The German Chemical Industry Association (VCI) and PlasticsEurope Germany have jointly presented a comprehensive assessment of the new ‘National Circular Economy Strategy’ (NKWS) of the Federal Ministry for the Environment, Nature Conservation, Nuclear Safety and Consumer Protection (BMUV). In their statement, the associations praise the positive approaches of the draft from June, but also express specific criticism of some measures. The strategy will now be revised, taking into account the feedback received, and harmonised within the Federal Government. Adoption by the cabinet is still planned for 2024.
The circular economy is a social responsibility
According to the VCI and PlasticsEurope Germany, the transition to a circular economy is a general political and social task. It is not just the framework conditions that need to be aligned to promote a circular economy. It is much more about changing the mindset in all areas of society. The Federal Ministry for the Environment, Nature Conservation, Nuclear Safety and Consumer Protection's (BMUV) draft National Circular Economy Strategy (NKWS) symbolises an important step in the right direction.
‘We welcome the fact that the draft NCA describes a comprehensive circular economy of diverse material flows, including waste prevention, circular design, complementary material and chemical recycling and the use of biomass and CO2. A growing circular carbon economy reduces dependence on fossil carbon sources. A successful circular economy requires legislative coherence at national and European level. Care must be taken to minimise bureaucracy when drafting new regulations. However, the large number of proposed measures requires prioritisation. The focus should be on strategic measures that increase the pace of transformation and at the same time contribute to greater competitiveness,’ the statement says.
Planned economic control elements within the framework of the NKWS would run counter to this. Instead, a culture of enabling a ‘circular economy’ business case is imperative for Germany.
The positive points of the strategy paper
- The importance of the chemical-pharmaceutical industry for Germany is recognised and important cornerstones of a successful transformation are addressed. The options for defossilisation through the use of all available non-fossil raw material sources (mechanical and complementary chemical recycling, renewable and biogenic raw materials, carbon dioxide from point and diffuse sources) are mentioned as essential building blocks for the substitution of fossil carbon.
- The need for a flexible mass balance approach is discussed and the fuel-use-exempt methodology is explicitly emphasised.
- The targeted promotion of demonstration plants, pilot projects and real-world laboratories is planned, but there are still gaps.
What the VCI and PlasticsEurope Germany see as critical
- Measures under the NKWS entail more regulation instead of more freedom for innovations and key technologies, such as biotechnology, digitalisation and hydrogen technologies.
- Polymer-specific quotas. Substituting primary polymers with recycled polymers can - due to varying recyclate quality - lead to reduced quality, which in turn creates uncertainty for the product manufacturer. This is because the manufacturer - and not the plastics manufacturer - is responsible for the functionality, safety and service life of its product. Insofar as the product manufacturer cannot guarantee stable material properties, this can lead to discrimination against the corresponding polymers - and thus also to ecologically disadvantageous material substitutions. Incentives for the use of circular raw materials should come from recycled material utilisation quotas (pull effect). In order for these to be effective, appropriate framework conditions must be created.
- While material complexity at product level should be reduced in the sense of design for recycling while maintaining product performance, material diversity at polymer level is a guarantee for material innovation and improved product properties. A limitation should therefore be discussed with a view to reducing material complexity at product level.
- Possible tightening of European legislation at national level and thus additional barriers within the EU internal market to the detriment of an EU circular economy.
- Negative implications for domestic primary raw material production: Domestic primary raw material production also plays an important role for downstream industries, including the chemical industry. Undifferentiated reduction targets, such as the reduction of primary raw material consumption and possible taxation of domestic raw material production, should be rejected.
The full statement by the VCI and PlasticsEurope Deutschland is available to download free of charge from the VCI website.
