Open Letter to the new College of Commissioners

03 12 2024

Brussels, 3 December 2024

Dear President-elect von der Leyen, dear College of Commissioners,

The EU has long been a frontrunner when it comes to plastics policy – the Single-Use Plastics Directive, the plastic packaging restrictions under the Packaging and packaging waste regulation, as well as the EU’s signature of the Bridge to Busan – all of these efforts are a testimony to the recognised devastating impacts of plastics across its value chain.

Unfortunately, plastic production and consumption are projected to triple globally by 2050 and could consume up to one-third of the remaining global carbon budget by 2050. Plastic production is one of the largest contributors (1) to global greenhouse gas emissions – nearly all plastics come from fossil fuels, and greenhouse gases are emitted at each stage of the plastic lifecycle (2).

The Commission has committed to continue pursuing climate neutrality by 2050 and zero pollution. This means that plastic, its chemical precursors and additives are as relevant as ever for EU policy priorities. To make matters worse, plastic and its many additives are a main carrier of toxic chemicals, such as PFAS, bisphenols and phtalates. These hazardous chemicals leach into food, our homes and the environment and pollute nature and our bodies. A recent Eurobarometer (3) survey confirms once again that European citizens deeply care about this issue: 84% of European citizens are worried about the impact of harmful chemicals present in everyday products on their health as well as on the environment. The same study shows that 84% citizens continue to be convinced that EU environmental legislation is necessary for protecting the environment.

The Rethink Plastic alliance calls on the Commission President and the entire college of Commissioners to provide a credible policy framework for plastics and drives the EU’s strategic autonomy while protecting citizens and the planet. The Rethink Plastic alliance therefore urges decision-makers under this new mandate to:

Deliver on a safe and circular economy that fits with EU and global climate, biodiversity and pollution objectives:

Enabling consumption reduction through sufficiency, reuse and repair while creating toxic-free material streams is the single most powerful lever in driving the EU’s strategic autonomy and should therefore be at the core of the Ecodesign for Sustainable Products Regulation (ESPR), its secondary legislation and the upcoming circular economy act. To serve an EU circular economy, the latter should recognise the waste hierarchy and introduce measures for reduction, reuse and repair to the same extent as for recycling.

Enforce circularity principles equally across the bioeconomy, including bio-based plastics, to avoid further encroaching on its first and foremost function: providing food and ecosystem services. The upcoming bioeconomy strategy update should mirror and expand on the principles already put forward in the 2022 Communication on an EU policy framework on bio-based, biodegradable and compostable plastics to hold up bio-plastics to the same environmental requirements as conventional ones by controlling their production scale, making them fully circular and toxic-free.
Clean material and product streams from the onset by restricting the use of hazardous substances. The presence of hazardous substances in materials and products hampers safe reuse and accumulates in products using recycled content. This has a direct impact on the demand for such recyclate and continues tipping the scale towards virgin raw material.

Keep the ambition in the plastics treaty process and following the INC-5 in Busan, work towards building even stronger support for a treaty that includes production reduction measures, phases out chemicals and polymers of concern, restricts problematic products and prevents microplastics emissions to be adopted at INC5-2. While the treaty process is ongoing, we encourage the EU to already adopt EU measures on production and chemicals of concern.

Divest from fossil projects and unsustainable production:

As it becomes increasingly evident that recycling alone cannot solve the plastic pollution crisis, a set of economic incentives to cut the production of new plastics while promoting reuse and high-quality recycling is urgently needed to stop pollution at source and accelerate the circular economy transition.

Subsidies into fossil projects need to be suspended – including those that rely on fossil fuels as a raw material such as for the production of plastics and petrochemicals, many of which are toxic chemicals and are currently under scrutiny in the EU (PFAS, PVC, Bisphenols… ). The IEA projects oil use for energy purposes will peak in 2027 to benefit fossil fuel use for petrochemicals and plastics production. A recent modelling exercise (4) confirms that removing such subsidies would have a negligible economic impact on the consumers of final products.
Reform and strengthen the Plastics Own Resource as part of the preparatory work for the next Multiannual Financial Framework, turning the current levy on non-recycled plastic packaging waste into a more effective incentive for genuine circularity of this high-impact sector by e.g. broadening the scope of the levy to target plastic prevention all along the value chain, widening its scope to also include other throw-away packaging materials and increasing the levy to provide a clearer economic signal to the market.

Deliver on tackling microplastic pollution to protect ecosystems, including the Ocean ,and safeguard health: the EU must meet its target of a 30% reduction in microplastic pollution by 2030, as set in the Zero Pollution Action Plan. Microplastics, whether intentionally added to products or unintentionally released into the environment, contaminate water, soil, and air, ultimately also threatening biodiversity and human health. While some sources of microplastic pollution are being addressed through targeted legislation (e.g., the plastic pellet regulation proposal, the REACH restriction, product design measures considered under the ESPR), a comprehensive set of binding measures is needed to address all major sectors including textiles, geotextiles, agriplastics, tyres, paints, detergents, and more.

Drive a just transition for the chemicals industry: the profitability of the EU chemicals industry should be assessed taking all societal and environmental costs into account. The valuation of impacts on human life, associated healthcare and insurance costs, as well as environmental remediation costs need to be considered to provide a full picture. Evidence suggests that environmental chemical exposures lead to costs that may exceed 10% of the global domestic product (5). Certain material compositions themselves – such as PVC, polycarbonate, polystyrene and polyurethane – are not conducive for circularity due to their inherent toxic properties. A clear and just pathway for the EU industry under the chemicals industry package needs to be developed to transition out of the production and use of hazardous substances and polymers – starting with PVC, PFAS, phthalates and Bisphenols.

We thank you for your consideration and remain at your disposal for any questions you may have.

Rethink Plastic alliance