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Viewpoint‘Cellulose supports
sustainable production’Members of the viscose industry, including Birla Cellulose, explain why they believe thatsustainable production and consumption solutions should include cellulosic polymers, in
response to a recent report on plastic waste

Back tonatureSustainably
managedforestplantations

Fully biodegradable andcompostable in soil, waterand marine conditions

Wet wipe
production
and use•••Meet functional requirements ofhygiene, health and flushability
More economical than othernatural wipes
Promotes forest-based economy

Abstract
As the EU leads global efforts to reduce
the level of plastic pollution caused bysingle-use plastics, the Single-Use Plastics
Directive (SUPD)1 is a critical part of theprocess to drive the change to moresustainable production and consumption.
It is a significant challenge to balance theneed to meet the functional requirementsthat many single-use plastics deliver
while transitioning to materials thatare based on natural resources, arecompostable or biodegradable, and are
renewable or reusable. Fortunately,
for some applications like wet wipes,
there are products available that meetboth performance and environmental

Viscose and lyocell
support an efficient
circular economy
Pulp

•
•

Forest-based viscose canreplace fossil fuel-based
plastics in SUP
Forests act as a carbon
sink and help fightclimate change••

Uses renewable energy
Recycle of cotton waste

Fibre
•
•
•

Closed loop process
Recycle chemicals and waste
Low water consumption

requirements and can meet the intent
of the SUPD to prevent the pollutionof marine and terrestrial environments
due to plastics, while contributing to theefficient functioning of internal markets.
Cellulosic polymers, known as viscoseand lyocell, meet all the requirements tobe considered natural polymers as thepolymerisation happens in nature andthey both pass current testing standardsof biodegradability and compostability indifferent conditions. Most importantly,
viscose and lyocell support EU goals ofsustainable production and consumption
by meeting performance standards with
reduced environmental impacts andencouraging a circular economy.

What are viscose and lyocell?
Viscose and lyocell are made of cellulose
derived from fully renewable natural
resources – typically pulp which itself
is derived from woody plants like trees.
Cellulose is difficult to dissolve due to adense hydrogen bonding network between
the cellulose molecular chains, which needs
to be reduced in order to make a solutionof cellulose. The solution is then forced
through a spinneret to produce filamentsthat are solidified, resulting in fibres ofnearly pure cellulose2. While traditionally,
manufacturers paid little attention to thesource of their wood for pulp, many fibre
suppliers have committed to assuring that
their wood is sourced from sustainably

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Viewpoint

managed locations and not old growthforests. The Canopy’s Hot Button report3
assesses viscose and lyocell suppliers
on how they are performing in terms ofsustainable sourcing of their wood supplies,
with the expectation that transparency
will drive higher performance of theindustry. Over 80% of viscose producers, byvolume, have now committed to policies
of sustainable wood sourcing. In recent
exciting developments, pre- and postconsumer cotton waste is being recycled
into viscose and lyocell fibres, and fibre
producers have already placed products
containing recycled cellulosic textile waste
in markets, further strengthening thecircularity of the value chain.
Well-managed forest plantations serve
as carbon sinks, pulling CO2 from theatmosphere at a greater rate than older
forests. Once this wood is harvested, thewood pulp is converted to fibres, therefore
creating long-term storage of the carbon.
Unlike cotton, which requires large
amounts of land, water, fertilisers and crop
protection chemicals to drive higher yields,
forest plantations do not require added
resources, so the impacts of viscose andlyocell raw materials on water, land andsoil health and chemicals consumption issignificantly lower.
Within natural fibre options for wet
wipes there are two major options:man-made cellulosic fibres and cotton.
And when we look at the environmental
impacts of both, viscose is much preferable
due to its low impact on the environment.
A study conducted by SEED4 (Sustainable
Development, Environment, Science andEngineering, KTH) on the LCA of cotton andviscose garments reveals that viscose has
a much lower impact on the environment
compared to cotton. The impact of viscoseon water is much lower than cotton and
it is important to note that a significant
portion of the cotton is grown in waterstressed areas.
A study conducted by Business for Social
Responsibility (BSR)5 compared the Relative
GHG emissions of different fibres andindicates that viscose is one of the fibres
with the lowest greenhouse gas emissions,thus supporting the United Nation’s
Sustainable Development Goals (SDG) 13.
Climate change and water stress are
the two biggest challenges the Earth faces
today. The natural-based fibres viscoseand lyocell can significantly contribute to

reducing the impact of water stress andclimate change.
Viscose and lyocell are produced
using chemicals to dissolve the cellulosecontained in wood and then rebuilt in fibre
form by regenerating the cellulose. Global
leaders have invested in processes toachieve a recycle rate for solvents used up
to 99.7% in the lyocell process and greaterthan 90% in the viscose process (basedon sulfur recovery). Those same leaders
have also made major strides in improving
water and energy efficiencies. Newer
technologies have enabled significant
reduction in wastewater pollutants,
therefore improving the quality of waterthat is discharged from the manufacturingsite. The UN’s SDG 12 aims to promotesustainable consumption, recycling andreuse of resources, environmentally soundmanagement of all types of waste, and useof more sustainable material choices. The

EU’s SUPD is an important contribution to
the achievement of SDG 12 because it aims
primarily to prevent and reduce the impactof plastic products on the environment,
particularly the aquatic environment. It
also aims to promote the transition toa circular economy with innovative andsustainable business models, products
and materials, while contributing to theefficient functioning of internal markets.
Viscose and lyocell help support theachievement of the EU’s SUPD objectives
to minimise plastic waste while still
providing products that meet the needsof the population. Wet wipe applications
include baby wipes, face wipes, personal
hygiene, cleaning, industrial wipes andmedical applications. Currently, wet wipes
are made mainly with polyester, which isblended with a small proportion of cotton,
viscose or lyocell. In its current form, aused wet wipe persists in the environment

Fibre

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Viewpoint

for hundreds of years, because mostof its constituent is non-biodegradable
polyester. Since viscose and lyocell fibres
are biodegradable and compostable,
these provide a good option to eliminate
the pollution of marine and terrestrial
environments by plastics from used wet
wipes, while meeting the performance of
the wet wipes applications6.

Meeting tough standards
The SUP Impact Assessment study7 by the EUcommission emphasised that plastic litter is amajor concern because non-biodegradability
and persistence is creating both land andmarine-based issues globally. The study
suggested that an important option is totransition single-use plastics to be basedon materials that are biodegradable suchas paper and wood. Microbial degradation
is an important mechanism of the naturaldegradation of cellulose. It is achieved
through hydrolytic enzymes known as‘cellulases’ that convert long chain cellulose
into gradually reducing lengths throughscission of the β-1, 4 linkages in cellulose
chains8. Such biodegradation of cellulose
proceeds under aerobic (forming CO2 andH2O) as well as anaerobic (forming CO2, CH4
and H2O) conditions.
This is followed by a typical comparisonof the biodegradation of cellulosic fibres(including man-made rayon) in weeks, ascompared to other alternatives currently
employed in single-use applications, as
depicted in the below graph.
This study shows that viscose degrades
faster than any other major fibres evaluated.
Deep ocean environments, however,are different due to limited availabilityof oxygen. Here, the prevalent
biodegradation by fungi is anaerobic
in nature11, as the marine environment
also hosts a remarkably high and diverse
microbial population. Several studies havedescribed biodegradation of cellulose
under these conditions12, and processed
cellulosic fibres are reported to degrade
faster than unprocessed wood13. Further,marine degradation of cellulose is several
times faster than plastics14.
Various manufacturers of man-madecellulosic fibres have reported testing by
OWS (Organic Water Systems, Belgium)for the certification body TÜV Austria,
to further demonstrate that viscose
staple fibre passed testing requirements
for composting and biodegradability

Schematic of the biodegration of polymers in aerobic and anaerobic conditions9in soil, water and marine conditions15.
Compostability and biodegradability
studies in soil were done in compliancewith the European Standard EN
13432. Biodegradability in the marine
environment studies were done incompliance with ASTM D6691 standards.
Highlights of some of the test results
include:• Aqueous aerobic conditions: Viscosefulfilled the 90% biodegradability
requirement within 28 days.
• Marine biodegradation test: Viscose
fibre was completely biodegradable
within 28 days of testing under marine
aerobic conditions.
• OK12 edition A ‘Bioproducts –degradation in seawater’ Marine
disintegration test: Viscose fibre fulfilled
the requirement and can be considered
for OK biodegradable Marine conformity
mark of TÜV Austria Belgium. The
disintegration test is described in the
document ref. TS-OK-23 (30°C ± 2°C, 3
months - Pass: >90%).
• Toxicity test with barley and cress
plants: After composting the test

sample, no residuals were left such as
metabolites, undegraded components
and inorganic components that exert anegative influence on the germinationand growth of barley or cress plants.
In summary, there are several methods
to measure biodegradability of substancesin different conditions and there are also
new methods being developed. However,
the relative degree of ease and speed withwhich viscose and lyocell biodegrades andcomposts compared to other substancessuch as cotton and polyester, is not likely
to change by changing the test method.
There is enough scientific evidence alreadyavailable that establishes that viscose andlyocell biodegrade significantly faster thanother fibres under various conditions (soil,
aquatic, marine, at different temperaturesand humidity, aerobic and anaerobic), andthe only factor that can be improved by new
methods would be perhaps establishingthese facts with even more comprehensive
measurements. Thus, viscose and lyocell are
well positioned to meet the intent of the
SUPD to reduce the impact of SUP waste on
the terrestrial and marine environments.

The above graph shows biodegradation of nonwoven fabrics in a Captina silt loam soil: (a) weight ofrecovered fabric versus burial period and (b) regression analysis by the first-order rate equation10

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Viscose and lyocell arenatural polymers
Natural polymeric materials such as hemp,
shellac, amber, cotton, wool, silk, paper, andstarch have been used for centuries. While it
is of great importance to discuss the definitionof what can be called a natural polymer
or substance, there is a risk that alternate
interpretations of the same definitions canlead to exclusion of substances that could
be the best solutions to problems createdby SUP, if these materials are defined asplastics. Materials such as paper, mercerised
cotton, pulp, viscose and lyocell, which are
understood as natural polymers in everyday
life, risk being called plastics because they all
are extracted using a chemical process andall have intermediate temporary products
formed, even though their final structure is
still cellulose, similar to the original structure.
Different countries define plastics
differently. Within EU regulations and ECHA
guidance notes, there are definitions forwhat can be considered as natural polymers.
Notable within these are:Natural polymers16 are a result of apolymerisation process that has taken placein nature, independently of the extraction
process with which they have been extracted.
A plastic means a material consisting ofa polymer as defined in article 3(40) of the
REACH regulation (EC) No 1907/2006, towhich additives or other substances may havebeen added, and which can function as a main

structural component of a final product withthe exception of natural polymers which havenot been chemically modified.
A ‘not chemically modified substance’is defined as a substance whose chemical
structure remains unchanged, even if it has
undergone a chemical process or treatment,
or a physical mineralogical transformation, forinstance to remove impurities17. (Unlike thedraft guidelines that limited this definition to‘no chemical reaction during the process’,18
the final version of the guideline19 did awaywith this restrictive definition and emphasised‘as long as the chemical structure of themolecule is not modified’).
A recent report on ‘What is Plastic?’ from
Eunomia20 misleadingly suggested to use adecision tree for determining if a substanceis a natural polymer, where they changed
the original definition given by the European
Chemicals Agency (ECHA) of what is ‘not a
chemically modified substance’ by redefining
it as ‘a substance whose chemical structure
remains unchanged during the entire
process of chemical treatment’.
It is worth applying this new definition tosome cases to illustrate how it can fail thevery purpose of the SUPD by eliminating
the substances that would help solve theproblems resulting from pollution of theenvironment by waste from single-use plastics.
The table below evaluates some commonlyused substances using the new definition andoriginal ECHA definition.

Criteria for natural fibres

Have the polymers been produced by biological organism?

Thus, from the table we can see that
products such as paper, pulp, mercerised
cotton, starch, viscose and lyocell risk being
called plastics, going against the longestablished conventional wisdom. There areseveral other examples that would fit theillustrations of how playing with a few words
of a well thought out definition by ECHA canlead to serious lapses in judgement.
For example, mercerisation is a key stage
in cotton textile finishing. Mercerised cotton,
lyocell and viscose have the same cellulose
structure. All three are based on natural
plant-based raw materials and have thesame modified structure of intermoleculararrangement changed from cellulose I to
cellulose II21, but without a change in the
structure of the molecules themselves.
Further, the pulp-making process for making
paper also involves the same change tocellulose II22, albeit to a small extent. Cellulose
II is also produced naturally, such as bysome organisms23. All three fibres as well as
paper go through intermediate ‘Na-alkoxideof cellulose’ or reduced intermolecularhydrogen-bonding during the purification/
extraction processes, but revert from theseweak/labile intermediates to the same final
chemical structure of the cellulose molecule.
All three are compostable and biodegradable.
During the purification/extraction processes,
there is also a macromolecular chain-scission
resulting in a chain-length reduction in these
fibres to a varying extent, and some have also

Result of application of the criteria on substances
Viscose, lyocell

Paper and pulp Textile cotton(mercerised)

Synthetics
polymers such aspolyester, nylon

Yes

Yes

No

Yes

Did the initial polymerisation occur in nature?

Yes

Yes

Yes

No

The extraction process should not cause polymerisation

Yes

Yes

Yes

No

Is the final structure same as the initial structure?

Yes

Yes

Yes

No

Is the material understood as a natural substance in everyday
life?

Yes

Yes

Yes

No

Is the material understood as not being a plastic substance ineveryday life?

Yes

Yes

Yes

No

Classification of the material based on definitions within ECHA
and EU regulations

Not achemicallymodified
substance

Not achemicallymodified
substance

Not achemicallymodified
substance

Not a naturalpolymer

New definition by Eunomia
The chemical structure is not modified during the process

No

No

No

No

Classification of material based on Eunomia definitions

Chemicallymodified
substance

Chemicallymodified
substance

Chemicallymodified
substance

Not a naturalpolymer

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Viewpointinterpreted this chain-scission as ‘chemical
modification’. It is important to recognisethat such chain-scission is not only inherently
harmless, but is also the very enabler andresult of biodegradation of cellulose in wood,
paper and cotton by the ‘cellulase’ enzymes
produced by microorganisms in nature, andis also part of the omnipresent processes ofpulp-paper making and cotton mercerisingand bleaching processes. There is no scientificbasis for treating lyocell, viscose, mercerised
cotton and paper differently, and for calling
any of these ‘chemically modified’ and others‘not chemically modified’, as they all follow
chemical processes for extraction.
Starch used in various foods is often
chemically modified24. Similarly, starch-based
disposable cutlery is made using a formof starch that has been modified througha chemical process. The move to starchbased cutlery is considered a successful
example of a transition from a fossil fuelbased, non-biodegradable plastic productto a biodegradable product. This innovation
serves the purpose of disposable single-use
cutlery which is fully biodegradable and meetsthe functional need and eliminates plastics
pollution. Vegetable oils are often chemicallyaltered following their extraction from plants,
consumed as foods, and not considered asplastics25.

Flushable and non-flushable
wipes
There are two types of wipes – flushable
and normal wipes. Both can be made using
viscose or lyocell. It is important to note that
not all wipes made from viscose or lyocell areflushable. Flushable wipes are made using a
totally different technology which provides
certain unique features to the wipe that makethem suitable for flushing, such as quick
wet disintegration, biodegradability, settlingtendency, sinking velocities and others.
These wipes are clearly marked as‘Flushable’ or ‘Fully Flushable’. All other wipes
are not flushable and should be clearly marked
as ‘Do Not Flush’.
A study conducted by Water UK 21, called
Wipes in the Sewage Blockages, reveals thetrue reasons:
1. The majority of the sewer blockage
material recovered comprised nonflushable wipes that were not designed
to be flushed and should not havebeen disposed of via the WC. Baby
wipes accounted for over 75% byweight of identifiable products. Surface

wipes, cosmetic removal wipes andfeminine hygiene products accounted
for approximately 20% by weight ofidentifiable products.
2. The products recovered that were
designed to be flushed accounted for asmall proportion of the products recovered– approximately 0.88% by total weightand 1.9% by weight of products that could
be identified. However, it is accepted thatduring the blockage recovery process sometoilet tissue and other weaker material islost in the blockage removal process.
So, it is clear from the above that 99%of the problem is caused by the flushing of
non-flushable wipes and products such as
feminine hygiene and cosmetic removal wipes.
Consumer awareness programmes could help
to solve some of the major causes of sewage
clogging, and millions of euros being spent on
cleaning clogged sewage systems could be put
to more productive use.
There are flushable wipes available in themarket that have been in use for more than adecade and meet flushability standards such
as GD4. There could be stricter standards
available for flushability compared to GD4 that
could help improve flushable wipes. This could
further reduce instances of clogging causedby flushable wipes, even though this is lessthan 1% of the total causes of clogging. It isalso important to focus on the major causesof sewage clogging that could have a greater
impact on this problem.

Nature-based wipes madefrom viscose and lyocell
support internal markets
An important objective of the SUPD is thatplastics are replaced with more sustainable
substances and products that promote a
circular economy and contribute to theefficient functioning of internal markets.
SDG 12 calls for the use of more sustainable
material choices by disincentivising fossil fuelbased products.
Viscose and lyocell are two productsthat could help fulfil all the above statedobjectives. They are based on wood derived
from sustainable forests and will replacefossil fuel-based products with nature-based
products. They are produced using the closed
loop production system which recycles
important chemicals used in the process,consuming significantly less water, land andchemicals compared to other natural fibres.
Moreover, recent innovations allow cotton
waste to be recycled into viscose production

and potentially save millions of tons of cotton
waste from going to landfill/incineration
annually. Viscose and lyocell, with 20% to 50%
recycled content, are already commerciallyavailable26 in the market and are being
promoted by brands among consumers.
It is anticipated that if wet wipes production
is to move to viscose and lyocell, it could
potentially increase the demand of dissolving
pulp by 1%, estimated by Eunomia, which isinsignificant and could easily be absorbed by
the value chain without any impact on pricing.
The potential Extended Producers
Responsibility (EPR) cost of a polyester wipe
estimated by Eunomia27 is €1.60 cents per
wipe. This means that for every wipe of€1.10# cents, €1.60 cents are required to
manage the environmental impact of waste
created by synthetic wipes. The EPR cost oflyocell and viscose wipes are estimated to be
nil in this report, if they are treated as natural
substances. The report also estimates thetotal global market of wet wipes is €10bn. Thismeans that EPR costs could run into billionsof euros in the case of non-biodegradable
wipes, and much of it would have to be borneby member nations and its citizens. A clear
definition of a natural polymer, which includes
viscose and lyocell as natural substances, could
help reduce this wasteful expenditure on EPR
in managing non-biodegradable plastic waste
which would add to the already worsening
climate conditions without any productive
output and hurt the economy.
In summary, the impact of a shift ofmaterials used in manufacturing wet wipesfrom polyester to viscose or lyocell would
support the efficient functioning of internalmarkets, and would not lead to any distortionin viscose prices and place any significant
stress on the demand and supply of pulp.
This would also reduce the EPR cost as
viscose and lyocell are easily compostableand biodegradable and waste management
expenses are much lower – contributing toefficient internal markets.

Conclusion
Natural polymers viscose and lyocell
are consistent with the EU’s sustainableproduction and consumption strategy
and meet the intent of the high standards
developed in the SUPD and support the
UN’s SDG 12 as they:• Are produced from sustainably sourced
wood from renewable forests andreplace fossil fuel-based products.
• Use closed loop manufacturing to recycle

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chemicals and other natural resources• Biodegrade and compost significantly
faster compared to other fibres undervarious conditions (soil, aqueous,marine) and meet international
standards of biodegradability• Have lower environmental impact
compared to other naturally grown
fibres like cotton as they consume lesswater, land and energy, and do notneed fertilisers and pesticides• Can be used to make flushable wipesthat meet international flushability
standards• Reduce the burden on landfills andincinerators, supporting the circular
economy, due to recent advances
allowing cotton waste to be recycled
into viscose• Are expected to contribute to theefficient functioning of internal markets
and to not cause any distortion of prices
in the markets.
In addition to meeting the intent of SUPD
and SDG 12, viscose and lyocell fit theWhat is the Eunomia report?
Published on 21 January 2020, the Eunomia report ‘What is Plastic?’ explores thepotential for certain materials to be considered as exempt from the EU’s Single-Use
Plastics Directive, with particular focus on man-made cellulosic fibres.
The report examines the scope for two of these polymers, lyocell and viscose, to be
included under the Directive, investigating both their chemical makeup and their
behaviour in the natural environment. The research evaluates the body of evidence
for the environmental impact of these polymers when used in wet wipes, with aparticular focus on the marine environment and the material’s biodegradability.
“Researchers found that there is not sufficient evidence to prove that these materials
will not have a similarly detrimental impact on the environment as a synthetic plastic
product,” states Eunomia.
The report goes on to identify the current market for these materials, and the impact ofan extended producer responsibility (EPR) system on these markets as part of the SUP
Directive regulations.
More information can be found at www.eunomia.co.uk

definitions of natural polymer substances,as outlined by ECHA, as the initial and final
structure is both cellulose and structuresare similar, and the polymerisation happensin nature.

Thus, viscose and lyocell are the mostsuitable substances for SUP applications
such as wet wipes and would help inachieving the objectives of the SUPD and
SDG 12.

References

1. https://data.consilium.europa.eu/doc/document/PE-11-2019-INIT/en/pdf
2. Regenerated Cellulose Fibers, Ed. C. Woodings; Woodhead Pub., 2001
3. Canopy Hot Button Report 2019 https://hotbutton.canopyplanet.org/summary-analysis/
4. https://kth.instructure.com/files/93812/download?download_frd=1
5. https://www.scribd.com/document/66843720/BSR-Apparel-Supply-Chain-Carbon-Report
6. https://www.edana.org/how-we-take-action/product-stewardship/flushability
7. https://ec.europa.eu/environment/circular-economy/pdf/single-use_plastics_impact_assessment.pdf
8. The biological degradation of cellulose, FEMS Microbiology Reviews 13 (1994) 25-58
9. Review on the current status of polymer degradation: a microbial approach, Bioresources and Bioprocessing volume 4, Article number: 15, 2017, https://link.
springer.com/content/pdf/10.1186/s40643-017-0145-9.pdf
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fabrics in aerobic Captina silt loam soil, Textile Research Journal 86(2) May 2015.
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cabdirect.org/cabdirect/abstract/19611100628;
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track/pdf/10.1007/BF02414760
14. Sustainable plastics: Environmental Assessment of biobased, biodegradable and recycled plastics, Ed. J. P Greene, 2014, John Wiley, Appendix E, Marine
Biodegradation Testing.
15. https://www.birlacellulose.com/certificates.php ; https://www.just-style.com/news/lenzing-fibres-certified-for-full-biodegradability_id136969.aspx .
16. https://echa.europa.eu/documents/10162/23036412/polymers_en.pdf/9a74545f-05be-4e10-8555-4d7cf051bbed
17. https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2007:136:0003:0280:en:PDF
18. https://ec.europa.eu/environment/chemicals/reach/pdf/8_draft_guidance_5.pdf
19. https://echa.europa.eu/documents/10162/23036412/annex_v_en.pdf/8db56598-f7b7-41ba-91df-c55f9f626545
20. https://www.eunomia.co.uk/wp-content/uploads/2020/01/What-is-Plastic-Main-Report_Final.pdf
21. Mercerization of primary wall cellulose and its implication for the conversion of cellulose I→cellulose II (https://link.springer.com/
article/10.1023/A:1015877021688)
22. Changes in Cellulose Crystallinity During Kraft Pulping. Comparison of Infrared, X-ray Diffraction and Solid State NMR Results, International Journal of the
Biology, Chemistry, Physics and Technology of Wood, 49 (6), 1995, 498–504
23. Candace H. Haigler, Biosynthesis and Biodegradation of Cellulose, CRC Press, 20-Dec-1990, Ch 1, p 9
24. Chemically Modified Starch and Utilization in Food Stuffs, http://article.sciencepublishinggroup.com/html/10.11648.j.ijnfs.20160504.15.html
25. Chemical modification of oils and fats (http://ocw.nagoya-u.jp/files/1/chap3.pdf)
26. https://www.adityabirla.com/media/press-reports/birla-cellulose-manufactures-viscose-fibre-using-pre-consumer-cotton-waste
27. https://www.eunomia.co.uk/wp-content/uploads/2020/01/What-is-Plastic-Main-Report_Final.pdf
https://www.tencel.com/refibra
https://www.just-style.com/news/new-viscose-fibre-made-from-recycled-cotton-textiles_id136527.aspx

Issue 1 2020 » Nonwovens Report International 53

P 48-53 Birla Cellulose.indd 53

27/02/2020 10:57:15