Oxo-biodegradation

"Biodegradable plastic" is a term that causes confusion and should not be used, because it could apply to two completely different types of plastic.

• Vegetable-based plastics, which are also loosely known as "bioplastics" or "compostable plastics", are tested in accordance with ASTM D6400 or EN13432 as to their ability to biodegrade under conditions found in industrial composting or biogas facilities.[1]

• Oxo-biodegradable plastics—which are made from polymers such as polyethylene (PE), polypropylene (PP), contain a prodegradant catalyst—usually a salt of manganese or iron, and are tested in accordance with ASTM D6954 or BS8472, or AFNOR Accord T51-808, as to their ability to degrade and then biodegrade in the open environment. The prodegradant catalyzes the abiotic degradation process so that Oxo-biodegradable plastic will degrade in the presence of oxygen much more quickly than ordinary plastic.[2] The plastic material has then been converted into small-chain organic chemicals, such as ketones, alcohols, carboxylic acids, and low molecular mass hydrocarbon waxes. The remaining chemicals are no longer plastic and are biodegradable by bacteria, which are ubiquitous in the terrestrial and marine environments. The timescale for complete biodegradation at any time or place in the open environment is much shorter than for "conventional" plastics, which in normal environments are very slow to biodegrade[3] and cause large scale harm.[4]

Degradation is initially prevented by the presence of polymer stabilizers in the plastic, which ensures a useful service-life for the article. Once the stabilisers have been exhausted OXO-biodegradation will begin. The chemical mechanism is that of autoxidation but it is greatly accelerated by the presence of metal-catalysts, which promote the homolysis of hydroperoxides into free radicals which drive the degradation process.[5] Access to oxygen is essential and OXO-degradable plastics will not degrade if buried deep in landfill.

Conventional polyethylene (PE) and polypropylene (PP) plastics will typically fragment quite quickly, but will then take decades to become biodegradable. OXO-biodegradable plastic, if discarded in the environment, will degrade to oxygenated low-molecular-weight chains (typically MW 5–10,000 amu) within 12–18 months, depending on the material (resin, resin thickness, anti-oxidants, etc.), temperature, and other factors in the environment.

Biodegradation of up to 92.74% has been observed in a soil environment within 180 days, when tested in accordance with ASTM D6954.[6] OXO-degradation has been studied at the Eurofins laboratory in Spain, where on 25 July 2017 they noted 88.9% biodegradation in 121 days.

The statements about biodegradation of oxo-degradable plastics were considered in the 2016 Eunomia Report for the EU Commission.

Oxo-biodegradable plastic degrades in the presence of oxygen. Heat and UV light will accelerate the process, but neither they nor moisture are necessary. Such plastic is not designed to be compostable in open industrial composting facilities, according to ASTM D6400 or EN13432; but it can be satisfactorily composted in an in-vessel process, and has been proved to be compostable according to ISO 14855 [Eurofins Laboratories 6.11.16].

The standards for industrial composting, ASTM D6400 and EN13432, require the plastic to convert to carbon dioxide (CO₂) gas within 180 days by industrial composting. Indeed materials that do comply with ASTMD6400, EN13432, Australian 4746, and ISO 17088 cannot properly be described as 'compostable' because those standards require them to convert substantially to CO2 gas within 180 days. you cannot therefore make them into compost - only into CO2 gas. This contributes to Climate Change but does nothing for the soil. A leaf is generally considered to be biodegradable, but it will not pass the ASTM composting standards, due to the 180-day limit.

OXO-biodegradable plastic conforms to the American Standard (ASTM D6954) and a British Standard (BS8472), which specify procedures to test degradability, biodegradability, and non-toxicity, and with which a properly designed and manufactured OXO product must comply. These standards contain pass/fail criteria.

There is no need to refer to a standard specification unless a specific disposal route (e.g., composting), is envisaged. ASTM D6400, EN13432, and  Australian 4736 are standard specifications appropriate only for the special conditions found in industrial composting.

According to an EU report, the oxo-degradable plastics do not biodegrade on a landfill nor should they be regarded as compostable.[7]

The Oxomar project(9) was a four-year interdisciplinary study, sponsored by the French Government. The scientists reported that “The goal was to evaluate the biodegradation of oxo-bio in marine waters.

They concluded 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 degradant catalyst was found to be of crucial importance in the degradation process.”

See also the report from Queen Mary University London by Rose et. al 11th February 2020(10). Para 2.6 says “Before testing, samples of LDPE and oxo‐LDPE were surface‐weathered in seawater for 82 days, undergoing natural variations in sunlight and UV intensity.

Landfill: Oxo-biodegradable plastic is not designed to be able to degrade in a landfill. If the plastic has been taken to a landfill, it has been responsibly disposed of and there is no need for it to degrade. Also, if anything biodegrades in anaerobic conditions it will generate methane, which is undesirable unless the landfill has been designed to collect the gas. Oxo-biodegradable plastic will not become biodegradable in the absence of oxygen.[8] Recycling:(11)

• Recyclers have to assess the level of degradation of any plastic sent for recycling whether it is oxo-biodegradable or not. They cannot recycle ordinary plastic which has started to degrade after exposure to sunlight.
• If the recyclate is to be used to make short-life products (eg food packaging) it does not matter whether it contains oxo-biodegradable plastic, because biodegradation is desirable.
• Stabilization is, therefore, necessary only for long-life products, and the producer of long-life products would stabilize them in the same way whether the recyclate contains oxo-biodegradable plastic or not. He does not need to know the proportion of oxo-biodegradable plastic in the feedstock. This normal stabilization would neutralize any oxo-biodegradable residue.
• It is not 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.

Many of the microplastics in the environment are caused by the fragmentation of ordinary plastic when exposed to sunlight. These fragments are very persistent in the environment 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, for single-use plastics The plastic falls apart because the molecular chains have been dismantled and it is no longer a plastic.

The European Chemicals Agency (ECHA) was asked to study oxo-biodegradable plastic in December 2017.[9] They made a Call for Evidence, and they informed the BPA on 30th October 2018 after 10 months of study, that they had not been convinced that it creates microplastics. ECHA has 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. It 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.[10]

The Biodegradable Plastics Association (BPA) claimed that the EMF report was inaccurate and pointed out that many of the organizations shown as endorsing the report aggressively promoted a rival bio-plastic technology. In contrast, many of the others whose logos appeared in the document produced the same plastic items that get into the open environment as litter(13). The paper's conclusions were rejected by Professor Ignacy Jacubowicz, who said the degradation process was not merely a fragmentation, but a change from a high molecular weight polymer to a material that can be bio-assimilated(14). [11]

The evidence for and against oxo-biodegradable plastic was also reviewed in November 2018 by Peter Susman QC, a deputy judge of the High Court of England, who had over 25 years of experience in adjudicating cases in the technology and construction branch of the High Court, involving the evaluation of expert evidence. He declared the scientific case favouring oxo-biodegradable plastic "clear and compelling". Susman examined the processes of abiotic and biotic degradation of plastics and then looked specifically at degradation in air and degradation in seawater. He concluded, in a 15-page report(15) that

It is no longer tenable to conclude that there is 'no firm evidence either way' whether oxo-biodegradable is effective. I consider that recent research provides clear and compelling evidence that oxo-biodegradable plastic is indeed effective in facilitating very significantly speedier degradation than is the case when that technology is not used... [I] cannot imagine that such significantly speedier final degradation occurs later than 'within a reasonable time'; however, the expression might be defined... [I regard the idea that biodegradable plastics might encourage littering as] "fanciful and unreasonable".[12]

On 16 January 2018, the European Commission published its report on using oxo-degradable plastic. The document forms part of the European strategy for plastics in a circular economy, which was released the same day.[13]

The Commission focused on three key issues relating to oxo-degradable: the biodegradability of oxo-biodegradable plastics in various environments, the environmental impacts of littering, and recycling.

This report was critically reviewed by the Biodegradable Plastics Association (formerly the Oxo-biodegradable Plastics Association) (BPA)(16) In its Proposal (2018/0172(COD)) for a Directive on "Reduction of the impact of certain plastic products on the environment", the EU Commission proposed various measures for reducing the number of plastic goods being produced and standards for encouraging collection for recycling. Most people would support those measures, but plastic will still escape into the open environment in unacceptable quantities until the plastic waste has been eliminated. This is not likely to happen any time soon.[14]

Notably, the Commission’s proposal did NOT include a ban on oxo-degradable or oxo-biodegradable plastics. This was inserted into the draft in the Environment Committee of the Parliament.

The BPA says that oxo-biodegradable technology is the ONLY way to prevent the accumulation of plastic waste that has escaped into the environment. If oxo-biodegradable technology were severely restricted in the EU, unintended consequences would exist. Some countries outside the EU could follow the EU’s lead with disastrous results, and much of their accumulated plastic waste would eventually find its way to the shores of Europe.

Recital (3) to the draft Directive says, "Marine litter is transboundary and is recognized as a global problem." The Reis report to the European Parliament (11 October 2018) says, "Every year in Europe, 150,000 tonnes of plastic are dumped into the sea. The situation is even more alarming at [the] global level, with 8 million tonnes ending up in the sea each year." Recital (5) to the draft Directive says, "In the Union, 80 to 85 % of marine litter, measured as beach litter counts, is plastic, with single-use plastic items representing 50%."

This is why plastic needs to be urgently upgraded to convert it into biodegradable materials much sooner than ordinary plastic if it does escape into the open environment, especially the oceans. The Directive was based on the Prodi, Reis, and Demesmaeker Reports to the European Parliament, none of which provided any scientific justification for a ban.

The BPA says that it has never been able to understand how it was possible to impose a ban on “oxo-degradable plastic” (by Art. 5 of the Single-use Plastics Directive 2019/904) without any dossier from the European Chemicals Agency (ECHA) showing any justification for any such ban. To make matters worse, the Commission had asked ECHA (under Art 69 of the REACH Regulation) to study whether these products created microplastics. ECHA received hundreds of pages of evidence but informed the BPA on 30 October 2018 that they were not convinced that microplastics were formed. They were instructed to terminate the study.

The Parliament and Council then proceeded to legislate, circumventing all the safeguards against arbitrary legislation provided by the Arts. 69-73 of REACH. Could it be that there was some improper influence?

According to the BPA, “The loser here is the environment because ordinary plastic is still being used to make products that get into the open environment every day, where they will lie or float around for decades. They should urgently be made with oxo-biodegradable technology, at little or no extra cost, so that they will biodegrade much more quickly and will not leave harmful residues.”

• 1 Scott, Gerald “Degradable Polymers, Principles and Applications” ISBN 1-4020-0790-6
• 2 ibid
• 3 ibid
• 4 Intertek 2.12.21
• 5 https://www.biodeg.org/subjects-of-interest/composting/
• 6 https://www.biodeg.org/wp-content/uploads/2021/02/Swift-evidence-to-BEIS.pdf
• 7 https://www.biodeg.org/wp-content/uploads/2021/07/Final-report-OXOMAR-10032021.pdf
• 8 https://www.biodeg.org/wp-content/uploads/2022/10/QM-published-report-11.2.20-1.pdf
• 9 Ibid fn 7
• 10 Ibid fn8
• 11 See https://www.biodeg.org/subjects-of-interest/recycling-2/
• 12 See https://www.biodeg.org/wp-content/uploads/2019/11/emf-report-1.pdf
• 13 https://www.biodeg.org/wp-content/uploads/2019/11/emf-report-1.pdf
• 14 https://www.biodeg.org/wp-content/uploads/2020/05/Reply-to-Ellen-MacArthur-Foundation-from-Prof-Ignacy-Jakubowicz-21-8-17.pdf
• 15 https://www.biodeg.org/uk-judge-find-the-case-for-oxo-biodegradable-plastic-proven/
• 16 https://www.symphonyenvironmental.com/wp-content/uploads/2022/09/bpa-responds-to-european-commission-2.pdf

• Oxo Biodegradable Plastics Federation