Submission Number: 00334
Received: 12/10/2010 10:48:49 PM
Commenter: Ramani Narayan
Organization: Michigan State University
Agency: Federal Trade Commission
Initiative: Guides for the Use of Environmental Marketing Claims; Project No. P954501
00334-57142.pdf Size = 133 KB
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These are comments for “Made from Renewable Materials”
Biobased materials or renewable materials refers to “organic materials that contain in whole or in part biogenic (biologically sourced) carbon”
The term organic materials refers to material(s) containing carbon based compound(s) in which the carbon is attached to other carbon atom(s), hydrogen, oxygen, or other elements in a chain, ring, or three dimensional structures – this is the IUPAC (International Union of Pure and Applied Chemistry) nomenclature
Based on the above, the biobased content or renewable material content is given by:
% biobased content = Bio (organic) carbon/total (organic carbon) * 100
The above identification and quantity of renewable material content in a product forms the basis for the USDA biopreferred program. This is also being adopted in European Union directives and Asian countries like Japan, China, and India. It forms the basis for ISO (International Standards Organization) and European Standards as well as ASTM standard.
The value proposition for biobased products/materials or renewable materials arise from the biogenic carbon in the product which provides for a reduced carbon footprint. The scientific basis for the fundamental value proposition of a reduced carbon footprint (climate change impact reduction) arises from a consideration of the “global biological carbon cycle” and presented as a separate attachment.
However, the key take home is that the manufacture and use of biobased/renewable materials offers an environmental value proposition of a reduced carbon footprint based on the biogenic carbon in the product. It does not speak to the end-of-life issue. Biobased renewable products can be recycled (for example Coca Cola’s bio-PET – bottle to bottle recycling) or composted (like PLA products) or waste-to-energy or find itself in landfills. These end-of-life claims must follow applicable FTC guidelines.
There is an underlying misunderstanding on what “made with renewable material: is and what ASTM D6866 test method provides. ASTM D6866 does not substantiate all claims that consumers reasonably infer. However, it does substantiate the amount of renewable material content in a product accurately, and verifiably
There is a conflict between the USDA biobased program and the FTC guidelines
Company A makes a product from bamboo and qualifies it as a biobased product under the USDA program based on the biboased content of the product using ASTM D6866. It may also be available for Federal procurement if it meets the minimum biobased content requirements laid down by USDA.
Company B makes a product from bamboo by chemical modifications with fossil reagents, blends with additional fossil additives/plasticizers. The biobased/renewable material content of the product does not meet the minimum requirements of the USDA program for the USDA label or Federal procurement. However, under the FTC example, it can make a “made from renewable materials claim” providing information on the material it uses (the bamboo), the fact that the bamboo grows at a rate that is in balance with its use . There is no guidance as to how the renewable content will be reported – will it be on a carbon basis, total mass basis. In the above example, there is no requirement for defining the end-of-life – will it be recycled, biodegraded.
Company A manufactures 100% bioPE film product and can apply to the USDA for biobased label as well as for Federal procurement under the USDA designated items list. using ASTM D6866.
Company B blends 20% virgin fossil based PE, 30% recycled PE and 20% bioPE to make a film product. They go to the market with a claim of using 50% “made from renewables”. They would not qualify under the USDA biopreferred program but under the FTC guidelines can go to market with “made from renewables”.
Again this would cause confusion in the marketplace