The road to an effective EU restriction of intentionally-added microplastics

The document analyzes the ECHA proposal to restrict intentionally added microplastics under the REACH Regulation, arguing that the current proposal is weakened by excessive derogations and long transition periods. It advocates for a broad scope that includes nanoplastics and soluble polymers, rejects exemptions for allegedly biodegradable plastics and sport pitch infill, and calls for stricter reporting requirements for plastic pellets to prevent environmental leakage.

• The document argues that the restriction should have no lower size limit to include nanoplastics, as they are expected to be more harmful than microplastics due to an increased surface/volume ratio and could lead to 'nonsensical substitutions'.
• The authors oppose derogations for allegedly biodegradable microplastics, stating that persistence is not the only concern and that current testing schemes (specifically Group 4 ISO tests) do not measure biodegradation under 'environmentally representative testing conditions' or provide a 'half-life'.
• The paper recommends a complete ban on rubber granules used as infill in sport pitches after a six-year transition period, noting that these are the largest contributors to intentionally added microplastic releases in the EU.
• The authors call for the removal of the derogation for water-soluble polymers, arguing that they pose risks due to their 'persistency, mobility and toxicity' and that alternatives are already available.
• The document criticizes the proposed reporting requirements for plastic pellets as too weak, recommending that they be treated in a separate provision that requires reporting of quantities handled at the site-level and a reduction of the transition period from 36 to 24 months.
• The paper argues against long transition periods for non-essential uses, specifically calling for no transition periods for rinse-off and leave-on cosmetics, fragrance encapsulation in detergents, and 'air care' products.

APA

Bernard, A., Romano, D., Vitali, E., Mongodin, F., Haut, G., Duguy, H., Berg, M., Prabhakar, M., & Gammage, T. (2020). The road to an effective EU restriction of intentionally-added microplastics. ClientEarth. https://www.clientearth.org/media/cbthksfa/the_road_to_an_effective_eu_restriction_of_intentionally-added_microplastics.pdf

Chicago

Bernard, Alice, Dolores Romano, Elise Vitali, Frédérique Mongodin, Gaëlle Haut, Hélène Duguy, Madeleine Berg, Madhuri Prabhakar, and Tom Gammage. The road to an effective EU restriction of intentionally-added microplastics. ClientEarth, 2020. https://www.clientearth.org/media/cbthksfa/the_road_to_an_effective_eu_restriction_of_intentionally-added_microplastics.pdf.

Wikipedia

{{cite press release |last1=Bernard |first1=Alice |last2=Romano |first2=Dolores |last3=Vitali |first3=Elise |last4=Mongodin |first4=Frédérique |last5=Haut |first5=Gaëlle |last6=Duguy |first6=Hélène |last7=Berg |first7=Madeleine |last8=Prabhakar |first8=Madhuri |last9=Gammage |first9=Tom |title=The road to an effective EU restriction of intentionally-added microplastics |publisher=ClientEarth |date=16 November 2020 |url=https://www.clientearth.org/media/cbthksfa/the_road_to_an_effective_eu_restriction_of_intentionally-added_microplastics.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{bernard2020road, author = {Bernard, Alice and Romano, Dolores and Vitali, Elise and Mongodin, Frédérique and Haut, Gaëlle and Duguy, Hélène and Berg, Madeleine and Prabhakar, Madhuri and Gammage, Tom}, title = {{The road to an effective EU restriction of intentionally-added microplastics}}, publisher = {ClientEarth}, year = {2020}, month = nov, url = {https://www.clientearth.org/media/cbthksfa/the_road_to_an_effective_eu_restriction_of_intentionally-added_microplastics.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }