On January 17, 2024, the European Association for Bioplastics (EUBP), in conjunction with 11 other associations in the European materials industry, issued a joint statement on the Green Claims Directive calling for the recognition of biocarbon in the Green Claims Directive.
Since the adoption of the Green Statement Directive by the European Commission in March 2023, the Parliament and the Council have been negotiating the content and wording of the draft report.
The aim of the Directive is to protect consumers from "greenwashing". However, these unsubstantiated and vague "green" claims for goods and services are at best misleading and at worst untrue. The Green Claims Directive will impose requirements on how green claims are communicated and introduce rules for environmental labeling schemes. Compliance with these requirements must be verified and certified by a third party.
Greenwashing is rampant in Europe. Currently, about 75% of products on the EU market carry some kind of implicit or explicit green claim. However, the sheer number of different labels (there are 230 eco-labels in the EU) can be confusing for consumers. Their environmental claims may be unreliable, unsubstantiated and lack credibility, making it difficult for consumers to make truly informed choices.
The Directive also requires companies to substantiate their voluntary green claims in business-to-consumer business practices by complying with a number of requirements relating to assessment (e.g., by providing the results of a full life-cycle assessment (LCA)). However, the Directive does not prescribe any single assessment methodology as the only effective way to substantiate green claims.
Twelve associations, including the European Bioplastics Association, called on the European Commission to consider four provisions to ensure that consumers have access to "reliable, comparable and verifiable information". These include a call for clear rules for comparison between different product categories and further development of methods for calculating the life-cycle environmental impacts of products.
In the view of these associations, the EU-recommended LCA methodology, Product Environmental Footprint (PEF), "does not cover all steps of the product life cycle", making it inapplicable to different value chains. While the EU recognizes that bio-based products play a key role in mitigating climate change, the current PEF methodology fails to recognize the environmental advantages of using biochar at the beginning of a product's life cycle over fossil carbon. In other words, the approach fails to encourage the use of renewable materials of biological origin to replace fossil materials.
The association wrote on LinkedIn that for Bioplastics Europe, "it is of utmost importance that biochar is used in any methodology to validate and justify environmental claims." The joint statement said, "The PEF methodology, like any LCA methodology, does not currently cover all the environmental aspects that society deems relevant, nor does it cover all the positive externalities from different industries, such as food waste avoidance, biochar uptake and recyclability.
Calculating the LCA of bioplastics has long been controversial. Proponents of bioplastics argue that by not taking into account biochar, it skews the picture that bioplastics contribute to global warming. Biogenic carbon refers to the carbon that is removed from the atmosphere as the feedstock grows and is eventually released back into the atmosphere at the end of the polymer's life.
Given that other materials such as bioplastics and paper temporarily store CO2, the scope of their LCA is also particularly important (e.g., cradle to gate vs. cradle to grave).
In this regard, the 12 associations urge the European Commission to recognize that "the provisions on the comparison of environmental statements need to be clarified with due reference to the existing LCA ISO standards in order to properly compare products in different product categories with different environmental impacts." Clear rules are needed to clearly define the boundaries of the scope of the comparison and the baseline for the comparison itself."
In addition to the European Bioplastics Association, other signatories to the joint statement include: the Alliance for Biobased Industries; the European Federation of the Paper Industry; the International Federation of Paper and Board Converters in Europe; Farmers of Europe and the European Agricultural Cooperatives; the European Carton Manufacturers' Association; the European Federation of the Furniture Industry; the European Tissue Symposium; the European Federation of Corrugated Board Manufacturers; the Federation of European Federated Envelopes, and Lightweight and E-commerce Packaging in Europe; Handicrafts and Small and Medium-Sized Enterprises in Europe; and the European Association of Carton and Cardboard Manufacturers.
Their other requirements are:
Ensure consistency of the Directive with relevant EU legislation while maintaining a level playing field with imported products; ensure that (information) requirements are strictly related to substantiation and that confidential information is protected; and ensure that existing, reputable third-party verified environmental certification schemes, and labels do not face obstacles in the verification process.
