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(Editor’s Note: 3E is expanding news coverage to provide customers with insights into topics that enable a safer, more sustainable world by protecting people, safeguarding products, and helping businesses grow. DEEP DIVE articles, produced by reporters, feature interviews with subject matter experts and influencers as well as exclusive analysis provided by 3E researchers and consultants.)
Whether a ban on laundry and dishwasher pods will wash with residents of New York City remains to be seen, but a bill to prohibit the sale of pods and sheets using polyvinyl alcohol (PVA or PVOH; the OH is the alcohol group when expressed in a chemical formula) was introduced by District 24 Council Member James F. Gennaro on 8 February 2024.
Known as the Pods Are Plastic Bill, the proposed legislation is “a prohibition on the sale of laundry and dishwasher pods and sheets using polyvinyl alcohol.” It not only prohibits the sale of laundry and dishwasher pods and sheets that include PVA/PVOH, it also requires education and outreach to retail and wholesale businesses on compliance with the requirements of the law. The bill – co-sponsored by Gennaro and council members Lincoln Restler, Alexa Avilés, and Erik D. Bottcher – was referred to the Committee on Environmental Protection, Resiliency, and Waterfronts for further discussion. Gennaro chairs that committee, and Restler and Avilés are members.
If approved, the law would go into effect in January 2026, and not surprisingly, the proposal set off a flurry of activity on both sides of the Atlantic.
Disagreements about the Impact of PVA/PVOH
Pods made with PVA/PVOH have long been touted by the companies marketing them as more environmentally friendly compared to traditional products/packaging, because they require less product and less water in the product, have a lower carbon footprint for emissions related to transport, and feature less plastic in packaging.
A widely cited study published 3 June 2021 in the International Journal of Environmental Research and Public Health found that up to 650,000 tons of PVA/PVOH is produced yearly around the world, a number that has been growing by approximately 4% every year since 2018. Some 17,200 metric tons of laundry and dish detergent pods are used in the United States annually, according to the study. The researchers estimated that 15 billion laundry and dishwasher pods are used each year by 126 million U.S. households.
Of that, according to the study, roughly 11,000 tons of PVA/PVOH reach wastewater facilities where 75% of it remains untreated while passing through the regular wastewater treatment process, with some of it ending up in treated sludge (biosoils), which is then used as fertilizer for agriculture.
As noted by study authors Charles Rolsky and Varun Kelkar, “Polyvinyl alcohol (PVA) is a water-soluble plastic commercially used in laundry and dish detergent pods (LDP) for which a complete understanding of its fate in the environment and subsequent consequences is lacking.”
The study was funded in part by Blueland, a cleaning supply company that was launched 22 April 2019 with the stated goal of eliminating “single-use plastic packaging from our everyday products, starting with cleaning products.” The company offers water-soluble cleaning tablets for laundry, hand soap, and cleaning sprays in paper packaging, along with reusable application or storage containers.
In a statement about the proposed ban, the American Cleaning Institute (ACI), a trade association for the cleaning products supply chain, commented, “…The campaigners – led by Blueland – are relying on shoddy science and intentional distortions about this.” (As of press time, Blueland has not responded to a request for comment.)
ACI pointed to more than 50 years of published science, including extensive reviews by regulatory agencies from around the world including the U.S. Environmental Protection Agency (EPA), “that have supported the environmental and human safety of PVA/PVOH for use in diverse industries.”
Calling the innovation of water-soluble films and laundry detergent packets “a sustainability success story,” ACI claimed the pods “help consumers safely use, dose, and store the products, making chores easier to do for everyone, including those with disabilities. They can be designed for cold water wash cycles, reducing the footprint associated with heating water.”
According to ACI, the water-soluble PVO/PVOH films used with detergents and other products are:
- Designed to dissolve completely in washing and dishwashing machines and then flow down the drain with the wash water.
- Are safe to use in the home and meet rigorous, internationally approved test methods to ensure they fully dissolve and biodegrade after use.
- Can be modified to be more or less soluble depending on the desired performance required for its intended application. Water-soluble versions of PVA/PVOH have been used in everything from food products, tablets, medicines, eye drops, and beauty products as well as detergent packets, and have been found to be safe for human use.
- Are accepted by the U.S. EPA Safer Choice program and other strict ecolabeling organizations around the world.
- Are listed on the EPA’s Safer Chemicals Ingredients List.
ACI Senior Vice President of Communications Brian Sansoni told 3E: “We agree that plastic pollution is a serious problem, and we’re committed to taking a collaborative approach to solving it. The PVA films used in detergents biodegrade and do not contribute to microplastic pollution. Once dissolved, this PVA biodegrades into components like carbon dioxide and water.”
Noting this grade of PVA/PVOH is also used in food and medical products, including vitamin supplements, Sansoni added, “Regulatory bodies around the world have looked at the grade of PVA we use and supported its safety, making this bill unnecessary.”
International Interest in PVA/PVOH
Grimanesa Till, Senior Chemical Business Advisor, Regulatory Consulting, 3E, said that for consumer cleaning products companies, the topic of PVA/PVOH is “continuously present.”
“We received many questions from customers and distributors on the use of PVA and its biodegradability,” she acknowledged, adding, “Companies supplying private label products for consumers and their retailers are increasingly facing reluctance from their customers on their use of PVA, as they were classifying PVA as a liquid polymer without taking into consideration its biodegradability.”
In cases where new regulations or legislation are being considered, manufacturers rely on the expertise and lobbying power of industry associations like ACI in the United States and the International Association for Soaps, Detergents, and Maintenance Products (AISE), headquartered in Brussels, a practice encouraged by Till.
By closely monitoring regulations, companies know when “to reach out to their industry organizations and contribute to a concerted approach. [That relationship with their industry organization] allows them to do their advocacy work, either on their own or through the industry organization,” she added.
As an example of advocacy on behalf of manufacturers, Till mentioned efforts launched in 2017 in Germany by the IKW (Industrieverband Körpeflege und Waschmittel/The Personal Care and Detergent Industry Association), which issued a statement on the use of PVA in cleaning products. The document is only available in German, but Till provided this translation of a key passage:
“Polyvinyl alcohol film is used for the casing of pre-dosed detergents and cleaning agents, so-called gel capsules or certain tablets. This polymer is water-soluble and inherently biodegradable. The safety assessment also shows that the quantities of dissolved polyvinyl alcohol that end up in surface waters are harmless to water bodies and their living creatures.”
AISE on 9 February 2024 shared its own research on the biodegradability of PVA/PVOH-based film used for capsules for liquid detergents. Published in Tenside Surfactants Detergents (Volume 58, Issue 2), a peer-reviewed publication and developed with the support of Henkel, Kuraray, McBride, Procter & Gamble, Reckitt, and Unilever, the research shared biodegradation data for the six water-soluble grades of PVA/PVOH that are most commonly used for laundry detergents’ capsule films. In summary:
Ready biodegradability screening test data on the six technical (commercial) PVA/PVOH film materials representing a range of films currently on the market were collected, anonymized, and aggregated for assessment. These films include structural modifications and auxiliary ingredients, required to meet performance and safety requirements for this specific part of the detergents market.
Researchers, the majority of whom work for the companies that supported the study, reported substantial variability between the results of biodegradation studies on different films. Some materials fully met the criteria for ready biodegradation, while others underwent biodegradation at a lower rate and did not fulfill these criteria.
“Nevertheless,” the study concluded, “for these materials the biodegradation process continued, and the biodegradation threshold was well exceeded subsequently as part of an enhanced test protocol.” Modelling across all aggregated data suggests that a total extent of biodegradation of 60% was reached after 28 days.
“[A]dequate biodegradability is confirmed by means of ready biodegradation screening tests, across a range of polyvinyl alcohol detergent grade films,” concluded study author Dominic Byrne, Senior Policy Manager, PlasticsEurope, who previously held the position of Scientific and Regulatory Affairs Manager at AISE. “The high water solubility in itself implies that detergent capsule films are not within the microplastic scope. Furthermore, their biodegradability ensures there is no concern for persistence or accumulation in the environment.”
EPA Asked To Weigh In
Blueland and the Plastic Pollution Coalition (PPC) petitioned the EPA in January 2023 to remove the “Safer Choice” approval for PVA/PVOH detergent pod products and change it to a “need more information” and to require companies selling these products to carry out testing to prove they are safe. EPA denied their petition in April 2023 on procedural grounds (the petitioners didn’t meet the standard for demonstrating that existing information and experience are inadequate), stating, “No evidence of toxicity or bioaccumulation potential for the soluble form of PVA used in detergent pods and sheets has been presented.”
“The NYC proposal was done against this backdrop [of a failure to remove Safer Choice approval at the federal level]. While I don’t have any special insight on the plans for Blueland and the PPC team, my guess would be that they saw NYC as a ‘favorable venue’ for this action. An anti-pod win in NYC will obviously energize the groups that are fighting against PVA (which is part of the larger anti-plastic movement),” said Rob Campbell, Senior Chemical Business Advisor, 3E.
When contacted for comment about the proposed NYC legislation, PPC referred 3E to Blueland. Blueland’s position on single-use plastics in general is clear. The company’s website states, “Our products have helped to eliminate over 1 billion single-use plastic bottles from landfills and oceans since 2019,” while a banner viewed on 14 February 2024 on the top of its website home page declares: “We’re banning plastic pods in NYC: Get Involved.”
Potential Impact for Industry
3E’s Rob Campbell pointed out that chemical restriction laws are not very common at the city level, citing one from 2019 in San Francisco, when an ordinance banning the sale of furniture containing flame retardant chemicals took effect.
“Generally, it seems that when the federal government doesn’t act, there are a handful of states that often will take up the cause. Chemical restrictions at a city/county level are pretty rare,” said Campbell. “What makes the NYC proposal interesting is that a company (Blueland) and an anti-plastic group (Plastic Pollution Coalition) have teamed up on an effort to get rid of the PVA pods.”
Till offered this advice for companies that are engaged in the manufacture, use, or distribution of PVA/PVOH films or products utilizing the films:
- Monitor proposed regulations and updates to existing regulations. As an example, Till pointed out that the EU now has a defined microplastic definition and restriction in place via REACH (Registration, Evaluation, Authorization and Restriction of Chemicals), which allows manufacturers to use their analytic data to differentiate their products from microplastics (such as in the case of PVA/PVOH). The EU also has a recommendation on the definition of nanomaterials, which is being used to tackle these types of materials in future regulations. (See Managing nanomaterials in the workplace | Safety and health at work EU-OSHA (europa.eu)
- Follow social media for insights into consumer views but be honest about any product claims you make on social media. For example, companies selling consumer products started placing “green claims” on their products, mainly because there’s been considerable pressure from consumers and nongovernmental organizations (NGOs). However, many of those “green claims” were not as accurate as stated (known as “green washing”), and the EU published a directive on green claims to protect consumers. (Green claims - European Commission (europa.eu).
- Prepare for new and updated regulations by reviewing internal processes (SDS preparation, labeling, conducting an evaluation of new (chemical) alternatives (re-formulation, testing), and placing compliant products on the market in a timely manner, which allows for market competitiveness. This goes beyond just monitoring; it involves regulatory interpretation and evaluation of applicability of the regulation to the company’s products and the specific consequences for the company and its products.
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(About the author: Sandy Smith, Senior Reporter, 3E, is an award-winning newspaper reporter and business-to-business journalist who has spent 20+ years researching and writing about EHS, regulatory compliance, and risk management and networking with EHS professionals. She is passionate about helping to build and maintain safe workplaces and promote workplace cultures that support EHS. She has presented at major conferences and has been interviewed about workplace safety and risk by The Wall Street Journal, CNN, and USA Today.)
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