Guides for the Use of Environmental Marketing Claims, Project No. P954501 #00175 

Submission Number:
00175 
Commenter:
Graham Chapman
Organization:
EcoPoly Solutions
State:
Outside the United States
Initiative Name:
Guides for the Use of Environmental Marketing Claims, Project No. P954501

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.