The Rt Hon George Eustice
Secretary of State
Department of Environment, Food and Rural Affairs (DEFRA)
Marsham Street,
London SW1P 4DF
June 1st 2020
Dear Secretary of State,
Re: oxo degradable/oxo biodegradable/oxo fragmentable plastics
We the undersigned associations call upon the Government to implement a total ban on the use, sale
and distribution in the UK of conventional non-biodegradable plastics containing additives, which are
meant to accelerate the fragmentation of plastics into microplastics. Such plastics are variously known
as “oxo degradable”, “oxo biodegradable” “oxo fragmentable” “bio-assimilable” but the definitions
are not exhaustive (1).
The UK voted for the European Single Use Plastics Directive (Directive 2019/904
https://eurlex.
clause at Article 5 that “Member States shall prohibit the placing on the market of the single-use
plastic products listed in Part B of the Annex and of products made from oxo-degradable plastic.”
Whilst the UK has left the EU we have retained the ambition to achieve at least the equivalent of
European environmental norms. At the same time, were the UK to allow these plastics, anything
containing them or packaged in them could not be exported to EU markets.
The ban on the use of oxo additives regards not just the EU. The USA also has effectively stopped the
sale of such additives by adjudging that the use of marketing terms such as biodegradable for plastics
using these additives is considered misleading. Companies have been fined for using such terms and
as a result these additives are not used in the USA. (2)
Why should this ban be implemented now?
As the UK is now in the process of revising legislation on the use of plastic packaging, now is the time
to act. Overwhelming scientific evidence, including research commissioned by DEFRA (3) and the EU, has
demonstrated beyond doubt that the claims these additives transform polyolefin plastics into
biodegradable plastics are unfounded. It is scientifically well-known that all polyolefin plastics are
naturally prone to oxidation under environmental conditions (aging). Such oxidation ultimately leads
to fragmentation and formation of microplastics, which build up in oceans and in soil.
The "oxo-additives" are designed to accelerate the natural oxidation of polyolefins, causing an early
fragmentation and the fragmentation of plastic products into microplastics. Thus the effect of these additives (if any) is merely to accelerate the conversion of macroplastics into microplastics, not solving the global problem of plastic pollution but worsening it.
Even the claimed disintegration effectiveness is questionable, under some environmental conditions.
Experiments undertaken by the University of Plymouth (4) in 2019 showed that plastic films claiming to
be “degradable” due to the oxo additives in them, remained intact in the sea and in soil after 3 years.
The UK Advertising Standards Authority in 2019 also found that the use of the term “biodegradable”
for dog poop bags made from oxo plastics were misleading as after 2 years these bags were still
undegraded. (5) Nevertheless, they are still sold in the UK.
Moreover, such plastics are not recyclable as the powders contained in them assist degradation and
therefore render instable plastic polymers when recycled together. These plastics are also not
compostable and lead to confusion among consumers and retailers who consider them to be
biodegradable as if they were compostable.
A very wide coalition of signatories including some of those signing here, led by the Ellen Macarthur
Foundation, called for a ban as long ago as 2017 that was reiterated in 2018 (6). That is attached. We
wish to remind you of the call from the Foundation and reiterate it ourselves here.
Whilst we in the UK are ourselves introducing national bans on single use plastics now is the time to
also ban the scourge of plastic fragments deriving from oxo additives. We hope you will act quickly to
implement this ban in the UK without further delay and respect the undertaking the UK voted for
when this issue was raised in the EU.
Yours sincerely,
Signatories (in alphabetical order)
ABBA
ADBA’s members include AD plants that receive food waste and the use of oxo degradable bags is a
contaminant they have to extract and landfill or incinerate.
BBIA
BBIA’ members are producers of certified compostable plastics and packaging whose industries are
damaged by competing against uncertified and unsubstantiated claims of biodegradability such as
those from oxo manufacturers.
ESA
The ESA’s members include the major UK waste companies that receive but cannot recycle or compost
oxo degradable plastics, increasing the landfilling and incineration of them and disrupting plastic
recycling.
FPA
The FPA’s members serve food and drink to the public and the use of oxo degradable materials reduces
the possibility of recycling or composting those containers.
Greenpeace
Greenpeace is an independent campaigning organisation, which uses non-violent, creative
confrontation to expose global environmental problems, and to force the solutions which are essential
to a green and peaceful future. Greenpeace's goal is to ensure the ability of the earth to nurture life
in all its diversity.
A Plastic Planet
A Plastic Planet is a UK organisation campaigning for the reduction of plastic use and waste.
REA
REA’s members include companies who compost food, garden and compostable packaging waste and
who similarly anaerobically digest food waste and all have to extract and dispose of oxo degradables.
RECOUP
RECOUP are a cross sector member based charity working across the plastic value chain to improve
UK plastic resource efficiency and recycling.
(1) We refer to any plastics to which additives are put in the master batches which disintegrate plastics into
fragments and microplastics and which are not certified as “biodegradable” under the standards recognised within UK law such as BSI 13432, BSI 14995, BSI 17033.