The proposed EU ban on the sale of polymer infills has been so firmly cast in stone that it hardly leaves room for debate. Yet, the same cannot be said for products made from biodegradable polymers. Precisely for this reason, it would be wise for the European Commission to look further into these developments.
In an attempt to avoid microplastic pollution by synthetic turf surfaces, the EU proposes to ban the placement onto the market from 2031 onwards of polymeric infills such as SBR, TPE or EPDM with a grain size of less than 5mm. The proposal also includes limitations for biodegradable polymer alternatives. These will have to be dissolved in water or in soil after six months or two years respectively. In the humid conditions we have in Europe, this makes biodegradable products made from a polymer hardly a realistic option. The European Commission seems to be aware of this problem, as it is prepared to grant an exemption to biodegradable products used in the agricultural industry, Bruno de Wilde of OWS Normec points out. “An example of this is the biodegradable agricultural films made from polymers.” OWS Normec has been testing the biodegradability of products for close to 30 years and is one of the world’s leading research institutes in this matter. But the European Commission is not so lenient when it comes to biodegradable infill. There are, it believes, sufficient alternatives to polymeric infills. De Wilde regrets that attitude. “Biodegradation is a concept that has many nuances.”
Difficult subject
In De Wilde’s view, there are many misunderstandings about the concept of ‘bio’ plastic. “Plastics have become the big enemy, but that mindset is not always right,” he notes. “The legislature should take a broader view because we are currently too rigid. Biodegradation is not a black and white characteristic but differs from environment to environment.” Biopolymers can be divided into two groups: biobased (products from renewable raw materials) and biodegradable. Products made from biobased raw materials are not necessarily biodegradable. According to De Wilde, Green PET is a good example of this. At the same time, a petrochemical material can still serve as a raw material for a biodegradable product.
De Wilde points out that we have ourselves to blame for the fact that the European Commission is now strict with regard to biodegradable infill based on a polymer. “Too many false promises have been made in the past. For example, people started claiming biodegradation for products that actually only decomposed and left behind non-natural residual products, while real biodegradation is the opposite of photosynthesis: the conversion to CO2.” He also partly attributes the lack of knowledge to the relative novelty of the ‘biodegradable’ phenomenon. “These types of products have only been around for 30 years. So they are relatively young and not yet very well known. That is now slowly starting to change. For example, both the United States and China are now fully committed to biodegradable products. But despite the many developments taking place in Europe, we are still very slow here.”
De Wilde calls the European legislation too restrictive. “The European Commission hands out a lot of subsidies with its left hand, but, at the same time, it pulls the brakes on with its right hand,” he sighs. “Often solutions are found in and, and, and, rather than either, or, or,” he says, referring to the precautionary principle where ‘prevention’ is first pursued (through behavioural change) before considering an ‘intervention’ through technical adjustments or (behavioural) improvements. A ban is the very last resort and is only considered when there are no other options available or everything else has failed. The precautionary principle is widely applied to guarantee the health and safety of anybody in a workplace and to prevent a product or activity from having a negative impact on the environment. “I understand that the European Commission faces a difficult task. Therefore, a possible solution for biodegradable infill made from a polymer could lie in the idea of only letting the clock start ticking after the functional life of the product has come to an end,” de Wilde says. In that case, the bar for the biodegradability of biodegradable infill would be considerably lower.
Changing framework
Willem Post of consultancy firm Greenhouse Advies understands the dilemma regarding biodegradable synthetic turf components and (proposed) legislation that leaves room for discussion. “You have to comply with the legislation, and the duty of care applies to everyone. You simply cannot deteriorate the soil. However, some pollution can be dissolved by diluting it, and other pollution dissolves completely on its own,” he notes. “Covering is also a form of remediation. However, what biodegradation is all about is the question: what influence does your degradation have on soil quality?” Post also points out that certain substances have never previously been considered problematic, but have nevertheless appeared on the radar as such in the past few years. “Think of PFAS. Five years ago, the use of these substances was not viewed as being problematic. However, the EU is now working on a total ban on the use or application of PFAS.” His advice is therefore to work out the recipe for products and subsequently test the soil for the presence (or absence) of the various ingredients in a product.
The legal framework in the Netherlands is currently the Soil Protection Act. This is supported by the Soil Quality Decree and the Soil Quality Regulation. However, the government intends to replace all of this with the new Environmental Act. “It is still not clear when this will be introduced. That could be either January 1 or June 1, 2024.” What is certain is that with the introduction of the Environmental Act, the system of the duty of care for soil will change. In addition to soil, it will soon also consider water and air.
Another stumbling block that Post sees is the various environmental services. “They must monitor compliance with the Soil Protection Act, but their views on matters may differ. Moreover, you can sometimes have to deal with multiple environmental services at one location.”
A wake-up call to many more?
If the European Commission continues to pursue the path it is proposing on deliberately added microplastics, then this could be a bad sign for when it wants to take action against microplastics resulting from, for example, yarn wear. The EU’s European Chemical Agency (ECHA) is already investigating this. Earlier this summer, researchers from the University of Barcelona published a scientific paper in which they claimed that yarn wear from synthetic turf surfaces is responsible for a large part of the pollution they registered in waters in Spain. The ECHA has undoubtedly studied this paper carefully. Yet we cannot do without polymers for our synthetic turf systems, claims René van Bremen of Senbis Polymer Innovations. He is not amused that the European Commission is not prepared to look less rigidly at biodegradable polymer infill. “We place high demands on the performance, predictability, replicability, safety, hygiene and long lifespan of, among other things, synthetic turf fibres. This can only be achieved by using polymers.” According to him, both the synthetic turf industry and the market would do well to mobilize. “The synthetic turf industry realized too late in 2018 what the consequences could be of the intended ban on the sale of polymer infill. We must not let that happen again.” For that reason too, Senbis was one of the eight parties that actively contributed to the LCA study for sports surfaces in the Netherlands. “We fully support our GreenFill biodegradable infill and our GreenBlade biodegradable synthetic turf. TÜV testing institute has already established that GreenFill is 100% biodegradable. We expect to be able to provide such a statement for GreenBlade in due course.” Both products have already been installed at various sports parks in the Netherlands. Like de Wilde, van Bremen states that biodegradable products are now fully accepted in the US. “The US is already clearly interested in our development, so that is encouraging. At the same time, we also need to better inform Europe and encourage governments to invest in these types of solutions. Anyone who now invests in biodegradable infill or synthetic turf does not, in principle, have to invest in management measures.”
Difficult discussion
The future of biodegradable infill or synthetic turf, therefore, remains subject to discussion. “I am confident that, as we gain more experience with biodegradable products and knowledge increases, the legislature will also look at its rules through different eyes,” says van Bremen. “What I only hope is that, as an industry, we learn lessons from the discussion about microplastic pollution from polymer infill. The radical plans of ECHA and the EC were only noticed when it was too late to intervene. Since then, the authorities have continued a path based on incorrect facts. This is partly the reason why the sentiments around synthetic turf are negative. That affects the entire industry.”
That the discussion about plastic and pollution seems to be built on quicksand is evident from a recent article about a study by the University of Utrecht. According to the researchers, the oceans only contain about 3.2 million tons of plastic. That is less than 1.5% of the 250 million tons claimed in recent years. The researchers came to this conclusion by using a more accurate calculation method. “The exact amount is irrelevant: plastic pollution is a problem. But in our search for solutions, we must remain realistic and continue to leave room for new innovations,” says van Bremen. “We cannot achieve this by rigidly adhering to a certain image.”