Position of European Bioplas tics

SOUND LCA AS A BASIS FOR POLICY

European
European
Bioplastics
Bioplastics
e.V. Marienstr.
e.V. Marienstr.
19/20 19/20
10117 Berlin
10117 Berlin European
European
Bioplastics
Bioplastics
e.V. e.V.

FORMULATION
European Bioplastics e.V. Marienstr. 19/20 10117 Berlin

phonephone
European Bioplastics e.V.
Marienstr.
Marienstr.
+49.30.28
19/20,19/20,
+49.30.28
48 2348
1011710117
5023 50
BerlinBerlin

Challenges and limitations in using LCA methodology to evaluate fax faxMarienstr.

+49.30.28 48 19/20,
+49.30.28234859 23 10117
59 Berlin
phone +49.30.28
e-maile-mail 48 23 50
info@european-bioplastics.org
info@european-bioplastics.org
innovative technologies fax web
web +49.30.28 48 23 59
www.european-bioplastics.org
www.european-bioplastics.org
e-mail info@european-bioplastics.org
web www.european-bioplastics.org
In recent years, policymakers have become increasingly reliant to support the climate change targets of the European
on the use of Life Cycle Assessments (LCA) to establish a proper Commission’s ‘A Clean Planet for All’ 2018 strategy,
basis for more transparent and evidence-based decision- which aims to achieve a carbon neutral economy by
making on policies and regulation. However, successful LCAs 2050, as well as the targets of the Paris Agreement. Each
must take into account a number of considerations in terms of these solutions offers benefits, and all of them are
of how they influence the final result and policy support. These needed to combat climate change.
include data availability and quality, modelling approaches,
Recommendation: EU and international climate targets
methodological choices, and uncertainty analysis.1
should be taken into account when benchmarking
LCAs were originally devised as a means for businesses to innovative plastics against conventional plastics.
identify hot spots and to leverage innovation in respect of a LCA studies should consider analysing innovative
specific product and its development. In the policymaking solutions in combination, and should seek to establish
process though, LCAs are instead used as a tool for comparison, the best case scenario and conditions to achieve the
specifically to evaluate diverse products or technologies that climate change targets, comparing against the
may not already have appropriate benchmarking. Here – and conventional material offerings that still predominate
in particular when comparing innovations with established the market today.
alternatives – significant challenges in terms of data availability
Bio-based plastics and fossil-based plastics are compared on
and methodological choices are the norm rather than the
an unequal basis in terms of production and conversion:
exception.
• While the bio-based plastics on the market are relatively
Challenges in using LCAs to assess innovative technologies
new materials (10-20 years), fossil-based plastics are a
such as bio-based plastics
more mature product (40-60 years).
In the separate datasets most commonly used for conducting
• Bio-based plastics are produced in a limited number
LCAs on fossil-based and bio-based plastics, substantial
of rather small-scale facilities, unlike fossil-based plastic
differences can be seen in the level of detail when considering
production, which is performed on a large, fully
input and output. These differences are also evident where
optimised basis.
datasets used to analyse the same products and processes
are derived from the same primary data source. That said, • In contrast to the conversion of fossil-based plastics
comparative LCA studies that use different background to products, making end products from bio-based
databases can lead to misleading results and interpretations. plastics is mostly conducted at small scale, often on
lines that are not fully dedicated and not running at full
For a sound LCA comparison of bio-based plastics with other
capacity.
plastic materials (e.g. fossil, recycled, CO2-based feedstock), it
is necessary to consider: • For many bio-based plastics, there are currently only
one or two producers, who themselves have only
EU and international climate change targets:
entered the market in the last 20 years.
• Bio-based, recycled and CO2-based plastics are all

complementary material solutions, originally created

1
European Commission, JRC Technical Reports, Sala S., Reale F., Cristobal-Garcia J., Marelli L., Pant R. (2016), Life cycle assessment for the impact assessment of policies, EUR28380 EN; doi:10.2788/318544,
VRhttps://ec.europa.eu/jrc/en/publication/life-cycle-assessment-impact-assessment-policies
19997 Nz, Amtsgericht
VR 19997 Nz, Amtsgericht Charlottenburg,
Charlottenburg, USt-IdNr. DE235874231
USt-IdNr. DE235874231
HypoVereinsbank
HypoVereinsbank Rosenheim,
Rosenheim, BLZ 711 BLZ200 71177,
200Konto 6356800,
77, Konto IBANIBAN
6356800, DE26DE26
7112 0077 00060006
7112 0077 3568 00,
3568BIC/SWIFT HYVEDEMM448
00, BIC/SWIFT HYVEDEMM448
1/3
 Recommendation: Future improvements in the Recommendation: The uptake of atmospheric carbon
efficiency of bio-based plastics – in terms of feedstock and release of biogenic carbon should be included in
sourcing, production, conversion, and end-of-life the appropriate phase of the product’s LCI. The uptake

European options
European
Bioplastics e.V.– Marienstr.
Bioplastics need to19/20
be19/20
e.V. Marienstr. adequately
10117 10117 Berlinconsidered and
Berlin and release of European
biogenic carbon
European needs
Bioplastics e.V. to
Bioplastics be included in
e.V.

European Bioplastics e.V. forecast
Marienstr.through
19/20 10117 theBerlin
application of appropriate the LCA impact European
category ofBioplastics
greenhousee.V. gas emissions.
Marienstr.
Marienstr.
19/20,19/20,
1011710117
BerlinBerlin
assumptions and modelling approaches. The phonephone
+49.30.28
+49.30.28
48 indirect
2348
5023 50
Modelling of indirect negative and positive effects:
underlying disparities should be described in the LCA’s fax fax Marienstr.
+49.30.28 48 19/20,
+49.30.28 59 23 10117
2348 59 Berlin
scope, interpretation, and evaluation. phone
• For bio-based +49.30.28
e-maile-mail 48 23 50
info@european-bioplastics.org
info@european-bioplastics.org
plastics, indirect negative effects (such as
fax web
web +49.30.28 48 23 59
www.european-bioplastics.org
www.european-bioplastics.org
ILUC) are increasingly modelled in LCAs. In order
For comparative LCAs, a level playing field is needed in respect e-mail info@european-bioplastics.org
to ensure a level playing field for the comparison
of data sources and quality: web www.european-bioplastics.org
process, indirect negative effects of fossil-based plastics
• Published life cycle inventories for fossil-based products also need to be considered.2
(e.g. from Plastics Europe) cover only the environmental
• In addition, LCAs should not only focus on negative
footprint of European manufacturing sites. For some
impacts, but also account for indirect positive impacts,
materials, the majority of the production happens in
especially where these are of high relevance to a
other regions of the world resulting in a most likely
functioning circular economy.3
higher environmental footprint. For European
consumption, production outside of Europe is still Recommendation: A balanced approach needs to be
important due to the need for imported products. This adopted to address indirect negative impacts as well as
geographical difference is not reflected in the analysis if indirect positive impacts. All compared materials
the appropriate regional datasets are not being used. (independent of feedstock) or products should be
scrutinised for such effects, to ensure a level playing
• Data sources also need to be screened to consider the
field.
scale of production they originate from: data relating
to small pilot plants is not comparable to data from fully Accurate reflection of end-of-life options for bioplastics:
optimised major facilities.
• Bio-based plastics offer multiple end-of-life options,
Recommendation: Fossil- and bio-based plastics depending on the material chosen and the application
datasets must be brought to the same level of quality at hand. Bottles made from bio-based PE can be
in terms of completeness, system boundaries, regional mechanically recycled in existing recycling streams;
scope, transparency, and modelling rules. Furthermore, bio-waste bags are made from biodegradable certified
they need to be made available via public databases. and compostable starch blends that can be recovered
Data also needs to be compared at an equal scale; in the through organic recycling i.e. industrial composting.
case of innovative technologies/industries operating at
Recommendation: The selected end-of-life option needs
smaller scale, data needs to be equalised to take into
to be realistic and product-specific.
account potential future maturing/development.
Final remarks:
Carbon sequestration should be addressed with bio-based
plastics: In order to address the challenges in using LCAs to evaluate
innovations and formulate corresponding policy initiatives,
• Bio-based plastics are produced from annually/bi-
EUBP urges the Commission to ensure accordance with ISO
annually renewable feedstock that sequesters carbon
14040/44 requirements to involve stakeholders when bringing
from the atmosphere while it grows. This carbon
comparative LCAs into the public domain.
is captured within the polymer/product until the end
of the material’s life. Once it can no longer be recycled,
the carbon re-enters the natural carbon cycle via
incineration or composting, thereby closing the material
carbon loop.

2
For example: military escort emissions for tankers, land occupation and spoiling. See also: V. Uusitalo and A. Enström : “Indirect global warming impacts from processes attributing to direct global warming and
example of permafrost melting”, published on www.european-bioplastics.org, December 2018
3
For example: the support of bio-waste collection with compostable bio-waste bags has been shown to increase the amount of separately collected bio-waste, which can then be used as valuable resource of compost
and furthermore does not end up in landfills where it would produce methane, thereby contributing to global warming.
VR 19997 Nz, Amtsgericht
VR 19997 Charlottenburg,
Nz, Amtsgericht USt-IdNr.
Charlottenburg, DE235874231
USt-IdNr. DE235874231
HypoVereinsbank Rosenheim,
HypoVereinsbank BLZ 711
Rosenheim, BLZ200
71177,
200Konto 6356800,
77, Konto IBANIBAN
6356800, DE26DE26
7112 0077 00060006
7112 0077 3568 00,
3568BIC/SWIFT HYVEDEMM448
00, BIC/SWIFT HYVEDEMM448
2/3
 In EUBP’s case, this would entail According to EuropaBio, the bio-based plastics industry ac-
counts for 23% of jobs and growth potential in the European
- consulting EUBP and other relevant stakeholders
industrial biotechnology sector. Today, this amounts to 20,000-
throughout the entire process of an LCA study
European
European
Bioplastics
Bioplastics
e.V. Marienstr.
e.V. Marienstr.
19/20 19/20
10117 Berlin
10117 Berlin 30,000 employees, butEuropean
implementing
European the e.V.
Bioplastics righte.V.
Bioplastics framework con-
comparing bio-based plastic products with any other
European Bioplastics e.V. Marienstr. 19/20 10117 Berlin ditions would result inEuropean
steep employment
Bioplasticsgrowth
e.V. and could
type of product used in the same applications; Marienstr.
Marienstr.
19/20,19/20,
1011710117
Berlin
4 Berlin
create up to 300,000 high-skilled
phonephone
+49.30.28
jobs
+49.30.28
48 2348
by 2030
5023 50
.
- consulting EUBP and other relevant stakeholders fax Marienstr.
fax
+49.30.28 48 19/20,
+49.30.28 59 23 10117
2348 59 Berlin
If current and futureinfo@european-bioplastics.org
phone studies
+49.30.28
e-maile-mail
fail
48 to address the specific
23 50
info@european-bioplastics.org
in respect of the relevant scope decisions – for example,
challenges thatweb
LCAs
fax pose
+49.30.28
web to innovative
48 23 59 technologies in
www.european-bioplastics.org
www.european-bioplastics.org
which functional units are chosen to allow for a
general and the bio-based
e-mail plastics industry in particular, the
info@european-bioplastics.org
meaningful comparison, which LCA methodological
conclusions andwebpolicy
www.european-bioplastics.org
formulation that arise from these
approach (e.g. allocation) is used, the applicability of
studies may be distorted and would potentially have a negative
different polymers and plastics (and the intended
impact on the European uptake of bio-based plastics and the
applications), and the assumed performance and
associated employment growth potential.
quality indicators of these polymers covering the whole
lifecycle from feedstock production through product About European Bioplastics
use to end-of-life.
European Bioplastics represents the interests of more than 70
- a mandatory critical peer review involving all relevant member companies throughout the European Union. With
stakeholder groups when making comparative members from the entire value chain, European Bioplastics
assertions and policy decisions. serves as both a contact platform and catalyst for advancing
the objectives of the growing bioplastics industry. For further
information, please visit http://european-bioplastics.org.

4
EuropaBio, Study on Jobs & Growth in Industrial Biotech in the EU, 2016.

Contact: European Bioplastics e.V., Phone: +49 30 28 48 23 50, Email: policy@european-bioplastics.org, www.european-bioplastics.org, July 2019
VR 19997 Nz, Amtsgericht
VR 19997 Charlottenburg,
Nz, Amtsgericht USt-IdNr.
Charlottenburg, DE235874231
USt-IdNr. DE235874231
HypoVereinsbank Rosenheim,
HypoVereinsbank BLZ 711
Rosenheim, BLZ200
71177,
200Konto 6356800,
77, Konto IBANIBAN
6356800, DE26DE26
7112 0077 00060006
7112 0077 3568 00,
3568BIC/SWIFT HYVEDEMM448
00, BIC/SWIFT HYVEDEMM448
3/3