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Document 52018AR0925

Opinion of the European Committee of the Regions — Communication on a European Strategy for Plastics in a circular economy

COR 2018/00925

OJ C 461, 21.12.2018, p. 30–36 (BG, ES, CS, DA, DE, ET, EL, EN, FR, HR, IT, LV, LT, HU, MT, NL, PL, PT, RO, SK, SL, FI, SV)



Official Journal of the European Union

C 461/30

Opinion of the European Committee of the Regions — Communication on a European Strategy for Plastics in a circular economy

(2018/C 461/05)


André VAN DE NADORT (NL/PES), mayor of the municipality of Weststellingwerf

Reference document:

Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions on A European Strategy for Plastics in a Circular Economy

COM(2018) 28 final



A.   General remarks

The Committee of the Regions:


Welcomes the European Commission’s Communication on a European Strategy for Plastics in a circular economy, and the challenges and key actions identified, and stresses that ambition is needed to make the transition towards a circular economy and to tackle the societal and environmental challenges and practical issues relating to plastics. Takes note in this context of the legislative proposals by the European Commission to target the ten single-use plastic products found most often on EU beaches and in EU seas which, together with abandoned fishing gear, constitute 70 % of all marine litter.


Recognises that plastics — being a highly durable, hygienic and inexpensive material — have a number of benefits, but is deeply concerned about the current low collection and recycling rates for plastics and believes that current practices to tackle this challenge are focussed too much on end-of-pipe solutions (collection, sorting, processing).


Stresses the key role and interest of local and regional authorities in the development and implementation of solutions for plastics in a circular economy. The responsibilities of local and regional authorities (LRAs) concern waste management and environmental protection: including elements such as waste prevention, collection, transport, recovery (including sorting, reuse and recycling), disposal and cleaning up litter, in streets, on coasts, in lakes and in the sea, supporting fisheries and tourism and building awareness about waste, littering and recycling matters among their citizens.


Focusses on the circular future of plastics from a local and regional perspective. This means less plastics, better plastics, better collection, better recycling and better markets.


Strongly believes that better cooperation and a material-chain approach between all stakeholders in the plastics value chain are essential for effective solutions. The measures must target all links in the value chain, including product design, plastics manufacturing, procurement, consumption, collection and recycling.


Emphasises the role of innovation and investment towards circular solutions in promoting the social and behavioural changes needed for the transition to a circular economy as a crucial step towards implementing the UN Sustainable Development Goals at EU, national, regional and local level; asks therefore the European Commission and the EU Member States, during their negotiations on the next MFF, to fully explore options for an increase in EU funding for the circular plastics economy.

B.   Less plastics

Prevention is the first priority to reduce plastic waste


Points out that plastic waste prevention should be the first priority in line with the overall EU waste hierarchy. Plastic that does not end up as waste will not need sorting, processing or incineration. Waste prevention starts with limiting the use of plastics, and through product design.


Recalls that there are many ways to avoid the unnecessary use of plastics in single-use products and the over-packaging of products. The essential criteria for packaging need to be strengthened in order to prevent unnecessary packaging and over-packaging and to regularly verify whether key products on the EU market fulfil these criteria.


Requests further research on the relation between packaging and food preservation on a life-cycle basis and possible alternative approaches to prevent food waste without the use of (complex) plastic packaging.

Prevention of litter and plastic soup and decrease of single-use products


Underlines the major concern about plastic litter: cleaning up has a high cost for LRAs and prevention of littering, both on land and at sea, is therefore essential.


Supports the European Commission’s initiative for a legislative proposal on single-use plastics, proposing objectives limiting the use of single-use plastics, since most of the plastic litter on our streets originates from single-use plastics. In this regard, takes the recent proposals focussing on the most wide-spread single-used products on beaches and in the sea as an important first step, but expects further ambitious action to address also littering by other single-use plastic items and on land.


Expects ambitious collection targets for single-use and on-the-go plastic applications covered by an extended producer responsibility (EPR) system, for example, plastic beverage packaging to be part of the producer responsibility in order to curb litter.


Stresses that producers and importers have full responsibility for the negative impact of their products when they become litter, and that they must therefore take full responsibility for the cost for collection and treatment of the littering of their waste.


Highlights the various difficulties of specific communities and regions of the EU, i.e. Outermost Regions, river communities, islands, coastal and harbour communities in the fight against marine litter and stresses the particular importance of involving stakeholders from these communities to ensure that their voices are taken into account in finding positive and practically applicable solutions.


Supports the organisation of awareness-raising campaigns on littering and clean up actions; promotes the participation of local and regional authorities (LRA) in events such as the ‘Let’s Clean Up Europe’ campaign and the European Week for Waste Reduction and encourages LRA to come up with additional initiatives and explores the possibilities of involving volunteers through the European Solidarity Corps.


Strongly supports against this background the principle included in the proposal for a Directive of the European Parliament and of the Council on port reception facilities for the delivery of waste from ships (COM(2018) 33) that the fees for the use of port reception facilities shall be reduced if the ship’s design, equipment and operation are such that the ship produces reduced quantities of waste, and manages its waste in a sustainable and environmentally sound manner.

Prevention of microplastics


Highlights that microplastics are an increasingly widespread and problematic phenomenon, which by now can be found in nearly any part of every ecosystem including the human diet. The effects of microplastics on animal and human health and on our ecosystems are to a large extent still unknown.


Advocates further research into the major sources and routes of microplastics, such as wear and tear from car tyres, textiles and litter, including the relation between plastics recycling and microplastics and the effects of microplastics on animal and human health and ecosystems. Therefore also emphasises the need to establish reliable and effective measuring technology and processes, and calls on the European Commission to support research and development activities for this matter.


Calls for a ban on oxo-degradable plastics and intentionally added microplastics in all products where they are not necessary from a human health point of view, including skin-care products and cleaning agents. The CoR also calls for minimum requirements on the release of unintentional microplastics from products such as car tyres and textiles, and on measures to reduce plastic pellet losses.

C.   Better plastics

Better design of plastics


Strongly believes that there is an urgent need for a better design of plastics, taking into account the possibilities for future separate collection, sorting and recycling of plastics and plastic products in order for plastics to become a sustainable element in the circular economy, and underlines that there is a strong need for innovation in this area.


Emphasises that in a circular economy, we should in principle not accept non-recyclable products or materials to be put on the EU market. Therefore by 2025 all plastics, plastic products and plastic packaging, placed on the EU market, should as a minimum be recyclable in a cost-effective manner. This also requires that environmentally harmful and hazardous substances should be completely removed from plastics and plastic products by 2025.


Underlines that a circular economy is also a fossil-free economy. Therefore a strong innovation agenda and subsequent support for the large scale roll-out of fossil-free plastics is needed in order to move from the current fossil-based plastics to innovative, sustainable and environment-friendly plastics.


Is convinced that it is necessary to limit the number of different polymers available when making plastic products to polymers which are fit for purpose and easy to separate, sort and recycle, especially for single-use products. EU-level industry standards for these applications may have to be developed for this purpose.


Requests further study into the need for harmonisation and possible limitation of additives used in plastics to influence and enhance the physical properties of plastics, in order to further ease and simplify the recycling of plastics and the application of recyclates. EU-level industrial standards for additives in plastics may have to be developed for this purpose.


Moreover, takes the view that plastic products other than packaging are also liable to create litter and should therefore be designed to avoid this, and also that producers must provide for the necessary systems to dispose of these products at the end of their useful life.


Recalls that Extended Producer Responsibility (EPR) schemes can play an important role in promoting eco-design, with a modulation of fees according to the level of circularity of the product, including the possibilities for reuse, separate collection, processing and recycling and on the amount of recycled content. EPR legislation therefore needs to include the responsibility for eco-design. EPR legislation should also refer to EU-level industrial standards for the use of polymers and additives in single-use products.


Stresses that it will be important, over the coming decades, to develop materials that do not have the negative impact on health and the environment that all plastics currently have and that can fully replace plastics. The Committee therefore calls for research activities and instruments that can create momentum towards a plastic-free future with new modern materials.

Biodegradable plastics


Recognises that the current generation of biodegradable plastics is not an answer to the problem of plastic litter and plastic soup as they do not biodegrade in a natural environment or in water systems.


Underlines that for consumers the message that some plastics should be separated as plastic and others as bio-waste, is confusing. This makes the communication to consumers complex and leads to mistakes in the separation of both conventional plastics and biodegradable plastics.


Emphasises that biodegradable plastics that end up in the plastics recycling stream hinder the recycling of conventional plastics. Therefore the use of biodegradable plastics should be limited to applications where biodegradability has a specific purpose, e.g. the use of biodegradable bags for the collection of bio-waste.


Stresses the need for better definitions and/or standards for the different forms of biodegradability. They should be linked to waste treatment, including standards for compostability and digestibility and take into account common practice in European treatment facilities. This will improve and/or simplify labelling, reduce littering and improve correct sorting, and it will also encourage the innovation of biodegradable plastics.


Particularly stresses the importance of ensuring that plastics marketed as being compostable do in fact break down in the environment without requiring industrial composting. This kind of definition can significantly reduce the risk of the spread of microplastics, as there is a risk that consumers may erroneously believe that compostable plastics as currently labelled can break down in the environment with no additional processing.

D.   Better collection


Emphasises that effective systems for separate collection of plastic waste are an essential requirement for a circular economy of plastics. For this purpose, collection systems have to be simple and logical for their users.


Highlights that existing collection systems in EU Member States usually do not target non-packaging plastics which are therefore not separately collected and end up in landfills or incineration plants as a part of residual waste, or even as (marine) litter. This leads to environmental damage, the loss of valuable recyclable materials and to confusion amongst consumers who do not understand why some plastics should be separated for recycling and other plastics not. Better information campaigns and greater consistency between Member States in the rationale of separate waste collection would increase both the amount recycled and the compliance of locals and tourists alike with guidance on separation.


Recognises that in those situations where the collection of plastics and plastic products is based on EPR, effective targets have to be set in such a way that producers are incentivised to go beyond the targets whenever possible.

Effective separate collection of plastics


Invites the Commission to involve all stakeholders including those active in waste prevention and management of non-plastic materials, to improve separate collection.


Stresses that the focus in the collection systems should be on plastics as a material rather than plastics as a packaging product. This would significantly simplify consumer communication and lead to an increase in collection rates. Improved alignment between LRA and EPR schemes would be necessary to address non-packaging plastic waste during dialogue with producers and importers. This also needs to be taken into account in the revision of the Packaging and Packaging Waste Directive.


Welcomes the preparation of guidelines on separate collection and sorting of waste and asks the European Commission to ensure that LRAs are involved in the process of preparation and dissemination of the guidelines considering the important role they have in many Member States.


Emphasises that local and regional waste management strategies should focus on the waste hierarchy, i.e. waste prevention, separate collection and minimisation of residual waste. There are many good examples and experiences of this kind of strategy. Innovation in separate collection should be stimulated and the exchange of best practices and knowledge between LRA should be strongly supported, e.g. through instruments such as the TAIEX peer-to-peer tool or the EU Urban Agenda.


Stresses the need to prevent China’s ban on plastic leading to more landfill, (illegal) dumping, or incineration and in addition the need to invest in modern recycling capacities.

Public awareness and behavioural change


Stresses that for the development of successful waste management strategies, the EC, Member States and LRAs have to be aware of the linkages at local and regional level between infrastructure, communication and public perception and the instruments that can be applied to support behavioural change.


Underlines that the public awareness of citizens of waste management is a precondition for the proper functioning of effective collection systems. Public awareness translates into support for separate collection and prevention, and organisation of local initiatives, but by itself it does not necessarily lead to behavioural change. Better understanding of the mechanisms that can contribute to positive behavioural change is therefore essential. The CoR therefore stresses that the further development of strategies to encourage behavioural change both through classical means such as incentives and sanctions, and through innovative methods should be stimulated and the exchange of best practices and knowledge between LRA should be strongly supported.


Encourages all local and regional stakeholders to contribute to increase awareness of the advantages of recycled plastics.

The use of a harmonised deposit system for beverage packaging should be considered on a European scale


Acknowledges that deposit systems have proven to achieve very high collection rates and high quality recycling and are also very effective in preventing litter and plastic soup.


Recognises that an increasing number of EU countries implement deposit systems, causing sometimes negative cross-border effects in regions with different deposit systems.


Suggests that a harmonised approach at EU level or at least a maximum of coordination should be considered for those Member States which currently implement deposit systems or which are planning to develop new schemes in the future, in order to prevent negative cross-border impacts and facilitate free movement of goods.

Alternatives to quantitative targets should be explored


Notes that targets related to separate collection and recycling of plastics in different EU Directives (Packaging and Packaging Waste, ELV Directive, WEEE Directive) are equal for all Member States, although the actual performance of Member States may differ greatly. This leads to a situation where some Member States still have to make a great effort where others already easily achieve targets and have no incentive to exceed targets.


Urges that the target-setting in the various directives should be re-examined in order to create stronger incentives and encourage a higher quality of recycling based on the following possible approaches:

introduction of a bonus when targets are exceeded,

expansion of the financial responsibility of producers to the full cost of waste management of their products, including the cost of cleaning up litter or the cost of collection and treatment of their products that have not been separately collected and still end up in residual waste.

E.   Better recycling

Development of sorting and recycling technology


Strongly supports research and innovation with regard to new sorting and recycling technologies, including depolymerisation. This could, theoretically, solve many of the current issues related to plastics sorting and recycling.


Emphasises the potential of regions and cities to develop and support bottom-up initiatives through living labs, innovation hubs, and other forms of collaborative and innovative approaches to promote smart design and the use of secondary raw materials.


Supports the proposed additional investment for priority research and innovation actions in the Strategy and offers to cooperate with the European Commission on the preparation of the new Strategic Research and Innovation Agenda on plastics. Such cooperation should ensure that the local and regional dimension is taken into account both in the identification of the priority problems to be tackled and in the adequate dissemination of innovations produced.


Supports the work to develop quality standards for sorted plastic waste and recycled plastics.

Energy recovery is preferable to landfill


Recalls that in the short term, unrecyclable plastic waste, or plastic waste which contains hazardous substances, should be treated in the most effective and cleanest waste-to-energy plants where the high energy content of plastic waste can be utilised to generate heat and power.

F.   Better markets

The uptake of recycled content in new products should be strongly encouraged


Strongly believes that the demand for recycled content by end users should be stimulated through financial incentives that create an actual financially attractive alternative for virgin materials and fossil-based plastics, as well as by removing barriers to a single market for secondary raw materials.


Recalls that subsidies still exist on fossil fuels, rendering virgin plastics cheaper than recycled plastics or bio-based plastics, which is a key economic barrier to the development of a circular economy for plastics; insists therefore that such wrong incentives need to be removed. In addition, producers or importers of fossil-based plastics or plastic products could be made financially responsible for the reduction of CO2 emissions from the final treatment of their plastic waste.


Stresses that by 2025, producers of plastic products should use a minimum of 50 % of recyclates in the production of new plastics, unless legal restrictions on the end products prohibit the use of recyclates. Emphasises that a value chain driven approach is required to align the interests of producers, consumers, LRAs, and the recycling industry in order to increase the quality of recycling and the uptake of secondary material.


Supports therefore the EU initiative regarding voluntary pledges for companies and/or industry associations and invites LRAs to give visibility to the pledges from stakeholders from their areas, promoting good practice and thus incentivising others to follow, while also checking how the pledges made are being followed-up and, if necessary, also highlight failures, in order to ensure that voluntary pledges are not empty promises used only to greenwash certain products or sectors.

Public procurement


Stresses the potential for Europe’s public authorities of Green Public Procurement (GPP) in plastic waste prevention as they can use their purchasing power voluntarily to choose environmentally friendly goods, services and works, which also sets an example for other organisations. Invites therefore all LRAs to contribute to the recyclability of plastics through their public procurement policies, by demanding the application of eco-design principles and the use of recycled content in products they procure.


Welcomes in this context the guidance which the European Commission and a number of European countries have developed in the area of GPP in the form of national GPP criteria (1) but asks the Commission to propose more detailed guidance documents containing information on the type of recycled plastics, their potential uses and the environmental and potential economic benefits for regional and local authorities in using recycled plastics.


Highlights that most of the plastic reaching the oceans comes from Asia and that only 9 % of plastic is recycled globally. Against this background, sees great potential to improve sustainability and traceability in global supply chains through the implementation of the EU’s new trade strategy ‘Trade for All’, which aims at using trade agreements and preference programmes as levers to promote sustainable development around the world. Endorses in this context the sectoral ‘EU Garment Flagship Initiative’ proposed by the European Parliament in March 2017 (2); highlights that such initiatives will also depend on local and regional authorities’ support in promoting them and should guide local and regional action in decentralised development cooperation.

Brussels, 10 October 2018.

The President of the European Committee of the Regions