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FTC Green Guides: Biodegradable Glossary


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Based on the FTC Green Guides, this glossary developed by J. Ottman Consulting provides a clear breakdown of the various terminologies used in sustainability communications, including when to use "biodegradable" vs other terms such as "compostable", "renewable", "natural", or "biobased". This tools aims to help communications avoid inadvertent "greenwashing" and possible backlash.

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FTC Green Guides: Biodegradable Glossary

  1. 1. 1 Biodegradable? Renewable? Natural? Compostable? Biobased? Think these green marketing claims all mean the same thing? Think again! They are all very different, with unique scientific and legal definitions. Using them interchangeably or incorrectly (according to either the dictionary or more pointedly, the FTC’s Green Guides for Environmental Marketing) could result in accusations of greenwashing or just confuse your customers and end-consumers. Here’s a “cheat sheet” based upon Webster dictionary definitions, FTC Guidelines for Environmental Marketing Claims (the ‘FTC Green Guides’, and as applicable, FDA and USDA. When available, we’ve included a reputable eco-label and made some additional comments. ‘Biodegradable’ Webster: Capable of being broken down especially into innocuous products by the action of living things (as microorganisms) FTC Green Guides (Section 260.8): Entire item will completely break down and return to nature within a reasonably short period of time after customary disposal; must completely decompose within one year if entering solid waste stream (i.e., a landfill). The FTC has consistently found that unqualified biodegradable claims for both plastics and paper are misleading. Below are links to recent decisions: • 2014/03/ftc-approves-final-order-settling- charges-down-earth-designs-inc • 2013/10/ftc-cracks-down-misleading-unsubstantiated- environmental Ottman and Eisen: Biodegradable and compostable are cousins. The terms are related in that both, when used properly, represent the breakdown of materials into harmless components, either aerobically (with air) or anaerobically (without air). Something that is compostable is by definition biodegradable under the proper conditions. Liquids can also be biodegradable (like a cleaning product). Suggestion: use the claim ‘biodegradable’ for liquids that are designed to ‘go down the drain’ and ‘compostable’ for solids intended for composting in municipal or industrial facilities. And keep in mind that landfills are designed so that their contents —not even food or paper— will not degrade (Degradation results in methane, a greenhouse gas that is 23 times more potent than CO2 and highly combustible, and landfills often support structures. LaGuardia and JFK are both built on landfill.). So if a potato chip bag or a plastic cup is marked ‘compostable’ chances are it will not degrade in a landfilll (ever or for hundreds of years), and consumer confusion over same can result in greenwash accusations and possibly lawsuits. Like many green marketing claims, biodegradability is proven by laboratory tests conducted according to agreed upon industry standards; if desired, the claim and its third party scientifically supported proof can then be certified by an independent organization and awarded a label for marketing purposes. (Government agencies, nonprofits, trade groups and for-profit companies can all certify claims and award labels.) In the US, industry standards are issued by ASTM International, a nonprofit organization that develops and publishes approximately 12,000 technical standards, covering the procedures for testing and classification of materials of every sort. Their standards cover biodegradation of plastics under accelerated landfill conditions; non-floating biodegradable plastics in the marine environment;
  2. 2. 2 degradation in the environment by a combination of oxidation (including photodegradation) and biodegradation; and anaerobic biodegradation in the presence of municipal sewer sludge. The Biodegradable label pictured here is a service of SCS Global Services, a Certified B Corporation based in Oakland, California. Using internationally recognized ‘readily biodegradability’ standards (ASTM 1720E and OECD 310), SCS verifies that cleaning and sanitation products degrade safely and efficiently in an aerobic environment and confirms that chemicals are not building up in the environment to harmful concentrations before degradation occurs. ‘Photodegradable’ (degradation in the presence of sunlight) claims for plastics are largely out of vogue since Hefty trash bags made this claim in 1991 and was sued by attorneys general in seven states. The issue: although the bags would ‘degrade’ in the presence of sunlight, 90% of the bags would wind up in landfills where there was no sunlight. Further, their their claim would need to have been qualified by indicating that the plastic component (which represented 94% of the product; the other 6% being cornstarch) breaks into little pieces only, but does not return to nature. Some petroleum-based plastics are ‘oxo-degradable’ indicating that the material may oxidize and begin the process of breaking down but does not return to nature. Naturally, manufacturers don’t want to claim their plastic degrades but stays in the environment. ‘Compostable’ Webster: adj. for compost, a mixture that consists largely of decayed organic matter and is used for fertilizing and conditioning land FTC Green Guides (Section 260.7): All the materials in the item will break down into or otherwise become part of usable compost (e.g., soil conditioning material, mulch) in a safe and timely manner (i.e., in approximately the same time as the materials with which it is composted) in an appropriate composting facility, or in a home compost pile or device; qualify if municipal or institutional composting facilities are not available to a substantial majority of consumers or communities where the item is sold. Ottman and Eisen: When products that claim to be compostable without scientific substantiation are accepted into composting facilities, sewage treatment facilities, or used in agriculture, they can leave behind significant amounts of non-biodegradable fragments (often plastic). Each year municipal composters lose thousands of dollars from eliminating plastic fragments and litter that contaminate finished compost. Partially degraded plastic fragments can harm fertile farmland or spoil natural surroundings. ASTM standard D6400 and ASTM D6868 are used to verify compostability of plastics designed to be aerobically composted in municipal or industrial facilities, as well as to determine aerobic biodegradation of plastics under controlled composting conditions. That standard undergirds the Compostable logo viewed here, issued by BPI (formerly, the Biodegradable Products Institute, According to BPI, there is no ASTM standard (or accompanying certification) for items that will breakdown in backyard facilities. ‘Renewable’ (materials) Webster: Capable of being replaced by natural ecological cycles or sound management practices USDA: In the context of biobased products, renewable resources include agricultural, forestry, and marine resources such as algae.
  3. 3. 3 FTC Green Guides (Section 260.16): (Advises marketers to) minimize risk of consumer misinterpretation by identifying material used and explaining why it is renewable; qualify any “made with renewable materials” claim unless the product or package is made entirely with renewable materials. Ottman and Eisen: Whereas biodegradable and compostable are kissing cousins, renewable and biobased (see below) are the fraternal twins of claims. Renewable is a term that resonates with consumers, while biobased is a technically accurate scientific term. Keep in mind, as detailed in the section below, that ‘non-renewable’ (as a descriptor for fossil fuels) means ‘more than 62,000 years old’, so unless qualified, ‘renewable’ could technically mean able to be regrown in 61,000 years! The LEED certification system for green buildings defines ‘Rapidly renewable’ resources as agricultural products derived from both plant and animal sources that take ten years or less to harvest. ‘Biobased’ Webster: Not defined Business Material or product derived from biological or renewable resources FTC Green Guides: FTC Green Guides defer to USDA, who defines biobased as follows: USDA Technical Definition of ‘Biobased’: A product determined by the USDA Secretary of Agriculture to be a commercial or industrial product (other than fuel or feed) that is composed, in whole or in significant part, of biological products, including renewable domestic* agricultural materials (including plant, animal and aquatic materials), forestry materials or an intermediate ingredient or feedstock. A ‘forest product’ means a product made from materials derived from the practice of forestry or the management of growing timber and includes pulp, paper, paperboard, pellets, lumber and other wood products; and any recycled products derived from forest materials. ( *includes trading partners According to the USDA, Biobased products generally provide an alternative to conventional petroleum derived products and include a diverse range of items including lubricants, detergents, inks, fertilizers, and bioplastics. Ottman and Eisen: The USDA Certified Biobased Product label pictured here is based upon the ASTM D6866 Standard Test Methods for Determining the Biobased Content of Solid, Liquid, and Gaseous Samples. Biobased is a scientific term and the percent biobased content of a product is verified using radiocarbon dating and internationally recognized standards that measure the ratio of new organic carbon to total organic carbon in a product. New organic carbon is derived from plants and other renewable agricultural, marine (including algae), and forestry materials. Total organic carbon consists of new organic carbon and old organic carbon that originates from petroleum. Biobased product content percentage does not include water or inorganic material and can be measured using ASTM D6866. The USDA Certified Biobased label generally supports a claim of renewability and the word ‘renewable’ can be readily used and understood when used as a claim for most commercially grown materials without qualification or FTC challenge. Products made from bio-based materials are often biodegradable but this is not always the case. For instance, the materials may have undergone a certain type of processing that renders them non-biodegradable, or they may be united in processing with non-degradable materials, e.g., a blend of bamboo and polyester that hinder biodegradation. Over 1500 products have been recognized as USDA Certified Biobased Products since the label’s launch in 2011.
  4. 4. 4 ‘Natural’ Webster: Existing in nature and not made or caused by people: coming from nature: not having any extra substances or chemicals added: not containing anything artificial FTC Green Guides: Not defined in FTC Green Guides (presumably because is has been defined by the FDA and USDA for use in food products including flavoring, colorings, additives, and in meat and poultry products.) Nevertheless, FTC has stated that advertisers must be able to substantiate whatever message their ‘natural’ claims reasonably convey to consumers. Ottman and Eisen: The term ‘natural’ is more strongly associated with ‘heath’ than ‘environmental’ claims, hence its prevalence in personal care products, apparel, and food products. ‘Natural’ ingredients are not necessarily healthy (or healthier or less harmful to health than synthetics) — Arsenic is natural!) Not surprisingly, claims of ‘natural’ are problematic and much litigation has resulted. The ecolabel viewed here is a service of the Natural Products Association, an advocacy group whose members consist of manufacturers and retailers of personal and home care products, foods, dietary supplements, and health/beauty aids. According to its website, the Natural Products Association was founded in 1936 and is the nation’s largest and oldest nonprofit organization dedicated to the natural products industry. Its 1,900 members represent over 10,000 retail and manufacturing locations, $117 billion in sales and have certified over 1,100 products and ingredients based on the organization’s published standards. In addition… The FTC Green Guides do not define the term ‘Sustainable’, for various reasons, given confusion with the term ‘renewable’, and presumably because ‘sustainability’ encompasses ‘environment’, as well as ‘economy’ and ‘social’, which are outside the scope of the Guides. The FTC Green Guides defer to the USDA for a definition of ‘organic’. In Europe, ‘organic’ means ‘biobased’. According to the USDA Organic website (, USDA Organic is a labeling term that indicates that the food or other agricultural product has been produced through approved methods that integrate cultural, biological, and mechanical practices that foster cycling of resources, promote ecological balance, and conserve biodiversity. Synthetic fertilizers, sewage sludge, irradiation, and genetic engineering may not be used. EN This document prepared by Jacquelyn Ottman, founder, principal of J. Ottman Consulting, Inc. Ms. Ottman advised the USDA on its launch of the USDA Certified Biobased label in 2011. For more information, please contact Ms. Ottman at Info [at] greenmarketing [dot] com. The information contained herein is intended as educational/ reference only and does not constitute technical or legal advice. Consult with appropriate technical and legal resources when making environmental marketing claims. Copyright (c) 2013 J. Ottman Consulting, Inc. This document may not be reproduced or distributed without permission of the author. All Rights Reserved. Click here to visit