WHY BIODEGRADABLE?
There is one thing on which we can all agree – that it is important to protect the environment, and especially the oceans, from plastic pollution.
Plastic products are immensely useful, especially for the poorest people, as they are very effective for protecting their food and water from contamination and deterioration. There is nothing wrong with polyethylene or polypropylene except that it can persist for a long time if it gets into the environment. It is made from a by-product of oil which used to be wasted, so until the world no longer needs petrol and oil for engines it makes sense to use this by-product. Oxo-biodegradable technology can also be used to confer biodegradability on plastics made from crops such as sugar-cane.
An important piece of research has just been published from the Universities of Sheffield, Stockholm, and Cambridge, concluding that care must be taken when formulating policies so that we do not inadvertently drive a shift to non-plastic alternatives with higher GHG emissions[1]. See also – Paper Bags[2]
We support efforts to improve waste management and to prevent the escape of plastics into the environment, but until these efforts are wholly successful throughout the world, we think that plastic products should be made so that they will not persist for decades, but will instead biodegrade and be returned to the eco-system by naturally-occurring bacteria and fungi. Indeed, the ONLY way to prevent plastic which has escaped into the environment from accumulating there for decades is to make it with oxo-biodegradable technology.
We would like to explain how d2w masterbatch technology can help to do this.
Professor Gerald Scott
The mechanism of abiotic peroxidation of hydrocarbons has been extensively studied over the past 50 years. D2w plastic was invented in the 1970s by Professor Scott and other polymer scientists [3] who had realised by then that polyethylene and polypropylene could cause an environmental problem if it escaped from the waste management processes and ended up in the open environment as litter.
So, knowing that much of it would not be collected, they discovered that if they introduced into the normal polyethylene or polypropylene a tiny amount of a catalyst (which is usually a salt of manganese or iron) the plastic would quickly become biodegradable if it escaped into the open environment, and be consumed by bacteria in the same way as nature’s wastes.[4] During its useful life it would perform in exactly the same way as normal plastic.
So their idea was that manufacturers would stop using ordinary plastic, and would upgrade it with their new technology at little or no extra cost. Sadly, this has not been adopted widely enough, so the plastic continues to lie or float around for decades. Prof. Scott said just before he died that if his invention had been more widely adopted the ocean plastic garbage patches would be much reduced.
He described it as “an insurance policy, to protect the environment if all else fails.”
In 2021 the Environmental Protection Agency of the USA issued a Report on their research into pro-oxidant masterbatches stating that they “could significantly reduce the persistence of plastic pollution without creating undesired by-products.”[5]
The reason why ordinary plastic is not biodegradable is that it comprises long entangled chains of molecules, which give it a high molecular-weight, and this is too high for the material to be accessed by microbes. The molecular-weight of ordinary plastic does reduce naturally over time, but it takes very many years -some say 100 years – before ordinary plastic ceases to be a plastic and has become biodegradable. So, what the d2w catalyst does is to cause the molecular chains to be dismantled by oxidation so that the material is no longer a plastic and becomes biodegradable. The important thing is not the size of the fragments, but the molecular-weight.
Light and heat will accelerate the process, but it will continue even in dark, cold, conditions. Moisture is not necessary for oxidation, and does not prevent it.
It is crucially important to understand how the hydrocarbon polymers degrade in the environment by a combination of peroxidation and bioassimilation and how the free radical chain mechanism can be controlled by antioxidants. It would be possible to make oxo-biodegradable plastic so that it started to degrade immediately, but it would then have no useful life. Sustainability must in practice be a compromise between commercial viability (i.e., cost-performance) and environmental acceptability. Bioassimilation of plastics residues in the environment is an essential but not the only requirement of technologically useful packaging plastic, and in most cases, plastics require a controlled lifetime before physical degradation commences.[6]
Life-cycle assessments by Intertek have shown that oxo-biodegradable plastic has a better LCA than the other materials used for packaging.[7]
Oxo-biodegradable plastic is now mandatory in Yemen, where the Government will not allow imports of a wide range of plastic products and packaging materials unless they are made with d2w and they will not renew the licences of factories who are found to be making the products in Yemen without d2w.[8] They have issued warning notices to factories, and Government inspectors and customs officers have been equipped with a hand-held device which can detect the presence of d2w in the plastic.
Yemen has a population of 28.5 millions, and produces more than a million tonnes of plastic products per annum.
The lobbyists for the “compostable” plastic industry will say that Yemen is a less-developed country and the government are allowing themselves to be duped into mandating a technology which doesn’t work. In fact they are following the lead given in their region by Saudi Arabia, Bahrain, and the UAE. They instructed experts to study the technology in detail and satisfied themselves that it will degrade and biodegrade in the environment much more quickly than ordinary plastic, leaving no microplastics or toxic residues behind.
So that is what d2w oxo-biodegradable plastic is for – but what is it NOT for?
- It is NOT a disposal route. The plastic is designed to be reused, recycled, and disposed of like normal plastic, but the d2w technology will make sure that if it gets into the open environment the molecular weight will rapidly reduce so that it becomes biodegradable.
- It is NOT primarily intended for Landfill, because if the plastic has been taken to landfill, it has been responsibly disposed of and there is no need for it to degrade. However, there will usually be enough oxygen in a landfill to cause degradation, and subsequent biodegradation.
- It is NOT for Composting[9]. Five short points on plastic marketed as “compostable”:
- It does not deal with the problem of plastic litter in the environment, because it is designed and tested to biodegrade in a composting facility, not in the open environment.
- It does not convert into compost (EN13432 and ASTMD6400 require it to convert into C02 gas)[10] It is therefore designed for a deliberate linear process and is not circular. The material is intended to be wasted and lost to atmosphere by conversion into CO2.
- It cannot be re-used, recycled, or made from recyclate
- It leaves microplastics in the compost and in the open environment
- It 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, and should instead be banned.
On 14th November 2022 the UK Environment Minister said “our call for evidence suggests these materials are often stripped out at the start of the process and landfilled or incinerated.”
On 2nd December 2022 the Minister said: “Compostable plastics must be treated in industrial composting facilities to be broken down and, when processed incorrectly, can be a source of microplastics and contaminate recycling streams….. This packaging does not contribute to a circular economy in the same way as packaging that can be reused or recycled into new packaging or products do, as compostable plastic packaging is generally intended to be used only once.”
ARGUMENTS AGAINST OXO-BIODEGRADABLE PLASTIC
There are a number of issues which are always raised:
- Microplastics. – Some of the microplastics found in the environment are coming from tyres and man-made fibres, and recycling is also a source of microplastics,[11] but most of the microplastics found in the environment are caused by the fragmentation of ordinary plastic when exposed to sunlight. These fragments are very persistent because their molecular weight is too high for microbes to consume them, and can remain so for decades.
This is why oxo-biodegradable plastic was invented. The plastic falls apart because the molecular chains have been dismantled and it is no longer a plastic. (When Ellen MacArthur Foundation asked Professor Jakubowicz for his advice He made this point, but they ignored it).[12]
The European Chemicals Agency (ECHA) were asked to study oxo-biodegradable plastic in December 2017. They made a Call for Evidence, and they advised after 10 months that they were not convinced that it creates microplastics. ECHA have never provided a dossier to support any ban on oxo-biodegradable plastic, and there is no evidence that microplastics from oxo-biodegradable plastic have ever been found in the environment.
d2w has been used for bread bags for more than ten years by the largest bread producer in the world (Bimbo bakeries) and there have been no problems with microplastics or recycling.
- that oxo-biodegradable plastic will contaminate a recycling stream and is incompatible with a circular economy. That is not correct, but it is correct for “compostable” plastics, which are not recyclable. Five points on recycling:[13]
- Recyclers have to assess the level of degradation of any plastic sent for recycling whether it is oxo-biodegradable or not. They cannot recycle plastic which has started to degrade after exposure to sunlight, whether it contains d2w or not.
- If the recyclate is to be used to make short-life products (eg food packaging) it does not matter whether it contains d2w, because biodegradation is actually desirable in case the item becomes litter.
- Stabilisation is therefore necessary only for long-life products, and the producer of long-life products would stabilise them in the same way whether the recyclate contains d2w or not. He does not need to know the proportion of d2w plastic in the feedstock, because normal stabilisation would neutralise any oxo-biodegradable residue.
- It is not therefore necessary to separate oxo-biodegradable PE or PP from conventional PE or PP before recycling, but if so desired oxo-biodegradable masterbatch could be made visible to automatic sorting equipment by including a marker.
- Oxo-biodegradable masterbatch is used in PE and PP, but NOT in PET.
- that recycling is preferable to biodegradation. Yes, but it is not possible to recycle plastic which has escaped into the open environment from which it cannot realistically be collected. The ONLY way to prevent it accumulating there for decades is to make it with a d2w masterbatch.
- has it been shown that oxo-biodegradable plastic will fully biodegrade? Yes, tests have been done by Intertek showing biodegradation of 92.74% (The percentage required by EN13432 for “compostable” plastic is 90%), and no reason has been shown why biodegradation should stop before it is complete. Tests will never find 100% carbon-evolution because some of the material converts into water and biomass. Even if it did not fully biodegrade, it would still be better than ordinary plastic, which would have created persistent microplastics but would not have biodegraded at all.
- EN13432 for “compostable” plastic requires biodegradation to be tested in a laboratory (not in a compost heap) but it is suggested that oxo-biodegradable plastic should be tested only in outdoor conditions. See however the statement of Dr. Graham Swift (Vice-chairman of the Technical Committee at ASTM) who says “It has been my experience that results from laboratory testing are very likely to be reproduced in the real world. I can see no cause for concern that they would not, and have seen no evidence that they have not.” [14]
- Further, a four-year interdisciplinary study, known as the Oxomar[15] project, has been sponsored by the French Government. The goal was to evaluate the biodegradation of OXO-bio in marine waters.
- In their conclusion the scientists reported that “We have obtained congruent results from our multidisciplinary approach that clearly shows that oxo-biodegradable plastics biodegrade in seawater and do so with a significantly higher efficiency than conventional plastics. The oxidation level obtained due to the d2w prodegradant catalyst was found to be of crucial importance in the degradation process.” Having established biodegradability the scientists did not find it necessary to continue the test until the material had completely biodegraded.
- See also the report[16] from Queen Mary University London by Rose et. al 11th February 2020. Para 2.6 says “prior to testing, samples of LDPE and oxo‐LDPE were surface‐weathered in sea water for 82 days, undergoing natural variations in sunlight and UV intensity.”
- In March 2024 researchers at Tokyo University confirmed the biodegradation of biodegradable plastics in harsh deep-sea environments. According to the leader of the team “To mitigate future marine plastic pollution, we must use biodegradable plastics in products where leakage into the marine environment is unavoidable.”
- that they cannot be sure how long the plastic will take to biodegrade in the open environment, but it is not disputed by anyone that it will be many times faster than ordinary plastic when exposed under the same conditions in the open environment. Queen Mary University say (at para. 2.3) up to 90 times faster.
- That oxo-biodegradable plastic encourages littering. However, much of the litter escapes by accident and is blown by the wind. Insofar as it is deliberate, would the kind of person who throws a plastic bag out of a car or train window bother to look for a label to see that it is biodegradable? There is in fact no reason to label the product as biodegradable because it is designed to be used and disposed of in the same way as ordinary plastic. Littering is in any event more likely with paper and cardboard which are known to be biodegradable, and plastics labelled as “compostable.”
PAPER [17]
It might be thought that paper is more environmentally-friendly than plastic – after all it is made from trees. But it doesn’t grow on trees, so the trees have to be destroyed to make the paper. In fact it takes 24 trees on average to make just one ton of paper.
It also takes more than four times as much energy to manufacture a paper bag than a plastic bag. Whole forests are cut down to make paper – forests that could be helping the environment by absorbing greenhouse gases.
Most paper bags are made by heating wood chips under pressure at high temperatures in a chemical solution. The chemicals used in paper production are toxic and contribute to pollution, including acid rain. They also pollute waterways, and the toxicity of the chemicals is long-term and settles in sediments, where it can work its way into the food chain.
In fact, paper bags produce 70% more air-pollutants and 50% more water-pollutants than plastic bags.
But it doesn’t end there. In 2005, the Scottish Government issued an environmental impact assessment[18] containing comparisons between a lightweight plastic bag and a paper bag.
Indicator of Environmental Impact
|
Plastic bag HDPE Lightweight | Paper |
Consumption of nonrenewal primary energy | 1.0 | 1.1 |
Consumption of Water | 1.0 | 4.0 |
Climate Change (emission of greenhouse gases) | 1.0 | 3.3 |
Acid Raid (atmospheric acidification) | 1.0 | 1.9 |
Air quality (ground level ozone formation) | 1.0 | 1.3 |
Eutrophication of water (algal blooms, dead zones, fish kills) | 1.0 | 14.0 |
Solid waste production | 1.0 | 2.7 |
Risk of litter | 1.0 | 0.2 |
As can be seen from the table above, paper has more adverse environmental impacts in almost every category. (A score greater than 1.0 indicates that the paper bag makes more contribution to that environmental problem than a lightweight plastic bag). See also the LCA done by Intertek for the UK Environment Agency[19]
Advocates for paper will say that paper bags are ‘green’ because they are 100% recyclable, and so they are in theory. In fact, paper can be recycled up to 7 times before losing its integrity, but a paper bag would need to be used at least 3 times to offset the environmental impact of its production. Paper bags are not durable enough to be used 3 times, and they rarely survive a single use, as they tear easily. Also, they are much heavier than plastic bags and are nowhere near as strong, so you would need more of them, and they completely lose their strength when wet.
Because paper is a lot heavier than plastic it costs a lot more to transport, and causes more pollution from transportation. According to a briefing paper published by the Northern Ireland Assembly in 2011[20] it would take approximately seven trucks to transport the same number of paper bags as can be transported by a single truck full of plastic bags.
Plastic is made from ethylene, a by-product of oil production which used to be wasted. Therefore, so long as we still need oil for transport and energy production it makes sense to use the by-product to make plastic products.
However, conventional plastic can be a problem as it takes decades to degrade, and it disintegrates into microplastics. Fortunately, this problem can be solved by using d2w biodegradable technology, so that if the bag or packaging escapes collection and ends up in the environment as litter on land or sea it will degrade and biodegrade (be consumed by bacteria and fungi) leaving nothing behind. Just like nature’s wastes.
Paper is fantastic, so let’s save some trees and use paper for the things that only paper can do. Plastic is not the eco-villain it is made out to be, and when made with d2w it is much kinder to the planet.[21]
AGRICULTURAL MULCH FILM
Farmers all over the world spread thousands of square kilometres of plastic sheet on their fields to protect their crop from weeds and to reduce the evaporation of water. Essentially, farmers have three options:
- Conventional plastic – after the harvest the farmer has to drag many hectares of plastic off his fields. He is not allowed to burn it on the farm, and burying it is not a good idea because it is labour-intensive and effectively puts the site out of cultivation, so he has to pay for it to be taken away. Some farmers send their plastic for recycling but it is usually contaminated with mud and other contaminants, so recycling does not make a lot of sense in economic or environmental terms when you consider the cost of hauling the plastic off the field, loading a large truck, and driving it along country roads to a recycling facility often hundreds of miles away – using fossil fuels, causing congestion, and emitting pollution. The plastic then has to be washed and the contamination has to be disposed of – and then the plastic has to be processed into recyclate.
Also, having lain on the fields exposed to sunlight it is likely to have degraded to the point that it is not fit for recycling, and fragments will have been scattered by the wind whilst being removed.
- PLA – this is expensive and may not be strong enough to resist tearing. The timescale for degradation cannot be programmed. A report of field-trials in Korea in 2024 says “It’s difficult to use agricultural mulching film made with PLA extracted from corn as it is difficult to set up the film on the field and there is hydrolysis due to rainwater, so the physical properties of the mulching film drop. As a result the function of the mulching film wasn’t maintained after 40 days, and it was impossible to use the film. But for the mulching film made with d2w, the physical properties of the film were maintained for 6 months even in the area where there is a lot of rain.
- d2w plastic – successful field-trials have been run in Wales[22] Which showed that the next time the field is ploughed, the biodegradable residue will be returned to the soil, where it will be bioassimilated by the bacteria and will provide a source of carbon for next year’s plants.
By taking note of the climatic conditions in the area, and using the correct formulation, it is possible to make the plastic last for as long or short a time the farmer requires.
It is no more difficult to spread d2w plastic on the fields than ordinary plastic, and a company in Ireland called SAMCO have invented a machine for laying the mulch film.
Mulch films made with d2w-type biodegradable polymers have been studied by scientists for more than 20 years. At page 47 of “Degradable Polymers, Principles and Applications”[23] Professor Scott says “The degradation products formed by oxo-biodegradation are of benefit to the agricultural environment as biomass and ultimately in the form of humus. Carbon is retained in the soil during oxo-biodegradation in a form accessible to growing plants, rather than by being emitted to the environment as carbon dioxide, as is the case with hydro-biodegradable polymers (e.g. pure cellulose and starch) ….. Time control of biodegradation of the synthetic carbon-chain polymers is achieved by antioxidants that behave similarly to naturally occurring antioxidants present in lignin and tannin.”
See also “Polymers and the Environment”[24]
With regard to the edges of the mulch film which are buried to hold it in place. They will still biodegrade because, unlike photo-degradable plastic, an oxo-biodegradable plastic does not need constant exposure to sunlight. It is also possible to make a mulch film in which the buried sides of the film incorporate a different biodegradable masterbatch as compared to the middle part of the film.
EUROPEAN UNION
We were not entirely surprised to see in December 2022 that the homes and hotels of 18 MEPs and officials had been searched by the police, yielding suitcases stuffed with banknotes.
The reason we were not surprised is that we have never been able to understand how it was possible for them to impose a ban on “oxo-degradable plastic”[25] without any proposal from the Commission, without any impact assessment or socio-economic analysis, and without a dossier from the European Chemicals Agency (ECHA) showing any justification for any such ban. The Commission had actually asked ECHA (under Art 69 of the REACH Regulation) to study whether these products created microplastics. ECHA received hundreds of pages of evidence but they informed the BPA in October 2018 that they were not convinced that microplastics were formed.
The Commission’s draft Directive did not include any ban on oxo-degradable or oxo-biodegradable plastic, but the Parliament proceeded to legislate, and circumvented all the safeguards against arbitrary legislation provided by Arts. 69-73 of REACH.
This Directive has been challenged by Symphony in the European Court in Luxembourg. The case was decided on 31st January 2024, and has attracted a lot of attention to Symphony’s d2w technology, which is enabling them to explain the technology to many more people around the world.
The reasons for the ban on “oxo-degradable” plastic are set out in Recital 15 of the SUP Directive, but they do not apply to d2w plastic. Nevertheless the wording of the ban had caused many people to think that it did apply, and Symphony decided to take legal action.
The first point we noticed about the judgment is that the court did not say that the EU had made a correct assessment of the technology. It simply held (incorrectly our view) that the legislators had not exceeded the limits of their discretion.
As we all know, thousands of tonnes of plastic packaging get into the European environment and its coastal waters every month, and will continue to do so – unless the EU bans plastic altogether, which would be a very foolish thing to do.[26]
Symphony have therefore been trying for more than ten years to explain to the EU Institutions that the way to reduce the pollution problem is not to ban plastic, which really is the best material for the job, but to improve waste-management and make the plastic oxo-biodegradable, so that it will quickly biodegrade if it does get into the open environment.
We were thinking that the Commission had understood the point, as they did not include a ban in their draft Directive. If they had thought that this type of plastic might constitute a threat to human health or the environment, they would be justified in taking action according to the precautionary principle. The correct action would be to refer the matter to their scientific experts, the European Chemicals Agency (ECHA), which they actually did.
However, when the draft Directive came before the Environment Committee of the Parliament, a ban was inserted without any Impact Assessment, without any socio-economic analysis, and without waiting for a report from ECHA, who were studying the technology at the time. They even disregarded the interim view of ECHA that microplastics were not formed by this type of plastic.
Symphony have been aware for a long time that the large companies who market a different – and not very useful – type of plastic as “compostable” have been (and still are) lobbying hard against Symphony’s technology, so as to increase their own share of the biodegradable plastics market. It is quite likely that the ban was inserted in Committee as a result of the efforts of these lobbyists.
When considering the Single-use Plastics Directive, the Environment Committee of the Parliament were not made aware of (or did not understand) that oxo-degradation and oxo-BIOdegradation are two very different things.[27]
The most disturbing feature of this court case is that evidence paid for by the Defendants such as the Eunomia literature-review,[28] on which the court placed much reliance – was acceptable to the court, but evidence from experts such as Intertek “has little probative value” because it was paid for by the Applicants (This point is made nine times in the judgment!). However, as laboratories and expert witnesses have to be paid, how is a Claimant against the EU to adduce any expert evidence before their courts which has any “probative value?” This places the Claimant at an impossible disadvantage, and fatally undermines the credibility of the Judgment, and indeed of the EU court system itself.
As to the technical assessment of the technology, the court confirmed that “if it is not to adopt arbitrary measures, which cannot be rendered legitimate even by the precautionary principle, the public authority must ensure that any measures that it takes, even preventive measures, are based on as thorough a scientific risk assessment as possible.” And “the scientific assessment should be based on the best scientific data available.
However, the EU had not carried out “as thorough a scientific risk assessment as possible” and their scientific assessment was not based on “the best scientific data available.” They cannot be heard to say that the best scientific data was not available because they had themselves prematurely terminated the ECHA enquiry and had failed to make an impact assessment at all. Nor can they justify disregarding the views expressed by ECHA in October 2018 as to the non-formation of microplastics.
This is another reason why the Judgment is fundamentally flawed, and Symphony can correctly say that this is “arbitrary legislation which cannot be rendered legitimate even by the precautionary principle.” It would however be a waste of time and money to appeal, as we no longer have confidence in the EU courts.
ECHA have never provided a dossier to support any ban on oxo-biodegradable plastic by the EU, and no evidence has been produced that microplastics from oxo-biodegradable plastic have ever been found in the environment.
The loser here is the environment, because ordinary plastic is still being used to make products which get into the open environment every day, where thousands of tonnes will lie or float around for decades. They should urgently be made with d2w oxo-biodegradable technology, so that they will biodegrade much more quickly and will not leave harmful residues.
[1] https://pubs.acs.org/doi/10.1021/acs.est.3c05191)
[2] www.biodeg.org/subjects-of-interest/paper-bags/
[3] www.biodeg.org/wp-content/uploads/2023/07/Scott-Wiles-paper-June-2001.pdf Scott, “Degradable Polymers, Principles and Applications” (ISBN 1-4020-0790-6) and Scott, “Polymers and the Environment” (ISBN 10: 0-85404-578-3).
[4] http://dx.doi.org/10.1016/j.chemosphere.2017.05.137
[5] https://cfpub.epa.gov/si/si_public_record_Report.cfm?dirEntryId=353810&Lab=CESER
[6] www.biodeg.org/wp-content/uploads/2023/07/Scott-Wiles-paper-June-2001.pdf page 617-9
[7] https://www.biodeg.org/subjects-of-interest/life-cycle-assessments/
[8] See https://www.youtube.com/watch?v=OG17MhWWP-Q
[9] https://www.biodeg.org/subjects-of-interest/composting/
[10] See also www.biodeg.org/wp-content/uploads/2023/07/Scott-Wiles-paper-June-2001.pdf page 621 ““Rapid mineralisation is not ideal for polymers in compost where the carbon in the original plastic should be converted over a longer period of time to biomass and only slowly to carbon dioxide. The oxo-biodegradable polymers (e.g. the polyolefins) are ideal for this purpose since controlled peroxidation is the rate-determining step in the overall process. Furthermore they cannot give toxic or otherwise objectionable by-products during bioassimilation”
[11] https://www.sciencedirect.com/science/article/pii/S2772416623000803
[12] https://www.biodeg.org/wp-content/uploads/2019/11/emf-report-1.pdf
[13] https://www.biodeg.org/subjects-of-interest/recycling-2/
[14] https://www.biodeg.org/wp-content/uploads/2021/02/Swift-evidence-to-BEIS.pdf See also www.biodeg.org/wp-content/uploads/2023/07/Scott-Wiles-paper-June-2001.pdf at page 620
[15] https://www.biodeg.org/wp-content/uploads/2021/07/Final-report-OXOMAR-10032021.pdf
[16] https://www.biodeg.org/wp-content/uploads/2022/10/QM-published-report-11.2.20-1.pdf
[17] https://www.biodeg.org/subjects-of-interest/paper-bags/
[18] http://www.scotland.gov.uk/Resource/Doc/57346/0016899.pdf
[19] https://www.biodeg.org/wp-content/uploads/2021/04/uk-ea-publishes-lca-of-supermarket-carrier-bags-.pdf
[20] https://www.biodeg.org/wp-content/uploads/2023/07/Northern-Ireland-comparison-of-bags-Feb-2011.pdf
[21] https://www.biodeg.org/wp-content/uploads/2021/04/intertek-final-report-15.5.121.pdf
[22] – See https://www.biodeg.org/wp-content/uploads/2020/09/Pembroke-Mulch-Film-Trial-Report-30.09.13V1.pdf.
[23] (ISBN 1-4020-0790-6)
[24] (ISBN 10: 0-85404-578-3) pages 109-118 and 461-466, and www.biodeg.org/wp-content/uploads/2023/07/Scott-Wiles-paper-June-2001.pdf page 618.
[25] (by Art. 5 of the Single-use plastics Directive 2019/904)
[26] See eg: https://www.biodeg.org/subjects-of-interest/paper-bags/ and https://www.biodeg.org/subjects-of-interest/life-cycle-assessments/
[27] “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 an intentionally-added prodegradant catalyst). 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.
[28] See https://www.biodeg.org/wp-content/uploads/2022/10/BPA-Comment-on-the-Eunomia-Report-2016-1.pdf
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