European Commission ignores own report

Why has the European Commission ignored its own specially commissioned report?

REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the impact of the use of oxo-degradable plastic, including oxo-degradable plastic carrier, on the environment – 16.1.2018 COM(2018) 35 final.

Why has the European Commission ignored its own specially commissioned report and instead based the above on other biased reports? Why is the EC looking at restricting the use of oxo-biodegradable technology in the fight against plastic waste in the environment whilst many other countries, having considered the credentials behind brands such as Reverte™ and recognised the benefits, are encouraging its use?

Wells Plastics has read the above report and whilst we believe there are a number of statements made in it that we consider highly inaccurate in relation to oxo-degradable plastics in general, we would like to emphasise that these are certainly not representative of our oxo-biodegradable additive know by the brand name of Reverte™.

Wells Plastics expected this report to have been firmly based on the final report regarding “The Impact of the Use of Oxo-degradable Plastic on the Environment” commissioned by the European Commission and compiled by independent consultants at Eunomia Research & Consulting which was issued in April 2017. The findings in this report were generally agreed both within and outside of the plastics industry to have been extensive, well considered and fair. Wells Plastics is in agreement with the main recommendation which is that:-

“The debate around the biodegradability of oxo-degradable plastic is not finalised, but should move forward from the assertion that oxo-degradable plastics merely fragment, towards confirming whether the timeframes observed for total biodegradation are acceptable from an environmental point of view and whether this is likely to take place in natural environments”.
Instead Wells Plastics notes that the report generally takes reference from other reports, the majority of which are inextricably linked to the (so-called) European biopolymer industry and are what Eunomia refer to in their conclusion above “should move forward from the assertion that oxo-degradable plastics merely fragment”.

Reverte™ has been developed and extensively tested over the last 10 years and during this time Wells Plastics has expended significant resources in obtaining independent credentials supporting all the claims made about the performance of the product with regards to the criteria specified in ASTM D6954-04 (2013). The credentials behind Reverte™ were not requested or used by the authors of this report so many of the points made and in particular the conclusions drawn are not applicable to Reverte™.

In particular we would like to highlight the following points in the report as not being applicable to Reverte™:

“So called oxo-plastics or oxo-degradable plastics are conventional plastics which include additives to accelerate the fragmentation of the material into very small pieces, triggered by UV radiation or heat exposure. Due to these additives, the plastic fragments over time into plastic particles, and finally microplastics, with similar properties to microplastics originating from the fragmentation of conventional plastics”.

Whereas Wells Plastics recognises that some oxo-degradable additives may not have conducted sufficient testing and collected evidence contrary to the above, plastics containing Reverte™ do not simply fragment into plastic particles, and finally microplastics but rather firstly, Reverte™ causes changes to both the molecular and chemical nature of the polymer molecules through a process of oxidation, to produce hydrophilic oxidised carbonaceous material which secondly will biodegrade harmlessly into the environment (it should be noted that this process of molecular and chemical change in the polymer preceding biodegradation is common for all types of plastics whether oxo-biodegradable or compostable/hydro-biodegradable). Wells Plastics has full independent testing data available to support this statement.

“Potential toxic effects on soils of residual additives from oxo-degradable plastics have been identified as a concern. Conclusions valid for all oxidising additives used can however not be drawn, because different oxidising additives are used in different concentrations”.

There are no toxic effects on soil from the use of Reverte™ in plastics and Wells Plastics has independent testing data to support this statement. To the contrary Reverte™ films have been used for many years as agricultural mulch films helping to boost crop production with no negative impact on the quality or safety of the food produce. Wells Plastics is proud to state that Reverte™ and plastics containing Reverte™ have been put through extensive toxicological testing such as OECD 207, 208 and both are fully compliant.

“Claims presenting oxo-degradable plastic as an "oxo-biodegradable" solution to littering which has no negative impact on the environment, in particular by not leaving any fragments of plastic or toxic residues behind, are not substantiated by evidence”.

Concerning the use of Reverte™, Wells Plastics does indeed have substantiated evidence to support its claim about Reverte™ being a positive solution towards dealing with the issue of plastic waste which ends up in the open environment. Wells Plastics believe that the use of Reverte™ in plastics packaging makes a positive impact on the environment and can see no scientific reason why the plastics industry should not be able to utilise and benefit from this fully tested and proven technology.

Reverte™ is an oxo-biodegradable additive which has been developed by Wells Plastics, a company with over 33 years of research, development, production experience and knowledge. This critical knowledge of plastics, state of the art ISO 9001 production site, extensive independent third party testing results, and thousands of internal oxo-biodegradability tests for our customers generated in our onsite laboratories operating in accordance with ISO17025, means that Reverte™ is a proven product backed by credentials that fully support all the claims we make.

The final sentence of the report states that “a process to restrict the use of oxo plastics in the EU will be started”. Given the substantial credentials behind Reverte™, Wells Plastics plans to actively engage in this process and will fight against any future restriction on the use of Reverte™ that might be considered by the EU.