issue 01/2022

However, the resulting JRC “Plastics LCA method”, turned
out to be highly problematic and rather biased, making it
impossible to carry out complete and well-balanced LCA
comparisons between biobased and fossil-based plastics.
In its current form, the method strengthens the current
dominance of fossil-based plastics and often just neglects
the negative impacts of the extraction of fossil resources
on climate and environment. This is grossly at odds with
the EU’s commitment towards reducing the dependency
on fossil-carbon and becoming climate neutral. The
methodology also undermines many of the targets set out
in the EU Green Deal and Plastics Strategy. It is therefore
also not in line with the latest IPCC report saying we need
to stop using fossil resources.
However, the whole issue is not only about bioplastics.
European Bioplastics drafted a two-page Position Paper [2]
N.N.: EUBA position on the JRC LCA Methodology and got
the support of other European Biobased Industry Groups,
organized in the European Bioeconomy Alliance (EUBA).
This is important support since this is not only touching the
bioplastics industry but the whole EU bioeconomy industry.
Therefore, EUBP, together with the other members of the
European Bioeconomy Alliance, have recently called upon
the Commission not to make use of the methodology until it
has been re-opened and significantly revised and improved.
Herewith a summary of our findings to illustrate
the significant asymmetry and shortcomings of the
methodology.
Biogenic carbon sequestration
The methodology ignores the key advantage of biobased
products, which is the uptake of carbon dioxide from
the atmosphere, sequestering it into products, and so
preventing that carbon dioxide from contributing to climate
change. This is a key advantage over fossil-based plastics.
Biobased products replace fossil carbon in plastics and
reduce the emissions of greenhouse gases. This fact should
be accounted for by being a mandatory part of a fair and
balanced assessment of environmental impacts. As an
example, the EU standard EN 16760 (“Biobased products –
Life cycle assessment”) provides guidance on how biogenic
carbon uptake should be accounted for in the assessment of
biobased plastics, but this calculation remains a voluntary,
meaningless option in the suggested methodology.
Comparing mature and immature production
systems
For fossil-based plastics, the raw material extraction,
production, conversion, logistics, and end-of-life options
have been optimized for the last 50–70 years, while
many biobased plastics are still in their early stage of
development. They are at the beginning of their maturity or
optimization curve.
The LCA methodology provides no real answer on how to
compare systems that have different levels of maturity. In a
meaningful assessment (LCA should inform about decisions
that shape the future) of biobased plastics, this potential
for further improvements should be incorporated. By not
acknowledging these differences, the LCA methodology
mainly supports the status-quo and ignores the potential of
innovation. That clearly can’t be the goal.
Data reporting requirements
In an area where the report really goes wrong are the
requirements on data reporting (this is the basic data that
goes into the life cycle inventory). It is not demanding for
the same requirements for data sets for biobased and
fossil-based feedstocks. For biobased production systems,
detailed company-specific data are required, while for
fossil-based systems, the industry average (black boxes)
data sets are still acceptable. It is still allowed to just exclude
emissions coming from accidents, spills, and oil fires. After
30 years of performing LCA studies, these practices need
to be stopped. For biobased plastics products, all kind
sof details are requested, which as such is totally correct,
about agricultural emissions, machinery use, heavy metals,
chemical use, resource types, production locations and
water consumption, while there is no or hardly any attention
paid to similar aspects for the fossil-based alternatives.
Incorporation of Land Use Change (LUC)
For biobased plastics, LUC shall be included, while for
fossil-based plastics, the methodology is much less strict.
This is not correct, including aspects should be consistent
for all types of materials. Even if the contributions seem
to be relatively small (which is often used as an excuse for
ignoring it), they should be included to increase awareness
and the fact that several relatively small contributions
can lead to a significant contribution. Further, continuous
improvement of agricultural practices, such as soil carbon
uptake by improved management, needs to be taken up in
the LCA calculations, instead of being parked at the side-line
under the header: ‘additional environmental information.’
Inconsistent inclusion of indirect effects
Negative indirect effects for biobased plastics, such as
Indirect Land Use Change(iLUC), are considered relevant
and recommended to be included, while the inclusion of
negative indirect effects of fossil-based plastics is explicitly
ruled out. A big omission is the lack of methodology to
include the direct and indirect effects of the leakage of
persistent plastics into our environment. On the other
hand, great importance is given in the LCA methodology
to the scientifically controversial issue of Indirect Land
Use Change (iLUC). It’s based on mere model calculations
that vary greatly due to the lack of standardized methods
– interestingly, unlike the calculation methods for biogenic
carbon uptake. Despite of the uncertainty, the assessment
of iLUC is considered important and mandatory in the LCA
methodology. Further iLUC contributions are often included
while no proof has been provided if it also takes place.
Requirements for providing proof
Also, with this aspect, the methodology is not consistent.
For positive indirect effects of biobased plastic products,
such as soil carbon storage by improved agricultural
management, proof is required, while no proof is required
for negative indirect effects of biobased materials, like iLUC.
Biodiversity impacts
In the JRC LCA method, the topic of biodiversity is
strongly linked to the agricultural production process of
biobased products. For fossil-based products, there is
much less attention for this topic, while there is a direct,
Opinion
bioplastics MAGAZINE [01/22] Vol. 17 43