Submission Number: 00175
Received: 12/9/2010 6:29:45 PM
Commenter: Graham Chapman
Organization: EcoPoly Solutions
State: Outside the United States
Agency: Federal Trade Commission
Initiative: Guides for the Use of Environmental Marketing Claims; Project No. P954501
Attachments: No Attachments
Having been involved in degradable plastics for 25 years and being a founder member of ASTM D20.96 I would like to make several comments:
1. Technology is continuously changing and the guidelines need regular review.
2. Specifying the time period for degradation is very complex, since products can have programmable life based on their environment; this is particularly true of oxo-biodegradable products.
3. Biodegradable does not = compostable; Some materials are compostable and not biodegradable.
4. Biobased does not = biodegradable. Many biodegradables use petroleum-based resins.
5. Green claims and environmental benefits must be based on an LCA. A biodegradable material that requires considerable energy for manufacture may have an overall negative impact.
6. More enforcement is necessary. We still see unsubstantiated (as well as non-third party) claims.
7. A full dossier on the benefits and substantiation of claims for oxo-biodegradable products is available.