Ambient Temperature Biodegradation Lab Reports are Not Accepted for Industrial Composting Certification

The Compost Manufacturing Alliance is committed to maintaining the highest standards for compostable products. As part of this commitment, we require that all products show acceptable laboratory verification under the latest version of ASTM D6400 or D6868.

We see a significant increase in laboratory reports where disintegration and mineralization or biodegradation is performed at ambient (20C +/-) temperatures rather than industrial composting temperatures (60C +/-). These temperatures are measured in the compost medium rather than outside the vessel or pile. While some certifications may accept ambient temperature results to satisfy their requirements, CMA does not.

CMA strictly applies the D6400 and D6868 criteria. These standards require:

6.1 In order to be identified as compostable in municipal or industrial aerobic facilities, products must pass the requirements of 6.2, 6.3, and 6.4 using the appropriate laboratory tests, representative of the conditions found in aerobic composting facilities, which reach thermophilic temperatures. ASTM D6400-26, 6.1 (Emphasis added.)

Thermophilic temperatures range from 55 to 70 C.[1] Therefore, disintegration and biodegradation testing must be performed at this temperature range to comply with the requirements of ASTM D6400 and D6868.

There is an assumption that if a product biodegrades or disintegrates at one temperature, such as ambient temperatures, it naturally follows that it will biodegrade at a higher temperature. This is simply not true!

Composting requires microbial activity to perform the work of degrading material. Microbial activity varies at different temperatures. Different microbial populations thrive at higher or lower temperatures. It is primarily this microbial activity that affects disintegration of material or products. Some microbes break down one material better than another. Therefore, the different microbes at different temperatures will not break down all materials – natural or manufactured – at the same rate.[1]

Reference

[1] Robert Rynk, Jeff Ziegenbein, Cary Oshins, Nanci Koerting, James Hardin, and Jeff Gage, “Process Management,” in The Composting Handbook: A How-To and Why Manual for Farm, Municipal, Institutional and Commercial Composters, ed. Robert Rynk et al. (Cambridge, MA: Academic Press, 2022), 505, Table 11.2.

If you are planning to apply for CMA certification, please confirm that your laboratory testing has been performed at the appropriate temperature.

If you have questions about our certification requirements, please reach out to Janet Thoman at janet@composterapproved.com.

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

I. Introduction

Certification is most often viewed as a means of conveying a company’s commitment to a certain value or standard. It provides a way to communicate to consumers or potential customers that the product or service meets specific criteria. Compostability certification, for example, communicates the product maker’s commitment to sustainable environmental practices. However, certification serves not only as a marketing tool but also as a proactive legal and regulatory risk management strategy.

II. The Legal Function of Certification

The value of certification as a risk management and mitigation strategy is often overlooked. The certification process can reveal weaknesses, confirm alignment with industry standards, provide evidence of due diligence, and position the brand within industry norms.

Risk presents in a multitude of ways with a broad range of potential impacts. Pertinent in the certification realm is the communication function, often in the context of a broader marketing and public relations strategy. Communications that imply fact present risks of violating regulation or misleading consumers. Establishing evidence and rationale for making fact-based claims is vital insurance against these threats.

There are two primary means by which false or misleading claims are challenged: regulation and civil litigation. Each presents unique considerations and requirements in the risk management context.

III. FTC Green Guides and Litigation Risk

Federal Trade Commission has promulgated guidance for making environmental claims in the Guides for the Use of Environmental Marketing Claims, more commonly referred to as the “Green Guides” 16 C.F.R. pt. 260 (2023). These Guides do not, in themselves, have the force of law, but the FTC can take administrative action under § 5 of the Federal Trade Commission Act, 15 U.S.C. § 45 (2023) if they can show that the claim was unfair or deceptive. Specifically:

§ 260.7 Compostable Claims.

(a) It is deceptive to misrepresent, directly or by implication, that a product or package is compostable.

(b) A marketer claiming that an item is compostable should have competent and reliable scientific evidence that all the materials in the item will break down into, or otherwise become part of, usable compost (e.g., soil-conditioning material, mulch) in a safe and timely manner (i.e., in approximately the same time as the materials with which it is composted) in an appropriate composting facility, or in a home compost pile or device.

(c) A marketer should clearly and prominently qualify compostable claims to the extent necessary to avoid deception if:

(1) The item cannot be composted safely or in a timely manner in a home compost pile or device; or

(2) The claim misleads reasonable consumers about the environmental benefit provided when the item is disposed of in a landfill.

(d) To avoid deception about the limited availability of municipal or institutional composting facilities, a marketer should clearly and prominently qualify compostable claims if such facilities are not available to a substantial majority of consumers or communities where the item is sold.

As a threshold matter, certification confirms that claims of compostability are not intended to mislead the consumer (§260.7(a)). This section focuses on the intent of the presentation of a product rather than on specific scientific evidence. The act of seeking out external confirmation of a claim is itself evidence of the lack of intent to mislead.

Section 260.7(b) requires documentation to show the marketing claims are based on scientific evidence. This must include

competent and reliable scientific evidence that all the materials in the item will break down into, or otherwise become part of, usable compost (e.g., soil-conditioning material, mulch) in a safe and timely manner (i.e., in approximately the same time as the materials with which it is composted) in an appropriate composting facility, or in a home compost pile or device.

16 C.F.R. § 260.7(b) (2023)

This definition presents significant ambiguities and potential interpretational conflicts. What qualifies as “competent and reliable scientific evidence”? Is laboratory testing sufficient to show that the material breaks down “in an appropriate composting facility, or in a home compost pile or device”? What does “approximately the same time as the materials with which it is composted” mean? Does “break down into, or otherwise become part of, usable compost” mean 100% of the product does so, or are microscopic remnants acceptable? These ambiguities suggest that manufacturers should consult their own legal counsel before making compostability or any environmental claim.

The term “compostable” itself is subject to many interpretations. Definitions have been codified into law, are contained in the Green Guides, and courts may use the consumer’s reasonable belief about what it means to be “compostable.” Therefore, it behooves the manufacturer to use the most conservative definition possible to ensure they are meeting the highest standards.

“(B)reak down into, or otherwise become part of, usable compost” is being interpreted to include the microscopic level. This is the precise basis on which litigation has been undertaken relative to PFAS in some jurisdictions. Many lawsuits are basing their causes of action upon a detailed and strict reading of the Green Guides and other statutes. They rely on state consumer protection laws to bring the lawsuit and cite to the Green Guides, as well as state law, as the measure of a deceptive claim.

Consumer protection laws, present in virtually every state, are designed to provide consumers with recourse and remedy when a business acts in an unfair or deceptive manner. When regulations do not exist or are not enforced, consumer protection laws are available to provide a means of compensating for harm but also as a means to stop bad actors in the marketplace. When breaking the law becomes more costly than following the law, bad actors have financial motivation to change their ways.

Defending against claims of unfair or deceptive practices, like the above, requires more than a bare statement that there is no ill intent, and that the manufacturer’s representatives subjectively believe the product is compostable. It requires evidence of compliance with the applicable definition as well as evidence demonstrating that the manufacturer is complying with industry-accepted standards.

IV. Benefits of Third-Party Certification

Even well-intentioned organizations face documentation gaps and communication breakdowns. Certification provides a structured process to confirm that documentation is complete and externally communicable.

Lack of documentation to support a claim or position can arise from a failure of the product to achieve one or more elements necessary to achieve certification. In a field in which others have met all criteria, finding an area of weakness can provide a manufacturer with an opportunity to focus remedial measures and take corrective action to ensure the product is not falling behind competitors.

Most importantly in the compostability realm, certification provides confirmation that the product has met widely accepted standards for safety and efficacy. This function is increasingly important as state laws evolve. Some states require specific attributes to label a product “compostable” and have implemented enforcement schemes. As part of their requirements, some states require third-party certification for any product claiming compostability (see Wash. Rev. Code § 70A.455.090 (2023)). In the consumer protection context, certification is an important affirmation in an environment in which consumers are increasingly aware of the health threats of unseen particles such as PFAS and microplastics.

Third-party certification is not uniform, however. There are differences in interpretation of the foundational standards such as ASTM. The perspective from which the certifier views and uses these standards is important to understand from a risk management perspective. While differing
interpretations may be valid and expected, choosing the awareness of these differences can maximize the efficacy of certification as a risk management strategy.

From the perspective of the compost manufacturer, CMA interprets the standards conservatively. We are committed to supporting the industry to achieve the highest standards possible and encouraging continual improvement of these standards over time. From our perspective, to do any less risks future repercussions in the form of litigation over contamination and unforeseen consequences of adopting a “good enough” attitude.

V. Limits and Evaluation of Certification

In the US, the ASTM standards are widely used as the basis for certification. ASTM D6400, D6868 and D8410 address baseline criteria for compostability. Laboratory standards are vital to ensure products are not contaminating the compost with toxic chemicals and will not affect the beneficial use of the product. However, not every aspect of compostability in the broader context of consumers and composting facilities is captured by these laboratory standards. The perspectives of consumers and of compost facility operators should be considered when assessing risk.
At CMA, products must meet the ASTM standards but must also pass field disintegration testing to achieve certification. To many composters, this is the criteria by which they consider an item compostable in their facility. This is the fundamental reason CMA came into being – composters wanted a standard that met their practical criteria for acceptance.

Ask a consumer what they think makes something compostable and they are unlikely to mention ASTM standards. There may be variance among consumers, but there will likely be commonalities that encompass the ability of the product to turn into compost and to do so safely. Considering the basis of many state laws and consumer protection actions is squarely viewed from the perspective of the consumer, manufacturers ignore the consumer perspective at their peril. Accepting laboratory standards as the sole basis on which to claim compostability may, in the end, be insufficient. Laboratory standards should be the starting point from a risk management perspective.

Where there are external, consensus-based standards, like ASTM, there is a predictable path to and parameters for certification. However, certification can go beyond the external standards. There is currently no consensus-based standard for compostability for disintegration of the product in a commercial compost setting. CMA has developed criteria, in conjunction with compost manufacturers, that are applied to CMA certified products.

There is no specific, generally accepted standard for testing for PFAS. Direct testing for PFAS is prohibitively expensive and impractical. Therefore, total fluorine testing is used as a proxy for PFAS testing. While certifiers now require total fluorine testing to achieve certification, there is no consensus-based standard method for this testing. Varied methods can result in varied results, a dangerous situation when managing risk. As a result, CMA requires total fluorine testing by a specific preparation method that has been developed and vetted by numerous labs and experts.

The presence of PFAS in compostable products is the basis of significant litigation (see above). This is an area in which using the best available, evidence-based method is vital. Litigation requires (expensive) expert testimony and evidence to support one’s position. Risk management should include an evaluation of the evidence at your disposal in a litigation context.

VI. The Disclaimer

Regardless of the certification scheme, the product manufacturer remains solely responsible for evaluating their products, claims and risks. Certification can be evidence of due diligence and meeting industry standards but does not guarantee or warrant that the product complies with any particular law or legal standard. The product manufacturer must use certification as one part of an overall risk mitigation strategy.

VII. Conclusion

In an environment of increasing scrutiny and low consumer and composter trust, evaluating and mitigating risk is vital to avoid regulatory enforcement and litigation. Should a manufacturer find itself in such a position, solid evidence will go a long way to supporting the company’s argument. Certification, with an eye on evaluating what the certification itself can provide, can be compelling evidence of the company’s commitment to achieving the highest standards.

We are sharing the results with you since we feel it is important to acknowledge your contribution by reporting back. CMA distributed this survey to simply ask the questions. Some respondents assumed the survey meant that we were going to announce a change imminently. We are not. This was strictly an information-gathering effort. We are committed to working with our customers and composters to make the system work. Asking questions is an important way we can understand stakeholders’ challenges, views, and opinions.

The survey was, in part, prompted by repeated questions and pressures to make logo use mandatory. The argument has been made that, if CMA certified products are not marked, the consumer has no way of knowing what is accepted at CMA network facilities. This is a challenge that we continue to work on. So far, we have found no easy answer that will satisfy everyone. We hope that the “greater mind” of the Future Search project will help us see new answers to challenges such as this.

To understand our context, CMA is not a non-profit organization. We do not have membership fees, nor do we receive any grants or government funding. We are a technical services company that must secure funding for all the work that we do. Our field-testing fees cover just that – field testing. Our field crew travels across the US to place and retrieve tests. We pay the testing facilities for their time. We do all the preparation of samples and sample tracking, and all the results reporting and follow up. We review all the ASTM laboratory reports and work with customers to support them in getting the appropriate lab testing and reports. This requires hours of staff time for every customer on top of the expenses for performing the field tests.

Our logo license program supports all the other work that we do: legislative advocacy, answering questions from consumers, product manufacturers and facilities, providing support and curated lists for compost facilities and cities, educational efforts such as speaking engagements, and more.

The survey was distributed to a broad range of people with whom CMA works. This included composters, product manufacturers, consultants, distributors and others.

Question 1: Do you have a Logo Use License with CMA?
As a threshold, 32.79% of respondents have a current license for use of the CMA name and logo.

Question 2: If you have a Logo License, do you use the CMA logo on the product itself (versus on the packaging)?

Of those with a license, 23.06% use the logo directly on their products.

Question 3: If you do not have a logo license with CMA, what factors affect your decision? Interestingly, the largest segment of answers on Questions 3 through 5 was “Other”.

Many of the “Other” comments mentioned the respondent was not yet CMA certified. Respondents also noted the difficulty embossing artwork, that they do not control the finished packaging and competing requirements. Cost was cited by 22.92%, and 10.42% already have too much on their packaging. 6.25% of respondents do not see the purpose.

Question 4: To facilitate recognition of CMA certified products by consumers and composters, CMA has been asked to make the use of the CMA Logo mandatory for all certified products. How do you view mandatory use of the CMA logo for certified products?

Overall, 17.5% of respondents would support a change and would be willing to pay a license fee. Thirty percent would support a change but would not be willing to pay a license fees. Between these two answers, 47.5% would support a change.

Of those who would not support, 35% would not support and 5% would not support and would discontinue business with CMA. “Would not support” received a total of 40% of the responses overall.

Question 5: What fee range would you consider reasonable as an annual CMA Logo License fee?

Respondents felt a logo use fee of less than $1,000 (31.58%) or a fee based on number of certified SKUs (21.05%) was reasonable. However, “Other” once again received the most responses at 38.6%. About half of the “other” comments said the right to use the logo should be automatic once the product is certified. Otherwise, many of the comments reiterated answers and comments to previous questions.

Question 6: Would you be willing to pay more for testing and evaluation if you automatically received license to use the CMA logo at certification?

Respondents clearly indicated (55%) that they would not be willing to pay more for testing if logo use was automatically included upon certification. Paying more for testing in this scenario was acceptable to 23.21% and 21.43% responded “Other”. “Other” comments addressed specifics on which the answer would depend. Factors noted were additional cost, how it would be structured and if a discount would apply if the product did not achieve certification.

CMA has historically resisted making logo use mandatory and folding the cost into testing fees. Many products do not pass and requiring those customers to pay for a logo they will not be able to use is, to us, unfair. This is one of the reasons we have maintained logo licensing as a separate fee.

If you have any additional feedback on these results , please feel free to reach out to me
at janet@composterapproved.com.

Fortunately, there are several ways each of us can reduce our impact (and reduce those costs) around the holiday season, and that collective spending message can make a big difference. Here are some simple, easy-to-implement ideas to enjoy the holiday season while considering the larger impacts, both personally and environmentally.

Ways to Waste Less (and save more)

Food Waste Tips

1. Make your own stock-All those delicious holiday meals mean veggie scraps and bones galore. Save them in your freezer and use them to make a delicious, nutritious, homemade stock! I typically have two 1-gallon bags in my freezer at all times- one for veggies, and one for bones (both raw or cooked will work). When they’re full, throw them all together into a large pot, fill with water, and let it simmer for 2 – 12 hours. Strain out and compost the remains, and presto! You’ve just gotten multiple delicious meals out of scraps that would have otherwise been wasted.
2. Leftovers plan- Creating a plan for your leftovers is a great way to ensure the food you put so much effort into doesn’t go wasted after. You can repurpose them into new meals, plan a menu for the days following, or freeze them accordingly!
3. Less meat, more plants- Eating less meat is a simple and effective way to reduce our carbon footprint. Plus, there are some incredibly delicious meals that are so tasty, you won’t spare a second glance for the roast turkey.
4. Local sourcing- Sourcing your ingredients from local farmers is one of the most powerful ways to vote with your dollar. Even though it tends to be more expensive, the taste of your final meal will be worth it! If you’re still concerned about the cost, then sourcing your protein from a local purveyor is the way to go. If you do not have a winter farmer’s market in your area, then try visiting a nearby grocery cooperative for the best quality meat products in your area.

General Waste Reduction Ideas

1. Reuseable gift wrapping- Finding ways to reduce, re-use, and repurpose gift wrapping is a great way to make less waste and spend less on all that gift wrapping. Plus, many folks don’t realize that conventional wrapping paper is not suitable for composting or recycling.
   1. Furoshiki is a cloth wrapping style that originated in Japan, perfect for the minimalist. In addition to being reusable, you can use almost anything already on hand- scarves, fabric, etc.
   1. Re-useable gift boxes and bows are a great option if you love the look of all those gifts under the tree! It will make the chore of present wrapping less painstaking and save you some extra dollars on tape too.
   1. Reusing old kraft paper or even newspaper is another good option, as it provides single-use wrapping with another use. Plus, with the right ribbons or accoutrements, it can look quite classy!
2. Décor- Decorations around the holidays are a key part of the festive season. And with some thought, they can be done well and with very little impact. Say goodbye to the tinsel, or items made from plastic. Instead, opt for natural.
   1. Foraged conifer sprigs, holly, pinecones, and the sort are not only great for making the house smell fresh- they’re also the easiest on your pocketbook! Just make sure to pick your foraging location with care- if it’s private land, make sure you have permission beforehand- and be conscious of your impact on the local environment.
   1. Handmade ornaments are beautiful when made from natural materials. They also make great gifts as a bonus! Your friends and family will be touched by the effort and care. It’s also a great way to get creative, as they can be whatever you want them to be! I made mine this year from dried orange slices and holly leaves, and they will look beautiful for years to come.
3. Re-usable advent calendars can be an exciting way to count down the days and create fond memories for the little ones.

Gift Giving

1. DIY gifts are my personal favorite type to give and to receive. The thought and care that goes into them are never wasted on the receiver. Plus, these can be anything that fit your skills or interest. Here are some ideas to get your creative mind going:
   1. Handmade ornaments like those mentioned above
   1. Artwork or Crafted goods like a painting, a scarf, or even a framed photograph
   1. Recipes you love and the dry-ingredients or spices to go with it
   1. Plant starts like an ivy cutting or your favorite herb
2. Experiences over things has been a popular practice in my family growing up. They are both exciting to receive and can make some of the best memories afterward. They can also be any size to fit your budget. Whether it’s dinner at that restaurant you’ve always wanted to try, or a family vacation, your loved ones are sure to appreciate the gift of quality time together.
3. Shop locallyat small businesses to support your local community and find some one-of-a-kind treasures.
4. Lightly Used items for re-sale are a great option for both the planet and the pocketbook. Craigslist or Facebook Marketplace provide platforms to find quality bigger gift items like an espresso maker, a nice piece of furniture, or a new tv!
5. Thoughtful consumables are another way to support small businesses and give a thoughtful gift. Coffee, chocolate, or tea can all be sourced fair trade and from small businesses, for instance.
6. Conservation gifts can be a thoughtful gift for those who say they “don’t want anything.” They also have an immediate positive impact. Examples include purchasing an acre of rainforest, or sponsoring a child in hunger.
7. Gifts to encourage less waste year-roundcan come in all shapes and sizes, such as:
   1. Bamboo cutlery kit for traveling or camping
   1. Re-usable alternatives to single use-plastic items like saran wrap or sandwich bags
   1. Home or backyard composter for those who love to garden
   1. Home plant growing systems for herbs and fresh greens
   1. Soda-stream or similar device to make your own soda at home

The holidays are a time to rejoice with loved ones. Celebrate, eat well, embrace the season to your heart’s content! However, there’s no need for over-indulging practices that will have a lasting impact. Whether you find one, or many good tips for your lifestyle here, I hope you find inspiration for your waste-less winter tidings. 

An update to CMA’s certification program is now live. CMA has introduced a track for materials and
components to now be eligible for acceptance and certification alongside their finished product peers.
Historically, CMA has only certified finished products related to food service or yard waste applications.
As product design evolves, packaging has become more complex in some respects. To provide some
assurance that the materials or components of a larger item are already vetted by CMA, we will now
certify or accept (as applicable) these parts on their own. This provides material and component
manufacturers with evidence that their parts can be used in a more complex compostable product with
confidence that they will disintegrate in industrial compost processes.

Materials and components will be evaluated in the same way in which finished products are evaluated:
Do they meet the applicable ASTM laboratory requirements? Do they meet the applicable field test
requirement? Do they demonstrate total fluorine <100 ppm? If applicable, do they comply with FDA
regulations for food contact materials, 21CFR 170-199 and/or FCN, if applicable, and good
manufacturing practices 21 CFR 174.5? If all requirements are met, an acceptance or certification letter
will be issued. To qualify, material or components must still be intended for food or yard applications. 
CMA will also issue a specification sheet that identifies the specific parameters of the
material/component’s acceptance/certification. These will include attributes such as: manufacturer,
thickness, density, grade(s), configurations, compost technology, etc. This specification sheet can be
shared with customers who are interested to know what configuration(s) have been vetted by CMA.

Any finished product using the certified component or material must be field tested in its final form and
must be tested to the required specifications and laboratory tests as outlined above to be certified in its
own rite. For single-layer materials/components, they will be certified at the maximum thickness that
passed field testing. Any thinner construction would also be certified. For a multi-layer
material/component, they will be certified for the exact layer configuration that passed field testing. Any
construction with a layer removed or utilizing thinner layer(s) would also be certified. Products that are
constituently identical and the same configuration as the accepted material/component may be line
item accepted (LIA) at CMA’s discretion. This does not apply to any product that modifies the properties
of the component (e.g., crystallization).

For questions or additional information about CMA’s material and component acceptance and
certification program, please contact Kari Rolnick at kari.rolnick@composterapproved.com. If you would
like to arrange a submission, please contact Diana Lloyd-Jones at
diana.lloydjones@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

Over time, some of CMA’s interpretations have diverged from other certifiers. (See post “CMA’s Position on ASTM D6868 and D8410”, May 10, 2023). As industrial compostability requirements and laws change and as we learn more about the process and materials, each certifier revises their requirements. CMA does not have input with other certifiers nor do other certifiers communicate their requirement changes to CMA.  European organizations certify based on EN13432 which treats coated and multilayer materials and products differently than ASTM D6868. CMA evaluates acceptance standards with the intent of minimizing contamination of compost, including contamination by microplastics. Additionally, CMA requires a specific protocol for total fluorine testing and that the test be performed at a CMA-approved lab.  (See post “PFAS:  The Importance of Testing Methods”, August 26, 2022.)

Considering these potential variations, effective October01, 2023, CMA will require new sample submissions to provide complete ASTM reports for all evaluated products.  We will no longer accept other certifications such as BPI and TUV in lieu of the laboratory reports. 

Any products submitted for testing and certification prior to October01, 2023, may still submit other certifications in lieu of full lab reports.  However, upon recertification, we will ask for the complete laboratory reports rather than updated certifications.  If you have any questions regarding this change, please contact me at janet@composterapproved.com. 

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.