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EuPC criticises contents of Commission's plastic carrier bags proposal
Whilst EuPC supports the goal of addressing irresponsible consumption of 'lightweight plastic carrier bags', EuPC is disappointed by the proposals attack on the internal market for plastic carrier bags. EuPC believes that the Commission's proposal violates basic principles of the internal market and questions what product the Commission will dismantle the internal market for next, due to environmental concerns and a lack of waste management enforcement. The Commission should do more to push voluntary initiatives on plastic carrier bags, with the full support of the value chain and trade associations.
EuPC also believes this proposal is a clear violation of the proportionality principle, as the proposal aims to 'reduce the consumption' of 'lightweight plastic carrier bags', yet it can allow for a situation where Member States can ban these products.
EuPC believes that this proposal aims to legalise the current Italian situation, where nonbiodegradable and non-compostable bags are banned. The Italian decree has been subject to a Commission investigation since 2010, during which a letter of formal notice was communicated to Italian authorities and a detailed opinion was issued by the U.K, both laying out the Italian decrees violation of EU law. The Italian situation favours bio-plastics over conventional polymers without taking into account the need for end of life solutions. The Commission's proposal would allow for other Member States to follow the Italian situation.
EuPC would, therefore, call on legislators to be wary of carrier bags from biodegradable plastics when it comes to questions of sustainability (including biomass used); they can as well be littered and will not degrade within a reasonable period of time, neither in the nature, nor in the marine environment. There are also unresolved issues in respect of end of life solutions (biodegradable plastics having a detrimental impact on the quality of plastics recycling as shown by EuPC independent industrial tests on degradable films and their effects on recycling).
Commenting on the proposal, EuPC Managing Director, Alexandre Dangis stated: "Ultimately, this proposal appears to be a short-sighted response to the bigger issue of waste management in Europe. This is unfortunate for the product targeted and indeed the several hundred SMEs in Europe that face a potential shutdown, if this proposal is brought into effect. On top of this, the calculation on CO2 emissions has been largely exaggerated."
EuPC would like to point out the gross error made by the Commission in table 1 of the executive summary. It states that in the case of a ban on plastic carrier bags, 147.6 Million t of CO2 emissions would be saved. In reality, the correct emissions savings would be 1.44 Million t and not a factor 100 times higher, as stated in the Commission's proposal. In short, a ban on plastic carrier bags would not equate to the CO2 emissions savings close to that of Belgium's total annual CO2 emissions (131 Million t in 2011).
EuPC remains ready to assist EU and national authorities on the issue of bringing consumption of lightweight plastic carrier bags to responsible levels and calls on the Member States to assist voluntary initiatives such as V-Bags Europe (http://www.europeanplasticfilms.eu/vbags-europe).
1 Proposal for a Directive of the European parliament and of the Council amending Directive 94/62/E on packaging and packaging waste to reduce the consumption of lightweight plastic carrier bags
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