BPA ANALYSIS OF HSAC REPORT

The Biodegradable Plastics Association (BPA) has today published its response https://www.biodeg.org/wp-content/uploads/2026/03/BPA-RESPONSE-31.3.26.pdf to the UK Government’s 2025 HSAC Report This BPA paper demonstrates conclusively that there is no technical, scientific, or safety‑based reason to prohibit or discourage the use of oxo‑biodegradable polyethylene (PE) and polypropylene (PP), provided they are correctly manufactured, and assessed using the appropriate international standards.

First, the paper establishes that oxo‑biodegradable plastic is not an experimental or unproven technology. It has been in continuous scientific development for over fifty years, and has been in commercial use for 20 years. It was invented by leading polymer scientists, and is supported by a coherent and well‑understood mechanism: - controlled oxidative chain scission followed by biological assimilation.

This two‑stage process is recognised and understood in the international technical literature and Standards, and there is no credible dispute in polymer science that oxidation reduces molecular weight and that sufficiently oxidised polyolefins are biodegradable. This has been demonstrated in the real world, notably by the Oxomar project.

It is fundamentally different from composting and mere physical fragmentation, and it does not leave microplastics.

Second, the paper shows that the correct technical benchmark already exists. ASTM D6954 (and aligned national standards such as BS 8472) was specifically written to assess plastics intended to degrade and then biodegrade in the open environment. These standards define what must be measured, how it must be measured, and what constitutes pass or fail for degradation, biodegradation, and environmental safety. The existence and long‑standing use of these standards means there is no technical gap requiring new methodologies, speculative testing regimes, or ad‑hoc academic proxies.

Third, the paper demonstrates that independent, ISO 17025‑accredited testing has already proven performance. The Intertek test reports cited show high levels of biodegradation of oxo‑biodegradable PE and PP, compliance with ecotoxicity requirements, and—critically—the absence of persistent microplastics. Molecular‑weight measurements confirm that any residual particles no longer behave as plastics. From a regulatory and technical standpoint, this directly addresses the principal concerns typically raised: persistence, toxicity, and microplastic formation.

Fourth, the paper shows that claims of technical failure are driven by inappropriate test protocols not by deficiencies in the technology. See https://www.biodeg.org/wp-content/uploads/2026/03/BPA-Dossier-with-links-10-2-26-optimised-V13-31-Mar-26.pdf Many academic papers which have passed peer-review, either test the wrong materials, fail to characterise samples, use incorrect standards (e.g. composting standards), terminate tests prematurely, or expose materials to conditions for which they were not designed (such as burial or submersion). The paper demonstrates that such studies cannot be used to draw valid conclusions about the performance of properly made oxo‑biodegradable plastics.

Fifth, the paper addresses geographical variability directly and shows that variation in degradation rate is not technical failure. Like all chemical and biological processes, oxo‑biodegradation proceeds more slowly in cooler or lower‑UV conditions, but there is no evidence that the process fails, stops, or reverses. This behaviour is entirely consistent with established kinetics.

No regulatory principle requires uniform speed of degradation across climates, only predictable and demonstrable performance relative to conventional plastics—which oxo‑biodegradable materials are intended to replace.

Sixth, the paper confirms that oxo‑biodegradable plastic is compatible with recycling, unlike some alternative materials that are nevertheless permitted on the market. There is therefore no technical incompatibility with circular‑economy objectives for collected material, while still providing a clear environmental advantage for plastic that inevitably escapes collection.

Taken together, the evidence shows that oxo‑biodegradable plastic such as Symphony’s d2w®:

• functions as designed;

• is supported by established polymer science and long user;

• is testable and verifiable using recognised standards;

• has been independently proven to biodegrade without creating persistent microplastics or ecotoxicity; and

• performs better than conventional plastic if it gets into the open environment, which is the only context in which its designed function is relevant.

Accordingly, this paper demonstrates that there is no technical justification for prohibition, restriction, or regulatory exclusion of oxo‑biodegradable plastics.