REG - Symphony Environment - EPA Ireland update

Symphony Environmental TechnologiesAnnouncement

19/09/2025 17:00

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RNS Number : 1240A  Symphony Environmental Tech. PLC  19 September 2025

 

19 September 2025

SYMPHONY ENVIRONMENTAL TECHNOLOGIES PLC

("Symphony", the "Company" or the "Group")

EPA Ireland Update

 

 

Symphony Environmental Technologies Plc (AIM:SYM), global specialists in
technologies that make plastic and rubber products "smarter, safer and
sustainable," is making this further update.

 

On 8th July 2025 Symphony announced that it had received confirmation from the
Environmental Protection Agency of Ireland ("EPA") as follows:

 

"We can confirm that d2w products do not fall within the scope of the
Single-use Plastics Directive (EU) 2019/904, which prohibits the use of
certain plastic materials due to their contribution to microplastic pollution.
The d2w technology has been scientifically demonstrated to undergo full
biodegradation without leaving behind persistent microplastics or toxic
residues. This conclusion is supported by independent studies and aligns with
the objectives of the Directive to reduce plastic pollution and promote
sustainable alternatives."

 

Furthermore, the EPA said "we have reviewed the Commission Notice (2021/C
216/01) published in the Official Journal of the European Union on 7 June
2021, which provides Guidelines on the implementation of the Directive. Based
on the evidence submitted, we are satisfied that d2w products are not subject
to the restrictions outlined in the Directive or its accompanying Guidelines."

 

Symphony has now been informed by the EPA that it has no function to issue an
assurance that a product is outside the scope of Article 5 of Directive (EU)
2019/904, and Symphony has received an apology. In Symphony's view it follows
that the EPA has no function to decide whether a product is within the scope
of Article 5, but officials in the EPA consider that they should follow the
Guidelines, which in their view bring d2w plastic products within the scope of
Article 5.

 

The EPA has however accepted that these Guidelines are not legally binding and
has not disputed that they were written without the benefit of subsequent
scientific evidence.  It has also accepted that the General Court of the EU
(in the case brought by Symphony against the EU Institutions) "did not make a
determination as to whether the  d2w  Product is oxo-degradable plastic or
not."

 

For the following reasons Symphony considers that the Guidelines are
demonstrably incorrect: Recital 15 says "this Directive should cover products
made from oxo-degradable plastic, as that type of plastic does not properly
biodegrade and thus contributes to microplastic pollution in the environment."
It follows therefore that plastics that have been scientifically demonstrated
to undergo full biodegradation without leaving persistent microplastics or
toxic residues are not oxo-degradable plastic for the purposes of the
Directive.

 

The EPA has not changed its earlier position that "d2w technology has been
scientifically demonstrated to undergo full biodegradation without leaving
behind persistent microplastics or toxic residues."

 

As to Art.3(3) of the Directive, the EPA has not disputed the scientific
evidence produced to it that (a) the d2w masterbatch does not "lead to"
anything - as the process of oxidation would occur anyway, and even if it did
(b) the plastic does not fragment into microplastics, and (c) there is no
chemical decomposition.

 

Symphony has been advised by Mr. Josh Holmes KC that the Directive can and
should be interpreted so as to allow products made with d2w technology to be
placed on the market in the EU.

 

 

 

Enquiries:

 Symphony Environmental Technologies Plc
 Michael Laurier, CEO                                                  Tel: +44 (0) 20 8207 5900
 Ian Bristow, CFO
 www.symphonyenvironmental.com (http://www.symphonyenvironmental.com)

 Zeus (Nominated Adviser and Broker)
 David Foreman, Emma Burn (Investment Banking)                         Tel: +44 (0) 203 829 5000

NOTES TO EDITORS

 

About Symphony Environmental

 

 

Symphony's d2w masterbatch technology is added to polyethylene (PE) and
polypropylene (PP) products at the manufacturing stage at little or no extra
cost, and ensures that if they get into the environment at the end of their
useful life they will not create microplastics and lie or float around for
decades.  Instead they will safely biodegrade, leaving no microplastics or
toxicity. If they get collected during their useful life they can be recycled
with ordinary PE and PP without separation See
 https://www.biodeg.org/subjects-of-interest/recycling-2/
(https://www.biodeg.org/subjects-of-interest/recycling-2/)

 

Symphony also supplies a range of plastic technologies under its d2p (designed
to protect) brand www.d2p.net (http://www.d2p.net) to provide protection
against insects, viruses, bacteria, fungi, rodents, odours, and fire.  It has
also introduced a new product under its NbR brand
https://www.symphonyenvironmental.com/natural-biodegradable-resin/
(https://www.symphonyenvironmental.com/natural-biodegradable-resin/) to reduce
the amount of fossil-derived material in plastic products.

 

Symphony has a diverse and growing customer-base and has established itself as
an international business with over 70 distributors around the world. Products
made with Symphony's plastic technologies are now available in nearly 100
countries and in many different product applications. Symphony itself is
certified according to ISO9001 and ISO14001.

 

Symphony actively participates in the Committee work of the British Standards
Institute (BSI), the American Standards Organisation (ASTM), the European
Standards Organisation (CEN), and the International Standards Organisation
(ISO).

 

Further information on the Group can be found at
www.symphonyenvironmental.com  and twitter @SymphonyEnv

 

See also Symphony on Instagram and Linkedin.

 

 

 

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