FURTHER NOTES ABOUT

AS4736 is an Australian Standard® Biodegradable plastics—Biodegradable plastics suitable for composting and other microbial treatment

This is totally different from ASTM 6954 thus Reverte won’t be able to meet this AS4736 requirement.

Reverte oxo-biodegradable additive masterbatch and bags are not compliant to the criteria stated in AS4736 which is an Australian Standard® Biodegradable plastics—Biodegradable plastics suitable for composting and other microbial treatment documents. Well Plastics UK are in the same opinion as the Oxo-biodegradable Plastics Association that bio-based is the wrong technology (reason is as attached). Composting is an artificial process operated according to a much shorter timescale than the processes of nature, and EN13432 itself says that is not appropriate for waste which may end up in the environment through uncontrolled means.

As explained during our discussion, there are numerous articles and studies that proved that bags are not supposed to biodegrade in landfill that is anaerobic (without oxygen). This is because it will release methane gas which causes 23 times more greenhouse gas effect that contributes to climate change. However if oxygen is present in the landfill, film containing Reverte that is oxidized to low molecular weight will be able to biodegrade.

Oxo-biodegradable plastic products are bioassimilated in the same way as nature’s wastes after their molecular weight has reduced to 40,000 Daltons or less. They are normally tested according to ASTM D6954-04 “Standard Guide for Exposing and Testing Plastics that Degrade in the Environment by a Combination of Oxidation and ” British Standard 8472, Swedish Standard SPCR 141 or UAE Standard 5009:2009. The tests performed according to ASTM D6954-04 tell industry and consumers what they need to know – namely whether the plastic is (a) degradable (b) biodegradable and (c) non eco-toxic. ASTM D6954-04 not only provides detailed test methods but it also provides pass/fail criteria. I attached all the important documents and biodegradation summary report which API may show to the customer.

I think we need to explain and emphasize the following to enhance the potential for oxo- biodegradable technology to the customer:

1. At the present time plastic packaging is the best option for protecting many foods and other goods from damage and contamination and for carrying them home. It is waterproof, strong and flexible; it can be adapted for a variety of products, it is not expensive, and is made from raw materials which are readily available.

2. However, because conventional plastics is not degradable and flexible packaging is non- recyclable; pollution due to carelessly discarded post-consumer plastics waste is now a worldwide problem and the issue is what to do with the thousands of tons of plastic waste which cannot realistically be collected for or other forms of responsible disposal, and escapes into the open environment, endangering wildlife and clogging up waterways?

3. In order to meet this specific challenge oxo-biodegradable plastic has been invented and developed by very distinguished polymer scientists.

4. It is important to distinguish between the different types of biodegradable plastic, as their costs and uses are very different. We should not use the generic term “biodegradable plastic” as this causes confusion. It should be clearly understood that there are two very different types of biodegradable plastic:

a. “Compostable” - (also loosely known as “bio-based plastics” or “”) and designed according to EN13432 to biodegrade in the special conditions found in industrial composting and will not biodegrade in the open environment, and

b. Oxo-biodegradable - made from petroleum-derived polymers such as PE, PP and PET, containing active ingredients (which do not include “heavy-metals”) designed according to ASTM D6954 to degrade and biodegrade in the open environment leaving no harmful residues. (Oxo-degradation is defined by CEN in TR15351 as “degradation resulting from oxidative cleavage of macromolecules.” And oxo-biodegradation as “degradation resulting from oxidative and cell-mediated phenomena, either simultaneously or successively.”)

5. If we are concerned about in the environment there is no point in choosing “compostable” plastics which obviously have to be collected before they can be composted. By contrast, oxo-biodegradable plastics can be re-used and recycled during their useful life, and only if they do not get collected will they ultimately biodegrade in the open environment by a two stage process; (a) oxidative degradation, which is chain scission in presence of heat and sunlight, followed by (b) biodegradation. Oxo- biodegradable plastic does not just fragment, but will be consumed by bacteria and fungi after oxidative cleavage has reduced the molecular structure to a level which permits living micro-organisms access to the carbon and hydrogen. It is therefore "biodegradable" in the open environment. This process continues until the material has biodegraded to nothing more than CO2, water, and humus, and it does NOT leave fragments of plastic in the environment. This has been specifically tested by third party laboratories and proven that bags containing Reverte biodegrade completely without leaving behind any toxic residues.

6. There is little additional cost of using oxo-biodegradable plastic, since it can be made with the same indigenously available polymer grades; machinery and workforce as conventional plastic. The time taken to degrade can be 'programmed' to a few months or a few years, depending upon requirements of various applications. And, until the plastic degrades it has the same strength and other characteristics as conventional plastic. Packaging is protected from degradation by antioxidants until used up.

7. Oxo-biodegradable plastic is already used by environmentally-responsible companies in more than 50 countries around the world and is mandatory in some parts of Africa, Asia and the Middle East, where governments recognise that making plastic smarter is preferable to trying to ban it. They do not want to leave plastic waste in the environment as a problem for future generations, and they understand that oxo-biodegradable plastic offers a solution to this problem. (see attached Emirates Conformity Assessment Scheme). Saudi Arabia had also fully implemented this.

8. Recognising the potential of oxo-biodegradable plastics, recently the EU Parliament has requested the Commission to make a study of all types of biodegradable plastics, including oxo-biodegradable. When the credentials of oxo-biodegradable technology have been proved to the Commission we would expect to see it adopted by the EU to deal with the problem of plastic waste which gets into the outdoor environment and cannot realistically be collected.

9. In UAE, the Federal standards body, Emirates Standards and Metrology Authority (ESMA) has developed UAE.S 5009- 2009, 'Standard for Oxo-Biodegradable bags and disposable plastics packaging'; and has already legislated for mandatory use of 'Oxo-Biodegradable' bags and disposable packaging wef January 1, 2013. (see attached UAE Ministry of Environment notification number 118,2013)

10. In February 2011 a Life Cycle Assessment by Intertek was published by the UK Environment Agency which shows that oxo-biodegradable plastic bags have a better LCA than bags or compostable plastic bags. In May 2012 a further LCA by Intertek included the litter metric and compared oxo-biodegradable plastic with bio-based plastic and conventional plastic. It put oxo ahead in its potential to reduce the plastic waste problem and its less harmful impact on the environment and on global warming. In its ability to reduce plastic litter, oxo-bio scored 75% better than conventional plastic, and bio-based plastics were worse than oxo in all 11 environmental impact categories. (https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/29102 3/scho0711buan-e-e.pdf).

11. Oxo-biodegradation has been studied in depth at the Technical Research Institute of Sweden and the Swedish University of Agricultural Sciences, and a peer-reviewed report of the work was published in Vol. 96 of the journal of Polymer Degradation & Stability (2011) at page 919-928. It shows 91% biodegradation in a soil environment within 24 months, in accordance with ISO 17556 and it does NOT therefore leave fragments of plastic in the environment.

12. Oxo-Biodegradable plastics are proven to be food contact safe meeting FDA and EU requirements for approval.

13. However, there are also a number of other companies in USA, Canada, United Kingdom, Sweden and Japan, offering their own oxo-biodegradable technology; so this technology is now widely available from various sources ensuring that a competitive market already exists.

Conclusions and recommendations:

We hope the above information is helpful to you and in conclusion we would like to suggest that:

A. The use of oxo-biodegradable plastics is mandated in the Rules for ‘carry bags, plastic sheets or like, agricultural mulch film and multilayered packaging’.

B. The use of compostable plastics is mandated in the Waste Management Rules for garbage bags used for organic waste collection and disposal in composting facilities since there are a portion of composting facility in Australia. As such, we would say that it is not appropriate for the government department to use Reverte garbage bags if the end disposal state would be in a composting machine.

Notes from Wells Plastics UK the developer and owner of Reverte™ Oxo-Biodegradable technology.