REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the impact of the use of oxo-degradable plastic, including oxo-degradable plastic carrier bags, on the environment
Date: 2018-01-16
Institutions: Directorate-General for Environment, European Commission
Subjects: biodegradability, environmental impact, environmental protection, environmental standard, marine environment, marine pollution, packaging product, plastics, toxic substance, waste recycling

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 16.1.2018  COM(2018) 35 final  REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL on the impact of the use of oxo-degradable plastic, including oxo-degradable plastic carrier bags, on the environment  
 
 
1. 

INTRODUCTION 

On 29 April 2015 the European Parliament and the Council adopted Directive (EU) 2015/7201 
amending  Directive  94/62/EC2  as  regards  reducing  the  consumption  of  lightweight  plastic 
carrier bags. 

The  main  objective  of  this  Directive  is  to  reduce  the  consumption  of  lightweight  plastic 
carrier  bags,  thereby  reducing  the  littering  of  these  bags  and  their  accumulation  in  the 
environment,  where  they  aggravate  the  widespread  problem  of  plastic  waste  in  the 
environment and in particular marine pollution. 

Article  20a  (2)  of  the  Packaging  Directive  tasks  the  Commission  to  present  a  report  to  the 
European Parliament and to the Council examining  the impact of the use of oxo-degradable 
plastic carrier bags on the environment and, if appropriate, present a legislative proposal. 

The purpose of the current report is to inform the European Parliament and the Council of the 
Commission’s follow-up to the mandate. 

The Commission examined the impact of so-called oxo-degradable plastic on the environment 
beyond  plastic  carrier  bags  and  underpinned  its  assessment  by  a  study  published  in  April 
20173, addressing the following three key issues: 

 

the biodegradability of oxo-degradable plastic in various environments, 

  environmental impacts in relation to littering, and 

 

issues related to recycling. 

Within  these  areas,  a  number  of  distinct  hypotheses  were  defined,  relating  to  claims  and 
assumptions  from  the  oxo-degradable  industry  about  the  material.  On  the  basis  of  evidence 
gathered with respect to the hypotheses, these were analysed to ascertain whether they can be 
supported or refuted. 

The study is based on an appraisal of literature, including scientific reports, and information 
from stakeholders and technical experts. 

2. 

BIODEGRADATION, COMPOSTING AND OXO-DEGRADATION 

For  a  good  understanding  of  the  issues  discussed  it  is  necessary  to  define  and  explain  the 
processes of biodegradation, composting and oxo-degradation.  

'Biodegradation'  is  a  process  by  which  material  disintegrates  and  is  decomposed  by  micro-
organisms  into  elements  that  are  found  in  nature,  such  as  CO2,  water  and  biomass. 
Biodegradation  can  occur  in  an  oxygen  rich  environment  (aerobic  biodegradation)  or  in  an 
oxygen poor environment (anaerobic biodegradation). 

'Composting' 
is  enhanced  biodegradation  under  managed  conditions,  predominantly 
characterised  by  forced  aeration  and  natural  heat  production  resulting  from  the  biological 

1 
2 

3 

Directive (EU) 2015/720. OJ L 115 of 6.05.2015, p. 11 
Directive 94/62/EC of  20 December 1994 on packaging and packaging waste. OJ L 365 of 31.12.1994, 
p. 10 
Final  report  of  the  study  on  the  impact  of  the  use  of  “oxo-degradable”  plastic  on  the  environment 
available  on 
  https://publications.europa.eu/en/publication-detail/-
/publication/bb3ec82e-9a9f-11e6-9bca-01aa75ed71a1/language-en/format-PDF/source-56357670 

the  Commission’s  webpage: 

1 

 
 
                                                 
activity  taking  place  inside  the  material.  The  resulting  output  material,  compost,  contains 
valuable nutrients and may act as a soil improver.  
In  theory,  almost  all  materials4  ultimately  may  biodegrade,  even  in  the  open  environment 
though  some  will  do  so  only  after  sometimes  hundreds  of  years  or  more.  Looking  at 
biodegradation of plastics as a means to avoid pollution hence only makes practical sense if 
this  is  linked  to  a  “reasonable”  time  frame5.  It  should  also  be  assessed  taking  into  account 
specific  conditions  and/or  environments,  such  as 
the  marine  environment,  where 
biodegradation is particularly challenging. 

Biopolymers  biodegrade  quickly,  both  under  controlled  conditions  and  in  the  open 
environment. 

Biodegradation of materials resulting from artificial synthesis, such as conventional plastics, 
is  theoretically  possible  when  the  material  is  broken  down  into  small  particles  and  the 
molecule mass of the material is sufficiently reduced to enable biodegradation.  Factors such 
as  light,  humidity,  oxygen  and  temperature  determine  the  degradation  rate.  In  the  open 
environment  it  may  take  a  long  time,  up  to  hundreds  of  years,  for  conventional  plastics  to 
biodegrade. Plastics marked as "biodegradable" only biodegrade under specific environmental 
conditions. Biodegradation does not depend on the resource basis of a material: biodegradable 
plastic (as conventional plastic) can be fossil-based or bio-based.6 

So  called  oxo-plastics  or  oxo-degradable  plastics  are  conventional  plastics  which  include 
additives to accelerate the fragmentation of the material into very small pieces, triggered by 
UV  radiation  or  heat  exposure.  Due  to  these  additives,  the  plastic  fragments  over  time  into 
plastic particles, and finally microplastics, with similar properties to microplastics originating 
from the fragmentation of conventional plastics.  

This  accelerated  fragmentation  would  also  accelerate  biodegradation.  Some  stakeholders 
present “oxo-biodegradation” as the solution to environmental impacts of plastic in the open 
environment.  They  claim  that  even  when  littered,  oxo-degradable  plastic  fragments  and 
biodegrades in the open environment without leaving any toxic residues or plastic fragments 
behind. 

The  question  is  however  whether  in  uncontrolled  conditions  in  the  open  environment,  in 
landfills or in the marine environment, the plastic fragments will undergo full biodegradation 
within a reasonable time-frame. If this is not the case, oxo-degradable plastic will contribute 
to  the  microplastics  release  in  the  (marine)  environment  while  misleading  consumers.  As 
recent  research  shows,  microplastics  released  in  the  marine  environment  get  into  the  food 
chain and end up being consumed by humans.  

There  is  also  a  question  of  whether  the  claimed  biodegradation  of  oxo-degradable  plastics 
may impact on consumers’ littering behaviour. 

Furthermore,  questions  relating  to  the  recycling  process  arise,  as  the  inherent  and  even 
programmed fragmentation through oxidising agents in the plastic waste streams may have a 
negative impact on plastic recycling. 

4 

5 

6 

These  include materials  resulting  from  artificial  synthesis  processes  (e.g.  plastics)  and  those  resulting 
from natural synthesis processes (“biopolymers”, such as cellulose and proteins), excluding rocks and 
metals. 
Defining a ‘reasonable’ time frame might differ from product to product depending also on the use of 
the  product  and  its  impact  on  the  environment;  the  environmental  impact  is  correlated  with  the  time 
taken for complete breakdown of the polymer. 
Bio-based plastics have the same properties as conventional plastics but are derived from biomass, as 
defined in European Standard EN 16575. 

2 

 
 
                                                 
3. 

ISSUES  RELATING  TO  BIODEGRADABILITY  OF  OXO-DEGRADABLE  PLASTIC, 
INCLUDING PLASTIC CARRIER BAGS 

3.1 

Fragmentation and biodegradation in the open environment 

A considerable number of studies have demonstrated that oxo-degradable plastic in the 
open  environment,  when  exposed  to  heat  and/or  UV  light  for  an  extended  period, 
indeed oxidises to the point where the plastic becomes brittle and fragments7. 

This first stage of degradation prepares the oxo-degradable plastic for biodegradation 
by reducing the molecular weight of the plastic to the point where it may be consumed 
by biological organisms8.  

While  oxidising  additives  will,  in  an  open  environment,  accelerate  fragmentation  of 
traditional  polymers,  the  pace  of  fragmentation  varies  significantly  depending  on 
conditions determined by temperature, light intensity and moisture. It is clear that oxo-
degradable plastic is prohibited from degradation if not first exposed to UV radiation 
and, to a certain extent, heat. As these conditions vary from day to day and according 
to local conditions, it is very difficult, if not impossible, to specify timescales in which 
e.g.  an  oxo-degradable  plastic  carrier  bag  will  fragment  in  the  open  environment. 
There is therefore no conclusive evidence of a degree of fragmentation resulting in a 
sufficiently  low  molecular  weight  of  the  plastic  that  may  enable  a  possible 
biodegradation. 

A major issue for oxo-degradable plastic is the trade-off between the intended service 
life and the period that might be needed for degradation in the open environment. Even 
if  biodegradation  may  be  facilitated  by  careful engineering of  the  chemical  package, 
evidence  is  not  available  to  definitely  conclude  that  this  will  happen  in  real  world 
situations.  If  the  circumstances  for  fragmentation  to  take  place  are  absent  or 
insufficient, biodegradation will not take place9.  

3.2 

Composting 

Composting  requires  material  not  only  to  biodegrade,  but  to  also  become  part  of 
usable  compost  and  provide  the  soil  with  nutrients.  The  evidence  suggests  that  oxo-
degradable  plastic  is  not  suitable  for  any  form  of  composting  or  anaerobic  digestion 
and will not meet the current standards for packaging recoverable through composting 
in  the  EU10.  Remaining  plastic  fragments  and  potentially  generated  microplastics 
might adversely affect the quality of the compost. 

3.3 

Fragmentation and biodegradation in landfills 

The  fragmentation  of  oxo-degradable  plastic  requires  oxygen.  In  most  parts  of  a 
landfill, especially the inner parts, little oxygen is present. Evidence to date suggests 
that  in  the  deeper  layers  of  landfill  (where  the  material  has  no  access  to  a  sufficient 
amount  of  air  and  only  anaerobic  degradation  is  possible)  there  is  little  or  no 

7 
8 

9 
10 

Final report, supra footnote 3, Table 3, p.21 
DEFRA:  Review  of  standards  for  biodegradable  plastic  carrier  bags,  December  2015,  review  of 
evidence from Loughborough University, cited in Final report, supra footnote 3, p.16  
Final report, supra footnote 3, Executive summary, E.1.1, ii 
Final report, supra footnote 3, 4.1.2.1. p.31 

3 

 
 
                                                 
biodegradation  of  oxo-degradable  plastic.  In  the  outer  layers  of  a  landfill,  where  the 
material has access to air, aerobic degradation is possible.  

The  key  distinction  from  an  environmental  protection  point  of  view  is  that  aerobic 
degradation produces CO2 whereas anaerobic degradation produces methane, which is 
a greenhouse gas 25 times more harmful (on a 100 years' time horizon) than CO2. 

Consequently,  if  some  biodegradation  were  to  take  place  in  the  deeper  layers  of  a 
landfill,  oxo-degradable  plastic  would  be  marginally  worse  than  conventional  plastic 
from  a  greenhouse  gas  point  of  view,  because  conventional  plastic  does  not 
biodegrade in these conditions. 

3.4 

Fragmentation and biodegradation in the marine environment 

There  is  currently  insufficient  evidence  to  provide  assurance  that  oxo-degradable 
plastic,  including  plastic  carrier  bags,  will  biodegrade  in  the  marine  environment 
within reasonable time. 

Few tests have been conducted, and currently no recognized standards exist that could 
serve as benchmark and allow a certification. 

Even if assuming that oxo-degradable plastic may fragment in the marine environment 
to  a  level  where  biodegradation  may  be  possible,  any  biodegradation  in  the  marine 
environment is expected to be much slower than in land based open environments, due 
to  the  lower  concentrations  of  oxygen  and  bacteria  present.  Furthermore,  before  a 
plastic  carrier  bag  fragments,  the  damage  caused  to  marine  ecosystem  marine  fauna 
(e.g. turtles, seabirds or whales) can be substantial. 

There is  no conclusive evidence  about  the time needed for oxo-degradable plastic to 
fragment  in  marine  environments,  neither  about  the  degree  of  fragmentation.  
Moreover  as  for  any  other  plastic  ending  up  in  the  marine  environment,  there  is  the 
risk that plastic fragments remain for a very long period in that environment and cause 
significant environmental damage and potential negative health impacts. 

3.5 

Conclusions  on  biodegradation  and  composting  of  oxo-degradable  plastic, 
in  different 
including  plastic  carrier  bags, 
environments 

in  uncontrolled  conditions 

There is general agreement amongst both the scientific community and industry that in 
open environments oxidising additives will accelerate the fragmentation of traditional 
polymers. 

However,  for  none  of  these  environments  a  full  biodegradation  process  has  been 
documented.  Most  experiments  were  carried  out  over  a  too  short  time  span  to 
demonstrate full biodegradation and the results of measurements of molecular weight 
reduction  in  the  initial  stage  of  fragmentation  were  extrapolated  following  certain 
models.  Therefore,  no  conclusive  evidence  is  currently  available  to  confirm  that  the 
fragmentation is sufficiently rapid and leads to a reduced molecular weight that allows 
subsequent biodegradation taking place within a reasonable time-frame.  

The evidence also suggests that oxo-degradable plastic is not suitable for any form of 
composting or anaerobic digestion. 

4 

 
 
4. 

ISSUES RELATED TO LITTERING 

4.1 

Potential toxic effects of the oxidising additives 

Potential toxic effects on soils of residual additives from oxo-degradable plastics have 
been identified as a concern.11 

Conclusions valid for all oxidising additives used can however not be drawn, because 
different oxidising additives are used in different concentrations.  

From  the  available  evidence  it  appears  that  the  oxo-degradable  plastics  industry  can 
create products with minimal toxic impact on flora and fauna; however, it has not been 
conclusively proven that there are no negative effects. 

A few test standards for oxo-degradable plastic specify some form of toxicity test, but 
these standards are not obligatory for products on the EU market; moreover, some of 
the 
the  standards  describe  checklists  without  defining  pass/fail  criteria  for 
toxicological test results. 

In  the  absence  of  adequate  standards  in  the  EU,  there  is  no  guarantee  that  all  oxo-
degradable  plastic  on  the  market  avoid  negative  toxic  effects  and  uncertainty  about 
real world toxicological impacts remains. 

4.2 

Potential increase in littering 

Even  though  no  conclusive  information  is  currently  available  on  the  disposal  or 
littering  of  plastic  according  to  the  type  of  plastic,  or  on  the  influence  of  marketing 
oxo-degradable  plastic  on  the  disposal  behaviour  of  consumers,  presenting  oxo-
degradable plastic as the solution for plastic waste in the environment may influence 
littering behaviour by making it more likely that it is discarded inappropriately12. For 
specific  oxo-degradable  products  such  as  agriculture  mulches  the  littering  issue  is  a 
given as those products are sold to farmers with the aim not to be collected after use 
(cf. take-back schemes for conventional plastics) but to be left on the land. 

4.3  Marine litter 

The  marine  environment  is  where  potentially  most  damage  by  plastic  waste  could 
arise,  including  fragmented  plastic  and  microplastics;  at  the  same  time,  subsequent 
collection or recovery of the plastic is least probable. 

As  oxo-degradable  plastic  is  designed  to  fragment  faster  than  conventional  one  it  is 
less likely to be recovered during litter clean-up exercises, and likely to be more easily 
transported  by  wind  and  water.  As  these  factors  may  contribute  to  oxo-degradable 
plastic being transported into the marine environment easier than conventional plastic 
it  can  be  said  that  oxo-degradable  plastic  contributes  to  microplastics  pollution  and 
therefore poses environmental risks. 

11 

12 

Even though not widespread, the use of cobalt has been observed by some studies and the possibility 
remains that producers can incorporate cobalt, or manganese, or other substances of concern, into their 
additives with no regulation on eco-toxicity to prevent this. 
Final report, supra footnote 3, p. 59-60 
See also, for the issue of littering behaviour and biodegradability, UNEP:  Biodegradable plastics and 
marine litter: misconceptions, concerns, and impacts on marine environments (2015), p. 29 

5 

 
 
                                                 
There  is  no  conclusive  evidence  of  full  biodegradation  in  a  reasonable  time  of  oxo-
degradable plastic in the marine environment.  

There is also insufficient evidence to conclude whether oxo-degradable plastic would 
increase  or  decrease  absolute  quantities  of  plastic  in  marine  environments.  In  the 
hypothesis  that  full  biodegradation  occurs  on  land,  the  quantity  that  may  otherwise 
transfer to the marine environment would be reduced. However, full biodegradation on 
land  is  not  proven  to  occur.  Consequently,  there  is  a  risk  that  the  fragmentation 
behaviour  of  oxo-degradable  plastic  exacerbates  issues  related  to  the  presence  of 
microplastics in the marine environment. 

Furthermore,  while  rapid  fragmentation  may  lead  to  less  entanglement  of  animals  in 
plastic,  it  at  the  same  time  increases  physical  ingestion  of  microplastics  by  marine 
animals. 

As oxo-degradable plastic is likely to fragment quicker than conventional plastic, the 
negative  impacts  associated  with  the  presence  of  microplastics  in  the  marine 
environment are concentrated within a shorter period of time. This could ultimately be 
worse  than spreading out  the impacts  over  a longer period, due  to an increase in the 
proportion  of  individuals,  species  and  habitats  affected,  as  well  as  the  burden  of 
impacts for an individual. 

5. 

ISSUES RELATED TO THE RECYCLING PROCESS 

5.1 

Identifying oxo-degradable plastic 

The inherent and programmed fragmentation as intended with the oxidising additives 
is  not  desirable  for  many  products  made  of  recycled  plastic.  Oxo-degradable  plastic 
should  therefore  be  identifiable  and  separated  from  other  plastics  collected  for 
recycling. 

Currently  available  technology  can  however  not  ensure  identification  and  separate 
sorting  of  oxo-degradable  plastic  by  re-processors.  Consequently,  recycling  of  oxo-
degradable plastic will take place mixed with conventional plastic. 

5.2  Quality issues and marketability of recyclates 

Significant  concerns  exist  within  the  recycling  industry  that  oxo-degradable  plastic 
negatively  affects  the  quality  of  recycled  plastics.  Tests  have  demonstrated  that  the 
presence of oxo-degradable plastic in a conventional plastic recycling system can lead 
to poor quality recyclate. Even though it also appears possible to produce high quality 
recyclate,  there  is  no  certainty  about  the  absence  of  negative  impact  of  the  oxo-
degradable plastic on the recyclate.13 

Evidence  suggests  that  the  impacts  of  oxidising  additives  on  recyclates  can  under 
certain  circumstances  be  avoided  with  the  inclusion  of  stabilisers.  The  appropriate 
quantity and chemistry of stabiliser would depend on the concentration and nature of 
the  oxidising  additives  in  the  feedstock.  However,  as  the  concentration  of  oxo-
degradable  plastic  in  recyclate  in  real  world  situations  is  unknown,  it  is  difficult  to 
know the correct dosing of stabilisers. 

13 

Final report, supra footnote 3, p. 97-101 

6 

 
 
 
                                                 
A  major  issue  is  furthermore  that  it  is  impossible  to  fully  control  the  level  of  aging 
experienced by oxo-degradable plastics during the product use phase, prior to products 
becoming waste and entering recycling processes. 

The existence of oxo-degradable plastic and the global nature of markets for secondary 
materials  present  risks  to  a  more  generalised  use  of  recovered  plastic  in  long-life 
products. The uncertainty of whether the recyclate may contain oxo-degradable plastic 
and  of  the  degree  of  oxidation  and  degradation  that  might  have  occurred  prior  to 
recovery limits the end-use for the recyclate, having a negative impact on the price of 
the recyclate and on the competitive position of the plastic recycling industry. 

6. 

CONCLUSIONS 

Taking into consideration the key findings of the supporting study as well as other available 
reports14,  there  is  no  conclusive  evidence  on  a  number  of  important  issues  relating  to 
beneficial effects of oxo-degradable plastic on the environment. 

It  is  undisputed  that  oxo-degradable  plastic,  including  plastic  carrier  bags,  may  degrade 
quicker in the open environment than conventional plastic. However, there is no evidence that 
oxo-degradable  plastic  will  subsequently  fully  biodegrade  in  a  reasonable  time  in  the  open 
environment, on landfills or in the marine environment. Sufficiently quick biodegradation is 
in particular not demonstrated for landfills and the marine environment. 

A  wide  range  of  scientists,  international  and  governmental  institutions,  testing  laboratories, 
trade associations of plastics manufacturers, recyclers and other experts have therefore come 
to the conclusion that oxo-degradable plastics are not a solution for the environment and that 
oxo-degradable plastic is not suited for long-term use, recycling or composting. 

There  is  a  considerable  risk  that  fragmented  plastics  will  not  fully  biodegrade  and  a 
subsequent  risk  of  an  accelerated  and  accumulating  amount  of  microplastics  in  the 
environment,  especially  the  marine  environment.  The  issue  of  microplastics  is  long 
acknowledged as a global problem in need of urgent action, not just in terms of clean-up of 
littering but also of plastic pollution prevention.  

Claims  presenting  oxo-degradable  plastic  as  an  "oxo-biodegradable"  solution  to  littering 
which has no negative impact on the environment, in particular by not leaving any fragments 
of plastic or toxic residues behind, are not substantiated by evidence. 

In  the  absence  of  conclusive  evidence  of  a  beneficial  effect  on  the  environment  and  indeed 
indications  to  the  contrary,  given  the  related  misleading  claims  to  consumers  and  risks  of 
resulting  littering  behaviour,  EU  wide  measures  should  be  considered.  Therefore,  in  the 

14 

Cf. UNEP: Biodegradable plastics and marine litter: misconceptions, concerns, and impacts on marine 
environments  (2015);  OWS:  Benefits  and  challenges  of  oxo-biodegradable  plastics  (2013);  European 
Bioplastics:  ‘Oxo-biodegradable’ plastics  (2009).  European  Bioplastics:  ‘Oxo-biodegradable’ plastics 
and  other  plastics  with  additives  for  degradation  (2015);  Ellen  MacArthur  Foundation:  The  new 
Plastics  Economy:  rethinking  the  future  of  plastics  (2016);  Ellen  MacArthur  Foundation:  The  new 
Plastics Economy: oxo-degradable plastic packaging is not a solution to plastic pollution, and does not 
fit in a circular economy (2017 – statement endorsed by over 150 organisations worldwide, including 
businesses  and  industry  associations,  non-governmental  organisations  and  associations,  public 
institutions,  research  organisations  and  scientists).;  EPA  Network:  Recommendations  towards  the  EU 
Plastics Strategy (2017 -  Discussion paper from the Interest Group Plastics of the European Network 
of the Heads of Environment Protection Agencies from Austria, Denmark, Finland, Iceland, Germany, 
Netherlands, Norway, Portugal, Romania, Scotland, Slovenia, Spain, and Switzerland) 

7 

 
 
                                                 
context of the European plastics strategy, a process to restrict the use of oxo-plastics in the EU 
will be started. 

8