Michael Stephen Column

Comments on the UK Advertising Standards Authority survey (FREE)

Today Michael comments on a survey commissioned by the UK Advertising Standards Authority. This is a FREE article

I have been reading the report of a consumer survey for the Advertising Standards Authority (ASA)  Consumer Understanding of Green Disposal Claims in Ads

The ASA is responsible for ensuring that consumers are not misled by claims on products or in advertising when deciding which products to buy, and a representative selection of consumers were asked how they perceived “compostable” and “biodegradable” claims.

The survey found, perhaps to the surprise of the ASA, that “Consumers rarely gave strong consideration to waste disposal at point of purchase or when engaging with advertising.” Also, “most participants engaged with green disposal terms at the point of disposal rather than point of purchase. As a result, most did not consciously think about the meaning or role of terms in advertising without prompting.”

Also, “green disposal terms like these were not considered a driver of purchase”

For many “cost considerations overrode environmental considerations.”

And then, “environmental claims can work against the likelihood of purchase. The belief that environmentally-friendly products come with a price premium, is so ingrained, that it seemed that some do not confirm this hypothesis by actually checking prices.”

COMPOSTABLE

Participants were asked about plastics products marketed as “compostable.”  They thought that “compostable products could result in ‘usable’ outcomes (e.g., soil).”

The participants had been given a definition of compostable as follows: “If a product is compostable, it is made from materials that can break down into simpler parts, such as water, oxygen and compost.  Unlike biodegradable products, compostable products break down into natural substances within a specific, defined time frame.”

Participants have been misled by this definition, because they were not told that plastic marketed as compostable does not result in ‘usable’ outcomes.  It does not convert into compost – it converts into CO2 gas, as required by EN13432 and ASTM D6400.  The ASA should therefore prohibit the description of any plastics as “compostable.”

“Understanding the complexities behind the terms ‘compostable’ and ‘biodegradable’ provoked stronger reactions of surprise, confusion, frustration, and, in some cases, anger, with some participants concerned the terms were misleading without sufficient qualification.  The phrase ‘compostable plastics’ was felt misleading given the very specific, specialist and additional requirements needed to achieve the environmentally friendly outcome.”

For this reason the ASA should prohibit the description of this type of plastic as “biodegradable” as consumers would think that a product marketed as biodegradable would biodegrade in the open environment, not in the very specific, special conditions found in an industrial composting unit.

“Participants were reassured to learn there were defined timescales for when a product is described as compostable in ads” but they were not told that these timescales might not be met in practice and that microplastics might be left in the soil. See https://www.chemeurope.com/en/news/1176729/ and https://www.anses.fr/fr/proscrire-matieres-plastiques-biodegradables-compost

Consumers were “alarmed to learn about the potential for ‘contamination’ of recycling by non-recyclable products, such as compostable plastics.”  This is a very real concern, because the difference between a “compostable” plastic product and an ordinary plastic product may not be obvious, and a post-consumer recycling stream could easily be contaminated.  This would not be the case with oxo-biodegradable plastic, which has been proved to be recyclable by tests at AIMPLAS according to the APR Protocol.

BIODEGRADABLE

Participants were asked about biodegradable plastic. However this question caused confusion because they were not told about the difference between oxo-biodegradation and hydro-biodegradation, which are completely different processes.

There is no mention of oxo-degradable or oxo-biodegradable plastic in the survey, but Participants were told that “Different products require specific conditions to breakdown fully, depending on the process of biodegradation, and if biodegradable items end up in landfill, they won’t be exposed to the natural conditions required to breakdown (as landfills shut out sunlight and moisture and have reduced oxygen levels).”

Participants were misled by the assumption implicit in this definition that biodegradation is desirable in a landfill. In fact, biodegradation in anaerobic conditions generates methane, which is a powerful greenhouse gas, and landfill operators do not want biodegradation unless the landfill is designed to collect the gas – which most of them are not.

Participants were further misled by the definition given to them that “Some things are naturally biodegradable, like food and plants, while other items can sometimes break down into harmful by-products – for example, some forms of biodegradable plastic can break down into harmful micro-plastics, much like traditional plastics.” 

The “forms of biodegradable plastic” were not specified. As mentioned above, it is true that the type of plastic marketed as biodegradable and compostable can create microplastics https://www.chemeurope.com/en/news/1176729/  and https://www.anses.fr/fr/proscrire-matieres-plastiques-biodegradables-compost but it is not true of oxo-biodegradable plastics.

As I have said many times in this column the European Chemicals Agency advised on 30th October 2018 that after a public call-for-evidence and ten months study they were not convinced that microplastics were formed. Microplastics are formed by the disintegration of ordinary plastics after exposure to sunlight, but the process of oxo-biodegradation converts the plastic into hydrophilic oligomers, which are not plastics and are biodegradable.

Participants were told that “most things can be called biodegradable because they will eventually break down – but there are no set definitions around how long a biodegradable product can or should take to break down.” This is correct, for the quite simple reason that the speed of biodegradation in the open environment will be fast or slow depending on the heat, light, and other conditions at the relevant place and time.  It is however certain, that oxo-biodegradable plastics will biodegrade with a significantly higher efficiency than conventional plastics – Queen Mary University London https://www.biodeg.org/wp-content/uploads/2022/10/QM-published-report-11.2.20-1.pdf says up to 90 times faster. The process of degradation once commenced will continue even in cold dark conditions.

It is possible to specify a timescale for biodegradation in the very specific, special conditions found in an industrial composting unit but for the reason mentioned above it is not possible, and never will be, to specify a timescale for plastics which are designed to biodegrade if they become litter in the open environment. Consumers need to be advised and the ASA need to understand, that these plastics are not intended for composting, and do not therefore need to biodegrade in the short timescale required by the industrial composters and specified in EN13432 and ASTM D6400.

Advertising and labelling for this type of plastic should not therefore be required to specify a particular timescale, and consumers can be informed only that it will biodegrade much more quickly than ordinary plastic in the same place at the same time.  Oxo-biodegradable plastic is not a waste management option, and consumers should dispose of it in the same way as ordinary plastic – it is there in case waste management fails and the product gets into the open environment as litter.

Irresponsible manufacturers and retailers are all too often deceiving their customers by claiming that products are oxo-biodegradable by affixing the logo of a reputable masterbatch supplier, such as Symphony’s d2w logo, but not including the masterbatch in the right quantity or at all.  Plastic products should not therefore be sold as oxo-biodegradable, nor bear the logo of a masterbatch supplier, unless the seller can produce evidence that the product has been correctly made with that supplier’s masterbatch which has been successfully tested according to ASTM D6954, BS8472, SASO 2789, ASTM D5338, ASTM D5988, ISO 14855, ISO 17556 or similar.

“Oxo-degradation” is defined by CEN (the European Standards authority) in TR15351 as “degradation identified as resulting from oxidative cleavage of macromolecules.”  This describes ordinary plastic, (which does not contain a prodegradant additive).  It will abiotically degrade by oxidation in the open environment and create microplastics, but does not become biodegradable except over a very long period of time.

By contrast, “oxo-biodegradation is defined by CEN as “degradation resulting from oxidative and cell-mediated phenomena, either simultaneously or successively”.  This means that the plastic (which does contain a prodegradant catalyst) degrades rapidly by oxidation until its molecular weight is low enough to be accessible to bacteria and fungi, who then recycle it back into nature.

Plastic manufacturers do not describe plastic as “oxo-degradable,” and confusion is often caused by NGOs and others using the term “oxo-degradable” when referring to “oxo-biodegradable” plastic.

CONCLUSION

The ASA should:

  1. prohibit the description of any type of plastic as “compostable.”
  2. prohibit the description of plastic as “biodegradable” unless it is designed and tested to biodegrade in the open environment.
  3. Not require any specific timescale to be specified for plastic designed and tested to biodegrade in the open environment.
  4. Not require any type of plastic to be proved to biodegrade in landfill.
  5. Prohibit the description of plastic as “oxo-degradable.”
  6. Prohibit the description of plastic as “oxo-biodegradable” unless the seller can produce evidence that the product has been correctly made with a masterbatch which has been successfully tested according to the relevant standards.

Michael Stephen

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 from Michael Stephen

Interview with Michael Stephen

Questions and Answers on OXO-Biodegradability


Disclaimer

The opinions expressed here by Michael Stephen and other columnists are their own, not those of Bioplasticsnews.com



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