FAQ

FAQs for Businesses Manufacturing/Selling Biobased Products

Advertising, Labeling and Marketing Claims

Q:	What is the difference between “neutral carbon”, “renewable carbon”, “fossil carbon”, and “green carbon”?
A:	Neutral carbon, renewable carbon, and green carbon all refer to carbon from biomass. They are also synonymous to biocarbon or biomass carbon. Fossil carbon, on the other hand, refers to carbon from fossil sources. Thus, carbon from burning plants would be called neutral carbon whereas carbon from burning coal or petroleum coke would be called fossil carbon.

Q:	Do biobased products earn points related to LEED certification?
A:	Biobased products may help to achieve Materials and Resources Credits 6 (MR 6) as well as additional credit categories. See article recently authored by an Iowa State University student on the BioPreferred.gov website http://www.biopreferred.gov/NewsRoom.aspx.

Does the certified percentage of biobased content as shown on the label always apply to the entire product contents?

What is the impact of biobased products on the environment? Are biobased products “better” for the environment?

How should I relate a product that displays the USDA certified biobased product label to other claims on the product like “organic”, “natural”, “biodegradable”, “compostable” or “renewable”?

Manufacturers are responsible for environmental marketing claims such as these so they are specific, qualified and substantiated and do not mislead or confuse the consumer or product user by themselves or in concert with the display of the USDA certified biobased product label. Both the US Federal Trade Commission (FTC) and the USDA BioPreferred program work together to help guide manufacturers and labelers in this area. The environmental marketing claims of organic, natural, biodegradable, compostable and renewable are among those likely to be found on a biobased product. In each case, the claim is made by the manufacturer, not the USDA. The USDA certified biobased product label verifies biobased content only, that is total “organic carbon” as defined by the scientific standard. The USDA certified biobased product label does not mean a product is organic, natural, biodegradable, compostable, renewable or implies any other product attribute.

“Organic”: Part or all of a biobased product’s content may be organically grown, but the USDA voluntary labeling program does not require it to be. Food products that are organic may be voluntarily certified by the USDA National Organic Program (Kathy, insert link here as appropriate), which has a different label, or by various other organizations.

“Biodegradable”: Product biodegradability is not a prerequisite for the voluntary labeling program. Some USDA certified biobased products are designed to be disposed of after a single use and/or used in environmentally sensitive applications.

“Natural”: Natural may be used in numerous contexts and may convey different meanings depending on that context. Several Federal agencies including the US Federal Trade Commission (FTC), the US Food and Drug Administration (FDA) and the USDA (which defines “natural” meat and poultry as “a product containing no artificial ingredient or added color” and which “is only minimally processed”), acknowledge that natural may be an appropriate descriptor in some contexts.

“Compostable”: Composting is one environment under which biodegradability occurs. In a composting environment, the explanation of the environment, the degree of microbial utilization (biodegradation), and the time frame within which it occurs are specified through established standards. ‘Compostable’’ generally means a product is capable of biological decomposition under controlled aerobic conditions, such as found in a compost pile or compost bin, by microorganisms or soil invertebrates. However, some products may not fully degrade (i.e., biodegrade) in a ‘‘backyard’’ compost pile versus an industrial facility. Most importantly, the limited availability of industrial compost facilities is a factor in making such a claim.

“Renewable”; “Made With Renewable Materials”: Biobased content may be renewable, i.e., contain renewable carbon derived from non-fossil sources, but there could be other ingredients in the product that are not. Organic carbon content is likely to be renewable and derived from plants or animals that have lived within the last 10 years. As with all advertising claims, any claim of renewable or made with renewable materials needs context, definition, qualification and substantiation to meet the guidelines set by the US Federal Trade Commission

Applying for and Using the Certification Label

Biobased Content

Why was the minimum content required for the USDA certified biobased product label set at 25%?

Q:	Is anything excluded from the calculation of biobased content?
A:	Yes, water and inorganic carbon are excluded since the testing standard, ASTM D6866, by definition only takes into account total organic carbon. Water does not contain carbon and some biobased products contain water in significant quantities. Some biobased products also contain inorganic carbon (carbonates) in significant quantities.

How is the biobased content of a product determined?

In meeting the definition of "biobased" in the 2002 Farm Bill, how does biobased content testing distinguish various types of carbon?

Q:	How is "inorganic carbon" (carbonates) considered in the ASTM D6866 standard?
A:	need answer

When applying for the USDA certified biobased label, is it required that the agricultural raw materials be grown in the U.S.?

Q:	How can we find out if the raw materials in our product meet the definition of biobased?
A:	The staff at Iowa State University is available to help you with this issue. Contact them at USDABioInfo@iastate.edu or 1-877-251-6522.

Q:	Are intermediate materials such as a bioplastic resin eligible for the voluntary labeling program?
A:	Yes, you can apply for the label for an intermediate material. Since there are no established product categories at this time for intermediates, the minimum biobased content would be 25%.

Can you provide an example of carbon content in PLA vs. PET?

Costs

Q:	Is there a cost to apply for the USDA certified biobased product label?
A:	At this time (2011), there is no cost for manufacturers or distributors to participate in the USDA BioPreferred program, certification, labeling or application process. However, businesses will be responsible for the cost of having the product tested for minimum biobased carbon content. Product testing is completed using the ASTM D6866 standard.

Q:	Can you give a ballpark figure on the cost of verifying the biobased carbon content for a single product?
A:	The testing cost is determined by the laboratory and the price may vary over time. As of June 2011, you can expect to pay approximately $600 for biobased content testing/verification. Hopefully, the volume of testing the USDA BioPreferred program generates will spur competition resulting in lower costs among the approved laboratories.

Is any USDA or other financial or grant assistance available to help defray the costs of testing?

Federal Purchasing Preference and BioPreferred Catalog Listing

Is third party verification of biobased content required to be in the BioPreferred (Federal purchasing preference) catalog?

Q:	Will products that fail the labeling application still be listed in the BioPreferred catalog?
A:	No.

How does the BioPreferred program's designation process work?

Q:	When will proposed rules be available for the future rounds?
A:	There is no set timeline for posting proposed rules. Rules for each item designation and round will only be created and posted after a sufficient amount of information has been collected on products within each item.

Q:	How do manufacturers/vendors make Federal agencies aware of the qualified products they have to offer?
A:	One method of letting Federal agencies and their contractors know about their qualified biobased products is to list them in the BioPreferred catalog. There are a number of other methods for locating biobased products. Research other Federal websites including GSA Advantage! and DoD Emall.

Are biobased products competitive in terms of cost and performance?

Program Background

Q:	What is the purpose of the USDA certified biobased product label?
A:	The USDA certified biobased product label is designed to harness the powers of certification and the marketplace to help purchasers and users identify products with biobased content and to assure them of the accuracy of this content.

What is the BioPreferred program and where did it originate?

Congress mandated the BioPreferred program to promote the increased purchase and use of biobased products that provide opportunities to boost domestic demand for renewable commodities and to create jobs and investment income. Section 9002 of the Farm Security and Rural Investment Act of 2002 (generally referred to as the "2002 Farm Bill") requires USDA to develop and implement a biobased markets program designed to increase the purchase and use of biobased products.

To meet the requirements of the 2002 Farm Bill, USDA established the BioPreferred program. USDA is continually determining categories of biobased products for designation for Federal procurement preference. Minimum biobased content has been established for each category designated for Federal procurement.

In addition, Section 9002 of the 2002 Farm Bill also requires that USDA establish a voluntary labeling program authorizing producers of biobased products to use a “USDA Certified Biobased Product” label. The USDA certified biobased product label became operational in February 2011.

The Food Conservation and Energy Act of 2008 ("2008 Farm Bill") reinforces the earlier legislation establishing the BioPreferred program In addition, it establishes a process for determining eligibility criteria for biobased intermediate ingredients and feedstock for Federal agency procurement; and, permits the labeling of intermediate ingredients, feedstock, and complex products.

In addition to the legislation, there are two Executive Orders (E.O.) reinforcing this legislation. Both the 2007 E.O. "13423 Strengthening Federal Environmental, Energy, and Transportation Management," and the 2009 E.O. 13514, “Federal Leadership in Environmental, Energy, and Economic Performance,” require Federal agencies to purchase biobased products.

Q:	What does the word “BioPreferred” mean?
A:	BioPreferred is the trademarked name of the USDA program designed to help market biobased products to Federal agencies that are required by law to give preference to the purchase of biobased products. It is now the name of the overall program, including both the Federal purchasing preference program and the voluntary (USDA certified biobased product) labeling program.

What is a“biobased” product?

Is a life-cycle assessment (LCA) required for the voluntary labeling program?

What is considered to be a “Mature Market” product?

Can pre-1972 products that have had significant changes made to them be applicable. For example paper products that now use new coatings or are created using modified processes?

Testing and Auditing

FAQs for Consumers About Biobased Products

Advertising, Labeling and Marketing Claims

Q:	What is the difference between “neutral carbon”, “renewable carbon”, “fossil carbon”, and “green carbon”?
A:	Neutral carbon, renewable carbon, and green carbon all refer to carbon from biomass. They are also synonymous to biocarbon or biomass carbon. Fossil carbon, on the other hand, refers to carbon from fossil sources. Thus, carbon from burning plants would be called neutral carbon whereas carbon from burning coal or petroleum coke would be called fossil carbon.

Does the certified percentage of biobased content as shown on the label always apply to the entire product contents?

Are biobased products “safer” than non-biobased products for me and my family?

What is the impact of biobased products on the environment? Are biobased products “better” for the environment?

Q:	Does a higher percentage of biobased content mean a product is “better”?
A:	Biobased content percentages do not indicate superior performance, safety or environmental impact.

Are products that display the USDA certified biobased product label independently tested for biobased content?

Have products that display the USDA certified biobased product label been made with biotechnology or contain “GMO’s”?

Biobased Content

Why was the minimum content required for the USDA certified biobased product label set at 25%?

Q:	Is anything excluded from the calculation of biobased content?
A:	Yes, water and inorganic carbon are excluded since the testing standard, ASTM D6866, by definition only takes into account total organic carbon. Water does not contain carbon and some biobased products contain water in significant quantities. Some biobased products also contain inorganic carbon (carbonates) in significant quantities.

How is the biobased content of a product determined?

How can we find out if the raw materials in our product meet the definition of biobased?

Q:	Are intermediate materials such as a bioplastic resin eligible for the voluntary labeling program?
A:	need answer

Q:	Can you provide an example of carbon content in PLA vs. PET?
A:	need answer

When applying for the USDA certified biobased label, is it required that the (agricultural) raw materials be grown in the U.S.?

Federal Purchasing Preference and BioPreferred Catalog Listing

Program Background

Q:	What is the purpose of the USDA certified biobased product label?
A:	The USDA certified biobased product label is designed to harness the powers of certification and the marketplace to help purchasers and users identify products with biobased content and to assure them of the accuracy of this content.

What is the BioPreferred program and where did it originate?

Q:	What does the word “BioPreferred” mean?
A:	BioPreferred is the trademarked name of the USDA program designed to help market biobased products to Federal agencies that are required by law to give preference to the purchase of biobased products. It is now the name of the overall program, including both the Federal purchasing preference program and the voluntary (USDA certified biobased product) labeling program.

What is a“biobased” product?

Testing and Auditing

FAQs for the BioPreferred Program - Federal Procurement Preference Part

Biobased Content

Q:	How is the biobased content of a product determined?
A:	ASTM D6866 "Standard Test Methods for Determining the Biobased Content of Solid, Liquid, and Gaseous Samples Using Radiocarbon Analysis" is a standardized analytical method, using radiocarbon analysis techniques. It is used to determine the biobased content of a product or package. ASTM D6866 compares the renewable/biological carbon to total organic carbon within solids, liquids, and gases.

In meeting the definition of "biobased" in the 2002 Farm Bill, how does biobased content testing distinguish various types of carbon (inorganic and organic)?

Does the BioPreferred program require that the (agricultural) raw materials be grown in the U.S.?

Are intermediate materials such as a bioplastic resin eligible for the Federal Procurement Preference and the voluntary labeling program?

Federal Purchasing Preference and BioPreferred Catalog Listing

Q:	Which Federal agencies are required to participate in this program?
A:	All Federal agencies including the Department of Defense and Federal agency contractors must give preference to biobased products within categories that have been designated by regulation: where the purchase price of the product exceeds $10,000; or, where the quantity of such items (or of functionally equivalent items) purchased during the preceding fiscal year cost a total of $10,000 or more.

How does the BioPreferred program's designation process work?

Q:	Which biobased product categories are currently required for purchase by Federal agencies and Federal contractors?
A:	All required biobased designated categories can be found here: http://www.biopreferred.gov/ProposedAndFinalItemDesignation.aspx

Q:	How do manufacturers/vendors make Federal agencies aware of the qualified products they have to offer?
A:	One method of letting Federal agencies and their contractors know about their qualified biobased products is to list them in the BioPreferred catalog. There are a number of other methods for locating biobased products. Research other Federal websites including GSA Advantage! and DoD Emall.

Is third party verification of biobased content required to be in the BioPreferred catalog?

Q:	When will proposed rules be available to designate additional product categories for a Federal Procurement Preference?
A:	There is no set timeline for posting proposed rules. Rules for each product category designation and round will only be created and posted after a sufficient amount of information has been collected on products within each category.

What is a BEES Analysis?

General Questions about Biobased Products

What is a“biobased” product?

What is considered to be a “mature market” product?

What is the impact of biobased products on the environment? Are biobased products “better” for the environment?

Q:	Does a higher percentage of biobased content mean a product is “better”?
A:	Biobased content percentages do not indicate superior performance, safety or environmental impact.

Are biobased products competitive in terms of cost and performance?

Are biobased products “safer” than non-biobased products?

Q:	Do biobased products earn points related to LEED certification?
A:	Biobased products may help to achieve Materials and Resources Credits 6 (MR 6) as well as additional credit categories. See article recently authored by an Iowa State University student on the BioPreferred.gov website here.

Q:	What is the difference between “neutral carbon”, “renewable carbon”, “fossil carbon”, and “green carbon”?
A:	Neutral carbon, renewable carbon, and green carbon all refer to carbon from biomass. They are also synonymous to biocarbon or biomass carbon. Fossil carbon, on the other hand, refers to carbon from fossil sources. Thus, carbon from burning plants would be called neutral carbon whereas carbon from burning coal or petroleum coke would be called fossil carbon.

Program Background

What is the BioPreferred program and where did it originate?

Q:	What does the word “BioPreferred” mean?
A:	BioPreferred is the trademarked name of the USDA program designed to help market biobased products to Federal agencies that are required by law to give preference to the purchase of biobased products. It is now the name of the overall program, including both the Federal purchasing preference program and the voluntary (USDA certified biobased product) labeling program.

The Voluntary Labeling Program

Q:	Who can apply for the USDA certified biobased product label?
A:	Manufacturers and distributors of biobased products, as well as those who incorporate these products into another product, may apply for the USDA certified biobased product label.

What are the requirements for qualifying for the USDA certified biobased product label?

Are products that display the USDA certified biobased product label independently tested for biobased content?

Q:	Where can I find additional information about the sampling, and testing required for the USDA voluntary biobased product certification and labeling program?
A:	The ASTM Operations Manual for Biobased Product Certification Program, Section 6, provides detailed requirements. Go to www.astm.org/certification, click on USDA Voluntary Biobased Product Labeling Program and look under “Program Documents.”

Does the certified percentage of biobased content as shown on the label always apply to the entire product contents?

How should I consider a product that displays the USDA certified biobased product label to other claims on the product like “organic”, “natural”, “biodegradable”, “compostable” or “renewable”?

Manufacturers are responsible for environmental marketing claims such as these so they are specific, qualified and substantiated and do not mislead or confuse the consumer or product user by themselves or in concert with the display of the USDA certified biobased product label. Both the US Federal Trade Commission (FTC) and the USDA BioPreferred program work together to help guide manufacturers and labelers in this area. The environmental marketing claims of organic, natural, biodegradable, compostable and renewable are among those likely to be found on a biobased product. In each case, the claim is made by the manufacturer, not the USDA. The USDA certified biobased product label verifies biobased content only, that is total “organic carbon” as defined by the scientific standard. The USDA certified biobased product label does not mean a product is organic, natural, biodegradable, compostable, renewable or implies any other product attribute.

“Organic”: Part or all of a biobased product’s content may be organically grown, but the USDA voluntary labeling program does not require it to be. Food products that are organic may be voluntarily certified by the USDA National Organic Program which has a different label, or by various other organizations.

“Biodegradable”: Product biodegradability is not a prerequisite for the voluntary labeling program. Some USDA certified biobased products are designed to be disposed of after a single use and/or used in environmentally sensitive applications.

“Natural”: Natural may be used in numerous contexts and may convey different meanings depending on that context. Several Federal agencies including the US Federal Trade Commission (FTC), the US Food and Drug Administration (FDA) and the USDA (which defines “natural” meat and poultry as “a product containing no artificial ingredient or added color” and which “is only minimally processed”), acknowledge that natural may be an appropriate descriptor in some contexts.

“Compostable”: Composting is one environment under which biodegradability occurs. In a composting environment, the explanation of the environment, the degree of microbial utilization (biodegradation), and the time frame within which it occurs are specified through established standards. ‘Compostable’’ generally means a product is capable of biological decomposition under controlled aerobic conditions, such as found in a compost pile or compost bin, by microorganisms or soil invertebrates. However, some products may not fully degrade (i.e., biodegrade) in a ‘‘backyard’’ compost pile versus an industrial facility. Most importantly, the limited availability of industrial compost facilities is a factor in making such a claim.

“Renewable”; “Made With Renewable Materials”: Biobased content may be renewable, i.e., contain renewable carbon derived from non-fossil sources, but there could be other ingredients in the product that are not. Organic carbon content is likely to be renewable and derived from plants or animals that have lived within the last 10 years. As with all advertising claims, any claim of renewable or made with renewable materials needs context, definition, qualification and substantiation to meet the guidelines set by the US Federal Trade Commission.

Have products that display the USDA certified biobased product label been made with biotechnology or contain “GMO’s”?

Q:	What is the auditing process for products or packages that obtain the USDA certified biobased label?
A:	USDA will routinely sample labeled products and packaging to ensure that these products and packaging contain the biobased content displayed on the label.

Glossary

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