EEB and ClientEarth Submission to the call for evidence

The EEB and ClientEarth submission to ECHA argues for a comprehensive restriction on intentionally added microplastics, warning that ECHA may prematurely narrow the scope of restrictions through unjustified derogations. The authors advocate for treating microplastics as non-threshold substances, similar to vPvB or PBT substances, due to their persistence and ability to bioaccumulate. They highlight the role of microplastics in transporting persistent organic pollutants (POPs) and leaching endocrine-disrupting additives into the environment and human body. The submission supports a broad definition of microplastics that includes liquid polymers and compostable bioplastics, and emphasizes the need to consider the high exposure risks associated with nanoplastics.

• EEB and ClientEarth express concern that ECHA may narrow the scope of microplastic restrictions by granting derogations based on the 'absence of risk' or a lack of technically and economically feasible alternatives, which they argue is an illegal interpretation of the REACH Regulation.
• The authors argue that microplastics should be treated as non-threshold substances in risk assessments, following the approach used for very Persistent, very Bioaccumulative (vPvB) or Persistent, Bioaccumulative and Toxic (PBT) substances, because specific dose-response relationships cannot currently be established for the aquatic environment.

APA

ClientEarth (n.d.). EEB and ClientEarth Submission to the call for evidence. https://www.clientearth.org/media/qnvg1odd/clientearth-and-eeb-joint-submission-to-echas-call-for-evidence-on-microplastics-coll-en.pdf

Chicago

ClientEarth. EEB and ClientEarth Submission to the call for evidence. n.d. https://www.clientearth.org/media/qnvg1odd/clientearth-and-eeb-joint-submission-to-echas-call-for-evidence-on-microplastics-coll-en.pdf.

Wikipedia

{{cite press release |author=ClientEarth |title=EEB and ClientEarth Submission to the call for evidence |url=https://www.clientearth.org/media/qnvg1odd/clientearth-and-eeb-joint-submission-to-echas-call-for-evidence-on-microplastics-coll-en.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{clientearthndeeb, author = {{ClientEarth}}, title = {{EEB and ClientEarth Submission to the call for evidence}}, publisher = {ClientEarth}, url = {https://www.clientearth.org/media/qnvg1odd/clientearth-and-eeb-joint-submission-to-echas-call-for-evidence-on-microplastics-coll-en.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }