Date: February 27, 2026

Re: Expansion of Accepted Testing Laboratories and Harmonization of Heavy Metals
Standards

Introduction
At the Improving the Circularity of Compostables and Composting (IC3) event in September
2024, inconsistency between compostability standards and certifications was identified as a
problematic area. Composters lack clarity of the meaning of each standard, and packaging
manufacturers are often held to different standards for the same product depending on the
geographic region or certifying entity.

CMA is committed to doing its part to address the challenges brought forward through the
IC3 process. As a result, CMA is taking two important steps: (1) adding additional ASTM
testing laboratories to its accepted lab list; and (2) harmonizing our heavy metals
requirements with the standards used by TÜV Austria.

Expansion of Accepted ASTM Testing Laboratories
To promote greater alignment across certification programs and reduce unnecessary
duplication of testing CMA is expanding its list of accepted ASTM testing laboratories.
Specifically:

• CMA will accept ASTM test reports from laboratories in Europe and Korea currently
  recognized by TÜV Austria. The list of CMA accepted labs, including these additions, the
  added labs can be found here.
• These laboratories must consistently and continuously demonstrate competency and
  certification to ISO 17025 requirements.
• CMA will continue to independently vet and add qualified third-party laboratories to
  ensure scientific rigor and reliability.
  This expansion improves efficiency for manufacturers, alignment across international
  markets, transparency and clarity for composters evaluating certified products, and
  potentially reduced testing costs.

Harmonization of Heavy Metals Requirements
Effective July 1, 2026, CMA is harmonizing its heavy metals requirement thresholds with the
European EN13432 standard used by TÜV Austria. This change does not affect existing CMA certified products but allows all future CMA certified products to meet only one heavy metal requirement. Any existing lower local heavy metal requirements must still be met.

BS EN 13432:2000 — Packaging—Requirements for packaging recoverable through composting and biodegradation—Test scheme and evaluation criteria for the final acceptance of packaging, Annex A1 (London: BSI, 2000).

Conclusion
Through these actions, CMA seeks to advance consistency across certification programs,
reducing confusion in the marketplace, supporting composters with clearer standards, and
aligning U.S. practices with European frameworks. We will continue to apply scientific rigor and practical implementation to support the highest standards for compostable products.

For questions, please contact Janet Thoman, Managing Director, janet@composterapproved.com

Food Bank’s Intense Commitment Gives BIPOC Farmers a Lift

When Eloise’s Cooking Pot started a program to purchase produce from local BIPOC farmers and producers, it didn’t take long to identify a slew of challenges in those working relationships.

While the farms produced food that was unparalleled in quality and rich in cultural relevance, they often struggled with practices that fell outside the realm of growing food –  like transporting food, marketing it, or invoicing for it. Eloise’s Cooking Pot’s experience is similar to that of other hunger relief organizations that have had to overcome barriers to working with local farms, such as dealing with smaller crop yields and limited cash flow.

“It’s not been smooth, but we are committed,” said Ahndrea Blue, Founder and CEO of  Tacoma, Wash.-based Making A Difference Foundation, which runs Eloise’s Cooking Pot, speaking last month at the Anti-Hunger Policy Conference in D.C. 

That commitment began about a year ago, when Blue found out that a nearby farmers market had lost access to the parking lot where its producers, many of them Black, Brown, Indigenous and/or members of refugee populations, set up their booths every week. She thought, “There’s a food shortage, you guys are displaced and have amazing product, how can we buy it?” She already had access to fresh produce and meats from a variety of distributors, “but this set of farmers … they grow on a whole ‘nother level,” she said.

Initially, Blue managed to connect with ten of the displaced farmers. Through word of mouth, she eventually was put in touch with another 28. It didn’t take long, however, to run into complications.

“The first farmer we purchased from could not invoice us and we didn’t understand why,” Blue said. It turned out, he and a few other farmers didn’t keep accounting books. Some farmers didn’t have their businesses licenses in order. Others needed equipment they couldn’t afford. For many farmers, the concept of wholesale pricing was unfamiliar. Other farmers were struggling to identify new markets and some faced problems transporting their food.

“We realized these were common issues and we wanted to make sure that anybody we were working with had everything they needed to be as successful as possible, to make them all profitable and viable,” Blue said.

Blue is a lawyer and members of her team are well-accustomed to applying for grants, as well as billing and developing businesses. So, Blue organized a pilot in which pantry staff gives free technical assistance to farmers — teaching them everything from how to write a business plan, to keeping the books, to learning about food safety — and additional seminars on how to apply for grants.

Many farmers were also short on labor so Blue hired a staffer to travel to farms, pick and package produce, and deliver it back to the food bank. She hired an additional grant-writer for them, too.

The big win: this June she’s been able to contract to buy all the products her farmers are raising, and to pay them in advance for it all, which she calls “exciting for everyone.” With the pilot now coming to an end, she’s currently fundraising for the next stage in her farmer partnerships: creating a hub where producers can share processing space and an office with on-site support. (This will not be the first such food hub in Washington state. Food Lifeline also is building one.)

So far, Blue’s been able to count many successes in these farmer partnerships. One of her favorites involves a third-generation Black beef cattleman named Farmer Ed, who once referred to his operation as a hobby — he’d never had a business plan and never made a profit. “He fought with me for three months about [filing his paperwork],” said Blue. Eventually, having accepted help to set himself up as a legitimate business entity through the food bank pilot, he finally turned a profit and stopped investing his own cash in his operation.

Food bank clients, who are free to “shop” the pantry five days a week, have noticed a difference in the quality of the food that’s now available to them at Eloise’s. In addition to beef — “every high-end piece, including T-bone steaks and prime rib,” said Blue — the food bank offers all parts of the pigs, lambs, chickens and turkeys it sources. Microgreens grown by a BIPOC-owned farm called Garden of Eden continue to grow once clients get them home. Plus there is a long list of produce, including sweet corn, beets, rutabagas, chard, potatoes, cilantro, basil, and garlic.

“We have people lined up waiting for it to come in,” Blue said.

Perhaps most important, “This is the food clients would normally [like to] eat but they probably couldn’t afford, and it’s healthier and more nutritious,” said Blue. “You have people who are in need of food who have come to expect inferior foods and now we have these products.”

Add to that a roster of farmers who have a place to “distribute their wares and get paid appropriately, [and] it doesn’t get any better than that.” – Lela Nargi

In winter 2023, BioCycle launched a survey of full-scale food waste composting facilities in the United States. Like in previous reports, BioCycle defines a full-scale facility as a municipal or commercial facility equipped to receive and process organic waste streams arriving by truckload volumes from generators and haulers on a year-round basis. Typically, these facilities are composting more than 2,000 tons/year of all organic waste. This contrasts with “captive” sites that typically compost their own organics and utilize the finished product on-site. There are hundreds, if not several thousand captive composting projects in the U.S. at universities and colleges, K-12 schools, correctional facilities, resorts, health care centers and corporate campuses.

Community composting sites, which do accept food waste from off-site and often distribute the compost in their locale, vary in scale. Very small, decentralized sites typically can’t accommodate truckloads of food waste; smaller-to-medium community composting operations with capacity to accept larger volumes are included in BioCycle’s 2023 food waste composting infrastructure report.

BioCycle received support from the Composting Consortium, a multi-year precompetitive collaboration of Closed Loop Partners, to conduct its national survey of food waste composting infrastructure, along with a second survey project on residential food waste collection access. This four-part series in BioCycle summarizes the key data and findings from this collaborative project (Parts I and II). Parts III and IV will report on findings of separate Composting Consortium projects, which analyzed state regulations for upgrading yard trimmings composting sites to accept food waste, and anaerobic digestion of compostable packaging.

The data reported is primarily from the 2022 calendar year. BioCycle extends a thank you to the composting facilities that participated in our 2023 survey.  Their information and insights have been critical to taking the pulse of full-scale food waste composting in the U.S.

Methodology

Survey data collection and analysis has been supported by Stephanie Motta, a recent graduate of Presidio’s MBA Sustainable Solutions program. BioCycle compiled a master list of full-scale composting facilities in the U.S. using data from its 2018 survey, BioCycle editorial archives, and the US Composting Council’s directory of Seal of Testing Assurance certified compost manufacturers that accept food waste. About 230 facilities were identified and subsequently divided into operations with only one facility, and companies that own and/or manage multiple facilities. The individual facilities received an online survey questionnaire. Companies with multiple facilities received spreadsheets to fill out; most of the questions in the online survey were asked in the spreadsheet. After the initial outreach, facilities contacted that are no longer in operation were removed from the Master List. A handful of operating facilities declined to participate.

Ultimately, data was collected from 200 food waste composting facilities. A total of 105 completed the online survey; companies with multiple locations submitted data on 73 facilities. Toward the end of the data collection period (March-May 2023), BioCycle created a mini-survey with 10 questions (key data fields necessary for compiling a national infrastructure picture) to composting sites that had not responded; 22 completed the mini-survey.

BioCycle and Part I co-authors Stephanie Motta and Paula Luu, senior director of Closed Loop Partners’ Center for the Circular Economy, conducted a robust quality assurance review to address inconsistencies and anomalies in the food waste composting infrastructure data set.

Data Overview

Location: Nearly 50% of all full-scale food waste composting facilities in the U.S. are located in California (35), New York (14), Colorado (13), Pennsylvania (10), Washington (9), Texas (9) and North Carolina (9). Alabama, Delaware, Kansas, Kentucky, Mississippi, New Hampshire, North Dakota, South Dakota, Utah, West Virginia and Wyoming have been identified as food waste composting deserts, areas without any full-scale composting operations. The feature image (at top) illustrates the geographic distribution of facilities across the U.S. On a regional basis, the West Coast leads in terms of number of full-scale facilities (53, including Hawaii and Alaska), followed by the Northeast (47), Midwest (36), Southeast (30), Mountain states/Southwest (21). and Central states (13).

Year Began: Of the 105 facilities completing the online questionnaire, 40 started composting food waste within the last 10 years and 32 started between 2005 and 2013 (Figure 1). The emergence of community composting sites overlaps with the growth in full-scale facilities since 2013, based on data in the Institute for Local Self-Reliance’s 2022 Community Composters Census.

Permit Type: Almost 70% (136) of the full-scale operations surveyed have a state solid waste facility permit. About 20% (39) have a source separated organics/food waste tier permit from their state’s solid waste agency. Seventeen report having a registration permit (e.g., below 5,000 cubic yards (cy)/year), and seven have an on-farm composting permit.

Permit Limits on Organic Waste and Food Waste Quantities: Facilities were asked if their permits limited the quantity of total organic waste and separately, food waste, that they are allowed to accept on an annual basis. Of the 159 facilities responding, 66% have an annual throughput limit on the total amount of organic waste they can accept. Of those with permit limits, 44% are at, or close to, their permitted capacity for all organic waste, and 25% have between 50% and 75% available capacity. In terms of limits on the annual tons of food waste that can be accepted, 67% of 162 facilities responding do not have a limit. This may reflect the survey finding that most of the facilities have solid waste permits that may not have limits on annual quantities of food waste accepted. Of the 53 facilities that do have an annual limit on the quantity of food waste they can accept, 65% process less than 10,000 tons/year of food waste.

Feedstocks Accepted

Allowed by Permit to Accept: Composting facilities were asked about the types of feedstocks they are permitted to accept, and the feedstocks they are actually accepting. The question about feedstocks allowed under their permits was only asked on the online survey. Of the 105 responding, the majority are permitted to accept yard trimmings and wood waste (97) as well as all food waste, including meat, fish, and dairy (93). Close to 75% of the 105 respondents are allowed to accept compostable bioplastics and molded fiber containers (78), soiled paper (77), and agricultural waste (71); 65 are permitted to accept animal manure.

Food Waste Types Accepted: Figure 2 breaks down the types of food waste the facilities are accepting. Over 90% accept preconsumer vegetative food waste (e.g., from supermarkets, restaurants); close to 80% accept commercial and institutional source separated pre and postconsumer food waste. All source separated postconsumer food waste (including meat, fish, and dairy) is accepted by 78% of respondents. Nineteen facilities (<1%) accept vegetative-only postconsumer source separated food waste; one respondent noted they were limited to vegetative only due to the local authority’s concerns about vector attraction. Finally, 73% of facilities accept food processing and/or food manufacturing waste that includes meat, fish, and dairy.

Other Feedstocks Accepted: Figure 3 shows the other types of feedstocks accepted. Agricultural waste (other than livestock manure) represents the largest category (94 of the 154 respondents to this question), closely followed by soiled animal bedding (84), e.g., horse manure and poultry litter. Livestock manure (e.g., dairy, beef) is taken by 55 facilities. Biosolids and/or septage is accepted by 24 sites. Categories of yard trimmings and wood waste accepted were asked in a separate question. Leaves lead the pack (173 of 178 responding to this question), followed by wood chips (166), garden waste (162), brush (156), tree trimmings (156), grass (84), clean wood waste (74), and land clearing debris (58).

Generators Serviced: Figure 4 captures the categories of generators serviced by the full-scale facilities (173 facilities responding). Commercial landscapers and tree trimmers comprise the largest sector serviced, which makes sense because many of the food waste composting facilities started out composting just yard trimmings along with tree trimmings and wood chips. Commercial food waste generators (e.g., restaurants, supermarkets) come in second (147), followed by institutional generators such as schools, colleges, hospitals, and correctional facilities. The fourth largest category of generators are municipalities (130) that contract with these facilities to process residential yard trimmings. Other food waste generator categories serviced are industrial (108), agriculture (99), residential drop-off (98), and municipally-contracted residential food waste (97).

Acceptance of Food-Contact Compostable Packaging

BioCycle has been tracking composting facility acceptance of food-contact certified compostable packaging for more than 15 years. Food-contact packaging is defined as items that either contain food (e.g., carryout containers, snack bags, pizza boxes) or are utilized to capture food waste at the point of generation (e.g., certified compostable liner bags, kraft paper bags). Based on BioCycle’s 2018 data, 60 of the 103 responding to the question indicated they accept compostable food-contact paper products and 49 reported accepting certified compostable food-contact bioplastics products. In 2023, all 200 facilities responded to the question (Figure 5): 142 (71%) accept compostable food-contact packaging and 58 (29%) do not. Additional data collected about food-contact packaging includes:

Types: Figure 6 breaks down the types of food-contact compostable packaging accepted (141 facilities reporting). Food-soiled paper and pizza boxes are accepted by 83% (117) of facilities reporting. (A future survey will ask separately about food-soiled paper and pizza boxes to get a more specific assessment regarding paper products/packaging.) Certified compostable bioplastic liner bags are accepted by 93 (66%) of the 141 facilities. These include bags used to line kitchen countertop containers and collection carts. Other types of bioplastics-based packaging accepted by reporting facilities are certified compostable foodservice ware (87) and bioplastics-coated paper products (44). Fiber-based packaging accepted includes kraft paper bags (86) and molded fiber containers (70). Food packaging, such as snack bags, is accepted by 48 facilities.

Reasons for Not Accepting Food-Contact Packaging: Facilities that said they do not accept compostable packaging were asked to select the reasons why using a check-all-that-apply question. There were 55 responses to the question; 78% (43) cited contamination from lookalike single-use plastic packaging and film plastic bags as the main reason. Other reasons given include:

• Compostable bioplastics do not disintegrate in composting process: 32
• Compost sold to certified organic growers (compost that includes bioplastics cannot be used by certified organic growers): 28
• Product labeling insufficient to ensure packaging is certified compostable: 27
• Potential for PFAS contamination in molded fiber products: 26

Compostable Packaging Certification Requirements: Eighty facilities responded to a question about the certification they require for compostable food-contact packaging. Some include more than one certification. The majority (45) require the packaging to be certified by BPI (Biodegradable Products Institute). Other required certifications include ASTM D6400/6868 compostability standard (31); Compost Manufacturing Alliance field-tested (16); and TUV/OK (international certification schemes) (3). Eleven facilities require that the products be tested before acceptance and seven do not require any certification.

Facility Operations

The survey asked a number of questions about the full-scale food waste composting facilities’ operations. The following summarizes the responses:

Composting Method(s): Similar to BioCycle’s 2018 food waste composting infrastructure findings, the majority of the 200 facilities responding utilize the windrow composting method (75). As shown in Figure 7, 46 use aerated static piles (ASP), and 11 use both windrows and ASP. Ten facilities have covered ASP (e.g., engineered covers) and nine have static piles. There are four facilities with in-vessel systems. BioCycle has seen an increase in the practice of combining methods of composting at food waste composting facilities. Some start with ASP to better control moisture, odors, and temperatures, and then have turned windrows for maturation, followed by static piles for curing.

Facility Ownership: Of the 200 facilities, 151 are commercially owned, 43 are owned by a municipality (although some are managed by a private company), four are run by nonprofits and two are employee-owned.

Facility Financing: BioCycle asked questions about facility financing in its 2023 survey. Out of a response pool of 126 to a check-all-that apply question, the majority (102) self-financed their facility, 66 received bank loans or financing through an equipment vendor, 36 were awarded state or federal grants, 11 had equity investors and seven received institutional equity and/or debt financing. When asked about the types of financing they may be seeking over the next 12 months (92 responses), 64 selected state and/or federal grants and 52 selected bank loans or financing through an equipment vendor; 15 may seek institutional equity and/or debt financing and 13 might seek an equity investor(s).

Equipment Types: BioCycle received 150 responses to its question about types of equipment used at the composting facilities surveyed. As would be expected, 145 out of the 150 have front-end loaders; 66 utilize windrow turners. Eighty-three facilities report having grinders or shredders, 17 use mechanical mixers, and 14 report having a depackager. In terms of screens, trommels lead the pack (114), followed by vibrating deck screen (39) and star screen (31). Twelve employ hand-sorting lines and 37 have air separation equipment for contaminant removal after screening. One facility reports using “brains and biceps”!

Equipment Upgrades To Accept Food Waste: BioCycle asked facilities about site and/or equipment upgrades that they made if they were adding food waste to an existing yard trimmings composting facility. Of the 121 who responded, 91 indicated the question was not applicable (either implying that no upgrades were necessary or the site began as a food waste composting facility). Twenty-six facilities noted that an improved composting pad and/or working surface were needed (e.g., installing an impermeable pad for food waste receiving or switching from compacted dirt pad to compacted gravel). Twenty-five installed food waste preprocessing/sorting equipment, e.g, a depackager, hand sortation line and/or slow speed shredder. Other upgrades include shifting to a forced aeration composting method (14); procuring a larger loader bucket (11); procuring a windrow turner (9); and installing an air classifier on the compost screen (8). Two facilities procured more land and two built new receiving areas for food waste.

Contamination Management: Figure 8 shows contamination thresholds allowed in incoming feedstocks (145 facilities reporting): zero tolerance (45); less than 5% (66); less than 10% (15); less than 15% (2); and no set threshold (17). A follow-up question on the survey asks how facilities determine if a load meets the threshold (by weight, volume or visual inspection). Of the 106 responses, the majority measure by volume of contamination (76); 15 measure by weight, and 15 do visual inspections.

Facility Expansion Plans: A question about plans for facility expansion received 127 responses: 51 facilities have no plans to expand, 48 plan to expand their existing site, and 28 said they will be opening additional food waste composting facilities.

Food Waste Collection Service: The majority of full-scale food waste composters are not vertically integrated in terms of offering a food waste collection service. Facilities collecting food waste typically will accept loads from other haulers if the feedstock being tipped meets their requirement, e.g., contamination thresholds. Of the 105 facilities reporting, 56% offer food waste collection and 44% do not. When asked if they are interested in expanding into collection (59 responses), 54% said no, 29% said maybe and 17% said yes.

Tonnages Composted

The BioCycle survey asked facilities about the tons of all organic waste and the tons of food waste they compost annually. The response options are given in ranges for two reasons:

• Many facilities, especially smaller ones, do not have scales and thus estimate the volume of material accepted in cubic yards.
• Generally speaking, commercially owned and operated facilities are reluctant to provide exact tonnages but are willing to report when given a range.

All Organic Waste Received: Figure 9 (164 facilities reporting) shows the tonnages of all organic waste received and composted, including food waste. The response options were given in the tonnage ranges shown in the figure. The conversion factor provided by BioCycle is 2 cubic yards (cy)/ton (although yard trimmings typically are 3 cy/ton). Less than 2% of facilities composted more than 100,000 tons of organic waste in 2022, while 31% composted less than 10,000 tons. Medium-scale operations (>10,000 tons/year to <49,000 tons/year) account for 38% of the facilities reporting. A total of 28 (17%) compost between 50,000 and 99,000 tons/year. Taking the minimum (low end of the range)  and maximum (high end of the range) of tonnages of all organic waste the surveyed facilities are composting, we estimate a minimum of 5,165,000 tons/year and a maximum of 8,824,888 tons/year in 2022.

Food Waste Composted: Figure 10 reports the quantity (tons) of food waste composted annually at the full-scale facilities (189 facilities responding). The same 2 cy/ton conversion factor was used. The majority (60%) of full-scale composting facilities in the U.S. responding to this question compost <5,000 tpy of food waste (113). There are 33 facilities composting between 5,000 and 9,000 tons/year (17% of all facilities reporting) and 26 (15%) composting between 10,000 and 25,000 tons/year. Four facilities (0.02%) compost between 50,000 and 100,000 tons/year and four (0.02%) compost more than 100,000 tons/year. When the tons of food waste composted in each range are tallied, we estimate that the full-scale food waste composting infrastructure in the U.S. composted a minimum (low end of the range) of 1,350,000 tons/year and a maximum of 2,652,388/year in 2022.

Figure 11 overlays the reported tons/year of food waste composted with data provided by facilities that reported the permitted tons/year of food waste allowed to be accepted and how much of that allowed capacity is being utilized. As noted earlier, most reporting facilities either don’t have a permitted limit and/or didn’t report capacity. Most of the facilities indicate they have capacity available to receive more food waste.

Compost Markets

Market Segments: Figure 12 captures the primary compost market segments for the compost and soil blends manufactured (176 facilities reporting). Not surprisingly, commercial landscapers, nurseries, and golf courses are the largest segment where compost and blends are sold (151 reporting), followed by the residential turf, gardens, and landscapes markets (137). These outlets are well established and in fact, since the COVID 19 pandemic, many compost manufacturers have sold out of the compost available. Conventional agriculture (89) and organic agriculture (72) are outlets for many facilities reporting, as are the erosion control and stormwater management, engineered soils markets (77) and topsoil blenders (70).

Volumes Produced: The estimated volume of compost produced annually was also reported in ranges. Figure 13 captures this data. Of the 189 facilities reporting, 39 produce between 10,000 and 25,000 cy/year, and 34 fall into the 25,000 to 50,000 cy/year range. There are 31 facilities that produce less than 2,500 cy/year — a reflection of the number of smaller scale facilities responding.

Reflections on Food Waste Composting Infrastructure In The U.S.

Gathering and analyzing data about full-scale food waste composting infrastructure in the U.S. for the past six months have led to a variety of insights about this sector of the organics recycling industry. Our reflections include:

• Since the last BioCycle national survey of full-scale food waste composting facilities in 2018, there has been a pandemic, an increase in states adopting food waste disposal bans or mandates, and media-worthy investment and merger and acquisition activity across the country. Five years later, the number of full-scale food waste facilities has increased 8%, from 185 to 200 facilities — a small but notable change. During that period, there was marked growth in the number of community and captive composting sites. A main takeaway from this year’s data is that food waste composting in the U.S. is happening across the ‘scale spectrum’ — from micro to macro.
• Similar to BioCycle’s findings in 2018, the majority of facilities (60%) reporting compost less than 5,000 tons/year of food waste. Using the maximum tons of food waste composted based on our 2023 data (2.6 million tons), today’s composting infrastructure processes up to 4% of the 66 million tons of total food waste generated annually in the U.S (Source: U.S. EPA). This reflects several realities, including increasing tonnages of food waste (primarily preconsumer) being processed at anaerobic digestion facilities, reluctance on the part of yard trimmings composting operations to accept food waste due to concerns about odors and contamination from conventional plastics, and facilities in a lower permitting tier that are limited on the annual tons of food waste they can accept. The composting industry is at an inflection point in its development, and to meaningfully address food waste, the industry needs to spur investment and industry action to establish compost manufacturing as a viable solution for food waste at scale.
• In terms of the quantities of all organic waste composted, ‘mega’ facilities are few and far between. Smaller-scale, independent operations play an important role in establishing food waste processing across the country. Funding for both ‘mega’ facilities and smaller scale facilities are needed to scale the industry’s capacity to process food waste as a whole. This is inclusive of ‘captive’ composting facilities which are on-site and do not accept off-site feedstocks.
• The majority of facilities that accept food waste today take compostable packaging of some sort (71%), and this trend is growing compared to historical data (up from 58% in BioCycle’s 2018 survey). The number of facilities that accept certified compostable food-contact bioplastics packaging (e.g., foodservice ware) also increased over the past five years — 87 out of 141 (62%) in 2023 as compared to 49 out of 103 (48%) in 2018. This increase reflects the progress made by certification bodies (i.e., BPI) and field-testing services (i.e., Compost Manufacturing Alliance) that instill a growing trust in products entering the market.
• Like past years, there is a reluctance among commercially operated facilities to share data, especially on the part of large solid waste companies that are increasingly operating full-scale food waste composting sites. That reluctance, combined with the unavailability of some data requested, makes it somewhat challenging to paint a national picture. Legislation currently in Congress, the bipartisan, bicameral Recycling and Composting Accountability Act, requires the U.S. Environmental Protection Agency (EPA) to collect and publish data on recycling and composting rates across the country to provide an accurate reflection of performance both nationwide and at the state level. This legislation will be an immense help to data on the composting sector.

In summary, food waste composting infrastructure in the U.S. is a proposition of different scales. BioCycle foresees that diversity and distribution of composting infrastructure continuing to grow. Part II of this series will report on the findings of BioCycle’s 2023 Residential Food Waste Collection Access Study, also conducted in collaboration with Closed Loop Partners’ Composting Consortium. Food waste composting facilities participating in the BioCycle’s 2023 Nationwide Survey: Full-Scale Food Waste Composting Infrastructure in the U.S. is available at this link.

Nora Goldstein is Editor of BioCycle, and has been conducting surveys on food waste composting infrastructure in the U.S. since the mid-1990s. Paula Luu is a Senior Project Director at Closed Loop Partners, an impact investment firm and innovation center focused on development of the circular economy. She leads the firm’s Composting Consortium, which works closely with brands, composters and other key stakeholders to gather data that can inform the best path forward and drive value across the composting system. Stephanie Motta is a Data Strategist for Closed Loop Partners’ Composting Consortium. Additionally, she leverages her recent MBA by actively contributing her expertise as a sustainable business consultant, empowering organizations towards ESG-focused practices.

On July 3 rd , 2023, Los Angeles County updated their ordinances on acceptable compostable products, including CMA as a new standard for qualifying products. The ordinances can be accessed here under Chapter 12.86 – REDUCTION OF WASTE FROM SINGLE-USE ARTICLES AND EXPANDED POLYSTYRENE RODUCTS. 12.86.010 – DEFINITIONS

This is fantastic progress. Yet, ordinances can sometimes be confusing to navigate. As such, we will review and assess what these definitions mean for product manufacturers aiming to be compliant with LA County’s new regulations.

The following has been outlined in LA County for an item to qualify as ‘compostable’ and thus be accepted into the local market:

1. It must be free of all intentionally added fluorinated chemicals, including, but not limited to, per- and polyfluoroalkyl substances (PFAS); and
2. It must satisfy one or more of the following additional requirements:

a . It must be certified as \”home compostable\” by a certifying organization acceptable to the director of Public Works. \”Home compostable\” means that the material will biodegrade at moderate temperatures in a composting bin designed for home use

b. It must be certified by its manufacturer to be composed solely of fiber-based material, such as paper or wood, without any coatings or additives that are not made entirely from fiber-based material; or

c. It must accommodate a specific food service application for which the Director of Public Works has determined that no single-use article that complies with subsection 2.a or 2.b of this definition is readily available, and it must have been certified as compostable by both the Biodegradable Products Institute (\”BPI\”) and the Compost Manufacturing Alliance (\”CMA\”).

The good news is: If you’re CMA approved or certified, you already have these boxes checked! That said, let’s break this down piece by piece.

1. It must be free of all intentionally added fluorinated chemicals, including, but not limited to, per- and polyfluoroalkyl substances (PFAS)” PFAS is a large group of chemicals used in a wide variety of applications, from ski wax to household products. In foodservice products, they are typically used to provide grease resistance and are commonly found in items such as deli sheets and molded fiber containers. Do you use Teflon pans? PFAS chemicals are used to provide that nonstick surface perfect for an over easy egg.

PFAS are quickly becoming known as “forever chemicals” because once used, they are nearly impossible to eliminate. They have been linked to several health effects including:

• Increased risk of some cancers
• Decreased fertility or increased high blood pressure in pregnant women
• Developmental effects in children
• Increased cholesterol levels and obesity risk
• Reduced ability of the body’s immune system

What’s more, commercial composters are passive receivers when items containing PFAS are introduced into the pile. The composting process cannot destroy these compounds, meaning that the finished product (compost) can also contain PFAS. Thus, to save our future gardens from chemical contamination, it’s best to limit foodservice items containing PFAS from entering the compost bin in the first place.

CMA implemented our PFAS policy in 2021 to ensure approved and certified products are not contributing to this challenge. To qualify, all submissions must be tested for total fluorine at a CMA
approved laboratory and meet the required criteria.

2a. It must be certified as \”home compostable\” by a certifying organization acceptable to the Director of Public Works. \”Home compostable\” means that the material will biodegrade at moderate temperatures in a composting bin designed for home use.

Currently, the only qualifying ‘home compostable’ certification is TUV’s OK compost HOME, in which a set of lab tests are conducted to replicate comparable home composting conditions. Due to the high variability in these conditions, there is not yet a field-based certification for home composting.

2b. It must be certified by its manufacturer to be composed solely of fiber- based material, such as paper or wood, without any coatings or additives that are not made entirely from fiber-based material;

This is fairly straightforward- the County wants fiber-only materials first and foremost. Birch cutlery, single-ply napkins, and coffee stir sticks are all good examples. However, there are certain foodservice applications where this parameter won’t work; if coffee or soup is served in an unlined or uncoated fiber cup, chances are that more will end up on the table than in your stomach. Hence…

2c. It must accommodate a specific food service application for which the Director of Public Works has determined that no single-use article that complies with subsection 2.a or 2.b of this definition is readily available, and it must have been certified as compostable by both the Biodegradable Products Institute (\”BPI\”) and the Compost Manufacturing Alliance (\”CMA\”).

This means that for product categories that cannot be fulfilled by a fiber-only solution, alternative items are acceptable. However, they must be certified compostable by both BPI and CMA.

Unlike other counties in California, LA County’s updated ordinances do not specifically restrict single-use bioplastic items, meaning that items made from PLA or a similar biopolymer may be accepted under section 2c.

By referencing CMA as an acceptable certification standard, LA County is ensuring that products entering the market are:

• Proven to disintegrate in real-world compost facilities
• Shown to meet ASTM D6400 or D6868 standards for compostability
• Not introducing PFAS into the compost stream

If you are a product manufacturer wishing to certify your items compliant for LA County, please contact Diana Lloyd-Jones for more information.

We commend LA County’s due diligence in the compostables area and fully support their efforts to improve local organics recycling programs.

Industrial compost manufacturers have historically accepted some paper-based products such as napkins and food soiled paper. In keeping with this reality, CMA accepts some paper-based products that have not been tested to ASTM standards.  For example, paper products with <1% of a single additive and a minimum of 95% fiber are eligible for substrate acceptance (SA). These products are “accepted” but not approved or certified by CMA. Until feasible and economical alternatives are readily available, we continue to work with manufacturers to move these products forward to full approval and certification.

For product certification, CMA requires passing ASTM D6400 or D6868 laboratory standards, as well as other requirements including field disintegration testing and total fluorine testing. For certification,CMA has made a conscious choice to interpret these standards conservativelyin the interest of protecting compost feedstocks and the environment through reducing and eventually eliminating non-compostable additives and materials that microfragment rather than fully biodegrade. Thisis also taken with a view toward risk management for our customers and our composting partners.

CMA evaluates all multi-layered products under ASTM D6868; this includes thermoplastic and thermoset coated (e.g., acrylic coated) paper. We require biodegradation testing of all coatings and layers, regardless of percentage. We understand that there are differences in opinion about whether this is necessary. However, ASTM D6868 6.3.1 requires, “The plastic coating or polymeric additives must meet the requirements of subsection 6.3 of Specification D6400.”ASTM D6400 6.3 requires, “6.3 Biodegradation—A plastic product must demonstrate a satisfactory rate of biodegradation by achieving the following ratio of conversion to carbon dioxide found in 6.3.1 and 6.3.1.1 within 180 days using the latest revision of Test Method D5338, ISO 14855–1, or ISO 14855–2.”  ASTM D5338 is preferred because it uses finished compost as the test medium.

Read together, D6868 6.3.1 requires a coating or additive to show “a satisfactory rate of biodegradation by achieving the following ratio of conversion to carbon dioxide…”  ASTM D6868 6.3.1 points only to D6400 6.3. D6400 6.3 only references 6.3.1 and 6.3.1.1 to specify the ratio of conversion to carbon dioxide. ASTM D6400’s reference to 6.3.1 and 6.3.1.1 is for a limited purpose and does not incorporate those sections in their entirety. Therefore, CMA requires that all coatings and layers be tested under ASTM D6868 to show biodegradation separately, in addition to the disintegration requirements for the whole product.

This is not just interpretational nitpicking. CMA believes this is the right direction to address the growing issue of microplastics in our environment. As a consumer society, we have inundated ourselves with a material that, while providing great social benefit, has also left us with persistent material that pollutes our water, soil and air. The long-term effects on human health, animal and plant life, water and soilare of great concern and are largely unknown. Human health is potentially impacted through toxicity, bioaccumulation, inflammatory and immune responses, and microbiome effects that can result in the spread of pathogens. [1]

Woods End Laboratories and Eco-Cycle[2], in a study of plastics in composting, demonstrated that: 1) plastic coatings do not biodegrade; 2) plastic coatings retard the biodegradation of paper layers; and 3) microplastic fragments were shed from all plastic-coated samples, contaminating the finished compost.

When microplastics are released into the environment, there is no feasible remediation measure. Compost manufacturers have changed their acceptance standards over time, but they are inundated with contamination, much of it in the form of plastics. While coatings on packaging may seem de minimis compared to all other sources of plastic contamination, pleading “I am not as bad as they are” is not an approach that will lead to improving the problem.

For these reasons, CMA continues to require biodegradation of all coatings on all certified products. Similarly, CMA will not adopt ASTM D8410 for evaluation of cellulosic-fiber-based packaging. While D8410 does exclude thermoplastic coatings, it does not necessarily exclude thermoset materials. As such, if a thermoset coating is applied at <1% dry weight, it would be exempt from biodegradation testing under this standard.The net result is that products can meet the 90% biodegradation requirement where traditional plastic coatings are used, resulting in knowing introduction of microplastics into the compost stream. For this reason, CMA will not accept D8410 for evaluation of fiber-based packaging.

On the other hand, CMA does fully support, approve and certify industrially compostable bioplastics that do fully biodegrade in the lab and disintegrate in its field testing.  These materials are not viewed as an issue for industrial composting.  The acceptance of products produced from these CMA certified products is up to each individual industrial composting operation and their regulators.

CMA encourages all stakeholders to strive for the best we can do.CMA recognizes the investments and innovation demonstrated by the packaging industry and compost manufacturers to address these issues. We understand sustainability is challenging and striving for solutions is sometimes daunting. We are committed to continuing our work with composters and packaging companies to connect the system in a way that achieves true sustainability. Sustainability is a team sport.  We are grateful to have you on our team.

[1] S. L. Wright and F. J. Kelly, “Plastic and human health: A micro issue?,” Environmental Science & Technology, vol. 51, no. 12, pp. 6634–6647, 2017.

[2]W. Brinton, C. Dietz, A. Bouyounan, D. Matsch, “Microplastics in Compost: The Environmental Hazards Inherent in the Composting of Plastic-Coated Paper Products, Woods End Laboratories and Eco-Cycle, Originally Published April 2011. Updated April 2016 and May 2018.

CMA strives to create a lane for innovation while acknowledging practical realities of the state of product development and the market. In this spirit, CMA accepts some compostable products that do not fit the laboratory definition of compostable.  These products are those that composters have traditionally accepted (like paper napkins) or that reduce plastic contamination.  For example, CMA accepted paper straws for a period to reduce the number of plastic straws that contaminated the compost stream.  Once compostable adhesives were reasonably available, CMA removed paper straws from this category.  Paper straws must now pass ASTM laboratory testing as well as field disintegration testing. 

To address a common contaminant in compost feedstock streams, CMA is adding paper produce stickers to its acceptance standards under our Plastic Elimination Strategy.  These small stickers, adhered to every fruit or vegetable in grocery stores across the country, enter compost streams by the millions.  Because of their size, these stickers can make it through many of the contamination reduction methods employed by compostoperations. Plastic stickers do not disintegrate in the compost process and remain at the end of processing, potentially contaminating the finished product.

Based on our research, a truly functional, compostable pressure-sensitive adhesive is not readily available in the market.  As with straws, we anticipate such an adhesive will be available within the next few years.  At that time, produce stickers will be required to pass ASTM as well as field disintegration testing to become CMA certified.  Until that time, CMA will evaluate paper produce stickers for acceptance (not certification) with confirmation of the following:

1. Constituency must be primarily paper.
2. Total fluorine <100ppm confirmed by testing at a CMA-approved laboratory using CMA-approved protocols.
3. Additional testing dependent on constituency.

These labels will be given the CMA-S designation.

For questions or additional information regarding CMA’s Plastic Elimination Strategy or evaluation of paper produce stickers, please contact Janet Thoman, Compliance Director at janet@composterapproved.com. 

USCC’s Compost 2023 was full of excellent information, innovation, old friends and new.  But my favorite moment, by far, was A1 Organics’ Bob Yost, upon receiving the Hi Kellogg Award, closing his remarks with, “It is not about you.” 

He’s right. It’s not about me.  Or you. Or any individual or any organization. It’s about our planet being assaulted by consumption and greed and ignorance.  It’s about what we can do, individually and collectively, to mitigate the harm we do daily.

The forces that have led us to this place are long-standing and complex. But it is safe to say that ego, manifest in greed and competition, has had a lot to do with it.  I wonder if ego isn’t what is going to thwart our best intentions.   

The composting and compostable products space is comprised of intelligent, hard-working people who want the best for our world. We each do what we can to fix the mistakes of the past to create a better future.  We do not always understand the perspective and the forces compelling others’ actions. Society and legislation are constantly in collision with the realities of product development, market forces and running a business.  What isn’t influenced by these forces are the microbes that do the heavy lifting.  The microbes don’t lie.  The piles don’t lie.  Maybe we should listen to the microbes. 

Maybe we should listen to each other.  Maybe we should share our vision more and our agendas less. In that spirit, I want to share CMA’s vision and the reasons we do what we do. 

CMA’s vision is a system that connects and works for everyone, that gets organics out of landfills and produces beautiful soil amendments to nourish our soils, clean our waters and sequester carbon. CMA strives to facilitate organics diversion by connecting compostable products – the vehicles for food — to compost manufacturers.  We work to create a system where compost manufacturers who bravely choose to accept compostable products can minimize contamination so they can create a saleable product that improves our world.  We want the cleanest compost, free of harmful chemicals and the microscopic particles that we cannot see but that wreak havoc on the environment and our bodies.

From where we sit, between product manufacturers and composters, we are pushing and pulling to try to make the ends meet in a sustainable way.  This does not always make everyone happy.  That’s ok.  We keep trying because it matters.  It matters that composters can create their products without being drowned by contamination.  It matters that packaging producers are told the truth so they can spend their R&D dollars wisely.  It matters that we get organics out of the landfills. It matters that we do anything we can to combat climate change.  We are willing to ruffle some feathers to achieve that. 

CMA requires products to pass the established and accepted laboratory standards for compostability.  These tests are vital to ensuring we are not introducing harmful substances into the compost and, thereafter, our environment.  But there are differences in interpretation about what these tests require.  To achieve our goals, we choose to take the most conservative interpretation of these tests. Sometimes that is disappointing to our customers.  We understand that frustration.  But we also understand that we cannot achieve our goals without pushing to raise the bar a little at a time. 

We also understand that there are products that may not meet every standard, but they are better than the alternative.  We grant these products some special dispensation until the market can come up with something better.  Some of these products fall into our Plastic Elimination Strategy category.  This is a category in which we encourage product development so the less-than-ideal products can be phased out.  But we want all stakeholders to take that trip with us.

Around 2018 we saw a huge surge in the manufacture of paper straws as an alternative to traditional plastic straws.  These straws contained adhesives that did not pass the ASTM lab standards.  However, from a composter’s perspective, paper straws were preferable to receiving traditional plastic straws.  For about five years, we accepted paper straws in our Plastic Elimination category.  Over those few years, product manufacturers responded.  A compostable adhesive became feasible and widely available in the market, and we removed paper straws from our Plastic Elimination category.  Paper straws must now undergo the same lab and field disintegration testing as any other product.  This is our strategy in action. This is cooperation in action.  This is how it can work.   

CMA, and Cedar Grove before us, has worked for over sixteen years day-in and day-out in the piles.  We put on our boots and get our hands dirty. We have performed nearly 200 field tests in eight different processes, and we have tested thousands of products.  We have tested and examined the feedstock and process parameters for every one of these tests.  We have made assumptions and proven ourselves wrong at times.  We have tested others’ assumptions. We only now believe we have enough information to start drawing some conclusions.  These conclusions, we hope, will provide everyone with more information to make the system work. 

Over the next several months, we will be sharing some announcements and information we have from years of field testing.  We will tell you what the piles have told us.   We will share our thoughts about how that information can be applied to serve our collective vision. 

Some of these communications might feel disruptive to a system that functions in silos.  CMA is the largest connected network of compost facility operators in the U.S. that accept compostable materials. These compost facility owners have the final say in what works and what they accept, and we will continue to work to create a space where compost manufacturers, the supply chain, haulers and solid waste experts work respectfully together to define the next chapter of compostables.   

We might keep ruffling some feathers.  That’s ok. We will keep trying because it matters.  We will try to share our vision a little more and our agendas a little less.  Because, you know, Bob’s right.  It’s not about me. 

CMA invites you to this conversation.  Please contact me at janet@composterapproved.com and share your vision.

The deadline for all bills to pass out of their house of origin was March 8, 2023.  Any bill that did not pass is not moving forward this session.  Several bills we were tracking fell to this deadline. 

Not Moving Forward This Session

The Extended Producer Responsibility (EPR) bill, known as the WRAP Act, did not pass in the House before the March 8 deadline and will not be moving forward this session.  This bill garnered huge interest and participation, undergoing numerous amendments.  With the input and engagement from this session, it is likely this bill will be reintroduced next session as a more seasoned bill.

Other bills that will not move forward this session include:

Biosolids:  SB 5245, requiring PFAS limits in biosolids and creating tracking and notice requirements.

Farm and fields program enhancement:SB 5484,supporting Washington’s food production system by providing technical assistance in support of improved voluntary environmental stewardship.

Cannabis waste: SSB 5376. Allowing the sale of cannabis waste.

Grants for managing ag waste: SB 5551 / HB 1574, supporting Washington’s crop and livestock farms, reducing greenhouse gas emissions, and generating renewable energy by capturing methane.

Still Active

The compostables stakeholder committee bill, ESHB 1033, has moved forward. The bill would establish a stakeholder advisory committee to address issues related to the use, collection, and processing of compostable products within the state.  The Advisory Committee will be comprised of representatives from government, compostable product manufacturers, compost manufacturers, certifiers, haulers, a trade association, and an environmental non-profit organization.  The goal will be to produce a report of findings and recommendations to the legislature in 2024. 

            The Battery Recycling bill, ESSSB 5144, passed out of the Senate and is in the House Committee process. Currently, Washington businesses are required to use battery recycling services, but there is no requirement for individual consumers to do so.  Despite voluntary options and efforts, battery recycling is not convenient, leaving mostof these dangerous and toxic items destined for landfills.  This bill would require battery producers to join a Producer Responsibility Organization (PRO).  The bill will not mandate battery recycling by individual consumer but aims to encourage recycling and provide more convenient disposal options. 

            Theplastic pollution reduction bill, SHB 1085, unanimouslypassed out of the House.  The bill would require all new commercial construction to include a water bottle refill station wherever a drinking fountain is currently required. To reduce direct pollution in state waters, the bill would prohibit manufacture, sale and installation of overwater structures that use plastic foam. Lastly, the bill would ban the use of miniature toiletry products for hotel guests in the state. 

            The Right to Repair bill, ESSHB 1392 has also passed in the House and moved to the Senate for consideration.  The bill would require certain electronics manufacturersto make accessible their product manuals, repair information, parts and special tools required to repair their products to allow consumers access repair services from independent facilities for products that they own.

The regular 2023 Legislative Session officially ends April 23, 2023. 

There’s nothing more comforting than the smell of a 3-hour roast warming first the house as it cooks, then the family table, and then your belly. Food holds one of the most unique placeholders in society; we need it to survive, to thrive; we share it with others in difficult times and moments of celebration; we personally identify with flavors from childhood or from our culture. I’m a firm believer that there isn’t a life scenario that the right meal can’t help. Feeling ill? Have a bowl of chicken soup. Dealing with a breakup? Grab some ice cream and skip the bowl. Want to impress the in-laws? Hello rack of lamb with a cherry glaze! Humanity incorporates food into countless aspects of our lives, but once the meal is over, we have a habit of forgetting about the remains. What happens to that roast once the family is tired of eating the same meal? What about the leftover Christmas cookies the neighbor dropped off that went stale? What happens to the buffet remains after they’ve been sitting on the line for hours on end? 

When one steps back from their personal role to assess the food system in its entirety, the unsustainable nature of the beast rears its ugly head. In the U.S., nearly a third of food produced for human consumption is either lost or wasted. That means nearly a third of all the inputs required to produce, process, ship, prep, and store food are also wasted. If food waste were a country, it would be the third largest emitter of greenhouse gases after the U.S. and China. When organic material decomposes in an aerobic environment, such as a compost pile, carbon dioxide is created. However, in a landfill, the lack of oxygen present causes organics to off gas methane- a greenhouse gas 100 times more potent at storing atmospheric heat than Carbon Dioxide. Out of the 63 million tons of food waste generated in 2018, only 4% was managed via composting. When faced with the facts, it’s commonly argued that the single most impactful step society can take to combat climate change is remove organics from the landfill. But how do we do that in the age of convenience? Enter compostables, stage left.  

Compostable foodservice ware is a small but key component to redirecting commercial organics from landfill to compost operations. In the age of convenience, simplifying the responsibility of the consumer is crucial. When lunch travels in a Styrofoam clamshell, there are some brave souls willing to scrape their leftovers out of the container and into the green bin, but it is unrealistic to expect this level of due diligence from the larger population. To capture those organics properly, it makes much more sense to make the vessel they’re stored in compostable as well.  

Personally, I’m a full believer that all food packaging will eventually need to be compostable for society to meet this goal. But the fact is, we’re not there yet. Today, CMA regularly sees items designed as compostable passing the required ASTM tests but failing to compost at the facility. This is a problem that must be solved in order to move the dial towards a true circular economy. Any items present in commercial composting that don’t disintegrate are designated as ‘contamination,’ sifted from the final product, and sent to the landfill at the expense of the composter regardless of whether they were designed to compost or not. If this problem persists, compost manufacturers will choose to stop accepting post-consumer food waste altogether. This is already happening in places like Oregon and Vermont.  

Through collaboration across stakeholders, we here at CMA are working to solve this problem. By working with product developers, ASTM lab experts, compost manufacturers, and industry leaders, we hope to foster transparent partnership in the goal of long-term, truly sustainable compost programs. It is my hope that this stakeholder collaboration will drive the development of new food-related compostables and contribute to shifting the organics from the landfill and into a high-quality, stable soil amendment.  

If you are a packaging designer, this is your call to action. Let’s collaborate across the manufacturing chain! Let’s develop compostable materials that work both in their shelf stability and in the compost pile. Let’s move away from single-use plastic alternatives and design foodservice and food-related items to work for the highest energy return. Let’s redesign the narrative so that, in the future, when Uncle Fred cleans out the fridge after the holidays, he’s not inadvertently sending organics to the landfill.  

Perfluoroalkyl substances (PFAS) is a broad class of chemicals of which many have been found to have adverse human health effects and/or to be environmentally persistent. Common materials such as Teflon polymers and coatings, Gore-Tex fabric and Scotchgard stain resistant chemicals are PFAS. In packaging, PFAS have many uses including in pulp molded products to impart water and grease resistance and as lining for microwave popcorn bags. Unfortunately, PFAS in packaging that is composted stays in the finished compost and then is transferred to the environment when the compost is spread on gardens, etc. and then washes into open waters with rain, irrigation or other means.

Thus, many localities such as San Francisco have banned the presence of PFAS in items to be composted. The Compost Manufacturing Alliance and all other industrial compostability certification agencies have similarly banned the use of PFAS in certified products and materials for industrial compostability since January 1, 2020 and before. Ideally, the presence of PFAS can be determined by chromatographic means for identifying the specific PFAS in the product or material; this requires the extraction of the PFAS intact from the product or material. However, three issues prevent this, the first is that PFAS binds to natural fibres and thus will not extract, the second is that not all specific PFAS chemicals have been identified for identification by chromatography and the third is expense.

Thus, a simpler means to detect the presence of PFAS is to measure the amount of fluorine (F) in the product or material, i.e. total fluorine analysis. To perform this analysis, the material must be digested, i.e. broken down, and then use well-known methods for determining F amount. The one complicating factor known early is that several non-PFAS chemicals also contain F; this includes common fillers and minerals such as talc. Thus, the non-PFAS chemicals containing F must also be tested independently and their contribution to the total F content of a material must be subtracted from any test result.

A second issue was raised by pulp molded foodservice ware manufacturer. In testing at outside labs, total F content reported varied from nearly non-detectable to over 1000 parts per million (ppm), i.e. from acceptable to not acceptable F content. The manufacturer stated that they did use PFAS in the product and thus the total F content should be over 1000 ppm. After talking with Ron Walling of Advanced Materials Center (AMC), AMC started a project to determine what the issue was. Working with three labs that test for fluorine, side-by-side analysis of products with and without PFAS. The study determined that the issue is the difference in the digestion methods used prior to the F content analysis. Some labs used an open crucible and others used a Paar bomb or closed crucible for the heated digestion. As F is volatile, the open crucible released the F to the atmosphere and thus gave a low F content after analysis. Thus, total F analysis requires that sample digestion be performed by a Paar bomb. CMA allows total F analysis by only approved labs after the proper digestion method.