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Opinion Mass Balance Can

Opinion Mass Balance Can ISSC PLUS certification be misleading – if the bio-based share is not labelled too? Comment by Michael Carus, nova-Institute Bridging the gap to a sustainable bio based economy Comment by Dr. Jan Henke (ISCC PLUS) On 23 April 2014 SABIC announced “that it will launch its first portfolio of certified renewable polyolefins, certified under the ISCC Plus certification scheme, which involves strict traceability and requires a chain of custody based on a mass balance system. The portfolio, which includes renewable polyethylenes (PE) and polypropylenes (PP), responds to the increasing demand for sustainable materials from SABIC’s customers.” Imagine you see the new SABIC PE or PP granulates with the label ISCC PLUS which claims “Certified Sustainability” – what will you think about the product? What does it mean? Are all of the PE or PP granulates themselves “certified as sustainable”? Or is it the feedstock used for the production of the material? The truth is: Neither of them are! The certification applies only to the biomass share of the feedstock and the granulates, without any information on the actual quantity of the share. SABIC uses certified sustainable “animal fats and waste” in their crackers: “We have optimized our technology to allow the production of renewable PP and PE using renewable feedstocks, which are made from waste fats.” But there is no minimum share of biomass required. So even if SABIC uses only 5% (certified) biomass and 95% crude oil for their PE and PP production, the ISCC PLUS label on the granulate still claims “Certified Sustainability” – although 95% of the feedstock and the product are not bio-based and therefore NOT certified as sustainable! We think that this is not a good idea. This could be misleading and can be harmful to the ISCC PLUS label and the companies using it. Some NGOs might (and will) call it green-washing. Is SABIC trying to get a GreenPremium price without having relevant additional costs? We suggest that the ISCC PLUS label – as well as other labels such as RSB – should only be used in direct correlation to the quantified share of the bio-based feedstock which they classify. That means in detail: It has to be clear that the label is only for the bio-based share of the feedstock in the product. That would mean in practice: The bio-based carbon content should always be labelled too – for example using the established label from Vinçotte or DIN CERTCO. Why a mass balance approach for sustainability certification and clear claims are essential The industrial use of bio based resources in particular in the chemical sector is stagnating. To increase their share, sustainable supply chains must be built up. This must be economically viable and sustainable. In the beginning it is only possible with low physical shares in the final product. Opponents of this approach argue that claims should only be made for a high physical share. These demands are out of the ivory tower. They negate the fact that for many producers a direct switch to high physical shares doubles costs or is in practical terms not feasible. The baby would be thrown out with the bath water. The share of certified bio based resources would decline. Under the mass balance approach, companies producing different outputs from the same feedstock (e.g. an integrated chemical site) can allocate the certified sustainable bio based share to only one or several out of all outputs. Under the global sustainability certification system ISCC PLUS there are two major prerequisites to do this: The certified sustainable output volume can never exceed the equivalent amount of certified feedstock. Clear claims must be used. They must reference the mass balance approach and never the physical content, unless this is clearly detectable. In the SABIC case the claim is not “certified sustainability” or “X% physical share of certified sustainable feedstock”. SABIC and their customers must always make reference to the mass balance approach. Other claims shall not be made. To promote the bio based economy it is essential to start with a mass balance Nova-Institut GmbH Hürth, Germany 44 bioplastics MAGAZINE [04/14] Vol. 9

Opinion RSB approach to certification of bio-based chemicals Comment by Melanie Williams (RSB) approach that allows smaller ratios of certified sustainable feedstock. Integrated sites using thousands of tons of fossil and non-sustainable feedstock cannot from one day to the other switch to certified sustainable bio based inputs. Further on the input can be spread over hundreds of outputs. A physical analysis (e.g. 14 C) may only detect a small bio content for a specific product. A mass balance approach would enable a company to allocate the bio content to a specific product. When demand is increasing other products can be included. At a certain point in time high physical shares will also become economically viable. Therefore, the mass balance approach is a stepping-stone towards the bio based economy. Opponents are freezing the current situation and will contribute to the stagnation of the bio based economy, although they claim aiming to achieve the opposite. The physical segregation of certified sustainable feedstock or the proof of relevant physical contents is also possible with ISCC PLUS. It might be an advantage to companies producing from 100% certified sustainable material or with high detectable shares. To increase the share of certified sustainable biomass in the chemical industry ISCC PLUS is promoting the use of both mass balance and segregation. This allows companies to reach higher shares on a continuous improvement basis and to promote the bio based economy. Bio-based alternatives are increasingly being used to substitute petroleum-derived products. Manufacturers of bio-based materials are keen to show consumers that their products have been produced responsibly from sustainable biomass; certification to a reputed Voluntary Sustainability Standard is the preferred option. The Roundtable on Sustainable Biomaterials (RSB) is the environmental and social certification that came out as the top performer in recent studies commissioned by WWF [1] and IUCN [2]. As manufacturers take their first steps towards producing bio-based drop-in chemicals, there will often be the need to use existing facilities, which currently process petroleum derived/fossil materials, somewhere in the supply chain. This will inevitably lead to the dilution of the bio-based material with fossil material. However, consumers will want to be assured that product labeled as ‘bio-based’ contain a minimum bio content. After a wide-ranging public consultation, RSB has set a requirement for a minimum of 25% bio-based content. This requirement specifies that the annual, average bio-based content, measured according to ASTM D6866, CEN/TS 16137 or any equivalent protocol, shall not be less than 25% by weight. A mass balance approach can be used to cope with a fluctuating biobased content as long as the annual average is always shown to exceed the 25% threshold. This average bio-based content should be stated on the product documentation and packaging. An RSB certified biochemical manufacturer can make a claim on their product or packaging that their product mix contains RSB compliant bio-chemicals. Companies can also make a claim in their marketing and publicity that they support socially and environmentally responsible production of biomass, bio-chemicals and bio-products. SABIC and BASF are to be congratulated for using bio-based feedstock, but under the RSB system they could not use a specific claim on their products until they reached the 25% threshold. So how should a company obtain recognition for their efforts in the early stages of replacing fossil-based products with biobased ones? They can get credit with consumers by showing that they are in compliance with the RSB Principles and Criteria for environmental and social sustainability. As they increase the bio-based content of their products to meet the minimum 25% threshold, they are then ready to make a strong claim that their product is bio-based, and that their product meets the robust bio-based sustainability criteria in the RSB standard. Related to this, RSB is currently considering the introduction of certificates, which are sold separately to the product, (commonly called a ‘book-and-claim’ system) to help manufacturers source sustainable bio-based feedstock even when none may be available in proximity to their manufacturing sites. This will also help companies in the early stages of replacing fossil-based products with bio-based alternatives. ISCC System GmbH Köln – Germany [1] [2] on_best_quality.pdf Roundtable on Sustainable Biomaterials (RSB) Geneva, Switzerland bioplastics MAGAZINE [04/14] Vol. 9 45

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