GO!PHA1, the Global organization for Polyhydroxyalkanoates (PHA) and our members are very concerned about the draft delegated act and Annex I thereto on technical screening criteria, determining under which conditions an economic activity qualifies as contributing substantially to climate change mitigation and adaptation.
We believe that excluding food and feed stock as a raw material for the production of renewable plastics in primary form (p. 95 Annex I) seriously undermines the potential of renewable polymers such as PHA to become a sustainable substitute for fossil fuel-based plastics.
PHA is one of the most innovative and versatile materials known to man. They are found in nature and are produced by bacterial fermentation. They biodegrade in soil, fresh water and in a marine environment. The EU has sponsored over 110 Million Euros worth of research and innovation projects in the last ten years to develop PHA for various uses as a more sustainable material than conventional plastics. A spreadsheet outlining these projects are given on the next page.
While it may be understandable that the EU does not wish to support food and animal feed crops from being used for producing renewable polymers, residues from food and feed can easily be used as a feedstock. We therefore recommend accepting food and feed crops as a feedstock for plastic in primary form. For sake of regulatory consistency we propose to align the primary plastic definition in view of food and feed crops with the Renewable Energy Directive (RED) definition: “…food and feed crops means starch-rich crops, sugar crops or oil crops produced on agricultural land as a main crop excluding residues, waste or ligno-cellulosic material and intermediate crops, such as catch crops and cover crops, provided that the use of such intermediate crops does not trigger demand for additional land.”
The current definition for plastics in the primary directive undermines confidence and investments in our sector and contradicts recommendations of Circular Economy Strategy, EU’s Bioeconomy Strategy, Horizon Europe as well as EU’s better regulation and innovation principle.