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ClientEarth supports ECHA's broad scope to restrict intentionally added microplastics but criticizes specific derogations and long transitional periods. The organization highlights that fertilisers account for 58% of microplastic emissions and argues that the proposed timelines for phasing out non-biodegradable polymers are too slow given the permanent persistence of these particles in the environment.

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  • ClientEarth supports the inclusive scope of the ECHA Proposal because it covers all sources of intentionally added microplastics regardless of sector or use, which is necessary due to the widespread use of these particles and their associated toxicological and environmental hazards.
  • ECHA estimates that approximately 36,000 tonnes of intentionally added microplastics are released into the environment annually under foreseeable conditions of use, a volume compared to six times the size of the 'Great Pacific Garbage Patch'.
  • The exclusion of fertilising products from the restriction is a major concern because fertilisers represent 58% of total microplastic emissions and are the primary source of such pollution.
  • ClientEarth argues that the timeline for phasing out microplastics in CE-marked fertilisers is inadequate, as biodegradability criteria may not be developed until 2026, and non-biodegradable polymers might persist until 2028 in the worst-case scenario.
  • Certain derogations based on the assumption that no polymers will be emitted to the environment are viewed as unjustified because the Proposal simultaneously requires users to report releases and follow instructions to minimise them, implying that releases are likely.
  • The proposed transitional periods, ranging from 2 to 6 years, are criticized as being vaguely justified and disproportionate to the risk, particularly for the agricultural sector where non-degradable polymers in control release fertilisers (CRFs) are emitted 100% into the environment.

Cite the original document

APA
ClientEarth (2019). Tackling intentionally added microplastics. https://www.clientearth.org/media/plcjws24/clientearths-contribution-to-the-public-consultation-on-echas-proposal-to-restrict-intentionally-added-microplastic-ce-en.pdf
Chicago
ClientEarth. Tackling intentionally added microplastics. 2019. https://www.clientearth.org/media/plcjws24/clientearths-contribution-to-the-public-consultation-on-echas-proposal-to-restrict-intentionally-added-microplastic-ce-en.pdf.
Wikipedia
{{cite press release |author=ClientEarth |title=Tackling intentionally added microplastics |date=May 2019 |url=https://www.clientearth.org/media/plcjws24/clientearths-contribution-to-the-public-consultation-on-echas-proposal-to-restrict-intentionally-added-microplastic-ce-en.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}
BibTeX
@misc{clientearth2019tackling, author = {{ClientEarth}}, title = {{Tackling intentionally added microplastics}}, publisher = {ClientEarth}, year = {2019}, month = may, url = {https://www.clientearth.org/media/plcjws24/clientearths-contribution-to-the-public-consultation-on-echas-proposal-to-restrict-intentionally-added-microplastic-ce-en.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }

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