March 17th, 2021

 

The Editor

The Conversation Australia and New Zealand

 

Re: Article published March 9, 2021 entitled “Biodegradable plastic will soon be banned In Australia. That’s a big win for the environment”   and amended to “A type of ‘biodegradable’ plastic will soon be phased out in Australia. That’s a big win for the environment”

 

 

Dear Editor,

We write in response to the above referenced article. Since publication, the Association has received countless inquiries and requests for clarification from concerned stakeholders, members of the public all reflecting community concern that certified compostable products might be banned when these individuals are already using them to great advantage in the diversion of organic waste from landfill to commercial or home composting.

Even though the title states biodegradable, it is implied that certified compostable products, which have the inherent property of biodegradability at end of life, are somehow targeted by the National Plastics Plan, which is quite clearly not the case, in stark contrast to the headline.

We therefore feel the need to clarify some of the points that have been carried in the article and for the purposes of responding we have italicized them.

The Australasian Bioplastics Association Incorporated (ABA) is the peak Industry body for the bioplastics industry in Australia and New Zealand. The two images representing Home Compostable and Compostable “labels” are registered trademarks and logos owned and administered by the ABA as part of its AS4736-2006 and AS5810-2010 Standard’s verification program for companies or individuals offering products and wishing to confirm that these products comply with the stringent requirements of either or both of the two Australian Standards.

The ABA is at great pains to have members and non members alike whom offer products to the market with the intended end of life of commercial composting or home composting verify their claims to those Standards through its voluntary verification program. Upon successfully passing all of the requirements for the respective Standards, the ABA registered logos are licensed for use to the successful applicant.

The headline of “Biodegradable plastic will soon be banned In Australia” is fundamentally misleading. The National Plastics Plan 2021 recently released by the Commonwealth lays out a path to “Phase out non compostable plastic packaging products containing additive fragmentable technology that do not meet relevant compostable Standards”.

The National Plastics Plan does not conclude to ban “biodegradable plastics”. The Plan specifically seeks to “phase out non compostable plastic packaging products containing additive fragmentable technology that do not meet relevant compostable Standards“. All products verified by the ABA program meet these relevant Standards.

The oxo-degradable, oxo-biodegradable, enzyme mediated, landfill biodegradable products or in other words additive fragmentable technologies, are not certified compostable and do contribute to microplastics in the environment as they fragment during their service life.

Why ‘biodegradable’ isn’t that great

In the case of simply labelling a product “biodegradable” the ABA does not support this in any way because in our view, a simple label of “biodegradable” is an unqualified claim and does not inform the consumer,

  • under what conditions does a product biodegrade if it biodegrades at all
  • what are the byproducts of biodegradation if it biodegrades at all?
  • when does the biodegradation occur and what triggers the biodegradation if it biodegrades at all or?
  • over what timeframe does the biodegradation take place if it biodegrades at all

It is universally acknowledged that biodegradation is a biological process initiated by microorganisms in an aerobic environment, such as composting. It is equally universally accepted that the outcomes of this biological process are carbon dioxide, water, and new biomass.

One way that is also globally accepted to confirm that a product has the inherent property of biodegradability is by proving that product, material or article conforms to Internationally accepted Performance Standards or Standard Specifications.

As no internationally accepted Performance Standard or Standard Specification for biodegradation exists, in the case of Australia and New Zealand the ABA considers the appropriate Performance Standards that ensure the inherent property of biodegradability exists, are Australian Standards 4736-2006 and AS 5810-2010.

These are the relevant composting Standards referred to in the National Plastic Plan.

Biodegradable plastic promises a plastic that breaks down into natural components when it’s no longer wanted for its original purpose. The idea of a plastic that literally disappears once in the ocean, littered on land or in landfill is tantalising — but also (at this stage) a pipe dream.

The ABA does not support the unqualified use of the term biodegradable. The term certified compostable is preferable as it conveys both the intended end of life for the article and confirms that in that end of life, complete biodegradation and ultimate disintegration is going to occur naturally.

Verification to the requirements of Australian Standards AS4736 and AS5810 proves that the inherent property of biodegradation exists through the successful passing of tests required by the Standards, but they are not a solution to littering.

At this stage Standards do not exist for marine biodegradation and when they are in place, will also neither be a solution to nor encourage littering into the environment, whether marine or terrestrial.

Littering is a behavioural issue. Conformance with the requirements of any Standard does not reduce the need for appropriate anti littering practices and education.

A major problem with “biodegradable” plastic is the lack of regulations or standards around how the term should be used. This means it could, and is, being used to refer to all manner of things, many of which aren’t great for the environment.

Certified compostable products, which are inherently biodegradable, are not a problem per se, as certification proves that the property of biodegradation exists. The  point here is about use of the term “biodegradable” as an unqualified claim and that there is a lack of regulations or Standards around how the term should be used.

In addition the ABA does not support and advises its members and non members alike to not use the term “biodegradable” in any way. The ABA believes this unqualified claim should be replaced with the wording certified compostable, in accordance with Australian Standard AS 4736 / 5810.

The making of environmental claims is in fact a regulated space.

The ACCC published a document, which fundamentally deals with plastics bags but nonetheless extends to other articles where such claims may be made and the considerations for use of such claims.

Additionally, the ACCC monitors this space and provides guidance on environmental claims – “Green marketing and the Australian Consumer Law” – available here.

The ABA directs members and non-members to these documents for guidance on making environmental claims.

Certainly there are many products marketed in ways which might be considered false, misleading, unqualified and when these come to the attention of the ABA, the ACCC is advised.

The lack of infrastructure to collect and process food waste is not a negative for the use of certified compostable plastics. Where a certified compostable product is used in the source separation or collection and the organics recycler can process them, certified compostable products add value to diversion of organics from landfill.

It is well documented in jurisdictions around the world that certified compostable products enable growth in infrastructure to accept the certified compostable products and increase the diversion of food waste and food soiled products, including bags and packaging, to the organics recycling sector.

Growth in organics recycling is critical for the replenishment of organic carbon into degraded soils, so providing for food security and economic development in that sector.

In appropriate applications, a certified compostable alternative to conventional plastic can help facilitate source separation and hygienic disposal of organics to organic recycling while assisting with the elimination of non-recyclable and non reusable packaging from the landfill stream.

Many plastics labelled biodegradable are actually traditional fossil-fuel plastics that are simply degradable (as all plastic is) or even “oxo-degradable” — where chemical additives make the fossil-fuel plastic fragment into microplastics. The fragments are usually so small they’re invisible to the naked eye, but still exist in our landfills, water ways and soils.

Proponents of fragmentable plastics, plastics with an additive incorporated to accelerate fragmentation under some conditions, claim the product to be biodegradable on the land or in landfill. None meet the requirements of internationally consistent compostability standards, including Australian Standards AS4736 or AS5810. None.

Oxodegradable, oxo-biodegradable. landfill biodegradable or enzyme mediated plastics are all synonyms for similar technologies that culminate in fragmentation of the conventional plastics, normally polyethylene, which result in additional accumulation of microplastics in the environment. It is these products referred to in the National Plastics Plan as “products containing additive fragmentable technology”.

As noted previously, certified compostable plastics are not a solution to the litter problem, a position strongly held by the ABA. Biodegradation in commercial and home composting conditions is a natural process requiring no pre-treatment.

Put simply, certified compostable products compost with the organics (food waste) they contain rather than simply disintegrate or fragment contributing to micorplastic contamination.

Compostable plastics aren’t much better

This section of the article implies that simply because collection services are not in place there is no value in certified compostable products.

The focus here should be on diverting food waste from landfill. With bans on organic waste to landfill there would be a signal to the organics recycling sector to continue the ongoing scaling up of the industry to accommodate more processing capacity for organics. The benefits of organics recycling are well understood and the Australian Organics Recycling Association (AORA) has recently published a document that quantifies the economic contribution of the sector.

Certified compostable plastics are endorsed for use in FOGO collections which will increase in number in the future as we move towards more diversion of organics from landfill to a more beneficial end of life. A list of all of AORA’s policies is available here.

The inclusion of certified compostable products in FOGO and other organics recycling processes helps facilitate that main purpose, which is organics recycling. If they can add value through hygienic source separation which ultimately aids in diverting food waste or food soiled articles from landfill, as these food soiled items are not recyclable nor reusable, then this is an example of an appropriate and beneficial use of certified compostable products.

Certified compostable products are designed to be used in solving the most problematic packaging or food waste issue if it is appropriate and makes sense.

Where can my plastic go, (infographic.)

Certified compostable products are suitable for both commercial and home composting. The Technical Committees that devised the test methods and the Standards were made up of a mix of entities that included Federal Government, agencies, academics, and industry. A full list of the Members of the respective Technical Committees is carried within each of the Standards.

Consideration was given to the conditions that exist in both commercial and home composting environments and were decided upon as resembling real world conditions and conducted under laboratory conditions necessary for reproducibility and accurate recording of performance.

Conditions in commercial composting vary from process to process however the purpose of achieving high temperatures as prescribed by the compost Standard AS 4454 of greater than 55 degrees C and above is not so that certified compostable products can biodegrade but to pasteurise the composting organic matter in order to sterilize harmful pathogens and kill weed seeds and effectively make the material safe for land application as a compost. This is a natural process driven by thermophilic bacteria naturally found in the organic matter.

The conditions in both commercial and home composting are conditions precedent to the advent of compostable plastics and are industry best practice for the safe production of organic outputs. Home composting of certified home compostable plastics in a well managed situation occurs perfectly well at ambient temperatures.

More focus should be placed on the lack of clear direction regarding mandatory organics diversion and source separation of organic wastes which does not exist sufficiently today and question why are we not banning organics from landfill.

Commercial composting and other organics recycling facilities do exist. The number of facilities is growing globally particularly in countries where organics to landfill is a prohibited practice. For example, Victoria’s new Recycling policy seeks to double the processing of organic waste in the next decade and certified compostable products have a part to play in that objective, where appropriate.

Australians perhaps do not appreciate the actual value of recycled organics that should be heading back to our degraded soils as composts, soil conditioner and mulches, rather than pouring into landfills where they generate methane under anaerobic conditions and escapes as a powerful greenhouse gas.

Certified compostable plastics can and do make sense and amongst other things  raise consumer awareness of source separation, clean feedstock for processors, cleaner bins, the reduction of organic waste to landfill and the great value of compost for soils.

We would like to continue the discussion on these topics and look forward to your comments in due course.

Yours sincerely

 

Rowan Williams                                                                   Warwick Hall

President                                                                                  Vice President

 

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