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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.
Q:
Does the certified percentage of biobased content as shown on the label always apply to the entire product contents?
A:
Not for all products. Water and inorganic carbon are excluded in calculating the percentage 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 in significant quantities. Inorganic carbon sources are known interchangeably as carbonates or sedimentary rocks, which includes limestone, dolomite, siderite, and any other source of carbon originating from mineral precipitation. Where these materials are present in a USDA certified biobased product, the biobased percentage content will be overstated on the label.
For example, if the USDA certified biobased label indicates "70% biobased," 70% of the carbon in the product is from biological materials. A liquid detergent concentrate with 70% biobased content will have the same 70% biobased content if diluted with any amount of water since only carbon is represented in the result.
In these cases USDA Brand Guidelines and Graphic Standards require labeling the product in a manner that clearly qualifies the biobased percentage, so that the USDA label does not mislead the purchaser or user.
Q:
What is the impact of biobased products on the environment? Are biobased products “better” for the environment?
A:
They can be; however, while many of the biobased products on the market today may have a more benign effect on the environment, are biodegradable and have lower disposal and cleanup costs than the fossil petroleum based products they replace,
a USDA certified biobased label is not a guarantee or expression of environmental preferability or impact. There is an expectation that the increased use of biobased products will help reduce petroleum consumption by increasing the use of renewable resources, thus reducing the amount of new carbon released into the atmosphere, helping to better manage the carbon cycle, in turn reducing resultant adverse environmental and health impacts.
Q:
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”?
A:
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
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.
Q:
How do I apply for the label?
A:
Applicants are required to submit an online application to USDA.
Q:
If my product is certified and eligible for the label, are entities that use the certified product but sell, distribute or incorporate into a product under a different name, such as a private label, also eligible to use the certification label?
A:
Yes, as long as the actual product also meets the minimum content level. You will need to complete an application for the USDA certified biobased product label.
Q:
What are the requirements for qualifying for the USDA certified biobased product label?
A:
Biobased products already identified within a USDA “designated item category” under the Federal Procurement Preference portion of the BioPreferred program must meet the minimum biobased content of the product category. BioPreferred Product Categories. Products that do not fall under a “designated Item” must be minimum 25 percent biobased unless the label applicant applies for and receives an alternative minimum biobased content allowance. Mature market products, which are excluded from the Federal procurement preference program, are also excluded from displaying the USDA certified biobased product label. (See definition of mature market products).
Q:
If my product is designated for the Federal Procurement Purchasing program and meets the requirements for minimum biobased content for its category, and that category allows biobased content less than 25%, can I still get the certification label?
A:
Yes, biobased products already identified within existing product categories under the Federal procurement preference must meet the minimum biobased content of the category.
Q:
If my product is designated in the Federal Procurement Preference program, do I still have to apply for the certification label, or is it automatic?
A:
You still must apply for the USDA certified biobased product label.
Q:
If there is no biobased product category already established for my product, what do I do?
A:
For products for which there is no minimum biobased content already established, the minimum biobased content is 25%.
Q:
How long does the approval process take once I apply for the USDA certified biobased product label?
A:
The USDA BioPreferred program has an initial goal of a maximum of 60 days for an application to receive approval (or denial), provided the applicant provides laboratory testing samples in a timely manner. Over time, USDA BioPreferred hopes to shorten the process, still keeping it as efficient and as effective as possible. If the approval takes longer than 60 day, there is no penalty imposed on or additional paperwork required by the applicant.
Q:
Can you explain the process for applying for an alternative to a minimum biobased content for a product?
A:
As indicated in the Final Rule, published in the Federal Register, Voluntary Labeling Program for Biobased Products, "manufacturers, vendors, groups of manufacturers and/or vendors, and trade associations may propose an alternative applicable minimum biobased content for the product by developing, in consultation with USDA, and conducting an analysis to support the proposed alternative biobased content. If approved by USDA, the proposed alternative applicable minimum biobased content would become the applicable minimum biobased content for the product to be labeled."
USDA will utilize a process similar to the one for the development and designation of categories for the Federal preferred procurement process. USDA will need information on the biobased products in that category currently on the market including: companies currently producing the products, user applications, industry performance standards, environmental health and safety benefit claims, biobased contents of products fitting alternative minimums, and mature market determination. Support materials for currently designated categories may be found at http://www.biopreferred.gov/ProposedAndFinalRegulations.aspx
Q:
What formats of the USDA certified biobased label copy are acceptable for upload? jpg? pdf?
A:
At this time (2011), we offer PNG, JPG, and GIF file types with additional file options and resolutions coming soon.
Q:
What is the procedure for receiving new labels for updated product formulations?
A:
At this time (2011), we have not established a procedure for recertification, but will be working with our system developers to incorporate the new process. Recertification will likely build off of the standard application process in partnership with ASTM International.
Biobased Content
Q:
Why was the minimum content required for the USDA certified biobased product label set at 25%?
A:
USDA BioPreferred consulted with many stakeholders in determining this threshold. Stakeholders consulted by USDA in the decision making process included technical experts, industry, the environmental community, the Federal government and similar programs around the world. USDA BioPreferred also utilized its own experience and expertise. It was judged that the 25% level would not only harmonize with efforts of the international community and best reflect the consensus judgment, but was designed to spur consumer acceptance of the label. USDA BioPreferred believes the 25% level is not insignificant and threshold levels are likely to rise as industries mature.
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.
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.
It is important to note that the term "renewable," for testing purposes, refers to recent plant-based and animal-based materials. This scientific definition of "renewable" may or may not apply to a specific product when marketing the product. Therefore, ASTM D6866 should not be used to prove claims of the renewability of a product or package based on Federal Trade Commission Guidelines. See: http://www.ftc.gov/bcp/edu/microsites/energy/about_guides.shtml.
Also, ASTM D6866 quantifies only the biobased content relative to the product sample’s total organic content and does not consider inorganic carbon and other non-carbon containing substances. With products or packaging that contain inorganic carbons and other non-carbon containing substances, it is the responsibility of the "certification holder" to appropriately qualify the biobased content percentage on the product label. Please see the "USDA BioPreferred Brand Guidelines and Graphic Standards" for further detail here: http://www.biopreferred.gov/LabelGuidelines.aspx
Q:
In meeting the definition of "biobased" in the 2002 Farm Bill, how does biobased content testing distinguish various types of carbon?
A:
Biobased solids, liquids, and gasses contain Carbon 14 and are easily differentiated from other materials such as fossil sources (petroleum) that does not contain Carbon 14. In the testing process, the percentage of organic carbon from agricultural and other biological sources is calculated relative to all the organic carbon in the sample. For example, "70% biobased" indicates that 70% of the carbon in the product is from recent biological materials, and 30% is from fossil sources.
ASTM D6866 quantifies only the biobased content relative to the material’s total organic content and does not consider the inorganic carbon and other non-carbon containing substances present.
For products with inorganic carbon constituting more than 3% of the total carbon, the inorganic carbon is excluded from the biobased content calculation. When submitting product samples for testing, inform the laboratory if a product's inorganic component concentration is greater than 3% of the product formulation.
Q:
How is "inorganic carbon" (carbonates) considered in the ASTM D6866 standard?
A:
need answer
Q:
When applying for the USDA certified biobased label, is it required that the agricultural raw materials be grown in the U.S.?
A:
Consistent with U.S. trade agreements to which USDA as a Federal government agency must adhere, biobased products that contain raw materials derived from imported plants (or other qualifying materials) are acceptable for the USDA voluntary labeling program. Imported products have to meet the same minimum content, verification standards, testing, and program requirements as U.S. products. Imported products must also meet any Federal labeling laws that may apply, including where required, country of origin. Products that contain imported agricultural materials would not qualify under the USDA Federal Procurement Preference, however.
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%.
Q:
Can you provide an example of carbon content in PLA vs. PET?
A:
The analysis is relating total renewable organic CARBON to total organic CARBON. As such, the mass (weight) of a component is not directly represented in the result. The result only directly relates the amount of carbon in each component to all the carbon in the product. The chemical formula for PLA is C3H6O3 (40 % carbon). The chemical formula of PET is C10H8O4 (62.5% carbon). Since PET has 22.5% more carbon in it than PLA, equal weights of each in a formulation is going to produce a biobased result less than 50%. In other words, if a product contains only 2 carbon containing components, PLA and PET, and both are present in a proportion of 50%, the biobased content is less than 50% because the PET (fossil) has more carbon in it than the PLA (renewable).
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.
Q:
Is any USDA or other financial or grant assistance available to help defray the costs of testing?
A:
USDA does not have such assistance, but some states may already have or be in the process of developing assistance programs. Hopefully, the availability of the USDA certified biobased product label will help state and local governments, agricultural, trade, and other organizations realize the benefits of promoting biobased materials and generate such efforts, particularly for small business. As USDA becomes aware of such efforts, it will post appropriate links on this website.
Federal Purchasing Preference and BioPreferred Catalog Listing
Q:
Is third party verification of biobased content required to be in the BioPreferred (Federal purchasing preference) catalog?
A:
USDA does not require manufacturers to provide third party verification of biobased content in order to be listed in the catalog. The manufacturer must self certify that they meet the minimum biobased content set for their product’s category in order to be included in the catalog. However, a Federal agency considering the purchase of your product may require third party verification. Testing is required for a product to display the USDA certified biobased product label. The USDA BioPreferred catalog distinguishes labeled products.
Q:
Will products that fail the labeling application still be listed in the BioPreferred catalog?
A:
No.
Q:
How does the BioPreferred program's designation process work?
A:
On a continuous basis, USDA selects and prioritizes categories of biobased products for designation as "preferred" products for Federal purchasing. Several categories of biobased products are bundled into a "round." These "rounds" are incorporated into a draft Federal regulation and are published with a public comment period. After public comments are considered, a final regulation to designate a biobased product category is published in the Federal Register.
One year after the final regulation is published, Federal agencies and their contractors must give preference to "BioPreferred" products when making purchases within this product category.
The product categories and products in Rounds 1 through 6 are finalized and are eligible for preferred Federal purchasing. These product categories include 50 BioPreferred products categories. Additional rounds are in the planning stages
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.
Q:
Are biobased products competitive in terms of cost and performance?
A:
Many biobased products are cost competitive for the Federal purchaser, especially if one considers the entire life cycle cost of the product in terms of safety and environmental considerations, disposal, transportation, installation, etc. On the BioPreferred.gov website, under "Training Tools," there is a checklist for determining life-cycle costs of products. In terms of performance, categories of biobased products designated for the Federal procurement preference were determined by USDA to be comparable to their non-biobased counterparts.
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.
Q:
What is the BioPreferred program and where did it originate?
A:
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.
Q:
What is a“biobased” product?
A:
A biobased product is defined by the Farm Bills as a product that is determined by the Secretary of Agriculture to be a commercial or industrial product (other than food or feed) that is composed, in whole or in significant part, of biological products, including renewable domestic agricultural materials (including plant, animal and aquatic materials) forestry materials or intermediate materials or feedstock. Biobased products do not include motor vehicle fuels, heating oil or electricity produced from biomass. Also, since the program is designed to stimulate markets for new biobased products, "mature market" products are excluded by law from the program, but are covered by other programs. Mature market products are those biobased products that had significant national market penetration in 1972. Examples of mature market products include cotton shirts or towels, paper plates, and wood furniture.
Q:
Is a life-cycle assessment (LCA) required for the voluntary labeling program?
A:
No. There are two reasons for this. First, the purpose of the voluntary label is to verify the presence of biobased content, and to be explicit in just how much biobased content is incorporated into labeled products. The label is not meant to impart environmental attributes to biobased products; rather it points to biobased content—biological materials, including renewable agricultural materials (including plant, animal, and marine materials), forestry materials, or an intermediate ingredient or feedstock. Second, USDA believes it is cost prohibitive for manufacturers of biobased products -- many of whom are small, entrepreneurial firms —to perform such a life-cycle assessment on their products when USDA does not have a plan for utilizing those data at this time.
Q:
What is considered to be a “Mature Market” product?
A:
Mature market products are excluded from the Federal procurement preference program and from the voluntary labeling program. Mature market products are defined as those products that had a significant market penetration in 1972. Examples of mature market products include cotton shirts or towels, paper plates, and wood furniture. The staff at Iowa State University is available to help you with this definition. Contact Iowa State University at USDABioInfo@iastate.edu or 1-877-251-6522.
Q:
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?
A:
It depends upon the changes being made and how they will be adding to or increasing the potential markets for biobased materials. USDA will seek input from industry stakeholders to determine if allowances should be made. For example, a paper cup would be considered a mature market product. That same cup might be turned into a new product by adding a polymer coating or film made from non-biobased materials to help reduce moisture absorption, which may or may not be mature (waxed paper cups would be considered a mature market product). Finally, that coating or film might be replaced with a biobased material making a third product. In this example, the third product would likely be considered a new product.
Testing and Auditing
Q:
How are applications for the USDA certified biobased product label evaluated?
A:
USDA, and its cooperator, Iowa State University, will evaluate each complete application to determine if the product meets the voluntary labeling criteria. Explanations will accompany rejected applications. Rejected applicants may revise applications and resubmit for consideration.
Q:
Where and when should I get my product tested for biobased content?
A:
Once your USDA certified biobased product label application has been approved, you will be notified by USDA and directed to the ASTM website (www.astm.org/certification) where you will need to complete an ASTM Biobased Participant Agreement and select an accepted laboratory for testing.
Q:
Where can I get a list of approved testing laboratories?
A:
A list of approved laboratories is available from ASTM International at http://www.astm.org/certification/filtrexx40.cgi?cert_index.frm
Q:
Where can I find additional information about the sampling, test specimens, 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.”
Q:
If my product has been tested in order to qualify for the Federal Procurement Preference program, does it have to be tested again for the USDA certified biobased product label?
A:
In response to concerns submitted by program participants, USDA has elected to modify its position on acceptance of previously tested products for USDA certified biobased product label applications. Products tested between February 20, 2010 -- February 20, 2011 will be considered “Legacy Products” and will be able to apply for the USDA certified biobased product label. Applicants will be asked to complete a separate authorization form provided by USDA via email. USDA will then contact the lab for a copy of the test results that will be attached to the Label Application (results will NOT be certified by ASTM).
Q:
If I’ve already had my products tested with one of the approved laboratories, will this help expedite the process or reduce my costs?
A:
It may. USDA recognizes that some products registered with BioPreferred and completed testing with the BioPreferred program prior to the BioPreferred program Voluntary Labeling Initiative (February 2011) and allows a waiver of the requirement of re-testing for products tested for biobased content prior to the inception of the Voluntary Labeling Initiative only under limited circumstances when a company paid for and completed testing on a product from the dates of 02/20/2010-02/20/2011.
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.
Q:
Do you confirm that the carbon content percentage indicated on the label is the one directly from the lab analysis?
A:
Yes.
Q:
My ASTM D6866 result is 60% biocarbon content. Does this mean that 60% of the carbon atoms in my sample are from biomass sources or 60% of the sample (weight) was from biomass, or are these both the same thing?
A:
No. The ASTM D6866 result means that 60% of the carbon "in" the combusted mass was from renewable sources, NOT 60% "of" the combusted mass was renewable material.
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.
Q:
Does the certified percentage of biobased content as shown on the label always apply to the entire product contents?
A:
Not for all products. Water and inorganic carbon are excluded in calculating the percentage 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 in significant quantities. Inorganic carbon sources are known interchangeably as carbonates or sedimentary rocks, which includes limestone, dolomite, siderite, and any other source of carbon originating from mineral precipitation. Where these materials are present in a USDA certified biobased product, the biobased percentage content will be overstated on the label.
For example, if the USDA certified biobased label indicates "70% biobased," 70% of the carbon in the product is from biological materials. A liquid detergent concentrate with 70% biobased content will have the same 70% biobased content if diluted with any amount of water since only carbon is represented in the result.
In these cases USDA Brand Guidelines and Graphic Standards require labeling the product in a manner that clearly qualifies the biobased percentage, so that the USDA label does not mislead the purchaser or user.
Q:
Are biobased products “safer” than non-biobased products for me and my family?
A:
A USDA certified biobased label is not a guarantee or warranty of safety. The USDA BioPreferred program does not test or judge product safety. Read the label fully. Precautionary labeling for consumer safety for both products and packaging is highly regulated by Federal law. Look for signal words such as “CAUTION”, “WARNING, “DANGER” and “POISON”. Also, consumers may access the manufacturer’s material safety and data sheet (MSDS), also known as a product safety data sheet. An MSDS is a form required in the U.S. by the Occupational Safety and Health Administration (OSHA) and contains data regarding the properties of a particular substance, and may include instructions for the safe use and potential hazards associated with a particular material or product. An MSDS is not primarily intended for use by the consumer, focusing instead on the hazards of working with the material in an occupational setting and may state a substance’s risks, safety and effect on the environment. If in doubt, contact the manufacturer.
Q:
What is the impact of biobased products on the environment? Are biobased products “better” for the environment?
A:
They can be; however, while many of the biobased products on the market today may have a more benign effect on the environment, are biodegradable and have lower disposal and cleanup costs than the fossil petroleum based products they replace,
a USDA certified biobased label is not a guarantee or expression of environmental preferability or impact. There is an expectation that the increased use of biobased products will help reduce petroleum consumption by increasing the use of renewable resources, thus reducing the amount of new carbon released into the atmosphere, helping to better manage the carbon cycle, in turn reducing resultant adverse environmental and health impacts.
Q:
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”?
A:
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
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.
Q:
Are products that display the USDA certified biobased product label independently tested for biobased content?
A:
Yes, products are tested to verify the actual biobased content in the product, by mass (weight). The USDA, through a grant with, Iowa State University, examines products and test results performed by independent, third-party accredited testing laboratories which certify that test results conform to ASTM International standards. ASTM is an internationally recognized nonprofit standards setting organization. The USDA asked ASTM to develop a standard for determining biobased content. The standard uses a variation of highly sophisticated radiocarbon dating to assure the accurate measurement of a product’s biobased content. The standard is now cited in Federal law (7 CFR part 2902) and is internationally recognized.
Q:
Have products that display the USDA certified biobased product label been made with biotechnology or contain “GMO’s”?
A:
Only the product manufacturer can answer that question. The USDA certified biobased product testing program measures organic carbon content only. The program does not measure or analyze sources of or the presence or absence of any product ingredients. Essentially all food crops have been modified and bioengineering technology is only one of a number of technologies used to modify crops. The USDA certified biobased product label can not be applied to foods and therefore it is highly unlikely USDA certified biobased products contain any organisms, since most foods do not contain organisms (seeds and foods like yogurt that contain microorganisms are exceptions). Furthermore, the chemical transformation of biological material in the manufacture of biobased products results in the loss of any genetic information, so such information can not be present in the final product.
Biobased Content
Q:
Why was the minimum content required for the USDA certified biobased product label set at 25%?
A:
USDA BioPreferred consulted with many stakeholders in determining this threshold. Stakeholders consulted by USDA in the decision making process included technical experts, industry, the environmental community, the Federal government and similar programs around the world. USDA BioPreferred also utilized its own experience and expertise. It was judged that the 25% level would not only harmonize with efforts of the international community and best reflect the consensus judgment, but was designed to spur consumer acceptance of the label. USDA BioPreferred believes the 25% level is not insignificant and threshold levels are likely to rise as industries mature.
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.
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.
It is important to note that the term "renewable," for testing purposes, refers to recent plant-based and animal-based materials. This scientific definition of "renewable" may or may not apply to a specific product when marketing the product. Therefore, ASTM D6866 should not be used to prove claims of the renewability of a product or package based on Federal Trade Commission Guidelines. See: http://www.ftc.gov/bcp/edu/microsites/energy/about_guides.shtml.
Also, ASTM D6866 quantifies only the biobased content relative to the product sample’s total organic content and does not consider inorganic carbon and other non-carbon containing substances. With products or packaging that contain inorganic carbons and other non-carbon containing substances, it is the responsibility of the "certification holder" to appropriately qualify the biobased content percentage on the product label. Please see the "USDA BioPreferred Brand Guidelines and Graphic Standards" for further detail here: http://www.biopreferred.gov/LabelGuidelines.aspx
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%.
Q. Can you provide an example of carbon content in PLA vs. PET?
A. The analysis is relating total renewable organic CARBON to total organic CARBON. As such, the mass (weight) of a component is not directly represented in the result. The result only directly relates the amount of carbon in each component to all the carbon in the product. The chemical formula for PLA is C3H6O3 (40 % carbon). The chemical formula of PET is C10H8O4 (62.5% carbon). Since PET has 22.5% more carbon in it than PLA, equal weights of each in a formulation is going to produce a biobased result less than 50%. In other words, if a product contains only 2 carbon containing components, PLA and PET, and both are present in a proportion of 50%, the biobased content is less than 50% because the PET (fossil) has more carbon in it than the PLA (renewable).
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
Q:
When applying for the USDA certified biobased label, is it required that the (agricultural) raw materials be grown in the U.S.?
A:
Consistent with U.S. trade agreements to which USDA as a Federal government agency must adhere, biobased products that contain raw materials derived from imported plants (or other qualifying materials) are acceptable for the USDA voluntary labeling program. Imported products have to meet the same minimum content, verification standards, testing, and program requirements as U.S. products. Imported products must also meet any Federal labeling laws that may apply, including where required, country of origin. Products that contain imported agricultural materials would not qualify under the USDA Federal Procurement Preference, however.
Federal Purchasing Preference and BioPreferred Catalog Listing
Q:
Are biobased products competitive in terms of cost and performance?
A:
Many biobased products are cost competitive for the Federal purchaser, especially if one considers the entire life cycle cost of the product in terms of safety and environmental considerations, disposal, transportation, installation, etc. On the BioPreferred.gov website, under "Training Tools," there is a checklist for determining life-cycle costs of products. In terms of performance, categories of biobased products designated for the Federal procurement preference were determined by USDA to be comparable to their non-biobased counterparts.
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.
Q:
What is the BioPreferred program and where did it originate?
A:
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.
Q:
What is a“biobased” product?
A:
A biobased product is defined by the Farm Bills as a product that is determined by the Secretary of Agriculture to be a commercial or industrial product (other than food or feed) that is composed, in whole or in significant part, of biological products, including renewable domestic agricultural materials (including plant, animal and aquatic materials) forestry materials or intermediate materials or feedstock. Biobased products do not include motor vehicle fuels, heating oil or electricity produced from biomass. Also, since the program is designed to stimulate markets for new biobased products, "mature market" products are excluded by law from the program, but are covered by other programs. Mature market products are those biobased products that had significant national market penetration in 1972. Examples of mature market products include cotton shirts or towels, paper plates, and wood furniture.
Testing and Auditing
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.
Q:
Do you confirm that the carbon content percentage indicated on the label is the one directly from the lab analysis?
A:
Yes.
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.
Q:
In meeting the definition of "biobased" in the 2002 Farm Bill, how does biobased content testing distinguish various types of carbon (inorganic and organic)?
A:
Biobased solids, liquids, and gasses contain Carbon 14 and are easily differentiated from other materials such as fossil sources (petroleum) that does not contain Carbon 14. In the testing process, the percentage of organic carbon from agricultural and other biological sources is calculated relative to all the organic carbon in the sample. For example, if a labeled product indicates "70% biobased", this means that 70% of the carbon in the product is from recent biological materials, and 30% is from fossil sources.
ASTM D6866 quantifies only the biobased content relative to the material’s total organic content and does not consider the inorganic carbon and other non-carbon containing substances present.
For products with inorganic carbon constituting more than 3% of the total carbon, the inorganic carbon is excluded from the biobased content calculation.
Q:
Does the BioPreferred program require that the (agricultural) raw materials be grown in the U.S.?
A:
Products that contain imported agricultural materials would not qualify under the USDA Federal Procurement Preference.
However, consistent with U.S. trade agreements to which USDA as a Federal government agency must adhere, biobased products that contain raw materials derived from imported plants (or other qualifying materials) are acceptable for the USDA voluntary labeling program. Imported products have to meet the same minimum content, verification standards, testing, and program requirements as U.S. products. Imported products must also meet any Federal labeling laws that may apply, including where required, country of origin.
Q:
Are intermediate materials such as a bioplastic resin eligible for the Federal Procurement Preference and the voluntary labeling program?
A:
Manufacturers 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%.
Intermediates are not currently included in the Federal Procurement Preference portion of the program. It is anticipated that product categories designated for a Federal procurement preference in the future will include intermediates.
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.
Q:
How does the BioPreferred program's designation process work?
A:
On a continuous basis, USDA selects and prioritizes categories of biobased products for designation as "preferred" products for Federal purchasing. Several categories of biobased products are bundled into a "round." These "rounds" are incorporated into a draft Federal regulation and are published with a public comment period. After public comments are considered, a final regulation to designate a biobased product category is published in the Federal Register.
One year after the final regulation is published, Federal agencies and their contractors must give preference to "BioPreferred" products when making purchases within this product category.
The product categories and products in Rounds 1 through 6 are finalized and are eligible for preferred Federal purchasing. These product categories include 64 BioPreferred products categories. Additional rounds are in the planning stages.
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.
Q:
Is third party verification of biobased content required to be in the BioPreferred catalog?
A:
USDA does not require manufacturers to provide third party verification of biobased content in order to be listed in the catalog. The manufacturer must self certify that they meet the minimum biobased content set for their product’s category in order to be included in the catalog. However, a Federal agency considering the purchase of your product may require third party verification. Testing is required for a product to display the USDA certified biobased product label. The USDA BioPreferred catalog distinguishes labeled products.
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.
Q:
What is a BEES Analysis?
A:
BEES (Building for Environmental and Economic Sustainability) is a decision support software tool which helps Federal procurement officers choose biobased products based on their environmental and affordability attributes. The BEES tool used by the U.S. Department of Agriculture also helps biobased manufacturers learn about the impact of their products on the environment and on their costs. The USDA collaborates with interested manufacturers by supporting BEES evaluations of candidate biobased products.
General Questions about Biobased Products
Q:
What is a“biobased” product?
A:
A biobased product is defined by the Farm Bills as a product that is determined by the Secretary of Agriculture to be a commercial or industrial product (other than food or feed) that is composed, in whole or in significant part, of biological products, including renewable domestic agricultural materials (including plant, animal and aquatic materials) forestry materials or intermediate materials or feedstock. Biobased products do not include motor vehicle fuels, heating oil or electricity produced from biomass. Also, since the program is designed to stimulate markets for new biobased products, "mature market" products are excluded by law from the program, but are covered by other programs. Mature market products are those biobased products that had significant national market penetration in 1972. Examples of mature market products include cotton shirts or towels, paper plates, and wood furniture.
Q:
What is considered to be a “mature market” product?
A:
Mature market products are excluded from the Federal procurement preference program and from the voluntary labeling program. Mature market products are defined as those products that had a significant market penetration in 1972. Examples of mature market products include cotton shirts or towels, paper plates, and wood furniture. The staff at Iowa State University is available to help you with this definition. Contact Iowa State University at USDABioInfo@iastate.edu or 1-877-251-6522.
Q:
What is the impact of biobased products on the environment? Are biobased products “better” for the environment?
A:
They can be; however, while many of the biobased products on the market today may have a more benign effect on the environment, are biodegradable and have lower disposal and cleanup costs than the fossil petroleum based products they replace, a USDA certified biobased label is not a guarantee or expression of environmental preferability or impact. There is an expectation that the increased use of biobased products will help reduce petroleum consumption by increasing the use of renewable resources, thus reducing the amount of new carbon released into the atmosphere, helping to better manage the carbon cycle, in turn reducing resultant adverse environmental and health impacts.
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.
Q:
Are biobased products competitive in terms of cost and performance?
A:
In terms of performance, categories of biobased products designated for the Federal procurement preference were determined by USDA to be comparable to their non-biobased counterparts.
Many biobased products are cost competitive for the Federal purchaser, especially if one considers the entire life cycle cost of the product in terms of safety and environmental considerations, disposal, transportation, installation, etc. On the BioPreferred.gov website, under "Training Tools," there is a checklist for determining life-cycle costs of products.
Q:
Are biobased products “safer” than non-biobased products?
A:
The USDA BioPreferred program does not test or judge product safety. Read the label fully. Precautionary labeling for consumer safety for both products and packaging is highly regulated by Federal law. Look for signal words such as “CAUTION”, “WARNING, “DANGER” and “POISON”. Also, consumers may access the manufacturer’s material safety and data sheet (MSDS), also known as a product safety data sheet. An MSDS is a form required in the U.S. by the Occupational Safety and Health Administration (OSHA) and contains data regarding the properties of a particular substance, and may include instructions for the safe use and potential hazards associated with a particular material or product. If in doubt, contact the manufacturer.
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
Q:
What is the BioPreferred program and where did it originate?
A:
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.
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.
Q:
What are the requirements for qualifying for the USDA certified biobased product label?
A:
Biobased products already identified within a USDA designated product category under the Federal Procurement Preference portion of the BioPreferred program must meet the minimum biobased content of the product category. http://www.biopreferred.gov/ProposedAndFinalItemDesignations.aspx. Products that do not fall under a designated product category must be minimum 25 percent biobased unless the label applicant applies for and receives an alternative minimum biobased content allowance.
Q:
Are products that display the USDA certified biobased product label independently tested for biobased content?
A:
Yes, products are tested to verify the actual biobased content in the product, by mass (weight). The USDA, through a grant with, Iowa State University, examines products and test results performed by independent, third-party accredited testing laboratories which certify that test results conform to ASTM International standards. ASTM is an internationally recognized nonprofit standards setting organization. The USDA asked ASTM to develop a standard for determining biobased content. The standard uses a variation of highly sophisticated radiocarbon dating to assure the accurate measurement of a product’s biobased content. The standard is now cited in Federal law (7 CFR part 2902) and is internationally recognized.
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.”
Q:
Does the certified percentage of biobased content as shown on the label always apply to the entire product contents?
A:
Not for all products. Water and inorganic carbon are excluded in calculating the percentage 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 in significant quantities. Inorganic carbon sources are known interchangeably as carbonates or sedimentary rocks, which includes limestone, dolomite, siderite, and any other source of carbon originating from mineral precipitation. Where these materials are present in a USDA certified biobased product, the biobased percentage content will be overstated on the label.
For example, if the USDA certified biobased label indicates "70% biobased," 70% of the carbon in the product is from biological materials. A liquid detergent concentrate with 70% biobased content will have the same 70% biobased content if diluted with any amount of water since only carbon is represented in the result.
In these cases USDA Brand Guidelines and Graphic Standards require labeling the product in a manner that clearly qualifies the biobased percentage, so that the USDA label does not mislead the purchaser or user.
Q:
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”?
A:
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.
Q:
Have products that display the USDA certified biobased product label been made with biotechnology or contain “GMO’s”?
A:
Only the product manufacturer can answer that question. The USDA certified biobased product testing program measures organic carbon content only. The program does not measure or analyze sources of or the presence or absence of any product ingredients. Essentially all food crops have been modified and bioengineering technology is only one of a number of technologies used to modify crops. The USDA certified biobased product label cannot be applied to foods and therefore it is highly unlikely USDA certified biobased products contain any organisms, since most foods do not contain organisms (seeds and foods like yogurt that contain microorganisms are exceptions). Furthermore, the chemical transformation of biological material in the manufacture of biobased products results in the loss of any genetic information, so such information cannot be present in the final product.
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.
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