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European Commission: Single Use Plastics Directive
Unilever: plant-based wipes
Overview
Unilever welcomes the EU Single Use Plastics Directive and need for more stringent labelling
requirements for plastic-containing wipes.
As a business, we acknowledge the growing concern around the environmental impact wipes can
have, especially if disposed of incorrectly. To help prevent our wipes from being flushed down the
toilet we feature the ‘do not flush’ logo on the front of our product packaging to help ensure they
are disposed of correctly (see Annex I).
We have also been innovating our wipes portfolio and exploring the use of plant-based wipe
materials, which we have already started to introduce across a number of brands (e.g. Simple and
Baby Dove).
The purpose of this paper outlines our approach to plant-based wipes and why, in our view, they
remain out of scope of the EU Single Use Plastics Directive.
EU Single Use Plastics Directive
Unilever supports the Commission’s ambitious environmental agenda, and as a manufacturer of wet
wipes, we are committed to using sustainable technologies which positively impact consumers, as
well as the environment.
We acknowledge the scope and definition of a ‘plastic’ as outlined in the EU Single Use Plastics
Directive.
We understand this definition to be as follows:
Art. 3 (1) SUP Directive states that “
'plastic' means a material consisting of a polymer within the
meaning of Article 3(5) of Regulation (EC) No 1907/2006, to which additives or other substances
may have been added, and which can function as a main structural component of final products, with
the exception of natural polymers that have not been chemically modified.” Article 3(40) of
Regulation (EC) No 1907/2006 of the European Parliament (“REACH”) states that a “
not chemically
modified substance” means “
a substance whose chemical structure remains unchanged, even if it
has undergone a chemical process or treatment, or a physical mineralogical transformation, for
instance to remove impurities”.
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Unilever’s wipes portfolio
The following outlines our view on which of our wipes falls within scope of the EU Single Use Plastics
Directive. We welcome any further discussion on our position.
In scope = plastic containing wipes
A small number of our wipes contain polyester and polypropylene. Where our wipes contain these materials, we
will ensure we adhere to the requirements outlined under the Single Use Plastics Directive. We already use the
‘do not flush’ logo on the front of pack, at the point of extraction.
Not in scope = wipes made from natural, plant-based fibres
Unilever’s plant-based wipes are made from materials derived from sustainably sourced, renewable wood pulp
and plant-derived fibres (viscose, cotton, cellulose). These wipes do not use any synthetically produced polymers
(i.e. polyester, polypropylene, polystyrene) and therefore we consider these wipes to fall out of scope of the EU
Single Use Plastics Directive. Our plant-based wipes also feature the 'do not flush' logo on front of pack, at the
point of extraction to ensure responsible disposal.
Please see below for more information which supports this rationale:
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External standards: All our plant-based wipes have passed the relevant ISO standard (ISO 14855/ISO
16929/EN 13432), which includes biodegradability, compostability, and ecotoxicity tests. These tests focus
on soil degradation, imitate real-world scenarios and are robust and internationally standardised. Thus, when
our wipes are disposed of correctly (i.e. not flushed down the toilet and discarded in home or industrial
compost or in the bin), they will break down completely with no adverse impact on the environment (see
Annex II for our test results). Our internal data shows wipes made up of viscose, cotton and cellulose
biodegrade faster in compost than tree leaves, pine needles and wood fibres (see Annex II for a visual of
our test results).
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Production process: In natural fibre production, there are both mechanical and chemical treatments that
the starting materials must go through in order to become viable for consumer use. These methods are well
developed, and essential for cleaning and processing these fibres. Lenzing, lead manufacturer of
cellulose/Tencel®, has a 99% recovery rate of the materials used in their processing. While the chemical
treatment may cause intermediate side reactions with the polymers, the final fibre structure is identical to
its natural starting point. The physical properties are maintained, and the degradability of the fibres is not
impacted.
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Considerations for the European Commission
It’s important to recognise the progress industry has made in shifting to plant-based wipes and
the broader benefits it has to the environment versus plastic-containing wipes. It is therefore
important to acknowledge and reflect this in the Single Use Plastics Directive. Please take the
following points into consideration when defining the scope of the requirements for wipes:
Plant-based wipes offer solutions to growing disposal and greenhouse gas (GhG)
concerns:
o Through our own internal investigations, along with available industry data, we
have data to support CO2 reductions (in kg) from fiber manufacturing at an
average of 30% in viscose and almost 100% in cellulose, compared to synthetic
polyester.
o Our available internal and external data also supports the proper disposal of
these materials and their associated lower GhG footprint. If disposed of in a
landfill, wipes which contain plant based fibers (e.g. viscose and cellulose) will
generate over 15x the greenhouse gasses compared to synthetic based (e.g.
polyester). This is explicitly driven by the synthetic material’s inability to break
down in the environment, and over time it will bioaccumulate in the landfills
instead of generating biogas.
o Alternatively, our data shows that when incinerated, polyester will generate
nearly 80x the GhG from fossil carbon release than plant-based wipes.
o There is significant industry data that shows, through composting, plant0based
wipes will break down into safe, non-toxic compounds that can be used for plant
growth. The production of CO2 in this breakdown will help facilitate
photosynthesis, while the compounds broken down in soil will contribute to plant
growth. Synthetic materials, such as polyester, will not break down and
bioaccumulate in compost environments.
Plant-based wipes also offer solutions to the growing marine concern. As stated, through
proper disposal, the materials are shown to break down in aerobic and anaerobic
environments. Additionally, Lenzing’s fibres, per ASTM D6691, are certified as seawater
safe, meaning they will also
eventually biodegrade (see Annex III). Synthetic-based materials (i.e. polyester,
polypropylene, polystyrene) have been shown to not break down
in any environments and will only continue to bioaccumulate in landfill and marine
environments.
Classifying plant-based wipes as “plastic” may hinder innovation around alternative
sustainable sources. With further development of these types of fibres, classifying
nature-derived materials, such as bamboo, which offer more environmentally positive
benefits on land use, as "plastic", may stifle innovation and increase the negative
environmental impacts of synthetics on the environment.
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The danger of classifying plant-based wipes as a ‘plastic’ under the EU Single Use
Plastics Directive is that it will fall under EPR requirements and will require producers
to pay for litter clean-up costs, consumer awareness as well as responsibility fees. This
may motivate these companies to remain in synthetic materials to absorb the costs
associated with EPR. These materials, from a sustainability perspective, are worse than
the naturals, as they rely on a non-renewable petrochemical resource, and will only
continue to contribute to the growing landfill accumulations.
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Annex I
Figure 1: Pack-shot of our Simple biodegradable wipes - features the 'Do Not Flush' logo on
front of pack, at the point of extraction.
Annex II
Testing conducted on plant-based wipes v synthetic:
Figure 2: Wipes made of viscose, cellulose (plant-based). Biodegrades in compost in 2 weeks.
Figure 3: Wipes made of cotton and viscose (plant-based). Biodegrades in compost in 6 weeks.
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Figure 4: Synthetic, polyester-based fabric, no biodegradation occurs in compost.
Annex III
Figure 5: Lenzing’s fibres are certified as seawater safe
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