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ETRA Response to ECHA Consultation on Microplastics

ETRA Response to ECHA Consultation on Microplastics Image 1

On 20 September 2019, ECHA closed the Public Consultation that it had launched on the Restriction proposal of intentionally added Micro-plastics. This was the first consultation step of a long and complex procedure that had begun in 2018 after the EU published its plastics strategy in February 2018.

The Commission requested that ECHA develop a restriction proposal for ‘microplastics that are intentionally added to consumer and professional products’. Then ECHA (the Dossier Submitter) submitted two restriction proposals on intentionally added microplastics in a variety of consumer and professional products.

According to the proposal:

  • Polymers shall not, from (approx. 2021), be placed on the market as a substance on its own or in a mixture as a micro-plastic in a concentration equal to or greater than 0.01% w/w
    • ‘micro-plastic’ means a material consisting of solid polymer-containing particles, to which additives or other substances may have been added, and where ≥ 1% w/w of particles have (i) all dimensions 1nm ≤ x ≤ 5mm, or (ii), for fibres, a length of 3nm ≤ x ≤ 15mm and length to diameter ratio of >3
    • Infill material fulfils the definition of microplastic, thus falls under the restriction proposal

The Public consultation of the report started on 20 March 2019 and it was held open, for 6 months, until 20th September. The next steps of the procedure will be:

  • An Opinion from RAC is due in March 2020
  • A Public consultation on SEAC’s draft opinion begins during the spring of 2020
  • SEAC’s final opinion is expected in June 2020
  • The Commission decision is expected in 2021

Some thousands of response have been submitted from many different sectors and bodies. ETRA submitted its Response (Number 2446) which included a range of critical issues :

  • The inclusion of infill materials in the micro-plastic definition is misleading and contradictory with the definition itself and with several parts of the Restriction Report.
  • Specifically, recycled rubber granulate used as infill material are not micro-scopic. But there are other more evident discrepancies.
  • ETRA defined 10 reasons why SBR infill material should not be included.
  • A more precise reading of the definition of ‘micro-plastic’ in the Restriction Report could eliminate ‘infill material’ from the discussion and could possibly lead to derogation.

The Response is the result of team work by the ETRA sport Committee, with a secondary objective, i.e., to raise points for reflection that could help other stakeholders and scientific bodies to enter into the debate.

The ETRA Response is available here below for downloading.

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