USDA Biobased Label Identifies Farm-Grown Content
By Paula Melton
A new Biobased Product label could begin appearing in 2011 on certain building products formulated with plant or animal ingredients, such as carpeting containing corn-derived fiber and foam insulation integrating soy content.
The Biobased Product labeling program, developed by the U.S. Department of Agriculture (USDA), responds to a mandate in the 2008 Farm Bill to create new markets for commodity crops and agricultural waste. It aims to stimulate innovation, create jobs in rural areas, and promote renewable alternatives to petroleum-based products. A consumer-targeted spinoff of the Federal BioPreferred Program, which aids federal agencies in the purchase of biobased products (a legal requirement), the program applies many of the same standards to consumer products.
The Biobased Product label will not be used for any foods, feeds, or fuels, or for energy produced by biomass. Nor can it be used for products that have long been made of cotton, wool, wood, paper, or other biobased materials--a point of major contention during the public comment period that accompanied the label’s creation. For example, a standard, 100% biobased paper plate would not qualify for the program, while a plastic plate containing 25% corn-based polymers would. USDA based the rule on its goal of stimulating innovation and job growth by creating new markets—not to reward “mature markets” (defined as those established before 1972) for using already widely accepted materials.
In addition to the mature market rules, here are some other requirements:
- New products in one of the 66 categories already recognized by the Federal
BioPreferred program must meet established standards for that category—for example, 7% biobased content for carpet and 95% biobased content for structural wall panels.
- Products in new categories must contain at least 25% biological material by weight.
- Products must be tested for biobased content by a third-party lab.
- The actual percentage of biobased material must appear on the label.
- Certified Biobased Products are subject to USDA audits for as long as a manufacturer continues to use the label.
An earlier draft of the rule would have required manufacturers to perform an environmental life-cycle assessment (LCA) of the materials used in the product, but this requirement does not appear in the final rule—a fact that some experts see as a major weakness of the program. “Labeling something as biobased may lead to the impression that it is environmentally preferable,” said Shelie Miller, a researcher at the University of Michigan’s School of Natural Resources and Environment who studies the life-cycle impact of biofuels. “That could be misleading.”
Knowing that a product is biobased “doesn’t give the full picture,” Miller says. While biobased plastics often require fewer fossil fuel feedstocks and result in lower carbon emissions than petroleum-based plastics, “agriculture and manufacturing have any number of impacts other than climate change.” These include devastating water pollution, irreversible erosion, and severe soil depletion.
In general, people are “willing to bear these environmental impacts because it’s part of the food system,” she said, but it’s harder to justify them for the sake of less essential goods. In preferring agricultural products for building materials and other products, she says, you are usually “trading a carbon issue for a water quality issue.”
USDA’s Kate Lewis acknowledged the “very thoughtful criticism” the agency had received about the label’s limitations, and said USDA had considered these issues very carefully when deciding not to require LCA or any other kind of environmental impact statement from manufacturers at this time. The problem, she explains, is that “there is no consistent method for determining a product’s life-cycle impact.” However, she said, USDA would continue to follow developments in standardizing life-cycle data and would almost certainly revisit LCA in the future.
For now, though, Lewis said the label will generally identify products that “increase our energy independence,” and that consumers should not mistake that for comprehensive sustainability. “We are not an eco-label,” she said. At the same time, she acknowledged that USDA has a responsibility to inform both manufacturers and consumers about that fact, and said a major educational campaign is in the works targeting both groups. “There is a lot of confusion about all these various seals and marks,” she said. “We’re hoping not to add to that confusion.”