OBPF response to Eunomia report May 2017

The Oxo-Biodegradable Plastics Federation (OBPF) welcomes the Final Report regarding:

“The Impact of the Use of ‘Oxo-degradable’ Plastic on the Environment.”

The final report regarding the impact of Oxo-Biodegradable (OBD) plastics on the environment for DG Environment of the European Commission compiled by Eunomia Research & Consulting has just been published – Framework Contract No ENV.A.2/FRA/2-15/0008 and 07.0201/2016/748104/ETU/ENV.B.3.

In November 2014, Members of the European Parliament proposed an outright ban on OBD plastics within the EU. Although this measure was blocked, an amendment to the Packaging and Packaging Waste Directive, adopted in May 2015, committed the Commission to examine the impact of the use of OBD plastic on the environment. This study has been undertaken in response to that request.

The OBPF co-operated extensively and, through the representation of multiple global manufactures on the Board of the OBPF, submitted a significant amount of information to the report authors for use in the compilation of this study.

The OBPF considers that generally the report, while containing some minor technical inaccuracies (which we do not consider it necessary to detail and discuss in this document at this time) and unsubstantiated opinions, is a balanced and positive review of oxo-biodegradable plastics technology. The report provides a suitable platform for further discussion and development of opinions and understanding with regards to this highly useful class of materials

The Articles of Association of the OBPF detail the reasons for the formation of the federation by leading OBD developers and producers:

To promote certification programmes…..
– To educate and promote public awareness of oxo-biodegradable products….
– To promote scientific, economic and social research into the development of products, applications, and systems deriving from and using oxo-biodegradable products.
– To provide informed and considered information…….
– To promote the appropriate use of oxo-biodegradable products through participation in development of standards, legislation, regulations….

The OBPF fully supports awareness through education and its members are available and willing to enter in to proper debate and discussion on all spects of oxo-biodegradable plastics technology with the relevant EU authorities as required, and we look forward to the opportunity to do so.

A review of various recommendations and items within the report follows below.

The OBPF is in agreement with the main recommendation of the study:

The debate around the biodegradability of PAC plastic is not finalised, but should move forward from the assertion that PAC plastics merely fragment, towards confirming whether the timeframes observed for total biodegradation are acceptable from an environmental point of view and whether this is likely to take place in natural environments”.

The OBPF is pleased that the authors have understood and accepted the evidence of the extensive third party testing provided and gives due recognition that OBD plastics biodegrade. The OBPF would welcome the opportunity to work further with the relevant EU group(s) to assist in moving the debate forward to focus on whether polymeric materials are fit for the application in which they are used, whether they be oxo-biodegradable, compostable or otherwise.

The report suggests that whilst OBD plastics can biodegrade under certain circumstances:

“There is still doubt as to whether they do so fully or within reasonable time periods in practice (and acknowledging the impracticality of defining what a ‘reasonable’ time period might be)”.

The OBPF recognises the need for this debate with consideration for the rates and extents of biodegradation achievable in the natural environment rather than those defined for the hydro-biodegradable polymer industry for degradation in the artificial environment of industrial composting, which it should be noted does not require complete biodegradation to be achieved.

The OBPF agrees with the report findings for the need for standard certifications and accreditations and would welcome the opportunity to assist with EU standard authorities in the compiling. OBPF members are active in the field of OBD standards and would welcome the opportunity to utilise their knowledge and expertise in the resolution of this matter. The issue can be simply summarised: how do you standardise the natural environment?

Regarding the toxicological effects of OBD whilst positive:

Whilst it has not been conclusively proven that there are no negative effects, it does appear that the PAC plastics industry can create products that have minimal toxic impact on flora and fauna’

The OBPF disagrees with the opinion that the lack of toxicological effects have not been conclusively proven, as it is general practice through ASTM D6954-04 (2013) for residues of biodegradation to be tested for ecotoxicity effects to internationally recognised tests – OECD 207 & 208 (amongst others) – the same tests used to assess the effects of herbicides, pesticides etc on the natural environment, and have been demonstrated to pass these requirements satisfactorily even when tested at levels >X10 the maximum required concentration. It should also be noted that if OBD material had toxicological effects on the environment then they would also stop the biodegradation process, which they again have been proven not to.

The message on littering appears to be confused:

There is a suggestion, on the basis of the evidence which is available, that indicates a greater tendency for littering to occur if the user believes that the substance is ‘biodegradable’. Although there is no noticeable physical difference between PAC plastic (until it starts to fragment) and conventional plastic, specific markings can be placed on products at the point of manufacture to differentiate a PAC plastic product. It is also possible indeed it seems quite likely that there would be some form of marketing extolling the claimed benefits of PAC plastic products in this regard. Consequently, it may be that littering of PAC products is more likely because of claims regarding their biodegradability. Nevertheless, rather than speculation, objective behavioural research is required to move this topic forward in a constructive manner.

The OBPF considers the highlighted sections to be unsubstantiated supposition which while recognised as speculation by the authors do give the reader the impression that they are pseudo-facts. However we welcome to final conclusions for the need for objective behavioural research to be performed.

The OBPF also considers the reported opinion of the recycling industry as a further example of unsubstantiated supposition:

“Opinions and anecdotal evidence provided by the plastics recycling industry indicate there is significant risk associated with PAC plastic due to the way in which it is perceived by reprocessors”

There have been many studies performed by reputable test houses researching various aspects of the inclusion of OBD plastics in the recycle stream which have positively demonstrated their suitability for recycling. It is further disappointing to consider that a principal member of the OBPF has actively tried to positively engage the recycling industry via the British Plastics Federation in order to design and implement a recycling study which has repeatedly been ignored.

We find the introduction of yet further terminology to the debate unnecessary:

‘Pro-oxidant Containing (PAC) Plastic – Plastic material that contains additives that may accelerate the oxidation of the material under certain conditions. This may then promote follow-on biodegradation.’

The OBPF considers this further terminology as unnecessary and a principal barrier that the oxo-biodegradable market suffers from. Oxo-biodegradability has been continuously and consistently been proven to occur as defined by CEN/TR 15321. This additional terminology has been introduced in a report which refers, from the title onwards, to proven oxo-biodegradability as “oxo-degradable” even when these products have been demonstrated clearly to “oxo-biodegrade” when tested to ISO14855 for biodegradability – the same test standard utilised in EN13432.

The OBPF considers it judicious to bring to the attention of the readers that EN13432 is also a standard for “disposal in industrial composting” but has been and still is misrepresented as the only standard for biodegradability. In-fact biodegradability can take place in any biologically active environment, i.e. ISO/ASTM standards are available to assess the biodegradability in the marine environment which is completely different to an industrial composter, but is still biodegradability. This “hijacking” of the definition of biodegradability has in our experience made and continues to be propagated by the hydro-biodegradable material producers for commercial gain. It is only necessary to see the published comment on this report by European Bioplastics (http://www.european-bioplastics.org/new-report-calls-to-suspend-the-use-of-oxo-degradable-plastics/) as further evidence of the manner in which facts are deliberately misrepresented by the hydro-biodegradable industry to further their arguments against oxo-biodegradable plastics:

Report comment:
“In the meantime the PAC plastics industry should be prevented from selling their products into markets that have been conclusively proved to be unsuitable—primarily composting and AD markets.”

European Bioplastics published comment:
‘In the meantime, the report concludes, “the PAC plastics industry should be prevented from selling their products”.’

No further comment is required here on this disgraceful misrepresentation.

Dr Gary Ogden FIMMM CSci, Chairman OBPF
Mr Ray Loflin, Secretary, OBPF

8th May 2017