WRAP believes that Publicly Available Specifications (PAS) are helpful to industry by defining categories of products and helping to drive quality and support innovation. With any PAS it is important to understand its parameters.
WRAP was represented on the steering group for the development of PAS9017 ‘Biodegradation of polyolefins in an open-air terrestrial environment’ and the chance to make representations about issues it could foresee relating to the PAS. WRAP is awaiting some further information with regards to these representations and at this time should clarify that WRAP being on the steering committee should not be taken as an endorsement of the PAS.
PAS 9017 details methods for demonstrating that a polyolefin plastic will biodegrade in an open-air terrestrial environment within a specific timescale and leave no micro plastics. It is critical to be able to provide evidence of any claim like this and to distinguish from oxo-degradable plastics which simply degrade to micro plastics and cause further environmental damage. WRAP believes that oxo-degradable plastics that break down creating micro-plastics should be banned, not only in the UK, but globally. To reflect this, WRAP is a signatory of the Ellen MacArthur Foundation Statement and under The UK Plastics Pact, oxo-degradable plastics that lead to micro-plastics are targeted for elimination in alignment with the definition of oxo-degradable plastics under the EU Single Use Plastics Directive.
Important points to note in relation to PAS 9017 are:
- The PAS does not cover soil, fresh water or marine environments so it offers no advantage if plastic makes its way to those places. This is an important limitation as much of marine plastic pollution originates from terrestrial litter.
- The use of the term ‘biodegradable’ should be avoided without being clear on the environment that the biodegradability applies to and being clear about the timescale. WRAP guidance exists on this.
- The time allowed for biodegradation to complete is 2 years.
- The PAS does not allow any green claims to be made, any claims should be made in accordance with ISO14021. The PAS gives the data to be able to meet/comply with ISO14021
- There is a danger that a claim of biodegradability could encourage littering and so the communication of this property needs to be carefully thought through – biodegradable materials should never be used as an excuse for littering.
- The PAS does not include evidence to validate the test methods proposed and assure the avoidance of microplastics during any stage of the decomposition process. Through the steering committee WRAP has seen evidence but this should be published alongside the PAS.
- The PAS does not cover the recyclability of biodegradable plastics and such claims also need to be substantiated
Littering is a real issue, which will be tackled in part by initiatives such as deposit return schemes and awareness campaigns. However, these will not solve the issue entirely. There are also cases where plastics items are used and may remain in the environment for some time. Tree guards for saplings may be example of this. WRAP is keen to encourage evidence led developments in plastics technologies which have no negative impact on the ability for plastic to be effectively recycled and have no negative impacts to the natural environment. However, it is incumbent upon those developing technologies to demonstrate this.