Latest / The Monégasque Table / Biodegradable Glitter vs Edible Glitter: Not the Same Question
Transcript
- Margaux: A venue emails a caterer 3 days before an event: "Is the glitter in the signature cocktail a microplastic? Our sustainability policy needs an answer." And the caterer forwards it to their supplier with no idea that the question they've been asked has nothing to do with whether the glitter is safe to eat. Dana: Those are the same question though. Surely those are the same question. Margaux: They are not, and that's the entire episode. Welcome to The Monégasque Table. Today: biodegradable glitter versus edible glitter — two labels, two different regulations, two different questions, and a lot of people answering the wrong one. Dana: I'm going to be difficult today, fair warning. Because "biodegradable" sounds like the safer word and you're about to tell me it isn't, and I don't think you can make that stick. Margaux: Then here's the answer up front, and you can spend 15 minutes trying to break it: "biodegradable" is a claim about what happens to a material in the environment. "Edible" is a claim about what happens when a person swallows it. They are answered by different rules, they are proven by different documents, and neither one certifies the other. Biodegradable glitter can be entirely unfit to eat. And a glitter made to be eaten is not automatically making any environmental claim at all. Dana: Right, but where does "biodegradable glitter" even come from? Two years ago nobody said it. Margaux: It comes from a piece of European law, and it's worth being precise about it because it gets cited at people constantly and almost always slightly wrong. Commission Regulation 2023/2055 — the microplastics restriction under the European chemicals framework — entered into force on the 17th of October, 2023. It restricts synthetic polymer microparticles that are intentionally added to products. Dana: Which in English means? Margaux: Small bits of plastic that are put in on purpose. And the regulation is unusually specific about what counts. A synthetic polymer microparticle is a solid polymer that makes up at least 1 percent by weight of a particle — or forms a continuous coating on it — where the particles are 5 millimeters or smaller in every dimension. There's a second limb for fibers: 15 millimeters or shorter with a length-to-diameter ratio above 3. Dana: So loose craft glitter is exactly that. Margaux: Loose plastic craft glitter is the poster child, and it's what the headlines were about. Regulatory summaries of the restriction describe loose plastic glitter as among the first products caught when the rules started applying, and the Commission's stated purpose — again, per those summaries, not my words — was not to ban all glitter but to replace plastic glitter with natural, biodegradable, soluble or encapsulated alternatives. Other product categories phase in on later dates that run out to 2035. Dana: Okay. So here's objection number one, and I want a straight answer. If Europe went to the trouble of restricting tiny plastic particles because they're bad, and edible glitter is also tiny particles — why isn't edible glitter caught by the same rule? Margaux: Two reasons, both written into the regulation itself, and I want to read them carefully rather than paraphrase them into something convenient. First: food is expressly exempt. The restriction carves out food, as defined in the European food law regulation, and feed. It is not a food rule. It was never a food rule. Dana: And the second? Margaux: The second is more fundamental. The definition covers polymers. And it explicitly excludes polymers that contain no carbon atoms in their structure. It also excludes polymers formed by natural processes that haven't been chemically modified. A polymer is a long chain of repeating molecular units — that's what plastic is. A mineral pigment is not a polymer. It's rock, ground fine and coated. Dana: So the answer to the venue's email is "it's a mineral, not a plastic." Margaux: The answer to the venue's email is more careful than that, and this is where I'm going to disappoint you slightly. What I can tell you is what the regulation says: it exempts food, and its definition doesn't reach materials that aren't polymers. What I am not going to do on this show is stand here and rule on whether any particular product — including ours — falls inside or outside a European restriction. That's a determination that belongs in a product's own regulatory file, signed by someone whose job that is. Not in a podcast. Dana: See, that's the round I came for, and I'm taking it. You just spent 4 minutes explaining a regulation and then refused to apply it. From where I'm sitting that's a dodge, and the caterer still has an email to answer in 3 days. Margaux: That's the round you win, and you should take it, because it's the fair criticism. So let me be useful instead of evasive. Here is what that caterer should actually do, and it works for any supplier, including us. Don't ask "is it a microplastic?" — that's a question a salesperson can answer with a vibe. Ask for three documents. One: the product specification, which tells you what the material actually is. Two: a lot-specific certificate of analysis, which tells you what was in the batch you bought. Three — and this is the one almost nobody asks for and it's the one that matters — a written regulatory statement from the supplier naming the food categories the product is intended for, in your market. Dana: Why that third one? Margaux: Because it's the only document where the supplier has to commit to something in writing that they can be held to. And here's a trap worth naming: a safety data sheet is not that document. Suppliers send them constantly because they're easy to send. But a safety data sheet is an occupational hazard document — it exists to tell a warehouse worker how to handle a substance in bulk. It is not food compliance evidence. If you asked for compliance and got a safety data sheet, you did not get an answer. Dana: That's more useful than "it's a mineral." Grudgingly. Margaux: It's also the answer that survives the follow-up question, which is the only kind worth giving to somebody with an inspector. Dana: Objection two. Let's flip it. Say I buy the environmentally friendly one — a biodegradable, plant-based glitter, sold as the responsible choice. Why can't I put that on a cupcake? Margaux: Because nothing in that sentence is about eating. Biodegradability describes what happens to a material after it leaves you — in soil, in water, over time. It says nothing about what happens on the way through a person. A material can break down beautifully in a compost heap and still be made with colorants that were never cleared for food, at particle sizes and purities nobody assessed for ingestion. Those are separate assessments, done by separate authorities, against separate criteria. Dana: And the US has its own version of this? Margaux: The US framing is completely different and much blunter. The FDA has published advice for home and commercial bakers, and it says to avoid using glitter and dust products on food unless the products are specifically manufactured to be edible. It then does something genuinely helpful: it lists the aliases these products travel under — luster dust, disco dust, twinkle dust, sparkle dust, highlighter, shimmer powder, pearl dust, petal dust. Same shelf, same aisle, wildly different products. Dana: So how does a normal person tell them apart? Margaux: The FDA gives one test and it's the single most useful sentence in this whole category. Companies that make edible glitters and dusts are required by law to include a list of ingredients on the label. So: if a label says only "non-toxic," or "for decorative purposes only," and carries no ingredient list — that product should not be used directly on foods. That's not our house rule. That's the agency's. Dana: "Non-toxic" isn't good enough? Margaux: "Non-toxic" is a claim about poisoning. "Edible" is a claim about food. A great many things are non-toxic and not food. Sawdust is non-toxic. Dana: Please don't put sawdust on a cupcake. Margaux: It's the same logic error as biodegradable, and it's why both words keep ending up on the wrong products. Every one of these terms answers a question adjacent to the one the buyer is actually asking. Dana: Give me the real-world version. Why does any of this matter beyond a venue's paperwork? Margaux: Because it has already gone wrong. During 2018 and 2019, health departments in Rhode Island and Missouri investigated heavy-metal poisonings connected to cakes decorated with luster dusts that contained high levels of copper, lead and other metals. Not glitter in general — specific decorative products that were never made to be eaten, used on food that people then ate. That's the reason the FDA advisory exists at all, and I want to be careful here: that story is about the category's rules existing for a reason. It is not a story about any named brand, and I'm not going to turn it into one. Dana: And this is where somebody asks about heavy metals in general. Margaux: And here's where I stay in my lane. The federal color-additive listing for mica-based pearlescent pigments — 21 CFR 73.350 — writes purity limits into the law itself: lead not more than 4 parts per million, arsenic not more than 3, mercury not more than 1. That is what the law requires of the additive. I'm citing it as the standard that exists, and I am deliberately not telling you that any particular jar was tested against it, because that would need a lab report in somebody's hand, and a claim like that should never be made from a microphone. Dana: You keep stopping short of the thing that would sell more jars. Margaux: That's the job. This category's biggest problem is people saying more than they can prove. In an analysis of about 2,400 reviews across this category, over 66 percent of the ingredient-related complaints weren't about a bad ingredient at all — they were about missing ingredient information. And separately, about 9.5 percent of the negative themes were people discovering the thing they bought wasn't actually edible. That's the wound. Overclaiming is what made it. Dana: Let me push on the word "edible" for a second, because you've been leaning on it. What does the FDA say is actually in the edible ones? Margaux: It names them, which is more helpful than most agencies get. The common edible ingredients it lists are sugar, acacia — that's gum arabic — maltodextrin, cornstarch, and food-approved color additives, including mica-based pearlescent pigments and the FD&C colors. So there's a real range under the word "edible": some of these products are essentially sugar with color on it, and some are mineral pigment. Both can be legitimately edible. They behave completely differently in a drink, which is a separate conversation, but neither is disqualified by what it's made of. Dana: And a listing that just says "food grade"? Margaux: "Food grade" is a phrase with no fixed legal meaning on a consumer label, and it's doing a lot of unearned work in this category. It's not a lie, exactly. It's just not checkable. The ingredient list is checkable. That's the difference, and it's why the FDA's test points at the list and not at the adjective. Dana: Objection three, and this is my last one. If you won't certify your own product on air, why should the caterer buy from you rather than from the supplier who cheerfully says "yes, totally compliant, no problem"? Margaux: Because that supplier just told you something they cannot possibly know about your market, your food category and your batch — and you now have that in an email, which is worth nothing when someone asks for the document behind it. What you should buy on is checkability. Is there an ingredient list printed on the jar you can read before you serve it? Will they send you a specification and a batch certificate when you ask? Will they put the intended food categories in writing? A supplier who answers narrowly is a supplier who has thought about the question. A supplier who answers expansively is a supplier who hasn't. Dana: That's an annoyingly good answer. Margaux: It's also just the FDA's test wearing a suit. Ingredient list on the label. Everything else is decoration. Dana: Who should skip all of this? Margaux: If you're doing crafts — a card, a centerpiece, a costume — none of this applies to you and edible glitter is a silly thing to buy for it; it costs a lot more per gram and it's engineered for a job you don't have. If your priority is genuinely environmental impact rather than food, then buy on that basis, and don't let anyone tell you an edible product is the green product — that's not the claim it's making. And if you're a business buying at volume and nobody will send you a specification and a lot certificate, walk away, whoever they are. That includes us on a day when we can't produce them. Dana: Dana's Scorecard. I came in convinced that biodegradable and edible were two words for "the good one." They're not even in the same conversation. Biodegradable is about what a material does in the environment; the European restriction that made everyone start saying it took effect on the 17th of October, 2023, targets synthetic polymers at 5 millimeters and under, expressly exempts food, and doesn't reach materials that aren't polymers at all. Edible is a food question, and in the US the test is the FDA's: is there an ingredient list on the label, and was the thing made to be eaten. "Non-toxic" doesn't pass it. Biodegradable doesn't pass it either. If you're buying for a business, ask for a specification, a lot certificate, and the intended food categories in writing — and know that a safety data sheet is not any of those. Caveat I'm keeping, and I'll say it out loud because he wouldn't: this episode told me what the rules say and refused to tell me who complies with them. I think that's right. I also think it's the most irritating kind of right. Margaux: Footnote. The MONÉGASQUE Snow White 10 gram drink glitter is on Amazon with its full ingredient list printed on the jar, about $15 — check the listing for current pricing, and read the list before you serve it. That's the same advice I'd give you about any jar in the aisle. Dana: Two things coming up. Next time, the question I've been sitting on since we started talking about jars that sit in cupboards: does edible glitter expire? Because mine is 2 years old and I have no idea. Margaux: Read the jar, not the internet — and we'll explain what actually degrades and what doesn't. And a bit further out, the one that follows directly from today: what a supplier's documents can and can't prove, and which ones to ask for first. Dana: The paperwork episode. I'll bring coffee. Margaux: This show is produced by the team at Monégasque, with AI-crafted hosts, and every number you heard was checked by humans against the documents. See you at the table.