It became clear once again that there is absolutely no level playing field when it comes to raw materials made from chemically recycled plastics. Although Jappe de Best, professor at Avans Hogeschool/Centre of Expertise Biobased Economy demonstrated with LCAs that the footprint of pyrolysis is smaller than that of incinerating the same types of waste, entrepreneurs still have no certainty about the status of these circular raw materials. They have to provide lots of evidence on origin and composition; far more than was ever needed for the supply of fossil feedstocks.
In spite of this heavy administrative burden, however, there is no certainty whatsoever that the new raw material will be allowed everywhere. A Central Desk that can provide such certainty does not exist. Within the Netherlands, the several Environment Services do not recognise each other’s judgements; what is considered raw material in the Groningen region may still be considered waste in the province of Limburg. And in the case of international deliveries, it remains to be seen whether or not they will be sent back at the border.
Going to court
This must and can be done differently, argue the partners of the PyroCHEM project, following the ‘End of Waste‘ report that Ecomatters wrote on behalf of Green Chemistry New Economy (GCNE). But waiting for new government regulations is not an option. Bjorn Koopmans of GCNE advises entrepreneurs to get started. If an Environment Agency objects, it should just go to court. “If, as an entrepreneur, you have done your homework and your documents are in order, I am convinced you will simply win such a court case,” he says.
At the same time, the industry itself can work with certification schemes. “The industry is perfectly capable of doing this and deserves the trust of the government to do so,” according to Koopmans. GCNE meanwhile is already working on a follow-up to EcoMatters’ study. This will look at how industry can persuade the government to be more facilitative, instead of assuming restrictions. Ultimately, to achieve the Dutch and European objectives in the field of circularity, it is important to have a conclusive and generally applicable End-of-Waste status, which applies not only to waste plastics but also to mixed waste streams containing biomass.
Read the full report (in Dutch) of the Moerdijk meeting on one of the websites mentioned below.