ASTM D8410-22

Standard Specification for Evaluation of Cellulosic-Fiber-Based Packaging Materials and Products for Compostability in Municipal or Industrial Aerobic Composting Facilities

SCOPE
1.1 This specification covers cellulosic-fiber-based packaging materials and products associated with food, landscape waste, and other compost feedstocks, which are intended to be composted under aerobic conditions in municipal and industrial composting facilities, where thermophilic temperatures are achieved.  
1.2 This specification covers cellulosic-based uncoated and coated packaging materials and products and covers whole packaging products. Products covered in this specification include cellulosic fiber-based products produced from cellulosic pulp, corrugated materials, containerboard, paper, paperboard, and molded fiber.  
1.3 This specification excludes end items where thermoplastic polymer is laminated or extruded to cellulosic substrates.  
1.4 This specification is intended to establish the requirements for labeling cellulosic-fiber-based packaging materials and products as “compostable in aerobic municipal and industrial composting facilities” in accordance with the guidelines issued by the Federal Trade Commission,2 provided the label includes proper qualifications as to the availability of such facilities.  
1.5 The properties in this specification are those required to determine if packaging materials and products will compost satisfactorily in large-scale aerobic municipal or industrial composting where maximum throughput is a high priority and where intermediate stages of biodegradation must not be apparent to the end user for aesthetic reasons.  
1.6 This specification is technically equivalent to ISO 18606.1.7.  
1.7 The values stated in SI units are to be regarded as standard. No other units of measurement are included in this standard.  
1.8 This standard does not purport to address all of the safety concerns, if any, associated with its use. It is the responsibility of the user of this standard to establish appropriate safety, health, and environmental practices and determine the applicability of regulatory limitations prior to use.  
1.9 This international standard was developed in accordance with internationally recognized principles on standardization established in the Decision on Principles for the Development of International Standards, Guides and Recommendations issued by the World Trade Organization Technical Barriers to Trade (TBT) Committee.

General Information

• Status: Published
• Publication Date: 31-Oct-2022
• ICS: 13.030.99 - Other standards related to wastes
• ICS: 55.040 - Packaging materials and accessories
• Technical Committee: D10 - Packaging
• Drafting Committee: D10.19 - Sustainability & Recycling

Relations

• Refers: ASTM D6866-24 - Standard Test Methods for Determining the Biobased Content of Solid, Liquid, and Gaseous Samples Using Radiocarbon Analysis
• Effective Date: 01-Feb-2024
• Refers: ASTM D6866-18 - Standard Test Methods for Determining the Biobased Content of Solid, Liquid, and Gaseous Samples Using Radiocarbon Analysis
• Effective Date: 01-Mar-2018
• Refers: ASTM D6866-16 - Standard Test Methods for Determining the Biobased Content of Solid, Liquid, and Gaseous Samples Using Radiocarbon Analysis
• Effective Date: 01-Jun-2016
• Refers: ASTM D1968-15 - Standard Terminology Relating to Paper and Paper Products
• Effective Date: 01-Oct-2015
• Refers: ASTM D6866-12 - Standard Test Methods for Determining the Biobased Content of Solid, Liquid, and Gaseous Samples Using Radiocarbon Analysis
• Effective Date: 01-Apr-2012
• Refers: ASTM D6866-11 - Standard Test Methods for Determining the Biobased Content of Solid, Liquid, and Gaseous Samples Using Radiocarbon Analysis
• Effective Date: 01-Apr-2011
• Refers: ASTM D5338-11 - Standard Test Method for Determining Aerobic Biodegradation of Plastic Materials Under Controlled Composting Conditions, Incorporating Thermophilic Temperatures
• Effective Date: 01-Apr-2011
• Refers: ASTM D996-10a - Standard Terminology of Packaging and Distribution Environments
• Effective Date: 01-Dec-2010
• Refers: ASTM D6866-10 - Standard Test Methods for Determining the Biobased Content of Solid, Liquid, and Gaseous Samples Using Radiocarbon Analysis
• Effective Date: 01-Jul-2010
• Refers: ASTM D6866-08 - Standard Test Methods for Determining the Biobased Content of Solid, Liquid, and Gaseous Samples Using Radiocarbon Analysis
• Effective Date: 01-Aug-2008
• Refers: ASTM D6866-06a - Standard Test Methods for Determining the Biobased Content of Natural Range Materials Using Radiocarbon and Isotope Ratio Mass Spectrometry Analysis
• Effective Date: 15-Oct-2006
• Refers: ASTM D6866-06 - Standard Test Methods for Determining the Biobased Content of Natural Range Materials Using Radiocarbon and Isotope Ratio Mass Spectrometry Analysis
• Effective Date: 15-May-2006
• Refers: ASTM D6866-05 - Standard Test Methods for Determining the Biobased Content of Natural Range Materials Using Radiocarbon and Isotope Ratio Mass Spectrometry Analysis
• Effective Date: 01-Mar-2005
• Refers: ASTM D6866-04a - Standard Test Methods for Determining the Biobased Content of Natural Range Materials Using Radiocarbon and Isotope Ratio Mass Spectrometry Analysis
• Effective Date: 01-Jul-2004
• Refers: ASTM D996-04 - Standard Terminology of Packaging and Distribution Environments
• Effective Date: 01-Apr-2004

Overview

ASTM D8410-22 sets the standard specification for the evaluation of cellulosic-fiber-based packaging materials and products for compostability in municipal or industrial aerobic composting facilities. Developed by ASTM International, this standard applies to materials such as paper, paperboard, molded fiber, and similar packaging designed to decompose under thermophilic, aerobic composting conditions typically found in large-scale facilities. The specification provides guidance on labeling these materials as “compostable” and ensures that products meet environmental and performance requirements, facilitating sustainable packaging solutions in the food, landscape, and general packaging sectors.

Key Topics

• Applicable Materials: The standard covers uncoated and coated cellulosic-fiber-based packaging, including items made from cellulosic pulp, corrugated materials, containerboard, paper, paperboard, and molded fiber. Laminated or extruded thermoplastics on cellulosic substrates are excluded.
• Compostability Requirements: To be labeled as compostable, products must:
  • Disintegrate so they are not visually distinguishable from finished compost after processing
  • Biodegrade by converting at least 90% of their organic carbon to carbon dioxide within specified timeframes, or be demonstrably biobased and inherently biodegradable
  • Not adversely affect plant growth or introduce harmful levels of heavy metals or toxins during composting
• Testing and Evaluation: The specification prescribes recognized laboratory methods to assess disintegration, biodegradation, and ecotoxicity, referencing key international and U.S. standards.
• Labeling Guidance: Products meeting the requirements may be labeled as “compostable in municipal or industrial aerobic composting facilities,” provided qualifiers regarding facility availability are included as per Federal Trade Commission guidelines.

Applications

ASTM D8410-22 is highly relevant for manufacturers, brand owners, certification bodies, and compost operators seeking to:

• Develop Sustainable Packaging: Ensure cellulosic packaging materials are truly compostable in large-scale, controlled composting settings, aligning with sustainability goals.
• Support Food and Yard Waste Diversion: Facilitate the use of certified compostable packaging for food service, grocery, and landscape applications, thus diverting more organic waste from landfill.
• Meet Regulatory and Market Demands: Provide consumers and customers with confidence in compostable claims, meeting local, national, and global requirements for environmental marketing.
• Enhance Compost Quality: Ensure that compost produced from packaging materials supports healthy plant growth and contains minimal contaminants.

Related Standards

Several national and international standards intersect with or complement ASTM D8410-22:

• ASTM D5338: Test method for aerobic biodegradation of plastics under controlled composting conditions.
• ASTM D6866: Test methods for determining biobased content through radiocarbon analysis.
• ISO 18606: Packaging and the environment - organic recycling (technically equivalent to ASTM D8410-22).
• ISO 16929 and ISO 20200: Methods for determining disintegration and biodegradation of packaging and plastics under composting conditions.
• EN 13432: European standard for packaging recoverable through composting and biodegradation, detailing test schemes and acceptance criteria.
• OECD Guideline 208: Plant growth test for assessing compost phytotoxicity.

Conclusion

ASTM D8410-22 plays a vital role in advancing compostable packaging by setting rigorous standards for cellulosic-fiber-based products. By specifying clear criteria and recognized test methods, the standard enables the responsible labeling and use of compostable packaging, supporting circular economy initiatives and the production of high-quality compost. Compliance with ASTM D8410-22 facilitates market access, consumer trust, and measurable progress toward sustainable packaging goals.

Standards Content (Sample)

This international standard was developed in accordance with internationally recognized principles on standardization established in the Decision on Principles for the
Development of International Standards, Guides and Recommendations issued by the World Trade Organization Technical Barriers to Trade (TBT) Committee.
Designation: D8410 −22
Standard Specification for
Evaluation of Cellulosic-Fiber-Based Packaging Materials
and Products for Compostability in Municipal or Industrial
Aerobic Composting Facilities
This standard is issued under the fixed designation D8410; the number immediately following the designation indicates the year of
original adoption or, in the case of revision, the year of last revision. A number in parentheses indicates the year of last reapproval. A
superscript epsilon (´) indicates an editorial change since the last revision or reapproval.
1. Scope 1.7 The values stated in SI units are to be regarded as
standard. No other units of measurement are included in this
1.1 This specification covers cellulosic-fiber-based packag-
standard.
ing materials and products associated with food, landscape
1.8 This standard does not purport to address all of the
waste, and other compost feedstocks, which are intended to be
safety concerns, if any, associated with its use. It is the
composted under aerobic conditions in municipal and indus-
responsibility of the user of this standard to establish appro-
trial composting facilities, where thermophilic temperatures
priate safety, health, and environmental practices and deter-
are achieved.
mine the applicability of regulatory limitations prior to use.
1.2 This specification covers cellulosic-based uncoated and
1.9 This international standard was developed in accor-
coated packaging materials and products and covers whole
dance with internationally recognized principles on standard-
packaging products. Products covered in this specification
ization established in the Decision on Principles for the
include cellulosic fiber-based products produced from cellu-
Development of International Standards, Guides and Recom-
losic pulp, corrugated materials, containerboard, paper,
mendations issued by the World Trade Organization Technical
paperboard, and molded fiber.
Barriers to Trade (TBT) Committee.
1.3 Thisspecificationexcludesenditemswherethermoplas-
2. Referenced Documents
tic polymer is laminated or extruded to cellulosic substrates.
2.1 ASTM Standards:
1.4 This specification is intended to establish the require-
D996 Terminology of Packaging and Distribution Environ-
ments for labeling cellulosic-fiber-based packaging materials
ments
and products as “compostable in aerobic municipal and indus-
D1968 Terminology Relating to Paper and Paper Products
trial composting facilities” in accordance with the guidelines
2 D5338 Test Method for Determining Aerobic Biodegrada-
issued by the Federal Trade Commission, provided the label
tion of Plastic Materials Under Controlled Composting
includes proper qualifications as to the availability of such
Conditions, Incorporating Thermophilic Temperatures
facilities.
D6866 Test Methods for Determining the Biobased Content
1.5 The properties in this specification are those required to
of Solid, Liquid, and Gaseous Samples Using Radiocar-
determine if packaging materials and products will compost
bon Analysis
satisfactorily in large-scale aerobic municipal or industrial
2.2 Organization for Economic Development (OECD) Stan-
composting where maximum throughput is a high priority and
dard:
where intermediate stages of biodegradation must not be
OECD Guideline 208 Terrestrial Plants, Growth Test
apparent to the end user for aesthetic reasons.
2.3 European Standards (EN):
EN 13432 Packaging-Requirements for Packaging Recover-
1.6 This specification is technically equivalent to ISO
18606.1.7. able through Composting and Biodegradation-Test
For referenced ASTM standards, visit the ASTM website, www.astm.org, or
This specification is under the jurisdiction of ASTM Committee D10 on contact ASTM Customer Service at [e-mail]. For Annual Book of ASTM
PackagingandisthedirectresponsibilityofSubcommitteeD10.19onSustainability Standards volume information, refer to the standard’s Document Summary page on
& Recycling. the ASTM website.
Current edition approved Nov. 1, 2022. Published November 2022. Originally Available from Organisation for Economic Cooperation and Development
approved in 2021. Last previous edition approved in 2021 as D8410 – 21. DOI: (OECD), 2 rue André Pascal, F-75775, Paris Cedex 16, France, http://
10.1520/D8410-22. www.oecd.org.
2 5
Guidelines for the Use of Environmental Marketing Claims, Federal Trade Available fromAmerican National Standards Institute (ANSI), 25 W. 43rd St.,
Commission, Washington, DC, 1992. 4th Floor, New York, NY 10036, http://www.ansi.org.
Copyright © ASTM International, 100 Barr Harbor Drive, PO Box C700, West Conshohocken, PA 19428-2959. United States
D8410 − 22
Scheme and Evaluation Criteria for the Final Acceptance 3.2.6 package component, n—the identifiable parts that
of Packaging together constitute the packaging product. Examples of com-
ponents include paper, paperboard, inks, and adhesives.
2.4 ISO Standards:
ISO 14855 Evaluation of the ultimate aerobic biodegradabil- 3.2.7 packaging product, n—the final article in the form in
ity and disintegration of plastics under controlled com- which it is to be used as packaging and ultimately composted.
posting conditions — Method by analysis of evolved The product may consist of a single or multiple component(s).
carbon dioxide
3.2.8 positive control, n—a reference material known to be
ISO 16929 Determination of the degree of disintegration of
biodegradable used to validate the viability of the microbial
plastic materials under defined composting conditions in a
community, and to provide a comparison with the test material
pilot-scale test
under evaluation. The positive reference material is typically
ISO 18606 Packaging and the environment — Organic
microcrystalline cellulose.
recycling
3.2.9 thermophilic, adj—the high-temperature phase where
ISO 20200 Plastics — Determination of the degree of
certain microorganisms are active. Thermophilic micro-
disintegration of plastic materials under simulated com-
organisms begin to become active around 40 °C with highest
posting conditions in a laboratory-scale test
activity between 50 °C and 60 °C. Thermophilic microorgan-
2.5 Standard Methods for the Examination of Water and
isms begin to die off above 65 °C.
Wastewater:
3.2.10 volatile organic solids, n—determined by comparing
2540G Total, Fixed, and Volatile Solids in Solid and Semi-
the dry weight to the mass remaining after incineration at
solid Samples
550 °C which determines the amount of organic matter.
2.6 Government Standards:
USEPA Method 1684 Total, Fixed, and Volatile Solids in
4. Classification
Water, Solids, and Biosolids
4.1 This specification covers one type of packaging mate-
40 CFR Part 503.13 Standards for the Use or Disposal of
rial: cellulosic-fiber-based packaging, with or without
Sewage Sludge
additives, or adhesives.
3. Terminology
4.2 The packaging product is intended to be used to protect,
hold or transport contents that are or become desirable organic
3.1 Definitions—Terms appearing in this specification are
wastes for composting.
found in Terminologies D996 and D1968, unless otherwise
noted.
4.3 The purpose of this specification is to allow for the
identification of these packaging materials as satisfactorily
3.2 Definitions of Terms Specific to This Standard:
composting in commercial and municipal aerobic composting
3.2.1 additive, n pl—substances added to cellulosic fiber to
facilities. Products meeting the requirements outlined below
impart or enhance material properties or to improve production
shall be eligible to be labeled as “compostable in municipal or
efficiencies. Additives can be mixed and incorporated into or
industrialaerobiccompostingfacilities”inaccordancewiththe
applied to the surface of the cellulosic material as a coating.
guidelines issued by the FederalTrade Commission as long as
3.2.2 blank composts, n—compost generated without the
proper qualifications as to the availability of such facilities are
addition of the test material.
included on the label.
3.2.3 cellulosic, adj—material derived from or containing
cellulose.
5. Materials and Manufacture
3.2.4 materials of natural origin, n—chemically unmodified
5.1 For packaging components and products that are made
ligno-cellulosic and other naturally occurring organic
in multiple thicknesses or densities, only the thickest or most
materials, such as wood, wood fiber, cotton fiber, starch,
dense products need to be tested for disintegration as long as
recycled fiber pulp, or jute.
the chemical composition and structure remains otherwise the
3.2.5 mesophilic, adj—the moderate-temperature phase
same. It is presumed that lower thickness and densities of the
where certain microorganisms are active. Mesophilic micro-
same products will also compost satisfactorily.
organisms are primarily active up to 40 °C and then activity
5.2 If the packaging product is too large to be tested in its
trails off towards thermophilic temperatures.
entirety in the disintegration test, it is acceptable to take a
representative portion of that product, provided the thickest or
densest portions of the product are used.
Available from Standard Methods, http://www.standardmethods.org, (877)
5.3 If additives are present in test samples at a given dry
...

This document is not an ASTM standard and is intended only to provide the user of an ASTM standard an indication of what changes have been made to the previous version. Because
it may not be technically possible to adequately depict all changes accurately, ASTM recommends that users consult prior editions as appropriate. In all cases only the current version
of the standard as published by ASTM is to be considered the official document.
Designation: D8410 − 21 D8410 − 22
Standard Specification for
Evaluation of Cellulosic-Fiber-Based Packaging Materials
and Products for Compostability in Municipal or Industrial
Aerobic Composting Facilities
This standard is issued under the fixed designation D8410; the number immediately following the designation indicates the year of
original adoption or, in the case of revision, the year of last revision. A number in parentheses indicates the year of last reapproval. A
superscript epsilon (´) indicates an editorial change since the last revision or reapproval.
1. Scope
1.1 This specification covers cellulosic-fiber-based packaging materials and products associated with food, landscape waste, and
other compost feedstocks, which are intended to be composted under aerobic conditions in municipal and industrial composting
facilities, where thermophilic temperatures are achieved.
1.2 This specification covers cellulosic-based uncoated and coated packaging materials and products and covers whole packaging
products. Products covered in this specification include cellulosic fiber-based products produced from cellulosic pulp, corrugated
materials, containerboard, paper, paperboard, and molded fiber.
1.3 This specification excludes end items where thermoplastic polymer is laminated or extruded to cellulosic substrates.
1.4 This specification is intended to establish the requirements for labeling cellulosic-fiber-based packaging materials and products
as “compostable in aerobic municipal and industrial composting facilities” in accordance with the guidelines issued by the Federal
Trade Commission, provided the label includes proper qualifications as to the availability of such facilities.
1.5 The properties in this specification are those required to determine if packaging materials and products will compost
satisfactorily in large-scale aerobic municipal or industrial composting where maximum throughput is a high priority and where
intermediate stages of biodegradation must not be apparent to the end user for aesthetic reasons.
1.6 This specification is technically equivalent to ISO 18606.1.7.
1.7 The values stated in SI units are to be regarded as standard. No other units of measurement are included in this standard.
1.8 This standard does not purport to address all of the safety concerns, if any, associated with its use. It is the responsibility
of the user of this standard to establish appropriate safety, health, and environmental practices and determine the applicability of
regulatory limitations prior to use.
1.9 This international standard was developed in accordance with internationally recognized principles on standardization
established in the Decision on Principles for the Development of International Standards, Guides and Recommendations issued
by the World Trade Organization Technical Barriers to Trade (TBT) Committee.
This specification is under the jurisdiction of ASTM Committee D10 on Packaging and is the direct responsibility of Subcommittee D10.19 on Sustainability & Recycling.
Current edition approved Oct. 1, 2021Nov. 1, 2022. Published November 2021November 2022. Originally approved in 2021. Last previous edition approved in 2021 as
D8410 – 21. DOI: 10.1520/D8410-21.10.1520/D8410-22.
Guidelines for the Use of Environmental Marketing Claims, Federal Trade Commission, Washington, DC, 1992.
Copyright © ASTM International, 100 Barr Harbor Drive, PO Box C700, West Conshohocken, PA 19428-2959. United States
D8410 − 22
2. Referenced Documents
2.1 ASTM Standards:
D996 Terminology of Packaging and Distribution Environments
D1968 Terminology Relating to Paper and Paper Products
D5338 Test Method for Determining Aerobic Biodegradation of Plastic Materials Under Controlled Composting Conditions,
Incorporating Thermophilic Temperatures
D6866 Test Methods for Determining the Biobased Content of Solid, Liquid, and Gaseous Samples Using Radiocarbon Analysis
2.2 Organization for Economic Development (OECD) Standard:
OECD Guideline 208 Terrestrial Plants, Growth Test
2.3 European Standards (EN):
EN 13432 Packaging-Requirements for Packaging Recoverable through Composting and Biodegradation-Test Scheme and
Evaluation Criteria for the Final Acceptance of Packaging
2.4 ISO Standards:
ISO 14855 Evaluation of the ultimate aerobic biodegradability and disintegration of plastics under controlled composting
conditions — Method by analysis of evolved carbon dioxide
ISO 16929 Determination of the degree of disintegration of plastic materials under defined composting conditions in a
pilot-scale test
ISO 18606 Packaging and the environment — Organic recycling
ISO 20200 Plastics — Determination of the degree of disintegration of plastic materials under simulated composting conditions
in a laboratory-scale test
2.5 Standard Methods for the Examination of Water and Wastewater:
2540G Total, Fixed, and Volatile Solids in Solid and Semisolid Samples
2.6 Government Standards:
USEPA Method 1684 Total, Fixed, and Volatile Solids in Water, Solids, and Biosolids
40 CFR Part 503.13 Standards for the Use or Disposal of Sewage Sludge
3. Terminology
3.1 Definitions—Terms appearing in this specification are found in Terminologies D996 and D1968, unless otherwise noted.
3.2 Definitions of Terms Specific to This Standard:
3.2.1 additive, n pl—substances added to cellulosic fiber to impart or enhance material properties or to improve production
efficiencies. Additives can be mixed and incorporated into or applied to the surface of the cellulosic material as a coating.
3.2.2 blank composts, n—compost generated without the addition of the test material.
3.2.3 cellulosic, adj—material derived from or containing cellulose.
3.2.4 materials of natural origin, n—chemically unmodified ligno-cellulosic and other naturally occurring organic materials, such
as wood, wood fiber, cotton fiber, starch, recycled fiber pulp, or jute.
3.2.5 mesophilic, adj—the moderate-temperature phase where certain microorganisms are active. Mesophilic micro-organisms are
primarily active up to 40 °C and then activity trails off towards thermophilic temperatures.
3.2.6 package component, n—the identifiable parts that together constitute the packaging product. Examples of components
include paper, paperboard, inks, and adhesives.
For referenced ASTM standards, visit the ASTM website, www.astm.org, or contact ASTM Customer Service at [e-mail]. For Annual Book of ASTM Standards
volume information, refer to the standard’s Document Summary page on the ASTM website.
Available from Organisation for Economic Cooperation and Development (OECD), 2 rue André Pascal, F-75775, Paris Cedex 16, France, http://www.oecd.org.
Available from American National Standards Institute (ANSI), 25 W. 43rd St., 4th Floor, New York, NY 10036, http://www.ansi.org.
Available from Standard Methods, http://www.standardmethods.org, [phone] or American Public Health Association (APHA), P.O. Box 933019, Atlanta, GA
31193-3019, (888) 320-APHA (2742), http://www.apha.org/publications/pubscontact.
Available from United States Environmental Protection Agency (EPA), William Jefferson Clinton Bldg., 1200 Pennsylvania Ave., NW, Washington, DC 20460,
https://www.epa.gov/sites/production/files/2015-10/documents/method_1684_draft_2001.pdf
Available from U.S. Government Publishing Office (GPO), 732 N. Capitol St., NW, Washington, DC 20401, http://www.gpo.gov.
D8410 − 22
3.2.7 packaging product, n—the final article in the form in which it is to be used as packaging and ultimately composted. The
product may consist of a single or multiple component(s).
3.2.8 positive control, n—a reference material known to be biodegradable used to validate the viability of the microbial
community, and to provide a comparison with the test material under evaluation. The positive reference material is typically
microcrystalline cellulose.
3.2.9 thermophilic, adj—the high-temperature phase where certain microorganisms are active. Thermophilic micro-organisms
begin to become active around 40 °C with highest activity between 50 °C and 60 °C. Thermophilic microorganisms begin to die
off above 65 °C.
3.2.10 volatile organic solids, n—determined by comparing the dry weight to the mass remaining after incineration at 550 °C
which determines the amount of organic matter.
4. Classification
4.1 This specification covers one type of packaging material: cellulosic-fiber-based packaging, with or without additives, or
adhesives.
4.2 The packaging product is intended to be used to protect, hold or transport contents that are or become desirable organic wastes
for composting.
4.3 The purpose of this specification is to allow for the identification of these packaging materials as satisfactorily composting in
commercial and municipal aerobic composting facilities. Products meeting the requirements outlined below shall be eligible to be
labeled as “compostable in municipal or industrial aerobic composting facilities” in accordance with the guidelines issued by the
Federal Trade Commission as long as proper qualifications as to the availability of such facilities are included on the label.
5. Materials and Manufacture
5.1 For packaging components and products that are made in multiple th
...