Considerations of European Bioplastics and AAF concerning the proposed Directive to reduce consumption of plastic bags

European Bioplastics and the European Starch Industry Association (AAF) support the introduction of incentives and measures that reduce the consumption of lightweight single-use plastic bags in Europe. The European Commission proposal to amend the Packaging and Packaging Waste Directive, through allowing Member States to introduce such incentives, is therefore a step in the right direction.

The Commission has chosen to legislate on the basis of creating a category of plastic bags, ‘lightweight plastic bags,’ based on the thickness of the material used. These lightweight bags are described as single use-bags and are currently the focus of the envisaged Member State measures[1]. Lightweight single-use bags are described as 50 microns (µm) or less in thickness by the European Commission. Currently, the proposed amending Directive does not cover reusable plastic bags.

Considerations of European Bioplastics and AAF:

European Bioplastics and AAF argue that, in order to achieve the general objective of the Commission’s proposal[2], the Directive should:

  1. Exempt lightweight plastic carrier bags (thickness ≤ 50 µm), which are both compostable as well as partly biobased, from possible measures aimed to reduce ‘single-use carrier’ bags.
  2. Contain provisions to allow Member States to promote, ‘durable and multiuse’ plastic carrier bags (with a thickness greater than 50 µm) that contain a significant amount of biobased content. Such provisions would prevent the circumvention of measures for lightweight single-use carrier bags.

A detailed explanation of these proposals is provided below:

1. European Bioplastics and AAF propose to exempt from any measures lightweight single-use plastic carrier bags that are biodegradable / compostable according to standard EN 13432 and which in addition are partially biobased.

This exemption would stimulate an efficient and separate collection of compostable household waste. This also recognises the fact that Europe will need bio plastic bags to enable effective organic waste collection, as composting will be vital in order to meet the target of recycling and landfill diversion by 2020. By making use of the double function of single-use biodegradable and compostable bags, biowaste would be diverted from landfill[3] and incineration towards composting.

It is also important to note that the findings of the impact assessment carried out for the Commission’s Proposal adequately show that only 0.17% of single-use biodegradable bags are littered – this stands in clear contrast to the 6.7% of single-use non-biodegradable plastic bags being littered.[4]

An additional advantage is the further promotion of biobased materials in the desired shift to a more biobased economy (Innovating for Sustainable Growth).

2. The Directive needs to contain provisions and take precautions to prevent circumvention of measures for lightweight single-use plastic bags. Only by making sure that the markets are not flooded by fossil-based carrier bags[5] that just barely exceed the threshold can the objectives of the Directive be achieved.

European Bioplastics and AAF, therefore, propose to insert two passages into the proposal that target shopping bags above the defined thresholds for lightweight single-use bags – so-called reusable shopping bags:

  • For durable and multiuse bags with a thickness greater than 50 µm, these bags should contain a significant amount of renewable raw materials.
  • For bags with a thickness greater than 50 µm, Member States shall have the option to apply the derogation.

The biobased content of reusable biobased shopping bags ensures that they have a lower carbon footprint than fossil-based bags, which reduces CO2 emissions.

About European Bioplastics

European Bioplastics represents the interests of around 75 member companies throughout the European Union. With members from the whole value chain, European Bioplastics serves as both a contact platform and catalyst for advancing the objectives of the growing bioplastics industry. For further information, please visit

About AAF

The AAF is the trade association which represents the interests of the EU starch industry both at European and international level. Its membership comprises 24 EU starch producing companies, together representing more than 95% of the EU starch industry and, in associate membership, 7 national starch industry associations.  For more information, please visit

March 2014

Contact: European Bioplastics e.V., Phone: +49 30 28 48 23 50, Email:, AAF, Phone: + 32 2 289 67 60, Email:,

[1]These measures include any kind of “…economic instruments (…) accompanied by the possibility for Member States to introduce market restrictions by way of derogation of article 18 of the Packaging Directive”.

[2]“The general objective of this proposal on plastic carrier bags is to limit negative impacts on the environment, in particular in terms of littering, to encourage waste prevention and a more efficient  use of resources, while limiting negative socio-economic impacts.”(p.2)

[3]The Landfill Directive (1999/31/EC) includes an obligation for Member States to reduce the amount of biodegradable municipal waste that they landfill to 35% of the 1995 levels by 2016 - 2020.

[4]Commission Staff Working Document: Impact Assessment for a Proposal for a Directive of the European Parliament and of the Council amending Directive 94/62/EC on packaging and packaging waste to reduce the consumption of lightweight plastic carrier bags, table 3, p. 15.

[5]These fossil-based bags are not only unsustainable from an environmental point of view. As they are less expensive than the biobased and biodegradable / compostable lightweight single-use plastic carrier bags, their consumption would grow disproportionately, possibly even overcompensating the reduced consumption of lightweight single-use plastic carrier bags.

March 31, 2014