A number of food packaging materials are looking to composability claims in an effort to gain premium sustainability and environmental credit from consumers.
This is particularly so with compostable plastic that plays a key role in the UK Plastics Pact, with signatories including the UK’s biggest supermarkets committing to make 100% of plastic packaging reusable, recyclable or compostable by 2025 as well as a range of newly formulated organic products.
However, the care and detail with which any ‘green’ claim should be made and substantiated and the limits of what can be claimed in relation to biodegradability was underlined by a recent Advertising Standards Authority (ASA) adjudication of Q River Ltd baby wipes.
The two key points from this adjudication were that
- Where test results relied on optimal conditions this did not replicate the reality sufficiently to permit appropriate substantiation.
- Where an absolute green claim is made the full life cycle of the product will be taken into account; including how it actually breaks down and decomposes. If its’ disposal could cause a negative impact on the environment this will be considered.
The ASA found that the product in question was organic and would release methane as it decomposed anaerobically therefore an absolute green claim could not be made.The fact that composting an organic product may result in the emission of gasses (even in a very small amount) that may be construed as having a negative impact on the environment, such as methane, will need to be actively addressed in any green claim and may result in some limitation of claims.
An overview of the ruling and key factors is provided below:
Q River Limited – baby wipes Q River Ltd - ASA | CAP 21 Oct
Ads referred to Mum & You baby wipes as 100% biodegradable and featured the claim “our wipes break down quickly after they are thrown away; in as little as 15 days; even in landfill conditions”.
The advertiser had provided three test reports confirming the wipes fully biodegraded in the test conditions within 15 days. However, the test was carried out under optimal conditions, (anaerobic conditions, the wipes were clean and were broken down to 1mm and were then mixed with methane producing bacteria and kept in an incubator set at 37 degrees Celsius for the duration of the test) and it did not replicate the condition of the wipes at the time of disposal or the conditions of a landfill, including when rubbish first arrived there. The ASA therefore considered the test was not appropriate to substantiate a claim that the wipes would completely biodegrade within 15 days of arriving at a landfill.
The ASA considered that when the wipes were disposed of, they would often not be suitable for home composting because they would be contaminated with matter that should not be composted.
The report produced by the manufacturer of the viscose fibre used in the wipe stated that the fibre was fully compostable in soil conditions according to the European standard EN13432. However, the ASA considered that because:
- the wipe was made up of ingredients other than the viscose fibre,
- the test did not state the time rate the viscose composted and test conditions optimal ie mature compost, 25 C, dark, stirred, clean wipes
- the wipe was not completely biodegraded within 15 days, and
- the test was carried out under optimal conditions and it did not replicate the conditions consistently found when home composting,
The ASA concluded that the test did not substantiate the claim as consumers would understand it.
Absolute claim re life cycle
The ASA considered that consumers would understand the claim “Being biodegradable is important to us as it means today’s mess won’t be a problem for tomorrow’s generation” to mean that, once the wipe had been disposed of, it would not have any negative impact on the environment. The ASA considered that this was an ‘absolute’ claim. The ASA therefore expected to see evidence relating to the environmental impact of the wipe for the entire life cycle including after disposal.
When organic waste, such as the advertised wipe, biodegraded in landfill anaerobically, it would emit methane. The ASA understood that some landfills collected some of the methane that was produced, but that not all did. Because methane was a highly potent greenhouse gas, if it was released into the atmosphere it contributed to global warming; a problem which would affect future generations. The ASA therefore considered that the disposal of the wipe could have a negative impact on the environment and had not seen evidence to the contrary therefore the complaint against this environmental claim was upheld.