotion of the waste hierarchy and extended producer responsibility, and improve recovery of fishing gear By mid Harnessing global action Actions focusing on key regions: development of a Strategic Research Innovation Agenda on plastics to guide future funding decisions ongoing Q1 ongoing Q2 cooperation on plastic waste prevention in major world river basins

14 examining options for specific action to reduce plastic pollution in the Mediterranean, in support of the implementation of the Barcelona Convention Actions in support of multilateral initiatives on plastic: renewed engagement on plastics and marine litter in fora such as the UN, G7, G20, the MARPOL convention and regional sea conventions, including the development of practical tools and specific action on fishing and aquaculture. support to action under the Basel Convention, particularly for the implementation of the toolkit on environmentally sound waste management Actions relating to bilateral cooperation with non-eu countries: promote a circular plastics economy in non-eu countries through policy dialogues on trade, industry and environment, as well as economic diplomacy use bilateral, regional and thematic funding in EU development, neighbourhood and enlargement policies to support the plastics strategy by preventing and appropriately managing waste and supporting the circular economy; through programmes and instruments including Switch to Green and the External Investment Plan Actions relating to international trade: support the development of international industry standards on sorted plastic waste and recycled plastics support the development of a certification scheme for recycling plants in the EU and in third countries ensure that exported plastic waste is dealt with appropriately in line with the EU Waste Shipment Regulation Additional action Proposal EU-wide plastics tax May

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