The inquiry’s proposal

Ecolabelling has received a substantial breakthrough in Sweden through the Nordic ecolabel Svanen (the Swan) and the Environmental Pro-tection Agency’s Bra Miljöval (Good Environmental Choice). The EU has, since 1992, an ecolabelling system – EU Ecolabel – that have large similarities with Svanen but have not received the same applica-tion in Sweden. Ecolabelling Sweden is responsible for Svanen and EU Ecolabel in Sweden. The company is 100 percent own by the Swedish state, is non-profit and is financed partially through a fee from the companies that have ecolabeling licenses and partially through governmental grants.

The EU Commission highlights in their plastic strategy that con-sumers must receive clear information about degradable plastic, what it entails when a product is advertised as degradable and how such products are managed in the waste stage. To enable correct sorting and to avoid unfounded environmental claims, the EU Commission intends to propose harmonised rules for defining and labelling com-postable and biodegradable plastic. From a littering perspective, it must, for instance, be clear for the consumer that when a plastic is

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compostable, biodegradable or bio-based, it does not decompose completely in the environment.

The idea of labelling is to make it easier for the customer, but at the same time it is important that it is not misleading or misunder-stood. It is therefore important that different labels for bio-based, recycling or decomposability do not contradict each other, but that they can run parallel to one another in an interconnected system.

This speaks for a unified national or international labelling within a establish labelling system. It can be discussed if introduction of a label should occur on EU or national level. A national labelling will become a national special requirement, which could entail a trade barrier. Therefore, it may be argued that a labelling system ought to be run on EU-level.

Compliance of a labelling system must be able to follow-up and undergo an independent audit. A label that the inquiry proposes can be controlled using standards. There exist three different European standards that can be used to define the share of bio-based content:

one that measures bio-based carbon content and two that bring forth the bio-based content. Additional methods for bio-based content are under development. One disadvantage with a label, which will be controlled with a method that measures bio-based carbon content, is that it excludes recycled plastic. An alternative for including both recycling and bio-based can be a label based on the amount of carbon dioxide emission, like energy labelling. The inquiry believes however that such a label would be more difficult to control than the pro-posed one.

5.2.2 Climate compensation fee

One incentive for increasing the share of renewable plastic is to put a fee on fossil products. In this way, responsibility is placed on com-panies that put a product on the market to use renewables before fossil. Such a system ought to also consider the environmental benefits of reuse and recycling. This may be achieved by companies that call back a product for reuse or recycling receiving a corresponding fee reduction. Such a system resembles the bonus malus system that was introduced in Sweden the 1^st of July 2018 for new cars, light busses and light trucks. In brief, the system meant that environmentally

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friendly cars with low emissions of carbon dioxide are rewarded with a bonus while gasoline and diesel-powered cars are charged with an increased vehicle tax during its three first years (malus).

In an analysis executed on behalf of Avfall Sverige (von Bahr et al, 2018), a climate compensation fee is highlighted as interesting to reach the goal of a fossil-free waste incineration. The study examines in detail different scenarios where most are deemed as entailing very high socioeconomic costs. A climate compensation fees is deemed interesting since it is technologically neutral and opens up for dif-ferent technological solutions. The companies can choose what they would like to focus on to reduce the plastic’s negative environmental impact – reuse, recycling or bio-based. This would increase the fossil plastic’s value and steer towards primarily using it in those applica-tions where the plastic’s technical qualities are really needed. In the legal analysis, it is highlighted that a climate compensation fee would remind of an excise tax with the difference that the level is controlled by costs of the climate compensation. Additionally, it is legally pos-sible to decide on environmental fees on a national level, but the EU needs to be notified.

5.2.3 Mass balance for bio-based plastic

One approach to getting the companies to increase the share of bio-based and/or reused raw material in their production, is to give the companies increased acceptance for calculations of mass balance.

The mass balance principle is based on a certain volume bio-based raw material being added to the same system as fossil raw material.

Corresponding volume bio-based products may then be sold as the volume bio-based raw material that is added. It is however not guaranteed that the specific bio-based raw material will end up in those products that are sold as “bio-based”. By calculating on the mass balance, a mixture of sustainable and unsustainable material is allowed, which entails that current infrastructure can be used. The advantaged of the mass balance concept is that it allows for a gradual transition. The companies can successively increase the share bio-based or perform substitution to other material in accordance with what is technologically and economically possible. For example, as the avail-ability of bio raw material increases.

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Mass balance for bio-based/reused products is however a very dis-puted question. For example, within the European standardisation efforts, it has only been possible to agree upon one calculation method for mass balance where the minimum content of bio-based in the pro-duct is guaranteed (material balance). Regarding other methods, some acceptance for a mass balance with strict system boundaries was present, but the conclusion was still that mass balance can be abused and should therefore be used with caution and after careful dis-cussions concerning prerequisites (SIS, 2018). This is to avoid double counting, but also because it becomes too uncomplicated in the end to move the bio-based advantages, which results in the decreased need for expanding the actual use of bio-based raw material. To calculate on the mass balance is therefore similar to a lifecycle analysis – it is all about the boundaries. The advantages however, outweigh the draw-backs and the inquiry therefore proposes that the government sup-ports the companies in their efforts by creating an acceptance for mass balance calculations for bio-based and/or reused plastic raw material.

5.2.4 Efforts on research and development

To increase the prerequisites for renewable plastic and to increase its share on the market, efforts on research and development are needed.

All actors in the supply-chain need to be involved and collaborate. In addition, research initiatives on renewable plastic need to be conducted in parallel with the efforts that are made to improve the recycling.

The inquiry recommends that specific efforts are placed on the following:

• As a point of departure, a mapping of the need for raw material for plastic is needed that takes into consideration any goals regard-ing how much bio-based plastic that society wants to see and includes competing usages and land-use.

• The background data for the various bio-based raw materials, which is required to conduct lifecycle analysis, are in many cases inadequate. Therefore, efforts ought to be made to develop said data for the various raw materials.

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• To investigate the prerequisites and the effect of using bio-based raw material when producing plastic, several factors are required.

For instance, life-span, recyclability and access to bio-based raw materials. To investigate what sustainability criteria that ought to be placed on future bio-based plastic is relevant to achieve a sus-tainable bio-based plastic.

• Focus on raw material for bio-based plastic has shifted and recently the focus has passed over to concentrating the research on by-pro-ducts from agriculture and forestry. The use of such raw material is still in great need of development.

• Industrial research projects like Skogskemi and Närodlad plast, which involve the whole supply-chain, are needed to increase the possibility of utilising Swedish bio raw material in the production of plastic. Additionally, the work carried out by Vattenfall to enable plastic from carbon dioxide ought to be supported so that different possible routes for renewable alternatives to produce plastic are examined.