I have been reading a Communication on 30th November 2022 from the EU Commission (COM(2022) 682 final) on an “EU policy framework on biobased, biodegradable and compostable plastics.” It is not an impressive document.
In this 15-page Communication there is the usual reference to reduce, reuse, and recycle but there is nothing to address the principal problem with plastics, – that is the long-term pollution of the environment, and in particular the oceans, by plastic which does not get collected for re-use, recycling or anything else. The technology which was actually designed to address this problem (oxo-biodegradation) is dismissed in one sentence.
Instead, the Commission focus on bio-based plastics. They recognise that some of these are not biodegradable, and can therefore cause long-term pollution of the environment in the same way as conventional plastics. With regard to the bio-based plastics marketed as “compostable,” they are biodegradable, but they are certified (according to EN13432) to biodegrade in an industrial composting facility, not in the open environment. They do not therefore address the pollution of the open environment if they escape, as some of them surely will. They are being used not only for caddy-liners but also for shopping bags, food-service ware, and other uses.
Even if they do get collected for composting, a study by the University of Bayreuth shows that “finished compost from composting facilities contains a large number of biodegradable plastic particles” which then get spread on land used for food production.
Sending plastic to a composting facility is a deliberate linear disposal route, as EN13432 requires it to convert into CO2 gas within 180 days. The plastic is therefore intended to be wasted. Also, a material that converts into CO2 not into compost, cannot be described as compostable, and the Commission should take action against companies who are so describing it.
Bio-based “compostable” plastic is also inconsistent with a circular economy because it cannot be re-used or recycled, nor can it be made from recyclate – three very important points which the Commission seem not to notice. Nor do they mention how much more expensive these plastics are, as compared with conventional plastic – an important point at a time when most of the people of Europe are struggling with a cost-of-living crisis.
The Commission say that “To fight greenwashing and avoid misleading consumers, generic claims on plastic products such as ‘bioplastics’ and ‘biobased’ should not be made.” Agreed.
The Commission also say that “plastics labelled as ‘biodegradable’ must always specify the receiving open environment for which they are intended and the required timeframe for their biodegradation, in terms of weeks, months or years. Therefore, plastic certified according to EN13432 for biodegradation in an industrial composting facility (not in the open environment) should not be described as “biodegradable” and the Commission should take action against companies who are doing this.
The Commission are also concerned about deception of the public by marketing a plastic product as “biobased” when the product may contain a substantial component of oil-based plastic. They say “In order to avoid misleading consumers, claims should only refer to the exact and measurable share of biobased plastic content in the product, stating for instance, that the ‘product contains 50% biobased plastic content.’ They should take action against companies who are not making this clear.
They add “Documenting the use of biomass through a chain of custody and attributing a share to end-products through mass balance accounting is a method which is not considered suitable for confirming the actual share of biobased content.”
LAND AND WATER RESOURCES
The Commission also say that “In most cases, the production of biomass requires the use of natural resources such as land and water and the use of chemicals such as fertilisers and pesticides. Therefore, producing plastics from primary biomass can lead to direct or indirect land-use change, which in turn can result in biodiversity loss, ecosystem degradation, deforestation and water scarcity, as well as competition with crops intended for human consumption.” The Commission are therefore discouraging the use of corn or potato starch to make plastics, as distinct from materials from non-food sources such as algae, being produced by companies such as Eranova in France.
So why do the Commission think that biobased plastics are at all useful? They wish to discourage the use of fossil resources to make plastic, but they accept that biobased plastic can itself contain 50% biobased plastic content. Also, the production and polymerisation of feedstock, even from vegetable waste, uses fossil fuels and generates emissions. By contrast, ordinary plastic and oxo-biodegradable plastic are made from a by-product of oil and gas which are extracted for fuels. Until the day arrives when they are no longer needed for fuels, it makes sense to use the by-product, and there is no present need for biobased plastics, even if they were useful.
The Commission say “in most of today’s biobased plastic products such as single-use packaging, the carbon initially taken up from the atmosphere is quickly released back” and “As biodegradable plastics are predominantly used in relatively short-lived applications such as food and beverage packaging, the resources used to produce these products are rapidly lost.” This is a linear process, so how can this type of plastic be consistent with a circular economy? The Commission also say that “More work is needed to assess and reduce the net greenhouse gas emissions of biobased plastics compared to their fossil-based equivalents, taking into account the lifetime of recycling applications and the possibility of multiple recycling.” In fact, Life-cycle Assessments by Intertek show that ordinary plastic and oxo-biodegradable plastic have lower net greenhouse gas emissions than biobased plastics.
The Commission seem to think that biobased plastic is useful for transporting food-waste for processing, but the composters and local authorities do not want it (Plastic Composting). Epsom Borough Council in the UK said “We used to ask you to use bio-liners to line your food-waste caddy, but the food-waste recycling companies found that bio-liners compost down much more slowly than the food. That slowed the recycling process and made it much more expensive. They tried dredging the bio liners out of the food-waste, but the sticky bio-liners got tangled around the dredging equipment. Cleaning them off was very expensive, so they found that using plastic bags was, overall, much more cost-effective.” In Parliament on 14th November 2022 the UK Minister for the Environment confirmed that “evidence suggests these materials are often stripped out at the start of the process and landfilled or incinerated”
The Commission makes an unsupported claim that biobased plastics can stimulate the creation of jobs, but this is not likely to be the case without subsidies out of taxpayers’ money. Also it fails to recognise job losses in the conventional plastics industry, and extra costs for reorganizing the supply chain, re-equipping factories, and retraining the workforce.
The Commission say that “Home composting is more challenging in terms of ensuring full biodegradation of compostable plastics and requires a greater degree of precaution. Compliance with standards for industrial composting does not imply decomposition also under home composting.” Correct.
They continue “Home composting for plastics not covered by EU rules should only be considered in the context of specific local conditions under the supervision of the relevant authorities and provided that the use of such plastics has clear added value.”
This makes no sense at all. How can a compost pile at the bottom of the garden be “supervised by the relevant authorities” (whoever they may be) and how can it be affected by “specific local conditions?” How can an expensive plastic bag add value when it simply converts to CO2 gas, not compost and could be the source of microplastics? Why in any event would anyone buy these bags when they could take kitchen waste to the bottom of the garden in a bucket?
On 2nd December 2022 the UK Government noted in Parliament the findings from UCL’s study into the home composting of plastics, which has shown that “home composting is not a viable destination for managing plastic waste.”
In October 2022 the French Agence Nationale de Sécurité Sanitaire de l’alimentation, de l’environnement et du travail (ANSES) said that “Even for those plastics claiming to be “biosourced, biodegradable or compostable” it is not guaranteed that they will degrade completely in domestic composters, especially since it is difficult to control the operating conditions. Therefore, when an individual spreads compost in his vegetable garden to grow vegetables, for example, contamination of the environment or crops cannot be excluded.”
“This contamination can come from the different constituents of the materials, or from microplastics resulting from their degradation. The constituents concerned may be polymers, residual monomers, additives or inorganic fillers presenting potential hazards to both human health and the environment.”
“ANSES therefore recommends that no plastic, even if labelled “biodegradable” and/or “compostable”, be placed in domestic or collective composting facilities.”
The Commission say “Mulch films used in agriculture are good examples of suitable applications of plastics that biodegrade in the open environment.” Correct.
They continue “Conventional – fossil-based and non-biodegradable – plastics are widely used to promote higher yields, earlier harvests, less reliance on herbicides and pesticides, to protect against frost and to conserve water. But proper management of these plastics in agriculture at their end of life is problematic. In 2019, only around 63% of agri-plastic (non-packaging) waste generated in the EU was collected, while the destination of the remaining 37% is unknown – either stored, burnt, buried or collected with other waste. Despite their high potential for recycling, only 24% of agri-plastic plastics placed on the market every year in the EU is currently recycled.”
I do not agree that they have a high potential for recycling, because they will have been lying in the fields exposed to sunlight, and will have become brittle and unsuitable for recycling. They will have created microplastics but will not have become biodegradable because the molecular-weight is still too high. The best type of biodegradable plastic for mulch-films is oxo-biodegradable, because the timescale for degradation and biodegradation can be customized according to the type of crop, the time of year, and the climatic conditions. This is done by adjusting the relative effects of the catalyst and the stabilisers within the masterbatch, but this cannot be done for bio-based plastics.
Successful farm trials have been done for d2w plastic. See https://www.biodeg.org/wp-content/uploads/2020/09/Pembroke-Mulch-Film-Trial-Report-30.09.13V1.pdf The commercial benefit of using d2w plastic film is that the farmer will no longer have to pay to have acres of contaminated, and fragmented, plastic removed from his farm. The environmental benefit will be that heavy vehicles will no longer have to drive around the country lanes collecting contaminated plastic, spreading plastic particles in the loading and unloading process, consuming fossil fuels, emitting pollutants, and occupying road space.
In short – Bio-based plastic marketed as compostable:
- Does not convert into compost (EN13432 and ASTMD6400 require it to convert into C02 gas)
- Is designed for a deliberate linear disposal process and is not circular. The material is intended to be wasted and lost to atmosphere by conversion to CO2 in a composting facility..
- Cannot be re-used, recycled, or made from recyclate
- 4. Leaves microplastics in the compost and in the open environment
- Does not deal with the problem of plastic litter in the open environment
- Is not wanted by industrial composters and local authorities.
It should not therefore be described as compostable or biodegradable. It should not be made mandatory for any purpose, and should instead be banned.
The Commission should be encouraging oxo-biodegradable plastic because:
- It can be used, re-used and recycled in the same way as ordinary plastic
- There is little or no extra cost
- If it escapes into the open environment it will biodegrade much more quickly than ordinary plastic, without leaving microplastics or toxic residues. The shorter the dwell-time the lower the potential for harm.
Michael Stephen is a lawyer and was a member of the United Kingdom Parliament, where he served on the Environment Select Committee. When he left Parliament Symphony Environmental Technologies Plc. attracted his attention because of his interest in the environment. He is now Deputy Chairman of Symphony, which is listed on the AIM market of the London Stock Exchange, and is the founder and Chairman of the Biodegradable Plastics Association.
Earlier Postings in this Column
All articles of Michael Stephen can be found here
- 1/ 1/ 20 – Plastiphobia, Microplastics and A Throw-Away Society
- 7/ 1/ 20 – Recycling, Lab Testing, Bangladesh and the Right Bioplastic
- 14/1/20 – Plastiphobia and Bioplastics Definitions
- 21/1/20 – Composting, the European Union and Unemployment
- 30/1/20 – Plastiphobia, Malaysia and a Case Against Compostables and Paper
- 7/02/20 – Coronavirus, MPs Letter, Montreal, Australia and the Dominican Republic
- 14/02/20 – Oman, MacArthur Foundation, Stifling Innovation, South Africa and Compostable Plastics
- 24/02/20 – Serbia, India, Pakistan and European Bioplastics
- 03/03/20 – Plastic To Protect Health and Common Sense on Plastic
- 10/03/20 – Plastiphobia, Singapore, Compostable Plastics, Doorknobs and Carbios
- 17/03/20 – Greening our Way to Infection, Defra Warns Against Bioplastics and Montreal
- 24/03/20 – Ditch the Plastic Bag Ban and Inn-Probio
- 01/04/20 – The Come Back of Plastic Bags, Compostable Plastic Not Wanted and EASAC
- 16/04/20 – Coronavirus and Agricultural Plastics
- 11/05/20 – Coronavirus, Peru, Barbados and Recycling
- 18/05/20 – Say No to Plastiphobia, False Descriptions and the Recycling Myth
- 02/06/20 – Definitions and More Setbacks for Plastiphobia
- 11/06/20 – BBIA, Food Waste and Testing of OXO-Biodegradable Plastic
- 19/06/20 – Oxo Biodegradation, Independent Reports and Precautionary Principle
- 29/06/20 – Banana Republic, Why Turn Plastic into CO2 and Plastic Waste from Ships
- 13/07/20 – Running Scared, The Daily Telegraph and Market Report
- 20/07/20 – Tipa, Plastics Today and The American Genius
- 27/07/20 – Coronavirus, Plastic Litter, Bahrain and Polymateria
- 17/08/20 – Plastics Europe, Confusing Issues and Paper
- 25/08/20 – Professor Emo Chiellini, Plastics Today, Greenwashing and Coronavirus
- 28/09/20 – Kill the Virus, Marine Degradation, Airports, Brazil Retail, Plastic Growth and Face Mask
- 08/10/20 – Compostable vs Biodegradable, Covid 19 and New British Bioplastic Standard
- 27/10/20 – Power of Lobbying, Paper and Cotton Worse than Plastic
- 02/11/20 – Covid 19 and Five Myths About Plastic
- 09/11/20 – Support for OXO BIO, Westminster Forum, Euractiv and Covid
- 23/11/20 – Toxicity of Bio-based and Biodegradable Plastics, and Covid Scaremongering
- 15/12/20 – Recycling and An Article from Austria
- 21/12/20 – EU Scientific Advisers, China Chose Wrong Bioplastics and Covid Nonsense
- 05/01/20 – EU, Covid Lockdowns, WRAP, British Standards Institution and Polymateria
- 12/01/21 – Intertek and Composting
- 19/01/21 – Recycling and Exporting Plastic Waste
- 22/02/21 – Seaweed Plastic, Orange Peel and Xampla
- 02/03/31 – OXO Biodegradable Plastic
- 08/03/21 – EU Scientific Reports and Paper vs Plastic
- 15/03/21 – India, Australia and Dow Chemicals
- 14/04/21 – Oxomar, UK Government and Microplastics
- 26/04/21 – Plastic to the Rescue of Covid and More News from Brazil
- 04/05/21 – Packaging Digest
- 07/06/21 – Minderoo Report and Korea Herald
- 30/06/21 – Recycling, Is the Use of Biobased Plastics Increasing, Confused Australians and Biodegradable Future
- 12/07/21 – EU Flawed Directive, Thailand and Pakistan
- 21/07/21 – Directors Talk, Confusion, Stir Magazine and Dumping Plastic Waste
- 02/08/21 – Angry Farmers, DEFRA and Substitutes for Plastic
- 06/09/21 – Microplastics
- 13/09/21 – UK Government, Defra and David Newman
- 20/09/21 – Michael Stephen Video Interview on Antimicrobial and Biodegradable Packaging
- 05/10/21 – Freedom of Information and Plastic Waste Solutions
- 14/10/21 – Michael Stephen at Pack4Change Summit
- 22/10/21 – Plastic from Algae and Carbon Dioxide
- 15/11/21 – Defra
- 22/11/21 – Defra, India, Food Service Footprint Magazine and Waste 360
- 30/11/21 – RWM Digital Spotlight and Plastiphobia
- 17/12/21 – Disposal in the Right Way and Defra Consultation Responses
- 04/01/22 – Precautionary Principle, Anti Oxo Campaign and Defra
- 11/01/22 – Microplastics
- 17/01/22 – Michael Laurier, A Saucy Problem and Unilever
- 21/02 /22 – No Alternative for Plastic
- 08/03/22 – Sustainable Agriculture, Canada, Consequence of Banning, United Nations
- 14/03/22 – Plastiphobia
- 04/04/22 – Virgin Mobile, Defra, OXO, Microplastics, End of Life Options
- 11/04/22 – Ellen MacArthur Foundation
- 09/05/22 – Response to Association of Plastic Recyclers
- 16/05/22 – Wrap and More Bad News for Compostable Plastics in UK Parliament
- 30/05/22 – A Threat to Humanity and Market Research
- 13/06/22 – Recycling, OECD and the Ellen MacArthur Foundation
- 27/06/22 – Recyclass, Unilever, UK Plastic Packaging Tax
- 04/07/22 – Korea, Carbon 13 Study, Defra, Food Shortages and Biobased Plastics
- 09/08/22 – Oxford Analytica, Indonesia, Paper is not the Answer
- 16/08/22 – Video, Canada, The Guardian, Food Waste, Recycled vs Virgin Polymer
- 22/08/22 – Defra and Plastics in Agriculture
- 30/08/22 – Recycling and Food Waste
- 07/09/22 – Microplastics, Environmental Footprints and Coffee Waste
- 21/09/22 – DEFRA
- 4/10/22 – Agricultural Film and Global Plastic Treaty
- 10/10/2022 – Anti-Plastic Zealots
- 17/10/22 – Innovation and the United Nations
- 31/10/22 – Defra Finally Complies with Disclosure Order
- 7/11/22 – Time to Ban Compostable Plastics? Also SUP Legislation in Wales and Scotland
Interview with Michael Stephen
The opinions expressed here by Michael Stephen and other columnists are their own, not those of Bioplasticsnews.com