SPC’s Use of the Term Policy for This Position Statement

In the context of the SPC, packaging policy is a term referring to political efforts from governments, corporations, or other organizations working in the sustainable packaging field on a global scale.

• Overarching laws, regulations, administrative actions, and other decision-making processes that an organization or
  government follows or creates.
• A mechanism to reach goals or desired outcomes at various governance levels within governments and organizations.

 

Scope

Based on our current membership concentration, we primarily focus on the United States and Canada while staying aware of Europe and international policies that may inform this primary focus.

The scope of packaging policy related work for the SPC encompasses any policy where the primaryrole addresses the packaging life cycle. Policies can be complex and multi-layered. The SPC limits efforts to packaging life cycle policies as this is core to the organization’s mission. To expand, the packaging life cycle includes the sourcing, manufacturing, distribution, use, and recovery of a package. Policies that fall outside this life cycle scope are acknowledged for
awareness but not incorporated into our direct work.

All work of the SPC must be relevant to current or future programs and member interest with the goal to help translate legislation, keep members informed, and encourage dialogue between all stakeholders in the supply and value chain.

1. 1. The SPC defines greenwashing as, “using accurate environmental facts to tell an inaccurate environmental impact story.” This definition is aligned with Mirriam Webster’s approach of defining greenwashing as, “the act or practice of making a product, policy, activity, etc. appear to be more environmentally friendly or less environmentally damaging than it really is.”
      The rhetorical argument framework of claims, support, and warrants is useful in assessing environmental marketing. This approach to defining greenwashing as a way of slanting how an environmental message is perceived is important because at the core, advertising is making an argument on behalf of a product. A claim is what is being asserted by the marketer, support is what data or evidence would back up the claim, and a warrant is the underlying reasoning that links the supporting evidence to the claim.
      An environmental claim considered to be greenwashing under this frame is not an inaccurate claim; rather, it is one that lacks rigor in the supporting evidence and/or relies on implicit warrants to persuade a consumer rather than clearly-stated compelling evidence. Overly broad claims that require the consumer to ‘fill in the blanks’ for why the claim is a good product attribute are relying on implicit warrants to persuade rather than a stated warrant. Greenwashing enables the marketer to avoid making a claim that would not be substantiated by generally accepted methodologies such as life cycle assessment, while still benefiting from a consumer making that logical leap.
   2. The term ‘greenwashing’ should not be used to refer to the use of false environmental claims in marketing; this is false advertising. Greenwashing is distinct from false advertising due to the use of accurate environmental facts to tell an inaccurate environmental impact story. Rather, the term greenwashing should be used to refer to the strategic use of certain claims, or absence of other relevant information, that presents an inaccurate view of the entire environmental impact. This is because strategies to prevent false claims and misdirection through ambiguous claims are different.
      This distinction between greenwashing and false advertising does not condone false advertising. If a message is known to be demonstrably false and is still used in advertising, that is morally wrong, demonstrates a lack of business ethics, and most importantly is illegal in the United States, Canada, the European Union, China, and many other jurisdictions. False advertising, whether environmental in nature or not, must be avoided.
   3. The SPC recommends pursuing independent substantiation for environmental claims. To avoid greenwashing, environmental marketing should include:
      • A stated warrant that links relevant supporting information to a specific and truthful claim,
      • Any necessary qualifications, and
      • Verification from an appropriate and credible independent organization.

      To move forward with on-pack consumer education, marketers interested in avoiding greenwashing should use thirdparty certification or verification programs that help to establish substantiation for all claims. There are robust certification
      programs for recycled content, material health, fiber sourcing, compostability and other common environmental marketing
      claims. There are also programs, such as the How2Recycle, OPRL, and APCO, that verify on-pack recyclability messaging for
      specific markets.

   To learn more, contact spcinfo@greenblue.org.

(1) Additives Have a Negative Impact on Recyclability

Plastics have two inherent attributes that make them ideal for recovery: their high embodied energy content qualifies their value for controlled energy recovery, and their exceptional durability renders them ideal for recycling. Additives that are fundamentally designed to compromise the structural integrity of a recyclable material are counterproductive to efforts to recycle more materials and to extract as much future value as possible from existing materials.

 

(2) Additives Contribute to Microplastics on Land and in Water

Most additives are designed to break plastics down into smaller pieces in order to make it sufficiently available to the microorganisms that perform biodegradation. These fragmented pieces may be invisible to the naked eye, yet their effects as microplastics have been shown to be seriously detrimental.

Terrestrial litter is likely to migrate, either by human or natural means, into a marine environment. Additives that are designed to enable biodegradation in terrestrial (on-land) conditions are not tested or designed to be effective in marine conditions. This is because marine conditions have a wider variability in temperature, microbial and nutrient availability, and
exposure to sunlight. In a marine environment, any fragmentation of petroleum-based plastic will exacerbate its harmfulness as pollution. Whether or not biodegradation successfully occurs in these various environments and conditions, petroleum-based plastics should not be designed to encourage fragmentation.

 

(3) Additives are not an Enabler for Compostability

Compostability describes a material’s ability to successfully undergo biological decomposition and transformation into a stabilized organic matter within a specified period of time. To beneficially complete the natural biological cycle, biodegradation should occur in a managed and controlled environment, such as an industrial composting operation. The material must also break down in a way that is non-toxic and harmless to human health and the environment.

Petroleum-based plastics made with biodegradability additives do not break down in such a manner. To date, these additives have not enabled non-compostable plastics to become compostable.

 

(4) Degradation Releases Greenhouse Gas Emissions

As organic materials degrade, their carbon content is transformed to one or more greenhouse gasses — either carbon dioxide if the degradation occurs in the presence of abundant oxygen, or methane if the degradation occurs in an oxygen-deficient environment such as a landfill.

When bio-based materials (such as fiber-based packaging) biodegrade in an oxygen-rich environment, like a composting facility, they complete a naturally-occurring, net-carbon-neutral carbon cycle. This is because the material’s carbon content was recently sequestered from atmospheric carbon dioxide. As material transforms its carbon content into carbon dioxide emissions, the environment shows no net loss or gain of carbon dioxide over the short lifecycle of the material.

Petroleum-based plastics, however, are not bio-based, and the addition of additives does not change that characteristic. If a petroleum-based plastic degrades in an oxygen-rich environment, such as when it becomes litter, it results in the release of previously dormant carbon. These emissions would not occur if the material remained intact and was instead reused or recycled.

In a landfill, petroleum-based plastics with degradability additives also generate methane, a more potent greenhouse gas than carbon dioxide. Even landfills that capture methane are harmful, because gas capture systems typically operate with limited efficiency.

Petroleum-based plastics that are not designed to biodegrade in landfills will remain mostly inert, storing their carbon and preventing it from reentering the atmosphere indefinitely. For this reason, encouraging an otherwise inert material to degrade in a landfill should be avoided.

 

(5) Biodegradability Marketing Claims are Increasingly Unlawful

It is illegal in California, Maryland, Minnesota, and Washington to use the term “biodegradable” in marketing claims related to plastic products and/or bags. In some instances, states and jurisdictions specifically restrict the use of marine degradable claims, as well as “oxo-degradable”, “decomposable”, and “degradable”. The Federal Trade Commission’s “Green Guides” also offer guidance on how marketers should avoid using these terms in ways that lead to consumer deception, and explicitly state that “Unqualified degradable claims for items that are customarily disposed in landfills, incinerators, and recycling facilities are deceptive because these locations do not present condition in which complete decomposition will occur within one year.”

Furthermore, marketing any non-compostable material to consumers as being beneficial due to its biodegradability may be misleading and detrimental to efforts intended to advance compostable packaging.

 

(6) Products with Additives Can Contribute to Littering and Consumer Confusion

An additive that is intended to make packaging “litter-friendly” and is marketed to consumers as biodegradable is a severe step in the wrong direction. Work conducted in 2009 by Keep America Beautiful found that consumers are more likely to litter when the item is marked as being “biodegradable”, although more recent data on the exact impacts on consumer behavior remains limited. A 2020 European Commission report references several studies showing a perception amongst consumers that “biodegradable” is an “inherently virtuous aspect of a product and that littering such an item would be less impactful.”

More broadly, studies have shown that consumers do not have a clear understanding of what the term “biodegradable” means. For example, a 2020 study of UK consumers found that 30-41% of consumers believed the term meant a product was home compostable, industrially compostable, would cause no harm to the marine environment, or would cause less harm if it was littered.

These behavioral trends indicate additives are counterproductive to the concerted efforts of industry and NGOs to change littering behavior and promote correct composting behaviors and responsible disposal.

 

---

 

Summary

While the material composition or performance qualities of biodegradability additives may change over time, their underlying impacts tend to remain the same — they break down a package into smaller fragments while confusing consumers. They have been found to be detrimental to recycling efforts, composting efforts, and open and marine environments.

For the reasons stated above, the SPC maintains its position firmly against the use of any additive in any petroleum-based plastic.

Additional Industry Position Statements

The SPC supports the position statements of the following organizations:

• Association of Postconsumer Plastics Recyclers (APR) — Statement on the Effects of Degradable Additives on Plastics
  Recycling
• Ellen MacArthur Foundation — Oxo Statement
• National Association for PET Container Resources (NAPCOR) — Degradeable Additives Provide Poor End-Of-Life Option For Pet Packaging

 

---

 

For more on biodegradability, please see the SPC’s Position on Biodegradable Packaging.

To learn more, contact spcinfo@greenblue.org.

1. “Biodegradable” is a confusing and imprecise term.

• • “Biodegradable” refers to materials that have the ability to break down by biological means into the raw materials of nature. On its own, the term does not indicate a specific time frame or environment for when a product will break down. Learn more here.
  • “Compostable” refers to materials that meet third-party standards and yield carbon dioxide, water, inorganic compounds, and biomass at a rate consistent with the biodegradation of natural food materials, while leaving no distinguishable remnants or unacceptable levels of toxic residues.
  • “Bio-based” refers to products that are derived from raw materials such as plants and other renewable agricultural, marine, and forestry materials. It explains the origins of a product (i.e. how it was sourced), not what will happen to it at its end-of-life.

Companies should use the most specific term that applies to their packaging; e.g. if the packaging has been certified compostable, use the term “compostable” rather than “biodegradable”.

 

2. Biodegradability marketing claims are increasingly unlawful.

It is illegal in California, Maryland, Minnesota, and Washington to use the term “biodegradable” in marketing claims related to plastic products and/or bags. The Federal Trade Commission’s “Green Guides” also offer guidance on how marketers should avoid using these terms in ways that lead to consumer deception, and explicitly state that “Unqualified degradable claims for items that are customarily disposed in landfills, incinerators, and recycling facilities are deceptive because these locations do not present condition in which complete decomposition will occur within one year.”

 

3. Biodegradable packaging does not align with third-party certification programs.

Third-party certification programs for compostable packaging, such as BPI, stress the importance of designing packaging to ASTM standards for compostability and verifying degradation with third-party testing. BPI has issued labeling guidelines for companies that emphasize the importance of clear, specific labeling on packaging. GreenBlue’s How2Compost program requires that a package first be BPI certified before it can receive the How2Compost label.
Learn more: SPC’s Guide to Understanding the Role of Compostable Packaging

 

4. Biodegradable packaging can contribute to littering and consumer confusion.

Consumer research indicates that the term “biodegradable” is not well understood by consumers, and can result in consumers discarding packaging on the ground (littering). It is unclear what will happen to the packaging when it is thus discarded in the open environment because of the immense range of climatic conditions; as a result, this behavior should be discouraged.

 

---

 

For more on biodegradability additives, please see the SPC’s Position on Degradability Additives.
To learn more, contact spcinfo@greenblue.org.