Innspill til EUs evaluering av regler for engangsplast og fiskeutstyr

Response to the public consultation on the evaluation of rules on single-use plastics and fishing gear

This response incorporates operational observations from key Norwegian stakeholders across the recycling value chain (Ragn-Sells, NG Nordic, BIR, Franzefoss Gjenvinning, and IVAR IKS) regarding the practical impacts of the
SUPD.

Overall, the SUPD has had incremental impacts yet. An IVAR IKS pick analysis comparing 2018 and 2025 municipal waste compositions showed a modest 2% increase in paper and a 1% decrease in plastic. However, we see a negative operational impact of substitution single-use plastic products with paper and composite materials in waste streams. Food-contaminated fiber and paper are substantially harder to recycle than the monomaterial plastics they replace.

Paper is a good substitute for tiny items that escape fine sorting regardless of material and are lost to incineration. The rise of composite materials lowers purity of sorted waste streams, hence hinders high-quality material recycling of paper and plastic.

Regarding tethered caps, these provide a clear technical benefit for central sorting facilities by ensuring the cap remains with the container rather than falling into the "fines" category which is often lost to incineration.

Economically, we anticipate an increase in demand for secondary plastics from 2030, which will improve the viability of the recycling industry. However, mandatory recycled content will only succeed if accompanied by sorting at the point of disposal to ensure the recycling value chain can capture the necessary materials suited for refinement.

Based on operational experiences from Norway, Sirk Norge provides the following recommendations:

1) Prioritize Monomaterials in Design as mono-materials are significantly
easier to handle and yield higher quality secondary raw materials.

2) EPR schemes must cover the full lifecycle costs, including waste management, to ensure producer incentives are direct and impactful.

3) Monitor the Paper-Substitution Trend: The Commission should closely monitor the shift toward substitutes for single-use plastics, to ensure replacements do not result in a net loss for material circularity.

The SUPD provides a strong regulatory foundation. However, reflecting the operational realities of Norwegian waste managers, we advocate for evidence-based policy refinements focused on material substitution and Design for Recycling to support the technical capabilities of the sorting and processing industry for secondary materials.