|Received:||2/11/2008 8:10:00 PM|
|Agency:||Federal Trade Commission|
|Rule:||Guides for the Use of Environmental Marketing Claims|
|Attachments:||533431-00068.pdf Download Adobe Reader|
Comments:Comment Info: ================= General Comment:Reference: Green Guides Regulatory Review, 16 CFR part 260, Comment, Project No. P954501 There has been much confusion on the biodegradable and compostable terms and noting the differences of terms like this are critical to the guide ? we trust the information will assist you during your review process. Also attached for your reference is an example of a biodegradable plastic vs. compostable (PLA) marketing collateral that further highlights some of the differences. Please do not hesitate to contact me with any questions, any requests for further clarification or supporting research to validate our claims at 800.996.2247 extension 152. Thank you for your time and consideration. Julieun Kawasaki Command Packaging 800.996.BAGS (2247) x 152 Compostable (PLA) is NOT Biodegradable though many have tried to associate the terms as the same. Compostable materials are generally made in part from corn, wheat, or potato starch with PLA (Polylactic Acid). Many of these materials were created from diverting crops that were once used to feed the people. Their make and design prevents degradation outside of an organic composting facility and with only 134 organic waste centers throughout the U.S. most of these compostable products will find their way to the landfills. As a further point of clarification, the yard waste that many consumers now separate curbside goes to different composting facilities than organic waste. Compostable packages must be sent to organic waste composting centers where they have much higher diversity in the waste content and require far more rigorous composting standards - i.e. the introduction of specific bacteria, temperatures of 180 degrees (F), constant turning of the materials, rodent control, etc. In the United States today there are 3000 yard waste composting facilities but only 134 organic waste centers. Since permitting for organic waste composting facilities are very difficult to obtain by municipalities, their existence in most neighborhoods are prohibited and undesired, limiting their accessibility. Furthermore, products made from these materials will not decompose if they end up in landfills. They will not degrade if they end up in trees or as litter on the side of the road. They will not break down in water and be less invasive to marine life than traditional plastic materials. Compostable products will not solve any litter or landfill problems and will have far less environmental benefits. Most importantly, compostable products are not recyclable and often contaminate the recycling stream when confused for plastic ? destroying the recycling effort. Biodegradable materials by design must fully break down, safely and relatively quickly, by natural or biological means, such as microorganisms like fungi, algae, bacteria, into raw materials of nature and then disappear into the environment. Biodegradable plastics are created with special additives to help them return to its original form of carbon dioxide, water, and humus. Unlike compostable bags, these materials do not need the assistance of composting facilities and will break down wherever other materials biodegrade. They can take about 9 months to 5 years to fully biodegrade, depending on the environment. They are also 100% recyclable, can be mixed with recycled material, and will not affect the recycling stream since the additive will be made inactive during the heating process of the recycling stream. In summary, the key issue in the biodegradable debate is really about time and conditions. Since compostable products will only degrade in composting facilities, to group them in with the biodegradable term will only add to the confusion and increase waste and increase cost for businesses and ultimately the consumer. Composting is not the waste policy prevalent in the United States. Without a federal mandate to build a significant number of organic composting facilities, grouping the terms as one or conversion to compostable products solves nothing. For example, with the U.S. market for grocery sacks at 100 billion per year and paper grocery sack supply being limited to 5 billion annually, if compostable bags are mandated by municipalities, the choice by default will be no bags in stores and restaurants. Americans want choice and mandating specific products or banning others is not the American way. It only serves to increase its competing product that may actually cause more pollution and waste despite the poplular belief. Consumers should know all the facts and be allowed to make informed choices between paper, plastic, biodegradable plastic, compostable, or no bag at all. We ask that you consider offering different classifications of the different types of biodegradable materials available to avoid confusion and that may cause more environmental harm in the end.