Posisjonsnotat om den globale plastforurensingsavtalen
I dag, 13. november, starter INC-3 i Nairobi. Dette er tredje gang det skal forhandles om den globale plastforurensingsavtalen. Det som er nytt denne gangen er at det ligger et “zero draft” til grunn for videre diskusjoner. NCMT har hatt avtalen på agendaen i høst, og har etablert en arbeidsgruppe som har kommet med innspill til Miljødirektoratet som er høringsorgan, og de som videreformidler innspill til den norske delegasjonen fra Klima- og miljødepartementet. Arbeidsgruppen som har utarbeidet vårt posisjonsnotat har bestått av representanter fra Amiblu, Ineos Inovyn, Helgeland Plast, Biesterfeld Norge, BB Marine, Kiwa og Gjenkraft. Les posisjonsnotatet under.
NCMT input to the INC-3 on the Plastic Pollution Treaty
NCMT welcomes the ambitious effort and worldwide work for a cleaner, safer, and less polluted world and supports the need for a global approach. Unfortunately, pollution can not be omitted completely. It would be the ideal situation. Plastic in itself is not the problem, but it becomes one when mismanaged. This has rightfully been included by the thorough section on waste management in the ZERODRAFT of the treaty.
As pollution is not possible to omit entirely, we as an industry support both the political and industrial perspectives as well as the end user angle to ensure that our industry and materials are as green and sustainable as possible.
NCMT and its members cover the whole value chain. And before regulations are put in place and phasing out of plastic turns out to be the option following ratification of the treaty, we encourage the negotiating parts to also take a similar wide perspective, conducting research in the entire value chains, and ensures cradle to grave Life Cycle Assessments are made and compared with the alternatives in different products before adding materials to the regulating lists. Plastics and composites normally have a very long service life. This must be taken into account!
In addition to our position paper, NCMT supports the input to INC-3 from Plastics Europe.
We look forward to the next steps of the negotiations of the treaty and welcome the opportunity to contribute in discussions and by our knowledge and network.
Best regards,
NCMT, on behalf of our members
Part II
Chapter 1-3 Primary plastic polymers, Chemicals and polymers of concern and Problematic and avoidable plastic products, including short-lived and single-use plastic products and intentionally added microplastics.
Plastic and polymers as alternative and safe solutions in production and use
NCMT members have a high focus on eliminating CO2 emissions as well as ensuring sustainable products. The use of polymers and composites may be considered as better and more sustainable alternatives compared to conventional products in the course of entire life cycles. The reasons for this are, when compared to conventional products:
Lighter weight
Longer lifetime
Less degradable
Less maintenance
NCMT believes in promoting sustainable production and consumption practices and at the same time establishing a global circular economy for plastics providing new business models.
We also believe that the industry is a trustworthy partner to engage in its own sustainable transition, in designing new products and business models, and when it comes to increasing sustainability on all three levels; economically, socially, and environmentally. It is important that the Governing body consists of members from the industry and secure means to support the industry in the transition.
Polymers of concern
In the Zerodraft proposed, the content of the Annexes discussed is still not determined. That is, criterias for restrictions on chemicals discussed is not known. A general concern is however that the proposed legislation does not distinguish between chemicals that will be present in the final plastic products and reactants (monomers) used in the process and not present in the final plastic product.
One can also question the need for this regulation to deal with chemical intermediates that will not be present in the final product, handled in an industrial setting, and regulated by each country in regulations for chemicals (for example REACH for Europe).
When discussing “polymers of concern”, it is important to remember that there are also polymers that are made and traded but are still intermediates to be reacted further to the final plastic product. Polymeric resins used in two component thermosets could be examples of such. In such cases they would typically be of lower molecular weight and have functional groups for the further reaction (curing). This may seem to be a concern, but finally reacted to a higher molecular weight and the functional groups are the ones reacting in the curing process.
Chapter 7 Extended producer responsibility
End user and producer responsibilities in environmentally sound waste management
The extended producer responsibility should be supported by a transition and development of infrastructure and dissemination of knowledge to intensify end user incentives.
NCMT believes that transitions to a more sustainable industry will be strengthened by incentives for the entire value chain to be aware of their responsibilities (and essential for securing circular options). This also supports SDG 17 - Cooperation to reach the goals, a good opportunity to utilize the power of cooperation to solve this global challenge.
NCMT supports the development of infrastructure to enhance circularity of plastic waste involving producers, consumers, and end users.
The treaty will be a strong instrument for impacting and advocating the transition to more sustainable use of plastics and polymers expectantly leading to more research and development in the industry and cooperation with academic institutions.
Annexes A and B
Regulated chemicals, materials, and products
Where recycling is an option, we would welcome the list of regulated products to be made in accordance with similar models as the Joint Research Centre (JRC)’s proposed framework for determining quality of recycling. This will take long term in-use occupation, environmental impact and total substitution potential into consideration, and give a balanced perspective on sustainability which would also be comparable across materials. Where recycling is not yet a commercially viable solution, we call on a wider understanding of a materials’ sustainable contributions to be used as reference than solemnly recyclability.
NCMT believes that the list of products will be much stronger if it is created in close collaboration with the industry itself, because we have in-depth knowledge of the manufacturing and handling of the materials and chemicals.
We acknowledge the importance of research for the continuous improvement of the quality and sustainability of plastic materials. However, a treaty based solemnly on research, and seen from a researcher’s point of view, would be incomplete. Therefore we strongly advocate for the active involvement of industry stakeholders in shaping the intricate nuances of the treaty, and the future development of it, so the experiences from those who handle these materials on an everyday basis is heard and learned from.
About NCMT
NCMT is a business cluster of companies and organizations working in the whole plastic and composite value chain. Within a few years, NCMT has taken the position as the unifying player within polymer and composite in Norway. The aim of the cluster is to establish a strong and world-leading collaboration that works to make the Norwegian polymer and composites industry a world leader in all 3 dimensions of sustainability.
