EuroCommerce Feedback on the Call for Evidence on the Biotech Act II

EXECUTIVE SUMMARY
EuroCommerce supports the objectives of the EU Bioeconomy Strategy and recognise the importance of industrial decarbonisation. Operating at scale, our sector has potential to support the EU’s decarbonisation objectives, to which we are committed. But to deliver on these objectives, the sector needs a framework that supports its competitiveness and creates incentives to invest, although the policy options under Biotech Act II (and options discussed under other fora) seem to not foster these conditions for retail and wholesale. We are concerned about our sector functioning as the primary demand-pull mechanism for upstream chemicals policy, especially under conditions of system readiness uncertainty, conflict with existing legislation, and lack of assessment of impact on the competitiveness of downstream operators. With our current feedback, we address options considered under the Call for Evidence for the Biotech Act II (e.g. minimum content, Made in Europe requirements), but also measures which have been or might be under consideration in other fora (e.g. certificate or credit based mechanisms, the DG GROW Workshop on Biotech Act II of 29 April). The design of any new legislative instruments should take into account major new obligations which have already been introduced downstream by existing legislation, avoid cumulative regulatory burdens and parallel systems. It should also take into account the contextualisation of policy measures in complex, global supply chains, and the potential conflicts with existing circular economy objectives, as measures designed to accelerate demand for bio-based inputs may unintentionally divert investment, infrastructure, feedstocks and regulatory focus away from circular solutions. Furthermore, the development of bio-based solutions still faces important scientific and methodological challenges, including the lack of harmonised methodologies for traceability, lifecycle analysis and verification of environmental impacts. In our view, these aspects should be carefully addressed before considering market-shaping systems or mandatory product requirements.

Read the full Position paper below.