World Centric Staff
The compostables industry currently sees labeling as the most effective way of reducing contamination in the composting material stream. It is our position that this “one piece” has been given an outsized role in many of the conversations about certification labeling policy and that greater emphasis needs to be placed on the practice of commercial composting and the standards to which they are held.
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New labeling principles published by the USCC and BPI and implemented with a patchwork approach in a select number of US states, set standards for labeling such as requiring the inclusion of a 3rd party product certification mark on the product through embossing, printing or stickers, and/or product tinting or striping in distinguishable colors like green, brown, or beige with the assumption that this will lead to less contamination at composting facilities.
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Key Takeaways:
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This article will more carefully consider whether or not labeling requirements and regulations do indeed lead to less contamination at composting facilities nationwide. The voice of the product manufactures, unfortunately, has been largely omitted from this issue. An issue which greatly impacts the look, feel, performance, and availability of their items. Upon review of a scant library of case studies and quantifiable data sets, the truth is not as straightforward as one might think.
The Growing Significance of Compostable Packaging
Composting is a steadily growing industry in the United States. In its report on a comprehensive 2023 survey following up on an earlier survey from 2018, BioCycle observes that “the number of full-scale food waste [composting] facilities [in the United States] has increased 8%, from 185 to 200 facilities—a small but notable change.” These full-scale facilities, which are typically “composting more than 2,000 tons/year of all organic waste,” do not include the many smaller facilities and the “hundreds, if not several thousand captive composting projects in the U.S. at universities and colleges, K-12 schools, correctional facilities, resorts, health care centers and corporate campuses.”
Composting is a steadily growing industry in the United States. In its report on a comprehensive 2023 survey following up on an earlier survey from 2018, BioCycle observes that “the number of full-scale food waste [composting] facilities [in the United States] has increased 8%, from 185 to 200 facilities—a small but notable change.” These full-scale facilities, which are typically “composting more than 2,000 tons/year of all organic waste,” do not include the many smaller facilities and the “hundreds, if not several thousand captive composting projects in the U.S. at universities and colleges, K-12 schools, correctional facilities, resorts, health care centers and corporate campuses.”
According to BioCycle, the majority of facilities that accept food waste take compostable packaging.
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Within this broad composting landscape, composters appear to be increasingly open to accepting compostable packaging, including compostable bioplastics, into the composting stream. Summarizing relevant trends between their 2018 and 2023 surveys.
BioCycle observes: The majority of facilities that accept food waste today take compostable packaging of some sort (71%), and this trend is growing compared to historical data (up from 58% in BioCycle’s 2018 survey). The number of facilities that accept certified compostable food-contact bioplastics packaging (e.g., foodservice ware) also increased over the past five years — 87 out of 141 (62%) in 2023 as compared to 49 out of 103 (48%) in 2018. |
It is clear that within the growing composting industry, compostable packaging is playing an increasingly important role. According to FMI, total compostable foodservice packaging sales are projected to surge at a CAGR of 4.5% between 2023 and 2033, totaling a colossal valuation of US $29.3 billion by 2033.
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Integrity of the Composting Stream
Few would argue with the idea that maintaining the integrity of the material stream processed by composting facilities is of paramount importance to the composting industry. In basic terms, achieving such integrity involves complementary aims: (1) the inclusion of compostable matter in the composting stream and, conversely, (2) the exclusion of non-compostable matter. Regarding the first of these aims, the key challenge is ensuring that as many compostable items as possible enter the stream without being diverted elsewhere. The labeling of compostable products (see this World Centric article for a breakdown) is touted as a key mechanism for ensuring that the appropriate items are indeed “accurately identif[ied]” as compostable, thus increasing the volume of compostable matter that enters (and remains in) the composting stream. |
Maintaining the integrity of the material stream processed by composting facilities is of paramount importance.
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The key challenge in meeting the second of the above aims involves not compostable items per se but their opposite: non-compostable items or, as they are widely called, contaminants, which can include materials like glass, metal, rocks, toxic materials and mostly conventional plastic the presence of such contaminants in the composting stream is considered the central obstacle to effective, environmentally beneficial composting.
Though, there is a broad growing acceptance of compostable products, Packaging Dive reports that some composters in recent years have reversed course, “implement[ing] pre-processing steps to remove compostable packaging along with contaminants.” Moreover, according to BioCycle, nearly a third (i.e., 29%) of the facilities surveyed for their 2023 report indicated that they still do not accept compostable food-contact packaging. When asked why, “78% . . . cited contamination from lookalike single-use plastic packaging and film plastic bags as the main reason.” Look alike items, commonly conventional plastic packaging and films, are often the main contaminants in the composting stream.
Look alike items, commonly conventional plastic packaging and films, are often the main contaminants in the composting stream.
Certification Labels to Counter Contamination
In view of such concerns, the inclusion of conventional plastics in the composting stream has been a persistent motivation for the drive to label compostable products. With very few peer reviewed articles available to determine precisely what type of labeling scheme is most effective, the suggested principles and current legislation is based on assumptions rather than data. The CLP/BPI report is one of the most widely circulated surveys on the topic and leaves many assumptions up for debate. (See previous article.)
Extending earlier work from 2022, the US Composting Council (USCC) in collaboration with BPI published in October 2023 a set of “Model Principles” meant to provide guidance for policy on the labeling of compostable products. The three recurring required elements for labeling are “the word ‘compostable’,” a “third-party certification mark,” and a “green, brown, or beige color or tint” (or, in some cases, a “stripe” in one of these colors).
Labeling is assumed to benefit both (a) the “end-users and consumers” (including businesses such as restaurants) who initially sort food waste into composting bins (i.e., “at the point of disposal”) and (b) the composting facilities (i.e., “composters”) who later receive this material and must determine the extent of any contamination. We will revisit below the significance of this two-part distinction as it relates to the probable utility of certification labeling.
In view of such concerns, the inclusion of conventional plastics in the composting stream has been a persistent motivation for the drive to label compostable products. With very few peer reviewed articles available to determine precisely what type of labeling scheme is most effective, the suggested principles and current legislation is based on assumptions rather than data. The CLP/BPI report is one of the most widely circulated surveys on the topic and leaves many assumptions up for debate. (See previous article.)
Extending earlier work from 2022, the US Composting Council (USCC) in collaboration with BPI published in October 2023 a set of “Model Principles” meant to provide guidance for policy on the labeling of compostable products. The three recurring required elements for labeling are “the word ‘compostable’,” a “third-party certification mark,” and a “green, brown, or beige color or tint” (or, in some cases, a “stripe” in one of these colors).
Labeling is assumed to benefit both (a) the “end-users and consumers” (including businesses such as restaurants) who initially sort food waste into composting bins (i.e., “at the point of disposal”) and (b) the composting facilities (i.e., “composters”) who later receive this material and must determine the extent of any contamination. We will revisit below the significance of this two-part distinction as it relates to the probable utility of certification labeling.
Challenging the Underlying Assumption
Recent legislation in Washington, Minnesota, Colorado, for example, coupled with the proposed guidelines by the USCC, BPI, and other policy influencers, suggests that an underlying assumption is in play—namely, that consistent certification labeling is our most important weapon in confronting the problem of contamination.
In what follows, we subject this claim to scrutiny and conclude that efforts to date have assumed an outsized role for labeling. That is, although certification labeling is important, it is just one of what are likely equally important multiple components of a solution to contamination of the composting stream.
Recent legislation in Washington, Minnesota, Colorado, for example, coupled with the proposed guidelines by the USCC, BPI, and other policy influencers, suggests that an underlying assumption is in play—namely, that consistent certification labeling is our most important weapon in confronting the problem of contamination.
In what follows, we subject this claim to scrutiny and conclude that efforts to date have assumed an outsized role for labeling. That is, although certification labeling is important, it is just one of what are likely equally important multiple components of a solution to contamination of the composting stream.
1. Labeling does not address all forms of contamination
To begin with, although somewhat obvious, it is worth bearing in mind that labeling does not address all forms of contamination. As noted earlier, contamination includes not simply look-alike plastic packaging but “glass, metal, rocks,” and “toxic or hazardous” materials (PFAs), a list to which can be added persistent herbicides and textiles. The point here is that labeling, out of the gate, has the potential to mitigate only a subset (although an important subset) of contaminants.
To begin with, although somewhat obvious, it is worth bearing in mind that labeling does not address all forms of contamination. As noted earlier, contamination includes not simply look-alike plastic packaging but “glass, metal, rocks,” and “toxic or hazardous” materials (PFAs), a list to which can be added persistent herbicides and textiles. The point here is that labeling, out of the gate, has the potential to mitigate only a subset (although an important subset) of contaminants.
Labeled products are not discernable at compost facilities.
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2. Labeled products are not discernable at composting facilities
Since there are two primary points in the composting stream at which sorting, may occur: (a) the point where end-users (i.e., consumers and businesses) decide into which waste stream a potentially compostable item should be placed and (b) composting facilities, which seek to identify and measure contaminants for possible removal from the composting stream prior to processing. It turns out that labeling’s practical utility at composting facilities, is severely restricted—as far as visual sorting out of contaminants is concerned—due to the sheer volume of incoming material, especially for full-scale commercial and municipal facilities. |
According to BioCycle, such facilities “receive and process organic waste streams arriving by truckload volumes from generators and haulers on a year-round basis” and typically compost “more than 2,000 tons/year of all organic waste.” As we have argued elsewhere, at that volume it is nearly impossible for composters to reliably distinguish acceptable from unacceptable via on-product labels on items when these loads are emptied at the site.
That is, unlike the relatively pristine conditions under which an end-user would typically check for a certification label in order to sort an individual product into the appropriate bin, the items of used packaging that arrive at composting facilities are often soiled, damaged, and literally buried within large amounts of organic matter. This makes visual inspection of individual items for the relevant labels in this context exceedingly difficult, especially at scale. Indeed, the USCC itself acknowledges that “[i]t is difficult to sift these [i.e., non-compostable man-made inerts] out of compost after they arrive at the facility.”
3. Labeling does not ensure proper sorting by end-users
Even in terms of the more ‘ideal’ environment in which end-users make sorting decisions, it is easy to overstate the role of certification labeling. Although end-users may not face the problem of volume encountered by composters, many end-users do face a deficiency of motivation and information which certification labeling itself only partially addresses.
Regarding motivation, an end-user is likely to make the effort to properly sort compostable from non-compostable packaging only if adequately motivated to do so—whether by concern for the environment or by consideration of more mundane benefits or costs (e.g., approbation or reproach of family members, neighbors, colleagues, etc. or a penalty dispensed by a municipality or institution). Arguably, present versions of certification labels do little in themselves to foster any such motivations. Strictly speaking, these labels are informational, not persuasive, in nature: They may identify the product as compostable, but in themselves they do little more.
This raises a related point: The limited information provided by certification labels does not—considered in isolation—serve as adequate composting guidance for all (or even many) end-users. That is, the bulk of information that end-users need in this regard is supplied not by the certification label on a product but in separate literature containing the guidelines that educate end-users in composting practice commonly provided to end-users by municipalities, institutions, or composters. This point seems to be acknowledged in a veiled manner by BPI when it describes the use of its Certification Mark as “the foundation of clear and consistent direction for end-users and consumers who are responsible for making decisions at the point of disposal” (emphasis added). To extend the metaphor, if labeling is the “foundation,” then the extra-label educational materials are the informational “house” that is built on that foundation. Certification labeling itself has limited utility apart from these educational guidelines.
That is, unlike the relatively pristine conditions under which an end-user would typically check for a certification label in order to sort an individual product into the appropriate bin, the items of used packaging that arrive at composting facilities are often soiled, damaged, and literally buried within large amounts of organic matter. This makes visual inspection of individual items for the relevant labels in this context exceedingly difficult, especially at scale. Indeed, the USCC itself acknowledges that “[i]t is difficult to sift these [i.e., non-compostable man-made inerts] out of compost after they arrive at the facility.”
3. Labeling does not ensure proper sorting by end-users
Even in terms of the more ‘ideal’ environment in which end-users make sorting decisions, it is easy to overstate the role of certification labeling. Although end-users may not face the problem of volume encountered by composters, many end-users do face a deficiency of motivation and information which certification labeling itself only partially addresses.
Regarding motivation, an end-user is likely to make the effort to properly sort compostable from non-compostable packaging only if adequately motivated to do so—whether by concern for the environment or by consideration of more mundane benefits or costs (e.g., approbation or reproach of family members, neighbors, colleagues, etc. or a penalty dispensed by a municipality or institution). Arguably, present versions of certification labels do little in themselves to foster any such motivations. Strictly speaking, these labels are informational, not persuasive, in nature: They may identify the product as compostable, but in themselves they do little more.
This raises a related point: The limited information provided by certification labels does not—considered in isolation—serve as adequate composting guidance for all (or even many) end-users. That is, the bulk of information that end-users need in this regard is supplied not by the certification label on a product but in separate literature containing the guidelines that educate end-users in composting practice commonly provided to end-users by municipalities, institutions, or composters. This point seems to be acknowledged in a veiled manner by BPI when it describes the use of its Certification Mark as “the foundation of clear and consistent direction for end-users and consumers who are responsible for making decisions at the point of disposal” (emphasis added). To extend the metaphor, if labeling is the “foundation,” then the extra-label educational materials are the informational “house” that is built on that foundation. Certification labeling itself has limited utility apart from these educational guidelines.
5. Labeling does not indicate what must be excluded
Labels mark only what can be included in the composting stream, not what should be excluded (i.e., contaminants). And even this information on what may be included is incomplete, as there are various types of non-labeled items/materials that are commonly allowed to enter the stream (e.g., food-soiled paper towels and napkins, uncoated paper plates and take-out cartons, pizza delivery boxes). Again, end-users must rely on the separate guidelines rather than certification labels for this information.
Labels mark only what can be included in the composting stream, not what should be excluded (i.e., contaminants). And even this information on what may be included is incomplete, as there are various types of non-labeled items/materials that are commonly allowed to enter the stream (e.g., food-soiled paper towels and napkins, uncoated paper plates and take-out cartons, pizza delivery boxes). Again, end-users must rely on the separate guidelines rather than certification labels for this information.
Labeling does not ensure degradation at the composting facility.
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6. Labeling does not ensure degradation at the composting facility
This final consideration is perhaps the most important of all the reasons presented here for why the utility of certification labeling is limited: Whether a product is awarded certification as compostable is determined based on the product’s material composition as this affects its degradability. The problem is that such degradability does not always align with its actual rate of degradation or decomposition in the field—the latter being dependent on a variety of contingent factors apart from the material itself. |
Different composting operations use different processes (windrow, ASP, in-vessel, etc.), and known compostable material substrates behave differently in these processes (e.g., fiber/paper may not degrade in ASP whereas bioplastics will, and vice versa for windrow). Moreover, even those facilities that use the same process can see different outcomes due to variance in a range of environmental factors including temperature, moisture, time of year, C:N ratio, pH levels, and exposure to sunlight, all of which can affect the rate and extent of a particular compostable product’s degradation. Length of composting cycle—which may be shortened for economic considerations as composters churn out product as quickly as possible—is yet another facility-contingent factor.
The particular environment (including the contingencies of the composting facility) in which a product is composted is at least as important as the material from which that product is made. Compostability certification—as conveyed through labeling—is a rather incomplete reflection of this relationship between product material and composting environment.
In that sense, it is not so much that test certifications are inherently “misleading” but that test certifications considered in isolation, apart from an independent assessment of the actual environment where composting will take place, can lead to an overvalued impression of the those certifications. This fact has important ramifications for future policy development.
Conclusions and Recommendations
The above discussion leads to several main conclusions as well as recommendations that follow for industry partners and policy makers:
The particular environment (including the contingencies of the composting facility) in which a product is composted is at least as important as the material from which that product is made. Compostability certification—as conveyed through labeling—is a rather incomplete reflection of this relationship between product material and composting environment.
In that sense, it is not so much that test certifications are inherently “misleading” but that test certifications considered in isolation, apart from an independent assessment of the actual environment where composting will take place, can lead to an overvalued impression of the those certifications. This fact has important ramifications for future policy development.
Conclusions and Recommendations
The above discussion leads to several main conclusions as well as recommendations that follow for industry partners and policy makers:
Acknowledging the limitations of labeling
Certification labeling is an important component in reducing contamination of the stream, and the establishment of requirements on the wording of labels (mandating “compostable”; prohibiting “biodegradable,” etc.) and visual design is a good start (where the data support these moves). However, the inherent limitations to the utility of labeling noted above should be acknowledged by industry representatives, certifying agencies, and policy makers alike. That is, even optimized labeling may primarily serve the otherwise motivated and informed consumer/business at the initial sorting stage and addresses the contamination problem only in regard to distinguishing compostable products from “look-alike” contaminants. Most importantly, by emphasizing the certification of particular products (based on their material composition), we risk overlooking the equally important role that facility-contingent factors play in determining the outcomes of the composting process.
Redressing the imbalance: Certification/regulation of composting facilities
The latter observation suggests that standardization and regulation of composting facilities specifically in regard to the effectiveness of their composting processes—is at least as important as labeling standards and regulation of products. However, although existing legislation includes a significant amount of regulation pertaining to composting facilities (e.g., various permit requirements), the vast majority of these regulations deal with public safety concerns instead of with composting outcomes per se. Even those regulations that address the latter tend to be vaguely worded—unlike the precise standards imposed on compostable products by certification agencies.
Given that certification labeling has limited ability to aid in the elimination of contaminants from the material stream at the compost facilities, perhaps what is needed is a different way to regulate the composting facilities mediated by a certification regimen (of the facilities themselves) in some ways parallel to that imposed on compostable packaging manufacturers.
Additionally, the roll out of Extend Producer Responsibility programs should provide support for technologies and operational adaptations to more efficiently and proficiently capture contaminants that will inevitably enter compost facilities. This would allow composting facilities to more equitably shoulder their share of the burden when it comes to ensuring effective, environmentally-friendly composting outcomes. It would also essentially upgrade USCC/BPI’s “encouragement” of field testing on the product side by placing the onus on composting facilities to rigorously demonstrate that they can effectively compost an appropriate range of compostable materials and products.
Certification labeling is an important component in reducing contamination of the stream, and the establishment of requirements on the wording of labels (mandating “compostable”; prohibiting “biodegradable,” etc.) and visual design is a good start (where the data support these moves). However, the inherent limitations to the utility of labeling noted above should be acknowledged by industry representatives, certifying agencies, and policy makers alike. That is, even optimized labeling may primarily serve the otherwise motivated and informed consumer/business at the initial sorting stage and addresses the contamination problem only in regard to distinguishing compostable products from “look-alike” contaminants. Most importantly, by emphasizing the certification of particular products (based on their material composition), we risk overlooking the equally important role that facility-contingent factors play in determining the outcomes of the composting process.
Redressing the imbalance: Certification/regulation of composting facilities
The latter observation suggests that standardization and regulation of composting facilities specifically in regard to the effectiveness of their composting processes—is at least as important as labeling standards and regulation of products. However, although existing legislation includes a significant amount of regulation pertaining to composting facilities (e.g., various permit requirements), the vast majority of these regulations deal with public safety concerns instead of with composting outcomes per se. Even those regulations that address the latter tend to be vaguely worded—unlike the precise standards imposed on compostable products by certification agencies.
Given that certification labeling has limited ability to aid in the elimination of contaminants from the material stream at the compost facilities, perhaps what is needed is a different way to regulate the composting facilities mediated by a certification regimen (of the facilities themselves) in some ways parallel to that imposed on compostable packaging manufacturers.
Additionally, the roll out of Extend Producer Responsibility programs should provide support for technologies and operational adaptations to more efficiently and proficiently capture contaminants that will inevitably enter compost facilities. This would allow composting facilities to more equitably shoulder their share of the burden when it comes to ensuring effective, environmentally-friendly composting outcomes. It would also essentially upgrade USCC/BPI’s “encouragement” of field testing on the product side by placing the onus on composting facilities to rigorously demonstrate that they can effectively compost an appropriate range of compostable materials and products.
Composting facilities and green waste collections sites should be incentivized to accept all certified compostable materials regardless their material composition.
Increased confidence in certified compostable materials
None of the above comments are meant to cast doubt on the validity or reliability of the certification standards themselves; indeed, we would argue that composting facilities and green waste collections sites should be incentivized to accept all certified compostable materials (not, e.g., just yard trimmings and food scraps), regardless their material composition.
This recommendation for increased acceptance of certified products goes hand in hand, therefore, with the preceding recommendations: To the extent that composting sites are held to high standards (in regard to ensuring composting outcomes) and adherence to local permitting standards, these same facilities and the patrons who sponsor them have strong grounds for confidence in the integrity of the composting stream.
Final Word
To sum up, we agree with SPC that labeling is one of many variables for successful capture of compostable materials while attempting to reduce contamination in compost material. "Consumers, municipalities, and composters must all play a role in participating in available programs, providing access to composting, and working to reduce contamination." . It is our position that this “one piece” has been given an outsized role in many of the conversations about certification labeling policy and that greater emphasis needs to be placed on the practices of composters and the standards to which they are held. Doing so, we believe, would lead to a more equitable and efficient sharing of responsibility for the integrity of the composting stream within the industry.
None of the above comments are meant to cast doubt on the validity or reliability of the certification standards themselves; indeed, we would argue that composting facilities and green waste collections sites should be incentivized to accept all certified compostable materials (not, e.g., just yard trimmings and food scraps), regardless their material composition.
This recommendation for increased acceptance of certified products goes hand in hand, therefore, with the preceding recommendations: To the extent that composting sites are held to high standards (in regard to ensuring composting outcomes) and adherence to local permitting standards, these same facilities and the patrons who sponsor them have strong grounds for confidence in the integrity of the composting stream.
Final Word
To sum up, we agree with SPC that labeling is one of many variables for successful capture of compostable materials while attempting to reduce contamination in compost material. "Consumers, municipalities, and composters must all play a role in participating in available programs, providing access to composting, and working to reduce contamination." . It is our position that this “one piece” has been given an outsized role in many of the conversations about certification labeling policy and that greater emphasis needs to be placed on the practices of composters and the standards to which they are held. Doing so, we believe, would lead to a more equitable and efficient sharing of responsibility for the integrity of the composting stream within the industry.
