Annexes to COM(2018)35 - Impact of the use of oxo-degradable plastic, including oxo-degradable plastic carrier bags, on the environment - Main contents
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| dossier | COM(2018)35 - Impact of the use of oxo-degradable plastic, including oxo-degradable plastic carrier bags, on the environment. |
|---|---|
| document | COM(2018)35  |
| date | January 16, 2018 |
However, for none of these environments a full biodegradation process has been documented. Most experiments were carried out over a too short time span to demonstrate full biodegradation and the results of measurements of molecular weight reduction in the initial stage of fragmentation were extrapolated following certain models. Therefore, no conclusive evidence is currently available to confirm that the fragmentation is sufficiently rapid and leads to a reduced molecular weight that allows subsequent biodegradation taking place within a reasonable time-frame.
The evidence also suggests that oxo-degradable plastic is not suitable for any form of composting or anaerobic digestion.
4. Issues related to littering
4.1Potential toxic effects of the oxidising additives
Potential toxic effects on soils of residual additives from oxo-degradable plastics have been identified as a concern. 11
Conclusions valid for all oxidising additives used can however not be drawn, because different oxidising additives are used in different concentrations.
From the available evidence it appears that the oxo-degradable plastics industry can create products with minimal toxic impact on flora and fauna; however, it has not been conclusively proven that there are no negative effects.
A few test standards for oxo-degradable plastic specify some form of toxicity test, but these standards are not obligatory for products on the EU market; moreover, some of the standards describe checklists without defining pass/fail criteria for the toxicological test results.
In the absence of adequate standards in the EU, there is no guarantee that all oxo-degradable plastic on the market avoid negative toxic effects and uncertainty about real world toxicological impacts remains.
4.2Potential increase in littering
Even though no conclusive information is currently available on the disposal or littering of plastic according to the type of plastic, or on the influence of marketing oxo-degradable plastic on the disposal behaviour of consumers, presenting oxo-degradable plastic as the solution for plastic waste in the environment may influence littering behaviour by making it more likely that it is discarded inappropriately 12 . For specific oxo-degradable products such as agriculture mulches the littering issue is a given as those products are sold to farmers with the aim not to be collected after use (cf. take-back schemes for conventional plastics) but to be left on the land.
4.3Marine litter
The marine environment is where potentially most damage by plastic waste could arise, including fragmented plastic and microplastics; at the same time, subsequent collection or recovery of the plastic is least probable.
As oxo-degradable plastic is designed to fragment faster than conventional one it is less likely to be recovered during litter clean-up exercises, and likely to be more easily transported by wind and water. As these factors may contribute to oxo-degradable plastic being transported into the marine environment easier than conventional plastic it can be said that oxo-degradable plastic contributes to microplastics pollution and therefore poses environmental risks.
There is no conclusive evidence of full biodegradation in a reasonable time of oxo-degradable plastic in the marine environment.
There is also insufficient evidence to conclude whether oxo-degradable plastic would increase or decrease absolute quantities of plastic in marine environments. In the hypothesis that full biodegradation occurs on land, the quantity that may otherwise transfer to the marine environment would be reduced. However, full biodegradation on land is not proven to occur. Consequently, there is a risk that the fragmentation behaviour of oxo-degradable plastic exacerbates issues related to the presence of microplastics in the marine environment.
Furthermore, while rapid fragmentation may lead to less entanglement of animals in plastic, it at the same time increases physical ingestion of microplastics by marine animals.
As oxo-degradable plastic is likely to fragment quicker than conventional plastic, the negative impacts associated with the presence of microplastics in the marine environment are concentrated within a shorter period of time. This could ultimately be worse than spreading out the impacts over a longer period, due to an increase in the proportion of individuals, species and habitats affected, as well as the burden of impacts for an individual.
5. Issues related to the recycling process
5.1Identifying oxo-degradable plastic
The inherent and programmed fragmentation as intended with the oxidising additives is not desirable for many products made of recycled plastic. Oxo-degradable plastic should therefore be identifiable and separated from other plastics collected for recycling.
Currently available technology can however not ensure identification and separate sorting of oxo-degradable plastic by re-processors. Consequently, recycling of oxo-degradable plastic will take place mixed with conventional plastic.
5.2Quality issues and marketability of recyclates
Significant concerns exist within the recycling industry that oxo-degradable plastic negatively affects the quality of recycled plastics. Tests have demonstrated that the presence of oxo-degradable plastic in a conventional plastic recycling system can lead to poor quality recyclate. Even though it also appears possible to produce high quality recyclate, there is no certainty about the absence of negative impact of the oxo-degradable plastic on the recyclate. 13
Evidence suggests that the impacts of oxidising additives on recyclates can under certain circumstances be avoided with the inclusion of stabilisers. The appropriate quantity and chemistry of stabiliser would depend on the concentration and nature of the oxidising additives in the feedstock. However, as the concentration of oxo-degradable plastic in recyclate in real world situations is unknown, it is difficult to know the correct dosing of stabilisers.
A major issue is furthermore that it is impossible to fully control the level of aging experienced by oxo-degradable plastics during the product use phase, prior to products becoming waste and entering recycling processes.
The existence of oxo-degradable plastic and the global nature of markets for secondary materials present risks to a more generalised use of recovered plastic in long-life products. The uncertainty of whether the recyclate may contain oxo-degradable plastic and of the degree of oxidation and degradation that might have occurred prior to recovery limits the end-use for the recyclate, having a negative impact on the price of the recyclate and on the competitive position of the plastic recycling industry.
6. Conclusions
Taking into consideration the key findings of the supporting study as well as other available reports 14 , there is no conclusive evidence on a number of important issues relating to beneficial effects of oxo-degradable plastic on the environment.
It is undisputed that oxo-degradable plastic, including plastic carrier bags, may degrade quicker in the open environment than conventional plastic. However, there is no evidence that oxo-degradable plastic will subsequently fully biodegrade in a reasonable time in the open environment, on landfills or in the marine environment. Sufficiently quick biodegradation is in particular not demonstrated for landfills and the marine environment.
A wide range of scientists, international and governmental institutions, testing laboratories, trade associations of plastics manufacturers, recyclers and other experts have therefore come to the conclusion that oxo-degradable plastics are not a solution for the environment and that oxo-degradable plastic is not suited for long-term use, recycling or composting.
There is a considerable risk that fragmented plastics will not fully biodegrade and a subsequent risk of an accelerated and accumulating amount of microplastics in the environment, especially the marine environment. The issue of microplastics is long acknowledged as a global problem in need of urgent action, not just in terms of clean-up of littering but also of plastic pollution prevention.
Claims presenting oxo-degradable plastic as an "oxo-biodegradable" solution to littering which has no negative impact on the environment, in particular by not leaving any fragments of plastic or toxic residues behind, are not substantiated by evidence.
In the absence of conclusive evidence of a beneficial effect on the environment and indeed indications to the contrary, given the related misleading claims to consumers and risks of resulting littering behaviour, EU wide measures should be considered. Therefore, in the context of the European plastics strategy, a process to restrict the use of oxo-plastics in the EU will be started.
(1) Directive (EU) 2015/720. OJ L 115 of 6.05.2015, p. 11
(2) Directive 94/62/EC of 20 December 1994 on packaging and packaging waste. OJ L 365 of 31.12.1994, p. 10
(3) Final report of the study on the impact of the use of “oxo-degradable” plastic on the environment available on the Commission’s webpage: https://publications.europa.eu/en/publication-detail/-/publication/bb3ec82e-9a9f-11e6-9bca-01aa75ed71a1/language-en/format-PDF/source-56357670
(4) These include materials resulting from artificial synthesis processes (e.g. plastics) and those resulting from natural synthesis processes (“biopolymers”, such as cellulose and proteins), excluding rocks and metals.
(5) Defining a ‘reasonable’ time frame might differ from product to product depending also on the use of the product and its impact on the environment; the environmental impact is correlated with the time taken for complete breakdown of the polymer.
(6) Bio-based plastics have the same properties as conventional plastics but are derived from biomass, as defined in European Standard EN 16575.
(7) Final report, supra footnote 3, Table 3, p.21
(8) DEFRA: Review of standards for biodegradable plastic carrier bags, December 2015, review of evidence from Loughborough University, cited in Final report, supra footnote 3, p.16
(9) Final report, supra footnote 3, Executive summary, E.1.1, ii
(10) Final report, supra footnote 3, 4.1.2.1. p.31
(11) Even though not widespread, the use of cobalt has been observed by some studies and the possibility remains that producers can incorporate cobalt, or manganese, or other substances of concern, into their additives with no regulation on eco-toxicity to prevent this.Final report, supra footnote 3, p. 59-60
(12) See also, for the issue of littering behaviour and biodegradability, UNEP: Biodegradable plastics and marine litter: misconceptions, concerns, and impacts on marine environments (2015), p. 29
(13) Final report, supra footnote 3, p. 97-101
(14)
Cf. UNEP: Biodegradable plastics and marine litter: misconceptions, concerns, and impacts on marine environments (2015); OWS: Benefits and challenges of oxo-biodegradable plastics (2013); European Bioplastics: ‘Oxo-biodegradable’ plastics (2009). European Bioplastics: ‘Oxo-biodegradable’ plastics and other plastics with additives for degradation (2015); Ellen MacArthur Foundation: The new Plastics Economy: rethinking the future of plastics (2016); Ellen MacArthur Foundation: The new Plastics Economy: oxo-degradable plastic packaging is not a solution to plastic pollution, and does not fit in a circular economy (2017 – statement endorsed by over 150 organisations worldwide, including businesses and industry associations, non-governmental organisations and associations, public institutions, research organisations and scientists).; EPA Network: Recommendations towards the EU Plastics Strategy (2017 - Discussion paper from the Interest Group Plastics of the European Network of the Heads of Environment Protection Agencies from Austria, Denmark, Finland, Iceland, Germany, Netherlands, Norway, Portugal, Romania, Scotland, Slovenia, Spain, and Switzerland)