In its Plastics Strategy, published in January this year, the EU Commission announced it had tasked ECHA to collect background information and review the scientific basis for taking regulatory action at the EU level regarding intentionally added microplastics in products.
CHEM Trust has participated in the first step of the process by responding to ECHA’s call for evidence and information that closed on 11 May 2018. ECHA will review the evidence presented and then plans to submit a restriction proposal to the EU Commission by mid-January 2019. The proposal will subsequently be discussed and amended by ECHA scientific committees before being submitted to public consultation later in 2019.
CHEM Trust’s concerns about microplastics
CHEM Trust has previously highlighted concerns about microplastics because they contribute to plastic pollution on land and in the ocean, and represent a hazard to wildlife and human health.
Some microplastics are deliberately produced and added to products – it is these microplastics that are targeted by the planned EU restriction. However, a larger quantity of micro plastic is released to the environment from other products, for example from vehicle tyres.
Microplastics are released to the environment through waterways, as they can pass through the filtration system of wastewater treatment plants, or they can be carried by the wind. In the EU alone, it is estimated that between 75 000 and 300 000 tonnes of microplastics are released into the environment each year.
Microplastics, as with most oil- and bio-based plastics, do not degrade in natural conditions. They therefore accumulate and persist in the environment, even leading to contamination of remote regions far away from exposure sources, as recently reported from Artic Sea ice. Moreover, their small size means that they can easily be ingested by various organisms, even plankton, and they further bioaccumulate through the food chain finally ending up on our plates.
Microplastics have the potential to carry hazardous chemicals and transfer them to organisms that ingest them. Some hazardous chemicals may be part of the original plastic, while others may be concentrated from the environment, even if they are phased out from sale but still present in the environment.
CHEM Trust’s response to ECHA’s call for evidence
CHEM Trust made the following three main comments in its response:
- CHEM Trust welcomes the fact that ECHA’s microplastics working definition does not set a lower size limit, meaning nanoplastics are covered. There is an increasing amount of evidence showing that plastic particles smaller than 10 microns, after ingestion, can migrate from the guts to the circulatory system, tissues and organs like the brain, causing physiological damage and/or behavioural disorders. This process, called translocation, also leads to bioaccumulation of microplastics in the organism.
- Microplastic particles have characteristic properties which are equivalent to those of vPvB (very Persistent and very Bioaccumulative) substances. CHEM Trust supports an approach that would treat microplastics as vPvB substances or PBT (Persistent, Bioaccumulative and Toxic) substances, which require emission reductions and minimisation in the REACH context.
- We also propose that it would be an important complementary measure to finally include registration requirements for polymers in REACH. This would help close knowledge gaps regarding hazard and exposure data of polymers in general, and also increase the information in the supply chain.
Ninja Reineke, Head of Science at CHEM Trust said:
“The use of microplastics in consumer products reaching the environment was a pretty bad idea in the first place. Removing them once they are out there is basically impossible. The planned restriction is very important, but it’s only a first step among many others that are needed to stop plastic pollution at source.”
Limitation of the current bans on microbeads in some EU member states
Several EU member states have recently introduced bans on some intentionally added microplastics, like Italy, France and the UK this January, and some other are working on restrictions. However, these bans only apply to microbeads present in rinse-off cosmetics, leaving many sectors able to still intentionally release microplastics into the environment. Microplastics are also used in detergents, paints, nutrient pellets in agriculture and in products used in the oil and gas industry. And let’s not forget glitter!
CHEM Trust acknowledges that the EU’s proposed restriction is broader in scope than the bans currently in place, as it aims to encompass intentionally added microplastics in products of any kind.