Obtaining ASTM D6400- D6868 Approval

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Rev 3.0 Obtaining ASTM D6400- D6868 Approval Woods End Laboratories inc. is a BPI Approved Certifier lab 1

Key BPI Requirements All products must meet ASTM D6400, ASTM D6868, ISO17088 or EN13432 Not contain any PP, PS, PE, PVC or other nondegradable resins (at 1% or more*) Woods End Laboratories is an approved lab: http://www.bpiworld.org/certified-compostabilitytesting-laboratories All data will be reviewed by BPI independent experts. This is not influenced by Woods End Labs. It may result in request for more data. 2 * Check with current standards regarding low level content of non-degradable compounds

Streamlined Use of this Document On page 7, determine which Main Category ( 1 or 2) that your product falls into; Consult Woods End for helpful evaluation if needed. If product is CATEGORY 2, go to page 10 and determine which Subcategory your product is; Level of Subcategory Testing is found on Page 11. 3

Overview The FTC is increasingly concerned about claims for compostability and biodegradability and may chose to examine claims on scientific merit. Woods End is an independent lab that can conduct trials to validate biodegradation and compostability. BPI is a NGO offering a certificate of approval in accord with an ASTM method. BPI has approved over 100 products, including raw materials and packaging products 4

Overview The BPI symbol for compostability is recognized throughout North America. The BPI logo adds credibility to product claims. Woods End Labs is America s oldest compost testing laboratory. The Woods End Lab testing process confers independent scientific validation status. Woods End labs may also perform biodegradability trials outside the scope of ASTM 6400. 5

BPI Approval Process Testing is determined by nature of material. 2 major categories of testing approval: Resin suppliers (highest level of testing) Converters (lesser level of required testing in dependance on 5 different conditions) 6

2 Categories of Testing 1. Resin Producers Manufacture raw materials Includes bagasse or molded pulp manufacturers 2. Converters Make end-products sold to consumers and distributors. Need separate testing even if using BPI approved resins from #1. Valid for 3 years 7

Approval Information Information you will be expected to obtain Complete Formulation Information Primary Resins, Any Additive or Fillers (>0.1%) Biodegradation Data per the standard Separate testing on resins or additives >1% by wgt Disintegration Data per the standard - Approved max. thickness of final product is what was tested Plant Growth per the standard Regulated Metals per the standard FTIR Spectrum, Ash Data & DSC (for PLA) Maximum Density for Bagasse Approved max. density is what was tested Samples (min 4) EU: DIN Certco or OK Compost Certificates (if appropriate) 8

Regulated Metals the proposed test material must pass the following metals standards Pollutant RESULT: Milligrams per kilogram, dry weight residue (rep A) / (rep B) Max Allowed Metals in composted residue, Concentration @ 50% (USA EPA 503 base only) INTERNATIONAL Max Allowed Metals Concentration @ 50% (EN 13432) Arsenic (As) Your test result here 20.5 * 5.0 Cadmium (Cd) 19.5 0.5 Copper (Cu) 750 * 50 Lead (Pb) 150 50 Mercury (Hg) 8.5 * 0.5 Nickel (Ni) 210 * 25 Selenium (Se) 50 * 3.5 Zinc (Zn) 1400 * 150 * - noted levels are accepted in USA but normally considered excessive in ecological studies. It is strongly recommended for purposes of international marketing to rely on the EN 13432 standard and not the USA sludge rule. 9

Category 1 Approval Formulation Information (BPI)* Biodegradation Data Disintegration Data Plant Growth Regulated Metals FTIR Spectrum, Ash Data & DSC for PLA Maximum Density for Bagasse Samples (min 4- BPI) Certificates (BPI) Resin & Bagasse Converters See next page 10 * Data to BPI for review.

Converter Sub-Categories: Appropriate Level of Approval Testing (Subcategory 1) Approved resin with no additives and of approved thickness (Subcategory 2) Approved resin, with mineral fillers (Subcategory 3) Approved resin, but at higher than approved thickness (Subcategory 4) Approved resin, containing additives or other resins at levels >1% (Subcategory 5) Paper coated with approved resin (this falls under ASTM D6868. 11

Converter Test Requirements Cat 1 Cat 2 Cat 3 Cat 4 Cat 5 Formulation Information (BPI)* Biodegradation Data Disintegration Data * * Plant Growth Regulated Metals FTIR Spectrum, Ash Data & DSC for PLA Maximum Density for Bagasse Samples (min 4- BPI) Certificates (BPI) * Requires special additional disintegration data related to a) thickness or b) resin additive 12

After Woods End Lab Testing: May apply for a BPI Licensing Agreement BPI may grant right to use BPI trademarks BPI Issues certificate & posts to BPI website Must submit to BPI packaging & sales materials with BPI Logo for approval Must follow Federal Trade Commission Guidelines, Canadian and California Labeling Laws. 13

Federal Trade Commission Guidelines (US) Compostable Label should carry this statement: This product is designed to be composted in a large facility. These do not exist in all communities. Check with your local officials In Canada, For composting in municipal programs, where accepted. 14 Labeling Guidelines NOTE! California Labeling Laws Plastic bags and all foodservice items cannot be labeled as biodegradable. Compostable claims must meet ASTM D6400 and D6868

Costs 1. Woods End Laboratory Testing: Determined at time of testing Affected by required level of testing and additional demands by reviewers Can be broken stepwise into ASTM 6400/5338 Subsections for explorative use. 2. BPI Review and Approval: (contact BPI during test process with approved lab testing process) $1,200- $4,500, according to BPI. 3. Annual Licensing via BPI $2,500 15

Alternate Biodegradability Trials Woods End offers research level biodegradability procedures: Useful to test experimental products prior to seeking official approval. Example: formulations of varying resins mixes, added layers, thicknesses. Useful to determine biodegradability under non-compost conditions. Example: ambient soil degradability; marine environment degradability; non-pla degradability Wood End designed the visual biodegradation process for a popular snack bag 16

Woods End Labs Contact Information Tel: (001) 207-293-2457 Fax: (001) 207-293-2488 Shipping address: 290 Belgrade Road, Mt Vernon, Maine USA 04352 Email: lab@woodsend.org Website: www.woodsend.org Other links: http://www.woodsend.org/compostability.html www.bpiworld.org 17