The European Chemicals Agency (ECHA) has published SEAC’s draft opinion on the Annex XV dossier proposing restrictions on intentionally-added microplastics and has opened it up to consultation.
SEAC, the Committee for Socio-economic Analysis, prepares the opinions of ECHA related to the socio-economic impact of possible legislative actions.
The intentionally-added microplastics dossier was supported by the RAC, ECHA’s peer review panel for risk assessment, last month.
RAC’s opinion recommended the following: that it a) wanted to see greater evidence that ‘biodegradable’ polymers (which are excluded from the restriction) are biodegradable in the environment; and b) that there should be no lower size limit in the definition of a microplastic (the ECHA had proposed a lower size limit of 100nm to avoid technical problems from an analytical standpoint).
SEAC's draft opinion: Key points
SEAC’s newly-released opinion likewise supports the proposed restriction on intentionally-added microplastics as the most appropriate EU-wide measure to address the identified risks, and likewise supports RAC’s stance that there should be no lower size limit in the definition of ‘microplastic’.
However, to ensure that the proposed restriction is implementable and enforceable, SEAC further acknowledged the necessity for a temporary lower size limit of 100nm.
SEAC estimates that reformulation costs associated with the ban would be about €9.3bn over 20 years across the cosmetics industry, as well as agriculture/horticulture, detergents and maintenance products.
As microplastics alternatives are generally higher priced, SEAC additionally estimates raw materials costs to industry to be €200m over 20 years.
When it comes to cosmetics, SEAC said it expected the cost per reformulation for cosmetics in particular to be “substantial”.
As such, for leave-on cosmetics that are mainly disposed via solid waste, SEAC noted that instead of a ban other measures to manage microplastic emissions, such as informing consumers on proper use and disposal could be appropriate considering their relatively low contribution to overall releases. However, these measures would not be as effective as a ban.
It expects more information on this option will be submitted in the consultation.
The consultation period began yesterday, 1 July, and interested parties are invited to submit their comments until 1 September 2020.
Peter Simpson, Senior Scientific Officer at ECHA, said that, following this consultation period, SEAC will “take a few months to digest all of the information that has come in” and potentially agree a final opinion in December 2020.
Once the opinions are adopted, the proposal and opinions will be sent to the European Commission for it to reach a political agreement on the proposal, a step that could take up to a year and a half.
When it comes to the ban’s environmental impact, Simpson told Cosmetics Business: “We’ve estimated that in terms of our restriction across all sectors that it affects, that it would prevent the release of about 500,000 tonnes of microplastics over the next 20 years.”
Current emissions of releases are 42,000 tonnes per year. This, he added, is equivalent to an area six times that of the largest existing plastic ‘garbage patch’ in our oceans.