GO!PHA's Contribution to the EU Biotech Act Consultation

The European Commission is advancing plans for a comprehensive EU Biotech Act, aiming to bolster biotechnology and biomanufacturing across the Union. This initiative seeks to streamline regulatory frameworks, enhance investment, and foster innovation in sectors ranging from healthcare to sustainable materials. A public consultation has been launched to gather insights from stakeholders, ensuring that the Act addresses current challenges and harnesses the full potential of biotech for Europe's competitiveness and sustainability goals.

The Global Organization for PHA (GO!PHA) took this opportunity to identify the major regulatory challenges for biopolymers like PHAs made via novel biotechnologies in the current EU legislative framework, highlighting a consistent theme: innovation in bio-based and biodegradable materials is hindered by outdated or misaligned legislations.

📢 Call to action: Align legislation to reflect scientific progress and material innovation contributing to EU’s broad goals—circular bio manufactured materials must be supported with harmonized standards, guidelines, and assessments, not be hindered by one-size-fits-all policies.

Key Challenges

The systemic challenges hindering innovation and adoption— from R&D to market access of novel materials—intersect with EU’s broader policy goals for decarbonization, competitiveness, and circular economy.

  • Inconsistent and narrow definitions (e.g., “natural polymer”) blocking bio-manufactured equivalents with blanket policies

  • Restricted scope for compostable packaging despite proven benefits has led to uncertainty, hindering uptake of compostable packing as seen in EU PPWR.

  • Outdated waste and recycling policies, especially the failure to recognize carbon recycling via composting or anaerobic digestion.

  • Inadequate lifecycle assessment (LCA) methods, which do not reflect the true environmental benefits of biodegradable, biobased materials.

  • Biomass prioritization policies favoring energy over materials, disrupting feedstock access and market growth for biopolymers.

Our Recommendations

Rooted in systems change, our contribution to the EU Biotech Act consultation focused on policy barriers that limit the scale-up of safe, sustainable materials like PHAs. Materials like PHAs, already supported for use in food contact and agriculture due to their safety and biodegradability, face outdated definitions and fragmented assessments leading to blanket policies that lump them in with traditional plastics and block scale-up and broader adoption. Non-plastic substitutes and alternatives like PHAs are key to enable a truly circular, renewable materials economy.

  • Adopting a criteria-based approach to define "natural polymers", assessing materials based on origin, functionality and properties, safety, and impacts

  • Expanding compostability applications scope to include biotech-derived materials with proven environmental performance to create innovation-friendly market.

  • Recognizing composting and anaerobic digestion—which is recycling carbon— as legitimate forms of recycling in waste management frameworks.

  • Refining LCA and carbon accounting methods to fairly assess biobased and biodegradable materials.

  • Establishing harmonized sustainability criteria for biomass across all uses— for biobased materials and not just energy—to ensure fair access and competition across sectors.

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The Road to a Global Plastics Treaty