COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT REPORT Combatting microplastic pollution in the European Union Accompanying the document Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on preventing plastic pellet losses to reduce microplastic pollution

EN EN
EUROPEAN
COMMISSION
Brussels, 16.10.2023
SWD(2023) 332 final
PART 1/3
COMMISSION STAFF WORKING DOCUMENT
IMPACT ASSESSMENT REPORT
Combatting microplastic pollution in the European Union
Accompanying the document
Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE
COUNCIL
on preventing plastic pellet losses to reduce microplastic pollution
{COM(2023) 645 final} - {SEC(2023) 346 final} - {SWD(2023) 330 final} -
{SWD(2023) 333 final}
Offentligt
KOM (2023) 0645 - SWD-dokument
Europaudvalget 2023
1
TABLES OF CONTENTS
TABLES OF CONTENTS…………………………………………………………………………………....1
TABLES OF CONTENTS OF THE ANNEXES…………………………………………………………….2
GLOSSARY………………………………………………………………………………………………….3
1 INTRODUCTION: POLITICAL AND LEGAL CONTEXT............................................................... 6
2 PROBLEM DEFINITION .................................................................................................................... 9
2.1 What are the problems related to microplastics in general? ...................................................... 9
2.2 What are the problems related to plastic pellets? .....................................................................12
2.3 The impacts of pellet losses......................................................................................................18
2.4 What are the problem drivers? .................................................................................................21
2.5 How likely is the problem to persist? .......................................................................................23
3 WHY SHOULD THE EU ACT? .........................................................................................................23
3.1 Legal basis................................................................................................................................23
3.2 Subsidiarity: Necessity of EU action........................................................................................24
3.3 Subsidiarity: Added value of EU action...................................................................................24
4 OBJECTIVES: WHAT IS TO BE ACHIEVED? ................................................................................24
4.1 General objectives....................................................................................................................24
4.2 Specific objectives....................................................................................................................25
5 WHAT ARE THE AVAILABLE POLICY OPTIONS? .....................................................................25
5.1 What is the baseline from which options are assessed? ...........................................................25
5.2 Description of policy options assessed in this impact assessment............................................32
5.3 Options discarded at an early stage ..........................................................................................35
5.4 The intervention logic ..............................................................................................................36
6 WHAT ARE THE IMPACTS OF THE POLICY OPTIONS? ............................................................37
6.1 Option 1: Mandatory standardised methodology to measure pellet losses...............................38
6.2 Option 2: Mandatory requirements to prevent and reduce pellet losses in a new EU law .......41
6.3 Option 3: Improved packaging for logistics of pellets .............................................................47
6.4 Option 4: EU target to reduce pellet losses ..............................................................................49
7 HOW DO THE OPTIONS COMPARE?.............................................................................................51
8 PREFERRED OPTION .......................................................................................................................54
8.1 Elements of the preferred option..............................................................................................54
8.2 Impacts of the preferred policy option .....................................................................................58
8.3 REFIT & administrative costs..................................................................................................62
8.4 Policy instrument......................................................................................................................62
9 HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED?...................................62
2
TABLES OF CONTENTS OF THE ANNEXES
ANNEX 1: PROCEDURAL INFORMATION
ANNEX 2 : STAKEHOLDER CONSULTATION (SYNOPSIS REPORT)
ANNEX 3: WHO IS AFFECTED AND HOW?
ANNEX 4: ANALYTICAL METHODS
ANNEX 5: COMPETITIVENESS CHECK
ANNEX 6: LEGISLATION AND ACTIONS RELEVANT TO REDUCING PELLET LOSSES TO THE EU
ENVIRONMENT
ANNEX 7: MICROPLASTICS AND PELLETS IN THE ENVIRONMENT
ANNEX 8: PROBLEM DEFINITION – PELLET LOSSES TO THE EU ENVIRONMENT
ANNEX 9: BASELINE
ANNEX 10: POLICY OPTIONS TO REDUCE PELLET LOSSES
ANNEX 11: IMPACTS OF POLICY OPTIONS TO REDUCE PELLET LOSSES
ANNEX 12: IMPACTS ON SMES
ANNEX 13: PRODCOM CODES USED TO QUANTIFY PELLET PRODUCTION, EXPORT AND IMPORT INTO
THE EU IN 2020
ANNEX 14: OTHER SOURCES OF MICROPLASTICS IDENTIFIED BUT NOT RETAINED
ANNEX 15: PRELIMINARY ANALYSIS OF THE MAIN SOURCES OF MICROPLASTIC EMISSIONS
3
Glossary
Term or
acronym
Meaning or definition
Microplastics Microplastics are small pieces of plastic, usually smaller than 5mm
Pellets Plastic pellets, also referred to as nurdles, nibs, preproduction pellets, and resin
pellets, are the starting material used for all plastic production worldwide. Pellets are
defined within ISO 472:2013 as “a small mass of preformed moulding material,
having relatively uniform dimensions in a given lot, used as feedstock in moulding
and extrusion operations”.
Pellet spill One-off escape of pellets from primary containment not necessarily resulting in loss
to the environment (if contained inside the operating boundary).
Pellet loss One-off or prolonged escape of pellets to the environment. The escape would
therefore result in loss outside the operating boundary into the environment (e.g.
water, soil).
Textiles In the context of this assessment, textiles refer to synthetic clothes made out of
chemically produced fibers that can be based on polymers produced by oil
distillation, such as polyester, acrylic, polyamide (nylon), acetate, and PPT
(polyparaphenylene terephthalamide i.e. Kevlar™).
Paints Paint means a pigmented or clear coating material, supplied in a liquid paste or
powder form, which, when applied to a substrate, forms an opaque film having
protective, decorative or specific technical properties and after application dries to a
solid, adherent and protective coating. It is a mixture of pigment (absent in the case
of vanishes), additives and binder (resin) in a solvent (organic solvent and/or water).
Most binders are synthetic polymers such as acrylic, alkyd, polyurethane, epoxy or
chlorinated rubber.
Detergent
capsules
These are small pouches containing highly concentrated detergent used in washing
machines and dishwashers. They are mostly made of dissolvable plastics such as
polyvinyl alcohol.
Geotextiles Geotextiles are a type of geosynthetics used for a variety of civil engineering
applications such as building roads, coastal protection, diking, flooding protection,
etc. They are primarily made of polymers such as polypropylene or polyester and are
mostly manufactured in two different forms woven and nonwoven.
CPR Construction Product Regulation
DDT Dichlorodiphenyltrichloroethane
EDC Endocrine disrupting compounds
EPR Extended Producer Responsibility
EQSD EU Directive 2008/105/EC on Environmental Quality Standards
EQS Environmental Quality Standards
ESPR Ecodesign for Sustainable Products Regulation
EURO7 European vehicle emissions standards – Euro 7 for cars, vans, lorries and buses
GHG Greenhouse gases
4
Term or
acronym
Meaning or definition
GWD EU Groundwater Directive 2006/118/EC
GPP Green Public Procurement
IA Impact Assessment
IED Industrial Emissions Directive
IMDG International Maritime Dangerous Goods
IMO International Maritime Organisation
LCA Life-cycle Assessment
MARPOL International Convention for the Prevention of Pollution from Ships
MSFD EU Marine Strategy Framework Directive
OCS Operation Clean Sweep
OCS CS Operation Clean Sweep Certification Scheme
OSPAR Convention for the Protection of the Marine Environment of the North-East Atlantic
PAH Polycyclic aromatic hydrocarbons
PCB Polychlorinated biphenyls
PET Polyethylene terephthalate
PM Particulate Matter
PVOH/PVA Polyvinyl alcohol
PVC Polyvinylchloride
PVOH based
products
Different Polyvinyl alcohol-based compositions used as protective films in detergent
capsules for laundry & dishwashers
REACH Regulation (EC) No 1907/2006 on the registration, evaluation, authorisation and
restriction of chemicals
SDG Sustainable Development Goals
SME Small and medium-sized enterprises. They are defined in the Commission
Recommendation of 6 May 2003 concerning the definition of micro, small and
medium-sized enterprises. SMEs are enterprises which employ fewer than 250
persons and which have an annual turnover not exceeding EUR 50 million, and/or an
annual balance sheet total not exceeding EUR 43 million. In particular, within the
SME category, a small enterprise is defined as an enterprise which employs fewer
than 50 persons and whose annual turnover and/or annual balance sheet total does not
exceed EUR 10 million; a microenterprise is defined as an enterprise which employs
fewer than 10 persons and whose annual turnover and/or annual balance sheet total
does not exceed EUR 2 million. Large-sized enterprise means an enterprise that is not
a micro, small or medium-sized enterprise.
5
Term or
acronym
Meaning or definition
SQAS Safety & Quality Assessment for Sustainability system
SSD Sewage Sludge Directive
SUP Single-use plastics
SWO Storm water overflows
TPMS Tyre Pressure Management System
TRWP & TWP Due to tyre’s friction with the road surface, the tyre wear particles (TWP) get
contaminated and encrusted as a mixture of road wear, tyre particles and other road
dust substances, called Tyre and Road Wear Particle (TRWP)
UWWTD Urban Wastewater Treatment Directive
Water FD Water Framework Directive
WEEE Waste from electrical and electronic equipment
WFD Waste Framework Directive
WWTP Wastewater treatment plants
6
1 INTRODUCTION: POLITICAL AND LEGAL CONTEXT
Microplastics are ubiquitous, persistent, very mobile and virtually impossible to capture once
released into the environment. In 2018, the EU Strategy for Plastics in a Circular Economy
acknowledged the risks posed by microplastics and advocated innovative solutions targeting different
sources. In 2019, the European Commission’s group of Chief Scientific Advisers recognised the
potential risks posed by these microplastics and encouraged action to reduce and prevent further
pollution.1
In 2020, as a follow-up action of the European Green Deal, the Circular Economy Action
Plan 2.0 committed the Commission to tackling the presence of microplastics in the environment by:
- restricting intentionally added microplastics in products (e.g. cosmetics, detergents,
fertilisers, artificial infill)2
;
- addressing unintentional releases of microplastics by developing labelling, standardisation,
certification and regulatory measures; harmonising methods for measuring unintentional
releases of microplastics; closing the gaps in scientific knowledge related to the risks and
occurrence of microplastics in the environment, drinking water and foods.
In 2021, in its Action plan: ‘Towards Zero Pollution for Air, Water and Soil’, the Commission
proposed that, by 2030, the EU should reduce both (intentional and unintentional) microplastic
releases into the environment by 30%. This target does not include the contribution of the degradation
and fragmentation of macroplastics abandoned, discarded or improperly disposed of into the
environment.3
Microplastic pollution observed in the environment originates from:
(i) the degradation and fragmentation of larger ‘macroplastic’ pieces abandoned, discarded
or improperly disposed of in the environment;
(ii) microplastics that are added intentionally to certain products, such as cosmetics, and
ultimately find their way into the environment; and
(iii) microplastics that are released unintentionally, mainly due to abrasion during use or poor
handling.
Although “macroplastics” are likely a large source of microplastics, their degradation and
fragmentation are not addressed in this Impact Assessment as these processes can take between a
couple of years and up to several centuries so no reliable information is available on the amount of
microplastics generated from macroplastics yearly. In addition, the most effective way of tackling
the degradation of macroplastics as a source of microplastics is by reducing the improper disposal of
macroplastics into the environment. The EU has already introduced an extensive strategy4
and
legislative framework to tackle macroplastic pollution, including the Single Use Plastics Directive
1
Scientific opinion on the environmental and health risks of microplastic pollution, April 2019.
2
Commission Regulation (EU) …/… amending Annex XVII to Regulation (EC) No 1907/2006 concerning the
Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) as regards synthetic polymer
microparticles.
3
Instead, the Zero Pollution Action Plan sets a 50% reduction target for plastic marine litter which will help contribute
to a reduction in the releases of microplastics from this source (see also Annex 2 of the Zero pollution action plan).
4
A European Strategy for Plastics in a Circular Economy, 2018.
7
(SUPD)5
, the Waste Framework Directive (WFD)6
, the Packaging and Packaging Waste Directive
(PPWD)7
and the Marine Strategy Framework Directive (MSFD).8
Similarly, intentionally added microplastics are not addressed in this IA because the Commission
has proposed a draft REACH restriction. This restriction was adopted on 25 September 2023.9
On microplastics unintentionally released, while several main sources were initially being
examined (see Table 1)10
, this Impact Assessment focuses on plastic pellets. They also referred to
as nurdles, nibs, preproduction pellets, and resin pellets, are the starting material used for all plastic
production worldwide11
. Due to their nature and size, they are regarded as being microplastics. The
focus on pellets is due to the conditions being in place for the application of the precautionary
principle12
and for immediate regulatory action tackling this source:
• Contrary to other sources of microplastics unintentionally released, for which an EU legal
framework exists or is being negotiated with the European Parliament and the Council, there is
no existing or forthcoming EU legislation specifically preventing and reducing pellet losses as a
form of pollution occurring along the entire supply chain in the EU. The proposal would remedy
a loophole in the current EU legislative framework.
• Sufficient evidence is available documenting the problem and the impacts related to pellet losses,
justifying intervention and allowing the design of specific policy measures, while this is not yet
the case for most other sources of unintentionally released microplastics.
• Contrary to other sources of microplastics unintentionally released, pellet losses are due to poor
handling and therefore largely preventable today in a cost-effective manner. No changes to
product or consumer behaviour are required to prevent and reduce pellet losses.
• Techniques to prevent pellet losses are already available to economic operators at an acceptable
cost.
• They are the third source of releases and account for 7-10% of microplastics unintentionally
released in the EU.
• Preventing and reducing pellet losses now does not impede any future action on other sources
later, as there is no interference between the different sources of microplastics.
In contrast, the other sources identified (paints, tyres, synthetic textiles, geotextiles and detergent
capsules) were not pursued in this Impact Assessment for several reasons. Measures tackling
microplastic releases from tyres had already been included in the EURO 7 Regulation proposal.
While the preliminary analysis showed that there is potential to reduce releases from paints, synthetic
textiles, geotextiles and, to a lesser extent, detergent capsules, it also highlighted uncertainties and
5
Directive (EU) 2019/904 on the reduction of the impact of certain plastic products on the environment.
6
Directive 2008/98/EC on waste and repealing certain Directives.
7
Directive 94/62/EC on packaging and packaging waste.
8
Directive 2008/56/EC establishing a framework for community action in the field of marine environmental policy.
9
Commission Regulation (EU) …/… amending Annex XVII to Regulation (EC) No 1907/2006 concerning the
Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) as regards synthetic polymer
microparticles.
10
Different approaches were used to estimate the releases from these sources because of the heterogeneity of the
available data or data unavailability. For pellets, textiles, detergent capsules and geotextiles, researchers have
estimated varying emission levels, as well as a range of possible emissions scenarios. For tyres, a modelling approach
was used to estimate the potential microplastic releases. For paints, a confidence interval was used in the estimations.
11
Pellets are defined within ISO 472:2013 as “a small mass of preformed moulding material, having relatively uniform
dimensions in a given lot, used as feedstock in moulding and extrusion operations”.
12
Communication from the Commission on the precautionary principle, 2000.
8
data gaps and concluded that other policy instruments may be better suited to tackle them. More
information and additional analysis is needed to better understand their patterns and frame the most
appropriate interventions. Where appropriate and necessary, separate impact assessments will be
prepared, to support possible measures to tackle microplastics releases. Box 1, below, provides an
overview of the conclusions for each source not pursued in this impact assessment. Annex 15 contains
the preliminary analysis undertaken for each of these sources.
Table 1: Estimated releases from six main sources of unintentional microplastic releases to the EU
environment
Source Quantity (tonnes/year), 2019*
Paints 231 000 – 863 000
Tyres 360 000 – 540 000
Pellets 52 140 – 184 290
Textiles 1 649 – 61 078
Geotextiles 6 000 – 19 750
Detergent capsules 4 140 – 5 980
TOTAL of the selected six sources 654 929 – 1 674 098
(90-93% of total emissions)
TOTAL of all sources 729 087 – 1 808 198
(*) Estimations based on the supporting study for this Impact Assessment
Box 1: Preliminary assessment of the other main sources of microplastic pollution not pursued in this
impact assessment13
Paints – Paints are widely used and on average 37% plastic polymer-based, making them a significant
source of microplastic releases. While shifting towards mineral paints would help reduce microplastic
releases, it is not clear yet if this would lead to an increase of other environmental impacts. The full
environmental profile andlife-cycle assessments of polymer and mineral paints are not available yet. Once
this information is obtained, requirements on microplastics in paints could be introduced via the Ecodesign
for Sustainable Products Regulation (ESPR)14
, where paints is one of the twelve priority products.
Tyres – Tyre abrasion leads to the release of microplastics. These releases are already being targeted in
the EURO 7 Regulation proposal15
and may be addressed by a delegated act under the Tyre Labelling
Regulation.16
Synthetic textiles – Most apparel is now made out of plastic fibres and releases microplastics. Some key
challenges encountered in the course of the assessment are that microplastic releases from synthetic fibres
occur throughout the value chain, that most of their production takes place outside of the EU, and that there
13
More details in Annex 15.
14
Proposal for a regulation of the European Parliament and of the Council COM/2022/142 final establishing a
framework for setting ecodesign requirements for sustainable products and repealing Directive 2009/125/EC.
15
Proposal for a regulation of the European Parliament and of the Council COM/2022/586 final on type-approval of
motor vehicles and engines and of systems, components and separate technical units intended for such vehicles, with
respect to their emissions and battery durability (Euro 7) and repealing Regulations (EC) No 715/2007 and (EC) No
595/2009.
16
Regulation (EU) 2020/740 on the labelling of tyres with respect to fuel efficiency and other parameters, amending
Regulation (EU) 2017/1369 and repealing Regulation (EC) No 1222/2009.
9
is not sufficient data regarding the profiles of different synthetic fibres and fibre combinations in terms of
microplastic releases. Subject to a better understanding of releases from synthetic textiles thanks to a
standardised measurement methodology, along with more life-cycle data of alternatives’ impacts, relevant
measures could be introduced in the framework of the Ecodesign for Sustainable Products Regulation, as
announced in the EU Strategy for Sustainable and Circular Textiles. Such an approach will ensure the
environmental sustainability challenges of textiles are addressed in a coherent and integrated way.
Detergent capsules – Laundry and dishwasher detergent capsules often rely on a dissolvable plastic film
to dispense their product during the wash. However, the complete biodegradation of this film is not
guaranteed and may cause microplastic pollution. Subject to scientific evidence pointing towards a need
for biodegradability criteria, future action could be taken under the Detergents Regulation.
Geotextiles – Geotextiles are a source of microplastic releases as they are mostly synthetic, used in harsh
conditions and not removed at the end of their service life. However, data on their uses and profile in terms
of degradation and microplastic releases is scarce. Once more data is available future action could be taken
in the framework of the Construction Products Regulation.17
In May 2023, five EU Member States and Norway called on the Commission to introduce the
necessary measures tackling unintentional microplastic releases, to reach the 30% reduction target in
microplastic releases by 2030. According to these countries, tackling microplastics pollution is a
cross-border challenge, and therefore national and voluntary measures alone are not sufficient.
Measures at EU level are needed.18
In March 2022, the United Nations Environmental Assembly launched international negotiations on
a Global Treaty on Plastic Pollution , which is expected to target inter alia microplastics. Other
international conventions and agreements are looking at the microplastics issue, such as the
Convention for the Protection of the Marine Environment of the North-East Atlantic (OSPAR) which
issued a non-binding recommendation.
In the EU submission to UNEP in view of the second session of the Intergovernmental Negotiating
Committee on an international legally binding instrument on plastic pollution (INC-2)19
, the EU and
its Member States “stress the need for the future instrument to include measures to reduce unintended
release of microplastics. This could include, for example, measures to minimise the risk of leakages
of plastic pellets from production, handling and transport”.
The EU has committed to implementing the UN 2030 Agenda for Sustainable Development guided
by the 17 Sustainable Development Goals (SDG). This initiative would contribute to goal 12 on
sustainable consumption and production, goal 14 on the conservation and sustainable use of the
oceans, seas and marine resources for sustainable development and goal 15 on life on lands, together
with goals 3 (Good health), 9 (Industry, innovation and infrastructure), 13 (Climate).
2 PROBLEM DEFINITION
2.1 What are the problems related to microplastics in general?
Microplastics are ubiquitous, persistent and transboundary. They are detrimental to the
17
Regulation (EU) No 305/2011 laying down harmonised conditions for the marketing of construction products and
repealing Council Directive 89/106/EEC.
18
Non-paper: Call for ambitious EU measures to reduce and prevent microplastic pollution, May 2023.
19
UNEP, The EU’s Pre-session Submission ahead of Second Session of Intergovernmental Negotiating Committee to
develop an international legally binding instrument on plastic pollution, 2023.
10
environment and potentially harmful to human health, and their mobility is an aggravating
factor (see an extensive analysis in Annex 7). Microplastics are easily transported through the air
and by surface and marine waters. They are found in soils (including agricultural lands), lakes, rivers,
estuaries, beaches, lagoons, seas and oceans. They travel across entire continents and are found in
the most remote, once pristine regions such as the Antarctic and Mount Everest, or in vulnerable
ecosystems like coral reefs and deep seas. Adverse impacts of pellets are described in detail in Section
2.3.
Risks of microplastic pollution were highlighted in a publication revealing that the 5th
planetary
boundary of novel entities was exceeded.20
Chemicals at large, including plastics, have been
identified as fulfilling the characteristics of a novel entity. The concept of planetary boundaries was
defined as the nine “boundaries within which we expect that humanity can operate safely”21
,
demonstrating the threat microplastics pose to the environment and potentially to humans.
Microplastic releases to the environment will continue to increase unless action is taken. All global
scenarios point to an increase. A 2019 global scenario22
suggests an exponential increase in
microplastic releases to the oceans unless their release is stopped urgently. In Figure 1, the global
accumulation of microplastics in the surface ocean is shown under three plastic emission scenarios.
A recent OECD scenarios for 206023
also highlight the importance of closing leakage pathways. This
scenario estimates that 298 610 tonnes of microplastics leak annually into the environment in the EU-
27 (intentional and unintentional).24
This IA has found a much higher figure for the annual (2019)
releases of (only) unintentional microplastics into the European environment: between 0.7 and 1.8
million tonnes. This estimate is considered an update, as it considers all recent relevant research on
the sources. It considers in particular the quite recent estimate on paints, which was neglected by
many studies before, but is now considered as probably the largest source of unintentional
microplastic releases.25
Annex 14 gives an overview of all sources of unintentional microplastics
identified. Annex 15 includes the calculations for the five other sources analysed in the preliminary
phase of this impact assessment.
20
Persson, L., Carney Almroth, B., Collins, C. et al., ‘Outside the Safe Space of the Planetary Boundary for Novel
Entities’, Environmental Science and Technology, Vol. 56, No 3, 2022, pp. 1510–1521, American Chemical Society.
21
Rockström, J., Steffen, W., Noone, K. et al., ‘Planetary boundaries: exploring the safe operating space for humanity’,
Ecology and Society, Vol. 14, No 2, Article 32. The planetary boundaries framework was updated in 2023 suggesting
the novel entities boundary is transgressed see ‘Earth beyond six of nine planetary boundaries’, Science Advances,
Vol. 9, Issue 37, Sep 2023.
22
Ourworldindata.org, “Microplastics in the surface ocean, 1950 to 2050”
(https://ourworldindata.org/grapher/microplastics-in-ocean).
23
OECD (2022), Global Plastics Outlook: Policy Scenarios to 2060, OECD Publishing, Paris,
https://doi.org/10.1787/aa1edf33-en.
24
The European Chemicals Agency ECHA (2020) estimated 176 000 tonnes of microplastics annually due to abrasion
and weathering of plastic products and an additional 42 000 tonnes of microplastics deliberately added to products
that are subsequently discharged. Opinion of the Committee for Risk Assessment and Opinion of the Committee for
Socio-Economic Analysis on an Annex XV dossier proposing restrictions on intentionally-added microplastics.
25
Paruta et al. (2022) Plastic Paints the Environment, EAEnvironmental Action 2022, ISBN 978-2-8399-3494-7.
11
Figure 1: Microplastics on the surface ocean 1950 to 205026
In 2019, the Commission’s Group of Chief Scientific Advisors considered that ‘although the
currently available evidence suggests that microplastic pollution at present does not pose a
widespread risk to humans or the environment, there are significant ground for concern and for
precautionary measures to be taken’27
(see Box 2).
Box 2: Recommendations by the European Commission’s Group of Chief Scientific Advisors
Since then, microplastic pollution has been extensively researched, and new evidence has emerged
confirming the need for precautionary measures to be taken.
Stakeholder views (see Annex 2) largely refer to the hazardous nature of microplastic pollution in
the EU and its negative impact on the environment (79% of all respondents completely or somewhat
agreed) and on human health (81% of all respondents completely or somewhat agreed). Regarding
the harmful economic effects of microplastics, 58% of EU citizens completely or somewhat agreed
with the statement, including half of the business organisations and two-thirds of the NGOs. All
stakeholders agreed action to reduce microplastics should be undertaken by all levels of public
authorities (EU, national, regional and local levels). Regarding pellets, stakeholders mostly agreed
that there is improper handling in current pellet-related activities. As to the type of action, 95% of all
respondents supported international action, 87% of them called on the EU to set up a comprehensive
legislative system for pellet-handling companies, and 71% of them supported voluntary measures.
26
Microplastics in the surface ocean, 1950 to 2050, Our World In Data.
27
Scientific opinion on the environmental and health risks of microplastic pollution, April 2019.
• Broaden existing policy to prevent and reduce microplastic pollution in both marine and freshwater
environments, and in air and soil, and prioritise substance- and context-specific measures for high-
volume, high-emission sources;
• Ensure that any new measures are of benefit to society by undertaking cost/benefit and similar
analyses;
• Develop a coordinated international response consisting of research collaboration (including filling
knowledge gaps on nanoplastic pollution), data sharing and standards development for
measurement, monitoring and risk assessment.
12
2.2 What are the problems related to plastic pellets?
Current practices for handling pellets lead to losses at each stage in the supply chain, causing
adverse environmental and potential human health impacts.
The problem of pellet losses has been known about since the 1980s with the US Environmental
Protection Agency (EPA) and the Center for Marine Conservation (now known as the Ocean
Conservancy) “detecting plastic pellets in US waterways from the Atlantic to the Pacific”.28
Plastic industrial raw materials come in different forms, including pellets, flakes, powders and in
liquid forms, all referred to collectively as “pre-production plastic pellets”.29
The umbrella term of
“pellets” will be used in this IA. In Europe, approximately 80 % of all plastic industrial raw materials
produced are in the form of round to oval granules of approximately 2 mm to 5 mm in diameter.30
A
relevant part of the remaining 20% is even smaller than 2 mm, such as powders, and a minor part can
be slightly bigger.
The pellet supply chain
Pellets can reach the environment through losses occurring at every stage in the supply chain:
production (virgin or recycled), processing (compounding, masterbatch making, converting, etc.),
distribution, other logistic operations (storage and tank cleaning), waste management, etc. Therefore,
tackling pellet losses clearly requires a supply chain approach.
The pellet supply chain is complex, involving several operators as outlined in Box 3. Virgin pellets
are manufactured at large installations and then stored in silos. They are mostly filled directly into
tankers, or packed for transport to conversion sites, where final plastic products are made. Transport
occurs by road, rail, air and cargo ship. Distribution methods vary from small bags (20‐25 kg) to silo
trucks (up to 35 t) and large maritime containers. Not all bags are sealed, airtight and puncture-
resistant to prevent damage and tears. Losses can also occur at recycling facilities, where plastic
waste is recycled back into pellets in order to be reintroduced into the plastic manufacturing cycle.31
Box 3: Companies handling pellets
28
Document Display | NEPIS | US EPA; Plastics Industry Association (2016) Operation Clean Sweep Celebrates 25
Years
29
The Convention for the Protection of the Marine Environment of the North‐East Atlantic (OSPAR) Commission,
OSPAR Background document on pre-production plastic pellets, 2018. Technically, according to ISO 472:2013, a
pellet is a “small mass of preformed moulding material, having relatively uniform dimensions in a given lot, used as
feedstock in moulding and extrusion operations”.
30
Plastics Europe, ‘Operation Clean Sweep® Progress Report 2017’, 2018
(https://www.opcleansweep.eu/application/files/8316/3456/6233/PlasticsEurope_OCS_progress_report-2017.pdf).
31
Hann, S., Sherrington, C., Jamieson, O., Hickmann, M., Kershaw, P., Bapasola, A., Cole, G. (2018). Investigating
options for reducing releases in the aquatic environment of microplastics emitted by (but not intentionally added in)
products, Eunomia.
• Producers who create virgin plastic pellets from oil, gas and other raw materials;
• Recyclers who collect, sort, clean and process plastic waste into recycled plastic flake or pellets;
• Traders/brokers who purchase the plastic material and store it or otherwise handle it before selling it
to converters or exporting;
• Intermediary facilities that handle the plastic material between the producer and the processor, such as
storage and repacking facilities;
13
Producers: in Europe, there are close to 100 large polymer-producing companies that are members
of the trade association “Plastics Europe”.32
These companies produce some 54.8 million tonnes of
virgin pellets per year and represent 90% of the total EU production. In 2021, circa 138 000 people
worked for plastic manufacturers in the EU27. The number of individual enterprises was around 2
300. In 2021, plastic manufacturers created a turnover of EUR 117 billion.
Processors / converters: their situation is significantly different as Figure 2 shows: the trade
association “European Plastic Converters” (EuPC) totals about 51 national and European industry
associations, representing 90% of the total EU processing, equivalent to ca 48 000 individual
companies, out of which 66% are micro-companies (some 31 400 micro-enterprises handling an
average tonnage below 100 tonnes and representing an average turnover of EUR 300 000 annually,
equivalent to 4% of the total turnover of the industry).33
Converters employ 1.3 million people and
have an annual turnover of EUR 269 billion.34
Recyclers: in 2021, there were some 730 plastic recycling companies in the EU. They have more
than 20 000 employees and create a turnover of EUR 8.5 billion annually. In 2021, they produced
7.6 million tonnes of recycled pellets, while the installed capacity is roughly 11 million tonnes. About
165 organisations are members of the trade association “Plastics Recyclers Europe” (PRE)
regrouping both national industry associations and individual, mostly large, companies.35
These
companies represent 80% of the EU market installed capacity.
Transporters: the “European Chemical Transport Association” (ECTA) represents approximately
100 transport companies active in the transport of chemical products, with about half handling also
pellets.36
Most of these ECTA members are not SMEs. They cover about 30% of the total pellet
transport in Europe. Beyond ECTA members, ca. 13 000 transporter providers are mainly micro and
small enterprises.
Other logistic operators: the “European Federation of Tank Cleaning Organizations” (EFTCO)
declares that around 440 tank cleaning stations in Europe deal with tanks containing pellets. Also,
there would be at least 850 storage or warehouse providers in Europe storing pellets. These
companies are mainly micro and small enterprises.
32
Plastics Europe, ‘Membership’ (https://plasticseurope.org/about-us/membership/).
33
European Plastic Converters (EuPC), ‘Organisation’ (https://www.plasticsconverters.eu/).
34
Eurostat (2021 figures) for EU-27 (Statistics | Eurostat (europa.eu))
35
Plastics Recyclers Europe, ‘Plastics Recycling Industry in Europe: Mapping of Installed Plastics Recycling Capacities
2021 Data’, 2023 (https://www.residuosprofesional.com/wp-content/uploads/2023/03/Plastics-Recycling-Industry-
in-Europe-2023.pdf).
36
European Chemical Transport Association, ‘List of ECTA and ECTA RC* Members 2023’
(https://www.ecta.com/organization/list-of-members/).
• Processors who transform the plastic pellets by either mixing them with other materials to alter their
physical properties or by transforming them directly into manufactured goods (the former are called
compounders and the latter converters). In this IA, we refer to all of them as “converters”;
• Distributors who sell (a small portion of) the plastic pellets to sectors such as construction;
• Logistic companies (including importers, transport and cleaning stations); and
• Waste management companies.
14
More information on the share of SMEs37
in the pellet supply chain is presented in Annex 12.
Figure 2: Breakdown of plastic processors
Pellet losses
Pellet losses can be the result of:
1) chronic, ongoing pellet incidents during routine operations. These losses usually occur as a
result of lack of awareness and improper training, poor handling and housekeeping practices
and due to the absence of pellet loss preventive and mitigating measures. They typically
happen during both bulk and packed loading and unloading operations at special installations
and during transport and logistic operations. The industry corroborates this presumption by
adding process and mixing points as other pellet loss hotspots.38
2) acute, one-off, pellet incidents. These usually occur as a result of accidents during transport
or major equipment failures in the absence of pellet loss preventive and mitigating measures.
37
SMEs are defined in the Commission Recommendation of 6 May 2003 concerning the definition of micro, small and
medium-sized enterprises. In particular, within the SME category, a small enterprise is defined as an enterprise which
employs fewer than 50 persons and whose annual turnover and/or annual balance sheet total does not exceed EUR 10
million; a microenterprise is defined as an enterprise which employs fewer than 10 persons and whose annual turnover
and/or annual balance sheet total does not exceed EUR 2 million.
38
Plastics Europe, ‘Operation Clean Sweep® Progress Report 2019’, 2020 (https://plasticseurope.org/knowledge-
hub/operation-clean-sweep-progress-report-2019/).
15
Figure 3: pellets lost in the environment & pellets ingested by fishes
(Credits last picture: Sri Lanka Marine Environment Protection Authority)
Chronic pellet incidents have been reported at production sites in the Netherlands39
, Belgium40
,
Spain41
, Denmark42
and Sweden.43
Logistics platforms like ports are hotspots for pellet losses: the
ports of Rotterdam, Antwerp and Tarragona have been reported to be heavily polluted locations by
several organisations active in the monitoring of pellet losses.44
An important part of chronic pellet
incidents also happens during the transport of pellets across land (e.g. road and rail), such as in
Belgium45
, or during maritime transport.46
Acute pellet incidents have happened in industrial facilities in Italy47
and during the transport of
pellets across land, e.g. in France48
and during maritime transport, e.g. in the Netherlands49
or in
Denmark.50
Acute pellet incidents where entire containers are lost at sea result in large quantities of
pellets being released directly into the marine environment.51
Some big incidents with unknown
origin have also to be mentioned, such as in the Loire-Atlantique coastline of France52
, among several
others in Europe and worldwide.53
Chronic and acute pellet incidents are presented in Annex 8.
Existing monitoring programs in Europe show the presence of plastic pellets in the marine
environment. In addition to those implemented in the context of the Marine Strategy Framework
Directive, which requires all Member States54
to monitor and assess microlitter on beaches55
, there
are programs like the Port of Antwerp’s collaboration with PlasticsEurope.56
However, plastic pellets
have been observed, since the 1970s, all over the world, in marine environments that are not close to
petrochemical or polymer industries. NGOs such as SOS Mal de Seine and Fidra have documented
this using different observation protocols. This demonstrates that while pellet losses can be
39
Westerschelde-plastic-nurdles-versie-definitief-21-11-2021-2.pdf (plasticsoupfoundation.org)
40
Ecaussinnes (Belgium): Surfrider Foundation tackles industial plastic granules
41
New report out exposes alarming impacts of plastic pellets across Europe - Good Karma Projects
42
Tackling sources of Marine Plastic Pollution through effective corporate engagement: a Danish Case Study
43
The unaccountability case of plastic pellet pollution - ScienceDirect
44
Plastic Giants polluting through the backdoor. New report out exposes alarming impacts of plastic pellets across
Europe - Good Karma Projects
45
Ecaussinnes (Belgium): Surfrider Foundation tackles industial plastic granules
46
Sources, fate and effects of Microplastics in the marine environment: a global assessement
47
Nurdle pollution hotspot identified in Italy (nurdlehunt.org.uk)
48
Morbihan. A truck loses its cargo, 28 tons of plastic pellets on the road (ouest-france.fr)
49
24 million plastic pellets from MSC Zoe on northern Dutch coastline – The Northern Times
50
Plastic pellets spill pollutes Danish, Norwegian, Swedish coastlines – KIMO (kimointernational.org)
51
In 2021, the container ship MV X-Press Pearl caught fire and sank losing approximately 1680 tonnes of plastic pellets
in a single event (some 84 billion pellets). In Europe, in 2020, the MV Trans Carrier lost more than 10 tonnes of
plastic pellets in the German Bight. Plastic pellets spill pollutes Danish, Norwegian, Swedish coastlines – KIMO
(kimointernational.org) 24 million plastic pellets from MSC Zoe on northern Dutch coastline – The Northern Times
52
Les plages de la côte Atlantique polluées par une marée de granulés plastiques, l’Etat porte plainte (lemonde.fr). In
less than an hour, volunteers collected more than 80,000 pellets from the Tréguennec in Finistère beach.
53
Nurdle Map (nurdlehunt.org.uk)
54
Commission Decision (EU) 2017/848 of 17 May 2017 laying down criteria and methodological standards on good
environmental status of marine waters and specifications and standardised methods for monitoring and assessment,
and repealing Decision 2010/477/EU
55
In 2016, pain started the MSFD subprogram on microplastics on beaches, and pellets were detected with an average
concentration of 47.8 pellets/kg or 419.2 pellets/m2. Currently, the MSFD Technical Group on Litter is developing a
protocol for monitoring pellets on beaches.
56
Plastics Europe, ‘Port of Antwerp Activity report 2021’, 2021 (https://plasticseurope.org/knowledge-hub/port-of-
antwerp-activity-report-2021/).
16
concentrated in one geographical area, they are also extremely mobile and can be dispersed by surface
water and sea currents, as well as through the air.
Pellet pathways
Spilled pellets can reach the environment and become losses through several pathways (Figure 4).
Figure 4: Pellet pathways (solid lines are pellet movements; dotted lines are loss pathways)
From production, processing and recycling installations, spilled pellets can either reach industrial
or urban wastewater treatment facilities (via wet cleaning pushing pellets to drains57
) or can enter the
environment directly (air, soil, surface and marine waters, but also via overflows making pellets
bypass the wastewater treatment facilities). In industrial wastewater treatment facilities, pellets are
captured in sludge and incinerated. However, the effluent may still contain some pellets (particularly,
flakes and powders). In urban wastewater treatment facilities, pellets are captured in sludge (between
95-99%, depending on the treatment efficiency). On average, half of sludge, which has captured
pellets, in the EU is spread on agricultural lands as fertiliser.
Pellets lost during logistic and shipping operations often reach the environment directly. Therefore,
the main pellet loss pathways are water-related, i.e. urban, rain and storm water for losses occurring
in terrestrial areas and marine water for losses at installations close to ports or occurring in the sea.
Scale of the problem
While observable, these losses are not routinely measured, or indeed readily measurable at any
specific step. There is no harmonized methodology for measuring pellet losses and not many
measurements have been made at different steps of the supply chain, nor are any systemic monitoring
and reporting data available within the Member States or the industry to calculate pellet losses.
Hence, it is impossible to establish exact figures on pellet losses at each step because it depends on
the installation size, actors involved, handling practices, etc., and all these aspects are very
heterogeneous in the EU. Nevertheless, efforts to quantify the amount of pellets entering the
57
In case of dry cleaning, pellets go to waste management (mostly for incineration) except for recyclers who collect and
put them back in the recycling process.
17
environment typically apply a ‘loss rate’ as well as a number of handling steps to the total pellet
volume handled. Robust empirical evidence to inform a ‘loss rate’ or a number of handling steps is
scarce. However, the greater the number of steps at which pellets are handled, the greater the
opportunities for loss. The major handling steps occur at production plants (of both virgin and
recycled pellets), processing installations and during logistic operations, i.e. all loading and unloading
operations to transport pellets from one installation to another, including warehouse installations,
where pellets are stored and/or re-packed, and cleaning installations.
Several studies use the figures for pellet losses of 0.01%-0.04%.58
However, all these studies refer to
the same estimate from just one processor and is based on measurement in the effluent, so it does not
measure losses at other steps of the supply chain or emissions happening otherwise, i.e. direct
emissions to air, water and soil. Given the high uncertainty and potential double counting, rates in
the range of 0.001% and 0.1% have been suggested by some studies.59
The Convention for the
Protection of the Marine Environment of the North-East Atlantic (OSPAR)60
found an even bigger
range in various publications; loss estimates show a variation from 0.0003% to 1% of total plastic
demand, making it difficult to estimate the exact magnitude of the problem. The reason for such a
large variation is that the actors involved in the supply chain range from micro-enterprises to large
companies and the level of awareness and measures in place to prevent pellet losses vary
considerably. Similarly, the number of handling steps in a typical supply chain is influenced by the
size of the operation.
To take into account these uncertainties, a range of loss rates has been used to calculate the losses
occurring at four major steps: production, processing, recycling and logistics (including distribution),
starting from the most often cited loss rates. It is estimated that losses happen at a higher rate at
processing and recycling installations because of relatively small installations and a large number of
handling steps (0.02%-0.06% of the total volume processed or recycled) than at production ones
(0.01%-0.03% of the total volume produced), and at an even higher rate during transport and logistic
operations because pellets more often reach the environment directly at these steps, but with a higher
uncertainty (0.03%-0.12%). These rates count for the major handling steps in the production,
processing, recycling and transport/logistic phases. These figures can be improved once the reporting
obligation under REACH (possibly complemented with a harmonised methodology under this
initiative) is in place.
Chronic losses in reference year
High volumes of pellets are produced and handled every year, both globally and in the EU. In 2019,
about 65.3 million tons of pellets (57.9 million tonnes of virgin, 6.5 million tonnes of recycled, and
0.9 million tonnes of bio-based) were produced in the EU.61
In the same year, 12.7 million tonnes of
pellets were imported to the EU to be converted into final plastic products at a converting site in the
EU, while 14.9 million tonnes of pellets were exported.
This IA has found that the amount of pellets lost to the environment in the EU in 2019 can be
estimated to be between 52 140 tonnes and 184 290 tonnes (logistics 27 870 – 111 480 tonnes,
converters 15 600 – 46 800 tonnes, producers 7222 – 21 665 tonnes and recyclers 1448 – 4345
58
Sea-based sources of microplastics to the Norwegian marine environment. Norwegian Environment Agency
(Miljødirektoratet) (2021). (according to Sundt et al. (2014)
59
Peano et al., ‘Plastic Leak Project’, 2020 (https://quantis.com/who-we-guide/our-impact/sustainability-
initiatives/plastic-leak-project/).
60
OSPAR, ‘Assessment document of land-based inputs of microplastics in the marine environment’, 2017
(https://www.ospar.org/documents?v=38018 Page 22).
61
Based on data from Eurostat and industry.
18
tonnes), equivalent to 0.08% to 0.28% of total pellet volumes in the EU. The methodology used to
calculate these losses is presented in detail in Annex 8.
2.3 The impacts of pellet losses
Four types of adverse impacts can be observed from pellets finding their way into the
environment: on the environment; on climate; on human health; and on the economy.
These impacts are summarised below and explained in more detail in Annex 7. Most of these impacts
are related to microplastics in general, due to a lack of research specifically assessing the impact of
pellets. However, as a subset of microplastics, it is assumed that most of the impacts of pellets are
comparable to those of microplastics. Indeed, approximately 80 % of all plastic raw materials
produced are approximately 2 mm to 5 mm in diameter, therefore well within the usual size of
microplastics (up to 5mm). Of the remaining 20%, a significant portion is smaller than 2 mm, such
as powders, and a minor part can be slightly bigger. In particular the portion with the smallest size
can have an impact on health. The disintegration of pellets into smaller particles also increases their
number and impacts. The sections below clearly state when the discussed impacts pertain to pellets
or microplastics more generally.
While certain categories of impacts (environment, climate and economy) are well documented and
relatively well known, the impacts on human health are still poorly understood, despite their
extensive presence in the human body. Nevertheless, as concluded by the General Scientific Advisers
of the Commission and the European Chemicals Agency, this gap in understanding should not
prevent action from being taken as it is likely that they pose a risk to human health. The precautionary
principle should therefore be applied. Research efforts are ongoing, in part thanks to EU support
under LIFE and Horizon2020, to further elucidate these risks and impacts. Global trends suggest that
microplastic emissions will continue to increase. We would generally expect that the adverse impacts
of pellets will be proportional to their part in the total microplastic emissions (see Annex 7).
Impacts on the environment
International Pellet Watch, initiated in 2005 by Hideshige Takada62
and The Great Nurdle Hunt63
,
organised by UK charity FIDRA, both relied on pellet samples collected by citizens to demonstrate
that pellet pollution is a global issue. Indeed, they are highly mobile and have been found thousands
of kilometres from the nearest pellet production or conversion facility64
in areas including important
Natura 2000 areas65
. Once in the environment, pellets are known to be eaten by a range of organisms
and animals and to cause harm to biodiversity and habitats66,67
. As pellets are mainly composed of
either polyethylene or polypropylene, once in the aquatic environment68
, they normally float. If a
62
edge://newtab (pelletwatch.org)
63
The Great Nurdle Hunt, Reducing plastic pellet pollution at sea.
64
Corcoran P. L. et al., A comprehensive investigation of industrial plastic pellets on beaches across the Laurentian
Great Lakes and the factors governing their distribution, Science of the Total Environment, 747:141227, 2020.
65
The unaccountability case of plastic pellet pollution - ScienceDirect
66
Cole, M., Lindeque, P., Halsband, C. and Galloway, T. S., ‘Microplastics as contaminants in the marine environment:
A review’, Marine Pollution Bulletin, Vol. 62, 2011, pp. 2588-2597.
67
Koelmans, A. A. et al., Risk assessment of microplastic particles, Nature Reviews Materials, 7:138–152, 2022.
68
The persistence of a pellet in the aquatic environment may be measured over decades or more, depending on the resin
type, the types and amounts of additives, and the reactions of the resins and additives to environmental processes (e.g.
weathering, sunlight, wave action). P. L. Corcoran, Degradation of Microplastics in the Environment, Handbook of
Microplastics in the Environment, 2022, 531–542. N. Kalogerakis et al., Microplastics Generation: Onset of
Fragmentation of Polyethylene Films in Marine Environment Mesocosms, 2017, doi.org/10.3389/fmars.2017.00084
19
biofilm starts to form on the pellets, which may change the buoyancy of the particle. Harm is caused
by pellets when they float or are in the water column, where they can be eaten by organisms and
marine animals either intentionally because they are mistaken for food or unintentionally when filter
feeding animals take in seawater.69
Several documented accounts describe pellet and other plastic
ingestion by wildlife, most notably seabirds and sea turtles.70,71,72
Seabirds, like fulmars, ingest pellets
more frequently than any other animal, as they capture prey from the sea surface, and approximately
one-quarter of all seabird species are known to ingest pellets.73
The ingestion of pellets, as with any
microplastic, can cause physical harm such as internal injuries and impair the ability to breathe,
swallow, digest food properly, or lead to death.74
In certain cases, microparticles cannot pass through
the digestive system, leading to malnutrition or starvation by creating a false feeling of fullness.75
Pellets’ and microplastics’ potential to act as a carrier for pathogenic microorganisms and their
potential toxicity are other integral parts of the problem. There is an emerging concern that
microplastics can act as a carrier for pathogenic microorganisms, including species of bacteria,
resulting in an increase in the occurrence of non-indigenous species.76,77,78
Although microplastics
do not pose acute fatal effects on living organisms, they can cause chronic toxicity over the longer
term. Due to their physical and chemical properties, microplastics can absorb and transport numerous
organic contaminants. Microplastics can also contain a complex mixture of chemicals, which may
subsequently be released into the environment and constitute new routes of exposure for organisms.
Impacts on climate
Microplastics represent a non-climatic pressure on ecosystems as carbon and nutrient cycling
processes in soil can be greatly affected by the presence of microplastics and their further
decomposition79
(and might therefore lead to a decreased capacity for GHG absorption). In addition,
plastics and microplastics are a source of GHG emissions, putting additional pressure on the climate.
GHGs are emitted throughout the plastic life cycle, because all related activities (extraction, refining,
manufacturing and end of life management) are carbon intensive. Conventional plastics (based on
fossil fuels) produced in 2015 accounted for 3.8% of total global CO2 emissions, and their share could
69
Werner S; Budziak A; Van Franeker J; Galgani F; Hanke G; Maes T; Matiddi M; Nilsson P; Oosterbaan L; Priestland
E; Thompson R; Veiga J; Vlachogianni T. Harm caused by Marine Litter. EUR 28317 EN. Luxembourg
(Luxembourg): Publications Office of the European Union; 2016. JRC104308
70
Lacroix C. et Huvet A.,
https://enviroplast2019.sciencesconf.org/data/TR1_1_PPT_journe_es_plastiques_et_environnement_Lacroix_Huvet
.pdf [Roundtable n°1 : Outlook and management in ports and coastal environments – scientific introduction : the
characterisation of pollution and associated risks], June 2019.
71
Ryan, P. G., ‘Seabirds indicate changes in the composition of plastic litter in the Atlantic and south-western Indian
Oceans’, Marine Pollution Bulletin, Vol. 56, no. 8, 2008, pp. 1406-1409.
72
Sheavly, S.B. and Register, K.M., ‘Marine Debris & Plastics: Environmental Concerns, Sources, Impacts and
Solutions’, Journal of Polymers and the Environment, Vol. 15, 2007, pp. 301-305.
73
Plastic particles in fulmars | OSPAR Commission
74
Group of Chief Scientific Advisors, ‘Scientific opinion on the Environmental and Health risks of microplastics
pollution’, Aprile 2019.
75
The Convention for the Protection of the Marine Environment of the North‐East Atlantic (OSPAR) Commission,
OSPAR Background document on pre-production plastic pellets, 2018.
76
Sources, fate and effects of Microplastics in the marine environment: a global assessement
77
Cole, M., Lindeque, P., Halsband, C. and Galloway, T. S., ‘Microplastics as contaminants in the marine environment:
A review’, Marine Pollution Bulletin, Vol. 62, 2011, pp. 2588-2597.
78
Khalid, N. et al., Linking effects of microplastics to ecological impacts in marine environments, Chemosphere, 264:
128541, 2021.
79
Rilling M. C. et al., Microplastic effects on carbon cycling processes in soils, Plos Biology, 2021,
https://doi.org/10.1371/journal.pbio.3001130
20
reach 15% by 205080
. A more recent study estimates even higher CO2 emissions from plastic
production (1.96 Gt of CO2e)81
.
Microplastics are widely found in aquatic environments.82
Their presence may cause more
greenhouse gas emissions as they can negatively affect multiple factors, such as phytoplankton
photosynthesis, which contribute to carbon sequestration.83
Impacts on human health
Humans are exposed to microplastics via food consumption84
and inhalation. The annual intake of
microplastics by humans has been estimated to range from 70 000 to over 120 000 particles a year,
depending on age, gender, region, and consumption, including ~70 000 particles inhaled in air and
~50 000 particles ingested in food and drink. Seafood is one of the main concerns for humans85
;
however, microplastics can also enter the food chain through plants.86
Microplastics have been found
in human stool,87
and some studies suggest that they may be present in pregnant women’s placenta,88
and more recently, in human blood.89
Although there is still no scientific consensus on their impacts, microplastics may be of concern to
human health mainly due to their small size, mobility and extensive presence in different
environments, increasing chances of exposure.90
High levels of exposure to microplastics are
believed to induce inflammatory reactions and toxicity, possibly due to the additives used to produce
the plastic.91
In addition to being toxic, there is evidence to suggest that additives such as dyes or
plasticisers could be carcinogenic and mutagenic.92,93
Pellets are likely to carry toxic chemicals as
well since persistent organic pollutants (POPs) such as polychlorinated biphenyls (PCBs), dichloro-
diphenyltrichloroethane (DDT), hexachlorocyclohexanes (HCHs), and polycyclic aromatic
hydrocarbons (PAHs) can be easily adsorbed to their surface and then released over time.94
The health
80
IPCC Working Group III Report: Mitigation of Climate Change (2022) https://www.ipcc.ch/report/sixth-assessment-
report-working-group-3/
81
Cabernard, L., Pfister, S., Oberschelp, C. et al. Growing environmental footprint of plastics driven by coal
combustion. Nat Sustain 5, 139–148 (2022).
82
Phytoplankton response to polystyrene microplastics: Perspective from an entire growth period - ScienceDirect
83
Can microplastics pose a threat to ocean carbon sequestration? - ScienceDirect
84
Sciencealert.com, Study shows how microplastics can easily climb the food chain. Should we be worried?, 2022.
85
Cox, K. D. et al., ‘Human consumption of microplastics’, Environmental Science and Technology, Vol. 53, No 12,
2019, pp. 7068–7074.
86
Sciencealert.com, ‘Study shows how microplastics can easily clim the food chain. Should we be worried?’, 2022
(https://www.sciencealert.com/study-shows-how-microplastics-can-easily-climb-the-food-chain-should-we-be-
worried).
87
Schwabl, P. et al., ‘Detection of various microplastics in human stool’, Annals of Internal Medicine, Vol. 171, No 7,
2019, pp. 453–457, American College of Physicians.
88
Ragusa, A. et al., ‘Plasticenta: First evidence of microplastics in human placenta’, Environment International, Vol.
146, 2021, Elsevier BV.
89
Leslie, H. A. et al., ‘Discovery and quantification of plastic particle pollution in human blood’, Environment
International, Vol. 163, 2022, Elsevier BV.
90
Marine microplastic debris: An emerging issue for food security, food safety and human health - ScienceDirect
91
Potential Health Impact of Environmentally Released Micro- and Nanoplastics in the Human Food Production Chain:
Experiences from Nanotoxicology | Environmental Science & Technology (acs.org)
92
Gasperi, J., et al., Microplastics in Air: Are We Breathing It In?, Current Opinion in Environmental Science & Health,
1–5. 2018. https://doi.org/10.1016/J.COESH.2017.10.002
93
Blackburn, K., Green, D., The potential effects of microplastics on human health: What is known and what is
unknown, Springer, Ambio, 51:518–530, 2021.
94
Corcoran P. L. et al., A comprehensive investigation of industrial plastic pellets on beaches across the Laurentian
Great Lakes and the factors governing their distribution, Science of the Total Environment, 747:141227, 2020.
21
impacts of POPs are not immediate but result rather from chronic, cumulative and long-term
exposure.95
In addition, microplastics could potentially act as vectors for pathogens and microbes.96
Impacts on the economy
Generally, the growing evidence on microplastics’ presence in seafood, salt, honey, fruits, vegetables
and drinking water could undermine consumer confidence and bear economic consequences.
There are potential negative economic impacts on activities such as commercial fishing and
agriculture (e.g. reduced fishing due to impacts of microplastics on marine eco-systems and fauna,
which eats it) as well as tourism and recreation (e.g. reduced attractiveness due to impacts of
microplastics on beaches and vulnerable areas like national parks, rivers and lakes97
). Clean-up
operations are challenging and, according to OSPAR, often costly, as clean-up off-site and in the
environment requires time and specialist equipment. Operations are usually the responsibility of local
communities with a negative impact on their budgets. Clean-up costs are often unknown. However,
beach clean-ups are estimated to cost the city of Marseille (France) EUR 1 000 000 per year.98
KIMO
Netherlands reported that the clean-up costs of the 2019 pellet spill of the MSC Zoe in the Wadden
Sea would be approximately EUR 100 000 annually.99
Monitoring costs of pellet ingestion by species
are also often unknown. However, la Rochelle Aquarium’s monitoring of microplastic ingestion by
loggerhead sea turtles cost a total of EUR 50 000 over four years. Another relevant example is the
monitoring of microplastic ingestion by fulmars provided by ornithological groups, which costs EUR
33 300 for one winter season.
The cost of pellets lost to the environment is equivalent to an economic loss for the businesses owing
them of EUR 52 – 184 million, coming from about 52 140 – 184 290 tonnes of lost pellets (with
around 1000 EUR/t).
2.4 What are the problem drivers?
There are several market and regulatory failures, which are summarised below and explained in more
detail in Annex 8.
2.4.1 Market failures
Prices do not reflect negative externalities: The activities of economic operators do not integrate
the negative externalities caused by pellets finding their way into the environment, leading to a
suboptimal market outcome. On one side, due to their small size, pellets are easy to spill; on the other
side, it is relatively costly to prevent spills or to clean up after spills as good handling practices require
measures to be taken, such as training of staff. The cost of lost pellets, incurred by economic operators
95
Nadal, M. et al., Climate change and environmental concentrations of POPs: A review, Environmental Research, 143:
177-185, 2015.
96
Microplastics from textiles: towards a circular economy for textiles in Europe — European Environment Agency
(europa.eu)
97
Plastic Giants polluting through the backdoor; Silent Pollution – Who is contaminating Puglia’s coastline with plastic
pellets?; Plastic pellets spill pollutes Danish, Norwegian, Swedish coastlines; Microplastic pollution in the surface
waters of Italian Subalpine Lakes; Granulés plastiques industriels sur le littoral français
98
OSPAR Background document on pre-production Plastic Pellets 2018. SOS Mal de Seine Association highlighted
the lack of capacity of public authorities to deal with large‐scale pollution of pellets on beaches (e.g. caused by lost
containers). As a matter of fact, clean‐up operations are complex to undertake because these particles are difficult to
see due to their size or vegetation which may hide them, and they should be carried out within an hour of an incident
to prevent widespread pollution by wind, rain, and/or tides.
99
Fishing for Litter fleet cleans up after MSC Zoe but who pays the costs? – KIMO (kimointernational.org)
22
involved in the production, use and transport of pellets, is not sufficiently high to motivate a change
in behaviour. In addition, once spilled, pellets are considered contaminated and therefore become
waste.100
There are no other incentives for economic operators to integrate the negative externalities
caused by pellets finding their way into the environment.
Imperfect information: Economic operators do not have sufficient information to be fully aware of
the pellets that are unintentionally lost from their operations (and of consequential impacts). As no
systematic reporting is in place, they are not aware of quantities released, and because there is no or
insufficient awareness raising about the impacts, they are not aware of the negative externalities.
Furthermore, as information on available preventive and mitigating measures by responsible
companies is not sufficiently promoted throughout the supply chain, they are not aware of possible
actions to be taken. Under these circumstances, it is difficult for economic operators to make
sustainable choices when investing in the equipment, determining their internal procedure or
choosing partners along the supply chain.
As such, no sufficient information about quantities, impacts, actions etc., is routinely sought or
promoted throughout the supply chain and economic operators do not sufficiently integrate concerns
about pellet losses in their operations. This problem of insufficient information is particularly acute
among the smaller companies, mostly on the conversion and logistic side.
Lack of specific support and attention for the smaller companies present in the pellet supply chain,
to which the measures to implement would be costly, also explains a suboptimal market outcome.
2.4.2 Regulatory failures
Existing EU legislation does not address pellets sufficiently: The absence of specific requirements
to implement best handling practices is arguably the most significant of the problem drivers. While
existing EU regulatory frameworks could be relevant (governing chemicals, marine litter, water,
industrial emissions, waste, packaging and transport activities), they do not specifically address the
issue of pellet losses and their responsible handling to prevent and reduce losses to the environment.
In particular, pellets are only very partially covered by the REACH restriction on microplastics
intentionally added to products101
as: 1) the requirements i.e. instructions for use and disposal and
reporting on estimates on quantities released on an annual basis, are generally defined and 2) they do
not help as such to effectively reduce pellet losses or prevent them (e.g. they are not a requirement
on their handling). No methodology is foreseen to measure pellet losses (it was left to the industry to
develop a methodology).
At the national level, France is the only Member State who has adopted legislation specifically to
prevent pellet losses. This is described in detail in Section 5.1.2. Generally, the very large majority
of facilities involved in the pellet conversion or the pellet logistic are too small to attract any public
attention and routine visits from the environmental regulators.
The absence of specific requirements in EU legislation to implement best handling practices is
explained in detail in Annex 8.
100
Hann, S., Sherrington, C., Jamieson, O., Hickmann, M., Kershaw, P., Bapasola, A., Cole, G. (2018). Investigating
options for reducing releases in the aquatic environment of microplastics emitted by (but not intentionally added in)
products, Eunomia.
101
Commission Regulation (EU) …/… amending Annex XVII to Regulation (EC) No 1907/2006 concerning the
Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) as regards synthetic polymer
microparticles.
23
2.5 How likely is the problem to persist?
It is likely that without EU action, the problems related to plastic pellets would worsen.
Table 2: Assumptions on whether / how the identified problems will persists
Problem Assumptions on whether / how this problem persists
(I) Market failure -
economic operators do not
integrate negative
externalities of pellet
pollution
• In the absence of external factors (economic crisis, pandemic etc.), the
demand and consumption of plastic products is expected to increase.
Pellets losses are also expected to continue in the coming years, as
without EU action, there are no incentives for economic operators to act,
particularly for some actors in the supply chain (e.g. actors with a low
public profile).
• Recently adopted voluntary initiatives and regulatory actions at Member
State level (i.e. France; other MS are mostly relying on industry efforts
or waiting for EU action) are expected to lead to some reduction in pellet
losses. However, the effectiveness of these initiatives and actions is also
likely to remain limited considering current enforcement issues and the
lack of enforcement mechanisms in the new initiatives and actions,
particularly for some actors in the supply chain (e.g. actors with a low
public profile).
(II) Market failure –
economic operators do not
have sufficient
information and
awareness as to pellet
losses (and consequential
impacts)
• As scientific understanding of environmental and human health impacts
of pellet pollution is further updated, new risks may be identified and
pressure to take action may increase.
• Recently adopted voluntary initiatives and regulatory actions are also
expected to increase the availability of information.
• However, the level and quality of information are likely to remain
limited. In particular, competencies, training and awareness of staff for
all actors in the supply chain may not improve substantially in the
absence of proper and mandatory training requirements. Similarly,
accessibility of information may not improve substantially in the
absence of proper and mandatory transparency mechanisms.
(III) Regulatory failure,
even if some aspects of
this can be addressed by
ongoing initiatives
(REACH reporting
obligation)
• The REACH reporting obligation may increase information on pellet
losses and improve the quality of the information collected to assess
future risks.
• However, the obligation is not specific to pellets but generic to all
‘derogated uses’, and it does not reduce pellet losses or prevent them
(e.g. it is not a requirement on their handling). Moreover, in the absence
of a harmonised methodology for measuring pellet losses, there will be
inconsistencies in estimates reported, and comparing data will be
difficult.
3 WHY SHOULD THE EU ACT?
3.1 Legal basis
This initiative is based on Article 192(1) of the Treaty on the Functioning of the European Union
(TFEU).
24
3.2 Subsidiarity: Necessity of EU action
Transboundary nature of the problem
This is the most important aggravating factor and reason to act. Microplastic pollution is readily
transported from one geographical place to another by atmosphere and surface waters and seas, and
can be found in the most remote places on the planet. National action alone cannot address the
problem of transboundary pellet pollution. As an example of this, 60% of European river basin
districts are international (either shared between EU Member States or between an EU Member State
and a third country), and the Water Framework Directive made cooperation between countries
sharing a basin within the EU mandatory. As an answer to this transboundary pollution, the Regional
Seas Conventions for the protection of the marine and coastal environment around Europe (for the
Mediterranean, Baltic, Northeast Atlantic and the Black Sea) have regional plans against marine
litter, including microplastics, and recommend actions to reduce them. In particular, the Convention
for the Protection of the Marine Environment of the North-East Atlantic (OSPAR) has adopted a non-
binding Recommendation102
containing guidelines to reduce the loss of plastic pellets into the marine
environment.
3.3 Subsidiarity: Added value of EU action
There is a clear benefit in taking action at the EU level on pellet losses, as this can efficiently ensure
a high level of environmental protection throughout the EU territory, and a harmonised and well-
functioning internal market across all Member States (same requirements for pellet pollution
prevention and reduction, reduced costs of harmonised approaches). Fragmented approaches, such
as national actions on one aspect only of pellet pollution (e.g. measuring), actions not covering the
entire pellet supply chain (e.g. producers and converters but not transporters) or actions limited to
one or a few Member States, would not bring efficiency gains as they are less effective in reducing
transboundary pellet pollution and overall more costly in achieving wider policy goals on reducing
releases of microplastics.
Furthermore, the size of the internal market provides a critical mass enabling the EU to promote
handling practices that release fewer pellets that could influence the pellet supply chain worldwide.
It will also guide EU actions at the global level in the context of the negotiations on a Global Plastic
Agreement and at the level of Regional Seas Conventions.
The principle of proportionality requires EU action to be limited in its content and form to what is
necessary to achieve the objectives of the Treaties it intends to implement. The application of this
principle is linked to the principle of subsidiarity and the need to match the nature and intensity of a
given measure to the identified problem. The principle of proportionality is considered throughout
the impact assessment and, in particular, in Annex 11 where the costs of the regulatory option for
SMEs are assessed.
4 OBJECTIVES: WHAT IS TO BE ACHIEVED?
4.1 General objectives
The general objective of this initiative is to contribute to the reduction of microplastic-related
pollution by preventing and reducing pellet losses to the environment that are due to current handling
102
OSPAR Recommendation 2021/06 on the reduction of plastic pellet loss into the marine environment.
25
pellet practices at all stages of the supply chain within the EU, thus reducing the adverse
environmental, economic and potential human health consequences of pellet pollution.
4.2 Specific objectives
Accordingly, the above general objective translates into three specific objectives:
• To reduce and prevent pellet losses in an economically proportionate manner to a level
consistent with the Commission’s 2030 target of a 30% reduction in both intentional and
unintentional microplastic releases (compared to 2016 levels);
• To improve information on the magnitude of pellet losses throughout the pellet supply chain,
in particular the accuracy of loss estimates, and to raise awareness among relevant actors; and
• To ensure the appropriate mitigation of impacts on SMEs involved in the pellet supply chain.
5 WHAT ARE THE AVAILABLE POLICY OPTIONS?
5.1 What is the baseline from which options are assessed?
The baseline has been developed using 2019 as the base year and the following data sources and
assumptions.
• 2019 is taken as the base year, as 2020 is an outlier because of COVID, and we are seeing
positive growth trends again from 2021.
• For virgin pellets, the projections are made from 2019 figures103
; a growth rate of 0.9% per
year is assumed till 2030.104
• Source for recycled pellets production data (2019-2021) is Plastic Recyclers Europe; a
growth rate of 5.6% per year is assumed.105
• Source for bio-based pellets production data (2019-2021) is Plastics Europe; for growth rate
a CAGR of 14% for 2022-2027106
, and the same trend is assumed to continue till 2030.
• Pellets imports and exports figures for virgin pellets are from Eurostat, a growth rate of 0.9%
is assumed till 2030.
Using these assumptions, the total EU pellet production is expected to reach about 80 million tonnes
in 2030. If we take into account imports and exports, the net volume of pellets used in the EU would
be around 76 million tonnes in 2030. The total figures estimated here are within a 1% range of to the
estimates from the recent OECD scenario107
that used a modelling approach.
103
Plastics Europe changed the calculation method in 2021, excluding adhesives, paints and coatings, thus not used to
be coherent with previous year estimates and also with import/export figures
104
Plastics Europe and SystemIQ
105
K 2022 - Trend Report Europe https://www.k-online.com/en/Media_News/Press/Technical_article/K_2022_-
_Trend_Report_Europe
106
Nova Institute (2023) Bio-based Building Blocks and Polymers Global Capacities, Production and Trends 2022–2027
https://renewable-carbon.eu/publications/product/bio-based-building-blocks-and-polymers-global-capacities-
production-and-trends-2022-2027-short-version-pdf/
107
OECD (2022) Global Plastics Outlook: Policy Scenarios to 2060. https://www.oecd.org/publications/global-plastics-
outlook-aa1edf33-en.htm
26
Figure 5: Pellet production volumes in EU-27 and projections until 2030
To define the projected development of total pellet losses by 2030, consideration was given to the
following: Existing and forthcoming EU legislation; National and international initiatives; Industry
initiatives. These legislation and initiatives are presented below.
5.1.1 Existing and forthcoming EU legislation
The requirement to report estimates of pellet losses under the REACH restriction on microplastics
intentionally added to products108
aims to increase information on pellet losses and improve the
quality of the information collected to assess the risks deriving from these microplastics in the future.
The reported information aims to allow uses with high releases to be identified and prioritised for
further regulatory risk management. However, the requirement does not help as such to effectively
reduce pellet losses or prevent them (e.g. it is not a requirement on their handling), and is lacking a
methodology to measure pellet losses (it was left to the industry to develop a methodology).
The Marine Strategy Framework Directive (MSFD) addresses the monitoring and assessment of the
impacts of microlitter, including microplastics, in coastal and marine environments in a way that they
can be linked to point-sources.109
An update of the first MSFD guidance110
on monitoring marine
litter guidance document is under development in view of harmonised methodologies, including the
monitoring of the presence and distribution of plastic pellets along the coastline. However, this does
not include specific requirements concerning the prevention or reduction of pellet losses at the source.
The revised Urban Wastewater Treatment Directive (UWWTD)111
and the evaluation of the Sewage
Sludge Directive (SSD)112
are not explicitly considered in the baseline as (1) the analysis was done
at the same time, and (2) more importantly, the measures under consideration for the UWWTD are
108
Commission Regulation (EU) …/… amending Annex XVII to Regulation (EC) No 1907/2006 concerning the
Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) as regards synthetic polymer
microparticles.
109
Directive 2008/56/EC establishing a framework for community action in the field of marine environmental policy:
“…micro-litter shall be monitored in the surface layer of the water column and in the seabed sediment and may
additionally be monitored on the coastline. Micro-litter shall be monitored in a manner that can be related to point-
sources for inputs (such as harbours, marinas, waste-water treatment plants, storm-water effluents), where feasible.”
110
Guidance on Monitoring of Marine Litter in European Seas (europa.eu)
111
COM/2022/541 final, 2022.
112
Council Directive 86/278/EEC on the protection of the environment, and in particular of the soil, when sewage sludge
is used in agriculture.
27
limited in scope and impact (mainly monitoring and in larger plants, additional treatment to remove
microplastics, which would go to sludge). As for the SSD, which is currently being evaluated, it is
not clear yet which measures would be proposed in a potential future revision. More information on
the links between water legislation and pellet losses is presented in Annex 6.
The Industrial Emissions Directive (IED)113
regulating the prevention and management of pollution
arising from industrial activities in large industrial installations, is only partially suited to address
pellet losses as a form of pollution occurring along the entire supply chain. While activities like the
production of polymeric materials on an industrial scale fall under the scope of the IED, other
activities like the conversion, storage or transport of pellets, usually operated by small and medium
enterprises, are not covered. Moreover, the BAT (Best Available Technique) Reference Document
(BREF) for the production of polymers was adopted in 2007 and does not address the specific issue
of pellet losses.114
Waste legislation such as the Waste Framework Directive (WFD)115
and Packaging and Packaging
Waste Directive116
does not specifically address the pellet loss issue as they do not regulate emissions
during the production of products or packaging. The WFD imposes Member States a generic
obligation to take waste preventive measures addressing the industrial generation of waste as pellets
can be.
Therefore, there is no comprehensive EU legislation addressing pellets to reduce their losses and their
environmental and potential health impacts, with a full supply chain approach.
5.1.2 National and international initiatives
A few Member States have already started to introduce measures to tackle pellet losses. These
measures are summarised in Table 3 and presented in detail in Annex 6.
Table 3: Member State actions targeting pellet losses
Country Actions
Austria • Law adopted addressing “filterable substances” to which pellets belong
Belgium
(Flanders)
• Introducing environmental permit system / Best Available Techniques
• Examining an environmental management system with possible certification
Denmark • Monitoring
• Waiting for OCS certification scheme implementation and Commission’s proposal
France • Law adopted providing minimum obligations to prevent pellet losses for all actors in
the supply chain along with mandatory external auditing
The
Netherlands
• Monitoring
• Waiting for OCS certification scheme implementation
Spain • Promoting OCS certification scheme implementation
Sweden • Revising current guidelines to make them more comprehensive and include more actors
across the supply chain
113
Directive 2010/75/EU on industrial emissions (integrated pollution prevention and control) (recast)
114
https://eippcb.jrc.ec.europa.eu/reference/production-polymers
115
Directive 2008/98/EC on waste and repealing certain Directives.
116
Directive 94/62/EC on packaging and packaging waste.
28
France is the only Member State who has adopted legislation specifically to prevent pellet losses.
This legislation covers businesses making and handling pellets in quantities higher than 5 tonnes
including logistic platforms but not transporters. The threshold has been reduced from what initially
proposed, i.e. 10 tonnes following public consultation. Businesses are subject to equipment and
procedural obligations to prevent the loss and leakage of pellets, and are required to be regularly
audited by independent and accredited certification bodies.117
Obligations remain of a relatively
generic nature. For instance, a business must identify areas where pellets are more likely to spill,
check that the packaging used is designed to minimise the risk of spills and train and raise awareness
among staff. As a unique transparency measure, the company must make the summary of the auditing
report available on its website. The Decree entered into force on January 1, 2022 for new sites, while
for existing sites, it will enter into force in 2023, at the same time as equipment obligations.
In 2021, the British Standards Institution published the Publicly Available Specification PAS
510:2021.118
This PAS is for use by any organization of any size in any part of the supply chain that
handles pellets. It builds on the industry-led Operation Clean Sweep® (OCS) programme by creating
a standardized and consistent approach to risk management and containment of pellets.119
The PAS
can be considered for further development as a British standard or constitute part of the UK input
into the development of a European or International standard on pellets.
In 2021, the parties to the Convention for the Protection of the Marine Environment of the North-
East Atlantic (OSPAR) adopted the non-binding Recommendation 2021/06120
to reduce the loss of
plastic pellets in the marine environment by promoting the timely development and implementation
of effective and consistent pellet loss prevention standards and certification schemes for the entire
plastic supply chain. The Recommendation was accompanied by supporting guidelines which set out
essential requirements for standards and certification schemes. The first full implementation report
is due in January 2025. However, an interim report on the progress made will be published in 2024.
A preliminary interim report was informally shared by OSPAR in February and the actions reported
by the Member States that are parties to the OSPAR Convention are presented in the above Table 3.
In the International Maritime Organization (IMO), a Correspondence Group on Marine Plastic Litter
from Ships looked at measures that could be relevant in reducing the environmental risk associated
with the maritime transport of plastic pellets. While three primary measures including packaging
were identified as particularly relevant to reduce the environmental risks associated with the maritime
transport of plastic pellets (and a voluntary circular to this effect was drafted), the Group was not in
117
Décret no 2021-461 du 16 avril 2021 relatif à la prévention des pertes de granulés de plastiques industriels dans
l’environnement [Decree n. 2021-461 of 16 April 2021 related to the prevention of the leakage of industrial plastic
pellets into the environment], Journal official “Lois et Décrets” no. 0092 du 18 avril 2021 [JORF] [Official journal
“Laws and Decrees” no. 0092 of 18 April 2021], 18 April 2021, Fr.
118
BSI Knowledge, ‘Plastic pellets, flakes and powders. Handling and management throughout the supply chain to
prevent their leakage to the environment. Specification - PAS 510:2021101’, 2021.
119
The PAS provides requirements in the following areas: a) Organizational responsibilities; b) Leadership and
commitment; c) Competence, training and awareness; d) Risk assessment of pellet loss to the environment; e)
Operational controls, i.e. prevention, containment and clean-up, procurement and suppliers; f) Internal and external
communication; g) Performance evaluation, i.e. monitoring and documentation, auditing and verification of
conformity; h) Improvement, i.e. internal and external non-conformity and corrective action, and continual
improvement.
120
www.ospar.org/convention/strategy
29
a position to conclude on the most appropriate instrument for mandatory measures.121
The Group
noted that experience gained from the implementation of the voluntary measures could be useful in
the further consideration of the most appropriate instrument for mandatory measures.
A similar international initiative is ongoing on containers lost at sea, and discussions are held on the
possibility of making the information on containers lost at sea available publicly (to date, sufficient
information is reported only to insurance companies). If retained, this measure would allow for a
better understanding of the scale and magnitude of pellets lost at sea and would facilitate liability
identification and compensation arrangements in line with the polluter pays principle.
5.1.3 Industry initiatives
In 1991, the industry-led Operation Clean Sweep (OCS) initiative was created by SPI (the US Plastics
Industry Trade Association, now known as the Plastics Industry Association), with companies
voluntarily signing a pledge to work towards zero plastic pellet loss.
Since 2015, the European plastic manufacturing industry has progressively adopted the Operation
Clean Sweep® programme (OCS)122
as a voluntary pledge. Under this programme, each company
making or handling pellets recognises the importance of making zero pellet losses by:
1) improving worksite set-up to prevent and address spills;
2) creating and publishing internal procedures to achieve zero pellet losses;
3) providing employee training and accountability for spill prevention, containment, clean-up
and disposal;
4) auditing performance regularly;
5) complying with all applicable local and national regulations governing industrial pellet
containment;
6) encouraging partners to pursue the same objectives.
Recommendations on how to deliver on each of these six actions are given in the form of a manual.
While best practices are generally well understood by OCS signatories they have not been
comprehensively implemented. As of September 2023, 2790 companies have committed to OCS123
.
This figure includes all PlasticsEurope’s members (these are producers; adherence to OCS is
mandatory for the members of this association). Only around 2% of EuPC’s members (converters)
have committed to OCS (around 1 000 converters out of 48 000); and only around 500 transport
companies. As no precise reporting has been made available within OCS, it is not possible to say
whether those who have committed have also effectively or fully implemented the programme, with
121
The three primary measures identified as relevant are: Packaging provisions for plastic pellets carried at sea;
Provisions for notifying the carrier so that containers containing plastic pellets can be identified; Stowage provisions
for freight containers containing plastic pellets. Among the options for mandatory measures, the Group considered
the three following options/instruments: Assignment of an individual UN Number (class 9) for plastic pellets
transported at sea in freight containers (UN Number); Amendment to Appendix I of MARPOL Annex III that would
recognize plastic pellets as a “harmful substance” (Harmful substance); A new chapter to MARPOL Annex III that
would prescribe requirements for the transport of plastic pellets in freight containers without classifying the cargo as
a harmful substance/dangerous goods.
122
www.opcleansweep.eu
123
www.opcleansweep.eu
30
evidence showing the opposite. Both acute and chronic pellet incidents have been reported to
continue over the last years, including at sites that are OCS signatories.124
The launch of the OCS Certification Scheme (OCS CS) aims to address these issues. Recognising
the low uptake of OCS by the industry, in 2019, European plastic manufacturers (PlasticsEurope)
and converters (EuPC) announced plans to develop a voluntary certification scheme building on OCS
and including requirements, third-party, independent auditing, certification and some level of
transparency (all aspects not foreseen under the current OCS programme). In January 2023, the new
scheme was officially launched by its promoters following preparatory work by a Supervisory Board
gathering producers, converters, representatives of some governments (Scotland, Germany and
Spain), one NGO (Fauna & Flora International), some certification bodies (Aenor and Tuv-Nord) as
well as one European Institution (the European Parliament). Representatives of the European
Commission, the European Chemical Transport Association (ECTA) and Cefic took part in the
discussions as observers.
Under the new scheme, companies are invited to comply with requirements from the following broad
categories:
• Commit to making zero loss of pellets, flakes, and powder a priority;
• Improve worksite set to prevent and address spills, meaning site risk assessments;
• Create and publish internal procedures to achieve zero pellet loss goals meaning documented
procedures, including, for instance, description of roles and responsibilities, but also
recording, investigation and follow-up of incidents and effectiveness of procedures,
equipment and instructions in place;
• Provide employee training, including theory and practical hands-on exercises and
accountability for spill prevention, containment, clean-up and disposal;
• Audit performance regularly, meaning internal audits;
• Comply with all applicable local and national regulations governing pellet containment;
• Encourage partners to pursue the same objectives to be monitored, for instance, via the % of
contracts containing an OCS clause.
Compliance will be verified at site level by third-party independent auditors. Once successfully
audited, companies will be certified compliant and will have the name of the company and the site
location listed in a public register. The certification will be valid for 3 years after the date of the first
audit, subject to an annual follow-up control audit. First audits started in June 2023.
While it goes in the right direction, the new scheme does not encompass the whole supply chain and
is, therefore, only a partial attempt to pursue zero pellet pollution effectively. First of all, while the
requirements are in principle applicable to all companies handling pellets, and all companies can get
audited and certified, the new scheme does not apply to the whole supply chain in the same way: it
is mandatory for members of PlasticsEurope (adherence to the existing OCS programme is already
mandatory for them) but is for the moment voluntary for key players in the pellet supply chain such
as converters, transporters, warehousing operators and recyclers.
124
Regarding chronic pellet losses in the Netherlands, Belgium and Spain, see
https://www.plasticsoupfoundation.org/wp-content/uploads/2022/03/Westerschelde-plastic-nurdles-versie-
definitief-21-11-2021-2.pdf; https://surfrider.eu/en/learn/news/ecaussinnes-belgium-surfrider-foundation-tackles-
industrial-plastic-granules-1211028228325.html; https://goodkarmaprojects.org/2020/11/20/new-report-out-
exposes-alarming-impacts-of-plastic-pellets-across-europe/?lang=en.
31
EuPC found it difficult to make adherence to the new scheme mandatory for their members (to date,
adherence of converters to the existing OCS programme is very low). Members of EuPC are
European and national associations representing close to 48 000 individual companies, out of which
66% are micro-companies. It is estimated that while the certification process is carried out over a
relatively short period of time for producers (PlasticsEurope expect all their members to be certified
by the end of 2024, some producers reporting however a longer period before certifying all their
sites), this process will likely take much longer for converters, with no assurance that it would cover
a major part of converters at all.
Transporters, warehousing operators and clean tankers are observers of the new OCS certification
scheme and will be assessed (not certified) under the chemical industry’s Safety and Quality
Assessment for Sustainability (SQAS) system, which contains revised requirements to tackle pellet
losses since March 2023125
. Full alignment between the new OCS certification scheme and the SQAS
system is still pending. In particular, there are no plans currently to oblige OCS-certified companies
to work exclusively with SQAS-assessed transport, warehousing and cleaning companies. To date,
there are approximately 3 000 transport companies which are SQAS-assessed and even more
transport companies which are not SQAS-assessed. According to the sector, SQAS-assessed
transport companies cover about 80% of the total pellet transport of virgin pellet producers in Europe.
Cleaning stations are mostly SQAS assessed, while among warehousing operators, only a part is
SQAS assessed.
To test the new scheme, nine pilot audits covering producers, converters and transporters were held
in 2021 in five countries: Belgium, Netherlands, Portugal, Spain and France. The audits are
conducted by well-known boddies like Aenor, Bureau Veritas, SGS, etc. All audited companies failed
to pass.
At the end of 2021, Fauna and Flora International (FFI) decided to resign from the Supervisory Board
of the new OCS certification scheme arguing that it does not fully align with the OSPAR
Recommendation and citing issues with the governance of the scheme, the level of transparency, the
lack of a formal standard from a recognised standardisation body, the fact that the whole supply chain
is not captured adequately and that timelines for compliance have not been set. Instead, FFI called
for the introduction of effective legislation applicable to all pellet handling companies and based on
a supply chain approach to fully eliminate this source of pollution126
.
Recyclers are neither promoters nor observers of the new scheme and have their own certification
scheme in place (RecyClass), which has a section on pellet losses requiring the implementation of a
procedure to prevent leakages within the premises of and surrounding the recycling plant and the
training of staff. To go a step further, recyclers are conducting a study on potential areas in the
recycling processes where microplastics can be generated and released and on preventive measures.
The recommendations of this study would be used to complete the RecyClass certification scheme
on the pellet losses/microplastics requirements.
125
SQAS questionnaires. A first addition to the SQAS assessment questionnaire was made in January 2022.
126
FFI call for the introduction of effective legislation that will require all pellet (flake and powder) handling companies
across the whole supply chain to provide independent verification that pellet loss prevention measures have been
implemented, maintained and monitored for effectiveness towards the goal of zero pellet loss to the environment,
prior to materials being placed on the market. They also call for tighter restrictions on the packaging and labelling of
pellets being prepared for transport to reduce the risk of loss and improve communication. Finally, EU legislation
should complement international maritime legislation for pellets currently being considered by IMO to reduce the
risk of catastrophic pellet pollution at sea.
32
5.1.4 The baseline
All in all, the above national and international initiatives are expected to contribute to a limited
change in pellet loss reduction by 2030. The only national legislation adopted to prevent pellet losses
via legal obligations (i.e. France) is relatively generic and does not cover transporters. An assumed
reduction is considered for France. Both the BSI PAS and the OSPAR Recommendation provide are
reference documents in the field as they provide a comprehensive but non-binding set of guidelines.
However, in both cases, it is up to the companies or parties to implement such measures, and it was
not possible, at the moment of the impact assessment, to evaluate their precise implementation. The
IMO work on pellets focuses on one aspect only i.e. shipping of pellets, and has resulted so far in
voluntary measures only, with very limited effects up to date.
Once fully in place, the new industry-led OCS certification scheme is expected to contribute to some
reduction in pellet losses by 2030. However, the new scheme does not adopt a full supply chain
approach and uncertainties persist about its enforceability. In particular, it is difficult to estimate the
take-up of the new scheme by the industry, and therefore its effectiveness, and this counts equally
for the schemes by the recyclers and logistic companies (respectively, RecyClass and SQAS). It is
generally expected that smaller firms will implement voluntary schemes to a lesser degree than larger
ones. This results in different assumptions for the producers (larger firms) compared to converters
and logistics (smaller firms).
Therefore, for the baseline, it has been assumed that by 2030:
1) 90% of the total virgin pellet volume produced (by the members of Plastics Europe) and 5%
for the non-Plastics Europe members will be certified compliant against OCS new rules and will
be effectively implementing such rules with a success rate ranging from 60% to 80%;
2) 20% of the total recycled pellet volume will be certified compliant against RecyClass pellet
provisions and will be effectively implementing the new provisions with a success rate ranging
from 40% to 60%;
3) 30% of the total volume processed will be certified compliant against OCS’ new rules and will
be effectively implementing such rules with a success rate ranging from 40% to 60%;
4) 40% of the total volume handled by logistics companies will be SQAS assessed and will be
effectively implementing such a scheme with a success rate ranging from 40% to 60%.
5) The French legislation will cover about 85% of the French pellet volume (about 10% of the EU
volume), leading to a 60-80% pellet loss reduction in 2030.
Based on these assumptions, there will still be pellets lost in the range of 42 050 – 170 266 tonnes
per year by 2030.
5.2 Description of policy options assessed in this impact assessment
This impact assessment considers four policy options addressing the general and specific objectives
defined under Section 4. These options were selected based on literature review and input from
stakeholders, either bilateral or in six stakeholder workshops, and a seventh workshop organised in
December 2022 to specifically address pellets, the related baseline and preferred option. Information
provided in response to the Inception Impact Assessment and the Public Consultation was also taken
into account along with the findings of a survey carried out between January and February 2023
specifically targeting SMEs active in the pellet supply chain as requirements would affect them more
33
than larger companies. Each selected option has been screened from a longer list of potential options
developed with experts and stakeholders that are presented in detail in Annex 10. As the IA focussed
on measures with direct impact and in alignment with the Commission’s overall 30% reduction target
by 2030, research actions were screened out at an early stage. However, they might still be needed to
foster further innovation in actions that could have an impact in the longer term. It was also estimated
that a full value chain approach should be privileged in order to assure that all parts would implement
pellet reduction measures.
5.2.1 Option 1: Mandatory standardised methodology to measure pellet losses
Focus: Develop a mandatory standardised methodology to measure pellet losses.
Description: under this option, the Commission initiates the development of a mandatory
standardised methodology to measure pellet losses from the range of relevant pellet-related industrial
activities (i.e. production, conversion, recycling, transport and other logistic operations), to be used
for the reporting on estimates of quantities released on an annual basis, as obliged under the REACH
restriction. Reporting is needed to increase information on pellet losses and improve the quality of
the information collected to assess the risks deriving from these microplastics in the future. This
methodology would need to be coherent with the requirements of the restriction. The new standard
will improve the quality of the reporting on the quantities released (one methodology for all instead
of several, different ones) improving the information on the magnitude of pellet losses throughout
the pellet supply chain, while also raising awareness among relevant actors as they can measure pellet
spills and losses and assess their evolution over time.
This option would be developed via the European Standards Organisation (CEN), which typically
takes 3-4 years to complete. The umbrella association of European converters (EuPC) is developing
for the OCS certification scheme signatories a methodology for measuring pellet losses, named the
Bow-tie model, and this work can serve as the basis of the mandatory harmonised methodology.
This option addresses mainly the problem drivers of market (imperfect information), but also of
regulatory failures and support to SMEs. It would address the information failure problem and allow
for the effective implementation of the other options. Indeed, a standard methodology is essential to
monitor the implementation of Option 2 and the evolution of pellet losses. It would facilitate the
comparison of different packaging solutions for pellets, under Option 3. It would also be necessary
to set up an EU target under Option 4. It is therefore the best and fastest option to address information
failure on pellets and monitor the possible success of the options.
5.2.2 Option 2: Mandatory requirements to prevent and reduce pellet losses in a new EU law
Focus: Impose mandatory requirements on proper handling of plastic pellets combined with
mandatory certification.
Description: under this option, mandatory requirements are defined and imposed on the entire pellet
supply chain thus maximising the opportunities of preventing and reducing pellet losses. The
requirements to comply with at the site level are based on those already identified by stakeholders in
the framework of the BSI PAS and OSPAR recommendation and the industry-led OCS certification
scheme. Firms will need to provide evidence of the following:
1. The creation and publication of internal procedures such as defining organisational
responsibilities, a pellet loss prevention policy with pellet loss prevention objectives, a regular
risk mapping exercise and corresponding risk management assessment at site level;
34
2. Competence, training and awareness of staff to prevent, contain and clean up spills including
maintaining a record of spills;
3. Operational controls including preventive, mitigating and clean up measures and equipment;
4. Communication of implemented policies, measures and objectives both within the
organisation and externally, as well as of improvement as reaction to non-conformity.
A risk mapping exercise needs to be performed to identify the leakage potential of all necessary,
handling steps in all high-risk areas and pathways to the external environment. Once this is done,
there needs to be a risk management assessment performed to determine where actions are required
for equipment, best practice handling, mitigation and remediation.
Knowing that the first step should be to avoid all unnecessary handling of pellets, preventive barriers
include “Avoidance of unnecessary handling” (as the possibility of minimising the number of transfer
points in the supply chain is the starting point for reducing spill opportunities) and “Best practice
handling”. The latter can take the form of collection and retention trays. Mitigation and clean-up
measures can take the form of filters, vacuum systems to remove accumulated pellets, and tools for
immediate cleaning (shovel, broom, brush, vacuum cleaner).
To demonstrate compliance with the defined mandatory requirements, all pellet handling companies
including transporters and logistic platforms must be externally audited and certified at the site level
by independent certifying bodies selected among accredited organisms, as a condition to operate.
This implementation approach is consistent with the OSPAR Recommendation, adopted by OSPAR
contracting parties including the EU and 11 Member States, which promotes certification schemes
for the entire supply chain. It is fully in line with the polluter pays principle as companies are required
to bear the compliance costs referring to the needed measures. It allows for a harmonised
implementation across the EU as a whole, ensuring a level playing field among operators in the single
market. Certification obligations will be imposed in a phased manner. Once externally audited,
companies or the auditors must notify the public authority about the outcome of the external audit
(i.e. whether the site was successfully certified as compliant or not, following the external audit). In
the case of non-compliance, the public authorities in the Member States are responsible for imposing
corrective measures and, where relevant, penalties.
This option does not include reduction targets and it is assumed that over a period of time the
certification process will deliver results. Once the measure under Option 1 is in place, the reduction
targets could possibly be defined. The measure under Option 1 would enable measuring its possible
success rate.
In light of concerns raised during a targeted SME consultation, three sub-options were assessed in
the form of:
- lighter requirements for the micro companies (sub-Option 2a);
- lighter requirements for the micro and the small companies (sub-Option 2b); and
- lighter requirements for the micro, the small and the medium companies in the pellet supply
chain (sub-Option 2c)
The possibility of lighter requirements was only considered for micro-, small and medium companies
because large operators (mainly producers) did not raise concerns about the economic burden of
complying with mandatory requirements during stakeholder consultations and bilateral meetings.
Instead, they indicated that as long as these requirements would build on existing industry best
practices (e.g. Operation Clean Sweep) then they would be relatively straightforward and quick to
implement. In addition, the relative cost of these requirements is low for large entreprises.
35
This option addresses the problem drivers of market and regulatory failures, as well as support to
SMEs.
5.2.3 Option 3: Improved packaging for pellet logistics
Focus: Impose packaging provisions for pellet logistics.
Description: this option imposes the use of specific types of bags and containers for transport,
intermediate storage and handling during these operations. It aims to ensure that all bags and
containers used for pellet logistics (transport, intermediate storage) are environmentally sealed,
airtight and puncture-resistant to prevent damage and tears, which could lead to pellet losses. It can
be set up as an independent legislation or can be implemented as part of the legal proposal in Option
2.
This option addresses the problem drivers of market and regulatory failures.
5.2.4 Option 4: EU target to reduce pellet losses
Focus: Introduce EU target to reduce pellet losses
Description: this option is to establish an EU emission reduction target for pellet losses in line with
the Commission’s overall microplastic releases reduction target of 30% by 2030. Companies must
introduce the same preventive, mitigation and clean up measures as in Option 2. Each Member State
must introduce the necessary transposing legislation and measures to ensure delivery, including
compliance assurance, reporting by economic operators to track progress against the target, and
enforcement. Periodic reporting by national public authorities to the Commission would also be
necessary to ensure delivery and appropriate remedial action in case of shortfall in reducing pellet
losses.
This first requires the establishment of a mandatory standardised methodology to measure pellet
losses (Option 1). Without it, it would be challenging to establish a baseline and measure the
achievement/non-achievement of the established target.
This option addresses the problem driver of regulatory failure.
5.3 Options discarded at an early stage
Overall, 173 ideas were identified during desk research and in stakeholder workshops. The main
discarded ideas are presented below.
Voluntary commitments like the one under the industry-driven OCS and in particular its new
certification scheme were considered as suitable options to address the identified problem driver
‘Market failure (prices do not reflect negative externalities)’. It was discarded as the new scheme was
in the meantime launched by its promoters. Therefore, this impact assessment considers such
commitment as part of the baseline. In Annex 6, the actions of industry are detailed.
The option of developing voluntary verification of best practices using well-designed standards and
certification schemes is ongoing under the work of the Commission of the regional convention for
the protection of the Marine Environment of the North-East Atlantic (OSPAR) and in the framework
of the above mentioned industry efforts. Therefore, this impact assessment considers such
development as part of the baseline. Also, certification is an essential part of Option 2.
36
Information/awareness raising on the handling of pellets throughout the pellet supply chain, and the
development of a universal information leaflet and labelling for packaging of plastic pellets for their
transport, were not considered as suitable options as they are already partially covered by OCS, they
would not trigger sufficient change, and where appropriate, they would be better taken up by the
mandatory requirements in Option 2.
Training obligations (with regular updates) for all actors in the pellet supply chain are not sufficient
as stand-alone measure, but would be better taken up by the mandatory requirements in Option 2.
Indeed, training is an essential part of this option.
The possibility of using the Industrial Emissions Directive127
to address pellet losses at relevant
installations was discarded on the ground of effectiveness, efficiency and relevance. The IED is not
suited to address pellet losses as a form of pollution occurring along the entire supply chain. While
activities like the production of polymeric materials on an industrial scale fall under the scope of the
IED, other activities like the conversion, transport or storage of pellets, usually operated by small and
medium enterprises, are not covered. Moreover, the BAT Reference Document (BREF) for the
production of polymers was adopted in 2007 and does not address the specific issue of pellet losses.
Supporting SMEs, including via financial incentives, is integrated in Option 2 as a way to mitigate
the regulatory burden on SMEs.
The possibility of setting extended producer responsibility schemes and environmental damage
remediation funds, financed by industry, were discarded on the ground of technical feasibility and
relevance. EPR targets a product, while for pellets, we have different types of “producers”, those who
manufacture the pellets, those who transform them into a product etc. Also, EPR aims to tackle the
end-of-life, i.e. when the product becomes waste, while for pellets, it is a diffused pollution issue
along the entire supply chain.
An initiative on classifying pellets as a “harmful substance” in the International Maritime Law is
currently already ongoing in the International Maritime Organization with the support of the
European Union. At the same time, the Ship Source Pollution Directive128
is under revision, and one
of the options could be to extend the scope of this Directive to cover this provision. Therefore, while
addressing the maritime transport of pellets by means of more stringent packaging or stowing
provisions may help reduce pellet losses at sea, this impact assessment considers such initiatives as
part of the baseline. The same applies to developing a mandatory reporting system for containers lost
at sea in international waters.
5.4 The intervention logic
The diagram below illustrates the logical connection between the problem, its drivers and the specific
objectives and policy options, which are assessed in Section 6.
127
Directive 2010/75/EU of the European Parliament and of the Council of 24 November 2010 on industrial emissions
(integrated pollution prevention and control) (recast).
128
Directive 2005/35/EC of the European Parliament and of the Council of 7 September 2005 on ship-source pollution
and on the introduction of penalties, including criminal penalties, for pollution offences.
37
Figure 6: The intervention logic
6 WHAT ARE THE IMPACTS OF THE POLICY OPTIONS?
Each policy option is assessed as regards its expected environmental, economic and social
consequences, as well as the costs and administrative burden it is likely to cause. This is based on a
qualitative and, where possible, quantitative assessment. All calculations are made in relation to the
baseline for 2030.
This assessment places particular focus on the pellet loss reduction that is possible under each policy
option as a contribution to the Commission’s 30% reduction target on microplastic releases to the
environment (compared to releases in 2016).
Environmental consequences mainly refer to the specific objective of reducing ‘pellet losses to a
level consistent with the Commission’s 30% reduction target’. A degree of uncertainty remains
around the impact of the policy options on pellet losses as the baseline pellet loss data is based on
incomplete data, as highlighted and addressed by the use of ranges to present pellet losses.
Assumptions, including on the impact of policy options on pellet loss rates, are explained in Annex
4. Monetising benefits on the environment (e.g. benefits on ecosystems and biodiversity) is difficult
due to the lack of available data. That is why a qualitative analysis is added.
Economic consequences refer to both the direct and indirect economic costs and benefits that are
generated from taking measures to reduce pellet losses. Taking measures to reduce pellet losses will
have positive knock-on economic effects on the pellet industry such as reduced waste, modernised
equipment, improved reputation, a level playing field among operators and the economic gain of
fewer pellets lost. These effects also include the positive knock-on economic effects on activities that
are affected by pellet losses (i.e. commercial fishing, agriculture as well as recreation and tourism in
affected areas). Taking measures will, however, generate direct compliance costs for the sector (both
adjustment and administrative costs), especially for SMEs.
Social consequences mainly refer to whether the policy option increases or decreases the creation of
jobs.
38
The administrative cost / burden on public authorities depends on the degree to which public
authorities are involved in the design, implementation or enforcement of the policy option.
The benefit to cost assessments are relative to the other options to allow for more effective
comparison of the different options. These impacts are presented in detail in Annex 11, along with
the stakeholder groups affected. The following coding is used to present the likely impacts.
Table 4: Coding used to present likely impacts (relative scale)*
Score Description
+++ Very significant direct positive impact or benefit
++ Significant direct positive impact or benefit
+ Small direct positive impact or benefit
(+) Indirect positive impact or benefit
+/- Both direct positive and negative impacts, and balance depends on how implemented
0 No impact or only very indirect impacts
(-) Indirect negative impact or cost
- Small direct negative impact or cost
-- Significant direct negative impact or cost
--- Very significant direct negative impact or cost
High High benefits significantly outweigh costs of measure
Medium Medium benefits on balance outweigh costs of measure
Low Low benefits close to or even below costs of measure
Uncertain Potential high benefits, but significant questions as to whether the measure can deliver
outcome
(*): The benefit to cost comparison is done in a relative scale, not in absolute values. Indications of
“high/medium/low” reflect therefor the comparison with the other option. E.g., “high” means that the benefit
to cost ration of the option is higher than for the option that has “medium”.
6.1 Option 1: Mandatory standardised methodology to measure pellet losses
Table 5: Summary of impacts of Option 1
Consequences/Impacts Assessment and considerations Benefit
to cost
Environmental Economic Social Cost
(+) (+) 0 (+) A mandatory standardised methodology benefits
all the other options by replying to the information
failure. While it can imply some (development and
testing) costs for the sector (but these might be
taken up by the Commission), it will still result in
cost savings as only one method needs to be
developed and applied, also leading to lower
verification costs.
The benefit to cost ratio is considered to be high
because the multiple benefits outlined above
outweigh the costs of developing this methodology.
High
Under this option, there are no direct reductions of pellet losses, but a mandatory standardised
methodology to measure such losses. Such a methodology will enable relevant actors to tackle
pellet losses, thus reducing the impacts on the environment. One methodology for all will be used,
instead of several, different ones that otherwise might be developed. The common standard will
simplify the reporting on the quantities released improving also the information on the magnitude
and evolution of pellet losses throughout the pellet supply chain, and raising awareness among
39
relevant actors. Setting reporting obligation is a necessary step to measure any reduction measure's
success rate.
This option benefits all other options as the magnitude of pellet losses is a critical knowledge gap
which requires a standardised measurement methodology. In addition, it will contribute to their
effective implementation and monitoring their success rate.
No significant social impacts are expected.
This option entails both costs and cost savings. The cost of developing (and testing) the
methodology is one-off and depends on the time required to develop the methodology. The European
Standards Organisation (CEN) typically takes 3-4 years to complete the process. Either the industry
could bear this cost, or the Commission could provide support through a dedicated study. The latter
approach is more likely if the standard has to be taken up in legislation.
When developing the common standard, CEN could take into account the methodology that is being
developed under the OCS certification scheme.
This assessment has estimated the cost of developing the common standard to be between EUR 558
087 (12 months development) and EUR 1 674 263 (36 months development). The testing at one
facility costs about EUR 700-1500 per test, depending on the installation size. Assuming that about
1 000 installations test the standard during the development phase, the testing therefore costs between
EUR 700 000 and EUR 1 500 000. The total costs would thus be between EUR 1 258 000 and EUR
3 174 000 (rounded figures). As the common standard would be based on developments under the
OSC certifications scheme, it is estimated that the lower end of the cost estimation is more likely.
The implementation costs incurred to use the common standard, once this is developed and tested,
are already considered under the REACH restriction (as part of the reporting costs) and do not need
to be taken into account here as the scope of companies is basically the same as it is in the REACH
restriction and its requirement to report pellet losses (the REACH restriction encompasses all uses,
while the upcoming pellet proposal would be limited to uses above 5 tonnes). These costs would
consist of the costs for the companies to set up specific reporting systems and for the public authority
to set up verification and evaluation systems129
.
At the same time, imposing a standardised methodology to measure pellet losses has the potential to
save costs on different levels:
- The plastic industry is developing a methodology, however, it is not clear how much such a
method would be accepted by the whole value chain. Some parts of the value chain and
Member States might also develop a methodology on their own. Under Option 1, there is only
one cost for developing the methodology, and not several;
- More importantly, businesses have to apply only one methodology in the different parts of
the supply chain and in different countries; and
- The verification and evaluation of the reporting by the public authority is simplified.
129
For the Committee for Socio-economic Analysis (SEAC), established under REACH, the total costs of reporting
could be substantial as the number of companies affected is likely to be large. SEAC considers that there are different
options to reduce such costs, e.g. by excluding certain actors (small or micro-sized companies) from the requirement
or by setting a threshold for microplastics volumes used or released to be reported. However, SEAC did not draw a
firm conclusion on how these different options would compromise the value of information obtained and hence the
benefits of reporting in terms of facilitating better risk management.
40
While it is difficult to do an exact cost-benefit assessment, the cost savings would be higher than the
development costs of the standard. These cost savings are fully in line with the Communication
COM(2021) 219 final on joining forces to make better laws130
.
Stakeholder views: Stakeholders generally agree on this option. In the targeted SMEs consultation
conducted early 2023, a standardised methodology to measure pellet spills and losses was mentioned
by 51% of respondents as a support measure that could best help them to take action to reduce pellet
losses. The testing costs for one facility would be around EUR 700 per test, which means a
proportionally greater cost for small compared to large companies. However, these costs are already
covered under the REACH restriction.
Summary: This is the basis for setting up the framework to measure pellet losses and thus
fundamental for monitoring pellet losses and their evolution in the future. This option will therefore
be instrumental to achieving the objective of improving the availability of data on pellet losses. It
will facilitate and improve the quality of the reporting on pellet losses required by the REACH
restriction on intentionally added microplastics. Coherence with the REACH restriction will need to
be assured. It will also raise awareness among relevant actors as they can measure pellet spills and
losses and assess their evolution over time. While an exact cost-benefit assessment could not be made,
the cost savings are expected to be higher than the development costs of the standard.The measures
in this option are considered to be proportional to the objectives it aims to achieve.
130
COM(2021) 219 final of 29 April 2021 on joining forces ro make better laws.
41
6.2 Option 2: Mandatory requirements to prevent and reduce pellet losses in a new EU law
Table 6: Summary of impacts of Option 2 and suboptions
Impacts Assessment and considerations Benefit -
cost
Env Eco Soc Cost
2 +++ + + --- Mandatory requirements & certification have the highest reduction
in pellet losses, and highest direct compliance costs for the sector.
This option was awarded a medium benefit to cost ratio because
while there are costs associated with these requirements for both
authorities and industry, the benefits to the environment, human
health and affected communities still outweigh these costs.
However, relative to option 2b it scores a bit less good.
Medium
2a +++ + + -- The reduction of pellet losses is still very high, but costs are lower
than under 2 thanks to lighter requirements for micro-enterprises.
This sub-option has a medium benefit to cost ratio because the
benefits outweigh the associated costs, but a bit less good then 2b.
Medium
2b +++ + + - Reduction of pellet losses is still very high; costs are lower than
under 2a thanks to lighter requirements for micro- & small
enterprises. This sub-option has a high benefit to cost ratio because
the economic operators for whom associated costs would be the
most burdensome, are subject to lighter requirements, which
reduces costs. The benefits are still high and therefore significantly
outweigh the costs compared to the other options.
High
2c ++ + + - The reduction of pellet losses is lower than under the other sub-
options, and costs are only slightly lower than under Option 2b due
to lighter requirements for micro-, small, and medium enterprises.
This sub-option has a medium benefit to cost ratio because while
the costs to industry have been significantly lowered, the resulting
benefits have also lowered due to more companies being eligible
for the lighter requirements. The lower costs for medium
enterprises are less important than for micro- and small ones.
Medium
In this option, imposing mandatory requirements and certification for all pellet handling companies
is the EU’s responsibility, while the sector bears the costs of the measures to implement and of the
audits, and the public authorities in the Member States are responsible, in the case of non-compliance,
for imposing corrective measures and, where relevant, penalties.
As it is a mandatory approach covering the full supply chain with explicit requirements, a certification
obligation and checks and enforcement activities by public authorities in the case of non-compliance,
we estimate that the sector will have a high degree of compliance (95% of the total virgin pellet
volume handled) and will be effectively implementing such rules with a success rate ranging from
80 to 95% (meaning that pellet losses would reduce with these percentages).
The economic impacts are primarily related to the direct compliance costs for the sector of
implementing the measures. Lighter requirements are assessed for SMEs in sub-options. The
environmental impacts are primarily related to the environmental benefits associated with the
reductions in pellet losses. A derogation for companies making and handling pellets in quantities
42
lower than 5 tonnes also applies (as done in the existing French legislation131
- this limit was decided
as a consequence of a public consultation in France), which avoids requiring costly investments with
very limited environmental benefits in terms of pellet loss reduction.
Environmental impacts
As this option requires that all actors of the supply chain comply with mandatory requirements and
certification (with the only exception of companies making and handling pellets in quantities lower
than 5 tonnes), the main expected environmental impact from this option is a significant reduction
of pellet losses that are likely to be harmful to ecosystems and biodiversity and may affect human
health.
Under this option, the reduction of pellet losses is expected to be between 27 128 tonnes/year (low
emission scenario) and 148 879 tonnes/year (high emission scenario), representing respectively a
65% and 87% reduction overall, compared to the baseline. This also leads to a saving of 106 to 583
ktCO2e, representing 11 – 58 M€/year in savings132
.
When providing for lighter requirements for the micro-enterprises, the reduction of pellet losses
ranges from 26 730 tonnes/year to 147 227 tonnes/year (105 – 576 ktCO2e). With lighter
requirements for the micro- and small enterprises, the reduction of pellet losses ranges from 25 142
tonnes/year to 140 621 tonnes/year (98 – 551 ktCO2e). Similarly, with lighter requirements for micro-
, small and medium-enterprises, the reduction of pellet losses ranges from 21 569 tonnes/year to
125 757 tonnes/year (84 – 492 ktCO2e).
Economic impacts
This option will entail both economic benefits and costs. These are presented below with the
indication of the stakeholder group affected.
Direct compliance costs for the sector
There is limited direct information available regarding the costs to companies of taking measures to
adhere with best practice handling over the value chain. Discussions with stakeholders in the course
of this IA suggest that the costs of implementing Option 2 would be limited for some parts of the
plastics industry, as these actors (producers and some converters and logistic companies) are already
moving towards measures and a system of external auditing and certification based on OCS. At the
same time, costs of this option vary significantly according to the types of companies. For example,
micro and small companies (which constitute 89% of all converters in numbers, but only 20% in
terms of turnover) would be significantly affected by the costs incurred by the upgrade of their
facilities, the introduction of procedures including internal and external audit and the training of their
personnel. There is also a significant number of transport companies handling pellets.
Stakeholder views: the NGOs active in the field have strongly supported harmonised minimum
requirements for pellet handling to be established at the EU level, along with a comprehensive and
transparent certification scheme requiring a secure chain of custody. The umbrella association of
European manufacturers, PlasticsEurope, has agreed that the most effective approach to tackling
131
Décret no 2021-461 du 16 avril 2021 relatif à la prévention des pertes de granulés de plastiques industriels dans
l’environnement [Decree n. 2021-461 of 16 April 2021 related to the prevention of the leakage of industrial plastic
pellets into the environment], Journal official “Lois et Décrets” no. 0092 du 18 avril 2021 [JORF] [Official journal
“Laws and Decrees” no. 0092 of 18 April 2021], 18 April 2021, Fr.
132
1 tonne of CO2
estimated value is 100 €/t.
43
pellet losses is mandatory external auditing and certification building on OCS and applied to all actors
throughout the supply chain. Producers therefore consider a legislative proposal requiring
certification of an OCS-like pellet loss prevention management system would be very quickly
implementable throughout the whole supply chain because it would benefit from the existing industry
initiative and would reinforce it. The umbrella association of European converters, EuPC, has pointed
to limited resources as a barrier to implementing voluntary measures under the industry-driven OCS
programme. The umbrella association of European recyclers, PRE, favour an EU-wide legally
binding instrument to enable a level-playing field in the single market among all actors in the supply
chain and across all Member States.
A second consultation targeting all SMEs handling pellets was conducted from January to February
2023 in all EU languages (Annex 12). Based on the 330 replies received, it emerges that a majority
of respondents prefers a lighter version of requirements. Specifically, they reported that the
requirement on the training of staff should be made mandatory in the same way for all companies,
but the obligation of being externally audited and certified should not be imposed on SMEs. The
survey also indicates that the direct economic impacts of this option would be too high to be
sustainable for micro and small companies, as well as companies with capacities below 1000 t.
Among the various best handling practices, the mandatory use of specific equipment and of specific
packaging (i.e. airtight, puncture-resistant and environmentally sealed) is identified as the most
expensive measure. Generally, the cost per tonne of the measures to be implemented would become
insignificant for companies with capacities above 5000 t. Finally, financial support and standardised
methodology to measure pellet losses are identified as the support that would best help respondents.
Costs of Option 2 are presented in Annex 11. They were calculated using industry estimates, where
available, on one hand, for producers (including recyclers) and converters and, on the other hand, for
logistic operators (transporters and storage/warehouse operators). As the industry has already started
implementing some of the proposed measures through their voluntary commitments (i.e. OCS CS,
RecyClass and SQAS), some of these costs are already incurred under the baseline.
The costs were calculated for micro, small, medium and large plastic enterprises. The upfront
investment costs and costs per tonne of pellets handled are relatively more important for SMEs,
especially for micro-and small enterprises than for other enterprises. It was therefore estimated that
lighter requirements would be needed to alleviate a part of these costs to mitigate concerns from
SMEs (e.g. lack of staff/time, lack of information on risks and solutions and lack of financial
resources). This is also consistent with the replies and requests received throughout the stakeholder
consultations. In light of the above, three sub-options were assessed in the form of:
- lighter requirements for the micro companies (sub-Option 2a);
- lighter requirements for the micro and the small companies (sub-Option 2b); and
- lighter requirements for the micro, the small and the medium companies present in the pellet
supply chain (sub-Option 2c).
These lighter requirements include, for example, additional time before entry into force of the
requirements and for renewal of the certificate and no costly investments (in particular into sewage
treatment system). It is estimated that this lighter regime will help reduce the costs of compliance by
10% (e.g. due to less paperwork).
The costs of applying lighter requirements for micro, small and medium sized companies for typical
plant capacities are presented in Annex 11. With these reduced requirements, we assume that the
pellet losses will be 35% higher from converters and 20% higher from logistics providers than under
the main scenario. This assumption means that the remaining requirements are still the most
important ones to reduce pellet losses, but that there is already a significant increase in pellet loss.
44
Overall, the cost of implementing Option 2 would be 742 and that of sub-options 2a, 2b, and 2c
would be 615, 516 and 479 million EUR/year respectively.
In particular for the converters, the lighter requirements reduced the cost per tonne to about half of
the ones under Option 2. For medium enterprises, this difference is smaller. Option 2 represented
already less than 0,5% of their turnover. An important reasons for the relatively high cost of
converters compared to the producers is that it is assumed that producers would already subscribe to
the OCS CS, while only a limited number of converters would do so.
The cost-effectiveness of the options ranges from 2 672 EUR/tonne avoided per year to 26 342
EUR/tonne avoided per year, depending on the sub-option and the lower/higher estimation of losses.
What would the costs be for the public authorities?
The costs will depend on its implementation in Member States, which may vary significantly. The
focus is on administrative costs, including monitoring, delays, complaint-handling mechanism, and
access to justice. Further costs for competent authorities can be related to the setting up and
maintaining of the system, including enforcement of the regulation. However, it may be covered by
existing systems through other legislation. In addition, the public authorities in the Member States
could be required to hold a public register of certified companies to ensure full transparency and
traceability of the supply chain and compliance with the requirements. This registry could be set up
in pre-existing systems to lower the costs. There might also be minor reporting costs (188 000 € per
year) for the economic operators (to notify the outcome of the certification), as reporting already
exists under REACH (see option 1).
The processing and enforcement costs for the public authorities in the Member States would be EUR
313 000 for the first year and EUR 125 000 per year for the whole EU (see Annex 11). These cost
will vary across Member States as they would be higher for larger ones and lower for smaller ones.
What would the benefits be for the sector?
For businesses owning the pellets, this option could prevent the estimated economic loss of EUR 42
to 170 million associated with about 42 050 to 170 266 tonnes of pellets being lost per year (1000
EUR/t)133
.
For SMEs implementing similar requirements under the international initiative of the BSI PAS, the
following benefits were reported:
• modernised equipment thanks to grants they secured;
• less legacy pellet pollution, which had previously been extensive around the sites;
• reduced waste (and lower waste management costs);
• improved staff awareness and training;
• reduced fire risk because proper and regular site assessments revealed build-up of dust in
areas previously unchecked;
• involvement of suppliers/customers – all site visitors are required to read and accept rules
relating to proper pellet management; and
• improved reputation.
133
Prices of plastics are fluctuating and depend on the exact polymer type and the stage of processing.
45
What would the benefits be for the economy at large and society?
Under this option, reducing pellet losses may have positive knock-on economic impacts on sectors
such as commercial fishing, agriculture, tourism and recreation, in areas where these activities are
affected by the releases with significant harm to ecosystems and biodiversity. In particular, there
would be fewer pellets lost to the marine environment and, thus, fewer perturbations to all marine
organisms, including economically important organisms such as oyster and seabass134
. Considering
that the ecosystem services provided by the oceans are estimated to be worth over USD 24 trillion,
the regulation of microplastics to help the protection of marine ecosystems and organisms seem to
be of significant importance135
. Similarly, there would be fewer pellets lost in the installations’
wastewater and in the sludge resulting from their treatment. Consequently, there will be less pellets
lost to the soil after the application of sludge on agricultural land.
Benefits would also include avoided costs to society such as those related to clean up and remediation
activities by local communities that are affected by the releases, that are normally challenging to
these communities in terms of technological, human and financial resources.
Social impacts
This measure requires additional staff to prevent pellet losses and for training. With the same
assumptions made on the share of the volume between micro, small, medium and large factories,
implementing the measure would need from 3 772 to 4 103 FTE personnel.
Since this option may increase the cost of plastic raw materials, the general public may be impacted
by an increase in the cost of plastic goods. Since plastic is used everywhere, any increase in its cost
is felt in society. However, the cost increase is likely to be limited as the cost of the measure is small
compared to the turnover of the sector. For large companies, in particular, it is possible that the
manufacturer would absorb such a slight increase in its production costs and that consumers would
be unaffected.
Summary: The introduction of mandatory requirements and certification would result in significant
reductions of pellet losses and plug a clear regulatory gap. This option would therefore be critical to
achieving the overall objective of this initiative of preventing and reducing pellet losses, while
mitigating its impacts on SMEs through its sub-options. The more losses are avoided, the greater the
positive impacts are for the environment and for economic activities like commercial fishing,
agriculture, tourism and recreation. The costs incurred by the sector under Option 2 and its sub-
options (without micro/without micro and small /without micro, small and medium companies) may
increase the cost of plastic goods produced and/or converted in the EU.
This option has less risks as to the probability of reaching the objectives and massively reduces the
number of free riders that exist in the voluntary approach. The system is set up in a way to limit
public costs as it involves third party auditing and certification. The possibility of a public register of
certified companies at national level would further increase the transparency and traceability of the
supply chain, with limited processing costs for the public authorities in the Member States. The
measures in this Option are therefore considered proportional to its objective.
134
Zhu, X. et al. (2020) ‘Bioaccumulation of microplastics and its in vivo interactions with trace metals in edible oysters’,
Marine Pollution Bulletin, 154, 111079. doi: https://doi.org/10.1016/j.marpolbul.2020.111079 83 Barboza, L.G.A et
al. (2018) ‘Microplastics cause neurotoxicity, oxidative damage and energy-related changes and interact with the
bioaccumulation of mercury in the European seabass, Dicentrarchus labrax (Linnaeus, 1758)’, Aquatic Toxicology,
195, pp. 49-57. doi: https://doi.org/10.1016/j.aquatox.2017.12.008.
135
WWF Report 2015; Reviving the ocean economy
46
Although the net costs of sub-option 2c are only slightly lower than sub-option 2b, the reduction in
pellet losses is also lower so sub-option 2c’s effectiveness and efficiency are slightly lower than 2b’s.
In addition, the reductions in costs are much more significant for micro- and small companies (under
option 2b) than medium companies (option 2c). Indeed, the costs to comply with requirements
represent less than 0.5% of medium companies’ turnover. Therefore, option 2c alleviates costs which
are less significant for medium enterprises, while significantly reducing the reduction of pellets lost
to the environment. In contrast, option 2b significantly alleviates the burden of the costs for micro-
and small enterprises, while nevertheless achieving a relatively high reduction in pellet losses.
The comparison of different options 2 and its sub-options 2a-c needs to take into account what the
ranges consist of (lower and higher figures under each option). The ranges are determined by the
uncertainty around pellet loss. Therefor, when comparing these ranges, one should always keep in
mind to compare either a low pellet loss scenario, a high pellet loss scenario or any intermediate one.
Therefore, the lower end figure of the costs of option 2 is linked with a lower end figure of the costs
of the other options 2a, 2b or 2c as these are all linked with the scenario of lower pellets losses.
Higher costs within the range of a specific option should be compared with the higher costs within a
range of another option, as they are linked to higher pellet reductions.
Table 7: Summary of impacts in 2030 of Option 2 and sub-options 2a, 2b and 2c
Option 2 Option 2a: Lighter
requirements for
micro-enterprises
Option 2b:
Lighter
requirements for
micro-and small
enterprises
Option 2c:
Lighter
requirements for
micro-, small and
medium-
enterprises
Environmental
impacts (reduced
pellet losses)
(tonnes)
27 128 – 148 879 26 730 – 147 227 25 142 – 140 621 21 569 – 125 757
Environmental
impact (Savings of
GHG emission)
(tonnes of CO2
eq)
106 210 – 582 890 104 655 – 576 424 98 437 – 550 560 84 446 – 492 366
Reduction in
trucks (number, of
25 t microplastics)
1085 – 5595 1069 – 5889 1006 – 5625 863 – 5030
Economic impacts
Cost of the
measure
(MEUR/y)
742 615 516 479
Savings from the
pellet losses
(MEUR/y)
27 – 149 27 – 147 25 – 141 22 – 126
Net cost to
businesses
(MEUR/y)*
593 – 715 468 – 588 376 – 491 353 – 457
Cost-effectiveness
(EUR/tonne/y)
3 982 – 26 342 3 177 – 22 005 2 672 – 19 536 2 805 – 21 186
47
Option 2 Option 2a: Lighter
requirements for
micro-enterprises
Option 2b:
Lighter
requirements for
micro-and small
enterprises
Option 2c:
Lighter
requirements for
micro-, small and
medium-
enterprises
Savings from
GHG emission
(MEUR/y)
11 – 58 10 – 58 10 – 55 8 – 49
Other economic
impacts
Public Administrations: increased costs for data collection (i.e. public register) and
overall monitoring of the implementation, intervention in case of non-compliance
(i.e. enforcement of the sanctions)
Citizens: limited increase of the cost of plastics goods
Tourism and recreation: increased attractivity through the reduction of pellets in
coastal areas and other vulnerable areas
Fisheries: fewer pellets released in water and improved ecosystem services due to
fewer pellets absorbed by marine organisms and animals in areas affected
Agriculture: fewer pellets released on soils and improved ecosystem services due
to fewer pellets affecting soil properties in areas affected
Society: fewer costs related to clean up and remediation activities by local
communities in affected areas
Social impacts
(jobs in FTE)
4 103 4 004 3 858 3 772
*Net cost: cost – savings. In every option there are 2 scenarios of the projection of the pellet losses. Therefore,
higher pellet loss reduction refers to lower costs and vice versa.
6.3 Option 3: Improved packaging for logistics of pellets
Table 8: Summary of impacts of Option 3
Consequences/Impacts Assessment and considerations Benefit
to cost
Env Eco Soc Cost
+ - 0 -- Improved packaging reduces pellet losses throughout the supply
chain (not quantified), but generates more GHG emissions (subject
to the packaging type), while entailing potentially quite high
investment costs for the sector. This option’s benefit to cost ratio is
considered medium to low because while it could significantly
reduce pellet losses, its costs could be high for industry.
Medium
to Low
This option specifically targets the producers of plastic pellets and logistics operators to prevent and
reduce pellet losses from transport (in case of re-packaging), intermediate storage and handling
during these operations. It could also be included in the mandatory requirements under Option 2.
Current packaging materials used to transport pellets are:
• plastic bags (up to 25kg of pellets) stacked on pallets;
• octabins (cardboard containers containing between 0.5 and 1.3 tonnes of pellets);
• big bags, containing from 0.5 to 1 tonne of pellets;
• containers, containing up to 25 tonnes of pellets; and
• silo trucks, containing up to 35 tonnes of pellets.
48
These different packaging materials do not present the same pellet loss risks, with plastic bags
holding the most risks for pellet losses and silo trucks the least. However, the plastic bags also hold
several advantages over rigid HDPE barrels and intermediate bulk containers (IBC) because they
allow for more flexibility in the size of shipments and prevent dust contamination. They also allow
for more volume to be transported per unit of transport, thus reducing GHG emissions and transport
costs. Silo trucks have airtight suction mechanisms and the loading and unloading of these trucks
leave little room for pellet spills, but if they are spilled, then they are collected for disposal.
Plastic bags are the packaging material which would be targeted first because of their poor resistance
to tears during operations. OSPAR136
mentions that plastic bags and octabins could be replaced with
reusable rigid HDPE barrels or with IBC (Intermediate bulk containers). Replacing existing
machinery and processes might also generate extra costs. Another approach could be to propose
thicker plastics bags which are more resistant to tears. The IMO Correspondence Group on Marine
Plastic Litter from Ships considered packaging provisions for plastic pellets carried at sea as primary
measures to take forward for further assessment.
The proposal for a packaging and packaging waste regulation137
includes a provision that requires
transport packaging to be reusable. The impact of this proposal was not examined as the focus of this
option is on the increased resistance of packaging.
Environmental impacts
This option could potentially significantly reduce pellet losses during logistics operations
(transport, intermediate storage and handling during these operations) thus bringing potentially
significant environmental benefits. However, there is not data available to quantify the losses due to
torn plastic bags or octabins. Also, replacing plastic bags with alternatives would increase GHG
emissions. Indeed, rigid HDPE barrels and IBC do not offer the same flexibility as plastic bags. When
not entirely filled up with material, they increase storage volume for a given quantity of material,
increasing the GHG emissions incurred by the storage. If thicker bags would be chosen, there would
only be a minor increase of GHG emissions (due to more use of plastics).
Economic impacts
What would the costs of this option be for the sector?
This option could potentially entail quite high costs, especially for producers, who may have to
change their production lines since plastic bags are automatically filled on-site through their own
manufacturing chain, and for SMEs. Similarly, logistics operators would have to adapt their transport
and storage approaches depending on the type of packaging. However, due to important data gaps, it
was not possible to quantify the direct compliance costs (mainly investment costs) for the sector
deriving from this option.
The cost per tonne of pellet losses avoided is expected to be higher than with Option 2 because it
would force the industry to overhaul their production lines to effectively remove the bagging lines
and replace for instance plastic bags with reusable and resistant rigid HDPE barrels or IBC. Imposing
thicker more resistant plastic bags could lower such costs. However, as all these solutions mainly
represent an investment cost, smaller enterprises would be affected more than bigger ones respective
to their size.
136
OSPAR Commission, Background document on pre-production plastic pellets, 2018,
https://www.ospar.org/documents?v=39764. Accessed 12 Apr 2022.
137
COM(2022) 677 final. Proposal Packaging and Packaging Waste (europa.eu)
49
Social impacts
There are no social impacts foreseen for this measure. However, moving towards more automated
solutions like silo trucks could reduce the number of jobs (more workforce is needed for manual
loading and unloading of pellet containers/bags).
Stakeholder views: NGOs often emphasise the importance of improving packaging to reduce pellet
losses, while industry is less convinced, especially in light of the expected high costs of improved
packaging. Plastics Europe, representing producers, considers that addressing packaging does not
address the root cause of the problem. From the second consultation conducted early 2023 targeting
all SMEs handling pellets, it emerged that while two-thirds of respondents consider the use of specific
packaging effective to reduce pellet losses, only 54% do it always or often (and a third never does it
or has no opinion). Views on whether this should become a mandatory requirement are mixed: 33%
in favour, 20% in favour if lighter requirements for SMEs, and 27% against, while the use of specific
packaging is estimated as the most costly measure both in terms of person/days and euros/tonne/year.
Financial support was identified as the support that would best help respondents along with a
standardised methodology to measure pellet losses.
Summary: The use of more resistant packaging materials and spill-proof packaging options would
reduce pellet losses throughout the supply chain. However, the impacts differ according to the type
of improved packaging chosen. While switching out plastic bags for barrels would likely present a
greater reduction in losses, it would also increase the GHG emissions and costs of transport, in
addition to require greater investment costs (as infrastructure will need to be replaced). Opting for
thicker more resistant plastic bags would avoid these investment costs and allow for greater volumes
to be transported per unit of transport. This option could be incorporated into a more comprehensive
set of requirements, such as those laid out in Option 2. Therefore, while this option would help
contribute to a reduction in pellet losses at certain stages of the value chain (eg. transport), it is
considered to be less effective than the more comprehensive Option 2. Due to the high associated
investment costs and the impact on pellet losses being limited to transport, the measures in this Option
were not considered proportional to the overall objectives of this initiative.
6.4 Option 4: EU target to reduce pellet losses
Table 9: Summary of impacts of Option 4
Consequences/Impacts Assessment and considerations Bene
fit to
cost
Env Eco Soc Cost
++ + + --- An EU emission target has potentially a high reduction of pellet losses,
as operators have to adopt preventive, mitigation and clean-up
measures, but the enforcement might be challenging. Its costs are
comparable / slightly higher than those of Option 2 and higher than
those under sub-options 2a-c. As it depends on Option 1, it can only be
implemented afterwards, leading to a delay in implementation time.
This option is considered to have a low benefit to cost ratio because
while its costs are similar to option 2, its benefits would be delayed and
will likely not be as high due to the challenges linked to its
enforcement.
Low
An EU emission reduction target for pellet losses is set in this option. This option can only be
achieved in the medium to long term as it first requires the establishment of a mandatory standardised
methodology to measure pellet losses (Option 1) (including its testing in various sites of different
50
sizes over a significant period of minimum 12 months). Further to that, knowledge should be gathered
on quantities released, through the REACH reporting requirement, before implementing this option.
Once developed, the standard would need to be applied over 12 to 36 months to generate a statistically
strong database including prevention, mitigation and clean-up measures. The target could be defined
as the result of this observation phase.
The target could be set either for the whole plastics industry, or at sector level. In the latter case, there
could be differentiated targets depending on the place in the supply chain. These approaches are
presented in Annex 11.
This measure could be implemented by including the emission threshold in legislation. It is a medium
to long-term measure, as time is necessary for the data to become available and for identifying the
relevant threshold. Once the threshold is defined, it could be possible to include it in legislation.
Environmental impacts
The reductions of pellet losses are expected to be in the same order of magnitude as in Option 2.
However, implementation and enforcement by Member States seem more challenging in this
option than in Option 2, which might lead to less reduction of pellet losses.
Economic impacts
The costs of this option are expected to be comparable to those in Option 2 as similar prevention,
mitigation and clean-up measures would be implemented. The cost of setting the target would depend
on the mandatory standardised methodology developed under Option 1.
However, other considerations seem equally important, possibly increasing costs of this option
compared to those of Option 2. First, accurate monitoring following the standardised methodology
developed under Option 1 would be needed to ensure that the target is respected (not included in
Option 2 which focuses on mandatory requirements and certification). Further, each Member State
must introduce the necessary transposing legislation and measures to ensure delivery, including
compliance assurance, reporting by economic operators to track progress against the target and
enforcement. Periodic reporting by national public authorities to the Commission would also be
necessary to ensure delivery and appropriate remedial action in case of shortfall in reducing pellet
losses. Similarly to Option 2, lighter requirements would be needed for SMEs, especially for micro-
and small firms, as achieving the same reduction objective would be more costly for smaller than
larger firms.
Social impacts
The main social impact is additional job creation mainly for the industry (for reducing pellet losses
and reporting) and some for competent authorities (for enforcement) – these are relatively similar to
Option 2.
Stakeholder views: This option was not discussed by stakeholders in detail. It was however
mentioned that setting up a performance monitoring system would be costly.
Summary: Defining an EU emission reduction target for pellet losses, once a mandatory standardised
methodology has been developed, tested and applied, can significantly reduce pellet losses as it
requires preventive, mitigation and clean-up measures to be taken. Both implementation and
enforcement are the tasks of the Member States, which are required to introduce transposing
legislation and measures to ensure delivery. However, this option only looks at the objective, and not
at the means to achieve it. It requires setting up a new system, instead of fully benefiting from the
existing good practices in industry, such as under OCS. Implementing a reduction target will also
take considerably more time. For these reasons, this Option is considered to be as efficient as Option
51
2 but less effective. It leaves it up to Member States to design their own regimes so this Option is
nevertheless considered proportional to the objectives of the initiative.
7 HOW DO THE OPTIONS COMPARE?
The qualitative analysis and comparison of the different options is done in a relative scale as there is
few evidence on absolute values. Also, using ranges for the estimation of the costs in options is linked
to the respective pellet loss. Option 1 has the potential to benefit all options by improving information
on and accuracy of pellet losses, thus ensuring the identified information failure is tackled. It also
presents synergies with the REACH reporting requirement on estimates of quantities released. It is
therefore considered that all options should build upon option 1 to ensure all identified problems are
addressed in the preferred option. Option 2 significantly contributes to the Commission’s 2030
overall microplastic releases reduction target, as proposed in the Zero Pollution Action Plan,
increasing policy coherence, and its sub-options 2a-c respond to the need to limit EU action to what
is necessary and proportional by building on industry commitments and by providing lighter
requirements for smaller businesses. While there was not enough data to calculate the exact costs of
Option 3, this option would entail quite high investment costs for the sector, and it was estimated that
the cost effectiveness of this option would be lower than for Option 2. Option 4 requires a
performance monitoring system first, which would take time, its implementation seems more
challenging and its costs would be slightly higher than under Option 2 (because of Member State
involvement) and its sub-options 2a-c. This option is not favoured in the short term.
Although the exact impact of each option cannot be assessed in detailed way, the relative scale to
compare different options will show which option would be relatively the best option and therefor
the preferred option. The estimation of costs is linked to the pellet volume that would be lost (in case
of higher costs there would be lower pellet losses and in case of lower costs there would be higher
pellet losses). The net costs per tonne avoided microplastic emission of the preferred policy option
are 3-4 times lower than costs under the REACH restriction138
on microplastics intentionally added
to products. The net costs of the options can also be compared to those calculated in the Impact
Assessment for single-use plastics (SUP), for the relevant Directive139
(see section 8.2.1).
There are some data gaps and uncertainties in the comparison of different options. The principal
uncertainty comes from the pellet loss rates used for production, recycling, processing and logistics
phases. There are uncertainties regarding the potential success of existing and upcoming measures
on the reduction of pellet loss. There are data gaps on the structure of the sector (except for converters
and producers), as well as on the exact costs and benefits that should be attributed under the different
options, leading to some uncertainties. Therefore, assumptions are used (more detail can be found in
Annex 4). Table 10 gives an overview of how the assessed policy options compare.
138
Commission Regulation (EU) …/… amending Annex XVII to Regulation (EC) No 1907/2006 concerning the
Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) as regards synthetic polymer
microparticles.
139
SWD(2018) 254 final (EUR-Lex - 52018SC0254 - EN - EUR-Lex (europa.eu))
52
Table 10: Summary of impacts of all options (and sub-options)
Impacts Assessment and considerations Benefit -
cost140
Option Env Eco Soc Cost
1 (+) (+) 0 (+) A mandatory standardised methodology benefits all
other options as it targets the information failure. While
it can imply costs (development and testing) for the
sector (or the Commission can take this up), it will
result in cost savings as only one method needs to be
developed and applied, also leading to lower
verification costs.
High
2 +++ + + --- Mandatory requirements and certification have the
highest reduction in pellet losses, with the highest
direct compliance costs for the sector.
Medium
2a +++ + + -- The reduction of pellet losses is still very high, but costs
are lower than under Option 2 thanks to lighter
requirements for micro-enterprises.
Medium
2b +++ + + - The reduction of pellet losses is still very high, and
costs are lower than under Option 2a thanks to lighter
requirements for micro- and small enterprises. This has
the highest cost-effectiveness of the (sub)options 2, 2a-
c.
High
2c ++ + + - The reduction of pellet losses is lower than under the
other sub-options, and costs are only slightly lower than
under Option 2b due to lighter requirements for micro-
, small, and medium enterprises.
Medium
3 + - 0 -- Improved packaging reduces pellet losses throughout
the supply chain (not quantified) but generates more
GHG emissions (subject to the packaging type), while
entailing potentially quite high investment costs for the
sector.
Medium
- Low
4 ++ + + --- An EU emission target has potentially a high reduction
of pellet losses, as operators have to adopt preventive,
mitigation and clean-up measures, but the
implementation and enforcement might be challenging.
Its costs are comparable / slightly higher than those of
Option 2 and higher than those under suboptions 2a-c.
As it depends on Option 1, it can only be implemented
afterwards, leading to a delay in implementation time.
Low
Table 11 provides an overview of the relative effectiveness, efficiency, coherence and proportionality
of the options assessed in this initiative.
A simple relative scoring system has been used to assess each option along the dimensions of
effectiveness, efficiency, coherence and proportionality ranging from “+” to “++++” with “+” being
the lowest score and “++++” the highest. Brackets “(+)” indicate a half-point. Effectiveness considers
how successful each option would be in achieving or progressing towards the objectives of this
initiative. Efficiency considers the resources used by each option to achieve the desired changed.
140
The benefit to cost comparison is done in a relative scale, not in absolute values. Indications of “high/medium/low”
reflect therefor the comparison with the other option.
53
Coherence considers how each option fits with existing or forthcoming EU legislation.
Proportionality considers whether the means required by each option are suitable and necessary to
achieve the desired end. These assessments are based on each option’s relative costs, economic,
environmental and social impacts, laid out in Section 6.
Table 11: Comparison of options according to effectiveness, efficiency, coherence and proportionality
Option Effectiveness Efficiency Coherence Proportionality
1 ++ ++++ +++ ++++
2 +++ ++ ++++ ++
2a +++ +++ ++++ ++
2b +++ ++++ ++++ +++
2c ++(+) +++(+) ++++ +++
3 ++ + ++++ ++
4 ++ +++ ++++ +++
Explanation of the scores (relative scale, based on impacts described in Table 7 and Table 10):
• Effectiveness: No option got score “++++” as each option would need other option(s) to be
most effective. Options 2 and sub-Options 2a and 2b scored “+++” as being most effective
options to achieve the objectives outlined in section 4 (better information and reduce pellet
loss). Sub-Option 2c has slightly lower effectiveness with less pellet loss reduced than
previous options, scored “++(+). Options 1, 3 and 4 have scored “++” as having lower
effectiveness than Options 2 and sub-Options 2a-2c with less clear evidence on achieving the
objectives.
• Efficiency: Options 1 and sub-Option 2b scored “++++” with Option 1 requiring low costs
and sub-Option 2b being the most cost-efficient. Sub-Options 2c, 2a and Option 2 have a
decreasing degree of pellet loss versus costs. Option 4 scored “+++” having high costs, but
also high impacts. Option 3, with high costs and limited reduction in pellet losses, scored “+”.
• Coherence: All options, besides Option 1, got the highest score as being coherent with
existing or forthcoming EU legislation. Option 1 got lower score “+++” due its linkages to
REACH legislation where coherence is slightly less (but it can be managed).
• Proportionality: Option 1 got highest score “++++” as being the basis of achieving the
objectives. Sub-Options 2b, 2c and Option 4 got scored “+++” as being proportional regarding
the costs and impacts they would achieve, but lower than Option 1. Options 2 and sub-Option
2a got scored “++” considering the costs and impacts they would entail. Option 3 got scored
“++” due to the high associated investment costs and the impact on pellet loss reduction being
limited to transport.
54
8 PREFERRED OPTION
8.1 Elements of the preferred option
Following the analysis of the different policy options, a preferred option has been constructed with a
view to addressing the problem identified in section 2 and achieving the specific objectives outlined
in section 4, in particular contributing to the Commission’s 2030 overall reduction target.
The preferred policy option is a combination of Option 1 (Mandatory standardised methodology to
measure pellet losses) and sub-Option 2b (Mandatory requirements in a new EU law with lighter
requirements for micro and small companies). The identified problem is about the mishandling of
pellets by businesses and consequential impacts, so public intervention is warranted.
Option 1 is needed to address the specific objective “To improve information on the magnitude of
pellet losses throughout the pellet supply chain, in particular the accuracy of loss estimates”. This
will be done through the REACH reporting requirement, which would be applied to all companies.
In that context, it could also be decided to exclude companies handling less than 5 tonnes per year.
Sub-Option 2b is needed to address the specific objective “To reduce and prevent pellet losses in an
economically proportionate manner to a level consistent with the Commission’s overall microplastic
releases reduction target of 30% by 2030” and the specific objective “To ensure the appropriate
mitigation of impacts on SMEs involved in the pellet supply chain”. This assessment shows that sub-
Option 2b has the highest benefit-to-cost ratio. It also aligns with the results of the targeted SME
survey where micro- and small companies expressed the main concerns about the burden of
complying with mandatory requirements. It will have a strongly positive environmental impact in
terms of reduced pellet losses compared to the baseline, reducing microplastic pollution, preserving
ecosystems and biodiversity and decreasing potential health impacts. Indeed, it could reduce pellet
releases into the environment by 60% to 83% compared to the baseline. The reduction potential is
expressed using a range due to a lack of reliable and comparable data creating uncertainty around the
baseline figure for pellet losses. However, the comparison of the different options is relatively more
certain as it shows how options rank as a relative scale is used to compare different options (see Table
10). This sub-option should represent on average a 7%141
reduction of the total amount of
microplastic releases. It is estimated that this initiative will contribute to around 1/4th
of the
Commission’s 30% reduction target for microplastics.
Sub-Option 2b will have positive knock-on economic impacts on sectors such as commercial fishing,
wastewater management, agriculture, recreation and tourism. It will also increase transparency and
significantly reduce the number of free riders. Costs for business (65 000 companies are expected to
be impacted of which 7 700 are medium or large companies) are expected to be higher in the
beginning as some initial investments are needed to be done. There will also be a learning curve
which will reduce process costs later on. However, costs are mitigated for micro and small
companies, and kept within acceptable limits for the other companies, ensuring a level playing field
in the single market (reinforcing the position of companies applying reduction measures vis-à-vis
companies not applying such measures). Those companies could also benefit from phased
implementation, financial and non-financial support (see examples in Annex 13). In light of the
impacts of microplastics (including pellets) on the environment and possibly health, it was judged
that the benefits of significantly reducing microplastic releases (by 1/4th
) would outweigh the
additional cost for industry. In addition, the existing industry scheme OCS has been mainly taken up
by larger companies who produce pellets, meaning that most of the pellets value chain does not abide
141
Based on 2018 data.
55
by these best practices. It is also difficult to assess the successful implementation of OCS and
therefore whether it is significantly reducing pellet losses. Option 2 addresses these issues by ensuring
all actors in the supply chain are subject to these requirements (thus preventing free riders and
levelling the playing field), and enforcing implementation of the requirements (thus reducing pellet
losses to the environment).
There is a balance to be sought between the magnitude of cost effects, in particular on SMEs, and
reducing pellet losses. It is observed that the preferred policy option reaches the appropriate balance,
but should the college want to go further, additional lighter requirements (not foreseen in sub-Option
2b) are described, mainly for micro- and small companies. These additional lighter requirements
would help reduce further administrative costs for micro-, small and medium companies, along with
carriers transporting pellets, but are assumed to increase pellet losses. Box 4 captures all requirements
for all operators, including additional lighter requirements conceived to mitigate further burden on
SMEs. As carriers do not have permanent facilities, they also warrant a differentiated approach.
Box 4: Overview of all requirements for all operators, including additional lighter requirements
conceived for SMEs (the latter not yet foreseen in sub-Option 2b)
A standard to measure pellet losses will be requested to help tackle the market and regulatory failure and
facilitate companies’ reporting on pellet losses, as required by the REACH restriction.
Large companies (Operators with 250 or more employees) with a capacity of over 1000t/year will be subject
to the following regime:
(1) Set up, implement and keep up-to-date a risk assessment;
(2) Train their staff;
(3) Monitor and keep records of relevant implementation actions and of estimates of losses;
(4) Internal assessment to monitor compliance with the pellet handling requirements, plus some other
additional requirements (i.e. formal management meetings reviewing compliance and awareness
and training programme);
(5) External audit by certifiers, based on data from internal assessment, to monitor compliance; and
(6) Certification, using the results of the external audit, to certify compliance and be listed in a public
register set up by public authorities in Member States.
Medium companies (operators with 50 to 249 employees) with a capacity of over 1000t/year will be subject
to the following regime:
(1) Set up, implement and regularly review a risk assessment;
(2) Train their staff;
(3) Monitor and keep records of relevant implementation actions and of estimates of losses;
(4) Internal assessment to monitor compliance with the pellet handling requirements, plus some other
additional requirements (i.e. formal management meetings reviewing compliance and awareness
and training programme);
(5) External audit by certifiers, based on data from internal assessment, to monitor compliance; and
(6) Certification, using the results of the external audit, to certify compliance and be listed in a public
register set up by Member States, with a longer transitional period before first certification (36
months instead of 24) and longer validity of the certificate (four years instead of three).
Micro- and small companies (operators with fewer than 50 employees) and companies with a capacity of
less than 1000t/year will be subject to the following regime:
(1) Set up, implement and keep up-to-date a risk assessment; the risk assessment is sent to public
authorities in Member States alongside the self-declaration (below) and made available to them on
demand at all times;
(2) Train their staff;
(3) Monitor and keep records of relevant implementation actions and of estimates of losses;
56
(4) No obligation of independent, third-party certification but self-declaration of compliance, as well
as a longer validity of their assessment (five years);
(5) No obligation to carry out internal assessments;
(6) No obligation to review compliance assessments at formal management meetings; and
(7) No obligation to establish an awareness and training programme and schedule.
Carriers providing transport of pellets will be subject to the following regime:
(1) Implement actions to prevent, contain and clean up losses;
(2) Train their staff;
(3) Monitor and keep records of relevant implementation actions and of estimates of losses;
(4) No obligation to carry out internal assessments;
(5) No obligation to obtain certification, or third-party environmental audit;
(6) No obligation to acquire certain equipment;
(7) No obligation to review compliance assessments at formal management meetings; and
(8) No obligation to establish an awareness and training programme and schedule;
Stakeholder feedback: In the OPC responses (Annex 2), stakeholders agree that there is improper
handling of pellets. There is also awareness that the measures undertaken so far are voluntary, at the
industry level, which needs more control to ensure compliance. The NGOs active in the field as well
as a group of Member States have strongly supported a regulatory approach at the EU level as the
only way to tackle pellet losses effectively. Converters have pointed to high costs and limited
resources as a barrier to implementing mandatory requirements, especially for SMEs. Producers have
considered a legislative proposal requiring certification of an OCS-like pellet loss prevention
management system as quickly implementable throughout the whole supply chain because it would
benefit from the existing industry initiative and would reinforce it.
This assessment showed that the preferred policy option does not go beyond what is necessary to
achieve the objectives of the initiative. It aligns with what the industry had indicated would be
appropriate to effectively reduce pellet losses, and includes lighter requirements for micro and small
companies, who had indicated the necessity of this.
Table 12: Preferred policy option gives an overview of the preferred policy option, based on the
comparison of options and the analysis of synergies and complementarities across options.
Table 12: Preferred policy option
Preferred option Benefit to cost142
Mandatory standardised methodology (Option 1) High
Mandatory requirements (sub-Option 2.b lighter
requirements for micro- and small companies)
High
142
The benefit to cost comparison is done in a relative scale, not in absolute values. Indications of “high/medium/low”
reflect therefor the comparison with the other option.
57
Table 13 summarises the policy options that are not retained to their full extent (these may be still
addressed partially, also due to positive spill-over effects from the preferred policy option).
58
Table 13: Discarded policy options
Options discarded Benefit to cost
Mandatory requirements (Option 2) Medium
Mandatory requirements (sub-Option 2.a lighter
requirements for micro-companies)
Medium
Mandatory requirements (sub-Option 2.c lighter
requirements for micro-, small and medium
companies)
Medium
Improved packaging for pellets logistics (Option 3) Medium - Low
EU target to reduce pellet losses (Option 4) Low
8.2 Impacts of the preferred policy option
8.2.1 Costs and benefits
The following table sets out the different types of costs and benefits of the preferred option – more
information is available on this in Annex 3.
Table 14: Overview of the preferred policy option’s benefits and costs
Benefits
Direct The preferred option will reduce pellet losses to the environment by 2030 with 25 142 to 140 621
tonnes (saving 98 – 551ktCO2e). This will benefit the environment and society thanks to higher
environmental quality. There will be positive knock-on economic benefits including job creation.
The measurement standard will help improve understanding around pellet loss quantities,
pathways and impacts by increasing the quality and availability of data on pellet losses. This will
allow industry to adapt their operations to reduce pellet losses, and enable public authorities to
monitor more effectively reduction measures.
The measurement standard will also make it easier for industry to measure their pellet losses and
for authorities to collect and verify data related to pellet losses, leading to cost savings.
The preferred option will help the level playing field in the single market across the supply chain
in the EU and improve the global reputation of the EU industry around environmental protection.
Indirect It will decrease possible risks to human health. It is a precautionary measure.
It will increase employee safety by reducing injury risks, due to fewer pellet spills to the work
floor.
It will result in healthier soil and water due to less pellets directly lost or indirectly through the use
of sewage sludge, improving ecosystem services and benefiting agriculture and fisheries.
It will reduce the quantities of pellets in affected areas, thus benefiting tourism and recreation.
It will prevent local populations from having to finance clean-up operations following losses.
59
Costs
Citizens/consumers Businesses Administrations
One-off Recurrent One-off Recurrent One-off Recurrent
None Possible
minor
increase
in the
price of
plastic
products.
Developing a
measurement
standard will
entail adjustment
costs of EUR 1.3
to 3.2 million, but
compensated by
recurrent savings
in reporting.
Applying the new requirements will
cost an additional EUR 376 – 491
million (including administrative
costs). Businesses could absorb
these or pass them on to consumers.
Costs if the
EU directly
supports the
development
of the
measurement
standard.
There will be
minor costs
for Member
States
associated
with the
processing of
the
certification
and
enforcement
of the
regulation
EUR 125 000
per year for
the whole
EU).
Operators need to
adapt their
administrative
procedures to the
new
requirements,
entailing one off
costs (EUR 0.1
million)143
.
Businesses will face administrative
costs for internal assessments,
external auditing and certification
of about EUR 43.9 million):
- internal assessment – EUR 30.8
million
- external audit and/or certificate –
EUR 12.9 million
- filling forms and tables – EUR 0.2
million (for notifying public
authorities of the certification).
Costs to set up
at national
level a public
register of
certified
companies
(EUR 36
700144
per year
for the whole
EU).
There is a balance to be sought between the magnitude of cost effects, in particular on SMEs, and
reducing pellet losses. It is observed that the preferred policy option reaches the appropriate balance,
but should the college want to got further, additional lighter requirements (not foreseen in sub-option
2b) are assessed. These additional lighter requirements would help reduce further administrative costs
for micro-, small and medium companies, along with carriers transporting pellets, but are assumed
to increase pellet losses. The overall measures and procedures are described in Box 4. Possible further
reductions in administrative costs are quantified in Box 5 and they are different from other figures in
the Impact Assessment.
Box 5: Possible further reductions in administrative costs due to additional lighter requirements
conceived for SMEs (not yet foreseen in sub-Option 2b)
Possible additional lighter requirements for SMEs and transport providers would further reduce costs for
internal assessments, external audit and/or certification and notification by EUR 24.6 million (from EUR
44 million down to EUR 19.4 million) compared to sub-option 2b. These include:
• For micro- and small companies and for transport providers: a EUR 12.7 million additional
reduction in costs due to carry out risk assessments only instead of the obligation to carry out risk
assessments and internal assessments (foreseen in sub-option 2b145
) and 9.2 million additional reduction
in costs due to no obligation to obtain external audit and/or certification (foreseen in sub-option 2b);
143
Total initial costs are EUR 0.5 million for businesses, which have been annualised over a 5 year period using a
discount rate of 3% (0.5 hour for medium and large businesses and 0.25 hour for small and micro businesses and
using EU average wages (29 €/hour)). It is estimated that the internal assessment is already covering most of the
related cost.
144
Total initial costs are EUR 313 000 million for public authorities, which have been annualised over a 10 year period
using a discount rate of 3% (50 person days in average for each Member State using EU average wages (29 €/hour)).
145
Although micro and small companies and the transport providers do not need to carry out internal assessment, it is
still estimated that 50% of the related cost needed to carry out risk assessments and compile the self-declaration.
60
• For medium companies: EUR 1.9 million additional reduction due to a reduced frequency of
certification (every 4 years instead of every year as foreseen in sub-option 2b);
• For large companies: EUR 0.8 million additional reduction due to a reduced frequency of
certification (every 3 years instead of every year as foreseen in sub-option 2b).
In addition to the reduction of EUR 24.6 million described above, it can be assumed that these measures
would also lead to an additional 10% reduction in personnel costs (related to pellet reduction measures) for
micro- and small enterprises and for all transport providers (in addition to the 10% reduction already
foreseen in sub-option 2b). This would translate to an additional cost reduction of EUR 16.9 million.
The sum of the possible additional reduction of costs of EUR 41.5 million would be around 8-11% of the
total net cost as calculated for sub-option 2b. For micro and small enterprises, the additional reduction is
equivalent to almost 15% of the net cost.
It is difficult to estimate the consequence of these additional lighter requirements on the reduction of pellet
losses; there is no data available. It is probable that additional lighter requirements lead to an increase in
pellet losses.
If assumed that pellet losses would increase with 10%, then these additional lighter requirements would
lower the reduction in pellet losses by about 2 500 to 14 000 t/year compared to sub-option 2b.
The net costs of the preferred policy option can be compared to those calculated for the REACH
restriction on microplastics intentionally added to products146
. The REACH restriction would result
in a cumulative emission reduction of approximately 500 000 tonnes of microplastics (central
scenario) over the 20-year period following its entry into force (including an 8-year transitional
period for fragrance encapsulates); the corresponding total restriction costs would be EUR 9.3 billion
(between EUR 2.1 billion and EUR 20.6 billion)147
. While the costs calculated for the preferred
option 2b would be similar the ones in REACH, the preferred option 2b would reduce significantly
more microplastics (83 000 tonnes per year) than under the REACH restriction (an average of 25 000
tonnes per year). Therefor the preferred policy option 2b is about 3 to 4 times more efficient than the
REACH restriction.
The net costs of the preferred policy option can also be compared to the Impact Assessment for
single-use plastics (SUP), for the relevant Directive148
. It was estimated that the SUPD would save
around 9 000 tonnes of SUP, for a loss of business turnover of around 3.8 billion EUR and additional
costs of 2.8 billion on information, compliance and waste management. While the methodologies
used in both IA are clearly different, the cost efficiency ratio on pellets is clearly higher than for the
SUPD, as this analysis estimates a minimum reduction in pellet losses to the environment of 25 000
tonnes for net costs of 491 million EUR per year.
The proposal will also make a significant contribution to the EU reduction target for microplastic
releases, as outlined in Box 6.
146
Commission Regulation (EU) …/… amending Annex XVII to Regulation (EC) No 1907/2006 concerning the
Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) as regards synthetic polymer
microparticles.
147
Compiled opinion of the Committee for Risk Assessment (RAC) and of the Committee for Socio-economic Analysis
(SEAC)
148
SWD(2018) 254 final (Circabc (europa.eu))
61
Box 6: Contribution of the preferred option to Zero Pollution Action Plan target
This Impact Assessment concludes that the preferred option could contribute to achieving ¼ of the
Zero Pollution Action Plan target for a 30% reduction in releases by 2030. This is a relatively high
contribution compared to its contribution to microplastic releases (7-10%) and suggests that this
course of action should be pursued.
8.2.2 SMEs
A consultation targeting specifically SMEs handling pellets was conducted from January to February
2023 in all EU languages (Annex 12). For a majority of the 330 replies received, only a lighter version
of requirements could be imposed. Specifically, they reported that the requirement on the training of
staff should be made mandatory for all companies, but that the obligation of being externally audited
and certified should not be imposed at all on SMEs. The survey also indicated that the direct
economic impacts of all the requirements would be proportionally more significant for micro and
small companies, considering their limited staff compared to medium and large companies. They also
appeared to be too burdensome for companies with a capacity below 1 000 tonnes per year. Among
the various best handling practices, the mandatory use of specific equipment and of specific
packaging (i.e. airtight, puncture-resistant and environmentally sealed) was identified as the most
expensive measure. Generally, the cost per tonne of the measures to be implemented would become
insignificant for companies with capacities above 5000t. Finally, financial support and a
measurement standard for pellet losses were identified as the support that would best help
respondents.
In order to reply to the survey and minimise burden, sub-Options were assessed, and sub-Option 2b
with lighter requirements for micro- and small enterprises chosen. Medium companies are not
included in the lighter regime as the costs are significantly less burdensome to them, as emerged both
during the targeted survey and our cost analysis. Further mitigating measures can be envisaged, such
as a delayed phasing-in of the requirements, longer validity periods for the auditing results,
differences in obligations (external audit or certification) and financial and non-financial support to
tackle concerns raised by SMEs (lack of staff/time, lack of information on risks and solutions and
lack of financial resources, see Box 5 and Annex 12). In addition, SMEs can benefit from various
EU programmes and support mechanism to help them implement this initiative (COSME, Enterprise
Europe, InvestEU, Horizon), along with national support through Cohesion policy and NEXTGEN
EU.
The Commission and Member States could provide some non-financial support. For example, a
project could be supported by the Commission which would:
1 develop SME-specific guidance and training materials and tools to help compliance with the new
legal requirements and certification;
2 deliver advisory services; and
3 establish a help desk/expert pool to assist first-level advisers and deal with more difficult
questions or issues.
Such support can be open potentially to larger companies. This non-financial support would incur
costs for the competent authorities and/or the Commission (with a budget of around EUR 1 million).
62
8.2.3 Competitiveness
According to EUPC, the turnover of the plastics sector in the EU27 in 2021 was EUR 405 billion.
Therefore, the additional estimated cost of option 2b would represent about 0.13% of the EU plastics
sector turnover. The additional costs are likely to have a very minor negative impact on the
competitiveness of the EU pellet producers, as their competitors outside the EU will not be subject
to the requirements (logistical operators importing pellets will have to comply within the EU). Annex
5 further details the preferred option’s impact on the competitiveness of the sector and of SMEs.
8.3 REFIT & administrative costs
There are no administrative costs for citizens.
There are administrative costs of EUR 44 million for businesses:
• One-off costs (EUR 0.1 million149
) of setting up systems in businesses for administrative
procedures to report pellet losses;
• Reccurent costs (EUR 43.9 million) for internal assessments, external auditing and
certification:
o internal assessment – EUR 30.8 million;
o external audit and/or certificate – EUR 12.9 million;
o filling forms and tables – EUR 0.2 million (for notifying public authorities of the
certification).
These costs are calculated for the preferred option 2b; they do not take into account the additional
reductions described in Box 5.
8.4 Policy instrument
A Regulation would be best suited to delivering the mandatory requirements foreseen under the
preferred option, as it will ensure pellet-handling companies will only have to comply with one set
of requirements across the Union that will be directly applicable ensuring equal implementation in
the Member States. The entire pellet supply chain will be subject to these requirements, and Member
States will be responsible for enforcement.
9 HOW WILL ACTUAL IMPACTS BE MONITORED AND EVALUATED?
Whilst the existing data is sufficient to underpin a policy response, more monitoring is needed to
further understand the dimension and impacts of the problem, inform further policy developments
and track the possible success of the proposed actions. Therefore, Option 1 was proposed under the
preferred options. In order to track performance against the 30% microplastic emission reduction
target (by 2030), an estimate of total pellet losses is required. An initial estimate has been compiled
for this IA, but further work should continually improve and expand this into the coming years. Based
on the results of the monitoring in 2030, a review of this initiative will take place.
149
Total initial cost are EUR 0.5 million for businesses, which have been annualised over a 5 year period using a discount
rate of 3% (0.5 hour for medium and large businesses and 0.25 hour for small and micro businesses and using EU
average wages (29 €/hour)). It is estimated that the internal assessment is already covering most of the related cost.
63
In the OPC, apart from business associations who somewhat agree, all other stakeholders completely
agree with a system to monitor and report microplastic releases throughout the life-cycle.
The following monitoring of microplastics could be helpful:
• The proposed monitoring of microplastics at the inlet and outlet of UWWTPs, as well as in the
sludge, included in the proposal for the revision of the UWWTD.
• The obligation to monitor and assess microplastics (including pellets) in coastal and marine
environments, in the framework of the MSFD. Regulatory thresholds for the concentration of
microlitter, including microplastics, are under preparation.
• The preparatory work for the revision of the list of polluting substances under the EQSD, the
GWD and the Water Framework Directive, including the setting of a methodology to monitor
microplastics in the aquatic environment as well as in the Drinking Water Directive.
In addition, standardised measurement measures could be developed for the unintentional releases of
microplastics from the other five main sources. These could be pursued through Research and
Innovation Programmes by relevant research projects or under the Standardisation Regulation.150
The information will need to be reported at Member State level and collated at EU level in order to
create synergies and consistency between policies. This could also help identify new sources of
microplastics that would need to be addressed by specific measures in the future
150
Regulation (EU) No 1025/2012 on European standardisation, amending Council Directives 89/686/EEC and
93/15/EEC and Directives 94/9/EC, 94/25/EC, 95/16/EC, 97/23/EC, 98/34/EC, 2004/22/EC, 2007/23/EC,
2009/23/EC and 2009/105/EC and repealing Council Decision 87/95/EEC and Decision No 1673/2006/EC.


EN EN
EUROPEAN
COMMISSION
Brussels, 16.10.2023
SWD(2023) 332 final
PART 3/3
COMMISSION STAFF WORKING DOCUMENT
IMPACT ASSESSMENT REPORT
Combatting microplastic pollution in the European Union
Accompanying the document
Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE
COUNCIL
on preventing plastic pellet losses to reduce microplastic pollution
{COM(2023) 645 final} - {SEC(2023) 346 final} - {SWD(2023) 330 final} -
{SWD(2023) 333 final}
Offentligt
KOM (2023) 0645 - SWD-dokument
Europaudvalget 2023
234
TABLES OF CONTENTS
ANNEX 15: PRELIMINARY ANALYSIS OF THE MAIN SOURCES OF MICROPLASTIC EMISSIONS
...........................................................................................................................................................235
1 THE ORIGINALLY IDENTIFIED SOURCES OF MICROPLASTIC EMISSIONS ......................235
2 INTRODUCTION TO THE PRELIMINARY ANALYSIS OF THE FIVE SOURCES ..................236
3 RELEVANT LEGISLATION FOR REDUCING MICROPLASTIC EMISSIONS & ONGOING
INITIATIVES....................................................................................................................................239
3.1 Ecodesign for Sustainable Product Regulation ......................................................................239
3.2 Tyres labelling and EURO 7 ..................................................................................................240
3.3 Construction Products Regulation..........................................................................................240
3.4 EU Strategy for Sustainable and Circular Textiles.................................................................240
3.5 Research .................................................................................................................................240
3.6 Member state and international actions on microplastics.......................................................240
3.7 Industry initiatives..................................................................................................................243
3.8 Multilateral Actions................................................................................................................245
4 PROBLEM DEFINITION BY SOURCE ..........................................................................................245
4.1 Problem definition for tyres ...................................................................................................245
4.2 Problem definition for textiles................................................................................................258
4.3 Problem definition for paints..................................................................................................265
4.4 Problem definition for detergent capsules..............................................................................269
4.5 Problem definition for geotextiles..........................................................................................274
5 BASELINE BY SOURCE .................................................................................................................276
5.1 Baseline for tyres....................................................................................................................276
5.2 Baseline for textiles................................................................................................................281
5.3 Baseline for paints..................................................................................................................290
5.4 Baseline for detergent capsules ..............................................................................................302
5.5 Baseline for geotextiles ..........................................................................................................307
6 POTENTIAL MEASURES ...............................................................................................................310
6.1 Measures for tyres..................................................................................................................310
6.2 Measures for textiles ..............................................................................................................321
6.3 Measures for paints ................................................................................................................332
6.4 Measures for detergent capsules.............................................................................................347
6.5 Measures for geotextiles.........................................................................................................350
6.6 Summary of policy measures .................................................................................................355
7. INITIAL IDENTIFICATION AND SCREENING OF IMPACTS ...................................................356
7.1 Identifying and selecting of impacts.......................................................................................356
7.2 Impact of measures for tyres ..................................................................................................361
7.3 Impact of measures for textiles ..............................................................................................386
7.4 Impact of measures for paints ................................................................................................413
7.5 Impact of measures for detergent capsules.............................................................................433
7.6 Impact of measures for geotextiles.........................................................................................438
7.7 Overview of possible measures to improve source characterisation ......................................445
7.8 Abatement curve of assessed measures..................................................................................445
8. RATIONALE FOR NOT YET PURSUING THE MEASURES FOR SOURCES: PAINTS, TYRES,
TEXTILES, DETERGENT CAPSULES, GEOTEXTILES ..............................................................447
235
Annex 15:
Preliminary analysis of the main sources of microplastic emissions
This Annex reflects the initial analytical work that was undertaken while developing this impact
assessment. While six major sources of unintentional releases of microplastic were identified (paints,
tyres, pellets, textiles, detergent capsules and geotextiles), pellets were the only source retained for
further legislative action in this impact assessment. The preliminary analysis showed that subject to
further analysis of cost-effectiveness, and the impacts of alternatives, existing or forthcoming
legislative instruments were better suited to tackling microplastic releases from paints, tyres,
textiles, detergent capsules and geotextiles. This Annex outlines the preliminary analysis of these
five sources in view of guiding any future analysis.
1 THE ORIGINALLY IDENTIFIED SOURCES OF MICROPLASTIC EMISSIONS
A UN Environment study1
identified as many as 74 sources for the release of microplastics (both
primary and secondary microplastics) into the environment. Depending on the literature source, the
importance and share of sources contributing to the unintentional release of microplastics vary
widely. Microplastics are released in different stages of the product life cycle, such as production,
transport, use, and end-of-life. Regarding industrial sources, the plastic and textile industries are
considered to be the major contributors.
It is to note that the present monitoring data lacks harmonization of sampling and analytical methods,
and data is difficult to compare. Different approaches were used to estimate the emissions from
sources because of the heterogeneity of the available data or data unavailability. Several studies have
indicated tyres, textiles and pellets as the main sources of the unintentional release of microplastics2
.
Further desk research and stakeholder consultation3
pointed to three additional sources, as the
preliminary analysis estimated them as main sources of unintentional releases of microplastics:
• Paints, probably the largest emitter, including also road markings and marine paints;
• Geotextiles;
• Detergent capsules (comprising laundry and dishwater capsules).
For pellets, textiles, detergent capsules and geotextiles, reliable estimates were not available on the
quantity of material or for the microplastic emission rate, and therefore researchers have estimated
1
UN Environment (2018): Mapping of global plastics value chain and plastics losses to the environment with a
particular focus on marine environment
2
Germany (2014) Sources of microplastics relevant to marine protection, Report for Federal Environment Agency.
Norway (2014) Sources of microplastic pollution to the marine environment, Report for Norwegian Environment
Agency.
Denmark (2015): Occurrence, effects and sources of releases to the environment in Denmark, Report for The Danish
Environmental Protection Agency.
Sweden (2016): Swedish sources and pathways for microplastics to the marine environment, Report for Swedish
Environmental Protection Agency
OSPAR (2017): Assessment document of land-based inputs of microplastics in the marine environment
Eunomia (2018): Investigating options for reducing releases in the aquatic environment of microplastics emitted by
(but not Intentionally added in) products: Final report.
Ryberg et al. (2019): Global environmental losses of plastics across the value chains. Resource, conservation and
Recyling.
3
A dedicated website https://microplastics.biois.eu was maintained to ensure constant interaction with stakeholders
236
varying emission levels. A range of possible emissions scenario was provided for these four sources,
which varies significantly for some sources such as textiles.
For tyres, on the other hand, in the absence of data, a modelling approach was used for estimating
the potential microplastic emissions, resulting in an average figure. On the basis of the uncertainty of
the input data and the modelling parameters, an uncertainty factor of about 20% was applied to
calculate the upper and lower ranges. For paints, a confidence interval for the micro-plastic leakage
to the environment was estimated using a Montecarlo approach. The first step is to set confidence
intervals for the input parameters. Since the data availability surrounding plastic losses from paint is
scarce, a qualitative approach rather than a data-driven approach is used to set the intervals on the
input parameters4
. Ultimately, the 95% confidence interval for the total paint micro-plastic leakage
to the environment in EU-27 is 231 - 863 kt a year. Estimated releases from these six sources are
captured in Table 1.
Table 1: Estimated releases from the six sources of unintentional microplastics release to the EU
environment
Source Quantity (tonnes/year), 2019*
Paints 231 000 – 863 000 (average 482 000)
Tyres 360 000 – 540 000 (average 450 000)
Pellets 52 140 – 184 290
Textiles 1 649 – 61 078
Geotextiles 6 000 – 19 750
Detergent capsules 4 140 – 5 980
TOTAL of the selected six sources 654 929 – 1 674 098 (90-93% of total emissions)
TOTAL of all sources 729 087 – 1 808 198
(*) Estimations based on the supporting study for this Impact Assessment
Other sources were also considered and summarised in Annex 14. It also includes further information
on each of these other sources that we did not retain in the analysis because they were considered as
microplastics coming from the intentional use of microplastics added to products or due to a lack of
sufficient information.
2 INTRODUCTION TO THE PRELIMINARY ANALYSIS OF THE FIVE SOURCES
In this chapter, we present the preliminary analysis undertaken for five of the originally
identifiedmajor sources: tyres, textiles, paints, detergent capsules and geotextiles. These sources were
analysed by identifying measures to tackle the following two interlinked problem areas:
➢ The negative environmental and (potential) health impacts associated with the
unintentional releases of microplastics into the environment from the five sources into
the environment. Most of the problems are associated with microplastics in general,
4
Paruta et al. (2022) Plastic Paints the Environment, EAEnvironmental Action 2022, ISBN 978-2-8399-3494-7
237
irrespective of their source. Specific impacts are explained when discussing the most relevant
sources.
➢ Insufficient data / information on unintentional microplastics releases from five sources.
There is an absence of comprehensive information on the unintentional releases of
microplastics from different sources (thus a high uncertainty). While existing information
might be sufficient to take action in some cases, also in line with the precautionary principle,
in other cases more information and research is needed in order to understand the sources of
microplastics and their impacts so that effective policies can be designed.
Although microplastics is an active field of research and the number of publications on microplastics
has increased rapidly in recent years, a standardised procedure for identifying/quantifying
microplastics from different sources is still lacking. Investigations are generally conducted using
different methods, covering differing particle sizes and expressed in different units that cannot be
converted, overall making it difficult to compare results across studies. Hence, the reported
abundance of microplastics and respective sources in the environment have high variability and may
differ by several orders of magnitude.
Data Uncertainties
This IA identifies, for each of the five sources, different uncertainties and data gaps that are
explained in more detail in the baseline of this Annex. Some salient features include:
Tyres: Several factors influence the release of Tyre Wear Particles (TWP) into the environment, e.g.
tyre material and design (which consists of many components), road composition, and driving
behaviour. Analysing tyre abrasion in environmental samples is challenging, and an interpretation of
the analytical data should reflect the external conditions. Additionally, reproducible quantification of
particles in the environment depends on the laboratories’ sampling and analytical techniques, where
weaknesses and knowledge gaps exist. The ongoing work to develop a harmonised test method and
standard to measure TWP emissions should help. In addition to uncertainties with the overall
emission factors for tyre abrasion, there is also a lack of data on the mix of tyres currently in use and
how they vary in terms of abrasion rates. A number of studies have demonstrated significant variation
in abrasion rates between different tyre models and types both across different categories (i.e. tyre
sizes and types) as well as within categories.
Textiles: the uncertainty of the microplastic estimations is high. In the baseline, they vary between
2 058 and 74 111 t per year in the EU. The data quality is low for production and wearing life-cycle
stages. There is no data for the end-of-life. The uncertainty comes from the limited data to quantify
microplastic emissions and not from the baseline extrapolation.
Paints: Some uncertainties and data gaps exist relative to market statistics of paint sold per paint
sector and the plastic content within it. For wear and tear losses, the lifetime of the paint system is
not a subject that is systematically researched and assessed, but its assessment is key in order to
determine microplastic pollution during the use phase of the object.
Detergent capsules: The estimated amount of potential microplastic losses through capsules to the
environment bears several uncertainties. The principal uncertainty results from the fact that this
source relates to a water soluble and biodegradable polymer. There is a lack of information on the
composition of PVOH and related mixtures used for detergent capsules due to trade secrets and the
subsequent lack of data on whether all PVOH-based grades are fully degradable in all environmental
media.
238
Geotextiles: There are several uncertainties and data gaps, in particular concerning the quantities
installed and for which application they are used, along with the related microplastic emissions.
Depending on the application, geotextiles do not represent the same microplastic emission potential,
e.g., geotextiles used to stabilise the soil during road construction are not exposed to UV, air, or
abrasion in the same way as geotextiles used for coastal protection. However, limited data is
available.
Table 2: Problem evolution and objectives of EU actions
Problem
area
How would the problem
evolve without action?
Why is action needed at the
EU level?
Objectives for remediation
Tyres The trends show an increase in
tyre wear emissions, with
increases of around 20-30%
expected by 2030. Whilst a test
method for measuring TWP
emissions is under
development, this alone will
not necessarily drive any
reductions.
Type approval testing for tyres
with a standard on tyre abrasion
is foreseen and then needs to be
implemented at a European and
international level to ensure
harmonisation of tyre quality and
characteristics.
EU action is required to set limits
also for tyre abrasion in order to
limit the emissions of
microplastics from tyres, as well
as to ensure a consistent
implementation of measures and
to avoid distortions in the market
and between Member States.
To reduce emissions from tyres
through actions targeted at the
tyres themselves as well as other
factors impacting emissions.
Textiles The trends show an increase in
microplastic emissions from
textiles, around 22% expected
by 2030.
EU action is required to improve
the understanding of microplastic
emissions over the life cycle of
synthetic textiles. EU action will
also ensure a consistent
implementation of measures and
avoid distortions in the market
and between Member States.
To improve the knowledge base
and bridge the data gaps through
better source characterisation.
To reduce microplastic emissions
from textiles through actions
targeted at the life-cycle
(production, washing, etc.) of
textiles.
Paint Paint is the key to asset
protection as it extends objects'
lifetime. How polymer-based
paint is used, though, is the
source of microplastic
pollution in the environment.
Without action, the business-
as-usual scenario is a never-
ending accumulation of
microplastic pollution in all
environmental compartments.
In order to prevent microplastic
emissions from paints,
mandatory action is needed to
make sure that measures are
applied in different sectors which
use paints.
Action at EU level would create
a coherent framework from
which every Member state will
benefit.
To improve the knowledge base
and bridge the data gaps through
better source characterisation.
To reduce microplastic emissions
from paints and incentivise the
development of new technologies
for paint application, maintenance
and capture.
Detergent
Capsules
The general increase in the use
of PVOH and related blends in
detergent capsules could raise
concerns regarding their
possible emissions in
wastewater. There is a lack of
data on whether all available
PVOH-based grades are fully
degradable in all
environmental media.
EU action would ensure a
consistent implementation of
measures to tackle microplastic
release from detergent capsules
and create a coherent framework
from which every Member state
will benefit.
To improve the knowledge base
and bridge the data gaps through
better source characterisation.
To ensure that PVOH does not
cause any adverse environmental
impacts, the objective of the
remediation is to actively reduce
the release of PVOH into the
European environment.
Geotextiles The geotextiles market is
seeing significant growth
(expected to grow by 2.5
times by 2029 compared to
An EU-wide action on tackling
microplastic emissions from
geotextiles will ensure deeper
insight into the problem and
To improve the knowledge base
and bridge the data gaps through
better source characterisation.
239
Problem
area
How would the problem
evolve without action?
Why is action needed at the
EU level?
Objectives for remediation
2019). This would result in a
significant release of
microplastics (particularly
from coastal erosion and river
margins applications).
create a coherent framework
from which every Member state
will benefit.
The reduction of microplastic
emissions from geotextile use.
3 RELEVANT LEGISLATION FOR REDUCING MICROPLASTIC EMISSIONS & ONGOING INITIATIVES
The following legislation and ongoing initiatives were identified as relevant to the reduction of
microplastic emissions. This overview aims to provide insight into the EU’s and Member States’
current approach to microplastics and point to any regulatory gaps. This section only contains the
legislation relevant to the five sources discussed and not to pellets. The legislation relevant to pellets,
such as the REACH restriction, is explained in Annex 6 of this IA on legislation related to pellets.
Several EU policies and instruments (waste management, air quality, industrial emissions legislation,
tyre labelling, motor vehicle type approval legislation) affect or could affect directly or indirectly the
generation and release of microplastics in the environment. The Fertilising Products Regulation
contains a provision on ‘Controlled Release Fertilisers’ targeting microplastic releases used for
fertilisers. But none of these has already taken decisive action.
3.1 Ecodesign for Sustainable Product Regulation
In March 2022, the European Commission adopted a proposal5
for Regulation establishing a
framework for setting ecodesign requirements for sustainable products and repealing Directive
2009/125/EC. This proposal is the cornerstone of the Commission’s approach to more
environmentally sustainable and circular products. The proposal builds on the existing Ecodesign
Directive6
, which only covers energy-related products.
This proposal will set harmonised rules on environmental sustainability for products, including
textiles and paints, to make them more durable, reliable, reusable, upgradable, reparable, easier to
maintain and refurbish, and energy and resource-efficient. A preliminary assessment of the products
to be included in the first Working Plan for the ESPR is currently ongoing. Textiles, detergents, tyres
and paints may be part of the working plan in the framework of the ESPR proposal – this is to be
determined at a later stage. The implementation of the ESPR is expected to include information and
performance requirements on products at the source of microplastic release and using the
corresponding testing and measurement method.
The Implementing Regulation on eco-design for washing machines and washer-dryers7
, adopted
in 2019, recognises the need to consider, in the next review of the Regulation foreseen by 2025, the
feasibility of new requirements for reducing micro-plastics in the water outlet, such as filters.
5
European Commission, Commission Proposal for a Regulation establishing a framework for setting eco-design
requirements for sustainable products and repealing Directive 2009/125/EC, COM(2022)142 final, 2022.
6
See Energy label and ecodesign (europa.eu)
7
Commission Regulation (EU) 2019/2023 of 1 October 2019 laying down ecodesign requirements for household
washing machines and household washer-dryers pursuant to Directive 2009/125/EC of the European Parliament and
of the Council, amending Commission Regulation (EC) No 1275/2008 and repealing Commission Regulation (EU)
No 1015/2010, OJ L 315, 5.12.2019, pp. 285-312.
240
3.2 Tyres labelling and EURO 7
In the recent revision of the Tyre Labelling Regulation8
, the co-legislators agreed to empower the
Commission to adopt delegated acts in order to include parameters or information requirements for
tyre “abrasion and mileage” (as soon as a suitable method is available). The co-legislator had clearly
in mind how an indicator of abrasion alone was not going to be effective in orienting consumer
purchase choice, and a complementary indicator, possibly combined and highly “valued” by
consumers, such as mileage, was necessary. The type approval legislation refers to the same testing
methods for the same parameters and sets the minimum requirements for efficiency, safety and health
protection. The Euro 7 standard adopted by EC in November 2022 has a placeholder to introduce the
abrasion limits for tyres once the emissions’ measurement methodology is developed.
3.3 Construction Products Regulation
The revised Construction Products Regulation introduces the requirements for construction products,
such as cement, steel, aluminium and plastics, to improve the protection of health, safety and the
environment, in line with the new Ecodesign for Sustainable Product Regulation.
3.4 EU Strategy for Sustainable and Circular Textiles
The EU strategy for sustainable and circular textiles9
, adopted on 30.03.2022, sets the vision for a
more sustainable textile sector by looking at the entire life-cycle of textile products and proposing
actions to change how to produce and consume textiles. The Strategy identifies microplastics releases
as one of the main issues to be addressed and refers to the current initiative. The Strategy also
mentions that “the Commission will propose harmonised EU extended producer responsibility rules
for textiles with eco-modulation of fees, as part of the forthcoming revision of the Waste Framework
Directive in 2023”.
3.5 Research
Besides the policy and legislative activities, the EU is dedicating substantial resources to better
understanding and combating marine litter (including microplastics) through a number of projects
funded by the LIFE, EMFF/EMFAF, Horizon 2020 and Horizon Europe Programmes or other
projects, including enlargement neighbourhood funding and regional (e.g. Interreg) funding.
3.6 Member state and international actions on microplastics
Several EU member states have implemented measures to tackle microplastic emissions, particularly
in recent years. If most of these measures are aimed at banning intentionally added microplastics
(such as in cosmetics) or single-use plastics, there are examples of initiatives taken on unintentionally
released microplastics that are presented in
8
Regulation (EU) 2020/740 of May 2020
9
European Commission, Commission Communication – EU Strategy for Sustainable and Circular Textiles,
COM(2022)141 final, 2022.
241
Table 3.
242
Table 3: Selected actions in Member States
Countries Sources Measure
France Textiles Mandatory requirement for all new washing machines to be equipped with
microfiber filters by January 1st
2025.10
Denmark Microplastics Monitoring program of Danish Marine Strategy including monitoring of marine
litter, analyses of microplastic in sediments, as well as analyses of macro and
microplastics in stomachs of two fish species.11
Netherlands Microplastics Research program on mitigation measures to avoid microplastic emissions from
pellets, tyres, textiles and paints.
Investigation on the supply chain by January, mainly on spills.
Developing a plan with a focus on small companies.12
Sweden Microplastics Research program in 2017 to identify the main sources of microplastic emissions in
Sweden.13
Similarly, outside of the EU, several countries have started actions against microplastic emissions,
which are summarised in Table 4.
Table 4: Selected international actions
Countries Sources Measure
Chile Microplastics National Strategy for Marine Waste and Microplastics Management, launched in
2021, with the objective for sustainable plastic waste management throughout
their life cycle, preventing and reducing the discharge of plastic waste in aquatic
ecosystems.
Commission for
Environmental
Cooperation
(CEC)
Microplastics Transformation of recycling and solid waste management in North America”
brings Mexico, Canada, and the US together to accelerate the adoption of circular
economy and sustainable management practices regarding materials (plastics and
microplastics) in North America.
UK Microplastics The UK government commissioned research projects to better understand the
issue of microplastics losses from tyres and clothing. A Rapid Evidence Review
has been commissioned to gather the evidence to progress approaches to more
consistent definition, sampling and assessment methodologies for monitoring
and reporting microplastics in water. Collaboration is also ongoing with the water
industry to establish methods to detect, characterise and quantify microplastics
in waste water and evaluate the removal efficiency of treatment processes.
10
LOI n° 2020-105 du 10 février 2020 relative à la lutte contre le gaspillage et l’économie circulaire (1) [Law n°2020-
105 of 10 February 2020 related to the fight against waste and the circular economy (1)], Journal official “Lois et
Décrets” no. 0035 du 11 février 2020 [JORF] [Official journal “Laws and Decrees” no. 0035 of 11 February 2020],
11 February 2020, Fr.
11
Ministry of Environment and Food of Denmark; Microplastics: Occurrence, effects and sources of releases to the
environment in Denmark, Environmental project No. 1793, 2015
12
Dutch Government, Policy Programme on (micro) plastics – European Marine Strategy Framework Directive, 2020
(https://g20mpl.org/partners/netherlands).
13
Swedish Government, ‘Microplastics’, 2022 (https://www.naturvardsverket.se/amnesomraden/plast/om-
plast/mikroplast/).
243
Countries Sources Measure
Australia Textiles The National Plastics Plan 2021 announced that the Australian Government will
work with industry to phase in microfibre filters on new residential and
commercial washing machines by 1 July 203014
Canada Textiles
Research
Under the Zero Plastic Waste strategy, Canada is implementing a comprehensive
approach to reduce plastics pollution, which includes investing in science to close
research gaps on macro and microplastics. The government provided funding to
support research on microfibre release occurring during washing, to design
dedicated test methods and to develop sampling methods for microfibres in
laundry effluent and wastewaters.
Norway Tyres,
Textiles, Turfs
The Norwegian Climate and Environment Ministry commissioned a review on
microplastics pollution, which includes measures to target wear and tear of
vehicle tires and textiles and losses from artificial turfs.
Norway has implemented speed limits to reduce local air pollution caused by
road dust will likely also reduce microplastic emissions.
USA
(Connecticut)
Textiles
Research
Development of research programs, awareness-raising campaigns and best
consumer practices to reduce microfibre shredding and microplastics emissions
during laundering
House Bill 5360 (2018) to target microfibres emitted during laundering. The bill
mandated further research on microfibres, awareness-raising initiatives and the
development of best consumer practices and industry efforts to prevent
microfibre shedding.
USA
(California)
Textiles Microfiber bill AB 129: development of a standard methodology to assess the
efficiency of microfiber filtration in washing machines
Bill AB 1952 (under preparation): launch of a pilot program on microfibre filters
USA (New
York)
Textiles New York State proposed Assembly Bill A01549 in 2018. This would require
the following labelling for all products containing more than 50% synthetic
material: “This garment sheds plastic microfibers when washed”.
USA (NASA) Monitoring Using a new technique relies on data from NASA’s Cyclone Global Navigation
Satellite System (CYGNSS), a constellation of eight small satellites that
measures wind speeds above Earth’s oceans and provides information about the
strength of hurricanes, the NASA team looked for places where the ocean was
smoother than expected given the wind speed, which they thought could indicate
the presence of microplastics. Then they compared those areas to observations
and model predictions of where microplastics congregate in the ocean.
3.7 Industry initiatives
Selected voluntary initiatives are presented in Table 5.
14
Australian Government, ‘National Plastics Plan 2021’, 2021
(https://www.agriculture.gov.au/sites/default/files/documents/national-plastics-plan-2021.pdf).
244
Table 5: Selected voluntary initiatives (Industry and NGO)
Name Sources Details
Microfibre
Consortium
Textiles Development of practical solutions for the textile industry to minimise microfibre
release to the environment from textile manufacturing and product life cycle.
Voluntary
Cross
Industry
Agreement
Textiles Several industry associations (International Association for Soaps, Detergents and
Maintenance Products, Comité International de la Rayonne et des Fibres
Synthétiques, European Outdoor Group, Euratex and the Federation of the European
Sporting Goods Industry) have formed a voluntary Cross Industry Agreement. The
partnership aims to contribute to the development of international standardised test
methods to identify and quantify microfibres, share information on the progress of
research, knowledge gaps, options and priorities and support and participate in
industrial research for the development of feasible and effective solutions
Clothing
Industry
initiative
Textiles Patagonia, Arc’teryx, REI and MEC and MetroVancouver commissioned Ocean
Wise’s Plastic Lab to investigate microfibers, the tiny textile particles that shed from
garments over their lifetime.
Tire Industry
Project
Tyres This project, launched by 11 major tyre manufacturing companies under the
umbrella of the World Business Council of Sustainable Development (WBCSD),
aims to identify and implement feasible measures in order to reduce the impact of
the life cycle of tyres on the environment, also in the context of microplastics
pollution. 15
European
Tyre and
Road Wear
Particle
Platform
Tyres The European Tyre and Rubber Manufacturers Association (ETRMA) initiated this
multi-stakeholder platform aimed to facilitate research, encourage stakeholder
cooperation and knowledge-sharing and explore mitigation options to reduce TRWP
pollution.
European
Tyre and
Rime
Technical
Organization
(ETRTO)
Tyres ETRTO is working on assessing the feasibility and accuracy of a standard test
method for the tyre abrasion rate to propose to the European Commission.
Plastic soup
foundation
Textiles
Cosmetics
With their Beat the Microbead app, one can scan all your personal care and cosmetic
products for yourself to see if they contain plastic ingredients. Their Ocean Clean
Wash campaign additionally raises awareness about microfibers and the relationship
between clothes and plastic in the ocean.
Race for
Water
Odyssey
Microplastics Raise awareness about microplastics16
Rethink
plastic
alliance
Microplastics Awareness raising, policy lobbying
Seas at Risk Microplastics Awareness raising, policy lobbying
15
https://tireparticles.info/our-research
16
https://www.raceforwater.org/en/news/microplastics/
245
3.8 Multilateral Actions
In March 2022, the second session of the 5th
United National Environment Assembly unanimously
adopted resolution 14: End Plastic Pollution: towards an international legally binding instrument17
(hereafter referred to as the resolution). The preamble to the resolution highlights that “plastic
pollution includes microplastics”. This inclusion indicates that the intergovernmental negotiating
committee (INC) will have to consider how to address microplastics in a forthcoming global
agreement.
In May 2019, the Conference of the Parties to the Basel Convention adopted a decision by which it
amended Annexes II, VIII and IX of the Convention in relation to plastic waste. A Plastic Waste
Partnership was created with the aim, among other things, to significantly reduce and eliminate the
discharge of waste plastics and microplastics in the environment. The OECD Council
Recommendation on Water calls for Adherents to prevent, reduce and manage water pollution from
all sources while paying attention to pollutants of emerging concern, such as microplastics. UNEP’s
Clean Seas campaign raises awareness on microplastics, such as on cigarette filters, textiles and
cosmetics.
4 PROBLEM DEFINITION BY SOURCE
4.1 Problem definition for tyres
Tyre wear is caused by the friction process between tyres and the road surface. Accordingly, tyre
wear is emitted wherever and whenever vehicles travel. From the point of origin, it can either be
transported directly into the three environmental compartments (soil, air, water) or indirectly through
remobilisation and deposition. Most tyre wear is initially deposited on or near the road surface. The
finer fractions (PM2.5 and PM10) can be transported much further by airborne drift18
. As exhaust
emissions of particular matter continue to decline due to legislation such as Euro 6, the contribution
that tyre wear and other non-exhaust emissions make to total PM emissions from road transport are
increasing significantly. For example, in the UK, non-exhaust emissions (i.e. particles from brake
wear, tyre wear and road surface wear) have been estimated to contribute around 60% and 73% (by
mass) of primary PM2.5 and PM10 emissions, respectively, from the road transport sector (and 7.4%
and 8.5% of total primary UK PM2.5 and PM10 emissions, respectively)19
. In the EU, non-exhaust
PM, emissions from brake, tyre or road wear, have all increased and become the dominant transport
emission source for PM10 (since 2012) and PM2.5 (since 2018)20
.
17
United Nations Environment Assembly, Resolution – End plastic pollution: towards an international legally binding
instrument, UNEP/EA.5/Res.14, 02.03.2022.
18
Air Quality Expert Group, Report for UK Department for Environment, Food and Rural Affairs, Scottish Government,
Welsh Government, and Department of the Environment in Northern Ireland, ‘Non-Exhaust Emissions from Road
Traffic’, 2019 (https://uk-
air.defra.gov.uk/assets/documents/reports/cat09/1907101151_20190709_Non_Exhaust_Emissions_typeset_Final.pd
f).
19
Air Quality Expert Group, Report for UK Department for Environment, Food and Rural Affairs, Scottish Government,
Welsh Government, and Department of the Environment in Northern Ireland, ‘Non-Exhaust Emissions from Road
Traffic’, 2019 (https://uk-
air.defra.gov.uk/assets/documents/reports/cat09/1907101151_20190709_Non_Exhaust_Emissions_typeset_Final.pd
f).
20
Vanherle, K. et al., ‘ETC/ATNI Report 5/2020: Transport Non-exhaust PM-emissions. An overview of emission
estimates, relevance, trends and policies’, Eionet Portal, 2021 (https://www.eionet.europa.eu/etcs/etc-
atni/products/etc-atni-reports/etc-atni-report-5-2020-transport-non-exhaust-pm-emissions-an-overview-of-emission-
estimates-relevance-trends-and-policies).
246
4.1.1 Pathways to the environment and the scale of their impact
The impact of tyre wear on individual environmental compartments and the organisms living there
is not sufficiently understood. However, there are already many studies that have estimated the total
emissions of tyre wear for a region or country. These have typically been developed by combining
activity rates (generally vehicle kilometres) with emission factors (i.e. the rate of microplastic release
per vehicle kilometre), sometimes disaggregated by road and/or vehicle type, although other
approaches have also been taken. A comprehensive literature review on tyre wear has been prepared
by Baensch-Baltruschat et al.21
This provides estimates of the mass losses of the tyres. In some cases
(e.g., in Sundt et al.), the calculated TWP (total) is supplemented by the polymer shares (polymer).
Table 6: Annual tyre wear emissions for different countries and regions from Baensch-Baltruschat et
al.22
supplemented by Hann et al.23
and ETRMA.242526
Country Tyre wear
emissions in
total (referring
to tyre tread)
tonnes/years
Calculation
method
Emission
Factor
applied
Remarks Reference
EU28 572,157 own data (ETRMA, 2018)
EU28 503,586 b k (Hann, 2018)
EU28 1,327,000 b Estimates based on EU
Registered LDV and HDV
X Total vehicle km derived
from data of Germany / no
differentiation of road type
(Wagner, 2018)
Germany 61,000 b own data Derivation of EF is not
explained
(Baumann, 1997)
Germany 111,420 b i (Hillenbrand, 2005)
Germany 60,000-
111,000
c (Essel, 2014)
Germany 133,000 b i (Wagner, 2018)
21
Baensch-Baltruschat, B. et al., ‘Tyre and road wear particles – A calculation of generation, transport and release to
water and soil with special regard to German roads’, Science of the Total Environment, Vol. 752, 2021, Elsevier BV.
22
Baensch-Baltruschat, B. et al., ‘Tyre and road wear particles – A calculation of generation, transport and release to
water and soil with special regard to German roads’, Science of the Total Environment, Vol. 752, 2021, Elsevier BV.
23
Hann, S., Sherrington, C., Jamieson, O. et al., Investigating options for reducing releases in the aquatic environment
of microplastics emitted by (but not intentionally added in) products, Eunomia report for the Directorate-General for
Environment, 2018.
24
Data provided by the European Tyre & Rubber Manufacturers Association (ETRMA) in: Hann, S., Sherrington, C.,
Jamieson, O. et al., Investigating options for reducing releases in the aquatic environment of microplastics emitted
by (but not intentionally added in) products, Eunomia report for the Directorate-General for Environment, 2018.
25
Hann, S., Sherrington, C., Jamieson, O. et al., Investigating options for reducing releases in the aquatic environment
of microplastics emitted by (but not intentionally added in) products, Eunomia report for the Directorate-General for
Environment, 2018.
26
Data provided by the European Tyre & Rubber Manufacturers Association (ETRMA) in: Hann, S., Sherrington, C.,
Jamieson, O. et al., Investigating options for reducing releases in the aquatic environment of microplastics emitted
by (but not intentionally added in) products, Eunomia report for the Directorate-General for Environment, 2018.
247
Country Tyre wear
emissions in
total (referring
to tyre tread)
tonnes/years
Calculation
method
Emission
Factor
applied
Remarks Reference
Germany 75,200 b j (Baensch-Baltruschat,
2020)
Germany 98,400 k (Baensch-Baltruschat(b),
2020)
Germany 125,188 b (Kole, Wear and Tear of
Tyres in the Global
Environment: Size
Distribution, Emission,
Pathways and Health
Effects, 2019)
Denmark 6514 – 7660 b l Recalculation of data
estimated by Lassen et al.
2015
(Kole, Wear and Tear of
Tyres: A Stealthy Source
of Microplastics in the
Environment. , 2017)
Denmark 4200 – 6600 d (Lassen, 2015)
Denmark 7310 d (Kole, Wear and Tear of
Tyres: A Stealthy Source
of Microplastics in the
Environment. , 2017)
France 37 646 d (Unice, 2018)
Seine River
basin (FR)
13 804 e (Unice, 2018)
Italy 50 000 n/a (Milani, 2004)
Netherlands 15452 (total) b n (Sherrington, 2016)
Netherlands 7726
(polymer)
b n (Sherrington, 2016)
Netherlands 17300 (only
tyre wear)
b o (Verschoor, 2016)
Netherlands 15030 b p (Kole, Wear and Tear of
Tyres: A Stealthy Source
of Microplastics in the
Environment. , 2017).
Netherlands 8768
(corrected for
amounts
trapped in
open pore road
surface)
b p (Kole, Wear and Tear of
Tyres: A Stealthy Source
of Microplastics in the
Environment. , 2017)
248
Country Tyre wear
emissions in
total (referring
to tyre tread)
tonnes/years
Calculation
method
Emission
Factor
applied
Remarks Reference
Norway 7500 (total) b l, m (Sundt, 2014)
Norway 4500
(polymer)
b l, m (Sundt, 2014)
Norway 9600 (total) f (Sundt, 2014)
Norway 5700
(polymer)
f (Sundt, 2014)
Norway 7100 (total) b l,k (Vogelsang, 2020)
Norway 4300
(polymer)
b l,k (Vogelsang, 2020)
Sweden 13000 b q (Magnusson, 2016)
Great
Britain
38000 – 75000 d (UK, 1999)
Great
Britain
42000 – 84000 d Update of data given by EA
UK
(Kole, Wear and Tear of
Tyres: A Stealthy Source
of Microplastics in the
Environment. , 2017)
A Own calculation, data source for number of inhabitants: total Europe (Eurostat, 2020), others (CIA, 2018).
B Estimation based on emission factors and total vehicle km.
C Data based on (Gebbe, 1997) and WDK (Association of German Rubber Manufacturing Industry, reporting year 2005)
D Estimation based on consumption of tyres and abrasive loss (weight loss during use).
E Derived from data for entire France based on population density and lengths of urban and rural roads in the Seine river basin
F Estimation based on the number of tyres collected for retreading and weight loss during use.
G Estimation based on the number of registered vehicles, life expectancy of tyres and loss during life time
H
Extrapolated from the emission data for DEU, DNK, GBR, ITA, NLD, NOR, SWE, AUS, BRA, CHN, IND, JPN, and USA, and
the world’s number of vehicles
I Emissions factors compiled by (Hillenbrand, 2005)
J Emissions factors compiled by (Gebbe, 1997)
K Emission factors by (Deltares-TNO, Emissieschattingen Diffuse bronnen Emissieregistratie. Remslijtage., 2016).
L (Luhana, 2004)
M (Anonymus, 2012)
N (Deltares-TNO, Emissieschattingen Diffuse bronnen Emissieregistratie. Remslijtage. , 2014)
O (Klein, 2015) (Dutch Pollutant Release and Transfer Register).
P Van Duijnhove et al. (2014)
Q (Gustafsson, 2008)
R (Aatmeeyara, 2009)
S Unified EF: 50 mg/km.
The total amount for the EU28, as shown in the table, is in the range of about 500 000 – 1 300 000
t/a (with the UK included). If the amount of emissions from the UK is excluded, according to Kole
249
(2017)27
, the emissions from the EU27 based on these studies would be about 460,000-1,220,000 t/a
(a specific quantification has been developed for this study and is described later in in the baseline.
Where tyre wear ends up in the environment is the subject of current research. The tyre wear mapping
study28
has calculated the input pathway after more direct emission of tyre wear for Germany and
selected regions in a comprehensive model. According to this, in Germany as a whole, tyre abrasion
is emitted in approximately 57% in urban areas, 43% to open spaces and forests. Direct input into
water bodies is only 0.4%, but indirect input from precipitation drainage must be considered.
The tyre wear deposited on the road surface can be flushed into surface waters via the road runoff
after precipitation, depending on the sewer system. Figure 1 shows the two possible sewer systems
“separate system”, where the road runoff is discharged directly into a surface water body, and the
“combined sewer system”, where the road runoff is discharged to a wastewater treatment plant.
During heavy rainfall events, the combined sewer system may be overloaded and drain directly to a
surface water body by means of a sewer overflow. Figure 2 shows volume flows based on the example
of Berlin and shows that about 78% of precipitation water is discharged untreated into surface waters.
The discharge via the sewer overflow amounts to 7% (15 million m³) and thus represents a pathway
that also needs to be taken into account.29
Sustainable drainage systems can be an efficient measure
to reduce emissions from tyre wear into the surface water, but such systems are mainly used on
motorways due to the space required. Further measures are discussed later in this section. WWTP is
not seen as a sink because microplastics from tyre wear will typically end up in sludge which is either
applied to fields as fertiliser and thus contributes to microplastic accumulation in the soil, or it is
incinerated or landfilled.
Figure 1: Volume shares of storm water in separations system and combined sewer system in Berlin30
27
Kole, P.J., Löhr, A.J., Van Belleghem, F.G.A.J. and Ragas, A.M.J., ‘Wear and Tear of Tyres: A Stealthy Source of
Microplastics in the Environment’, International Journal of Environmental Research and Public Health, Vol. 14, No.
10, 2017.
28
German Federal Ministry of Traffic and Digital Infrastructure (BMVI), ‘Schlussbericht 19F2050A-C:
TyreWearMapping: Reifenabrief – ein unterschätztes Umweltproblem?’ [Final report 19F2050A-C:
TyreWearMapping: Tyre abrasion – an underestimated environmental problem?], 2021
(https://www.umsicht.fraunhofer.de/content/dam/umsicht/de/dokumente/kompetenz/prozesse/tyrewearmapping-
schlussbericht.pdf), De.
29
TyreWearMapping - Digitales Planungs- und Entscheidungsinstrument zur Verteilung, Ausbreitung und
Quantifizierung von Reifenabrieb in Deutschland. Final report 19F2050A-C
30
Wicke, D. et al., ‘Projekte: Relevanz organischer Spurenstoffe im Regenwasserabfluss Berlins (OgRe)’ [Project: The
relevance of organic trace substances in Berlin stormwater runoff], organischer Spurenstoffe im Regenwasserabfluss
Berlins. Hg. v. Kompetenzzentrum Wasser Berlin. Kompetenzzentrum Wasser Berlin.
250
Baensch-Baltruschat et al.’s study defines the total release of tyre and road wear particles in Germany.
Up to 20% of tyre abrasion was estimated to enter surface waters depending on the sewer systems.
According to Baensch-Baltruschat et al., 74% ends up in the soil, which is within the range of the
studies31,32
(49% - 85%). There is a lack of data on how microplastics behave once they enter soil
and surface water and the extent to which degradation occurs.
Figure 2: Releases of microplastics from tyre wear into the environment for Germany33
4.1.2 Factors affecting the scale of the problem
This section discusses the key parameters influencing tyre wear, building on the problem drivers
identified in the figure above. A comprehensive overview of the key parameters influencing tyre
wear, according to Boulter et al.34
presented in figure below.
Figure 3: Influences on the emission factor of tyre wear
Possible influencing variables are divided into driving behaviour, tyre, road surface and vehicle
characteristics. From a technical measurement point of view, it is very difficult to evaluate the
individual influencing factors separately. The RAU project “Tire wear in the environment” has
31
Unice et al., Characterizing export of land-based microplastics to the estuary – Part II: Sensitivity analysis of an
integrated geospatial microplastic transport 250odelling assessment of tire and road wear particles, 2018
32
Hann, S., Sherrington, C., Jamieson, O., Hickman, M., Kershaw, P., Bapasola, A., & Cole, G. (2018). Investigating
options for reducing releases in the aquatic environment of microplastics emitted by (but not intentionally added in)
products. Report for DG Environment of the European Commission, 335.
33
Baensch-Baltruschat, B. et al., ‘Tyre and road wear particles – A calculation of generation, transport and release to
water and soil with special regard to German roads’, Science of the Total Environment, Vol. 752, 2021, Elsevier BV.
34
Boulter, P. G. „A Review of emission factors and models for road vehicle non-exhaust particulate matter.“ Project
Report PPR0065, Department for the Environment, Food and Rural Affairs, Scottish Executive, Welsh Assembly
Government, and the Department of Environment in Northern Ireland, 2006
251
identified the factors (Figure 4) that influence tyre wear35
. According to this, road topology and
driving behaviour have the most significant influence on tyre wear emissions. The road topology
describes the road layout and can be divided into different driving situations such as curves,
intersections, slopes and straight roads etc. Changing the topology (e.g. increasing the curve radius)
is certainly not technically feasible on a large scale. But a reduction of the permitted maximum speed
could be an agreed adjustment here. In addition, hot spots can be identified with the description of
the topology so that specific measures, such as the treatment of road runoffs or optimised road
cleaning, can be implemented. The driving behaviour can be described, for example, by acceleration
behaviour. An aggressive driving behaviour (high accelerations) leads to more tyre wear than a
moderate driving behaviour (low accelerations).
Also, the project team carried out road dust studies that underlined the influence of road topology. In
the local investigations, traffic lights, curves, gradients and straight roads were considered and
compared. In the analysis of the road dust samples, increased SBR (styrene-butadiene rubber)
contents were found at the locations of curves and traffic lights.
Figure 4: Factors influencing the formation of tyre wear and maximum influence36
Development in transport volume and mode of transport
In the OECD report37
, a reduction of PM10 emissions from road traffic by 251 approx. 40 % from
2000 to 2014 was determined (Figure 5). However, the decrease is only caused by exhaust emissions;
the emissions from non-exhaust (tyres, brakes, roads) remained constant. With further internal
combustion engine vehicles (ICEVs) optimisation and progressive replacement of ICEVs by electric
vehicles (EVs), a further reduction in exhaust emissions can be expected, and the non- exhaust
emissions will become the main source of PM10 emissions in road traffic.
35
Barjenburch, M. and Venghaus, D., ‘Präsentation: Reifenabrieb in der Umwelt’ [Presentation: Tyre abrasion in the
environment], Abschlusskonferenz "Plastik in der Umwelt" [Conference "Plastic in the environment"], 2021
(https://bmbf-plastik.de/sites/default/files/2021-05/Session-B_Venghaus_RAU.pdf).
36
Barjenburch, M. and Venghaus, D., ‘Präsentation: Reifenabrieb in der Umwelt’ [Presentation: Tyre abrasion in the
environment], Abschlusskonferenz "Plastik in der Umwelt" [Conference "Plastic in the environment"], 2021
(https://bmbf-plastik.de/sites/default/files/2021-05/Session-B_Venghaus_RAU.pdf).
37
OECD, Non-exhaust Particulate Emissions from Road Transport: An ignored environmental policy challenge, 2020,
OECD Publishing, Paris.
252
Figure 5: Annual PM emissions from road transport, EU-28, 2000-2014
A key driver of tyre wear emissions is driving mileage. It is expected that there will be a significant
increase in road transport volumes over the next decades. The JRC estimates (Figure 6) show a 16%
increase in passenger road transport between 2010 and 2030 and 30% for 2010-2050. Freight
transport is estimated to increase by 33% by 2030 and 55% by 205038
.
Figure 6: Estimated passenger and freight transport on roads in Europe39
Tyre characteristics
The influence of tyre characteristics and construction was investigated in detail by the German
Automobile Association (ADAC). Under representative conditions, car tyres from various
manufacturers were tested for emission factor (EF) and driving safety. A distinction was made
between the three tyre types: summer, winter and all-season tyres with different tyre dimensions. Due
to the limited data available, all-season tires are only listed for one dimension. Driving safety was
assessed for dry and wet road surfaces and on snow for winter tyres. The figure below shows the tyre
wear emissions in mg/vehicle km, as an average of all four vehicle tyres.
38
Alonso Raposo, M. and Ciuffo, B., The Future of Road Transport: Implications of automated, connected, low-carbon
and shared mobility, JRC116644, 2019, Publications Office of the European Union, Luxembourg.
39
Barjenburch, M. and Venghaus, D., ‘Präsentation: Reifenabrieb in der Umwelt’ [Presentation: Tyre abrasion in the
environment], Abschlusskonferenz "Plastik in der Umwelt" [Conference "Plastic in the environment"], 2021
(https://bmbf-plastik.de/sites/default/files/2021-05/Session-B_Venghaus_RAU.pdf), De.
253
Figure 7: Emission factors of different tyres40
Figure 7 shows a significant difference in EF due to the tyre dimension. As the tyre dimension
increases, it also increases the average EF. However, the scattering of the EF within a tyre dimension
is particularly interesting, where the deviations between the manufacturers are up to 100% apart. A
significant correlation between EF and driving safety was not observed in the study. Both low-
emission tyres achieved good results in driving safety and tyres with high EF, and vice versa. The
study identified tyre models in all categories that have low tyre wear and do not compromise on
safety. There are data gaps in terms of the volumes of each of these tyre models that are sold each
year as well as the distances driven, which, combined with the emission factors, influence overall
emissions from tyres. The challenge in tyre development is to move the composition (and
construction) towards higher abrasion resistance while ensuring the same driving safety.
Nevertheless, as shown in the ADAC study41
, there is a large potential for tyre manufacturers to
produce TWP emission-optimized tyres that also provide driving safety.
The ADAC study also highlighted the need to adopt good practices, such as shaving tyres (i.e.
removing fine rubber protrusions or pins that might be left over from the production process) before
putting them in the market to avoid releasing them into the environment during the first kilometres
of their use. Fine rubber pins are created when the rubber is injected into the tyre mould through fine
channels. Many manufacturers remove these residues in a further production step in order to return
the material directly to the material cycle. However, it appears that some manufacturers do not
remove the residues and directly place the tyres on the market with these rubber residues. However,
it is highly uncertain exactly what proportion of tyres placed on the market include these rubber pins.
They seem to be more commonplace for budget tyres than more premium brands and potentially
more frequent for winter tyres where the injection channels are necessary due to the fine tread
structure compared to summer tyres. Whilst it is very challenging to quantify the exact contribution
that they may make to overall tyre wear emissions, some initial estimations appear to indicate that
their overall impact is expected to be very low, less than 0.5% and potentially closer to 0.1% of the
total wear from a tyre42
.
40
ADAC, ‘Tyre wear particles in the environment’ / 31940 RMU
41
ADAC, ‘Tyre wear particles in the environment’ / 31940 RMU
42
Personal communication with the JRC, May 2022.
254
In materials science and R&D, innovations are also reported, such as the use of dandelions43
or
moss44
. One possibility would be using innovative additives such as nanotubes (TUBALL45
), which
should be effective for improved performance. However, the effect on tyre wear emission is unclear.
A test method covering tyres for both light and heavy-duty vehicles is currently being developed by
the European Commission through a study led by IDIADA. The study is expected to propose and
validate appropriate test methods, evaluate the performance of current tyres in Europe with these
methods and perform a cost-benefit analysis of possible tyre abrasion limits by third quarter of 2022.
The results of the project will allow the inclusion in the future of abrasion limits in Euro 7 emission
standards for motor vehicles and their components (such as tyres) adopted in November 2022. The
UNECE WP.29 established a joint Task Force between its Working Party on Noise and tyres (GRBP)
and its Working Party on Pollution and Energy (GRPE) in February 2022 to develop the tyre abrasion
test method and a Global Technical Regulation. This is expected by 2024.
In general, a standardized test method and limit should consider the physical properties and chemical
composition of the emitted tyre wear. The physical characteristics include the emitted particle mass,
number and size distribution. It is essential to prevent an increase in the potentially toxic particulate
matter fraction (especially PM2.5).46
A limit value based only on mass may lead to less tyre wear
being emitted in general, but it does not reflect a shift from large/few particles to small/many
particles. Furthermore, it is assumed that larger particles are better retained during emission
treatment. However, the consideration of chemical composition is also highly relevant from the point
of view of environmental protection. Until now, tyre manufacturers have not been required to disclose
the components used. In the Emission Analytics/PEW report47
, 100 different tyres available on the
European market were analysed for tyre wear rate and chemical composition. More than 400 organic
components were found in an average tyre, with 49% of the organic mass consisting of often-
carcinogenic aromatic and polycyclic hydrocarbons. In this study, there is a factor of 4 between the
highest and lowest emitting tyre manufacturers. In order to regulate or prevent the use of
environmentally harmful substances, disclosure of the ingredients by the tyre manufacturers would
be recommended.
Tyres are also sold with only part of the vent spews shaved off: sometimes, even those on the tread
are left there. Vent spews, also known as “tyre hairs” or “Tire hairs” (or vent sprue, nibs, or nippers),
are the result of excess rubber expelled through air channels in the tyre mould (needed because of the
intense heat and pressure used during curing).
43
Continental, ‘Erste Versuchsreifen aus Löwenzahn-Kautschuk’ [First test tyres made from dandelion rubber]
(https://www.continental-reifen.de/specialty/unternehmen/sustainability/taraxagum/continental-tires-dandelion-
taraxagum), De.
44
Goodyear, ‘Der internationale Reifenhersteller Goodyear stellt heute auf dem Autosalon in Genf seine jüngste
Mobilitätsvision für die Städte von morgen vor: den neuen Konzeptreifen „Oxygene“, der dazu beiträgt, dass urbane
Mobilität in Zukunft sauberer, komfortabler, sicherer und nachhaltiger wird’ Kautschuk’ [International tire
manufacturer Goodyear is presenting its latest mobility vision for the cities of tomorrow at the Geneva Motor Show
today: the new concept tyre "Oxygene" will help make urban mobility cleaner, more comfortable, safer and more
sustainable in the future], 2018 (https://www.goodyear.eu/de_de/consumer/why-goodyear/geneva-motor-show.html),
De.
45
OCSiAl, ‘TUBALL: Revolutionary Carbon Nanotubes for the Tyre Industry’, 2017 (https://ocsial.com/de/news/-
tuball-revolutionary-carbon-nanotubes-for-the-tyre-industry-/).
46
ETRMA (in Hann et al. 2018)
47
Emission Analytics / PEW report (2022) - Research report - Tire chemical composition and wear emissions
255
Vehicle characteristics
A shift of passenger vehicles from internal combustion engine vehicles (ICEVs) to electric vehicles
(EVs) is assumed48
, whereby the influence of EVs on tyre wear emissions is controversially
discussed. The absolute vehicle weight of an EV may increase when directly comparing the same
vehicle model available as ICEVs and EVs due to the weight of the batteries. In this case, tyre wear
emissions will also increase. It is expected that future development of the batteries (higher energy
density for the same weight or volume) might decrease this weight difference
Another factor to consider is the engine power or drive torque. EVs bring full torque to the road
already at start-up. Although efficient traction control (anti-slip control) is possible, there is still a
higher point-to-point power transfer. The negative influence on tyre wear emissions due to engine
power has been studied, among others, in Gebbe et al49
. In the OECD report50
, the focus is on airborne
non-exhaust particulates, with EVs classified into light weight (driving range up to 160 km) and
heavy weight (driving up to 480 km or more). The OECD report’s assessment shows:
• Light weight: 11-13% less non-exhaust PM2.5 and 18-19% less PM10 than ICEVs;
• Heavy weight: reduce PM10 by only 4-7% and increase PM2.5 by 3-8% relative to
conventional vehicles.
There is a trend towards heavier vehicles and with bigger wheels and tyres, which has a negative
effect on tyre wear emissions. A market share analysis by the International Council on Clean
Transportation (ICCT)51
shows the significant development of demand for Sport Utility Vehicles
(SUV) in Europe over the last 20 years. Since EV variants are also offered for these SUV models, a
decline in the trend is not expected.
48
Venghaus et al. 2021 RAU - "Reifenabrieb in der Umwelt" Abschlusskonferenz "Plastik in der Umwelt"
(20./21.04.2021)
49
Gebbe et al., ‘Quantifizierung des Reifenabriebs von Kraftfahrzeugen in Berlin’ [Quantification of tyre wear of motor
vehicles in Berlin], Technische Universität Berlin [Technical University of Berlin], 1997, De.
50
OECD, ‘Policies to reduce microplastics pollution: Focus on textiles and tyres’, 2021 (https://www.oecd-
ilibrary.org/environment/policies-to-reduce-microplastics-pollution-in-water_7ec7e5ef-en).
51
The International Council on Clean Transportation, ‘European vehicle market statistics: Pocketbook 2021/22’, 2021
(https://theicct.org/wp-content/uploads/2021/12/ICCT-EU-Pocketbook-2021-Web-Dec21.pdf). Diaz et al. 2020
European vehicle market statistics 2020/21
256
Figure 8: Passenger car registrations by vehicle segment52
Road surface characteristics
Although porous asphalt can have a negative impact on the tyre wear emission rate, porous asphalt
is seen as a positive influence due to its retaining effect.53
In order for the retaining to be effective,
regular cleaning of the road surface is needed. The use of this asphalt is currently planned primarily
for motorways. The use of rubber asphalt also needs to be considered. Although the addition of tyre
material results in a reduction potential of CO2 emissions and noise and contributes to the recycling
process of waste tyres, it also improves the temperature properties and fatigue resistance of the
asphalt.54
Nevertheless, it must be critically examined whether additional tyre material from the
asphalt is emitted into the environment during the use phase.55
Collection and treatment of road run-off is a challenge, especially in urban areas. Due to the high
investment costs, no significant use is assumed without regulatory intervention. There is also a
crossover with some elements of the Urban Wastewater Treatment Directive.
Vehicle operation
Speed limits (motorways) are under discussion because of their impact on exhaust emissions.
Germany is the only country in the EU27 without a general speed limit. Whether a speed limit will
be introduced is currently the subject of political discussions. According to the UBA, a speed limit
could reduce CO2 emissions by 6.7% at 120 km/h and 13.8% at 100 km/h.
In several Member States, there is a growing tendency to limit speed in urban areas for both safety
and environmental reasons (in particular, for air quality and climate change reasons). For example,
52
Ibid.
53
European Tyre and Road Wear Particles (TRWP) Platform, ‘Way Forward Report’, 2019 (https://www.etrma.org/wp-
content/uploads/2019/10/20200330-FINAL-Way-Forward-Report.pdf).
54
Wang, Q.Z. et al., ‘Waste Tire Recycling Assessment: Road Application Potential and Carbon Emissions
Reduction Analysis of Crumb Rubber Modified Asphalt in China’, Journal of Cleaner Production, Vol. 249, 2020,
Elsevier BV.
55
Bhashyam, S.S. et al., ‚Microplastics in the marine environment sources, impacts and recommendations‘,
Research@THEA, 2021.
257
Spain has introduced a 30 km/h speed limit in urban areas for roads with one lane in each direction.
Similarly, Paris implemented a general speed limit of 30 km/h in 2021.
The significance of an urban speed limit of 30km/h in Germany and its federal states in terms of tyre
abrasion emissions has been investigated by the TyreWearMapping project56
. With the physical
model, a reduction of about 50% was calculated for both passenger cars and heavy-duty vehicles,
considering 50 km/h as the maximum permitted speed in urban areas.57
Figure 9: Impact – urban speed limit 30 km/h
An increase in the proportion of autonomously driving vehicles could have a reducing effect on tyre
wear emissions. Autonomous driving makes it possible to optimise the flow of traffic and thus reduce
braking and starting manoeuvres and moderate the driving style, for example.58
Moreover,
autonomous driving is expected to have vehicles move more smoothly and calmly. The development
of the share of fully autonomous driving vehicles, for which the impact is most effective, in the total
number of autonomous vehicles is shown in the following figure.59
56
German Federal Ministry of Traffic and Digital Infrastructure (BMVI), ‘Schlussbericht 19F2050A-C:
TyreWearMapping: Reifenabrief – ein unterschätztes Umweltproblem?’ [Final report 19F2050A-C:
TyreWearMapping: Tyre abrasion – an underestimated environmental problem?], 2021
(https://www.umsicht.fraunhofer.de/content/dam/umsicht/de/dokumente/kompetenz/prozesse/tyrewearmapping-
schlussbericht.pdf), De.
57
German Federal Ministry of Traffic and Digital Infrastructure (BMVI), ‘Schlussbericht 19F2050A-C:
TyreWearMapping: Reifenabrief – ein unterschätztes Umweltproblem?’ [Final report 19F2050A-C:
TyreWearMapping: Tyre abrasion – an underestimated environmental problem?], 2021
(https://www.umsicht.fraunhofer.de/content/dam/umsicht/de/dokumente/kompetenz/prozesse/tyrewearmapping-
schlussbericht.pdf), De.
58
Center of Automotive Management 2021 https://auto-institut.de/automotiveinnovations/emobility/elektromobilitaet-
in-europa/
59
Center of Automotive Management 2021 https://auto-institut.de/automotiveinnovations/emobility/elektromobilitaet-
in-europa/
258
Figure 10: Range of sales projections for AVs (fully automated) until 2055 (as% of AV of total vehicles
sold) (sc=scenario)
Other factors
On-board information on driving behaviour or awareness campaigns (e.g. “deadly dust”60
initiated
by the tyre wear collective and how&how) can positively influence driving behaviour or even reduce
vehicle kilometres in general. Furthermore, on board tyre pressure monitoring systems (TPMS),
which warn drivers when tyre pressure is dangerously low, can also help to reduce microplastic
emissions as tyre pressure is an important factor in abrasion rates. Such systems are currently
calibrated from a safety perspective but could be adapted to also optimise for tyre wear.
The alignment of the wheels can also play an important role in tyre wear as well as tyre lifetime.
Directive 2014/45/EU on periodic roadworthiness tests61
sets minimum requirements (and
frequencies) for periodic testing of road vehicles which includes specific technical elements that are
to be covered. These include wheels and their alignment. However, the requirements for checks on
wheel alignment are indicated to be “…not considered essential in a roadworthiness test”, so may
not be applied uniformly across the EU.
4.2 Problem definition for textiles
Most scientific papers discuss the unintentional release of microplastics from textiles used in clothing
with a focus on the emission of microplastics during the use phase and, more specifically, on textile
washing. Due to the lack of data on microplastic emissions from polycotton (used in household and
professional textiles/furnishing), and the amount of polyester contained in the polycotton blend, no
estimation could be made. According to the first approximations made by RDC Environment,
microplastic emissions from professional textiles would represent less than 5% of the emissions from
clothing. The focus is, therefore, on the microplastic emissions of clothing from households.
It is known that synthetic textiles are prone to release microplastics in water during washing because
of abrasion. The water is then treated in WWTP. According to the Swedish Environmental Protection
Agency, most of the microplastic (around 98%) is removed from water in WWTP and retained in
60
How & How and The Tyre Collective, ‘Deadly Dust Campaign, 2020 (https://how.studio/work/deadly-dust).
61
European Parliament and Council of the European Union, Directive 2014/45/EU on periodic roadworthiness tests for
motor vehicles and their trailers and repealing Directive 2009/40/EC, OJ L 127, 29.4.2014, pp. 51.
259
sewage sludge62
. About half of the sewage sludge is then spread on agricultural land63
, used in soil
production, or incinerated. However, microplastic releases can occur during the entire lifetime of
textiles, including production, wearing, washing, drying and end-of-life. Consequently, the fibres
may not only enter the environment via WWTP discharges but also via airborne emissions, landfill
leakages, etc. Fibrous microplastics have been found in freshwater, seas, soils, air and remote ice and
polar regions64
. The figure below presents the different pathways followed by unintentionally
released microplastics from textiles.
Figure 11: Emission pathways for secondary microplastics from synthetic textile in the air, water and
soil (ETC/WMGE, 2021)
4.2.1 Factors affecting the scale of the problem
Three general problem drivers impact the unintentional release of microplastics from textiles:
• Increase in production and use of synthetic textiles;
• Regulatory failure as the microplastic release from textiles is an externality;
• Lack of knowledge and practice (for consumers and producers).
These general problem drivers can be divided into several specific problem drivers, discussed further.
Increase in production and use of synthetic textiles
Since microplastics from textiles are emitted during production as well as during use, an increase in
production necessarily implies a bigger release of microplastics from textiles. More intensive use of
textiles, such as an increasing washing frequency, will also lead to more microplastic emissions.
Problem driver 1: Increase in demand for textiles
Between 1996 and 2012, there was a 40% growth in the number of clothes purchased per person in
the EU65
. This trend is expected to increase in the future, as at a global level, the consumption of
62
Magnusson et al. (2017) Swedish sources and pathways for microplastics to the marine environment, Report for
Swedish Environmental Protection Agency.
63
When sewage sludges are applied to soil, the microplastics end up back in the environment and can be washed away
by rain. Some sludge is also incinerated.
64
Zhang, Y-Q., et al., ‘Microplastics from textile origin – emission and reduction measures’, Green Chemistry, No. 15,
2021.
65
ETC/WMGE, ‘Textiles and the environment in a circular economy’, 2019 (https://www.eionet.europa.eu/etcs/etc-
wmge/products/etc-wmge-reports/textiles-and-the-environment-in-a-circular-economy/).
260
clothing and footwear is expected to increase by 63% between 2019 and 2030. This increase in
textiles consumption leads to an increase in textiles production, thus increasing microplastics
emissions from textiles (both from production and in use). In practice, this increase in consumption
is accompanied by a decrease in the number of uses per piece66,67
. A higher renewal rate also means
more textiles being thrown away and more emissions at the end-of-life stage, especially if the textiles
are recycled (shredding can cause a lot of microplastic emissions68
).
Several factors and drivers explain the increase in textile consumption, including production trends
based on low-cost and fast fashion, a respective decrease in the price of clothing, the increasing
affluence of consumers, and further trade liberalisation. Beyond the increase in textiles consumption,
the growing population in Europe also implies an increase in the use of textiles. This will lead to
more microplastic emissions in the air (because of wearing and drying) and water (because more
washing cycles will be performed). According to OECD statistics, the EU population is expected to
increase by 1.3% by 203069
. The European Commission has recently adopted the EU strategy for
sustainable textiles70
. As summarised by Interreg Europe71
, “the new strategy sets out the vision and
concrete actions to ensure that by 2030 textile products placed on the EU market are long-lived and
recyclable, made as much as possible of recycled fibres, free of hazardous substances and produced
in respect of social rights and the environment. Moreover, consumers will benefit longer from high-
quality textiles -fast fashion should be out of fashion- and economically profitable re-use and repair
services should be widely available.” Regarding microplastics, the European Commission plans to
address the unintentional release into the environment by a set of prevention and reduction measures
at the different life-cycle stages.
Problem driver 2: Increase in use of plastic as raw materials for textiles
The figure below shows the evolution of the split of world fibre production72
between 1980 and 2030.
Synthetic fibres represent 75% of total fibres in 2020, a share that will reach 85% in 2030 (with 70%
for polyester alone).
66
Deutsche Gesellschaft für Internationale Zusammenarbeit (GIZ) [German Agency for International Cooperation],
‘Study for the German Federal Ministry for Economic Cooperation and Development (BMZ): Circular Economy in
the Textile Sector’, 2019
(https://www.adelphi.de/de/system/files/mediathek/bilder/GIZ_Studie_Kreislaufwirtschaft_Textilsektor_2019_final
.pdf).
67
European Environment Agency (EEA) (2019) Textiles and the environment in a circular economy
68
RDC Environment assessment based on experts’ estimates literature review
69
OECD, ‘Population projections: evolution forecasts of EU (28 countries) population between 2021 and 2030’, 2022
(https://stats.oecd.org/Index.aspx?DataSetCode=POPPROJ#).
70
European Commission, Commission communication - EU Strategy for Sustainable and Circular Textiles;
COM(2022)141 final, 2022.
71
Interreg Europe, ‘New EU Strategy for sustainable and circular textiles’, 2022 (https://www.interregeurope.eu/news-
and-events/news/new-eu-strategy-for-sustainable-and-circular-
textiles#:~:text=The%20new%20strategy%20sets%20out,social%20rights%20and%20the%20environment).
72
Yang Qin, M. (2014). Global fibres overview. Tecon OrbiChem: Synthetic Fibres Raw Materials Committee Meeting
at APIC 2014.
261
Figure 12: World fibre production per fibre between 1980 and 2030
According to Fibre2Fashion73
, the increase in the use of synthetic fibres will probably continue for
the next few decades because of the relatively low cost of synthetic fibres compared to natural fibres
and the availability of raw materials. Viscose staple fibres are an alternative to cotton fibres because
of their physiological performance. Cellulose fibres have specific properties that make them difficult
to substitute with petroleum-based synthetic fibres. Given the limited production of cotton fibres, the
share of viscose is likely to increase to cover the increase in textile consumption and the increase in
population. In terms of environmental impact, the CO2 equivalent of producing viscose staple fibre
is similar to that of cotton fibre. However, the impact on ecosystem diversity is better in the case of
cotton, see next figure.
73
Fibre2Fashion, ‘Man-made fibres driving growth’, 2017 (https://www.fibre2fashion.com/industry-article/7895/man-
made-fibres-driving-growth).
262
Figure 13: Environmental impact of fibre production processes74
Problem driver 3: Increase in textile washing frequency
According to AISE, the average amount of washing cycles in the EU is staying relatively stable at
around 3.5 washes a week per household (a slight decrease was observed between 2008 and 2017,
followed by a slight increase between 2017 and 2020), as well as the average load, which remains
around 80%. However, the capacity of the average washing machine sold in the EU has been
increasing: while in 2004, 97% of washing machines sold in the EU had a capacity of less than 6 kg,
in 2014, 60% of them had a capacity of 7 kg or more. This means that there is an average increase in
the quantity of textiles washed per washing cycle and thus an increase in textile washing frequency.
Regulatory failure as the microplastic release from textiles is an externality
Problem driver 1: No eco-design requirements on the unintended release of microplastics
No eco-design requirement is currently defined at the production level to reduce microplastic
emissions from textiles. Furthermore, no document or information has been developed to guide
producers on this matter, which is not tackled in the main guides. For instance, the BREF (Best
Available Techniques Reference Document) for the Textiles Industry developed under the Industrial
Emissions Directive groups microplastic emissions with TSS (Total Suspended Solids), and does not
provide specific solution or guidance for reducing microplastic emissions during the production
phase75
. The Textiles BREF mentions that there is currently a lack of information about microplastic
emissions76
.
The implementation of eco-design criteria is limited by knowledge gaps and the lack of standardised
measurement methods to quantify microplastic emissions. These methods are currently under
development and could be used in the future to set a threshold on microplastics released from textiles.
74
JRC, Environmental Improvement Potential of textiles (IMPRO Textiles), January 2014.
(https://publications.jrc.ec.europa.eu/repository/handle/JRC85895)
75
JRC, ‘Best available techniques (BAT) Reference Document for the Textiles Industry’, 2023
(https://eippcb.jrc.ec.europa.eu/sites/default/files/2023-01/TXT_BREF_2023_for_publishing%20ISSN%201831-
9424_final_1_revised.pdf).
76
Textiles BREF ”In conclusion, at the time of drafting this document, there was little information available as to
the emissions of microplastics to water from textile production facilities, in terms of emissions actually
monitored and therefore in terms of the significance of these emissions.”
263
However, as shown in figure below, nearly 80% of textiles consumed in Europe are imported and
produced outside of Europe. Regulation at the producer level would then require developing an
international approach and commitment. In addition, to effectively enforce ecodesign measures and
avoid barriers to free trade inside the EU as a result of the implementation of national measures,
ecodesign measures should be implemented at the EU level. The European Commission proposed a
new Ecodesign for Sustainable Products Regulation (ESPR) in 2022. This framework aims to set
ecodesign requirements for specific product groups to significantly improve their circularity, energy
performance and other environmental sustainability aspects. Textiles are identified as a priority in
this framework.77
Figure 14: Overview of the import, export, production and consumption flows of textile products, EU,
2017, kg per person78
Problem driver 2: No legal requirements to prewash textiles
High microplastic emissions occur during pre-washing due to loose fibres resulting from the
manufacturing process. No prewashing step is required at the producer level before selling the
textiles. A pre-wash step could be added during production to specifically remove microplastics and
must be associated with the obligation of having a proper wastewater treatment plant. This could also
be an ecodesign requirement. Currently, pre-washing can be done by consumers to eliminate certain
chemical residues before wearing clothes.79
With the goal of eliminating pre-washing for consumers,
the pre-wash should cover both functions: removing microplastics and removing chemical residues.
Problem driver 3: No legal requirements for washing machines and tumble dryers to reduce the
release
In France, a law was approved in February 2020 mandating that, as of January 2025, all washing
machines sold in France be equipped with a filter for synthetic microfibres. An amendment to this
77
European Commission, Commission Proposal for a Regulation establishing a framework for setting eco-design
requirements for sustainable products and repealing Directive 2009/125/EC, COM(2022)142 final, 2022.
78
ETC/WMGE, ‘Textiles and the environment in a circular economy’, 2019 (https://www.eionet.europa.eu/etcs/etc-
wmge/products/etc-wmge-reports/textiles-and-the-environment-in-a-circular-economy/).
79
Time, ‘Why You Should Always Wash New Clothes Before Wearing Them’, 2019 (https://time.com/5631818/wash-
new-clothes/).
264
law was adopted in June 2021, enabling the implementation of other technologies80
(alternative to
filters) such as capturing bags or absorbing balls to reduce microplastic emissions from washing.81
The use of filters in washing machines was also studied in Sweden, but there does not appear to be
any such initiative in other EU countries.82
Ecodesign requirement on washing machines and tumble
dyers could also facilitate the use of filters. However, particular attention should be paid to how
consumers handle the filters. If they are eventually washed or rinsed in a sink, there will be no
decrease in microplastic release.
Problem driver 4: Very costly to invest in end-of-pipe wastewater treatment (including preventing
microplastics in sludge)
Most wastewater treatment plants contribute to reducing microplastic concentration in water
efficiently. However, decreasing the amount of microplastics in sludge is more challenging. Almost
half of this sludge is usually spread on soil, which leads to microplastic releases into the soil.
Implementing an additional treatment step to treat sludge would be costly, and there do not yet appear
to be commercially available techniques to do so effectively.
Lack of knowledge and practice
There is a lack of knowledge and practice, both at the consumer and producer level. At the consumer
level, the awareness is low, and there is no communication or guidance on how to reduce releases,
while at the producer level, there is a lack of knowledge on eco-design measures and how to improve
manufacturing processes in order to reduce emissions.
Problem driver 1: No or limited awareness among consumers
There is very limited awareness of the microplastics issue among consumers. According to a survey
in the US in July 2020, 57% of the population had never heard of microplastics before. It means that
the aware public represents around 40% of the population. About 50% of those who do know about
microplastics have learned about them in the past year83
. According to this study, around 30% of US
consumers think microplastics need to be addressed urgently.
Problem driver 2: No guidance to consumers on how to avoid or reduce unintentional releases
Information on how to reduce microplastic emissions from household washing machines is available
online for consumers already aware of the issue. Several websites list the different existing options
available for consumers (laundry bags, balls or filters, and general information on washing).84,85
However, this information is directed to an aware public (representing around 40% of the population,
80
Alternatives to the filters.
81
Sénat français [French Senate], Amendement n°2143 au projet de loi relatif à la lutte contre le dérèglement climatique
[Amendment n°2143 to draft legislation on the fight against climate change], 10.06.2021
(http://www.senat.fr/amendements/2020-2021/667/Amdt_2143.html), Fr.
82
Australia also announced its intention to “Work with the textile and whitegoods sectors on an industry-led phase-in
of microfibre filters on new residential and commercial washing machines by 1 July 2030”.
83
The Nature Conservancy and Bain & Company, ‘Toward eliminating pre-consumer emissions of microplastics from
the textile industry’, 2021
(https://www.bain.com/globalassets/noindex/2021/tnc_bain_white_paper_eliminating_microplastics.pdf).
84
The New York Times, ‘Your Laundry Sheds Harmful Microfibers. Here’s What You Can Do About It’, 2021
(https://www.nytimes.com/wirecutter/blog/reduce-laundry-microfiber-pollution/).
85
Irish Examiner, ‘Green washing: How to reduce microplastic in your laundry’, 2022
(https://www.irishexaminer.com/property/homeandgardens/arid-40951550.html).
265
see section above). At the same time, there is no or limited communication on this issue to the general
public. If filters become mandatory or more widely used, particular attention should be paid to how
consumers handle the filters or other devices to avoid microplastic releases. If they are eventually
washed or rinsed in a sink, there will be no effect on overall microplastic emissions.
Problem driver 3: Lack of knowledge on eco-design measures and how to improve manufacturing
processes in order to reduce emissions among producers
At the producer level, no or few technical solutions are defined. The implementation of eco-design
criteria is limited by knowledge gaps and sometimes contradictions in the literature, as well as the
lack of standardised measurement methods to quantify and compare microplastic emissions. At this
stage, it is hard for producers to efficiently change the design of their textiles to reduce microplastic
emissions.86
Producer voluntary initiatives reported so far are limited in terms of market shares; some examples
of initiatives include the following:
• TextileMission project87
: project carried out with several partners such as Adidas AG (retailer
of sporting goods) and VAUDE Sport GmbH & Co (retailer of mountain equipment). The
main work areas are the microplastic output of marketable textiles, retention capacity of
different cleaning or purification steps in wastewater treatment plants, sustainability aspects
of alternative materials, biodegradable materials and new cutting and processing possibilities,
and production and testing of prototypes.
• Cross Industry Agreement (CIA)88
: voluntary collaboration for the prevention of microplastic
release into the aquatic environment during the washing of synthetic textiles of five European
industry associations representing the global value chain of garments and their associated
maintenance, namely AISE, CIRFS, EOG, EURATEX and FESI
• Patagonia (retailer of outdoor equipment and clothing)89
: the company initiated two studies.
The first study focused on measuring the amount of microfibers that come off the products in
the wash (and comparing them to lower-quality items). The objective of the second study is
to understand better the fibre and fabric characteristics that lead to microfiber release and to
develop a rapid test method to assess the potential of fabrics to shed during laundering. Both
studies are conducted to enable the research and development of new materials.
4.3 Problem definition for paints
Generally, paints are made from the following components: pigments (absent in the case of
varnishes), solvents (organic solvents and/or water), various additives and a binder. With few
exceptions (e.g., pure mineral paint, which contains inorganic binders), the binder is a polymer, most
commonly a synthetic resin, which binds all the other ingredients together and influences durability,
and flexibility, and it is responsible for the general mechanical properties of the film (Bierwagen et
al., 2017). Common binders are alkyls and epoxies, but paint might also contain polyurethanes,
polyesters, polyacrylates and polystyrenes (C. Gaylarde et al. 2021). After the paint has been applied,
86
Opting for natural fibres would stop microplastics emissions but would also increase other environmental impacts
(CO2 emissions, land use, etc.).
87
TextileMission, Project: Microplastics of Textile Origin - A Holistic View: Optimized Processes and Materials,
Material Flows and Environmental Behavior, 2017-2021 (https://bmbf-plastik.de/en/joint-project/textilemission).
88
Euratex, ‘Cross Industry Agreement’ (https://euratex.eu/cia/).
89
Patagonia, ‘An update on microfiber pollution’, 2018 (https://www.patagonia.com/stories/an-update-on-microfiber-
pollution/story-31370.html).
266
the solvents (and/or water) evaporate, leaving binder, additives and pigments behind, forming the
solid content.
The majority of paint formulations do not contain microbeads as an ingredient90
; however, due to
their resin content, paint particles (dried together with additives or in liquid form as polymers) are
considered as microplastic91
. Out of the 52 Mt of paint produced globally in 2019, 19.5 Mt are
synthetic polymers92
, representing 5% of total world polymer production (368 Mt - PlasticsEurope,
2020). Paint has, in fact, a high polymer content - on average 37% - and can be found on a wide range
of objects and infrastructures used in our society: cars, boats, indoor walls, buildings, and bridges,
among others. It is not without reason, as paint delivers value by protecting objects from
environmental degradation and corrosion. Thus, by increasing the lifetime of objects, paint eliminates
the need for frequent replacement or maintenance that would otherwise be necessary, with the
associated environmental impacts. But since paint is often applied on exterior surfaces to protect
them from wear and tear and corrosion, it should come as no surprise that paint lost during the
application, wear and tear, or removal will eventually find its way to the environment.
Many studies have already pointed out that paint particles are part of the increasingly important
microplastic source in our oceans. Ingredients of the paint binders such as polyurethanes, polyesters,
polyacrylates, polystyrenes, alkyls and epoxies have been increasingly identified in environmental
samples all over the globe93
,94
,95
,96
,97
,98
, highlighting the importance of better assessing the
contribution of paint to plastic pollution.
90
Microbeads are intentional added microplastics which are covered by the REACH restriction: European Chemicals
Agency, Bakcground Document to the Opinion on the Annex XV report proposing restrictions on intentionally added
microplastics, 2020 (https://echa.europa.eu/documents/10162/b56c6c7e-02fb-68a4-da69-0bcbd504212b).
91
Verschoor, A. et al., ‘Emission of microplastics and potential mitigation measures: Abrasive cleaning agents, paints
and tyre wear’, Dutch National Institue for Public Health and the Environment, 2016
(https://rivm.openrepository.com/bitstream/handle/10029/617930/2016-0026.pdf?sequence=3)
92
Market research from MarketsandMarkets Research Private Limited
93
Turner, 2021, Paint particles in the marine environment: An overlooked component of microplastics,
https://doi.org/10.1016/j.wroa.2021.100110)
94
Dibke et al. Microplastic Mass Concentrations and Distribution in German Bight Waters by Pyrolysis–Gas
Chromatography–Mass Spectrometry/Thermochemolysis Reveal Potential Impact of Marine Coatings: Do Ships
Leave Skid Marks? https://doi.org/10.1021/acs.est.0c04522
95
Schell, T., Hurley, R., Buenaventura, N. T., Mauri, P. V., Nizzetto, L., Rico, A., & Vighi, M. (2022). Fate of
microplastics in agricultural soils amended with sewage sludge: Is surface water runoff a relevant environmental
pathway?. Environmental Pollution, 293, 118520;
96
Turner, A., Ostle, C., & Wootton, M. (2022). Occurrence and chemical characteristics of microplastic paint flakes in
the North Atlantic Ocean. Science of The Total Environment, 806, 150375;
97
Cardozo, A.L.P., Farias, E.G.G., Rodrigues-Filho, J.L., Moteiro, I.B., Scandolo, T.M., Dantas, D.V. (2018). Feeding
ecology and ingestion of plastic fragments by Priacanthus arenatus: What's the fisheries contribution to the problem?
marine Pollution Bulletin 130: 19-27;
98
Herrera, A., Ŝtindlová, A., Martínez, I,. Rapp, J., Romero-Kutzner, V., Samper, M.D., Montoto, T., Aguiar-González,
B., Packard, T., Gómez, M. (2019). Microplastic ingestion by Atlantic chub mackerel (Scomber colias) in the Canary
Islands coast. Marine Pollution Bulletin 139: 127-135)
267
Figure 15: Different ways of microplastic release from paints
From the EA-Environmental Action analysis published in January 202299
, a large part of the paint is
mismanaged in the EU (40%) and thus leaks to the environment. The majority (63%) of this leakage
occurs in the form of microplastics emitted during paint application, maintenance and wear and tear.
The remaining 37% of the leakage (mostly microplastics) stems from unused paint or is associated
with the end-of-life of the painted objects. The leakage occurs predominantly on land (63%) and in
oceans and waterways.
If one looks in more detail, this 37% of the global leakage is the result of different forms of solid
waste mismanagement and the leakage occurring directly in the ocean (e.g., through wear and tear or
maintenance of commercial ships or offshore rigs), the latter accounting for 18% of total leakage.
Paint leakage is geographically ubiquitous, with leakage rates ranging from 22% in high-income
North America to 50% in low and middle-income Europe. This means, for instance, that half of the
paint applied in European low-income countries will eventually leak into the environment in one way
or another. Because of its larger population, the highest contribution to total leakage in absolute terms
comes from the Asia Pacific region (54% of total leakage).
The six paint sectors analysed in the EA’s global study are architectural, marine, automotive, road
markings, industrial wood and general industrial. They contribute to the total leakage with individual
leakage rates ranging from 28% (automotive sector) to 74% (road markings sector). The architectural
sector is the largest contributor to the total leakage (48%), and the road markings sector is the smallest
contributor (2%). In terms of leakage specifically to ocean and waterways, the contribution from
architectural paint is similar to that of marine or general industrial paints. EA-Environmental Action’s
report100
shows that the paint industry is potentially the sector with the highest contribution to
microplastics leakage to ocean & waterways (1.9 Mt/year), higher than tyre dust, synthetic textile
99
Paruta, P., Boucher, J., Pucino, M. (2022). Plastic Paints the Environment, EA- Environmental Action, ISBN 978-2-
8399-3494-7
100
Paruta, P., Boucher, J., Pucino, M. (2022). Plastic Paints the Environment, EA- Environmental Action, ISBN 978-2-
8399-3494-7
A pplicat ion Removal
Leakage
Wear&Tear
Unused
EndOfLife
Design credits to: Martha Perea Palacios marpereapalacios@orotaller.com
268
and other known sources combined (less than 1.5 Mt/year in total101,102
. This finding does not imply
that these other sources are not part of the problem, as the paint leakage identified in the EA study
only adds up to the leakage from these other sources, which was already high in absolute value. To
understand the reasons behind this change in the methodology, one needs to look at the previous
research focusing on other sources of microplastics. Some of the previous studies on plastic leakage
have included paint but under “other sources” of primary microplastic release in the environment.
The contribution of paints to the total microplastic leakage was estimated to range from 9.6% to 21%
in different studies (see Table 7). Although none of the studies takes into account all paint sectors
and all geographies, this alone is not enough to explain the difference with the EA’s assessment.
The root differences are rather that not all loss types are accounted for in previous studies, and that
wear and tear and removal rates are very different. For example, the Eunomia report103
excludes all
losses due to overspray. Furthermore, most studies base their wear and tear and removal rates on an
OECD report104
or on values provided by CEPE (the association representing the interests of the
coatings sector at European level)105
. For instance, Eunomia estimates that only 0.5% of the
antifouling marine paint will be lost to the environment due to wear and tear during the lifetime of
the boat, even when most antifouling paint is meant to “erode” or “peel off” in order to prevent
fouling on the boat hull. The EA study assumes that within 4 years, 35% of the antifouling paint will
be lost and thus is an important source of microplastics release. This is a conservative estimate, as
according to a paper by paint manufacturer International Paint Ltd.106
, CEPE considers all the biocide
contained in the antifouling paint to be released during the antifouling coating lifetime (100% loss
rate). The same paper claims that the actual emission is a factor 2.9 smaller (34% loss rate).
101
Boucher, J., & Friot, D. (2017). Primary microplastics in the oceans: a global evaluation of sources (Vol. 10). Gland,
Switzerland: IUCN
102
Lau, W. W., Shiran, Y., Bailey, R. M., Cook, E., Stuchtey, M. R., Koskella, J., & Palardy, J. E. (2020). Evaluating
scenarios toward zero plastic pollution. Science, 369(6510), 1455-1461
103
Hann, S., Sherrington, C., Jamieson, O., Hickman, M., Kershaw, P., Bapasola, A., & Cole, G. (2018). Investigating
options for reducing releases in the aquatic environment of microplastics emitted by (but not intentionally added in)
products. Report for DG Environment of the European Commission, 335.
104
OECD (2009). Emission scenario document on coating industry (paints, lacquers and varnishes). OECD Health and
Safety Publications, Series on Emission Scenario Documents, 22: 201.
105
CEPE, 2021. About us. Accessed on 19/11/2021. https://cepe.org/about-us/who-we-are/
106
Finnie (2006) Improved estimates of environmental copper release rates from antifouling products. Biofouling : The
Journal of Bioadhesion and Biofilm Research
269
Table 7: Comparison of studies on plastic leakage from paints
4.4 Problem definition for detergent capsules
Industry claims that detergent capsules have revolutionised the world of household care and
professional cleaning and hygiene industry within the last ten years. They afford several key
advantages by being more convenient for consumers (easy and correct dosing), avoiding skin contact
with active ingredients like detergent, salt and rinse aid and optimising resource use and packaging.
The cornerstone of these detergent capsules relies on using a water-soluble plastic film that must be
dissolved during the washing cycle. The water-soluble plastic films are mainly composed of
polyvinyl alcohol (PVOH). The typical thickness for these water-soluble plastics is between 30 and
50 µm. For instance, in the case of liquid laundry detergent capsules, the volume of each liquid
laundry detergent capsule is considerably lower than that of an equivalent dose of traditional
detergent. Yet, it cleans the same full load of laundry. All active ingredients are contained in a single
unit dose capsule, which dissolves after contact with water inside the washing machine and then
Source Geography Sectors
Paint
microplastic
leakage
(kt/ yr)
Per capita
equivalent
(g/ cap/ yr)
Paint share
of micro-
plastic
leakage (%)
IUCN
Boucher & Friot,
20 1
7
Global
• Marine
• Road
markings
1
56
(to ocean &
waterways)
23
(to ocean &
waterways)
1
0 ,7%
EUNOMIA
Hann et al, 20 1
8
EU
• Architectural
• Marine
• Automotive
• Road
markings
20
(to ocean &
waterways)
40
(to ocean &
waterways)
1
1
.6%
MEPEX
Sundt, Schulze
& Syversen,
20 1
4
Norway
• Architectural
• Marine
• Road
markings
1
.1
(to
environment)
21
4
(to
environment)
1
4%
UNEP
Ryberg et al.,
20 1
8
Global
• Architectural
• Marine
• Road
markings
640
(to
environment)
84
(to
environment)
21
%
Sw edish
EPA
Magnuson et al.,
20 1
6
Sw eden
• Architectural
• Marine
• Road
markings
• General
Industrial
1
.8
(to
environment)
1
86
(to
environment)
9.6%
EA
Paruta et al.
20 21
Global
• Architectural
• Marine
• Road
markings
• General
Industrial
• Automotive
• Industrial
wood
1
’857
(to Ocean &
W aterways)
267
(to Ocean &
W aterways) 58%
270
releases the detergent. In addition to this convenience, the high concentration level leads to lower
product amounts/job needed to be transported through the supply chain, which is a sustainability
advantage by reducing CO2 emissions. Additionally, the film performs the containment function,
enabling high-efficiency cleaning agents that facilitate low-temperature and low-water wash cycles
(which directly improves sustainability, as a significant portion of the carbon emissions from a
laundry cycle comes from the use phase of heating water). As a unit dose, precise portion control is
a key feature to dispense only the quantity needed per load, effectively reducing excessive use and
consumer/end-user overdosing.107
The key enabler of this capsule is a water-soluble film, which holds
the concentrated detergent solution. This film is generally based on PVOH, with polymer backbone
modifications and specific performance additives such as salts (e.g., calcium carbonate) and
plasticizers (e.g., glycerol). The films are developed to readily dissolve as intended in the washing
process, including in sustainability-driven cold-water cycles, and meet the technical challenges of
mass volume production and regulatory compliance.
The definition of “microplastics” of the REACH restriction might not be applicable to PVOH, either
because it is in the form of a film (then not complying with the size limits of the definition) or because
it fulfils the solubility criteria set in the restriction. However, even if PVOH is water-soluble and as
such not in the scope of the REACH restriction, it may adversely impact the environment (see
Rolsky108
). Detergent capsules frequently contain multiple compartments, allowing the formulators
to separate ingredients which at the elevated concentrations of liquid laundry detergent capsules
would not be compatible with each other. To ensure consumer safety and avoid spillage, the film is
designed not to dissolve and rupture during routine transport and handling (e. g. when touched with
wet hands); to resist compression (e. g., during transport or dosing); and to trigger an aversive reaction
in case of oral contact. These features are required for liquid laundry detergent capsules in the EU
under Regulation (EU) No. 1297/2014 (amending the CLP Regulation (EC) 1272/2008), which was
put in place to help reduce accidental exposures involving young children observed in the market.
With respect to their powder analogues, these detergent capsules provide better protection against
any allergic issues related to skin contact and any accident related to misuse by children.
As far as water-soluble films are concerned, more particularly related to their water-solubility feature,
the use of PVOH can be expanded to other applications as a sizing and finishing agent in the textile
industry and as a thickening or coating agent for paints, glues, packaging of meat, pharmaceuticals
and paper and food industries. The fate of PVOH relating to these different applications remains
uncertain.
With a yearly global production of 650,000 tonnes, PVOH is becoming increasingly popular, with
an annual growth rate of 4% from 2018 to 2023. In Europe, the use of PVOH is estimated to be
around 100 000 tonnes per year, of which 20 000 tonnes are used as protective films for detergent
capsules (see further in the calculation of the baseline).109
Other uses are papermaking, textile warp
sizing, as a thickener and emulsion stabilizer in polyvinyl acetate (PVA) adhesive formulations, in a
variety of coatings, and 3D printing. As aforementioned, the PVOH films can be used for all relevant
products (capsules filled with detergent for the washing machine and all chemicals for the household
107
AISE report on SOLUBLE FILMS IN SINGLE-DOSE DETERGENT PRODUCTS: Information on their purpose,
technical characteristics, testing and usage (April 2022, Provided by A.I.S.E. in support of the study for the European
Commission on “Microplastics pollution – measures to reduce its impact on the environment”)
108
Rolsky, C. and Kelkar, V., Degradation of Polyvinyl Alcohol in US Wastewater Treatment Plants and Subsequent
Nationwide Emission Estimate’, International Journal of Environmental Research and Public Health, Vol. 18, no.
11: 6027, 2021.
109
Renewable Carbon, ‘BioSinn – Products for Which Biodegradation makes sense’, 2021 (https://renewable-
carbon.eu/publications/product/biosinn-products-for-which-biodegradation-makes-sense-pdf/).
271
and garden, such as chlorine tablets for the garden pond). However, in the case of PVOH-based
capsules, they have a direct environmental impact as these capsules are directly delivered into grey
water before wastewater treatment plants.
The common way to obtain PVOH is through a hydrolytic deprotection process conducted on
polyvinyl acetate (PVA). To facilitate the processability window, PVOH can also be used as blends
or mixtures (PVAI, Polyviol, Alcotex, Covol, Gelvatol, Lemol, Mowiol, Mowiflex, and Rhodoviol)
when used as a protective film for laundry and dish detergents110
. For the sake of clarity, the term
“PVOH types” indicates the generic composition of these protective films.
As reported by Rolsky111
, the general increase of PVOH and related blends used in capsules and
others could be more and more considered as one of the most ubiquitous pollutants in wastewater.
Some reports112
highlight that when PVOH is discharged into water bodies, PVOH and related blends
likely have an adverse effect on the environment. Due to its surface properties, it has been reported
that PVOH's ability to foam can inhibit oxygen transfer, causing irreparable harm to aquatic life at
high concentrations. In addition, PVOH can potentially adsorb dangerous chemicals or contaminants,
such as antibiotics or heavy metals, at high concentrations, posing a threat to the environment and
our food chains, similar to traditional polluted plastics at high concentrations.
The fate of PVOH in wastewater treatment systems113
has been explored (using radio-labelling to
have a clear follow up about the complete biodegradation), with some studies indicating the
degradation of PVOH-films during the wastewater treatment process even if the complete
degradation has not been established following this process. For instance, some claims have
highlighted that the PVOH and related mixtures used as detergent capsules are fully biodegradable,
but they require additional investigations to confirm this statement. The biodegradation of PVOH
occurs under specific circumstances, which may not be present during wastewater treatment or in the
natural environment (river, seas, and oceans). The PVOH biodegradation is usually conducted in the
presence of oxidative bacteria in which they oxidize the tertiary carbon atoms, leading to the main
endo-cleavage of PVOH molecules and ultimately to the formation of hydrolysable by-products
(hydroxy ketone and 1,3-diketone). Other microorganisms such as bacteria Pseudomonas can utilize
PVOH as a carbon source, and many of these processes can take place simultaneously to begin the
degradation of the polymer. While several bacterial species have been documented degrading PVOH,
110
Julinova, M. et al., ‘Water-soluble polymeric xenobiotics - Polyvinyl alcohol and polyvinylpyrrolidon - And potential
solutions to environmental issues: A brief review’, Journal of Environmental Management, No. 228, 2018, pp. 213-
222.
111
Rolsky, C. and Kelkar, V., Degradation of Polyvinyl Alcohol in US Wastewater Treatment Plants and Subsequent
Nationwide Emission Estimate’, International Journal of Environmental Research and Public Health, Vol. 18, no.
11: 6027, 2021.
112
(a) Cole, M., Lindeque, P., Halsband, C. and Galloway, T. S., ‘Microplastics as contaminants in the marine
environment: A review’, Marine Pollution Bulletin, Vol. 62, 2011, pp. 2588-2597.
(b) Li, J., Zhang, K. and Zhang, H., ‘Adsorption of antibiotics on microplastics’, Environmental Pollution, Vol. 237,
2018, pp. 460-467.
(c) Brennecke, D., Duarte, B., Paiva, F., Caçador, I. and Canning-Clode, J, ‘Microplastics as vector for heavy metal
contamination from the marine environment’, Estuarine, Coastal and Shelf Science, Vol. 178, 2016, pp. 189-195.
(d) Lei, L. et al., ‘Oxidative degradation of poly vinyl alcohol by the photochemically enhanced Fenton reaction’, Journal
of Photochemistry and Photobiology A: Chemistry, Vol. 116, No. 2, 1998, pp. 159-166.
(e) Sun, W., Chen, L. and Wang, J., ‘Degradation of PVA (polyvinyl alcohol) in wastewater by advanced oxidation
processes’, Journal of Advanced Oxidation Technologies, Vol. 20, No. 2, 2017.
(f) Hollman, P.C.H., Bouwmeester, H. and Peters, R.J.B., ‘Microplastics in Aquatic Food Chain: Sources, Measurement,
Occurrence and Potential Health Risks’, RIKILT-Institute of Food Safety, 2013 (https://edepot.wur.nl/260490).
113
Wheatley, Q. and Baines, F., ‘Biodegradation of polyvinyl alcohol in wastewater’, Textile Chemist & Colorist, Vol.
7, No. 2, 1976, pp. 28-33.
272
they are present in soils and not usually in natural water compartments.114
In the case of old sludge,
the microorganisms are usually acclimatised and could effectively biodegrade these PVOH and
related mixtures. Knowing that these PVOH and related mixtures used as water-soluble films can
contain certain additives (e.g. salts and plasticizers), the related additives could likely modify and to
some extent, inhibit their biodegradation ability.115
To clearly demonstrate the full biodegradation of
these PVOH after wastewater treatments, specific procedures and related characterization techniques
must be employed, such as radiolabelling PVOH in order to follow up the ultimate fate of these
PVOH types.
A recent report has highlighted that the PVOH films used for detergent capsules were shown to be
potentially biodegradable in OECD screening test conditions.116
The OECD 301 series of
biodegradation tests are commonly used by manufacturers and users of these water-soluble films.
They are considered stringent screening tests, conducted under aerobic conditions, in which a high
concentration of the test substance (in the range of 2 to 100 mg/L) is used and ultimate biodegradation
is measured by non-specific parameters like Dissolved Organic Carbon (DOC), Biochemical Oxygen
Demand (BOD) and CO2 production. These tests are also used under existing EU legislation to
measure the biodegradability of mixtures (surfactants under Regulation (EC) No 648/2004 on
detergents) and polymers (under the recently adopted REACH restriction on intentionally added
microplastics). These tests are considered stress tests for the test chemical since the system does not
have an environmentally realistic ratio of a test chemical to microbes (which in an actual WWTP
would be orders of magnitude higher). The inoculum is sourced from a well-operated domestic
wastewater treatment plant with a diverse and robust microbial population, and no pre‐exposure to
the test chemical is allowed. In these studies, the test material is the sole carbon and energy source
for the population of microorganisms to use and grow. Using 6 representative PVOH and related
mixtures, the extent of biodegradation after 28 days was estimated at 60.4% on average, but the full
biodegradation has not been demonstrated except on the basis of extrapolation models.
Figure 16: Model extrapolation beyond 28 days
114
Yamatsu, A., Matsumi, R., Atomi, H. and Imanaka, T.: Isolation and characterization of a novel poly(vinylalcohol)-
degrading bacterium, Sphingopyxis sp. PVA3. Appl Microbiol Biotechnol 72 (2006), 804 – 81. PMid:16583228;
DOI:10.1007/s00253-006-0351-4
115
Byrne et al., Biodegradability of Polyvinyl Alcohol Based Film Used for Liquid Detergent Capsules, Environmental
Chemistry, (2021)
116
Byrne et al., ‘Biodegradability of polyvinyl alcohol based film used for liquid detergent capsules’, Tenside Surfactants
Detergents, Vol. 58, No. 2, 2021.
273
There are some international standards (e.g., ISO standard 14593: 1999) that can be used to
demonstrate the complete biodegradation of biodegradable plastics, such as some microbial
polyesters in natural aqueous compartments (marine), i.e., the complete metabolisation of C-substrate
into CO2. However, the standards are commonly conducted at temperatures above room temperature
and do not correspond to the real environmental situation. Therefore, PVOH removal during
wastewater treatments is still in question due to a lack of comprehensive research and must be even
experimentally demonstrated in some natural compartments, such as in marine conditions in which
the rate of biodegradation can be slowed down due to a low temperature (e.g., 4°C in oceans).
4.4.1 Value chain of water-soluble plastics
The main actors in the value chain are:
• Detergent manufacturers
• Water-soluble plastic producers
• Water-soluble plastic processors
• Wastewater management companies
Below is a description of their respective roles.
• Detergent manufacturers belong to the European household care and professional cleaning
and hygiene industry, particularly those manufacturing detergent capsules for laundry and
dishwasher capsules. More than 1700 companies are active in the domains of soaps,
detergents or maintenance products.
• Water-soluble plastic producers are manufacturers of virgin PVOH materials for water-
soluble productions. Historically, air Products and DuPont were among the first PVOH
manufacturers of PVOH, but today Kuraray (Japan) is one of the largest manufacturers of
PVOH resins.
• Water-soluble plastic processors transform PVOH pellets by mixing them with plasticizers
and salt to alter their physical properties, particularly water-solubility. Such activities are
related to compounders. The major supplier in Europe is Kuraray under the brand name
monosol.
• Wastewater management companies are treating urban and industrial wastewater with a
fundamental role in ensuring public health and environmental protection by removing
suspended solids, harmful bacteria, and pollutants of emerging concern. They can be of
private and public bodies. Urban wastewater treatment in Europe has improved over recent
decades, largely above 80% of wastewater treated since 1995.
4.4.2 Routes of water-soluble plastics loss
Related to its inherent water-solubility, the major release of PVOH and its blends as detergent
capsules occur through conventional water treatments in the form of greywater from domestic, public,
and industrial sources. One might not exclude that other PVOH fractions not used as detergent
capsules, such as chlorine tablets, can be found elsewhere, such as in soils. In this respect, the major
route of PVOH and its blends is related to water discharges of greywater from domestic, public, and
industrial sources, mainly reaching most wastewater treatment plants in Europe. There are different
wastewater treatment levels (primary, secondary, sludge, and disinfection) before leaving the
wastewater treatment plant. The primary treatment based on mechanical treatments (stirring,
filtration, etc.) and the secondary treatment based on biological actions (digestion, etc.) are
compulsorily implemented in the EU and in the case of sensitive areas (coasts, etc.), additional
treatments (tertiary treatments based on advanced filtration, etc.) are even considered. For instance,
for discharges to sensitive waters, the wastewater treatment plant directive requires that all urban
274
areas populated by more than 10 000 people provide primary, secondary and tertiary treatment. In a
highly dense EU country such as The Netherlands, more than 90% of wastewater treatment is based
on a tertiary treatment, consisting of a disinfection chamber and a filtration unit. 117 118 119 120
Figure 17: Collection rate of urban wastewater in the Netherlands
Related to the misuse or non-intentional release of PVOH in some natural compartments (e.g. soil),
we may not exclude that all PVOH cannot reach the facilities related to wastewater treatment plants.
Therefore, PVOH residues could be likely found in both treated sludge and water.
Water-soluble plastics used for detergent capsules have been recently extended to other types of more
environmentally friendly resins, such as the LACTIPS company121
. They propose a casein-based
packaging film for dishwasher tabs claimed as “OK bio-degradable WATER” by the private company
TÜV Austria, but are not endorsed by any CEN or ISO standard. However, at this moment, these
alternatives are still unsuitable as these LACTIPS products derived from milk protein are non-
VEGAN products and could not be widely accepted as water-soluble films. Another issue is related
to their poor transparency as water-soluble films. Some suppliers in Germany can provide
biodegradable films based on natural products (starch) with the EU Ecolabel. The EU-Ecolabel
recognised the biodegradability of these products, in which the water-soluble films were a part of the
overall composition.
4.5 Problem definition for geotextiles
Geotextiles are a type of geosynthetics used for various civil engineering applications. They are
primarily made of polymers such as polypropylene or polyester and are mostly manufactured in two
different forms woven and nonwoven. Figure 18 below shows various examples of geosynthetics.
117
European Environment Agency, ‘Urban wastewater treatment in Europe’, consulted March 18th
2022
(https://www.eea.europa.eu/data-and-maps/indicators/urban-waste-water-treatment).
118
European Environment Agency, ‘Urban wastewater treatment in Europe’, consulted March 18th
2022
(https://www.eea.europa.eu/data-and-maps/indicators/urban-waste-water-treatment).
119
European Environment Agency, ‘Urban wastewater treatment in Europe’, consulted March 18th
2022
(https://www.eea.europa.eu/data-and-maps/indicators/urban-waste-water-treatment).
120
European Environment Agency, ‘Urban wastewater treatment in Europe’, consulted March 18th
2022
(https://www.eea.europa.eu/data-and-maps/indicators/urban-waste-water-treatment).
121
Lactips, ‘Polymère naturel et biodégradable en milieu aquatique’, consulted on March 18th 2022
(https://www.lactips.com/).
275
Figure 18: Various samples of geosynthetics
From bottom to top: the rough black surface of high-density polyethylene (HDPE) geomembrane,
white carrier nonwoven geotextile, black geonet, white nonwoven filter geotextile (folded back),
black woven geogrid and a white.122
There is a real environmental advantage in using geotextiles as their mechanical properties enable
civil engineers to significantly increase the tensile strength of soils. They are lightweight materials,
so they have lower carbon emissions than equivalent concrete or metal. Furthermore, they weigh
significantly less than other materials which can be used to stabilise soils, e.g., gravel and rock. As a
result, the CO2 balance when using geotextiles versus gravel or more traditional stabilising materials
is in favour of geotextiles123,124
. Indeed, rising sea levels and increasing storm strength are disrupting
European coasts to a greater extent than before, and geotextiles are used for protecting coasts.
Although geotextiles are, in theory, designed to withstand the harsh conditions to which they are
exposed in these applications, there are examples of these geotextiles failing and not serving their
intended purposes nor being removed (after use) from coastal areas where they can become hotspots
for macro and microplastics emissions.
The issue seems to stem from two main factors: first, the materials may not have sufficient resistance
to the environmental conditions they are exposed to (temperature variation, exposure to water, salt
water, UV light, abrasion, etc.) and second, the extreme weather events such as storms which the
material can be exposed to. Some autoclave tests performed in 2021125
exhibit good life expectancies
(a half-life of 330 years for mechanical properties retainment) for different geotextile types. However,
the mechanical wear of the materials was not taken into account, which is unfortunate considering
that mechanical wear in coastal erosion protection applications is a very destructive force.
The industry has estimated the longevity of geotextiles by studying the influence of thermal and UV
ageing on the reduction in mechanical properties of the geotextiles. Their results showed that for an
unexposed 1.5 mm thick HDPE geomembrane, the life expectancy for the retention of 50% of
mechanical capacity could be up to 450 years, whereas it was 97 years for the exposed membranes.
122
Müller, W.W. and Saathoff, F., ‘Geosynthetics In Geoenvironmental Engineering’, Science And Technology Of
Advanced Materials, Vol. 16, No. 3, 2015.
123
Dixon, N., Raja. J., Fowmes, G. and Frost, M., ‘Sustainability Aspects Of Using Geotextiles’, Geotextiles, 2016, pp.
577-596.
124
Edana, ‘Why use nonwovens in geosynthetics and civil engineering?’, Consulted 6 January 2022
(https://www.edana.org/nw-related-industry/nonwovens-in-daily-life/geosynthetics-and-civil-engineering).
125
Scholz, P. et al., ‘Environmental Impact Of Geosynthetics In Coastal Protection’, Materials (Basel), Vol. 14, No. 3,
2021, pp. 634.
276
126
A study indicates that the successive exposure of polypropylene geotextile to UV degradation, sea
water and thermal cycle “showed the existence of relevant interactions between the degradation
agents and the reduction factors obtained by the traditional methodology were unable to represent
accurately (by underestimating) the degradation occurred in geotextiles.”127
The tests performed128
to evaluate the life expectancy of these materials emulated the thermal,
radiative and chemical processes to which geotextiles are exposed. However, they did not consider
the mechanical abrasion which happens when geotextiles are exposed to the outside environment.
One can infer that adding mechanical abrasion to the three degradation tests discussed would reduce
the life expectancy of these materials even more for the geotextiles used in harsh environments, such
as when used for coastal erosion protection. The general problem drivers for the microplastic
emissions from geotextiles are similar to other sources, viz. market failure, regulatory failure and
information/knowledge failure.
Scale of microplastic emissions from geotextiles
Estimations of the emissions of microplastics from geotextiles are scarce, but there are no lab results
or experiments conducted, except the Bai, Xue et al. experiment in China. There are several
explanations for this; first of all, geotextile weathering and environmental impact because of
microplastics is a newly studied subject. Moreover, in-situ sampling is extremely difficult because
these materials are either directly exposed to harsh environments and water (e.g., coastal erosion
protection) where any microplastic particle emitted is extremely difficult to sample from the
environment, either they are buried in the foundations of roads, building, or any other large
construction works where to sample any microplastics; one would need to dig up the surrounding
soil. The fate of geotextiles buried underground and potential microplastic emissions are also not
known.
5 BASELINE BY SOURCE
5.1 Baseline for tyres
A key driver of tyre wear emissions is driving mileage. It is expected that there will be a significant
increase in road transport volumes over the next decades. The JRC estimates a 16% increase in
passenger road transport between 2010-2030 and a 30% increase for 2010-2050. Freight transport is
estimated to increase by 33% by 2030 and 55% by 2050129
. Most recently, in the context of preparing
the Fit for 55 Package130
, the Commission assumed the increase in passenger car transport will grow
by around 30% and around 20% for road freight transport131
. Additionally, climate change effects,
126
Koerner, R. M., Hsuan, Y.G. and Joerner, G.R., ‘Lifetime Predictions Of Exposed Geotextiles And Geomembranes’,
Geosynthetics International, Vol. 24, No. 2, 2017, pp. 198-212.
127
Carneiro, J.R., Almeida, P.J. and De Lurdes Lopes, M., ‘Laboratory Evaluation Of Interactions In The Degradation
Of A Polypropylene Geotextile In Marine Environments’, Advances In Materials Science And Engineering, Vol.
2018, 2018, pp. 1-10.
128
The thermooxidation tests were carried out according to method A of EN ISO 13438 and the damage suffered by the
geotextile (during the degradation tests) was evaluated by tensile tests according to EN 29073-3 [33] (the method
specified in EN 12226 [19] for determining the changes in the tensile properties of aged nonwoven geotextiles).
129
Alonso Raposo, M. and Ciuffo, B., The Future of Road Transport: Implications of automated, connected, low-carbon
and shared mobility, JRC116644, 2019, Publications Office of the European Union, Luxembourg.
130
European Council and Council of the European Union, ‘European Green Deal - Fit for 55’, 2022
(https://www.consilium.europa.eu/en/policies/green-deal/fit-for-55-the-eu-plan-for-a-green-transition/).
131
European Commission, ‘Policy scenarios for delivering the European Green Deal’, 2022
(https://energy.ec.europa.eu/data-and-analysis/energy-modelling/policy-scenarios-delivering-european-green-
deal_en#scenario-results).
277
e.g. more frequent heavy rainfall events, will exacerbate the problems linked with releases of those
microplastics from urban runoff and stormwater overflows (SWO). Finally, the increasing
electrification of vehicle fleet may negatively influence tyre wear emissions and abrasion since
‘electrified vehicles’ (i.e. hybrid ICE) are generally heavier compared to their conventional
counterparts. Battery electric vehicles are not necessarily heavier than conventional ICE vehicles of
comparable class and power, particularly the larger ones132
. Moreover, energy density (in weight and
volume) is predicted to improve, so longer-range battery electric vehicles (BEVs) are expected in the
future without an increase in weight. The possible effects of the introduction of electrified vehicles
on non-exhaust emissions have been summarised in a recent OECD report133
.
With regards to tyre abrasion, important improvements could be expected since the proposal for a
Euro 7 Regulation includes a review clause and related empowerments in order to include tyre
abrasion limits in the type approval process. An ongoing Commission study and work performed in
the UN Forum for Harmonisation of vehicle regulations on tyre abrasion test method will provide the
basis for a tyre abrasion standard. The Tyre Labelling Regulation134
included the possibility of a
delegated act on tyre abrasion when the standard on abrasion (and mileage) becomes available.
5.1.1 Analytical approach
It is still a challenge to collect representative environmental samples of tyre wear, whether in water,
soil or air.135
Due to a lack of reliable methodologies, measurement uncertainties and incomplete
databases, no reliable results can be quantified. An analytical or a top-down approach is possible.
Analytical problems hamper the environmental monitoring of emitted TWP. Emitted TWP cannot be
analysed using FTIR or Raman spectroscopy, commonly used for other microplastics. Since tyre
tread and emitted TWP have a complex chemical composition and emitted TWP are difficult to
separate from environmental matrices, markers are needed to detect the particles in environmental
samples. In general, chemical compounds that are additives in tyre tread materials in sufficiently high
concentrations are used as markers. A reliable marker should i) be specific to tyre rubber polymer, ii)
be present in comparable concentrations, preferably independent of tyre brands, iii) not easily leach
out or be transformed under environmental conditions and iv) be easily and precisely detectable.
Typical markers used are inorganic Zn, benzothiazoles such as 2-(4-morpholinyl)benzothiazole
(24MoBT) and N-cyclohexyl-2-benzothiazolamine (NCBA) (components of vulcanization
accelerators), NR (natural rubber) and SBR/BR (styrene butadiene rubber/ butadiene rubber). For all
markers, a sample preparation to separate emitted TWP from other particles is useful to reduce the
background concentration, prevent matrices effects and concentrate emitted TWP to get a
representative sample. By using thermoanalytical methods, a fractionation in several size classes is
useful. The reason is that bigger particles have a high influence on the total mass, but in general, the
number of particles is less than for smaller particles.136
Furthermore, by analysing the air samples,
the particle size <10µm is more relevant to evaluating health hazards.
132
E.g. A Tesla Model 3 LR, 4x4, 441 HP weighs 1726 kg, while a BMW 330e, 4x4 292 HP weighs 1820 kg.
133
OECD, Non-exhaust Particulate Emissions from Road Transport: An ignored environmental policy challenge, 2020,
OECD Publishing, Paris.
134
European Parliament and Council of the European Union, Regulation (EU) 2020/740 on the labelling of tyres with
respect to fuel efficiency and other parameters, OJ L 177, 5.6.2020, pp. 1–31.
135
Peter Tromp et al., Presentation on the ‘Comparison and improvement of analytical techniques for quality data on TWP
in the environment’, Conference Setac Europe, 2021 (https://globe.setac.org/tire-wear-and-microrubber-particles/).
136
Venghaus, D. et al., Report on project RAU (Tyre abrasion in the environment) – ‘Tire Wear in the environment –
RAU’, 2021, Funded by the German Federal Ministry of Education and Research (BMBF).
278
Top-Down approach
Based on a mileage approach, tyre abrasion emissions can be estimated theoretically. An emission
factor (EF) is defined and multiplied by the distance travelled. The resulting quantity corresponds to
the losses on the tyre tread and represents the emitted TWP. The EF can be made dependent on
various influencing variables, which are explained below.
Quantification of emissions
By differentiating between vehicle types (motorcycle, passenger car, HDV, etc.) and road types
(urban, rural and motorway), the influencing variables from Boulter et al.137
- tyre and vehicle
characteristics, road surface characterisation and vehicle operation - can be taken into account, i.e.
emission factors of the vehicle types are adjusted according to the driving situation
(urban/rural/motorway). Based on the methodology for determining the emission rate described
above and considering influencing factors, emission factors (EF) can be determined.
The figure below shows an overview of EF from various studies138
. It is clear that the EF for
motorcycles, passenger cars and light/medium vehicles show hardly any deviations. The EF for
heavy-duty vehicle (HDV) and buses, on the other hand, fluctuate strongly.
Figure 19: Emission rates according to vehicle type in various studies139
The EF, according to Deltares and TNO140
, has already been used several times in the calculations of
the Netherlands Environmental Agency141,142,143
. Furthermore, the EF served as a basis for the TWP
137
Boulter, P.G., Thorpe, A., Harrison, R.M. and Allen, A.G., ‘Road Vehicle Non-exhaust Particulate Matter: Final
Report on Emission Modelling’, TRL, 2006.
138
Peano, L. et al., ‘Plastic Leak Project. Methodological Guidelines’, Quantis, 2020 (https://quantis.com/report/the-
plastic-leak-project-guidelines/).
139
Ibid.
140
Deltares and TNO, ‘Emissieschattingen Diffuse bronnen Emissieregistratie - Bandenslijtage wegverkeer’ [Emission
estimates Diffuse sources Emission registration - Tyre wear road traffic], 2016 (https://docplayer.nl/22104153-
Bandenslijtage-wegverkeer.html), Nl.
141
Geilenkirchen, G. et al., ‘Methods for calculating the emissions of transport in the Netherlands’, PBL Netherlands
Environmental Assessment Agency, 2020 (https://www.pbl.nl/sites/default/files/downloads/pbl-2020-methods-for-
calculating-the-emissions-of-transport-in-the-netherlands-2020-4139.pdf).
142
Verschoor, A. et al., ‘Emission of microplastics and potential mitigation measures: Abrasive cleaning agents, paints
and tyre wear’, Dutch National Institue for Public Health and the Environment, 2016
(https://rivm.openrepository.com/bitstream/handle/10029/617930/2016-0026.pdf?sequence=3).
143
Klein, J. et al., ‘Methods for calculating the emissions of transport in the Netherlands’, 2019
(https://english.rvo.nl/sites/default/files/2019/05/Klein%20et%20al%202019%20Methodology%20report%20transp
ort%202019.PDF).
279
emissions calculations in numerous studies144
. To estimate TWP emissions for the EU27, the most
recent road traffic data from the Eurostat database were used (Table 8).
Taking into account the given data and assumptions, this results in an annual emission quantity of
450,000 t/a TWP for the entire EU27 for 2020, which is at the bottom end of the range from other
studies (460,000-1,220,000 t/a) discussed previously. The shares of the road sectors
(urban/rural/motorway) in the total emissions can be estimated on the basis of the available mileage
data. According to this, most tyre wear is emitted on urban (39%) and rural (38%) roads. The share
of motorways is 23%.
Figure 20: Annual estimated TWP emissions for the EU27, 2020
In order to develop an estimate for the final release of tyre wear (i.e. to which environmental
compartments they are released), the methodological guidelines of the Plastic Leak Project145
were
used. The tool published for this project takes all input pathways into account and allows specific
parameters to be adjusted. Although there are uncertainties in the data, e.g. the share of
separate/combined sewer systems or the recycling of sewage sludge, it nevertheless provides
information on how different measures could affect it.
The table below shows the calculated estimates for the final release of tyre wear into the environment.
Table 8: Estimation of the final release of emitted TWP
FINAL RELEASE COMPARTMENTS
Removed from
the
environment
share
of
roads
OCEANS
(sediments
and water
column)
FRESH-
WATER
(sediments
and water
column)
SOILS AIR
OTHER
TERRESTR
IAL
COMPAR-
TMENTS
Average 2% 14% 59% 5% 9% 12%
144
Vogelsang, C. et al., ‘Microplastics in road dust – characteristics, pathways and measures’, 2019
(https://www.miljodirektoratet.no/globalassets/publikasjoner/M959/M959.pdf).
145
Quantis, ‘The Plastic Leak Project’ (https://quantis.com/who-we-guide/our-impact/sustainability-initiatives/plastic-
leak-project/).
280
Urban 39% 2% 19% 48% 5% 12% 19%
Rural 38% 0% 3% 91% 5% 5% 0%
Motorway 23% 3% 26% 38% 5% 12% 21%
The table shows that the majority of the emission is deposited in the soil (59%), which is the
significant input pathway for rural roads in particular. This includes wind drifts to roadside and
ditches as well as WWTP sludge agriculture and compost use. With regard to the input into the
aquatic environment, urban areas and motorways are of particular importance. Other terrestrial
compartments include stormwater sludge and sewage sludge listed in Eurostat as other and unknown.
Sludge for incineration is evaluated as "removed from the environment". Although it can be assumed
that airborne particles will deposit in the environment over time and thus contribute to the input of
soil, surface waters or oceans, the intention of the pathway estimation is to identify which
compartments and the living organisms in them are affected by the emission. The proportion of
airborne particles is therefore set to 5%, according to Baensch-Baltruschat et al.
The baseline is the projection of emissions over the assessment period. The different factors that
could potentially influence tyre wear emissions in the future have been assessed above. The following
table summarises the expected effect of these factors on the tyre wear emissions. In addition to these
factors, any future potential regulatory actions on abrasion rates could have a significant positive
effect.
Table 9: Key factors and their effect on tyre wear emissions.
Factor Estimated Impact on TWP Emissions
Development in transport volume and
mode of transport
Increase
Tyre material innovations High effect and high potential
Road material innovations Limited effect but high potential
Electric vehicles
Increase – depending on battery technology developments which might
reduce the effect
Vehicle weight (SUV trend) Increase
Speed limits Decrease
Porous asphalt Limited decreasing effect – but medium potential impact
Driving behaviour
Changes in behaviour can lead to increases (greater acceleration, sharp
breaking etc.) or decreases (slower acceleration / speeds, reduced ./
smoother breaking)
Autonomous driving / connected
driving
Limited decreasing effect in the short term, but medium potential impact
in the longer term
For transport volumes, there are EU projections available that quantify how it is expected to evolve.
In preparation of the European Green Deal Package, the Commission carried out a scenario
assessment, including projections of the development of the transport sector and transport volumes.
The policy scenarios assume continued transport growth. Though they include some reductions
281
compared to the reference scenario, the increase in passenger car transport is assumed to grow by
around 30% and about 20% for road freight transport146
. It means that an increase in emissions can
be expected due to the continued road transport growth.
Considering the different factors, it is difficult to quantify the expected change in emissions in the
future. The increase in road traffic and the (assumed) higher weight of electric vehicles would all
lead to an increase in tyre wear emissions. More restrictive speed limits, better tyres, and improved
driver behaviour through autonomous driving and awareness campaigns would lead to lower
emissions. The following assumptions have been made:
• It is assumed that all factors except the transport volume increase cancel each other out. For
example, effects of increases in the weight of passenger cars are offset by the factors that
reduce emissions such as speed etc.
• The projected increase in transport volumes by 2030 of 30% for passenger transport and 20%
for freight transport lead to proportionate increases in the microplastic emissions by the
respective vehicle categories.
In total, the emissions are therefore expected in the baseline to increase from around 450,000 tonnes
per year to 570,000 tonnes per year in 2030.
5.1.2 Uncertainty and data gaps
Several factors influence the release of emitted TWP into the environment, e.g. tyre material and
design, which consists of many components, road composition, and driving behaviour. The analysis
for the determination of tyre abrasion in environmental samples is a challenge, and an interpretation
of the analytical data should be carried out, taking into account the external conditions. In general,
these variables' comparison and inclusion are not explored. Additionally, reproducible quantification
of particles in the environment depends on the laboratories' sampling techniques and analytical
techniques. Currently, there is a knowledge gap which is a combination of sampling techniques and
evaluation procedures most suitable for quantification of emitted TWP to get realistic values. This
gap should be at least partially filled with the ongoing work to develop a harmonised testing method
and standard.
In addition to uncertainties with the overall emission factors for tyre abrasion, there is also a lack of
data on the mix of tyres currently in use and how they vary in terms of abrasion rates. Several studies
have demonstrated significant variation in abrasion rates between different tyre models and types
both across different categories (i.e. tyre sizes and types) as well as within categories.
5.2 Baseline for textiles
The European demand for synthetic textiles is estimated at 8 million tonnes (ETC/WMGE, 2021c),
representing almost 14 % of Europe’s total plastic consumption. Between 1996 and 2012, there was
a 40% increase in the amount of clothes purchased per person in the EU, and, according to the
European Environmental Agency (EEA), between 1996 and 2018, clothing prices in the EU dropped
by over 30 %, relative to inflation. Since 2000, Europeans have purchased more pieces of clothing
but spent less money in doing so. These trends are expected to increase in the future, as at a global
level, the consumption of clothing and footwear is expected to increase by 63% between 2019 and
2030. The global consumption of synthetic fibres increased from a few thousand tonnes in 1940 to
146
European Commission, ‘Policy scenarios for delivering the European Green Deal’ (https://energy.ec.europa.eu/data-
and-analysis/energy-modelling/policy-scenarios-delivering-european-green-deal_en).
282
more than 60 million tonnes in 2018, and continues to rise. Since the late 1990s, polyester has
surpassed cotton as the fibre most commonly used in textiles. While the majority of synthetic textile
fibres are produced in Asia, Europe stands out as the world’s largest importer of synthetic fibres by
trade value147
, and also produces and exports such fibres.148
This increase in consumption leads to an
increase in textiles production thus increasing microplastic emissions from textiles. In practice, this
increase in consumption is accompanied by a decrease in the number of uses per piece149
. A higher
renewal rate also means more textiles being thrown away and more emissions at the end-of-life stage.
Due to their low cost, synthetic materials are one of the levers of fast fashion.
The global increase in textile consumption implies a wider use of synthetic fibres, namely polyester
and a consequent increase in fibre production. More than half of the global fibre production is
polyester, making it the most common synthetic fibre (55 million tonnes in 2018) (Textile Exchange,
2019)150
, in with a large majority of polyester, which should represent around 70% of the total fibre
production in 2030. The growing share of synthetic fibres is linked to the limited production of cotton
and its relatively high price, as well as the increasing use of synthetic fibres in industries (synthetic
fibres are used in a wide range of technical products: tyres, conveyor belts, reinforcement in
composites, etc.).
147
Birkbeck, C.D., Global Governance Brief: Strenghthening international cooperation to tackle plastic pollution:
options for the WTO, The Graduate Institute of Geneva, 2020.
148
Manshoven, S., Smeets, A., Arnold, M. and Fogh Mortensen, L., ‘Plastic in textiles: Potentials for circularity and
reduced environmental and climate impacts’, European Environment Agency and European Topic Centre on Waste
and Materials in a Green Economy, Eionet report ETC/WMGE 2021/1, 2021.
149
Hemkhaus, M., Hannak, J., Malodobry, P. et al., ‘Circular economy in the textile sector’, study for the German Federal
Ministry for Economic Cooperation and Development, 2019.
150
Textile Exchange, ‘2019 Preferred Fiber & Materials Report’, 2019 (https://store.textileexchange.org/product/2019-
preferred-fiber-materials-report/).
283
Table 10 sums up current microplastic emissions from synthetic textile per year in the EU. Data
quality was assessed according to the number of sources and the uncertainty151
. Not all emissions to
water reach the environment. Indeed, part of the emissions to water will be captured by wastewater
treatment plants. A large majority of microplastics are captured in the sludge152
. However, in Europe,
approximately 50% of all sludge are applied in agriculture as fertilizer153
. So, due to sludge usage as
fertilizer (the other half being incinerated, the microplastics are not emitted to the environment), 50%
of emissions to water will reach the environment. Outside Europe, all emissions to water are
considered to be emitted to the environment.
151
The data used for calculating the emission ranges are presented in the appendices of the supporting study for this
Impact Assessment.
152
Lares, M. et al., ‘Occurrence, Identification And Removal Of Microplastic Particles And Fibers In Conventional
Activated Sludge Process And Advanced MBR Technology’, Water Research, Vol. 133, 2018, pp. 236-246, Elsevier
BV.
153
Hann, S., Sherrington, C., Jamieson, O. et al., Investigating options for reducing releases in the aquatic environment
of microplastics emitted by (but not intentionally added in) products, Eunomia report for the Directorate-General for
Environment, 2018.
284
Table 10: Microplastic emissions from synthetic textile per year in the EU27 - 2021
Production Washing Drying Wearing End-of-Life
Microplastic emissions
per year due to EU
consumption (tonnes)
[841 ;
22,704]
Of which
21%
happen in
the EU
[635 ;
5506]
[137 ;
7501]
[37 ;
25,367]
NA
Type of emissions Air / water Water Air Air Air / water
Data quality Low Medium Medium Low NA
Number of sources 1 6 4 2 0
These quantifications need to be refined along with standardised measurement methods in order to
understand the influence of each factor and to be able to compare data. Standardisation should specify
all the experiment criteria and impose only one measurement method to compare studies with one
another. However, these values already underline the need to tackle microplastic emissions and
generation directly at the source.
The baseline scenario has been developed for the year 2030. The quantities of microplastics emitted
per year in 2030 are estimated by taking into account the evolution of the parameters related to the
general problem driver “Increase in production and use of textiles”, such as the increase in clothing
consumption and the increase in the share of synthetic materials in clothing. The following table lists
the parameters used to define the baseline scenario and gives their evolution between the current
situation and the foreseen situation in 2030. The values for 2030 are either estimated on the basis of
the literature or are assumed (details provided in “Comments” column).
Table 11: Evolution of the parameters of the microplastic emissions from textiles between the current
situation and 2030 (parameters marked with an * are used directly in the emission calculations)
Parameter Sub-
category
Unit Data
considered
in the state
of the art
(current
value)
Baseline
scenario
(forecast
data)
Comments
Evolution of the
population
Population * - million 447 449 154
Households in
Europe (1)
- million
households
195 198 Population increase: 1.3% 155
Market data
154
Toute l’Europe.eu, ‘A quoi ressemblera l’Europe en 2030’ [What will Europe look like in 2030?], 2020
(https://www.touteleurope.eu/environnement/a-quoi-ressemblera-l-europe-en-2030/), Fr.
155
Calculation according to OECD projections between 2021 and 2030.
285
Parameter Sub-
category
Unit Data
considered
in the state
of the art
(current
value)
Baseline
scenario
(forecast
data)
Comments
Consumption of
textile products *
- million
tonnes
7.4 156
9.0 Increase in textile production: +23% 157
Proportion of
man-made fibres
in clothing sector
- % 33.9% 38% Assumption: 38% of man-made materials
(cf. section “Increase in production and
use of synthetic textiles” / problem driver
2)
Polyester * Woven % 8.40% 9.38%
Knitted % 8.60% 9.60%
Polypropylene * Woven % 0.20% 0.22%
Knitted % 1.20% 1.34%
Acrylic * Woven % 0.30% 0.33%
Knitted % 8.40% 9.38%
Polyamide * Woven % 1.50% 1.67%
Knitted % 5.30% 5.92%
Washing
Number of
washes per
household (2)
- washes a
week
3.35 No
change
According to 2008, 2017 and 2020 AISE
data, no change in frequency158, 159
Average capacity
of a washing
machine (3)
- kg 6.5 7 Assumption based on (JRC, 2016)
Relative load of
one wash (4)
- % 82% -
156
Calculation based on the following data: 6.4 million tonnes of clothing consumed in the EU in 2015 (source: ECAP,
‘Mapping clothing impacts in Europe: the environmental cost’, 2017 (http://www.ecap.eu.com/wp-
content/uploads/2018/07/Mapping-clothing-impacts-in-Europe.pdf)) and “40 per cent growth in the amount of
purchased clothes per person in the EU between 1996 and 2012”, which means 2.5% growth per year (source:
ETC/WMGE, ‘Textiles and the environment in a circular economy’, 2019 (https://www.eionet.europa.eu/etcs/etc-
wmge/products/etc-wmge-reports/textiles-and-the-environment-in-a-circular-economy/))
As in the EC/Eunomia (2018) report, professional textile washing – namely in hospitals or hotels – was not considered.
Professional and household linens are mainly composed of cotton or polycotton (polyester/cotton blend) . Due to the
lack of data on microplastics emissions from polycotton, the amount of polyester contained in the polycotton blend,
no estimation could be made. According to first approximations made by RDC Environment, microplastics emissions
from this source would represent less than 5% of the household emissions from clothing.
157
Calculation based on the following data: “40 per cent growth in the amount of purchased clothes per person in the EU
between 1996 and 2012” (source: ETC/WMGE, ‘Textiles and the environment in a circular economy’, 2019
(https://www.eionet.europa.eu/etcs/etc-wmge/products/etc-wmge-reports/textiles-and-the-environment-in-a-
circular-economy/))
158
AISE, ‘A.I.S.E.’s pan-European habits survey 2020’, 2021 (https://www.aise.eu/our-activities/information-to-end-
users/consumer-research.aspx).
159
AISE, ‘A.I.S.E. Pan-European Consumer Habits Survey 2017’, 2018
(https://www.aise.eu/documents/document/20180528165059-
aise_consumershabitssurvey2017_summary_final.pdf).
286
Parameter Sub-
category
Unit Data
considered
in the state
of the art
(current
value)
Baseline
scenario
(forecast
data)
Comments
Machine load *
(3)*(4)
- kg of
textile
washed per
cycle
5.33 5.33 Calculation based on the average capacity
of a washing machine and the relative
load of one wash
Note: no increase in load despite the
increase in capacity.160
Number of
washes per year *
(1)*(2)
- billion
washes
34.0 34.5 Assumption: increase in the number of
washes according to the population
Drying
Number of
tumble dryers in
use in European
households *
- million 78.0 78.3 Assumption: increase in the number of
dryers according to the population
Number of uses
per year *
- times per
year
107 No
change
Average load * - kg 4.4 No
change
161
The microplastic emissions per year for 2030 are presented in the following table. It should be noted
that emissions of microplastics per year for the year 2030 are calculated using the following
assumption, “there is no change in the quantities of microplastics emitted per kg (kg worn, kg
washed or kg dried)”. This assumption is based on the fact that the time considered is too limited
to identify and implement eco-design and research & development actions as a baseline without
policy measures fostering changes. No quantified data is available for microplastic emissions related
to the end of life of clothing. For these emissions, the evolution of emissions (in % terms) is estimated
only based on the increase in clothing consumption.
160
European Commission, Final report - Review study on household tumble driers, 2019 (https://www.applia-
europe.eu/images/Library/Review_study_on_tumble_dryers_06-2019.pdf).
161
Ibid.
287
Table 12: Evolution of the quantities of microplastics emitted per year (tonnes/year)
Emissions Data estimated
in state of the art
(current value)
Baseline
scenario
(forecast data)
Evolution Comments
Production in
Europe (emissions
to air and water)
159 - 4293 217 - 5869 + 37% Emissions in Europe.
Evolution estimates based on the increase
in textile consumption and increase in the
share of synthetic materials
Production
outside Europe
(emissions to air
and water)
682 – 18 411 932 – 25 172 + 37% Emissions outside Europe.
Evolution estimates based on the increase
in textile consumption and increase in the
share of synthetic materials
Use phase –
wearing
(emissions to air)
37 – 25 367 42 – 28 438 + 12% Increase due to the increase in the share of
synthetic materials and population growth
Washing
(emissions to
water)
635 - 5506 714 - 6223 + 12% Increase due to the increase in the share of
synthetic materials and the evolution of
washing habits
Drying (emissions
to air)
137 – 7501 153 – 8410 + 12% Increase due to the increase in the share of
synthetic materials and population growth
End-of-life
(emissions to air
and water)
No quantified
data
No quantified
data
+ 37% Evolution estimates based on the increase
in textile consumption.
The evolution of the emissions linked to the
end of life corresponds to an overestimation
because no stock is considered.
The evolution of microplastic emissions varies between +12% and +37%, depending on the type of
emissions considered. Among the four parameters used to define the baseline scenario, the most
influencing parameters are:
• Increase in the consumption of clothing (for production and end of life)
• Increase in the share of synthetic materials (for wearing, washing and drying).
Note: According to CircularInnoBooster Fashion and Textile project, second-hand clothing accounts
for 2% of the total weight of the fashion and luxury goods sector in the world162
. This figure is
expected to grow by 15 to 20% over the next five years. At present, the market for second-hand
clothes is still limited. The use of second-hand clothes makes it possible to: reduce the consumption
of new clothes and therefore reduce production (thus avoiding microplastic emissions at this stage).
On the other hand, studies163, 164
show that microplastic emissions during care increase with the age
of the garment. Thus, emissions could increase during washing.
162
CircularInnoBooster Fashion and Textile project, ‘Second-hand fashion, a new impetus for clothing consumption’,
2021 (https://circoax.eu/second-hand-fashion-a-new-impetus-for-clothing-consumption).
163
Hann, S., Sherrington, C., Jamieson, O. et al., Investigating options for reducing releases in the aquatic environment
of microplastics emitted by (but not intentionally added in) products, Eunomia report for the Directorate-General for
Environment, 2018.
164
Textile Mission, ‘Textiles Mikroplastik reduzieren - Erkenntnisse aus einem Interdsziplinären Forschungsprojekt’
[Reducing textile microplastic emissions: Insights from an interdisciplinary research project], 2021
(https://textilemission.bsi-sport.de/fileadmin/assets/Abschlussdokument-
2021/TextileMission_Abschlussdokument_Textiles_Mikroplastik_reduzieren.pdf), De.
288
The following figures show the evolution of microplastic emissions between 2021 and 2030 for the
min and max values. In Figure 21, the microplastic emissions are expressed in tonnes/year. In Figure
22: the emissions are represented relative to 2021 emissions (i.e. 2021 = 100%). Microplastic
emissions increase by +25% or +21% depending on whether the min and max thresholds are
considered. There is not enough data to estimate what is the most plausible between min and max.
The average microplastic emissions were used to quantify the impact of the policy measures.
Figure 21: Evolution of microplastic emissions between 2021 and 2030 (in tonnes/year)
a) b)
Figure 22: Evolution of microplastic emissions between 2021 and 2030, a) for min thresholds, b) for max
thresholds
5.2.1 Uncertainty and data gaps
The uncertainty of the microplastic estimations is high. In the baseline, they vary between 2,058 and
74,111 t per year in the EU. The data quality is low for production and wearing life-cycle stages.
289
There is no data for the end-of-life. The uncertainty comes from the limited data to quantify
microplastic emissions and not from the baseline extrapolation (see following table).
Table 13: Microplastic emissions from synthetic textile per year in the EU27 - 2021
Production Washing Drying Wearing End-of-Life
Microplastic
emissions per year
due to EU
consumption
(tonnes)
[841 ; 22,704]
Of which 21%
happen in the EU
[635 ; 5506] [137 ; 7501] [37 ; 25,367] NA
Type of emissions Air / water Water Air Air Air / water
Data quality Low Medium Medium Low NA
Number of sources 1 6 4 2 0
These quantifications need to be refined along with standardised measurement methods in order to
understand the influence of each factor and to be able to compare data. Standardisation should specify
all the experiment criteria and impose only one measurement method to compare studies with one
another. No quantified data is available for microplastic emissions related to the end of life of
clothing. The following figure shows the evolution of microplastic emissions between 2021 and 2030
for the min and max values. There is not enough data to estimate what is the most plausible between
min and max. The average microplastic emissions were used to quantify the impact of the policy
measures.
Figure 23: Evolution of microplastics emissions between 2021 and 2030 (in tonnes/year)
290
5.3 Baseline for paints
Out of the 52 Mt of paint produced globally (in 2019), 19.5 Mt are plastic polymers165
. This
represented 5% of the total global polymer production that year. Paint has a high plastic content - on
average, 37% - and can be found on a wide range of objects and infrastructures used in our society:
cars, boats, indoor walls, buildings, and bridges, among others.
According to data provided by Statista, citing Kusumgar, Nerlfli & Growney as sources (but without
precise reference), paint volumes have grown steadily from 2009-2021, with yearly growth rates of
4%-9%. If we perform a linear fitting of this past trend and extrapolate it to 2030, we can expect that
globally 27 Mt of plastic polymer will be used in paint.
The results presented hereafter are an extract from the global EA assessment Paruta et al., 2022. The
analysis focuses on paint microplastic release to the environment during the application, wear and
tear, removal of paint or handling of the painted object when it reaches its end of life.
It is important to highlight that loss rates are poorly documented both in the scientific and grey
literature; therefore, an accurate assessment is not feasible at the moment. The following sections
present an estimate of the order of magnitude of the paint leakage to determine whether paint
represents a significant contribution to the total plastic leakage. To navigate through this data-scarce
environment, expert assumptions have been used for some of the model parameters.
The first thing to estimate is the paint demand by sector. Figure below shows the way plastic polymers
were used across the different paint sectors in EU-27 in 2019. The architectural sector ranked first
with 42% of the total input, followed by the automotive and marine sectors with 17% and 15%,
respectively.
Figure 24: Yearly input of plastic in paint by sector for EU-27, data for 2019.
The total amount of plastic content of paint used in 2019 in the EU was 2,326 thousand tonnes, of
which 628 kt/year leaked into the environment. The majority of this leakage was in the form of
165
Market research from MarketsandMarkets Research Private Limited
Architecture Automotive Marine General Industrial
Industrial wood Road markings Others
General
Industrial
Automotive
Marine
Industrial
wood
Road
markings
Architectural
Others
42%
17%
15%
11%
9%
1% 4%
Input of plastic in paint by
sector
291
microplastics, for a total of 482 kt/year, of which 298 kt/year was leaked to the ocean and waterways
and 145 kt/year to land. Despite the uncertainties arising from the leakage calculation, it is clear from
this study that the majority of applied paint does not benefit from proper management during
maintenance or end-of-life.
Figure 25: Total amount of plastic in paint each year for the six sectors, EU27
Figure above shows the plastic from paint in leaked and well-managed fractions. The plastic leakage
amount is divided into its fractions of micro- and macro-plastics and the amounts that end up in the
environment (Ocean & Waterways and Land). On the right side, the picture shows the shares of each
sector to the total microplastic leakage. In terms of microplastic leakage to the environment, the
marine sector is the largest contributor to the total leakage (46%), while industrial wood is the least
important one (1%).
Figure 26: Contribution by loss mechanism of the microplastic leakage to the environment (Land and
Ocean & Waterways)
The paint leakage is mainly due to wear & tear (41%) and removal (29%) loss mechanisms (Figure
26). About 16% of the micro-leakage happens at the end-of-life (EoL) of the painted object. In this
case, the losses are associated with the practice of shipbreaking of European commercial vessels,
which takes place on the beaches of India, Bangladesh, Pakistan, China and for a small part (3.5%)
in Turkey (UNCTAD, 2019). All the six sectors contribute to the total leakage, with leakage rates
ranging from 2% (industrial wood) to 63% (marine sector) (Table 14), where the leakage rate is
defined as the ratio between the microplastic leakage to the environment and the total plastic input.
292
Table 14 presents the overview of the total leakage contribution for both environmental
compartments of each sector and its split between micro- and macro-leakage.
Table 14: Overview of plastic leakage from paint by sector, for EU-27 (2019), in kt
The results are obtained following the approach described in Paruta et al. 2022. The values are in
thousand tonnes (kt), and they refer to plastic quantities. In the case of marine paints, the microplastic
leakage to the environment includes paint lost during maintenance and shipbreaking of European
vessels in other countries, for a total of 127 kt. Furthermore, the paint lost while European vessels
are at sea has been allocated to the EU – 27 countries, for a total of 68 kt.
In the following sub-sections, we provide an insight into the analysis by sector to illustrate how paint
flows across the various stages of its life cycle before reaching its final fate.
293
5.3.1 Architectural
Figure 27: The Sankey diagram of the flow of plastic in architectural paint (2019)
Paint can be lost before reaching its supporting material (application), it can detach from it (wear and
tear or removal), or it can be disposed of with or without it (unused or end-of-life). Ultimately, the
lost paint can be well managed (disposed to a sanitary landfill or incineration facility), embedded in
new products, or leaked to land or oceans and waterways. Here we highlight the part of the leakage
that happens in the form of microplastics. In 2019, 1,019 kt of plastic was used in architectural paint
within the EU-27 countries. This includes paint used on interior and exterior surfaces. About 71% of
the plastic is from paint used on interior surfaces (Hann et al., 2018). The predominance of interior
paint is intuitively justified by the fact that there is more interior than exterior surface to paint and
that interior paint is re-painted more frequently than exterior due to aesthetic purposes. The amount
of architectural paint used in the EU-27 was estimated using the following sources:
• The total amount of plastic used for architectural paint globally, i.e. 10,801 kt according to
MarketsandMarkets Research Limited;
• The number of households in EU-27 is computed as the total population divided by the
average number of people per household (United Nations, 2019. Database on Household Size
and Composition 2019). Total population by country as reported by the World Bank "What a
Waste" database 2.0 (Kaza, S. et al., 2018).
The number of households is not the only parameter that impacts the amount of paint used. The
income level, the paint type, the weather, and the building material could be additional factors
influencing the paint consumption by region. However, they have not been considered here, as no
models are available to determine the quantitative impact on the paint used. Nonetheless, according
to Hann et al., 2018, 947 kt of plastic was used in architectural paint in Europe in 2018, which is
closed to the estimate presented here of 1,019 kt for 2019.
294
Figure 28: Sankey diagram focusing on the portion of architectural paint that ultimately leaks to the
environment in the form of microplastic
Overall, 12% of the plastic in architectural paint put on the EU market leaks into the environment in
the form of microplastics, i.e. a total of 121 kt. Of this, 93 kt leaks to land, while 28 kt to oceans and
waterways. The leakage is mainly due to exterior paint being lost to the surroundings due to wear &
tear and paint removal done without ensuring paint collection. Some of the paint is also lost to the
environment during the application, either because of overspray of exterior paint or rinsing brush or
rollers for interior and exterior paint. Although losses related to overspray are estimated at 15% (85%
transfer efficiency), architectural paint is mostly applied by brush or roller, which accounts for 1.6%
of paint losses to wastewater.166
This assessment assumed that interior paint is always applied by
brush or roller and that exterior paint is applied 80% of the time by brush or roller.
We estimate that a large part (68%) of the paint applied to a building will stay on until its demolition
(end-of-life). Dust formation during demolition is a known phenomenon, and it has been investigated
mostly because fine particles suspended in the air are known to be hazardous to human health167
.
Lacking quantitative estimates, we assume 10% of the paint that is still on the walls during demolition
is lost to the environment as dust. The remaining paint follows the end of life of the supporting
material. Both concrete, wood and plasterboard (the main support of interior paint) can be recycled.
The EU had set a mandatory target of 70% recovery rate of construction and demolition waste by
2020 and concrete is mostly recycled as granulate that is then used in backfilling or road
foundations168
. On average, in the EU, 83% of the mineral waste from construction and demolition
was "recycled" in 2016169
. Plasterboard, which is mainly made of gypsum, can be recycled into new
plasterboard through mechanical grinding, and it is then refined to have a uniform texture and be re-
used to form plasterboards. According to British Gypsum, a UK manufacturer of interior lining
systems, paper flakes (coated with paint) can be separated from gypsum during the recycling process
and used as cattle bedding170
. The hazardous risk to the health of the animals and the food chain
safety linked to this practice is still to be investigated. Finally, painted or varnished wood is
166
A.J. Verschoor and E. de Valk, RIVM 2017, Potential measures against microplastic emissions to water, RIVM
Report 2017-0193
167
Ebadian et al. Technology assessment of dust suppression techniques applied during structural demolition, 1996
168
Wahlström, M., Bergmans, J., Teittinen, T., Bachér, J., Smeets, A., & Paduart, A. (2020). Construction and
Demolition Waste: challenges and opportunities in a circular economy.
169
European Environment Agency, 2021. Accessed on https://www.eea.europa.eu/publications/construction-and-
demolition-waste-challenges/construction-and-demolition-waste-challenges
170
British Gypsum (2021). Accessed on 21/10/2021. https://www.british-gypsum.com/about-us/csr/environmental-
challenges/plasterboard-recycling
295
sometimes considered recyclable to produce wood chippings for plywood or particle board. In
another context, regulation asks for painted wood to be disposed of as waste.
Overall, knowledge of paint losses during demolition and recycling practices of the support material
(EoL) is lacking. They appear to be outside the scope of this assessment on the unintentional release
of microplastics. However, the proper management of paint at the EoL needs attention since most of
the paint is left on the building material until its end-of-life and the management of the construction
and demolition waste stream still remains a challenge.
5.3.2 Marine
Figure 29: Sankey diagram of flow of plastic in marine paint (2019)
Paint can be lost before reaching its supporting material (application), it can detach from it (wear &
tear or removal), or it can be disposed of with or without it (unused, end-of-Life). Ultimately, the lost
paint can be well managed (disposed to a sanitary landfill or incineration facility), Embedded in new
products, or can leak to land or oceans and waterways. Here we highlight the part of the leakage that
occurs in the form of microplastics.
In 2019, 357 kt of plastic was used in marine paint within the EU-27. This includes plastic used in
marine paint for commercial vessels (84%) and leisure vessels, both professional and Do It Yourself
(DIY)171
. Marine paint can be applied to the interior of the boat, the superstructure, or the hull, and
antifouling paint is applied above the hull and protects the boat from biofouling. The amount of
marine paint applied on boats and vessels in the EU-27 was estimated using:
171
Hann et al. 2018 Investigating options for reducing releases in the aquatic environment of microplastics emitted by
(but not intentionally added in) products
296
• The total amount of plastic used on boats and vessels paint globally, i.e. 10,801 kt, according
to MarketsandMarkets Research Limited172
• The share of commercial vessels and leisure boats that are owned by EU-27
The share of commercial vessels is computed based on the UNCTAD database, which provides the
ownership of propelled seagoing vessels of 1000 gross tonnes and above by dead-weight tonnage.
Overall, this leads to a 36% share attributed to the EU (2017 data). If we were to base the assessment
only on container-carrying vessels, the share would be 45%173
. Leisure boats share is based on the
share of recreational global boat park per country, as provided by ICOMIA174
.
It is worth highlighting that most of the paint applied on commercial vessels is not applied in
European drydocks but in Asia. In this analysis, we account for all paint that is applied on European
vessels independently of where the maintenance takes place. Overall, 63% of the plastic in the paint
applied on European vessels will leak into the environment in the form of microplastics, for a total
of 223 kt/year, of which 210 kt leaks to land, while 13 kt to ocean and waterways.
There are three main pathways of microplastic leakage to oceans and waterways:
• Wear and tear of exterior boat paint at sea;
• Removal of paint during maintenance of commercial vessels at the dry dock (mostly in Asia),
or of leisure vessels, mostly in the EU;
• End of life of commercial vessels at ship graveyards.
Other minor pathways are maintenance of superstructure paint that takes place while the vessel is at
sea. Little is known about the waste management of paint at drydocks. If sand blasting is used, paint
dust can travel hundreds of meters before depositing175
. The world commercial fleet is dismantled in
ship graveyards on the beaches of India, Bangladesh, Pakistan, China, and for a small part (3.5%). In
Turkey176
. In Bangladesh, India and Pakistan, ships are broken apart directly on the beach instead of
on an industrial site (NGO Shipbreaking Platform, 2021). Therefore, a portion of the commercial
paint that is left on the ships will be lost to the ocean.
About 57% of microplastic leakage to the environment occurs in drydocks or beaches outside Europe,
for a total of 127 kt.
172
Market research from MarketsandMarkets Research Private Limited
173
UNCTAD (United Nations Conference on Trade and Development). (2017, October). Review of Maritime Transport
2017. Geneva: United Nations.
174
ICOMIA (International Council of marine Industry Associations). (2018). Recreational boating industry statistics
2017
175
Swedish Environmental Protection Agency, Report n° C183 - ‘Swedish sources and pathways for microplastics to the
marine environment’, 2016
(https://www.ivl.se/download/18.7e136029152c7d48c205d8/1457342560947/C183+Sources+of+microplastic_1603
07_D.pdf).
176
UNCTAD (United Nations Conference on Trade and Development). (2017, October). Review of Maritime Transport
2017. Geneva: United Nations.
297
5.3.3 General industrial
Figure 30: Plastic flow in general industrial paint from the net input to the fates (2019)
In 2019, 269 kt of plastic was used for general industrial paint in the EU-27. General industrial paint
is considered here the protective paint used to protect steel or metal surfaces from corrosion. It is
used in the oil & gas sector (refineries, pipelines, offshores), petrochemical sector, power generation
applications, water and waste treatment, and many other applications.
The amount of general industrial paint used at the EU - 27 level was estimated using the following
sources:
• The total amount of plastic used for general industrial paint globally, i.e. 2,915 kt, according
to MarketsandMarkets Research Limited177
• It is assumed that steel is the main surface on which general industrial paint is applied. The
share of paint used in Europe is based on the steel used by country in 2018, as provided by
World Steel Association, 2021178
Overall, 37% of the plastic in general industrial paint put on the EU market leaks to the environment
in the form of microplastics, for a total of 102 kt. Of this, 55 kt leak to land, while 47 kt to oceans
and waterways. The leakage is mainly due to losses during the application, wear and tear and removal.
Many aspects surrounding paint practices by the general industrial sectors are undocumented. It
would be crucial to know the paint distribution within the sub-sector in the different EU-27 countries.
How much of the paint is destined for structures that are close to aquatic environments (e.g. offshores,
underwater pipelines, bridges)? The maintenance frequency and general practices are also not clear.
General industrial is the sector where data is the scarcest.
177
Market research from MarketsandMarkets Research Private Limited
178
World Steel Association (2021). 2021 World steel in figures
298
5.3.4 Road markings
Figure 31: Flow of plastic in road markings paint from the net input to the fates (2019)
In 2019, 36 kt of plastic was used for road markings paint in EU-27 countries. Hann et al., 2018 lists
four different types of paint (solvent-based, water-based, thermoplastics, cold plastics) and provides
their demand in the European market. The different paint types have different compositions and
plastic content. The amount of plastic used for road markings paint used at the EU-27 level was
estimated using the following sources:
• the total amount of plastic used for road markings globally, i.e. 234 kt according to
MarketsandMarkets Research Limited179
• the kilometres of road country, as reported by CIA180
Overall, 56% of the plastic in the road markings paint will leak to the environment in the form of
microplastics, for a total of 20 kt. Of this, 10.5 kt leak to land, while 9.5 kt leak to ocean and
waterways. The main pathway for road markings losses to the environment is wear and tear from
mechanical abrasion, and this is primarily due to contact with vehicle tyres. Another possible pathway
leading to losses of microplastic in the environment could be during the road markings, paint removal
to redesign traffic lanes, parking slots, etc. Removal of paint for redesign can be performed in several
ways: blasting, grinding, using lasers, chemical methods and even burning181
. The literature mentions
dust formation (in the case of grinding) as a health concern to the removal workers. Still, no evidence
has been found of pollution due to the removed paint being uncollected. Interviews conducted with
road marking companies in Switzerland affirmed that the removed paint is collected independently
from the technique used. Assuming a similar situation in the EU, about 90% of the paint is collected
and disposed of as solid waste in EU-27, and 10% is left on the road in the form of finer dust particles
and uncollected.
179
Market research from MarketsandMarkets Research Private Limited
180
CIA. (2021). Roadways. Accessed on 9/11/2021. https://www.cia.gov/the-world-factbook/field/roadways/
181
Pike, A. M., & Miles, J. D. (2013). Effective removal of pavement markings (Vol. 759). Transportation Research
Board.
299
5.3.5 Automotive
Figure 32: Flow of plastic in automotive paint from the net input to the fates
In 2019, 422 kt of plastic were used for automotive paint in EU-27 countries. About 71% of the paint
is used for automotive OEM, applied during the car manufacturing process, and 29% for automotive
refinish, applied at a later stage, for example, due to accident damage, damage to the original paint
system, or to change the car colour.
The amount of automotive paint used at the EU-27 level was estimated using the following sources:
• the total amount of plastic used for automotive paint globally, i.e. 2'041 kt according to
MarketsandMarkets Research Limited182
• for automotive OEM, the shares of motor vehicles manufacturing by country in 2019, as
provided by OICA183
.
• the share of automotive Refinish is based on a dataset of motor Vehicles per 1000 people by
country. The data set is published on OurWorldInData184
, which cites NationMaster185
as the
source.
182
Market research from MarketsandMarkets Research Private Limited
183
OICA (2022). International Organization of Motor Vehicles Manufacturers. 2019 Production Statistics.
https://www.oica.net/category/production-statistics/2019-statistics/
184
OurWorldInData, 2014. Accessed on 25/10/2021. Motor vehicles per 1000 inhabitants vs GDP per capita, 2014.
https://ourworldindata.org/grapher/road-vehicles-per-1000-inhabitants-vs-gdp-per-capita
185
NationMaster, 2014. Accessed 25/10/2021. Motor vehicles per 1000 people: Countries Compared.
https://www.nationmaster.com/country-info/stats/Transport/Road/Motor-vehicles-per-1000-people
300
Figure 33: Portion of automotive paint that ultimately leaks to the environment in the form of
microplastics
Overall, 3% of the plastic in automotive paint put on the EU market leaks to the environment in the
form of microplastics, for a total of 12 kt. Of this, 9 kt leak to land, while 3 kt to oceans and
waterways. One of the main pathways for microplastic leakage is the loss at the application of refinish
paint.186
The transfer efficiency of spray guns in body shops is as low as 50%, and an interview with
industry experts put the figure closer to 60%. We assume that only a minor part of the over-sprayed
paint will be lost to the environment, while the rest will deposit on masking material and will be
disposed of with it.
The wear and tear losses include flaking and chipping of the paint due to weathering (such as
exposure to ultra-violet sun rays), but also due to accidents and collisions. According to an interview
with an automotive paint expert, these types of losses are minimal. Therefore, we assume a 2% loss
rate even though, according to OECD, flaking and chipping losses of automotive paint are quantified
at 10% (after rescaling by the OECD application losses).187
5.3.6 Industrial wood
Figure 34: Flow of plastic in industrial wood paint from the net input to the fates
In 2019, 223 kt of plastic was used for industrial wood paint in EU-27 countries. We did not
distinguish between the possible direct applications of industrial wood paint. It is typically applied
186
OECD (2009) Emission Scenario Document On Adhesive Formulation, 2009
187
OECD (2009) Emission Scenario Document On Adhesive Formulation, 2009
301
on wooden surfaces such as “joinery, kitchen cabinets, furniture, flooring, millwork, speciality wood
products, and exterior building products” (American Coatings Association, 2018)188
.
The amount of industrial wood paint used at the EU-27 level was estimated using the following
sources:
• the total amount of plastic used for Industrial Wood paint globally, i.e., 1,232 kt, according
to MarketsandMarkets Research Limited189
• the EU-27 share is determined based on the wood consumption by country. FAO online
database "Forestry Production and Trade" 190
allows to select the specific wood application
and track their production and trade around the world. The applications selected for this study
are hardboard, MDF/HDF, OSB, other fibreboards, particle board, plywood, sawn wood, and
veneer sheet. The reference year is 2019.
Overall, 2% of the plastic in industrial wood paint put on the EU market leaks to the environment in
the form of microplastics, for a total of 3.4 kt, of which, 3.2 kt leak to land, while 0.2 kt leak to ocean
and waterways. According to OECD191
analysis of the wood furniture sector, around 50% of the paint
is lost at the application when using a dry booth (other techniques being wet booth or curtain coating).
We assume that application takes place in an industrial setting and that the over-sprayed paint is dealt
with as solid waste.
5.3.7 Data gaps and uncertainties
Microplastic pollution from paint has only recently been investigated, for this reason there are still
many uncertainties and data gaps.
Some uncertainties and data gaps are relative to market figures of paint sold per paint sector and
plastic content within it. In order to estimate microplastic pollution one needs to know on which type
of objects the paint is applied, but often market data are split by type of paint sold or sectors such as
"coil coatings” which are not easily related to the final painted object. Therefore, a common
understanding between scientific community and paint industry is needed in order to gain insight on
the paint market in a way that is useful for microplastic calculations.
In terms of paint loss mechanisms (application, wear & tear, removal, unused, at end-of-life), the
estimates used in this assessment are mostly conservative. An example of conservative estimate
performed in the study are paint losses due to overspray, which are modelled to be at 15%, i.e., 85%
transfer efficiency (Paruta et al. 2022). This performance is well above that of some technologies
listed in the Best Available Techniques Conclusions document, related to the Industrial Emission
Directive, (Chapter 4 of the Directive 2010/75/EU on Industrial Emissions (the Directive)), which
have transfer efficiency of 50%-60%. A transfer efficiency of 60% means that 40% of the applied
paint is lost to the surrounding environment.
Another example is unused paint. It is believed that, on average, 3%192
of professional paint and 15%
of DIY paint are unused (Verschoor, A., De Poorter, L., Dröge, R., Kuenen, J., & de Valk, E. (et al.,
188
www.paintcare.org
189
Market research from MarketsandMarkets Research Private Limited
190
Forestry production and trade, 2021. Accessed on 25/10/2021. Forestry production and trade.
https://www.fao.org/faostat/en/#data/FO
191
OECD (2009) Emission Scenario Document On Adhesive Formulation, 2009
192
OECD (2009) Emission Scenario Document On Adhesive Formulation, 2009
302
2016,).193
These are the same values used in this assessment, but, according to a personal
communication with ADEME (the French agency for ecological transition), paint cans recovered
through an EPR scheme targeting household chemicals are, on average, 40% full. Additionally, an
internal paint company document indicates that 30-40% of paint prepared for an offshore
maintenance job can end up being unused and subsequently disposed of. Furthermore, this
assessment assumes all unused paint to be properly disposed, while a personal conversation with an
industry expert revealed that according to their own experience, disposal of paint down the household
drainage system is common practice for both professionals and DIYers.
For wear & tear losses, the lifetime of the paint system is not a subject that is systematically
researched and assessed, but its assessment is key in order to determine microplastic pollution during
the use phase of the object.
From the modelling point of view, a key assumption in Paruta et al. 2022, is that “Wear & Tear”
happens in a localized fashion, meaning that if the outmost layer of paint (top-coat) is affected in a
certain place, then the deeper layers will also be affected." This has important consequences on the
assessment of wear & tear losses. The hypothesis was formulated after discussing with paint industry
experts, but it should be validated through testing on the ground. Other sector-specific assumptions
that were used to overcome uncertainty and data-gaps are mentioned in the baseline itself, and more
can be found in Paruta et al. 2022, but the aforementioned data gaps are believed to be the key ones
to investigate in order to improve the baseline assessment, namely:
• Volumes (in mass) of paint sales per sector (with sector split based on final painted object) as
well as plastic content (in mass);
• Average transfer efficiency of spraying technologies;
• Volumes of unused paint and its fate;
• Lifetime of paint (see Measure PNT#1);
• Validation of the assumption that wear & tear happens in localised form and affects all paint
layers.
5.4 Baseline for detergent capsules
Among the water-soluble plastic films available for the protective film for laundry and dishwasher
detergents, polyvinyl alcohol (PVOH) is the most widely used. With a yearly global production of
650 000 tons, PVOH is therefore becoming more and more used with an annual growth rate of 4%
between 2018 and 2023. In Europe, around 100 000 tonnes of PVOH is estimated to be used every
year, of which 20 000 tonnes are used as protective films for detergent capsules.194
A similar growth
rate is expected for the coming years.
5.4.1 Calculation of the baseline
To define the baseline about the loss of detergent capsules into the environment, we have estimated
their contributions following both bottom-up and top-down approaches.
193
Release of microplastics and potential mitigation measures: Abrasive cleaning agents, paints and tyre wear, OECD,
2009.
194
Renewable Carbon, ‘BioSinn – Products for which biodegradation makes sense’, 2021.
303
In our bottom-up approach, we used the data about the number of washes per household in Europe
as provided in our report and this article195
for data on laundry capsules. It roughly estimates the
amount of PVOH released into the environment as follows.
Number of wash cycles in the EU: 34 000 000 000
Weight of the shell of a capsule: 0.4g – 1.6g (we will use 1g as the average value)
Share of PVOH in a capsule shell: 65% - 99% (we will use 85% as the average value)
The survey performed in the US study evaluates capsule usage at 70% of all laundry detergent use,
but there is no information available regarding the European use of capsules and we assume the EU
situation comparable to the US. Upon this assumption, we can use a conservative estimation of 50%
capsule usage since, in the EU, powder and liquid detergents are more or less used in the same
proportion as the US.
By considering the share of washes done using capsules (50%), the total amount of PVOH entering
wastewater due to detergent capsules is:
T = 34 000 000 000 * 1g * 0.85 * 0.50 = 14 450 tonnes per year
To estimate dishwasher capsules' contribution, we assumed that 45% of European households are
equipped with a dishwasher196
and the number of cycles per household per year (280)10
. As there are
195 455 million households in Europe197
, the dishwasher capsule shell weighs 0.3g – 0.7g (we use
0.5g as the average). Moreover, the dishwasher capsule shell has the same composition as detergent
capsules.
As no information on dishwasher capsule usage in Europe could be found and considering the US
situation, we assumed that the number of dishwasher cycles per year is close to that of Europeans
(280 cycles), i.e., 34% of the time.
Thus, the total amount of PVOH entering wastewater due to dishwasher capsules is:
195 455 000 * 0.45 * 280 * 0.34 * 0.5g * 0.85 = 3 559 tonnes per year
The total microplastics emitted to wastewater from the use of detergent capsules and dishwasher
capsules can be estimated at 18 009 tonnes per year.
This number is a rough estimation but remains close to the value reported by Nova Institute in a
bottom-up approach. The EU market for dishwasher tabs with water-soluble film is around 400 000
195
Rolsky, C. and Kelkar, V., Degradation of Polyvinyl Alcohol in US Wastewater Treatment Plants and Subsequent
Nationwide Emission Estimate’, International Journal of Environmental Research and Public Health, Vol. 18, no.
11: 6027, 2021.
196
APPLiA, ‘What if all Europeans had a dishwasher?’, 2021, Accessed November 19th
2021 (https://www.applia-
europe.eu/images/2017-03---DW-campaign-analysis.pdf).
197
Eurostat, ‘How many single-parent households are there in the EU?’, 2021
(https://ec.europa.eu/eurostat/web/products-eurostat-news/-/edn-20210601-
2#:~:text=In%202020%2C%20there%20were%20195.4%20million%20households%20in,single%20parents%2C%
20accounting%20for%204%25%20of%20total%20households).
304
tonnes annually, corresponding to 20 billion tabs of 20 grams each. The film itself weighs less than
1 g, which puts its total volume in the EU at around 20 000 tonnes.198
In another bottom-up approach199
, the recent data provided by International Association for Soaps,
Detergents and Maintenance Products (A.I.S.E.) indicates that 20.5 ktonnes of dissolved capsules in
2021 were emitted from the use of liquid laundry detergent capsules (8.4 kt), automatic dishwashing
tablets (12.1 kt) and WC care products (0.03 kt) in the EU, including Norway (non-EU member) in
this estimation. We must highlight that even if Norway as a non-EU member is included in these
estimations, the contribution of this country with respect to the EU doesn’t impact the overall
emission of PVOH grades in the EU. In the case of the first two categories (i.e., liquid laundry
detergent capsules and automatic dishwashing tablets), we assumed that 5% of the total capsule or
tablet was exclusively derived from PVOH based on the NOVA report200
.
Table 15: Liquid laundry detergent capsules – retail volume (in kilotonnes)*
2017 2018 2019 2020 2021
EU+Norway 103.2 121.1 137.3 152.6 167.1
PVOH release** 5.2 6.0 6.9 7.6 8.4
* AISE reports that these figures may be slightly underestimated based on their own PVOH consumption. (which may
also include internal wastage). The population of Norway is about 1% of that of the EU.
** Based on a conservative assumption of max. 1g PVOH film per capsule (5%).
Table 16: Automatic dishwashing tablets – retail volume (in kilotonnes)*
2017 2018 2019 2020 2021
EU+NO 197.5 202.0 209.2 237.3 242.9
PVOH release** 9.9 10.1 10.5 11.9 12.1
* AISE member reports that these figures may be slightly underestimated based on their own PVOH consumption (which
may also include internal wastage). The population of Norway is about 1% of that of the EU.
** Based on a conservative assumption of max. 1gPVOH film per capsule (1% - values to be confirmed by AISE).
However, we made the same assumption as in the case of liquid laundry detergent capsules) to be comparable to the
estimations made in the NOVA report, i.e., 5%.
NB. Euromonitor provides sales data for all tablets without differentiation between wrapped/unwrapped or
removable/soluble film.
Moreover, WC care products contain a small proportion of toilet cleaning products, such as rim
hangers and cistern blocks, corresponding to an estimated total PVOH quantity of 0.03 kt/annum
in 2021.
In Table 17, a US study201
indicates that 61% and 18% of PVOH fractions reached the sludge route
and the aqueous route (via soil contamination)) respectively. However, the estimations about the 18%
losses out of wastewater treatment plants must be considered prudently as the study was conducted
198
Renewable Carbon, ‘BioSinn – Products for Which Biodegradation makes sense’, 2021 (https://renewable-
carbon.eu/publications/product/biosinn-products-for-which-biodegradation-makes-sense-pdf/).
199
Annex AISE (sent on April 27th
, 2022).
200
Annex AISE (sent on April 27th, 2022).
201
Rolsky, C.; Kelkar, V. Degradation of Polyvinyl Alcohol in US Wastewater Treatment Plants and Subsequent
Nationwide Emission Estimate. Int. J. Environ. Res. Public Health 2021, 18, 6027.
305
in India (Kaur et al., 2012)202
and do not correspond to the situation in the EU. In Europe, we may
therefore assume that the situation about the wastewater treatment (even if soil contamination cannot
be excluded) is almost optimal, assuming that nearly 50-60% of PVOH and related mixtures shall
reach the sludge route and the other fractions 40-50% shall reach the environment, but no studies
have addressed this issue after wastewater treatment plants up to now.
Considering the biodegradation level reported in OECD testing, i.e., a simulated degrading
environment representative of wastewater treatment plants, 40% of non-biodegradable PVOH could
release into the environment using the data reported in the study. Indeed, this study considered a 28-
day window while 10 days is the average length of time usually considered for wastewater treatment
plants. Other studies have shown that biodegradation of PVOH in acclimated wastewater systems
can be even enhanced and reach a degradation rate close to 80% as suggested by Schonberger et al.
(1997)203
. Several conditions must be encountered: (1) steady PVOH influx, (2) sufficiently low food
to microorganisms and sufficiently high sludge age and (3) adaptation of the microorganisms (as a
rule demands several weeks). The fate of PVOH after wastewater treatment remains challenging as
specific approaches (e.g., radioisotope labelling) will have to be developed accordingly. After
wastewater treatment, the trace of PVOH has never been reported due to the difficulty of assessing
their presence using classical detection techniques to their high solubility in water, and their impact
may somehow be underestimated by contrast with microplastics well-identified in sewage sludge204
.
Additional investigations shall be made to assess this.
Table 17: Assessment of PVOH release of detergent capsules into the environment via the sludge route
Source Geography Sectors PVOH leakage to
wastewater
treatment plants,
Tonnes
PVOH release
into the sludge
in % related to
the leakage
PVOH
release into
sludge,
Tonnes
PVOH release into
the environment,
Tonnes (40% from
sludge)
BOTTOM-UP
APPROACH
Nova Institute,
2021
Byrne 2020
EU-27 Protective films
for laundry and
dish detergents
Garden pond
20 000 20-40% 4 000-
8 000
1 600-3 200
BOTTOM-UP
APPROACH*
AISE
EU-27 Liquid laundry
detergent
capsules
Automatic
dishwashing
tablets
20 500 20-40% 4 100-8
200
1 640-3 280
TOP-DOWN
APPROACH
EU-27 Protective films
for laundry and
dish detergents
18 000 20-40% 3 600-
7 200
1 440-2 880
(*) Including Norway. Excluding Norway, the estimates would approach the Nova Institute figures.
In the EU, the overall amount of PVOH leakage issued from protective films for laundry and dish
detergents is estimated to be around 18 000 – 20 000 tonnes annually using different approaches
(bottom-up & top-down) obtained from technical literature and stakeholder information. As the
202
Kaur et al. Wastewater production, treatment and use in India, 2012
203
Schonberger, H., Baumann, A. and Keller, W., ‘Study of microbial degradation of polyvinyl alcohol (PVA) in
wastewater treatment plants’, American Dyestuff Reporter, Vol. 86, 1997, pp. 9-18.
204
Chand, R., Rasmussen, L.A., Tumlin, S. and Vollertsen, J., ‘The occurrence and fate of microplastics in a mesophilic
anaerobic digester receiving sewage sludge, grease and fatty slurries’, Science of the Total Environment, Vol. 798,
2021, Elsevier BV.
306
PVOH issued from protective films for laundry and dish detergents is directly discharged into urban
wastewater, the overall amount related to PVOH leakage is exclusively through waste water followed
by sludge. In the wastewater treatment plants, around 60-80% of the overall amount of PVOH is
totally biodegraded, and the remaining fraction, i.e., around 20-40%, is mainly released to the sludge
from which the ultimate release of PVOH in the environment is not properly assessed from the current
scientific literature. This means that from the microplastics released into wastewater treatment plants,
around 3 600-8 000 tonnes reach the sludge. In the EU, about 40% of sludge is applied on agricultural
land. Assuming that about 40% (EU average) of this sludge is applied to agricultural land, i.e. 1 440-
3 280 tonnes. Of this, about 60% will reach natural waters and the rest remain in the soil. Recent
evidence shows that microplastics in soil could also be taken by the crops.205
There is only one study estimating the PVOH release in the environment directly through wastewater
at 15.7%206
, which would represent around 2 700 tons a year for the EU. The PVOH in water could
biodegrade over a period of time, but the extent of biodegradation in natural conditions has not been
studied. The possible non-biodegraded part of PVOH could still remain in the water.
Adding the share of PVOH through aqueous and sludge routes, we can assume that 4 140 – 5 980
tonnes (thus on average around 5000 tonnes) of microplastics coming from PVOH of detergent
capsules would be directly released into the environment.
5.4.2 Uncertainties and data gaps
The estimated amount of microplastic losses through capsules to the environment bears several
uncertainties. The principal uncertainty comes from a lack of information on the composition of
PVOH and related mixtures used for detergent capsules due to trade secrets and uncertainties about
the fate of PVOH in WWTP and later in the marine environment and soils upon the existing testing
protocols as:
• Initial discussions with the International Association for Soaps, Detergents and Maintenance
products/AISE (March 12th, 2022) highlighted that the current PVOH and related mixtures
used for detergent capsules are trade secrets due to their long history of implementation as
water-soluble plastics not only in detergent applications but other applications. The report
made by AISE (April 27th
, 2022) has reduced the uncertainties on the PVOH release even
though the AISE members report that these figures may be slightly underestimated based on
their PVOH consumption (which may also include internal wastage). However, no better
basis is currently available to calculate quantities of film placed on the market/released by
dissolution during use.
• The testing protocols used for assessing the biodegradation extent of PVOH and related
mixtures are related to OECD norms in which a 28-day duration is applied during testing.
However, it could be affected because these PVOH and related mixtures are associated with
mixtures and/or contaminated with detergents.
• Depending on the characteristic features of wastewater systems, a PVOH biodegradation in
acclimated wastewater systems could reach a degradation rate close to 80%, as referenced by
205
Sciencealert.com, ‘Study shows how microplastics can easily clim the food chain. Should we be worried?’, 2022
(https://www.sciencealert.com/study-shows-how-microplastics-can-easily-climb-the-food-chain-should-we-be-
worried).
206
Rolsky, C.; Kelkar, V. Degradation of Polyvinyl Alcohol in US Wastewater Treatment Plants and Subsequent
Nationwide Emission Estimate. Int. J. Environ. Res. Public Health 2021, 18, 6027.
307
Schonberger et al. (1997)207
, but this need to be confirmed. There exist some more appropriate
protocols (e.g., EU ECOLABEL)208
.
5.5 Baseline for geotextiles
According to the supporting study for this IA, a total of 530 712 tonnes of geotextiles were used in
the EU in 2019 and since 2002, 5 048 962 tonnes of geotextiles have been installed.209
Geotextiles
are used for various construction applications, from building roads to protecting coasts from erosion
and enabling vegetation to root. Because of climate change, sea levels are rising, and the intensity of
storms is increasing, which in turn will increase the demand for geotextiles. Various market
projections suggest a threefold growth in the geotextiles market in Europe during 2019-2029210
, and
one can expect similar growth in emissions.
5.5.1 Calculation of the baseline
Different market data were compiled to estimate the quantities of geotextiles used worldwide yearly.
Table 18: Existing sources on geotextile use and microplastics emissions
Source Year of
estimate
Geotextile
quantity
Geotextile type Emissions
Bai, Xue et al.211
2021 14 billion m2 All types, 2% natural
fibre, 17% PET-based
materials
0.24 – 0.79 million tonnes emitted by
PET geotextiles. However the findings
of this study have been strongly
criticised for their unreliability.
Prambauer et al.
212
2019 1.4 billion m2 All types, 2% natural
fibre
Methacanon 213
2010 700 million m2 All types, 2% natural
fibre
US Department
of Agriculture 214
1991 700 million m2 All types, 2% natural
fibre
Own
calculations
2021 530 712 tonnes
(EU)
2 653 560 tonnes
(worldwide)
All types, 62.5% non-
woven textiles, 27.5%
woven, 10% other
207
Schonberger, H., Baumann, A. and Keller, W., ‘Study of microbial degradation of polyvinyl alcohol (PVA) in
wastewater treatment plants’, American Dyestuff Reporter, Vol. 86, 1997, pp. 9-18.
208
European Commission, ‘EU Ecolabel’, EU Ecolabel - Home (europa.eu).
209
Grand View Research Inc, ‘Geotextiles Market Size & Share, |Industry Report, 2020-2027’, 2022
(https://www.grandviewresearch.com/industry-analysis/geotextiles-industry).
210
Ibid.
211
Bai, X., Li, F., Ma, L. and Chang, L., ‘Weathering of geotextiles under ultraviolet exposure: A neglected source of
microfibers from coastal reclamation’, Science of the Total Environment, Vol. 804, 2022, Elsevier BV.
212
Prambauer, M., Wendeler, C., Weitzenböck, J., & Burgstaller, C.‚ ‘Biodegradable geotextiles – An overview of
existing and potential materials’, Geotextiles And Geomembranes, Vol. 47, No. 1, 2019, pp. 48-59, Elsevier BV.
213
Methacanon, P., Weerawatsophon, U., Sumransin, N., Prahsarn, C., & Bergado, D., ‘Properties and potential
application of the selected natural fibers as limited life geotextiles’, Carbohydrate Polymers, Vol. 82, No. 4, 2010,
pp. 1090-1096.
214
English, B.W., ‘Geotextiles, A special Application of biofibers’, United States Department of Agriculture, 1995
(https://srs.fs.usda.gov/pubs/5718).
308
Source Year of
estimate
Geotextile
quantity
Geotextile type Emissions
Miszkowska et
al. 215
2017 NA Non- woven
grammage: 200, 280,
450 g/m2
Grand View
Research 216
2020 4.323 billion m2
All types, non-woven
1 561million m2
,
knitted, 279.8 million
m2
Notably, the table's first source (Bai, Xue et al.)217
is the only one to estimate geotextile emission but
also includes many errors in the methodology and calculations. As a result, it is impossible to rely on
the results provided by this study. The quantification of the total quantity of geotextiles used in civil
engineering applications is presented here. This will serve as a basis for applying the precautionary
principle because although geotextiles are built to last, they will eventually break down into
microplastics. The exact emission estimates are being made.
The data used to calculate the figures given below are from Edana, the nonwoven and related
industries association. Using this data, the total non-woven production in the EU in 2019 was 1.775
million tonnes218
(calculated from their country data).
Non-woven materials are used for a wide variety of applications; Edana lists the applications for
which their members' products are used, and these percentages are assumed to be the same for non-
members. Thus, it is assumed that out of all non-wovens:
• building and roofing industry applications represent 9.8% of the market,
• filtration (air & gas and liquid) applications represent 3.7% of the market, and
• civil engineering / underground applications represent 5.4 % of the market.
Thus, 18.9% of the non-woven production can be considered geotextiles.
Since not all geotextiles produced in the EU are used in the same geographical area perimeter, the
export and import of non-woven must be taken into account when estimating the total EU
consumption. The EU imports close to 370 000 tonnes of non-woven materials and exports close to
390 000 tonnes, so the total quantity of nonwoven used in the EU is roughly as follows:
1 775 000 + 370 000 – 390 000 = 1 755 000 tonnes
The share of nonwoven used in geotextile applications is 18.9%, so the total quantity of non-woven
geotextiles used in the EU is:
215
Miszkowska A., Lenart, A. and Koda, E., ‘Changes of Permeability of Nonwoven Geotextiles due to Clogging and
Cyclic Water Flow in Laboratory Conditions’, Water, Vol. 9, No. 9, 2017, pp. 660.
216
Grand View Research Inc., ‘Grand View Research Forecasts Global Geotextiles Market’, 2014
(https://www.estormwater.com/grand-view-research-forecasts-global-geotextiles-market).
217
Bai, X., Li, F., Ma, L. and Chang, L., ‘Weathering of geotextiles under ultraviolet exposure: A neglected source of
microfibers from coastal reclamation’, Science of the Total Environment, Vol. 804, 2022, Elsevier BV.
218
Edana, ‘Nonwovens markets, facts and figures’, Consulted March 21st
2022 (https://www.edana.org/nw-related-
industry/nonwovens-markets).
309
1 755 000 * 0.189 = 331 695 tonnes.
Assuming that the EU geotextile market is similar to the US one, nonwovens represent 62.5% of the
market, woven represent 27.5%, and the other types represent 10%. 219
Thus, the total tonnage of geotextiles used in the EU in 2019 was estimated to be:
331 695/0.625 = 530 712 tonnes
As discussed earlier, since geotextiles, once installed, are for the large majority not removed, and
despite being stable for an extended period, are going to eventually break down, the total amount of
geotextiles installed over the last 20 years was calculated. To do so, a constant CAGR of 10% was
used, 220
and so the total geotextile tonnage installed in the EU in the period 2002 – 2022 is:
∑
530712
1.1𝑛
= 𝟓 𝟎𝟒𝟖 𝟗𝟔𝟐 𝒕𝒐𝒏𝒏𝒆𝒔
𝑛=20
𝑛=0
The figures calculated before are estimations of installed quantities and not microplastic emissions.
However, they represent the total quantity of material susceptible to emitting microplastics into the
environment. In order to provide an estimate of microplastic emissions from geotextiles, a worst-case
scenario is developed. It is based on the microplastic emissions figures presented in the article from
Bai Xue et al221
, which, although clearly flawed, is the only source quantifying emissions which we
could find.222
Their estimate global microplastic emissions from non-woven PET geotextiles used in
erosion control applications are between 240 thousand tonnes and 790 thousand tonnes. However, as
stated previously, they misquoted their source for market data and used multiplied it by a factor of
10. Therefore, their figure for microplastic emissions will be divided by a factor of 10, bringing it
down to between 24 thousand tonnes and 79 thousand tonnes. The EU represents 25% of the global
geotextile market223
, the worst-case estimate for microplastic emissions from geotextiles (assuming
all geotextiles sold in the EU will be used in applications where microplastic emissions could occur)
would be:
between 6 000 and 19 750 tonnes per year in the EU.
There are several caveats to these figures, which bear a lot of uncertainties:
• PET geotextiles are not the only materials used for erosion control applications, in fact, the
polymers used are more generally polypropylene and polyethylene-containing additives to
increase their UV resistance. However, we don’t have market figures for other polymer types
and thus cannot be extrapolated.
219
Geotextiles Market Analysis Report By Material, By Application, By Product, By Region And Segment Forecasts
From 2020 To 2027. (2020). Retrieved from https://www.millioninsights.com/industry-reports/geotextile-market
220
Markets and Markets, ‘Geotextile Market by Material Type (Synthetic, Natural), Product Type (Nonwove, Woven,
Knitted), Application (Road Construction and Pavement Repair, Erosion, Drainage, Railway Work, Agriculture), and
Region – Global Forecast to 2022’, 2017 (https://www.marketsandmarkets.com/Market-Reports/geotextiles-market-
492.html).
221
Bai, X., Li, F., Ma, L. and Chang, L., ‘Weathering of geotextiles under ultraviolet exposure: A neglected source of
microfibers from coastal reclamation’, Science of the Total Environment, Vol. 804, 2022, Elsevier BV.
222
Stakeholders were consulted on that matter but did not send us articles or scientific data quantifying microplastic
emissions.
223
Fact.MR, ‘Geotextile Market – Forecast to 2019 to 2029’, 2022 (https://www.factmr.com/report/4655/geotextile-
market).
310
• Not all geotextile materials are exposed to the harsh conditions necessary to degrade the
polymers and cause microplastic emissions.
• The emissions figures are coming from a study of questionable quality and so are difficult to
trust.
5.5.2 Uncertainties and data gaps
There are several uncertainties and data gaps when discussing geotextiles in the EU. The quantities
installed and for which application they are used, and the related microplastics emissions are the most
important ones. Indeed, depending on their applications, geotextiles do not represent the same
microplastic emission potential, e.g., geotextiles used to stabilise the soil during road construction
are not exposed to UV, air, or abrasion in the same way as geotextiles used for coastal protection.
From these differences will stem variations in microplastic emissions.
6 POTENTIAL MEASURES
6.1 Measures for tyres
6.1.1 Long list of measures
Tyre wear emissions can be reduced by measures that impact one or more of the parameters.
Furthermore, there are measures to increase the treatment of road run-off after the emissions have
been released. Hence, potential measures have been grouped in the following way:
Tyre characteristics: The most direct type of measure would be to improve tyre characteristics by
introducing regulatory limits for tyre wear. Such a measure would aim at banning tyres with high
emissions from the market. More broadly, it could require developing tyres with lower tyre wear
emissions. There are potential trade-offs with other functionalities of the tyres, notably safety, which
need to be taken into account. This would impact the overall tyre design and composition. In terms
of specific policy instruments, the Commission should prepare a report on tyre abrasion by the end
of 2024 to review the measurement methods and state-of-the-art in order to propose tyre abrasion
limits. A placeholder for such limits was introduced in the recently adopted Euro 7 Regulation. The
existing legislation on tyre labelling224 could be amended to include tyre abrasion as a criterion for
the labelling in addition to energy use, safety and noise. Another measure could be to oblige
manufactures to clean the tyres from the fine rubber pins (remaining from the production process)
when placing tyres on the market.
Vehicle characteristics: Vehicle characteristics can affect tyre wear emissions. The trends towards
the higher weight of passenger cars and consumers buying bigger vehicles potentially increase the
wear. Whether it is possible to introduce measures that would limit the weight of the vehicles is
difficult to assess, and it depends partly on innovation and development in battery technology. The
engine power and acceleration potential also impact tyre wear, so it could be limited in some way to
reduce tyre wear emissions. Changing the vehicle characteristics in order to indirectly affect tyre
abrasion is not considered an effective method to limit microplastics release.
Road infrastructure characteristics: The use of alternative road surface materials could decrease
tyre wear. More generally, the whole layout of the infrastructure plays a role. Given that the design
of roads is subject to many requirements, a possible measure would be to also include tyre wear as a
224 European Parliament and Council of the European Union, Regulation (EU) 2020/740 on the labelling of tyres with respect to fuel efficiency and other parameters, OJ L 177,
5.6.2020, pp. 1–31.
311
criterion in the overall design i.e. to try and reduce overall tyre wear. This could include road layout
and/or the materials used for road surfaces. However, there are also important safety aspects (i.e.
level of grip) to take into consideration.
Sustainable mobility: Vehicle operation, including the total volume of road transport, is subject to
various policy instruments and strategies at local, national and EU levels. Currently, there is a
significant focus on the need to decarbonise transport and reduce impacts of air pollution. Most
instruments are not directed against the transport volume, but rather reducing transport externalities.
The trade-off between the benefits of mobility and the external costs of road traffic demonstrates that
it is not likely that transport volumes can be affected as an instrument to reduce the amount of tyre
wear. However, adding microplastic pollution to the list of external effects of transport could give a
prominence to incentives aiming at reducing the amount of road transport.
Emissions treatment: On the emissions side, measures can be taken by treating the stormwater. A
set of rules for treating stormwater runoff for discharge into surface waters, “Requirements for
stormwater treatment-DWA A102” (DWA-A 102)225 has been published in Germany. The DWA
102 requires that the stormwater must be treated from a traffic volume of 2000 motorised vehicles /
24 h. As already mentioned above, decentralised filter systems or sustainable drainage systems can
be used here. Furthermore, optimised street cleaning is also a potential measure for reducing the
input, e.g., cleaning the roads at hot spots before rain events. This requires intelligent networking of
street cleaning and weather forecasting. Finally, measures could be taken to remove microplastics
from the sewage sludge generated at urban wastewater treatment plants. Microplastics are generally
well captured by existing techniques applied at such plants. However, they can then be released into
the environment when the sludge is used as a fertiliser and spread on agricultural land.
Overall, 205 measures (including duplicates and measures that could be grouped together) were
identified during desk research and by participants of the 2nd stakeholder workshop (24 November
2021). Using this feedback and literature review, a long list of 29 unique measures was established.
A number of the measures identified by stakeholders at the workshop were duplicates and/or could
be grouped together hence the much smaller number of measures taken forward for the screening
process (discussed below).
6.1.2 Measures discarded prior to assessment
The table below summarises the measures that have been screened out from the evaluation as well as
the reasons for their exclusion. It should be noted that, in some instances, the measures that have been
screened out could be effective for reducing microplastic releases from tyre wear but are not
considered appropriate for EU intervention and/or interact/overlap with existing EU initiatives.
225
DWA-A [German Association for Water, Wastewater and Waste], DWA-A Arbeitsblatt 102-2/BWK-A 3-2 –
‘Grundsätze zur Bewirtschaftung und Behandlung von Regenwetterabflüssen zur Einleitung in Oberflächengewässer
– Teil 2: Emissionsbezogene Bewertungen und Regelungen’ [DWA-A worksheet 102-2/BWK-A 3-2 – ‘Principles
for the management and treatment of stormwater runoff for discharge into surface waters - Part 2: Emission-related
assessments and regulations’], 2020 (https://webshop.dwa.de/de/dwa-a-102-2-regenwetterabflusse-12-2020.html),
De.
312
Table 19: Screening of measures for tyres
Problem area Measure description Reason for screening out
Market failure /
Information
failure
Disclose tyre composition:
transparency of all tyre
components and additives to
reduce toxic leakage into the
environment. As tyres are
recycled as materials for
playgrounds and sports pitches,
this would be important to
understand.
This measure has been excluded on the grounds of technical
feasibility and political acceptability due to concerns over the
confidentiality of information on the exact composition of
different tyre models. Tyre composition for generic families of
tyres is already made available with more details in data sheets
provided by the manufacturers when supplying tyres to the
vehicle manufacturers. The use of hazardous substances could
be regulated through REACH. The measure is also not
considered specific enough on microplastics.
Market failure /
Information
failure
Monitoring tyre emissions in the
environment by adding a tracing
material to the tyres.
Whilst this measure would be valuable from a research
perspective, it has been excluded from the evaluation on the
grounds of proportionality and effectiveness and efficiency.
There is already a significant body of research on tyre particle
emissions with lots of ongoing attention. Further research
should be continued under the Commission’s Horizon
programme.
Market/Regulat
ory failure
Alternative materials (e.g.,
biodegradable materials):
Prioritise sustainable and
regenerative materials that do
not have externalities (e.g.
cutting down forests for more
rubber plantations).
The measures is excluded on the grounds of technical
feasibility as there are no commercially available alternative
materials that could replace current materials without
compromises for lifetime, safety etc. Additional research and
development is required before this can be considered further.
Market/Regulat
ory failure
Extending tyre lifetime to reduce
wear.
A measure focused on extending tyre lifetime could incentivise
manufacturers to innovate to reduce abrasion, but it could also
lead to manufacturers simply producing tyres with a thicker
tread. This would lead to heavier tyres with implications for
fuel efficiency and not necessarily any reductions in TWP
emissions. The measure to establish an abrasion limit value is
considered a more appropriate measure to avoid such
outcomes. Therefore, this measure has been excluded on
effectiveness and efficiency grounds.
Market/Regulat
ory failure
Reducing vehicle weight:
Incentives for reducing vehicle
weight
While reducing vehicle weight can reduce TWP emissions, it
is not so simple to do so, not least with the increasing
development and uptake of electric vehicles. At present these
are generally heavier than their internal combustion
counterparts due to the weight of the batteries (however higher
energy density in future batteries might compensate the
difference). There is also a shift towards greater uptake of
larger vehicles, e.g., SUVs, with larger wheels and tyres.
Therefore, this measure has been excluded for technical
feasibility reasons as well as coherence/overlaps with wider
EU policies such as those focused on, e.g. decarbonisation.
Market/Regulat
ory failure
Install particle catchment
systems to collect tyre particles
from cars, light-duty vehicles
and/or heavy-duty vehicles
This measure has been excluded on technical feasibility
grounds. The techniques themselves are not fully commercially
available, and there are some technical constraints with their
implementation, e.g. space constraints.
Market/Regulat
ory failure
Acceleration limitation in urban
areas: Acceleration reduction
could be installed in new
Whilst these measures tackle driver behaviour and could help
reduce TWP emissions, they have been excluded on the
313
Problem area Measure description Reason for screening out
vehicles. Buses already use it to
prevent people from falling
during acceleration. / Kick-
downs for emergency situations
can be limited to a certain
number per time / Slip: traction
control system (TCS)
grounds of political feasibility as they are expected to face
significant opposition from the industry and consumers.
Market failure /
Information
failure
Advanced driver information
systems in vehicles to reduce
abrasion
Whilst measures to change driver behaviours can help to
reduce TWP emissions, this measure would only be voluntary,
so it has been excluded as effectiveness is unlikely to be
significant.
Regulatory
Failure
Speed limits for motorway
and/or urban areas
All of the sustainable mobility measures identified act to either
reduce overall vehicle kilometres and/or change driver
behaviour, all of which can impact TWP emissions. However,
these measures have been excluded on proportionality and
coherence grounds and subsidiarity. Traffic management and
other related measures fall within the remit of local, regional
and national authorities and are not appropriate for EU
intervention. Furthermore, there is already significant action on
sustainable mobility driven by other agendas, including
decarbonisation and local air quality.
However, whilst these measures have been excluded from
further consideration for a specific microplastics intervention,
the impacts of such measures on TWP releases (as co-benefits)
should be taken into account for their development and review.
This may help to make an even stronger case for their adoption.
Market failure /
Regulatory
failure
Improve traffic management to
support smoother traffic flows
Market failure /
Information
failure
Awareness campaigns:
consumer awareness campaigns
on driving impact
Market failure /
Information
failure
Reduction in individual
automotive traffic promoting
shared rides and communal
transport as well as public
transport.
Market failure /
Regulatory
failure
Distance/ Road transport
reduction: Reduce road transport
(passenger and freight) to limit
microplastic released from
abrasion of car and truck tyres
Market failure /
Regulatory
failure
Bicycle traffic: improved cycle
safety and connectivity, e.g. bike
lanes
Market failure /
Information
Failure
Field research: Research to
determine pathways of TWP to
the environment, including
through drainage infrastructure
and storm water pipes, combined
sewer overflows (CSOs),
wastewater treatment plants
(WWTP) / hotspot
identification/marker substance
A number of stakeholders indicated that further research was
required in order to understand the pathways of TWP to the
environment better. There is already a considerable body of
research focused on this topic, with more ongoing, including
through EU programmes, and further EU intervention is not
considered necessary.
314
Problem area Measure description Reason for screening out
Market failure /
Regulatory
failure
Sludge treatment:
Reducing/preventing the
spreading of sewage sludge on
agricultural land
The recent revision of the Urban Wastewater Treatment
Directive (UWWTD)226
identified that existing practices
remove up to 80-94% of microplastics from the wastewater and
then transfer them to the sludge. According to the ongoing
evaluation of the Sewage Sludge Directive (SSD), 40% of
sewage sludge is spread on agricultural land and used as a
fertiliser. Some MS have introduced a ban on the use of sewage
sludge in agriculture. As for the EU level, around half of
sewage sludge is applied on agricultural land. The Sewage
Sludge Directive (SSD) may be revised in the coming years
(depending on the findings of the evaluation) and could
consider this issue further.
Market failure /
Regulatory
failure
Sludge treatment: Enhancement
of capabilities of water treatment
facilities to eliminate
microplastics from sludge
Whilst current treatment techniques at UWWTPs have a
relatively high removal rate for capturing microplastics from
the wastewater, and this is mostly transferred to the sewage
sludge. There are yet commercially available techniques to
remove the microplastics (at least to any significant extent)
from the sewage sludge prior to its application on agricultural
land (in those Member States where it is spread and not
incinerated). The supporting study to the evaluation of the
Sewage Sludge Directive227
concluded that further research is
needed to understand the potential impacts of sewage sludge
treatments on microplastics. Therefore, the measure has been
excluded due to a lack of technical feasibility.
Market failure /
Information
Failure
Artificial intelligence /
promoting autonomous driving
and advanced driver assistance
systems vehicles to reduce
abrasion (TYR#4)*
This measure is already being taken up by the car industry
Regulatory
failure
Improve capture and treat road
run-off water (e.g. filter systems
for gullies)
A voluntary approach through guidelines would be the best
approach in this phase. This is taken up in another measure
Regulatory
failure
Improve road cleaning in high
emission hotspots (intelligent
network)
A voluntary approach through guidelines would be the best
approach in this phase. This is taken up in another measure
Regulatory
failure
Mandatory shaving off of vent
spews
IDIADA information given to the JRC (unpublished) indicates
that for a specific tyre brand the total amount of the rubber pins
(also called vent spews) could reach approximately 10 g per
tyre. Considering an average abrasion of approximately 1.0-1.5
kg during the tyre’s lifespan, the overall effect is calculated to
be at the level or lower than 1%. Taking into account that most
tyres in the fleet do not feature these rubber pins, the overall
impact is expected to be much less than 0.5% and probably
closer to 0.1%.
Further implications: Based on the available information, there
are tyres with almost no or very few rubber nibs, while some
226
European Commission, Commission staff working document - Evaluation of the Urban Waste Water Treatment
Directive; SWD(2019)701 final, 2019.
227
Wood et al., Study report in support to the evaluation of the Sewage Sludge Directive, Exploratory study - final report,
2021.
315
Problem area Measure description Reason for screening out
other tires feature long and numerous rubber nibs. One can
safely assume that this amount of extra rubber will be much
different from one tyre to another depending on each tyre
manufacturer. Furthermore, there is no information regarding
the additional cost of removing the rubber pins at the
manufacturing procedure.
(*) To note that this measure was discarded later in the process, which is the reason why it has a number
(TYR#4) that cannot be found later in this study.
6.1.3 Measures to be assessed for tyres
Measure TYR#7: Road design and cleaning guidelines
Type of measure: Non-binding approach
Description of the measure
This measure is about the support the EC could give to the development of guidelines at a European
level for use by the Member States for road design (design, materials and capture and treatment of
run-off water) and cleaning. These guidelines would encompass the following:
• The development of criteria to define the contribution of the road design and material to
tyre abrasion and specifications for road design, including considering road materials that
can absorb TWP (e.g. porous asphalt) and/or TWP rates (e.g. rubber asphalt).
• Approaches for increasing uptake of capture and treatment systems for road run-off water
(focused on urban areas) to prevent or minimise direct runoff into surface waters.
• Options for changing current road cleaning practices to optimise the removal of TWP.
This would cover the timing of the cleaning where it should take place before any major
rainfall as well as more cleaning of road/street sections with a high level of tyre wear.
How would the measure work?
There are still a number of uncertainties on the effectiveness and technical feasibility of such
measures, so a regulatory intervention is not considered feasible. Therefore, the measure would entail
the development of guidance and specifications for road design requirements (including options for
capture and treatment of road run-off) and material characteristics, which the Member States could
then apply when maintaining and building roads. The measure could include criteria for when to
collect and treat road run-offs as well as when and how to undertake road cleaning. The guidance
could identify best practices to demonstrate examples where such approaches have been delivered in
practice and the benefits that have been realised.
For road cleaning, the guidelines would support more informed cleaning of roads in high-release
hotspots ahead of major rain and storm events to reduce run-off to UWWTPs and the environment.
It could encourage the cleaning of roads with the largest traffic volumes and, therefore, the most
significant amounts of TWP and would encourage timings based on weather forecasts. It should be
noted that treatment of the run-off water would lead to the generation of sludge and that no
commercially available technology is currently available for removing the microplastics from the
sludge (to any significant extent). It means that the sludge would need to be incinerated to be removed
entirely.
316
How could the measure be implemented?
The measure could be implemented by developing guidance and technical materials informed by a
technical working group to be established. There could also be potential for amendment of the Green
Public Procurement (GPP) criteria for road transport in the future to accommodate microplastic
considerations228
.
Measure TYR#3: Modulated fees in EPR for tyres
Type of measure: Market-Based Instrument
Description of the measure
Introducing or modifying an EPR scheme so that it covers the use phase of tyres would require that
all companies placing a tyre on the EU market would incur fees related to the emissions of the tyre,
and the revenue from the fees could then finance the treatment of run-off from roads in order to
capture and remove the microplastics and/or consumer awareness raising activities.
How does the measure work?
There are already EPR schemes for tyres in 20 Member States229
, and they have been introduced for
managing end-of-life tyres (ELTs). In such a scheme, a producer would be responsible for the
disposal and management of tyres after their use. Other systems which exist for managing ELTs in
the EU are free market systems and tax systems.230
Under a tax system, the government is responsible
for ELT management, as seen in Denmark and Croatia. A tax on tyre producers is used to finance the
government’s management of ELTs and will be passed on to the consumer. 231
EPR schemes and tax
systems are similar in that producers face a cost to manage ELTs; however, under an EPR, the
responsibility of the management falls upon the producer.
A free market system is operated in Germany and Austria. Under a free market system, laws are
usually set regarding the transportation, use, disposal and storage of ELTs.232
Unlike other systems,
there is no party which is designated as responsible for the management of ELTs. Any operations to
recover ELTs are contracted under free market conditions to comply with the relevant legislation.
This is often accompanied by voluntary action within the industry to promote best practices. Unlike
EPR and tax systems, there is no direct payment from producers which can go towards ELT
management.
228
JRC, JRC Technical report and criteria proposal – Revision of the EU Green Public Procurement Criteria for Road
Transport, 2021 (https://ec.europa.eu/environment/gpp/pdf/criteria/EUGPP_roadtransport_technicalreport.pdf).
229
Includes Belgium, Bulgaria, Czech Republic, Estonia, Finland, France, Greece, Hungary, Ireland, Italy, Latvia,
Lithuania, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain and Sweden. Based on: European Tyre
& Rubber Manufacturers’ Association (ETRMA), ‘Circular Economy’ (https://www.etrma.org/key-topics/circular-
economy/#:~:text=In%20the%20EU%2C%20three%20different,of%20a%20product's%20life%20cycle).
230
European Tyre & Rubber Manufacturers’ Association (ETRMA), ‘Circular Economy, 2019
(https://www.etrma.org/key-topics/circular-economy/).
231
World Business Council for Sustainable Development (WBCSD), ‘Global ELT Management – A global state of
knowledge on regulation, management systems, impacts of recovery and technologies, 2019
(https://docs.wbcsd.org/2019/12/Global_ELT_Management%E2%80%93A_global_state_of_knowledge_on_regulat
ion_management_systems_impacts_of_recovery_and_technologies.pdf).
232
World Business Council for Sustainable Development (WBCSD), ‘Managing End-of-Life Tires’, 2018
(https://docs.wbcsd.org/2018/02/TIP/End_of_Life_Tires-Full-Report.pdf).
317
It is unclear how Cyprus, Luxembourg and Malta conduct ELT management or whether any formal
system is in place. In 2018, high percentages of ELT were treated in Cyprus (145%) and Malta
(100%), suggesting that measures are in place.233
No data is available for Luxembourg.
The measure considered here would be about the use phase of tyres. The scheme could be designed
in alternative ways with regard to how the fees would be calculated and what the revenue would
finance. Current EPR schemes and tax systems, as seen across 22 countries in the EU, could be
adapted with modulated fees (EPR) or taxes to cover microplastic releases. For Austria and Germany
and a free market system, it is unclear if they could be adapted to also account for microplastic
releases or if an EPR scheme or similar system would need to be introduced. For those Member States
without any such scheme in place, then there would be a need to introduce something new. Any EPR
scheme for abrasion (new or modulated fees for an existing scheme) would have to comply with
Article 8a(4) of the Waste Framework Directive (Directive 2008/98/EC). It requires that
Member States shall take the necessary measures to ensure that the financial contributions paid by
the producer of the product to comply with its extended producer obligations: ..
(b) in the case of collective fulfilment of extended producer responsibility obligations, are
modulated, where possible, for individual products, or groups of products, notably by taking into
account their durability, reparability, reusability and recyclability and the presence of hazardous
substances, thereby taking a life-cycle approach and aligned with the requirements set by relevant
Union law, and where available, based on harmonised criteria in order to ensure smooth functioning
of the internal market234
This requirement could potentially be challenging as the cost of removing the microplastic from road
run-off might be difficult to estimate and also challenging to agree on the criteria for what the EPR
should cover. See the discussion below under Implementation.
The proposed revision of the Urban Wastewater Treatment Directive (UWWTD) establishes an EPR
scheme. It would cover releases of micropollutants by introducing a fee for products that lead to their
release (e.g. pharmaceuticals), based on the quantities and the toxicity of the products placed on the
market. An EPR scheme could be implemented in a similar way.
How could the measure be implemented?
As mentioned above, there are already EPR schemes in many Member States, although it seems that
they differ in the way they are implemented. In several Member States, there is more than one
scheme235
. EPR schemes that deal with end-of-life management are more straightforward in many
ways. They are focused on ensuring that used tyres are managed safely and ensuring a high level of
reuse or recovery of materials/energy. The introduction of EPRs in all Member States would therefore
require EU legislation, and it would be necessary to specify some minimum requirements for an EPR.
Though there are existing EPRs, changes to their working might be needed, or it might be necessary
to define new and specific EPRs to cover tyre wear.
233
European Tyre & Rubber Manufacturers’ Association (ETRMA), ‘End of Life Tyres Management – Europe 2018
Status’, 2020 (https://www.etrma.org/wp-content/uploads/2020/09/Copy-of-ELT-Data-2018-002.pdf).
234
European Parliament and Council of the European Union, Directive 2008/98/EC on waste and repealing certain
directives, OJ L 312, 22.11.2008, pp. 3-30.
235
Winternitz, K., Heggie, M. & Baird, J., 'Extended producer responsibility for waste tyres in the EU: Lessons learnt
from three case studies – Belgium, Italy and the Netherlands', Waste Management, Vol. 89, 2019, pp. 386-396.
318
The practical implementation would require the definition of:
• Who should pay the fee, and what should be the level and differentiations?
• What should the collected fee cover?
• Definition of the governance and the practical organisation set-up for the EPR
While the specific governance set-up might be left to the discretion of each Member State, issues of
minimum fees etc. might be required at an EU level.
There is a recent OECD study on modulated fees in EPR schemes236
. The study lists key
considerations for an EPR with a more advanced fee structure. Generally, there are few actual
examples, but there could be an issue if the EPR is not perceived as fair and transparent. For an EPR
to work, the test standard needs to be defined as required for the previous measures (TYR#1 and
TYR#2). Then the fee would be correlated to the emission level of each tyre in order to provide an
incentive for innovation in tyres with lower emission rates. The next question is what the revenue
should cover. Currently, experience suggests that much of the microplastics are actually captured by
the wastewater treatment processes but then released into the environment in some Member States
via the spreading of sewage sludge. The share of road run-off is not covered; which are collected by
separate storm-water systems or just discharged into the ditches along the roads. An EPR system
could be used to fund the treatment of stormwater that is not being treated and improve the collection
and treatment of road run-off currently not collected. It could also cover consumer awareness-raising
activities.
The challenge in setting up the system would be:
• The emissions are not constant along the road network, but the hotspots might not be known
or registered.
• An EPR would probably not be able to fund improvement for all roads, and it would be
necessary to define priority criteria.
• Collection and treatment of road run-off would also potentially remove other types of
pollution.
Given the described issues and challenges, there is a need for further clarifications of the legal aspects
on what can and should be defined at an EU level and what will be for Member States to define. For
those Member States that currently do not have an EPR scheme in place for the end-of-life tyres,
there are two main options:
• Require the establishment of an EPR scheme but potentially only covering microplastic
releases.
• Adapt existing approaches (e.g. taxation) to provide a financial mechanism for charging
manufacturers depending on the abrasion rates of their tyres, e.g. taxes could be modulated
to account for microplastic releases.
Measure TYR#1: Emission limit value for particles from tyre wear/abrasion
Type of measure: Regulatory action
236
OECD, OECD Environment Working Paper No. 184 - Modulated fees for Extended Producer Responsibility schemes
(EPR); ENV/WKP(2021)16, 2021.
319
Description of the measure
The aim of this measure would be to phase out the worst-performing tyres from an abrasion point of
view through the implementation of an emission limit value. This would require an appropriate test
method and standard, which is already under development, as discussed previously. Only then could
the absolute limit values be defined for different tyre types (sizes and models). In principle, lower
abrasion tyres should also have a longer lifetime, thus increasing the time before they need to be
replaced, although tyre design means that no direct comparison can be made between different tyres
in terms of durability. As discussed previously, data from recent studies show quite a high variation
across different tyre brands and tyres with respect to their abrasion rates. Hence, by restricting the
use of the worst-performing tyres, TWP emissions would be decreased. The measure could have an
impact fairly quickly, considering that the average lifetime of a tyre before being replaced is around
5-10 years (dependent on usage and driver behaviour).
How does the measure work?
There is no internationally agreed standard for measuring the emission rate of a particular tyre.
However, as discussed earlier, such methods are now under development. Then an emission limit for
tyre wear can be set (broken down for different tyre types), and only tyres that pass that emission
limit value using the agreed test method will be approved. A ban on the worst-performing tyres will
lead to lower average emission rates and lower total emissions of TWP from tyres. Limits would
need to be defined separately for different types (i.e. summer, winter, all-year tyres, sizes and
performance classes) and light-duty and heavy-duty vehicles. Options for setting limits could be
based on the lower, e.g. 10% of performers in each category or a certain percentile. Limit values
could be phased over time, with limits being tightened (within technical feasibility bounds) as
manufacturers innovate to produce tyres with lower abrasion rates.
How could the measure be implemented?
Abrasion limits will be introduced in recently adopted Euro 7 Regulation once the methodology is
available.
Measure TYR#2: Emission labelling of particles released from tyre wear.
Type of measure: Regulatory action
Description of the measure
There is already a labelling scheme for tyres focused on safety, energy efficiency and noise. This
measure would add tyre abrasion as a fourth element to the label.
How would the measure work?
All tyres placed on the EU market would have to be tested to determine their abrasion rate. As with
measure TYR#1, this measure would require that a technical standard and method for measuring the
emission rates be established. Once this has been adopted, different emission levels would be defined
by label values (like A, B, C etc.) and a symbol to be placed on the label. The label would give the
consumer a possibility of taking the microplastic emissions into account when purchasing new tyres.
It may be most effective to consider including the abrasion rate alongside impacts on tyre lifetime as
lower abrasion rates may equate to an increase in tyre lifetime, thus saving consumers money. This
320
is considered to be a greater driver for consumer purchasing than microplastic emissions237
. In the
future, such a label could also be utilised by city and other local/regional authorities where emissions
are greatest, e.g. to apply restrictions on the sale of certain tyres with higher abrasion rates.
How could the measure be implemented?
Regulation (EU) 2020/740 includes a provision for the Commission to introduce tyre abrasion and
mileage criteria as soon as reliable test methods are in place (Article 13).
Measure TYR#6: Regular wheel alignment to minimise tyre wear
Type of measure: Regulatory action
Description of the measure
This measure is about ensuring the axis (wheel) alignment is maintained so that the abrasion rate is
kept at the level that follows the vehicle design. Misalignment can appear through the use and wear
of the vehicle and lead to increased abrasion. Therefore, this measure would be a requirement to test
the alignment regularly and correct and adjust the wheels in case of any misalignment.
How would the measure work?
By a requirement to regularly test the alignment, the negative effects of misaligned wheels could be
reduced or eliminated. This could be done as part of the mandatory roadworthiness tests. As the
roadworthiness tests only take place every fourth year (as a minimum, in many Member States they
are more frequent), there would still be an effect from misalignment, assuming the misalignment
happens gradually.
How could the measure be implemented?
There are already some requirements on wheel alignment captured by existing EU legislation, namely
Directive 2014/45/EU on periodic roadworthiness tests238
. This sets minimum requirements (and
frequencies) for periodic testing of road vehicles, including specific technical elements to be covered.
These include wheels and their alignment (namely, to check that the alignment of the wheels is in
accordance with the vehicle manufacturer’s requirements). However, this specific requirement is
marked with an “X” which the footnote specifies: “(X) identifies items which relate to the condition
of the vehicle and its suitability for use on the road but which are not considered essential in a
roadworthiness test,” i.e. it does not appear to be a mandatory requirement for roadworthiness testing.
The test is also focused on the steered wheel requirement on driving safety. The alignment of the axis
is an additional requirement, but it could be implemented as amendments to the existing legislation.
Measure TYR#5: Enhance monitoring of tyre pressure
Type of measure: Regulatory action
237
European Commission, ‘Study assessing consumer understanding of tyre labels, 2019
(https://ec.europa.eu/info/sites/default/files/energy_climate_change_environment/overall_targets/documents/tyre-
label_final-report_0.pdf).
238
European Parliament and Council of the European Union, Directive 2014/45/EU on periodic roadworthiness tests for
motor vehicles and their trailers and repealing Directive 2009/40/EC, OJ L 127, 29.4.2014, pp. 51.
321
Description of the measure
The measure would entail enhancing the on-board monitoring of tyre pressure in new vehicles to
reduce TWP emissions.
How would the measure work?
According to the ETRMA239
, under-inflated tyres can increase fuel consumption (up to 4%) and have
implications for the tyre's lifespan (reduction up to 45%). Tyre pressure monitoring systems (TPMS)
are currently required for new cars and vans and will be for trucks but are primarily calibrated for
driver safety, i.e. TPMS currently shows if tyres are at dangerously low pressure, typically 20% below
optimal. The measure would entail a more sensitive calibration of the TPMS to flag when the pressure
is not optimal from a tyre wear perspective (i.e. it would alert the driver sooner when the pressure
has dropped). The feasibility of tightening current thresholds (in the context of the uncertainties of
the systems) and the exact threshold at which alerts would need to be determined based on a more
in-depth technical assessment of the optimal level for reducing tyre wear, the sensitivity of the
systems and likely driver behaviour (including the risk of driver annoyance if set too low). This could
be combined with a communication campaign to make consumers aware of the importance of proper
tyre pressure.
It should be noted that if the system is very sensitive, then it might face opposition from industry and
car users. It might also lead to car users having the system switched off or ignoring it if it is very
sensitive.
How could the measure be implemented?
The change of the TPMS to give warnings when lower pressure increases the abrasion rate could be
implemented as amendments to the existing type approval regulations.
6.2 Measures for textiles
6.2.1 Long list of measures
Following a workshop with stakeholders and a review of relevant literature, a long list of measures
to reduce microplastics releases from synthetic textiles was developed. About 155 measures were
identified during the workshop. After removing duplicates and regrouping some measures, the list
was refined to 29 measures. The long list of measures is described in the table below. They can be
classified by the type of measure:
Standardisation: There is a need to quantify microplastic release from synthetic textiles on the whole
life-cycle with a standardised method.
Regulating releases: Microplastic releases can be limited by setting thresholds for specific life-cycle
steps. For example, it could be at the production plant or in washing machines by households.
Technological: Technologies can help reduce microplastic releases from textiles at different life-
cycle steps.
Communication and behaviour change: To raise awareness and promote behaviour by reducing
microplastic releases (purchase decision, washing practice, etc.) could also be relevant to reducing
releases and supporting other measures.
239
European Tyre & Rubber Manufacturers’ Association (ETRMA), ‘The tyre industry’s role in advancing Connected
& Automated Driving’ (https://www.etrma.org/key-topics/mobility/).
322
Incentives and disincentives: Taxes and subsidies could provide incentives/disincentives to
companies/consumers to change their production process (material input, plant equipment, etc.) and
purchase behaviour favouring less microplastic releases.
Research needs: There are still a lot of uncertainties regarding microplastic releases from textiles
(quantification, health impact, production techniques to limit releases). Research would help reduce
these uncertainties and help companies implement the changes in their production process.
6.2.2 Measures discarded prior to assessment
The table below summarises the measures that have been screened out from the evaluation and the
reasons for their exclusion. It should be noted that, in some instances, the measures that have been
screened out could be effective for reducing microplastic releases from textiles but are not considered
appropriate for EU intervention and/or interact/overlap with existing EU initiatives.
Table 20: Screening of measures for synthetic textiles
Problem area Name of the
measure
Description Reason for screening out
Market failure /
Regulatory
failure
Professional
laundries'
emissions
regulation
Making microplastics filters
compulsory for professional
large-scale laundries. There
would be a need to define a
minimum efficiency threshold
for the filter and define a set of
criteria to identify the
laundries subject to the
regulation.
This measure has been excluded on the grounds
of relevance because this measure was very close
to another measure that was kept (the one making
filters compulsory on all washing machines) but
with a smaller scope.
Information
failure
Textiles
production
facilities
reporting
requirement
The reporting of releases of
the production facility would
be compulsory for all textiles
sold on the EU market.
This measure has been excluded on the grounds
of effectiveness because this measure does not
entail reductions in microplastic releases directly.
It is only a means to compare production plants
on their microplastics releases more easily. In
addition, textiles production installations which
are regulated by the Industrial Emissions
Directive and the European Pollutant Release and
Transfer Register (E-PRTR), are already subject
to reporting.
Market failure /
Regulatory
failure
Technological
solutions to
reduce
microplastic
releases
Improving the efficiency of
the microplastics filters.
This measure has been excluded on the grounds
of effectiveness because it is not prone to create
short-term results, as it is an R&D measure. It
would need to support another measure, like the
measure to make washing machine filters
compulsory.
Market failure /
Regulatory
failure
Emission limit
for textiles placed
on the EU market
An emission limit that targets
the whole life-cycle will lead
to technology changes that
enable the textile
manufacturer to respect the
emission limit.
A custodial sequence that occurs as ownership or
control of the material supply is transferred from
one custodian to another in the supply chain295
has to be organised to ensure the traceability of
the textile’s characteristics regarding microplastic
emissions. It could be organised via certificate
323
Problem area Name of the
measure
Description Reason for screening out
trading, stating a microplastic emission category,
for example296.
This measure has been discarded as most of the
production is outside the EU, often in SMEs in
developing countries, making the implementation
very difficult for products place on the EU
market. This measure would not be feasible,
proportionate nor political feasible. Other
measures also seem much more suited, like
TEX#3: Restriction of synthetic fibres and fabrics
with high releases of microplastics.
Market failure /
Regulatory
failure
Emission limit
during
production
During production, an
emission limit will lead to
technology changes that
enable the production plants
to respect the emission limit.
Discarded for the same reasons as the measure
before (emission limit for textiles placed on the
EU market)
Regulatory
failure/
Information
failure
Develop
guidance on Best
Available
Techniques
Developing Best Available
Techniques (BAT) on textiles
and their associated levels of
releases for these parts of the
value chain for which there
are no BATs. This measure
would make information more
easily accessible to a greater
number of professionals.
This measure has been excluded on the grounds
of effectiveness because this measure would only
make information more easily accessible.
However, it would not create any constraint or
incentive to reduce microplastic releases in the
short/medium term.
Market failure /
Regulatory
failure
Mitigate and
control WWTP
Equipping WWTP above a
size threshold (e.g., > 50 000
PE) with compulsory filters.
This measure has been excluded. It would rather
belong to the evaluation of the Urban
Wastewater Treatment Directive, which is dealt
with in a distinct policy process. Further, the
measures is also excluded on the grounds of
effectiveness because an extra filter in WWTP
would not be cost-effective as most of the
microplastics are already captured (between 80
and 95 %, according to EurEau).
Market failure /
Regulatory
failure
WWTP sludge
incineration
Compulsory incineration of
WWTP sludge.
This measure was screened out on several
grounds, including technical feasibility,
coherence with other EU objectives,
proportionality, and political feasibility.
Mandating incineration of sewage sludge instead
of spreading is not considered realistic. In some
Member States, it is an important fertiliser.
There is not the capacity to incinerate it, and/or
it would conflict with other objectives,
including, e.g. decarbonisation, circular
economy and agriculture.
324
Problem area Name of the
measure
Description Reason for screening out
Information
failure
School
intervention
Funding
programs/associations that
intervene in schools to raise
awareness on the issue of
microplastics and
communicate best practices
surrounding the issue.
This measure has been excluded on legal
feasibility because education is not one of the
EU areas of action. Moreover, this measure was
close to another that consisted of funding
communication campaigns to raise awareness on
microplastics and communicate best practices.
Regulatory
failure
Taxing
microplastic
release
Taxing textiles sold in the EU
based on their estimated
microplastic releases over
their life-cycle.
The measure was screened out on the grounds of
proportionality and political feasibility of
common taxation between all MS.
Regulatory
failure
Taxing textile
plastic content
Taxing textiles sold in the EU
based on the quantity of
plastic in their production.
The measure was screened out on
proportionality and the political feasibility of
common taxation between all MS.
Market failure /
Regulatory
failure
Subsidising
sustainable
clothing
Subsidising clothes producers
who make clothes following
the product environmental
footprint category rules on
textile and apparel. This is a
long-term measure, and the
implementation could take
place through the textile EPR
scheme (by using eco-
modulation).
The measure was screened out on the grounds of
proportionality and the political feasibility of
subsidies.
Market failure /
Regulatory
failure
Subsidising
innovative
textiles
Subsidising the producers of
textiles who apply techniques
prone to reducing
microplastic releases to their
textiles.
This measure was screened out on the grounds
of (1) political feasibility, as to subsidise a part
of the textile sector, and (2) technical feasibility
as there are not yet innovative textiles with much
lower microplastic releases made with synthetic
fibres. It is too soon to think about subsidizing
producers of innovative textiles, as the industry
is still at the R&D stage on this question.
Information
failure
Research
yarn/fabric
characteristics
Funding research on the link
between microfibers release
and yarn/fabric
characteristics.
These measures are screened out on the grounds
of effectiveness because R&D measures cannot
create short-term results and have highly
uncertain outcomes. R&D is nevertheless
already happening under EU programmes and
will continue to be pursued.
Information
failure
Textiles
microplastics
release sources
database
Developing a database of the
risk of microplastic release
depending on several
characteristics (yarn type,
fabric, age, washing
condition, etc.).
Information
failure
Research textile's
use phase
Funding research on
microfibers releases during
textiles' use phase.
Information
failure
Research dying
techniques
Funding research on less
emitting dyeing techniques.
325
Problem area Name of the
measure
Description Reason for screening out
Information
failure
Research
biodegradable
Research on biodegradable
microplastics.
Information
failure
Research mixing
organic/synthetic
fabric
Funding research on the link
between microfibers release
and the mixing of
organic/synthetic fabric.
Information
failure
Research on
health effects
Funding research on the
health effects of microplastics
(airborne included).
Information
failure
Research on pre-
wash releases
Funding research on the
amount of microplastic
released during pre-wash.
Information
failure
Research
Microfibre
Consortium's
roadmap
Funding research on the need
for the Microfibre
Consortium's roadmap.
6.2.3 Measures to be assessed for textiles
Measure TEX#8: Raising awareness on best practices for consumers of textiles
Type of measure: Supply chain/consumer information to enable selection of less polluting products
or change in behaviour
Description of the measure
The measure would involve a communication campaign aiming to raise awareness on microplastics
and communicate best practices surrounding the issue.
How does the measure work?
The Member States could coordinate the communication campaign.
The list below gives a few communication examples:
• Which fibres emit microplastics
• Washing practices to reduce microplastic releases
• Washing machine filter maintenance
• Impact of fast fashion on microplastic releases
Consumers and households will be affected by this measure as the communication campaign will
target them.
How could the measure be implemented?
326
The measure would be implemented through dedicated actions or legislation changes (ecodesign for
textiles and electrical and electronic equipment).
Measure TEX#9: Mandatory label showing textiles’ emissions of microplastics
Type of measure: Supply chain/consumer information to enable selection of less polluting products
or change in behaviour
Description of the measure
The measure implies that each textile item must have a label informing the consumer of the estimated
microplastic releases during the product's life-cycle.
How does the measure work?
It is important to note that there is currently no methodology to quantify the microplastic releases of
textiles over the life-cycle. Therefore, the mandatory label measure needs to be combined with the
measure TEX#1 “Create a standardized measure to quantify microplastic releases on the life-cycle”.
How could the measure be implemented?
The measure would be implemented through legislation changes (ESPR or Textiles Labelling
Regulation).
Measure TEX#7: Modulated fees in EPR for textiles
Type of measure: Market-Based Instrument
Description of the measure
By 2025240
, there will be targets at the EU level to increase the separate collection of textile waste.
Whether it will be applied via an EPR by the Member States is unclear. The European Commission
also adopted an EU strategy for sustainable and circular textiles241
, which states that “the Commission
will propose harmonised EU extended producer responsibility rules for textiles with eco-modulation
of fees”. This measure aims to include a “microplastic release” component in existing and future
textile EPR schemes242
.
How does the measure work?
Including a “microplastic release” component to existing and future textile EPR schemes can be done
via eco-modulated fees, the microplastic release externality into account or financing measures
reducing microplastic releases. The EPR is a tool to combine with other measures. The administrative
cost of a waste management EPR for textiles with a microplastic component should not be completely
allocated to microplastics as the EPR serve many purposes. The cost of the microplastic part in the
eco-modulated fee might be very low. An EPR scheme could also be dedicated to microplastics for
textiles or combined with other sources of microplastics if reduction measures are similar.
240
European Parliament and Council of the European Union, Directive (EU) 2018/851 on waste, OJ L 150, 14.16.2018,
pp. 109-140, article 12b.
241
European Commission, Commission communication - EU Strategy for Sustainable and Circular Textiles;
COM(2022)141 final, 2022.
242
Extended Producer Responsibility.
327
How could the measure be implemented?
The measure would be implemented through legislation changes (Waste Framework Directive).
Measure TEX#2: Restrict synthetic fibres for certain applications
Type of measure: Regulatory action
Description of the measure
For some types of clothes, synthetic fibres could be replaced by natural or artificial ones. The use of
synthetic textiles could be restricted by law to technical applications (see table further).
How does the measure work?
The measure consists of replacing synthetic fibres in all non-technical clothes243 with natural fibres
or non-oil based man-made fibres (such as cellulose-based fibres), except for those categories of
clothes for which it is impossible to do without synthetic polymers because of their technical
specificities (waterproofing, flexibility, etc.). The table below summarises the proportion of such
clothing that is not considered feasible to be replaced by natural fibres or non-oil based man-made
fibres.
Table 21: Technical products
Products Proportion of
technical clothing
(assumption)
T-shirts (sportswear) 50%
Trousers and shorts (sportswear) 50%
Technical jackets -
Anoraks, ski jackets, etc. 100%
Anoraks, ski jackets, etc. (knitted or crocheted) 100%
Raincoats 100%
Overcoats, car coats, capes (other) 50%
Overcoats, car coats, capes (knitted or crocheted) 50%
Swimwear 100%
Tracksuits 100%
Ski suits 100%
Hosiery 100%
For all other products, oil-based synthetic materials (polyester, polypropylene/elastane, acrylic and
polyamide) are replaced by natural or other artificial materials (cotton, viscose, flax, wool). The
current fibre mix was assumed to replace the oil-based synthetic fibres244
:
243
The focus is on clothes because the majority of microplastics emissions arise from clothes and not from households
textiles.
244
Beton, A. et al, ‘Environmental Improvement Potential of textiles (IMPRO Textiles)’, Publications Office of the
European Union, EUR 26316, JRC85895, 2014.
328
• Cotton: 66%
• Viscose: 15%
• Wool: 15%
• Flax: 3%
Weight, numbers of units and composition data from the JRC Impro textiles study245
have been used.
The Impro Textiles study is still relevant because the technological changes have been limited since
then. Moreover, this study compares the fibres with a consistent methodology relevant to this impact
assessment. With this measure, the proportion of oil-based synthetic materials used falls from 38%
(baseline scenario) to 12%. Other important assumptions and limitations include the following:
• Natural materials also emit microfibres. There is little evidence about the fate and persistence
of natural fibres such as wool and cotton. In addition, natural fibres could be the source of the
leaching of chemicals present on the fibres following the dyeing or finishing stages. (ETC,
Microplastic pollution from textile consumption in Europe, February 2022). This is, therefore,
a limit of this measure.
• The measure was defined by considering an increase in the proportion of cotton in clothing
from 41% to 58%. In practice, the proportion of cotton is subject to the constraints of the
production (notably land use) and the demand for this material.
• The proportions of natural and man-made materials following the implementation of measure
1a have been calculated based on the current proportions of these materials in clothing. In
practice, each fibre has particular characteristics, and its use depends on the properties
expected for the product. The replacement of oil-based synthetic materials will therefore
require identifying the most suitable natural or artificial material(s) for each use.
How could the measure be implemented?
The measure would be implemented through legislation changes (ESPR).
Measure TEX#3: Restrict synthetic fibres & fabrics with high releases of microplastics
Type of measure: Regulatory action
Description of the measure
For the type of clothes with high releases of microplastics, oil-based synthetic fibres could be
replaced by natural or artificial ones. The use of synthetic textiles could be restricted by law in these
clothes with high releases of microplastics.
How does the measure work?
Replacing oil-based synthetic fibres in clothes with natural or other man-made fibres where it is
feasible from a technical and production capacity points of view and only where the highest emitting
types of fibres and categories of clothes are targeted. Synthetic fibres are kept for the specific
categories of clothes for which synthetic fibres are necessary for their technical characteristics
245
Ibid.
329
According to the literature246
, knitted polyester, acrylic and polyamide lead to the highest
microplastic releases.
In addition, the following figure shows that the main categories of clothing, in terms of tonnes, are
tops, underwear, nightwear and hosiery and bottoms. These categories also correspond to products
with high wash frequencies, which are therefore likely to emit more during washing (variation
between 1 and 5 for the number of uses before washing: 1 for T-shirts and underwear, 2 for the shirts,
5 for pullovers, 3 for trousers) (PEFCR Apparel and footwear, draft version, 2021).
Figure 35: Consumption of different categories of clothing and household textile products in the EU-27
(source: IMPRO textile, 2014)
For non-technical applications with the highest releases of microplastics, oil-based synthetic
materials are replaced by natural or other artificial materials (cotton, viscose, flax, wool).
The current natural fibre mix was taken to replace the synthetic fibres247
:
• Cotton: 66%
• Viscose: 15%
246
Cai Y., Mitrano, D.M., Heuberger, M., Hufenus, R. and Nowack, B., ‘The origin of microplastic fiber in polyester
textiles: The textile production process matters’, Journal of Cleaner Production, Vol. 267, 2020, Elsevier BV.
Folkö, A., ‘Quantification and characterization of fibres emitted from common synthetic materials during washing’,
Environmental Science, 2015.
Hann, S., Sherrington, C., Jamieson, O. et al., Investigating options for reducing releases in the aquatic environment of
microplastics emitted by (but not intentionally added in) products, Eunomia report for the Directorate-General for
Environment, 2018.
247
Beton, A. et al, ‘Environmental Improvement Potential of textiles (IMPRO Textiles)’, Publications Office of the
European Union, EUR 26316, JRC85895, 2014.
330
• Wool: 15%
• Flax: 3%
Weight, numbers of units and composition data of the JRC Impro textiles study248
are used. Only few
synthetic fibres have been replaced by natural ones. The proportion of synthetic materials falls from
38% (baseline scenario) to 21%
How could the measure be implemented?
The measure would be implemented through legislation changes (ESPR)
Measure TEX#4: Mandatory prewashing of textiles before placing on the market
Type of measure: Regulatory action
Description of the measure
Prewashing would be mandatory for all the textiles put on the EU market. Therefore, the plants in
and outside the EU putting textiles on the EU market would need to equip themselves (washing and
drying machines).
How does the measure work?
In practice, a certification mechanism with a chain of custody model could attest to the prewashing
of the textiles. The amount of microfibre released from synthetic fabrics is bigger in the first few
washes than at other stages. Therefore, at the end of the production phase and/or before the
textiles/garments are put on the EU market, mandatory prewashing could reduce the microplastic
released during the washing phase. To be efficient, especially outside the EU, where wastewater
treatment is limited, this measure should be combined with measure TEX#5: Specific wastewater
treatment in production plants.
How could the measure be implemented?
The measure would be implemented through legislation changes (review of the IED Directive, BREF
for the companies in the EU and potentially the non-quantitative performance requirements of the
ESRP).
Measure TEX#5: Specific wastewater treatment in textile production plants
Type of measure: Regulatory action
Description of the measure
A specific wastewater treatment would be mandatory for all the textiles put on the EU market.
Therefore, the plants in and outside the EU putting textiles on the EU market would need to equip
themselves. This measure implies a microplastic filtering system for the wastewater of textile
production plants. Some of the production plants in the EU are covered by the IED and by the BAT
248
Ibid.
331
Conclusions for the Textiles Industry249,
in which cases the corresponding permits must contain
emission limit values based on the BAT Conclusions. The BAT Conclusions contain, inter alia, levels
for direct emissions of suspended solids into water bodies.
This measure is associated with measure TEX#4: Mandatory prewashing before placing on the
market. There are microplastic emissions at several steps of textile production (pre-treatment of the
fibres, dyeing, etc.). Therefore, wastewaster treatment is more relevant than only filters for
prewashing.
How does the measure work?
In practice, a certification mechanism with a chain of custody model could attest to a specific
wastewater treatment to capture microplastics during the production phase, especially during wet
processing as dyeing, printing, and chemical finishing.
How could the measure be implemented?
The measure would be implemented through legislation changes (possibly through the
Urban Wastewater Directive for the companies in the EU).
Measure TEX#6: Compulsory filters for washing machines
Type of measure: Regulatory action
Description of the measure
This measure aims to reduce microplastic releases from the washing process during the use phase by
making filters compulsory for household washing machines.
How does the measure work?
A filtration device can be added to the drum of the washing machine or positioned at the end of the
drainpipe (external filters), or it can be a built-in filter (internal filter). Performance criteria and
handling criteria have to be defined. There is a risk of mishandling the retained microplastics. For
example, if the consumer rinses the filter in the sink, the microplastics will still be transferred to the
urban wastewater system. Therefore, clear communication is needed to advise on and promote best
practices of filter cleaning.
A filter could be mandatory for new machines sold as those filters are more cost-efficient than the
filters added to existing machines. External filters would be advised to consumers with high
awareness who would like to reduce their microplastic emissions because they are likely to apply
best practices and avoid rinsing the filtering system in the sink. It would take between 7 and 12 years
to cover all washing machines with internal filters based on the uptake in new and existing stock and
the average lifetime of washing machines.
249
COMMISSION IMPLEMENTING DECISION (EU) 2022/2508 of 9 December 2022 establishing the best available
techniques (BAT) conclusions, under Directive 2010/75/EU of the European Parliament and of the Council on
industrial emissions, for the textiles industry, OJ L 325, 20.12.2022, p. 112–161
332
How could the measure be implemented?
The measure would be implemented through legislation changes (implementing measure under the
Ecodesign Directive for electrical and electronic equipment or possibly under the proposal for
Ecodesign for Sustainable Products Regulation).
Measure TEX#1: Standardised methodology to quantify microplastics releases from textiles
Type of measure: Standardised measurement methodology
Description of the measure
This measure entails creating a standard for the measurement of microplastics releases over the life-
cycle of synthetic textiles.
How does the measure work?
This measure requires defining a reference method to quantify (via weight, for example) microplastic
release at each step of the life-cycle and a standard testing method (filter to use, washing temperature,
etc.) for synthetic textiles. The result could be a CEN standard that covers the microplastic releases
of textiles on the whole life-cycle.
How could the measure be implemented?
It could be implemented through voluntary or regulatory channels (e.g. a new EU legislation).
6.3 Measures for paints
6.3.1 Long list of measures
Microplastic releases from paints can be reduced by measures that impact one or more of the life
cycle stages of the paint and the painted object. Hence, potential measures have been grouped in the
following manner:
Knowledge and capacity building: Paint with respect to other sources of microplastic pollution has
only recently caught the attention of policymakers. Thus, several actions could be taken to deepen
the understanding of the paint microplastics problem and address it at both a scientific and
legal/policy level. Awareness-raising and education on the issue is also a key point to tackle.
Product Design; Measures could be taken at the very first stage of the paint life, meaning improving
the paint formulations and improving the quality of the products on the market in the light of
environmental compatibility.
Application & Maintenance Actions can also be taken at a later stage, at the moment of application
or once the paint is already on the intended object (e.g. maintenance and removal).
During the stakeholder workshop organised on 17 March 2022, 53 proposals in total were identified,
out of which 7 were excluded as they were only comments and not measures. 5 were screened out.
The remaining 41 selected measures were grouped and merged to form 12 more comprehensive
measures.
333
6.3.2 Measures discarded prior to assessment
The table below summarises the measures that have been screened out from the evaluation as well as
the reasons for their exclusion. The reasons for exclusion are mainly technical feasibility or their lack
of coherence with other EU objectives.
Table 22: Screening of measures for paints
Category Measure
description
Reason for screening out
Market failure
/ Regulatory
failure
Use more biocide anti-
fouling agents to
prevent organisms from
sticking to the hull and
thereby prolong the
lifetime of antifouling
paint
The measure has been discarded for lack of coherence with other EU
objectives. This is because it is in contrast to other efforts at the
European level to reduce the detrimental effects of biocide in nature
Biocidal Products Regulation (BPR), Regulation (EU) 528/2012.
Promote the use of self-
healing paints
The idea of self-healing paints is based on the reparability of applied
paint layers. Repair of the paint layer is currently only possible once
for each crack, and this technique is still under development. The
expected full-scale application could still take 10 years […].250
In light
of this information, we discarded the measure for reasons of technical
feasibility as we want to focus on more promptly available solutions.
Promote the use of
paints with higher
content of solids (less
solvent/water) in order
to consume less of the
paint itself
This measure was discarded as it doesn’t address the problem. The
share of the paint that solidifies is the one constituted by the polymers;
what renders the mixture liquid is a solvent. Therefore, having thicker
paint (i.e. with less solvent) would not affect its microplastic release.
Replace antifouling
paint with silicone paint
Antifouling paint is used to prevent biofouling, which causes increased
ship fuel consumption, reduces the ship’s top speed, and can spread
invasive species. Most antifouling paints release biocide to prevent
biofouling, and silicone paint is a biocide-free alternative that prevents
fouling by creating a sleek surface. The measure has been discarded
because it does not necessarily reduce microplastic releases.
Market failure
/ Regulatory
failure
Since winter
maintenance of roads
can influence road
marking wear (e.g.
street sweeping), one
could provide a monitor
and reporting scheme
on when street
sweeping should be
carried out in relation to
precipitation events,
etc.
This measure has been discarded for low efficiency and lack of
coherence with other EU objectives; road maintenance is designed
to prioritise safety and not avoidance of wear and tear of road
markings.
250
Faber, M., Marinković, M., de Valk, E., & Waaijers-van der Loop, S. L., ‘Paints and microplastics. Exploring the
possibilities to reduce the use and release of microplastics from paints. Feedback from the paint sector’, RIVM (Dutch
National Institute for Public Health and the Environment) report, 2021.
334
Category Measure
description
Reason for screening out
Introduce microplastic
releases during paint
maintenance as a
criterion in the
Taxonomy Regulation.
The measure would require economic activities that wish to be labelled
as sustainable to not emit microplastics during paint maintenance. The
measure would, therefore, target only selected sectors such as wind
energy. Consequently, the measure has been discarded due to a
potential lack of effectiveness and efficiency.
EPR to finance proper
disposal of paint
removed during surface
maintenance
The measure was discarded because it is not possible to clearly
attribute the responsibility (from an EPR perspective) to paint
producers as they are not alone responsible for the poor application
and maintenance of paints.
Information
failure
Assess and try to better
understand which paint
substitutes can be used
for specific
applications.
The measure has been discarded for technical feasibility reasons.
Differentiating the use of paint and pairing it with possible substitutes
would require a comprehensive assessment of the economic,
environmental, and social impact of all those substitutes. Also, a
substitute for application A may not work for application B. Different
aspects such as climatic conditions also needs to be considered.
Investigate the
degradation process of
paints
“Degradation” in this context refers to the change in polymer-based
product (paint particles in the environment) properties such as tensile
strength, shape, colour, molecular weight etc., under the influence of
one or more external (environmental) factors such as heat, light,
chemicals, or other applied forces. Investigating degradation
mechanisms alone will not be efficient in reducing microplastic
releases, and consequently, this measure has been discarded due to a
lack of effectiveness and efficiency.
Innovation challenges The measure has been discarded due to a lack of effectiveness in
controlling microplastic release in the short term.
Monitoring of paint
microplastic pollution
in the aquatic
environment
This measure has been discarded because it is not specific to paints.
This can be dealt with by including microplastic monitoring in
environmental monitoring through existing policies.
Market failure
/ Regulatory
failure
Preventing boats from
undergoing ship-
breaking beaching
practices
The measure has been discarded because of proportionality.
6.3.3 Measures to be assessed for paints
Measure PNT#2a: Mandatory label on paint lifetime and plastic content
Type of measure: Supply chain/consumer information to enable selection of less polluting products
or change in behaviour. The label requirement should be mandatory. Possibly, the measure could be
set up as a voluntary label (not assessed). Further on, the requirement could be transformed as a
threshold value needed for product authorisation and to enter the EU market. This is assessed in
Measure PNT#2b.
335
Description of the measure
This measure aims to inform consumers on key properties of paint, i.e., the plastic content of paint
(expressed, for example, as a percentage of the total weight) and the paint lifetime, so that they can
make an informed choice based on their needs and avoid polluting behaviour. Paint is a mixture;
therefore, its performances and properties are correlated to the nature and the relative quantities of
its components, a major one being the binder, which is the one commonly made of synthetic organic
polymers. Plastic content is, therefore, to some extent, correlated to the paint system properties, for
example, the lifetime, but that largely depends on the nature of the polymers themselves and the
conditions to which they are exposed. A higher plastic content could, in fact, increase the paint
lifetime and therefore decrease the need for repaint). However, examples of completely different
systems also exist, such as mineral-based architectural paint, which contains less than 5% of plastic
and requires repainting every 20-25 years on exterior surfaces, while most plastic-based paint used
for exterior surfaces requires repainting every 8-12 years. Not all applications require long-lasting
paint systems. Interior walls, for example, tend to be repainted every 3-4 years, not because the paint
system breaks and the substrate risks being damaged, but for aesthetic purposes. Interior decorative
paint is estimated to cover 70% of the architectural paint demand251
, which itself covers more than
50% of the market share. The DIY sector is another sector where probably weather-enduring paint
systems are unnecessary (e.g., for paintings, woodworks, etc.), although this sector covers a much
smaller portion of the market.
How does the measure work?
The measure requires paint producers that sell on the EU market to add on the paint label the plastic
content and the lifetime of the paint. To reach this goal, several steps are required. Having a clear
definition of plastic content in paint is key: whereas the REACH252
only refers to polymers (chapter
2), and the Single use plastics directive 253
– point 11 – clearly excludes paint from the scope, a
definition of the plastic content in the paint is missing. This creates disagreement among stakeholders
regarding the issue.
As a first step, a scientific task force can be created to investigate the use of synthetic polymers in
paint and come up with a definition of plastic content in paint that is sufficiently inclusive to cover
the development of a new formulation of synthetic polymers. In that regard, after scientific
discussions conducted with polymer experts in academia, the following point of discussion (non-
exhaustive list) need to be considered:
• Should the plastic in the paint definition include all synthetic polymer-based materials? The
definition of plastic material should comprise the terms polymer and resin as well, as resins
are actually polymers. Also, the definition should be inclusive enough to account for the
current paint formulation and synthesis/usage of new polymers.
• In which physical state is a substance considered plastic: solid/liquid/gas? Typically, with
the term plastics, only solid polymers are considered, but one has to pay attention to the fact
251
Hall et al., Constructing sustainable tourism development: The 2030 agenda and the managerial ecology of sustainable
tourism, J. of Sustainable Tourism, 27:7, 2018.
252
European Parliament and Council of the European Union, Regulation (EC) 1907/2006 concerning the Registration,
Evaluation, Authorisation and Restriction of Chemicals (REACH), establishing a European Chemicals Agency,
amending Directive 1999/45/EC and repealing Council Regulation (EEC) No 793/93 and Commission Regulation
(EC) No 1488/94 as well as Council Directive 76/769/EEC and Commission Directives 91/155/EEC, 93/67/EEC,
93/105/EC and 2000/21/EC, OJ L 396, 30.12.2006, pp. 1.
253
European Parliament and Council of the European Union, Directive (EU) 2019/904 on the reduction of the impact of
certain plastic products on the environment, OJ L 155, 12.6.2019, pp. 1-19.
336
that an amorphous solid polymer is considered liquid by thermodynamics because it is not
crystalline. In this context, though, a liquid should be considered as a material showing the
container's shape. Polymer dispersions instead could also be solid (e.g. pigmented plastics)
but also liquid as those in paint. The inclusion of liquid polymers and PLF (Polymer in Liquid
Formulations), which can solidify in various circumstances (type of polymer, temperature,
evaporation of solvent etc.), should also be discussed.
• What should be biodegradability? For this point is particularly important to discuss whether
to include biodegradable polymers (if so, which are the characteristics of the material to be
considered biodegradable)? A valuable starting point is represented by the analysis done in
the RIVM report 2016 (Verschoor et al., 2016). To be noted that in this case, the definition of
what should matter is the final product and not the synthetic route nor the source (e.g., bio-
sourced polymer) as they do not affect potential risk assessments.
The measure would require that agreements are made on the definition of paint lifetime and that the
use of a standardised test is being ensured (see PNT#1).
Thresholds to limit plastic content below a certain amount and/or lifetime above a certain number
of years could be set to access the European market (PNT#2b).
Antifouling paints should be excluded from this legislation. Antifouling paints are applied on ship
hulls to prevent marine biofouling (e.g., algae, barnacles, and mussels). Biofouling reduces the speed
and increases fuel consumption, which is crucial in preventing non-indigenous species contamination
from one water basin to another. The principle through which the paint works is based on the presence
of the release of active substances, i.e., toxic biocides, from the coating that acts to repel and/or poison
fouling organisms. These types of paint are either hard paints, which are more durable (but still wear
off over time) or ablative paints, also known as self-polishing paint, which slowly slough off in the
water. This kind of paint contaminates the environment by design with both toxic substances and
microplastic particles. We suggest excluding antifouling paint from the scope as plastic releases being
one of the concerns, as antifouling paint is also related to biocides emissions, CO2 emissions and the
spread of non-indigenous species. Therefore, for antifouling paint, a more inclusive approach needs
to be taken into account to avoid trade-offs between a reduction in microplastic releases and an
increase in biocides or CO2 emissions, for example.
Benefit:
The expected/desired impact is:
• Consumers choose less plastic-intense paints, especially when a long paint lifetime is not a
key requirement for the application (e.g., interior architectural paint, DIY decorative works)
• Promote the use of mineral-based paints (as opposed to plastic-based paints), especially for
exterior architectural paint
• Inspire formulations of new products or improvement of existing ones or other technological
alternatives to paint to reduce the environmental impact of paint coatings
Negative environmental impacts in terms of CO2 emissions or toxicity cannot be excluded, for
example, a more toxic compound could be introduced by extending the lifetime of the paint. There
is insufficient evidence on the effects of reduced plastic content, and whether it could impact the
functional properties of the paint and its cost. Once a definition of plastic paint is agreed upon at the
EU level, it should be easy for paint producers to determine the amount of plastic in paints based on
the paint formulation. The plastic content could be expressed as a “wet” share, i.e., plastic
weight/paint weight, as a “dry” share, i.e., plastic weight / (paint weight when cured), or in grams.
Probably, the “dry” share, in %, is the one that would have the most significant impact in driving
consumer behaviour, as it is easier to understand than values in grams, and it is higher than the “wet”
337
share. Having the plastic content in grams instead would simplify reporting of plastic content for
paint importers (see the measure on a deposit-return scheme for paint containers).
The crucial step is the development and adoption at the EU level of a standardised methodology to
determine the paint-system lifetime (linked to the wear & tear rate)254
. While in light of new
legislation, testing the lifetime of the paint products should not be a burden for big paint producers,
small businesses might encounter difficulties. Open access or creating conventions with testing
facilities at the European level for companies might be a valuable means of implementation.
Alternatively, a threshold on the amount of paint put on the market could be set to exclude smaller
companies from the labelling requirements. Attention should be put on how the consumer
understands the concept of paint “lifetime”. The lifetime should be understood as “time needed before
repaint” and not as “time before the paint degrades in the environment”. The label's design must be
agreed upon so that it is easily understandable and highly visible since the main target group of the
measure is the general public. A monitoring framework should verify compliance with the legislation.
In order to facilitate monitoring of compliance with the label requirements, standardised tests to
assess plastic content could be put in place.
We believe imposing thresholds to enter the EU market should take place at a later stage (see measure
PNT#2b). Following this reasoning, if the thresholds on maximum plastic content would be imposed,
the compositions of the paints will need to change to provide the same (or improved) performances.
There is no way to predict what new formulations would look like in terms of environmental impact
(one possibility out of many: lower plastic content, same lifetime but more toxic degradation products
once released into the environment).
How could the measure be implemented?
At the EU level, some directives on paint composition exist already, for example, to define eligibility
requirements that minimize environmental impact (e.g. Ecolabel255
), or GPP that requires the
inclusion of clear and verifiable environmental criteria for products and services in the public
procurement process and also directives on the VOCs (Volatile Organic Compounds256
) aimed to
prevent the negative environmental effects of emissions of chemicals included in paint. Other
relevant legislation which could take up this measure include the Construction Products Regulation
and the Ecodesign for Sustainable Products Regulation.
Measure PNT#3a: Promote mineral paint in the architectural sector
Type of measure: Non-binding approach
Description of the measure
Measure ‘PNT#3b: Restrict polymer-based paints in the architectural sector’ has a similar set-up, but
with a regulatory, binding approach. Currently, the paint market is dominated by formulations based
on polymeric organic binders. This doesn’t leave much space for alternatives, which might be
valuable for some sectors that might not necessarily require high plastic content paints or might even
benefit from different formulations. Mineral paint (formulations based on inorganic binders like
silicate or lime) is a valuable alternative in the Architectural sector. Mineral paint should contain less
254
KTA-Tator, ‘Expected service life and cost considerations for maintenance and new construction protective coating
work’, 2016 (https://kta.com/kta-university/expected-service-life-coatings/).
255
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32014D0312
256
Directive 2004/42/EC
338
than 5% organic compounds (including binder, solvent, and additives) (according to German
regulation DiN 18363 2.4.1), while the rest is mineral raw materials (e.g., alkali potassium silicate).
The very nature of the chemical bonds within the ingredients renders these products robust and
resistant, especially to UV radiation (in contrast to paint based on organic binders). When applied to
a mineral substrate, these products present a lifetime which can go up to two folds the one of usual
dispersion paint (the one based on organic binders), i.e., a lifetime of 20-25 years compared to a
standard 8-12 years, for exterior coatings257
. This measure aims to increase the market for mineral
paint and render it the primary product used in architecture. The desired impact is to decrease the use
of paints with high plastic content in the Architectural paint sector, which represents the highest
market share. This will significantly decrease the amount of microplastic pollution due to paint
particles from buildings.
How does the measure work?
This measure will use voluntary approaches to increase the penetration of mineral paints through
market demand and supply.
How could the measure be implemented?
The measure could be implemented as an inclusion of the mineral paint in the GPP or the
ECOLABEL in a way that will be a soft push towards this kind of no-plastic-containing coatings.
Measure PNT#5: Good practices for paint applications in all sectors
Type of measure: Non-binding approach
Description of the measure
This measure is about the EC support to draft guidelines by the paint sector on good practice guidelines
for all sectors using paints to prevent microplastic releases to the environment during the paint
application and maintenance of the painted layer of an asset. This measure could indirectly incentivise
the technological development of clean maintenance techniques. The measure requires compiling a
set of good practices for various assets (buildings, road markings, industrial facilities, auto, industrial
wood items) for paint application, removal, surface preparation and waste management. In terms of
enforcement, environmental permits granted to asset owners could include the requirement of
compliance with good practices. The expected impact of the measure is the reduction of microplastic
release from paint maintenance in Europe and incentivising the technological development of clean
paint removal methods.
How does the measure work?
The first step is to define a set of good practices to limit paint releases to the environment. These
practices should cover (non-exhaustive list):
1) Paint application in a closed environment
2) Paint application in an open environment
3) Paint removal in a closed environment
4) Paint removal in an open environment
257
Personal communication by a stakeholder
339
Furthermore, they should include best practices for surface preparation, as good surface preparation
is key to guaranteeing good paint adherence to the substrate and maximising the paint lifetime
(reducing paint input on the market and microplastic releases during the use phase).
Overall, we estimate that around 139 kt of microplastic is leaked into the environment due to
improper paint removal (note that of this, 48 kt are lost during ship maintenance outside of Europe).
Losses at applications are also to be considered, especially in sectors where spray is used (automotive
and industrial wood) and in situations where the application cannot be made indoors (e.g. general
industrial settings). The architectural sector, in this respect, contributes less than others because
brushes and rollers are used.
Specifically for the sectors of Marine, Road Markings, Architectural, General Industrial, and
Automotive, good practices are already available, as presented below.
Marine:
Various activities occur at shipyards that can lead to paint microplastic releases into the environment.
Overall, we estimate that around 50 kt of microplastic is lost to the ocean during commercial ship
maintenance at dry-dock, and another 10 kt is lost due to the maintenance of leisure vessels. For
commercial vessels, the activities performed in shipyards are: paint application during boat building,
paint removal and re-paint during boat maintenance (for example, at dry-dock or floating dock), and
in-water removal of biofouling of the boat hull. For leisure vessels, instead is generally paint removal
and re-paint (mostly done onshore, in the open air).
The good practices for ship maintenance should cover (non-exhaustive list):
1) Paint application in a closed environment (for leisure boat maintenance or ship-building)
2) Paint application in an open environment (for leisure boat maintenance onshore and commercial
boat maintenance in dry-dock or floating dock)
3) Paint removal in a closed environment (for leisure boat maintenance)
4) Paint removal in an open environment (for leisure boat maintenance onshore and commercial
boat maintenance in dry-dock or floating dock)
5) In water hull cleaning
Furthermore, they should include best practices for surface preparation, as good surface preparation
is key to guaranteeing good paint adherence to the substrate and maximising the paint lifetime
(reducing paint input on the market and releases during the use phase). For points 1 and 3, it is
straightforward to identify good practices, as the paint losses are confined to a closed space. On the
other hand, avoiding releases requires technological development or capturing mechanisms when it
comes to maintenance in the open environment or in water.
Some of the technologies known to prevent releases during maintenance of metallic surfaces are
vacuum blasting and ultra-high pressure water jetting with vacuum systems and filter technology.
For the maintenance of wood surfaces (mostly for leisure vessels), infrared paint removal prevents
dust formation and facilitates the collection of removed paint. For paint application, air-less spray
guns have a higher transfer efficiency, 90%, than air guns, 70% (International Labour Office (2012).
Encyclopaedia of Occupational Health and Safety 5th
edition). For in-water hull cleaning, which is
done to remove biofouling but can also lead to antifouling paint losses, technologies exist that provide
in-water vacuum cleaning of the hull. In general, open-sand blasting of painted surfaces should be
avoided in open environments, as it has been shown that the dust formed can travel hundreds of
meters from the blasting site (EPA, 2016. Evaluation distances for effective air quality and noise
management.), directly polluting ocean and seas. Dust formation during maintenance has been a
concern mainly for the workers’ health. During a personal communication, a stakeholder mentioned
340
that China is now banning the use of open sandblasting in shipyards and promoting hydro-blasting
instead. Hydro-blasting without a pump/vacuum system prevents dust formation, requiring the water
to be collected and filtered to remove microplastic. Currently, some shipyards are using gravitational
settling tanks to “treat” the water collected from drydocks (email exchange with InfoMil
Netherlands). This could be insufficient to guarantee to capture microplastics, which have specific
gravity similar to that of water (0.9 – 1.4g/cm3, Andrady AL, 2011.)
The Best Available Techniques Conclusions document for surface treatment using organic solvents
including preservation of wood and wood products with chemicals define Best Available Techniques
for painting of ships, including removal of old paint, for those shipyards using a large quantities of
organic solvents. Shipyards in the scope of this document are required to implement the BAT in order
to operate. The techniques allowed during drydocking involve the use of protection systems like nets
when sandblasting or the use of wet blasting methods. Both these techniques redirect the removed
paint residues to the water that is collected at the bottom of the drydock. The document indicates that
the water should be collected, separated, and sent to wastewater treatment plants. In addition, a
document of the Infomil Knowledge centre in the Netherlands258
also states that the water collected
from the dock is to be sent to wastewater treatment or treated aside with settling tanks and then
released to surface water or water treatment plants.
In conclusion, in application of the current set of BAT, the paint lost during surface preparation and
paint re-application would be redirected to wastewater. Unfortunately, as a study made by the Tumlin
and Bertholds for the Swedish Svenskt Vatten shows, 40-60% of the microplastic in the incoming
wastewater is then found then in the sludge, which in Europe is often used as a soil fertilizer. Another
aspect on which the guidelines could be clear and strict is the spraying techniques. In fact, some of
the spray techniques listed in the BAT have a transfer efficiency of 50% or 60%, which is much lower
than the transfer efficiency of 90% that one can obtain with airless spray guns. Transfer efficiency of
50% would imply that half of the paint is lost at application, and if the paint application is made
outdoors, this is a significant direct leakage to the environment.
The conclusions that can be drawn from the analysis of the BAT document show that the good
practices for ship maintenance should then involve techniques that maximise transfer efficiency at
application and minimize dust formation at removal. The latter can include both vacuum blasting
techniques and water blasting, but in the second case (as for any technique involving water usage),
the wastewater should be appropriately treated; otherwise, the microplastics that end up in the sludge
would just be used in agricultural soil.
Road Markings: The document “Effective Removal of Pavement Markings” by the National
Academies of Sciences, Engineering, and Medicine 2013. Washington, DC: The National Academies
Press259
reports various techniques for removing road markings, and for our purposes, we may focus
on those with low to no dust formation. These will be grinding, shot blasting, excess oxygen, laser
and chemical removal. Another potential solution is the creation of inlaid road markings; although
this is a quite demanding technique which might compromise the integrity of the road, therefore it is
valuable only in countries with heavy snowfalls where snow can ruin the markings260
.
258
Rijkswaterstaat Environment [The Directorate-General for Public Works and Water Management], ‘Kenniscentrum
InfoMil [Knowledge Centre InfoMil] (https://www.infomil.nl/), Nl.
259
Pike, A.M. and Miles, J.D., ‘Effective Removal of Pavement Markings’, National Cooperative Highway Research
Program, Report 759, 2013.
260
Johannesson, M., & Lithner, D., ‘Potential policy instruments and measures against microplastics from tyre and road
wear: mapping and prioritisation’, Swedish National Road and Transport Research Institute (VTI), No. 1092, 2021.
341
Architectural: For the application of paint products on buildings, mineral paint can be used when
mineral substrates are as concerned (see PNT#3a & PNT#3b). For interior surfaces, using paint
products with low polymer content should be considered, as performance against harsh weather is
not an issue.
In the removal phase, especially on wood substrates, the best practices to minimise paint release from
wood surfaces are vacuum sanding or infrared removal. For metal surfaces, instead, the best option
is to optimise the applications using technologies with a high transfer rate.
General Industrial: This sector is characterised almost exclusively by metal surfaces on which the
paint is applied. The best option to reduce microplastic leakage is to optimise the applications,
reducing overspray losses using higher transfer rates. Technologies with transfer rates from 50% to
75% could be found in the Best Available Techniques Conclusions by Chronopoulos et al.261
.
According to the ILO, air-less spray guns have a transfer efficiency of 90% (International Labour
Office (2012). Encyclopaedia of Occupational Health and Safety 5th
edition).
During the removal phase, it is imperative to use technologies that capture the paint particles during
operation. This will guarantee the elimination of releases into the environment. Lastly, during
removal, a critical step is to perform proper surface preparation prior to reapplication. Indications on
the process are provided by the paint product warranty, and this will maximise the paint lifetime.
Automotive: The only recommendation we can provide is to increase the transfer efficiency of paint
guns for repair jobs. Several studies exist where they relate spray systems and application conditions
to transfer efficiency. Heitbrink et al., 1996; Poozesh, S., et al., 2018. The recommendation is always
to use the best system and condition possible to minimize the losses of paint ad application.
Once good practices have been developed, they could be implemented by granting a certification to
paint professionals who comply with good practices to promote their work and incentivize the use of
clean methods for asset maintenance.
How could the measure be implemented?
A set of guidelines should be developed per sector and adopted by the relevant industrial sectors
voluntarily.
Measure PNT#4: Deposit-return scheme for paint containers
Type of measure: Market-Based Instrument
This measure should be mandatory.
Description of the measure
The aim of this measure is to put in place an EPR scheme to drive knowledge creation and gather
valuable insight on the volume of unused paint, its contribution to environmental pollution and its
fate (points 1-3 above). Subsequently, once a better understanding exists, the EPR scheme will be
valuable in driving change, reducing unused paint, microplastic pollution and increasing circularity.
261
Chronopoulos G. et al., ‘Best Available Techniques (BAT) Reference Document on Surface Treatment Using Organic
Solvents including Preservation of Wood and Wood Products with Chemicals’, Publications Office of the European
Union, EUR 30475 EN, JRC122816, 2020.
342
It will address the problem of market failure and regulatory failure. I will also address the information
failure problem because:
1. The amount of unused paint is potentially currently underestimated
2. It is unknown how much unused paint is improperly disposed of in EU-27 (e.g., disposal to
unauthorised dumpsites, disposal through household drainage system), leading to
environmental pollution
3. Of the unused paint that is collected, only a small fraction is recycled
Point 1
It is believed that, on average, 3% (OECD, 2009) of professional paint and 15% of DIY paint are
unused.262
(Release of microplastics and potential mitigation measures: Abrasive cleaning agents,
paints and tyre wear)., OECD, 2009.). But, according to a personal communication with ADEME
(the French agency for ecological transition), paint cans recovered through an EPR scheme targeting
household chemicals are, on average, 40% full. Additionally, an internal paint company document
indicates that 30-40% of paint prepared for an offshore maintenance job can end up being unused
and subsequently disposed of.
Point 2
In terms of fate, in our baseline assessment, we assumed that the 85 kt of plastic within unused paint
in Europe is always disposed of as waste. A personal conversation with an architectural paint industry
expert revealed that professionals and DIYers might use the domestic drainage system to dispose of
unused paint. Since sludges recovered from wastewater treatment in Europe (except for the
Netherlands) are spread on agricultural land as fertilizer, the disposal of unused paint in the domestic
drainage system leads to microplastic pollution to the environment. Moreover, some paint is also
disposed of in unauthorised dumpsites (personal conversation with ADEME), although an assessment
of the volumes of improperly disposed paint is not yet available.
Point 3
Unused paints are a valuable resource, and their recycling is technically feasible263
. Paint is 37%
plastic as the binder. Added microbeads are a specific case used only in some technical coatings (e.g.
road markings). So unused paint has also plastic and though emission from unused paint into the
environment is not necessarily in the form of microplastic, but as plastic, that in turn will be
fragmented in microplastics. It is unknown how much of the unused paint is recycled in EU-27.
According to a personal communication with ADEME, in France, where there is an EPR system in
place to target the disposal and management of household chemicals (including paint), it is estimated
that less than 1% of the recovered paint is recycled. The lack of recycling is due to a conflict between
the PRO and the only paint recycler on French territory. “The vast majority of the waste is still
incinerated (mostly with energetic valorisation – R1 treatment)”. But in the process, metallic
containers are also incinerated.
262
Verschoor, A. et al., ‘Emission of microplastics and potential mitigation measures: Abrasive cleaning agents, paints
and tyre wear’, Dutch National Institue for Public Health and the Environment, 2016
(https://rivm.openrepository.com/bitstream/handle/10029/617930/2016-0026.pdf?sequence=3).
263
AkzoNobel, ‘AkzoNobel launches recycled paint to help close loop on waste’, 2019
(https://www.akzonobel.com/en/media/latest-news---media-releases-/akzonobel-launches-recycled-paint-to-help-
close-loop-on-waste).
343
Benefit: The ultimate desired impact is to increase the disposal of unused paint through proper
channels and finance its recycling. An efficient way to target DIYers could be by actively involving
the distribution chains through deposit-return schemes (i.e., easily accessible collection points and
communication/promotion campaigns to encourage the general public) or by promoting the door-to-
door collection.
How does the measure work?
This measure requires setting up an EPR scheme where paint producers pay based on how much
plastic they put on the market. The money collected will be used in the first phase to drive knowledge
creation and in the second phase to drive change.
The EPR scheme requires paint producers, as well as paint importers within the EU market, to declare
to the EPR operator how much (wet) paint they put on the market and how much of that paint is
plastic. In order to harmonise the reporting, a standard definition for plastic in the paint should be
agreed upon. A threshold could be set to only target the main producers, therefore avoiding excessive
administrative burdens for the authority as well as for small paint producers. A small number of large
producers dominate the paint industry. Both European and non-European paint companies sell paint
on the EU market. We could not find figures for the paint sold to the European market from non-
European producers, but there are figures for paint sold by European producers264
. These indicate
that the top 3 European producers cover more than 50% of the paint sales (from EU producers to the
EU market), and the top 10 cover 80%. At the global level, the trend is similar, with the top 20
producers covering 80% of the global paint sales265
. Input from ADEME confirms the trend;
according to their data, the top 5 paint producers represent 81% of the market.
For each paint sector, after it has been determined how much paint is sold in the EU market, one
could decide that all producers and importers of more than a tenth of it should be included in the EPR
scheme. This would probably limit the number of paint producers/importers to 3-5 per sector. There
is currently no single definition of the different paint sectors. In this assessment, we used a split based
on the asset on which the paint is applied, but a different split could be more suitable for the paint
industry. In the first phase, the objective of the EPR scheme and the role of the PRO would be to:
1. Assess the amount of unused paint as well as the amount of paint put on the market
2. Finance research and assessment studies of improper disposal of unused paint
3. Assess the current recycling rate of unused paint and the potential recycling capacity
In the second phase, the objective of the EPR scheme will be to increase the collection rate of unused
paint through the proper channels (e.g. by setting up deposit-return schemes, door-to-door collection,
etc.) and reduce microplastic pollution through preventive measures (such as communication
campaigns) or curative measures (e.g., by financing wastewater treatment). Ultimately, the EPR
should incentivise the recycling of unused paint. A successful example of a take-back scheme seems
to be PaintCare, a program of the American Coatings Association, active in 10 US states, that
encourages households and businesses to bring unused paint to the collection site.266
In Denmark, the
city of Odense put in place a door-to-door collection system for hazardous household waste (see
GOOD PRACTICE ODENSE: Hazardous Waste Collection October 2014, for reference).). In
264
European Coatings, ‘Ranking: The 25 largest coatings producers in Europe’, 2018 (https://www.european-
coatings.com/articles/archiv/ranking-the-25-largest-coatings-producers-in-europe).
265
Coatings World, ‘Top Companies Report’, 2021 (https://www.coatingsworld.com/issues/2021-07-01/view_top-
companies-report/top-companies-report-163001/).
266
PaintCare, ‘Home page’(www.paintcare.org).
344
Odense, paint accounts for 75% of the volume of the recovered hazardous waste. On the other hand,
a distribution chain in France, Tollens, currently allows for the take-back of paint cans. However, a
conversation with a local distribution centre revealed that they accept only clean cans or small
quantities of paint residue. The recovered cans are sent to recycle the can itself and not the paint.
Therefore, if a take-back scheme is put in place, the scheme's basic principles and organization should
be clearly stated and communicated to actually target the paint and avoid the return of the can alone.
The information gathered through the EPR scheme and the PRO should be made publicly available.
Such a report could also implicitly allow keeping track of the amount of paint that has not been
recovered and improperly disposed of by comparing the performance in the different Member States.
To facilitate the comparison, it would be better to require the paint producers or the importers to
declare the amount of “wet” paint put on the market, i.e., including the solvent or water that
evaporates upon application.
How could the measure be implemented?
This measure would require setting up a Producer Responsibility Organisation (PRO).
Measure PNT#2b: Threshold on lifetime and plastic content for paints
Type of measure: Regulatory action
This measure is dependent on measure PNT#1 and PNT#2a.
Description of the measure
This measure aims to regulate access to the European market only to paints that have plastic content
below a chosen threshold (expressed, for example, as a percentage of the total weight) and a lifetime
above a certain threshold, in order to reduce microplastic pollution. A better insight on how plastic
content and paint lifetime are defined and their relation to plastic pollution is available in measures
PNT#1 and PNT#2a.
How does the measure work?
The measure aims on building on the knowledge created through the introduction of labels on paint
lifetime and plastic content (PNT#2a), in order to exclude from the market the worst performing
paints in terms of microplastic pollution potential. The thresholds could become increasingly
stringent over the years. The measure should be applied on all paints sold on the European market
(with the exception of antifouling paints – see measure PNT#2a). The thresholds could be different
for the different paint sectors. The direct benefits of setting an upper threshold for plastic content and
a lower threshold for paint lifetime would be:
• Reduction of wear & tear losses (due to longer lifetime of paint system), which should be
visible as a reduction of paint demand (less repaint needed);
• Reduction in microplastic releases due to lower plastic content in paint formulation.
It is necessary for measure PNT#2a to be introduced first in order to have a clear idea of what is the
current configuration of the market in terms of plastic content and its correlation with paint lifetime.
As this becomes clear, thresholds can be imposed. After the introduction of thresholds, the
compositions of the paints will need to change to provide the same (or improved) performances.
There is no way to predict what new formulations would look like in terms of environmental impact
345
(one possibility out of many: lower plastic content, same lifetime but more toxic degradation products
once released into the environment).
How could the measure be implemented?
Imposing thresholds on plastic content and lifetime is a type of product regulation.
Measure PNT#3b: Restrict polymer-based paints in the architectural sector
Type of measure: Regulatory action
Description of the measure
This measure builds on the analysis of ‘Measure PNT#3a: Promote mineral paint in the architectural
sector’, but going from a non-binding to a binding, regulatory approach. Currently, the paint market
is dominated by formulations based on polymeric organic binders. This doesn’t leave much space for
alternatives, which might be valuable for some sectors that might not necessarily require high plastic
content paints or might even benefit from different formulations. Mineral paint (formulations based
on inorganic binders like silicate or lime) is a valuable alternative in the Architectural sector. Mineral
paint should contain less than 5% organic compounds (including binder, solvent, and additives)
(according to German regulation DiN 18363 2.4.1), while the rest is mineral raw materials (e.g.,
alkali potassium silicate). The very nature of the chemical bonds within the ingredients renders these
products robust and resistant, especially to UV radiation (in contrast to paint based on organic
binders). When applied to a mineral substrate, these products present a lifetime which can go up to
two folds the one of usual dispersion paint (the one based on organic binders), i.e., a lifetime of 20-
25 years compared to a standard 8-12 years267
, for exterior coatings. This measure aims to increase
the market for mineral paint and render it the primary product used in architecture.
How could the measure be implemented?
The measure requires a new regulation which imposes limits on the use of dispersion paint (based on
organic polymeric binders) for the architectural sector. The desired impact is to decrease the use of
paints with high plastic content in the Architectural paint sector, which represents the highest market
share. This will significantly decrease the amount of microplastic released due to the paints used in
buildings.
How does the measure work?
It could be in the form of imposing limits on the use of dispersion paint (based on organic polymeric
binders) in the architectural sector. It can be intended as a full ban on this kind of product or a
limitation on the allowed share. We advise this measure not to be imposed on architectural coatings
intended for wood and metal, as mineral-based paint is brittle and weak when tensile forces are
applied. At the moment, to the best of our knowledge, only one independent study was done
(Trischler & Partner GmbH, Ökobilanzierung von Silikatfarben- und Kunstharzdispersionsfarben –
ein systematischer Produktvergleich, Darmstadt u. Freiburg, 1996) and points in favour of the mineral
paint. But it is an outdated report with respect to new LCA standards and to new technologies in paint
production. Therefore, an updated life cycle assessment would be needed first.
267
Personal communication with a stakeholder
346
How could the measure be implemented?
The measure could be implemented through the CPR or a new legislation.
Measure PNT#1: Standardised methodology of paint lifetime
Type of measure: Standardised measurement methodology
Description of the measure
When a plastic-based coating (for this measure, we consider any organic polymer-based coating)
starts losing its intended properties, it is at risk of detaching from the support and being released into
the environment contributing to microplastic release. Evaluating how well and how long a paint
coating will last on the support is one of the big challenges the paint industry has to face. There is no
unique way to do it as it depends on numerous factors: paint formulation (type and quantities of
ingredients) and substrate properties, environmental conditions, coating thickness, etc. Currently, the
“expected lifetime” is reported for certain paints to establish a warranty for the product. The
definition of the expected lifetime, though, is currently open to interpretation and it can be different
for decorative paints and performance coatings. In the case of decorative coating, it indicates the time
after which the coating loses its decorative purpose; in the case of performance coatings, it indicates
the time after which the coating loses its functional purpose. The lifetime is usually estimated by the
paint producers using different techniques. For example, for coatings designed to protect assets in
exterior environments, accelerated testing is one means by which formulators assess the specific
performance properties relevant to different end-use applications. Long-term performance under
harsh conditions is, as a matter of fact, required for coatings used in the oil and gas, petrochemical,
and wastewater industries.
There are several internationally applied standardised test methods — ISO (e.g., ISO 12944 on
corrosion), ASTM (e.g., B117 salt fog test for evaluation of corrosion performance, D4587
weathering assessment based on UV exposure coupled with condensation, D5894 cyclic salt fog/UV
testing, etc.) — but not all are required nor applicable for every coating and, to the best of our
knowledge, are not mandatory. Furthermore, these standardised tests assess only one phenomenon at
time, be it abrasion, corrosion, exposure to UV light, resistance to water, etc, but the lifetime is
determined by the combination of all. These testing methods are also not free from limitations,
evolving coating technologies, lack of real-time monitoring for test conditions, new expectations of
coating performances, regulations and a certain level of subjectivity involved in reporting the results,
only to mention a few. In addition, there is a need to identify the appropriate tests to perform for a
given coating formulation and application.268
A word of caution is needed at this stage: a direct, clear, positive correlation between one parameter,
plastic content, and lifetime or other properties of paint cannot exist, or at least cannot be the same
for all paint types. It is, in fact, the combination of all the components of the paint mixture (which
includes the polymers) and how they interact with each other that determines the product's
performance. Polymer properties (strength, elongation at break, elasticity, environmental resistance
etc.) are determined by the chemical composition, the molecular weight and molecular weight
distribution, the morphology of the polymer particles and of the polymer film itself. The first step
should be to agree on a definition of paint lifetime, valid for all sectors, and this should be intended
as “time needed before repaint” and not as “time before the paint degrades in the environment”. For
268
Element, ‘Materials testing: Abrasion & wear testing’ (https://www.element.com/materials-testing-services/abrasion-
and-wear-testing).
347
example, it could be defined as the time until 5%-10% of coating breakdown occurs (KTA, 2017),
which implies a release of 5-10% of the paint (and plastic) to the surrounding environment. This
measure is applicable for all paint types independently from the solvent they are based on (water-
born – dispersion paints and water-soluble paints - or solvent-born) because they can all release
microplastics. A special case could be constituted by those paints which are both water-soluble and
water-sensitive. These, in fact, might release polymers as molecular dispersions in water.
Nevertheless, they should be assessed and accompanied with a lifetime because they do release
polymeric content into the environment, just on occasion, not in solid form269
.
How could the measure be implemented?
It could be implemented through voluntary or regulatory channels. A scientific panel with coating
experts should develop a definition for paint lifetime and identify the best testing methods available
– which should be regularly updated by the agency which develops them – for each type of paint
application.
6.4 Measures for detergent capsules
6.4.1 Long list of measures
During the stakeholder meeting (17 March 2022), a preliminary list of policy measures was first
presented to the stakeholders, such as the eventual environmental persistence and the complete
biodegradability of these PVOH in different natural compartments; the most suitable standard to
assess the biodegradation of these PVOH and related mixtures; the use of alternatives to PVOH and
related mixtures such as casein- and starch-based products in which their water-solubility and
biodegradability in water have been demonstrated; and the redesign of the capsules in such as a way
that the use of PVOH is not necessary. After discussing these different measures, six main ideas were
identified in the stakeholder workshop, divided into different themes. After eliminating the
duplicates, the list of selected measures is shown below:
• Commitment to propose a fully biodegradable water-soluble plastics and related additives;
• Redesign the capsules in such a way to avoid the use of PVOH;
• Ensure the implementation of a suitable standard to demonstrate the biodegradation of PVOH
films with respect to microorganisms/references used for testing in real-life conditions (e.g.,
wastewater treatment plants);
• Implement the OECD test guidelines selectively to PVOH and related mixtures;
• Use instructions on how to load the capsules in an appropriate way to avoid any overloading;
• Strengthening enforcement and sanctioning for breaches of relevant obligations deriving from
applicable EU legislation.
269
Kopeliovich, D., ‘Classification of paints’, Substances & Technologies, 2014
(https://www.substech.com/dokuwiki/doku.php?id=classification_of_paints).
348
6.4.2 Measures discarded prior to assessment
Table 23: Screening of measures for detergent capsules
Problem area Measure title Reasons for screening out
Market/Regulatory
failure
Implementing
alternatives to
PVOH
The detergent industry is willing to deliver more sustainable products,
mainly based on bio based and biodegradable alternatives.
However, the current biodegradable alternatives derived from biomass
cannot meet the minimum technical requirements of PVOH and related
mixtures, i.e., an appropriate water-solubility on use, a good compatibility
with detergent products and good film-performances.
Market/Regulatory
failure
Make
biodegradation
standards
compulsory for
marine and
freshwater
The biodegradation assessment is conducted on the basis of six tests in
OECD 301, and each method results in an assessment of aquatic effluent
biodegradability in fully aerated conditions. Briefly, OECD 301A
measures the disappearance of organic carbon, OECD 301B quantifies the
generation of carbon dioxide, OECD 301C, 301D, and 301F monitor
oxygen uptake, and OECD 301E monitors the disappearance of dissolved
organic carbon. These tests are stringent tests that provide clear figures
about biodegradation. A compound giving a positive result in such a test
may be assumed to biodegrade quickly in municipal wastewater treatment
plants and the environment.
A separate measure is not needed at this moment.
Market/Regulatory
failure
Banning PVOH
and related
mixtures
Even if the measure could solve the microplastic releases from PVOH, it
could result in excess use of detergents, leading to increased
environmental impact.
Another reason is related to the health issue because using PVOH and
related mixtures avoids any skin contact with detergents and any allergic
issues during handling and using the capsules.
Market failure Load the capsules
in an appropriate
way
This is already part of existing policy and market practices.
Regulatory failure Strengthening
enforcement
Biodegradation standards are not taken up yet so enforcement of this
cannot happen.
6.4.3 Measures to be assessed for capsules
Measure CAP#1: Standardised methodology to quantify microplastics releases from detergent
capsules
Type of measure: Standardised measurement methodology
Description of the measure
As there is a critical knowledge gap, this measure will enable an understanding of the volume and
scale of capsule losses occurring at different life cycle stages and addresses the problem driver,
“information/knowledge failure”. There remain some uncertainties on the release of PVOH into the
environment, particularly the exact usage of PVOH and related mixtures as detergent capsules and
after wastewater treatment in which the biodegradation of PVOH depends on acclimatised
349
microorganisms. These uncertainties are related to the fact that the current standards to assess the
biodegradation of commercial PVOH and related mixtures, particularly OECD 301, gives a quick
figure about the biodegradation of tested compounds in municipal wastewater treatment plants.
However, a positive result is obtained when a certain value of biodegradation (beyond 60%) is
achieved after 28 days, and it is assumed that the compounds will continue to get biodegraded after
water waste treatments. The complete biodegradation of the tested compounds is not required for
validating the test, giving some uncertainties on the fate of PVOH, particularly whether the non-
degraded fractions will completely biodegrade after or not.
How could the measure be implemented?
It could be implemented through voluntary or regulatory channels (REACH, Detergents Regulation,
ESPR, new EU Framework on microplastics), including the use of appropriate characterization
techniques to assess the biodegradation of PVOH and related mixtures after wastewater treatments
in an appropriate manner.
Measure CAP#2: Apply current biodegradability standards to detergent capsules
Type of measure: Regulatory action
Description of the measure
This measure will enable complete biodegradation of PVOH and related mixtures after wastewater
treatments. Currently, no tests are applied to evaluate the biodegradability of PVOH. The measure
would mean that PVOH is required to comply with an already available biodegradability test method
potentially the OECD 301B270
(with or without the relevant 10-day window) which would ensure a
higher level of biodegradation. According to the OECD guidelines for the testing of chemicals, the
10-day window begins when the degree of biodegradation has reached 10% Dissolved Organic
Carbon (DOC) removal, theoretical oxygen demand (ThOD) or theoretical carbon dioxide (ThCO2)
and must end before or at day 28 of the test. Pass levels after 28 days (with 10–day window):
• 60% ThCO2 - Theoretical carbon dioxide production
• 60% ThOD - Theoretical oxygen demand
• 70% DOC - Dissolved organic carbon removal
Chemicals which reach the pass levels after the 28-day period are not deemed to be readily
biodegradable.
How could the measure be implemented?
The Detergents Regulation could be adapted to use an existing biodegradation standard.
Measure CAP#3: Redesign biodegradability standards for detergent capsules
Type of measure: Updated standardised measurement methodology and its application
270
Test No. 301: Ready Biodegradability | OECD Guidelines for the Testing of Chemicals, Section 3 : Environmental
fate and behaviour | OECD iLibrary (oecd-ilibrary.org)
350
Description of the measure
This measure will enable assessing the biodegradability of any water-soluble plastics in normal
environmental conditions.
How does the measure work?
Once the films are dissolved in water after use, the dissolved polymer chains are disposed of and
degraded during the wastewater treatment. In principle, they must be biodegraded afterwards, but
some PVOH could remain intact and could be released into the environment. However, the natural
conditions are different in terms of temperature and the likely absence of acclimatized
microorganisms. The adaptation of biodegradability standards to more relevant natural conditions
could be envisioned in such a way that even if PVOH traces are released, their full biodegradation is
ensured.
How could the measure be implemented?
This could be taken up potentially in the detergents regulation or a new legislative framework.
6.5 Measures for geotextiles
6.5.1 Long list of measures
After desk research, through the stakeholder workshop held on 17 March 2022, and bilateral
discussions with industrial stakeholders, 58 measures were identified. After refining this list, 6
measures were retained; a large reduction in the number of measures came from the removal of
duplicates and the combination of measures that different stakeholders identified. Following is the
longlist of measures:
• Guidelines for correct installation, use and maintenance of geotextiles in different
applications
• Work with relevant industry groups/associations to gather data
• Define an appropriate testing protocol to measure the potential release of microplastics
• Design product to ensure adequate durability and end-of-life handling, and optimum Life
Cycle assessment (including global warming)
• Ban of geotextiles
• Plastic-free alternatives should replace geosynthetics used for coastal or riverbank
protection
• Publication of product passports to give the exact list of contained chemicals for each
product
• Work on developing erosion-control applications in which the geotextile is covered and
unlikely to be able to release microplastics
• Procedure to request and receive approval by authorities to use the geotextile must be
established, not just free for all
• Inform municipalities and other public administrations on the environmental impacts of
geosynthetics in the open environment
• Make producers/users responsible for regular reporting on the condition and maintenance
of geotextiles in use
351
6.5.2 Measures discarded prior to assessment
The table below presents the measures which were discarded after the preliminary screening of
measures, along with the justification for discarding.
Table 24: Screening of measures for Geotextiles
Problem Area Measure Title Reason for screening out
Information/knowledge
failure
Work with relevant
industry
groups/associations to
gather data
This measure was discarded because it is included in other
retained measures. It is not a standalone measure but an element
that can be used in other measures to achieve a goal.
Product design Design product to
ensure adequate
durability and end-of-
life handling, and
optimum Life Cycle
assessment (including
global warming)
This measure is part of other retained measures.
Regulatory failure Blanket ban of
geotextiles
It doesn’t seem politically acceptable nor proportionate nor
efficient to ban geotextiles in general; they serve a purpose and
should be kept among the possible solutions for civil engineering
solutions available in the EU.
Market failure/
Regulatory failure/
Information failure
Product passport gives
the exact list of
contained chemicals
for each product
This measure would not reduce microplastic releases nor
increase our understanding of microplastic releases from
geotextiles; it would only give information regarding the
potential release and toxicity of microplastics from geotextiles as
well as some information on their material properties.
Information failure Inform municipalities
and other public
administrations on the
environmental impacts
of geosynthetics in the
open environment
The gains from this measure are expected to be minimal if
enforced on its own because geotextiles are cheaper to install
than traditional materials and so will still be used in construction
works. It is also covered by a retained measure.
6.5.3 Measures to be assessed for geotextiles
Measure GEO#2: Guidelines for geotextile use
Type of measure: Non-binding approach
Description of the measure
This measure requires the industry to develop guidelines for: the selection of geotextiles for specific
applications, the proper installation methods for geotextiles to limit microplastic releases, the correct
maintenance of geotextiles (how to repair damaged materials, when to replace damaged geotextiles,
352
their end-of-life management, etc.). The industry has extensive knowledge regarding the applications
that their products can be used for as well as the optimal conditions to use their materials in, e.g.,
during an exchange with members of the International Geotextiles Society (IGS), we were informed
that the society does not recommend using geotextiles to reduce glaciers melting and that geotextiles
exposed to UV light should have high stabilizer content to reduce their weathering.
How does the measure work?
Whenever a project is designed to contain geotextiles, the industry would follow the guidelines
provided with the material. Moreover, the clients would be able to verify that the selected material
and its installation are up to the industry’s standard set by the guidelines.
How could the measure be implemented?
A set of guidelines for the proper usage of geotextiles (which material, what manufacturing process
and how to install them) will be published by the industry and used when appropriate when
geotextiles are installed.
Measure GEO#3: Use biodegradable geotextiles for specific applications
Type of measure: Regulatory action
Description of the measure
There are applications of geotextiles for which geotextiles are needed for a limited time, such as
holding vegetation still while they root. For these applications, a plastic mesh (Figure 36) is used,
which will then biodegrade and released into the environment.
Figure 36: Geotextile mesh used for vegetation support
These materials might not be fully biodegradable; the measure GEO#3 would require that only
geotextiles biodegradable, following certain standards, are used in the EU for vegetation support
applications.
How does the measure work?
The measure works by restricting the use of non-biodegradable geotextiles for vegetation support
applications.
How could the measure be implemented?
353
This measure could be implemented through the CPR or the Waste Framework Directive. However,
in the current version of the CPR, it would be non-binding for the Member States.
Measure GEO#4: Establish geotextile classes according to emissions of microplastics
Type of measure: Regulatory action
Description of the measure
This measure aims to develop an emission control framework. Similar to existing classifications in
the CE marking for construction materials, a classification system for geotextiles would be
developed. It would be based on the microplastic release potential of the geotextile (depending on its
material and manufacturing process). This classification would then be used to define applications
where, depending on the class, only certain geotextiles could be used, requiring the highest class of
materials to be used for the harshest applications.
How does the measure work?
First, using a testing method for microplastic releases (currently non-existing) from geotextiles (see
GEO#1), the materials would be classified according to the quantity of microplastics they emit. Then,
the applications for which a certain class of material are required (because their environment is
harsher than others) will be defined. The result would be a list of applications for which each class
of geotextile could be used. As a result, the geotextiles with higher microplastic release potential
would be only used in certain conditions (e.g. not exposed to UV, sea water etc.). Consequently, only
geotextiles with low microplastic release potential would be used in exposed conditions, which will
limit releases
How could the measure be implemented?
It could be implemented through the existing CPR271
, which already has the class concept
implemented for other materials. This measure can be implemented under the current version of CPR,
provided that GEO#1 has been implemented.
Measure GEO#1: Standardised methodology to quantify microplastics released from geotextiles
Type of measure: Standardised measurement methodology
Description of the measure
Develop measurement standards and testing protocols for microplastic release from geotextiles to
assess the impact of UV, temperature variations, water and salt-water and abrasion on release rates
for all types of geotextiles. These measurement protocols will need to be designed so that they
consider the interactions between the different weathering agents. Indeed, a recently published study
shows that the interactions have a non-negligible impact on the weathering of geotextiles. Moreover,
the measurement protocols will need to be designed to monitor microplastic releases since current
standards used to monitor the impact of different weathering agents on geotextiles focus on their
271
European Parliament and Council of the European Union, Regulation (EU) No 305/2011 laying down harmonised
conditions for the marketing of construction products and repealing Council Directive 89/106/EEC, OJ L 88, 4.4.2011,
pp. 5-43.
354
influence on the mechanical properties (e.g. tensile strength) of the materials, not on the microplastic
releases. Some work is already done, or first steps are taken; for instance, the method to assess the
effects of internal hydrolysis/oxidation is regulated and included in CE marking; the method for
abrasion is an ISO standard and needs further development to include microplastic release potential.
The impact of UV and temperature variation needs to be assessed further because the internal
hydrolysis test is done at 100ºC. The assessment of microplastic release makes sense for the leaching
obtained from the abrasion test, but further ageing approaches because the test is not aggressive
enough to produce microplastic release. This point needs to be verified.
How does the measure work?
This measure requires defining a reference method to simulate the influence of different weathering
agents (such as UV light, temperature variation, exposure to fresh and seawater, abrasion, etc.) on
microplastic releases from geotextiles and then quantify the microplastic releases.
How could the measure be implemented?
It could be implemented through voluntary or regulatory channels (new EU Framework).
355
6.6 Summary of policy measures
The following table summarises the policy measures initially retailed for assessment.
Table 25: Summary of policy measures
Sources Policy measures
Paints PNT#1: Standardised methodology of paint lifetime
PNT#2a: Mandatory label on paint lifetime and plastic content
PNT#2b: Threshold on lifetime and plastic content for paints
PNT#3a: Promote mineral paint in the architectural sector
PNT#3b: Restrict polymer-based paints in the architectural sector
PNT#4: Deposit-return scheme for paint containers
PNT#5: Good practices for paint application in all sectors
Tyres TYR#1: Emission limit value for particles from tyre wear/abrasion
TYR#2: Emission labelling of particles released from tyre wear/mileage
TYR#3: Modulated fees in EPR for tyres
TYR#5: Enhance monitoring of tyre pressure
TYR#6: Regular wheel alignment to minimise tyre wear
TYR#7: Road design and cleaning guidelines
Textiles TEX#1: Standardised methodology to quantify microplastic releases from textiles
TEX#2: Restrict synthetic fibres for certain applications
TEX#3: Restrict synthetic fibres & fabrics with high releases of microplastics
TEX#4: Mandatory prewashing of textiles before placing on the market
TEX#5: Specific wastewater treatment in textile production plants
TEX#6: Compulsory filters for washing machines
TEX#7: Modulated fees in EPR for textiles
TEX#8: Raising awareness on best practices for consumers of textiles
TEX#9: Mandatory label showing textiles’ emissions of microplastics
Detergent
capsules
CAP#1: Standardised methodology to quantify microplastics releases from detergent capsules
CAP#2: Apply current biodegradability standards to detergent capsules
CAP#3: Redesign biodegradability standards for detergent capsules
Geotextiles GEO#1: Standardised methodology to quantify microplastics released from Geotextiles.
GEO#2: Guidelines for geotextile use
GEO#3: Use biodegradable geotextiles for specific applications
GEO#4: Establish geotextile classes according to emissions of microplastics
356
7. INITIAL IDENTIFICATION AND SCREENING OF IMPACTS
The first step in assessing the impacts is a screening to identify the most important ones. The
identification of impacts covers both direct and indirect impacts. The following section sets out how
we have screened the impacts to be considered in the impact assessment.
7.1 Identifying and selecting of impacts
The list of impacts that need to be considered is based on the Better Regulation Toolbox Tool #18.
The table below presents the impact by the three categories: environmental, economic, and social.
Table 26: Potential economic, social and environmental impacts
Economic Social Environmental
Climate √
Quality of natural resources √
Biodiversity √
Animal welfare √
Working conditions etc √
Public health & safety and health systems √
Culture √
Governance, participation and good administration √
Education and training √ √
Conduct of business √
Position of SMEs √
Administrative burden on business √
Sectoral competitiveness, trade and investment flows √
Functioning of the internal market √
Public authorities (and budgets) √
Sustainable consumption and production √ √
Efficient use of resources √ √
Land use √ √
The likelihood or scale of environmental risks √ √
Employment √ √
Income distribution, social protection and inclusion √ √
Technological development/digital economy √ √
Consumers and households √ √
Capital movements, financial markets and stability of the euro √ √
Property rights, intellectual property rights √ √
Territorial impacts (specific (types of) regions and sectors) √ √ √
Innovation and research √ √ √
Fraud, crime, terrorism and security √ √ √
Resilience, technology sovereignty, open strategic autonomy,
security of supply
√ √ √
Transport and the use of energy √ √ √
Food safety, food security and nutrition √ √ √
Waste production, generation and recycling √ √ √
Third countries, developing countries, and international relations √ √ √
Sustainable development √ √ √
Fundamental rights √ √ √
357
For the issues to be covered in the impact assessment, we have screened the following as potentially
relevant impacts (but not necessarily significant).
Table 27: Potentially relevant impacts
Environmental impacts
Quality of natural resources / reducing pollution of microplastics for the biodiversity
Efficient use of resources
Waste production, generation and recycling and its impact on land use
Climate change
Economic impacts
Conduct of business (operating costs)
Administrative burdens on businesses
Position of SMEs
Public authorities including local communities (and budgets) Change in costs to MS authorities for
administrative, compliance and enforcement activities; Change in costs to EU institutions
Innovation and research
Technological development / digital economy
Functioning of the internal market and competition
Macroeconomic environment
Third countries and international relations
Consumers and households
Social impacts
Public health & safety
Employment
Governance, participation and good administration
When selecting the most relevant and significant impacts, the following criteria have been taken into
consideration:
• The relevance of the impact within the intervention logic: this considered whether the impact
is relevant to assessing the policy options' direct contribution to the objectives.
• The expected absolute magnitude of the expected impacts.
• The relative size of expected impacts for specific stakeholders: this considered whether any
of the impacts would be particularly relevant and significant for a specific stakeholder group,
even if the impact overall may be small. This includes whether impacts will be concentrated
on specific Member States or industries and whether they will add to the existing regulatory
burden for any specific stakeholder group. Impacts on SMEs are also considered.
• The importance for Commission’s horizontal objectives and policies: this considered
whether the impact is relevant to determine any trade-offs between the objectives for
amending the Regulation and other EU objectives and policies.
The outcome of this step is the final list of impacts that have been examined, indicating whether they
are likely to be positive or negative (using the following signs: ++, +, o, -, --) and which stakeholder
groups they are most likely to impact. Colour coding is used to summarise the impacts referring to
the direction (positive or negative) and size (small or large) of any expected impacts.
358
Table 28: Coding used to present expected impacts
-- - 0 + ++ U
Strongly
negative
Weakly
negative
No or limited
impact
Weakly
positive
Strongly
positive
Unclear
Table 29: Screening of significant impacts
Impact Significance Impact on key
stakeholder groups
Justification for inclusion / exclusion
Impacts included
Environmental impacts
Quality of natural
resources
++ Reduced microplastic
pollution or better
quality of natural
resources means
improved eco-systems,
improved biodiversity
and improved services
for the economy and
society (e.g. fishery), but
the general public is the
affected group
The objective is to reduce microplastic
pollution, so this is a key impact
category.
Efficient use of
resources
+/- No specific group is
impacted
Reducing waste is about more efficient
use of resources. In particular, the
objective is to reduce the waste, and
therefore this category should be
included. Some mitigation strategies
could in turn, lead to increased resource
use (e.g. reduction of product lifespan
leading to increased renewal rate), e.g.
reducing paint spillage. It is, therefore,
an important category that should be
included.
International
environmental
impacts
++ Reduced eco-system
services could impact
fisheries, but it is the
general public being the
affected group
Pollution with microplastic affects both
cross-border river basins and the seas
and is, therefore, an important
international impact that should be
included.
Waste production,
generation and
recycling and its
impact on land use
+ Wastewater treatment
companies
Sectors potentially
affected by microplatics
waste such as tourism
and agricultural sectors
The amount of microplastics is
impacting the infrastructure needed for
waste water treatment.
If not properly managed, microplastics
can pile up in certain areas (such as
coastal areas) and negatively impact
other activities (tourism, agriculture)
As with efficient resources, reducing
and managing waste is part of the
objectives, and the impact category
should be included.
Climate change + / - No specific group is
impacted
Reducing waste will lead to less GHG
emissions, for example, during the
359
Impact Significance Impact on key
stakeholder groups
Justification for inclusion / exclusion
production of plastics. Some mitigation
strategies could, in turn, lead to
increasing or decreasing GHG
emissions. It is, therefore, an important
category that should be included.
Economic impacts
Operating costs and
conduct of business
-- Industrial operators Most measures will affect the operating
costs of industries.
Administrative
burdens on
businesses
-- Industrial operators Some of the considered measures will
have administrative costs that should
be quantified and included.
Operation / conduct
of SMEs
- / 0 SMEs are part of the
affected sectors.
The affected industries include SMEs.
There are high shares of SMEs in the
textile industry.
Functioning of the
internal market and
competition
++ Industrial operators Several Member States are starting to
take action, it is therefore important to
tackle this at EU level, preserving the
internal market. The proposed
measures are not expected to
significantly affect the internal
market's functioning. As the options
will place the same obligations on
industries and businesses in all
Member States, the functioning of the
market should not be affected.
However, if EU policies replace
national policies affecting only a few
Member States, the impact will be
more equal competition across the EU
and therefore have a positive impact on
the internal market.
Public authorities:
Change in costs to
authorities for
administrative,
compliance and
enforcement
activities
- Member State
competent authorities (at
local, regional and/or
national levels
depending on PRTR
responsibilities).
The considered measures will impact
Member State authorities in terms of
data collection, verification, correction
and enforcement activities.
Public authorities:
Change in costs to
the Commission
- European Commission The considered policy options could
have impacts on the Commission and
its services.
Innovation and
research
+ Industrial operators. Some of the options could provide
incentives for innovation and research.
Third countries and
international
relations
+/- Third countries There could be effects on countries
outside of the EU with both direct and
indirect impacts, and this category
should be included.
Consumers and
household
- Households Some measures directly target
consumer behaviour or affect
consumers through prices or
availability of products. The impacts
are likely to be negative (price
increase)
360
Impact Significance Impact on key
stakeholder groups
Justification for inclusion / exclusion
Social impacts
Reduced health
impacts due to lower
pollutant emissions
++ Public It is an objective of the considered
measures to reduce risks to human
health.
Governance,
participation and
good administration:
Improved public
access to information
+/0 Public The options are not expected to change
governance and public administration
significantly. Though the options
might not directly target access to
information, there might be improved
data on microplastic pollution.
Impacts not included
Macroeconomic
environment
0 Manufacturers primarily Though there could be significant costs
associated with some of the considered
measures, it is not likely to have
macroeconomic impacts.
Technological
development / digital
economy
0 Industrial operators,
Member State
authorities,
manufacturers
The innovation and research impact
category covers the impacts on
technological development related to
the sectors concerned.
The economic impacts primarily include the costs of implementing the measures. The benefits of the
measures are reductions in emissions of microplastics. Whilst it is not feasible to quantify or value
changes in environmental impacts, reductions in emissions of microplastics will reduce the negative
environmental impacts from the baseline. In most cases, the emission reductions will affect emissions
to all environmental compartments. Hence, the environmental impacts will be more or less
proportional to the reduced emissions. There may also be impacts on fuel efficiency for some
measures and associated changes in GHG emissions. Similarly, the social impacts, which include the
possible negative human health effects, are also likely to be affected proportionally by reductions in
emissions. It means that all measures have more or less the same types of environmental and social
impacts, and only the magnitude differs. Where there are differences, they are described under the
respective measure.
The approach to the assessment of cost impacts draws on evidence identified as part of the literature
review and stakeholder consultations. In many cases, the costs are affected by multiple factors, so the
cost estimates presented are generally an order of magnitude estimates. Similarly, for the assessment
of the reduction potential and the likely realisation of it. Many factors influence the assessment of
the reduction potential, and the assessment provides order of magnitude estimates.
361
7.2 Impact of measures for tyres
Table 30 shows the comparison between all measures evaluated to reduce microplastic emissions
from tyres.
Table 30: Comparison of measures for tyres
Measure Estimated
reduction
potential
Estimated
Cost-
effectiveness
(EUR/tons
reduced/year)
Other
environmental
impacts
Other
economic
impacts
Social impacts
% Ktons/
year
TYR#7: Road
design and
cleaning
guidelines
Not quantified
– guidance
only
Additional
costs for road
authorities for
new road costs
and road
maintenance
TYR#3:
Modulated fees in
EPR for tyres
Not quantified Costs are likely
to be passed on
to consumers in
higher prices
although they
can choose to
purchase lower
abrasion tyres
where cost
increases will
be much more
limited.
TYR#1: Emission
limit values for
particles from tyre
wear/abrasion
5-
25%
85 500 136 Reduction of
microplastic
pollution in
marine
environment,
air and soil
Costs are
likely to be
passed on to
consumers in
higher prices
Health and
environmental
benefits from
microplastic
release
reductions
TYR#2:
Emission/mileage
labelling of
particles released
from tyre wear
less
than
1%
4 275 1 604 Reduction of
microplastic
pollution in
marine
environment,
air and soil
Costs are
likely to be
passed on to
consumers in
higher prices
TYR#6: Regular
wheel alignment
to minimise tyre
wear
1% -
2%
9 108 145 245
(without fuel
savings)
CO2 emission
reductions due
to fuel savings
Reduction of
microplastic
Positive
impact for
motorists and
customers
(increased
362
-43 287 (with
fuel savings)
pollution in
marine
environment,
air and soil
tyre lifetime
and lower fuel
consumption)
TYR#5: Enhance
monitoring of tyre
pressure
1% -
3%
10 403 996 (without
fuel savings)
-23 298 (with
fuel savings)
CO2 emission
reductions due
to fuel savings
Reduction of
microplastic
pollution in
marine
environment,
air and soil
Positive
impact on
motorists and
customers
(increased
tyre lifetime
and lower fuel
consumption)
Additional
costs for
motorists for
testing and
alignment
(where
necessary)
Marginal
positive impact
on road safety
and noise
reduction
Table 31 shows the comparison of the impacts of the measures assessed to reduce microplastic
emissions from tyres.
Table 31: Summary of impacts for measures for tyres
Policy Option Environmental impact Economic Impact Social impact
TYR#7: Road design
and cleaning
guidelines
Additional costs for
road authorities for
new road costs and
road maintenance
TYR#3: Modulated
fees in EPR for tyres
Provide incentive for
manufactures to innovate and
produce tyres with lower
abrasion rate
Provide incentive for the
consumers to purchase low
abrasion rate tyres
Provide financing for road
infrastructure measures
Medium costs to
set-up and manage
the scheme (where
required) / minimal
costs to amend
existing schemes.
Costs for industry
depends on fee
level and structure
Fee might be
passed on to
consumers –
higher costs of
tyres
There are already EPR
schemes for tyres
covering end-of-life
management in 20
Member States so limited
social impact.
363
TYR#1: Emission
limit values for
particles from tyre
wear/abrasion
Benefit in the order of 5-25%
reduction of emissions
Benefits can be realised fairly
quickly
Precondition to
have test method in
place
Costs of testing is
assessed as low
No or low
additional costs for
tyres with low
abrasion rate
Important to make sure that
safety is not compromised.
Testing seems to indicate
that there are lower
abrasion tyres on the
market which do not
compromise on safety.
TYR#2:
Emission/mileage
labelling of particles
released from tyre
wear
Benefit depends on consumer
reaction, supporting
consumer awareness raising
will be needed
Benefits in the order of less
than 1% reduction of
emissions.
Precondition to
have test method in
place
Costs of inclusion
of abrasion levels
on label minimal
To maximise the impacts
of inclusion of tyre
abrasion levels on labels,
there should also be
consideration of impacts
for tyre lifetimes so
consumers can see the
potential financial benefits
of buying lower abrasion
tyres.
TYR#6: Regular
wheel alignment to
minimise tyre wear
Benefit potential depends on
current situation which is not
known. Maximum potential
is in the order of 2%.
High total costs for
checking wheel
alignment at
regular inspections
and realigning
where necessary.
Significant co-benefit is
lower energy use and longer
tyre life. This should
increase the incentive for
vehicle users.
In some Member States
these checks may already
be mandatory.
TYR#5: Enhance
monitoring of tyre
pressure
It is estimated that this
measure could give up to 10-
20% emission reduction for
an individual vehicle, but it
depends on vehicle user’s
behaviour i.e. whether they
actively follow the warning
signals to inflate tyres.
System is already
in place.
Potentially only
minor costs of
calibrating the
systems.
Technical
assessment to
determine
feasibility and
appropriate
threshold and
consumer
awareness raising
activities.
Significant co-benefit is
lower energy use and
longer tyre life. This
should increase the
incentive vehicle users.
The impact of each measure is outlined below.
364
TYR#7: Road design and cleaning guidelines
What would be the costs of the measure?
The direct costs of developing guidelines for road design and road cleaning will be relatively small.
The guidance could be incentivised by the EC and developed by a technical working group comprised
of relevant Member States experts in road design, road cleaning and tyre abrasion.
In order for the guidance to achieve results, road authorities in the Member States would have to
invest in specific technical measures. They are discussed below.
• For road design:
o The road design elements where abrasion rate criteria could be added include, for
example:
▪ Choice of road surface materials (porous asphalt / rubber asphalt)
▪ Road designs (use of roundabouts and traffic lights, road curvature etc.)
o Using road surface materials which generate less abrasion is one that can be applied
on most roads. It is likely that such pavements are more costly than the standards
used today. Overall, it is difficult to estimate the costs as it will depend on how
much of the road network where such surfaces would be applied. Applying careful
identification of sections with high traffic loads and high levels of TWP emissions,
the cost-effectiveness of this measure can be increased. There are examples of road
surfaces that lead to more energy-efficient driving and less noise generation, where
the additional investment costs are in the order of 10%272
. The Danish example
illustrates that although the surface is more expensive, the savings on energy
consumption and the lower noise levels lead to a positive economic cost-benefit
assessment.
o Having abrasion rate criteria for road design is mostly relevant for new roads. Existing
roads are not changed very frequently in terms of the use of different types of
crossings, curvatures, etc. It is, therefore, a more long-term measure. There are no data
to allow an assessment of the cost implications of including a criterion on abrasion
rate in the construction or reconstruction of roads.
• Collection of road run-off
o The costs of improving the collection and treatment of road run-off vary according
to local conditions. There are many factors that make it very difficult to generalise
the costs.
o In urban areas with combined sewer systems, run-off is already collected and treated
at UWWTP, albeit microplastics captured at the plant end up in the sewage sludge,
which, in some Member States, is then spread on agricultural land. At heavy rain
events, there may be storm-water overflows meaning the run-off is not treated and is
released directly into the environment. In urban areas where run-offs are collected in
a separate system, there are no additional costs of collection, but additional
treatment needs to be put in place. Additional treatment can be costly to install.
o Outside of the main urban areas, there might be varying degrees of collection and
treatment. In many Member States, a collection of road run-off is installed for the
most utilised roads273
Upgrading existing collection and treatment could lead to
272
See M. Pettinari, Bjarne Bo Lund-Jensen, B. Schmidt (2016) Low rolling resistance pavements in Denmark
273
CEDR, 2016, Management of contaminated runoff water: current practice and future research needs
365
increased treatment, but the costs would vary depending on the specific local
conditions.
o In all cases, increased treatment would result in the generation of volumes of sludge
with high concentrations of microplastics. There is currently no commercially
available technology for removing microplastic (at least to any significant extent). It
means that only the incineration of the sludge will remove the microplastics in the
sludge.
• Intelligent road cleaning
o The costs of this technical measure depend on current practices across the EU. If there
is already regular road/street cleaning, then by focusing on cleaning of hotspots and
aligning the timing with weather forecasts might not lead to any significant additional
costs. If more frequent cleanings are required, the measure will increase the operating
costs of the responsible authorities.
o There are no data that provide an overview of the current practices in EU27, and
therefore, it is difficult to estimate the costs. It would be necessary to have an estimate
of the length of roads that could be considered as hotspots and costs per km of road
cleaning.
o The RIVM (2018) study has assessed the technical measure, and through a small
survey of 8 municipalities in the Netherlands the study indicates that road cleaning
takes place from 2 to 12 times annually. This indicates a large possible variation in
current practices.
As this measure provides guidance, the actual level of implementation of the specific measures and
the associated costs will depend on the uptake of the guidance by relevant Member State competent
authorities.
What would be the benefits of the measure?
Given that the measure is guidance, the impacts will, as mentioned above, depend on the uptake by
Member States.
Below, we discuss the possible benefits for each type of technical measure: road design, road run-off
management and road cleaning.
• Road design:
o Quantification of the benefits is challenging as there are no data on the distribution
of emissions by the length of the network. The RAU study has estimated that
emissions are higher at crossings and curves274
, but without more specific data, it is
not possible to estimate the reduction potential. It can be noted that:
▪ By considering hotspots, it might be possible to achieve cost-effective
reduction
▪ A full realisation of the measure will only happen in the long term. The road
designs are not changed very frequently. Also, road surfaces have long
lifetimes.
• Collection of road run-off
o This technical measure will reduce the amounts of microplastic that are being washed
into the freshwater environment. The total reduction potential is difficult to estimate.
In principle, all the run-off in urban areas is collected. With the installation of filter
systems on gullies in urban areas, at least 50% of the emissions collected by not treated
274
TyreWareMapping
366
road-run off could be removed. Currently, about half the urban emissions are not
treated. Installation of filters on all urban roads which are currently not subject to
treatment of the run could amount to reductions in the order of 10%.
• Intelligent road cleaning
o The RIVM 2018 study concludes that the effect is relatively low. The study estimates
an effect of road cleaning in the order of 2% of the emissions being captured. The
result was based on simulating a large number of cleaning events with varying
efficiency. Such impacts are very localised in nature.
Economic impacts
The economic impacts depend on the use of the guidance and the level of implementation of the
technical measures covered by the guidance.
▪ Road design:
The choice of using road surfaces that create less abrasion might initially lead to higher investment
costs for road authorities. The benefits in terms of less energy consumption are gained by the road
users.
The economic impacts depend on how road authorities will apply abrasion criteria and whether
including such criteria will impact the costs of road construction and/or road maintenance. It might
lead to higher costs, but data do not allow for the estimation of the magnitude of potential costs.
▪ Collection and treatment of road run-off
Increased collection and treatment of road run-off will require investment costs in collection and
treatment systems. It is important to note that there are considerations on the management of
stormwater in relation to the ongoing revision of the UWWT Directive. Storm-water overflows and
non-treated stormwater causes pollution with a number of pollutants. Considering all the pollutants
from road run-off might increase the cost-effectiveness of increased collection and treatment.
However, the level of costs that would be attributable to the problem of tyre wear cannot be further
assessed with significant in-depth analysis.
▪ Intelligent road cleaning
The economic impacts will be increased costs for road maintenance authorities. The costs will depend
on current practices. In case street cleaning already takes place on a regular basis, optimisation with
regards to hotspots and before major rainfall might not lead to any additional costs.
Environmental impacts
The environmental impacts depend on the use of the guidance and the level of implementation of the
technical measures covered by the guidance.
▪ For road design
The environmental impacts will be proportional to the reduction in emissions, although they cannot
be quantified.
▪ Collection and treatment of road run-off
Collection and treatment of road run-off will reduce the emissions reaching soils and being
discharged into water bodies. The magnitude of the impacts depends on how much road run-off will
be additionally collected and treated. As discussed above, the ongoing revision of the UWWT
Directive might lead to changes in the management of stormwater, including road run-offs. If there
367
are changes to the management of stormwater, it might have impacts on pollution with nutrients and
micropollutants as well as microplastics.
It is important to note that currently, there is no commercially available technology to remove
microplastics from the wastewater sludge to any significant extent (based on current knowledge). It
means that the only method to manage the sludge so that the microplastics are permanently removed
is incineration. Incineration could lead to negative air quality impacts as well as CO2 emissions, and
it is not in line with EU objectives on the circular economy.
▪ Intelligent road cleaning
The environmental impacts will be proportional to the reduction in emissions which are highly
uncertain. Furthermore, it should be noted that if the overall level of street cleaning is increased, then
it will lead to higher energy and water consumption.
Social impacts
The social impacts depend on the use of the guidance and the level of implementation of the technical
measures covered by the guidance.
▪ For road design
The impact on human health from lower microplastic emissions will be proportional to the reductions
achieved. If the use of more porous asphalt surfaces leads to less noise, it will have a positive impact
on the human health of residents living nearby the roads.
▪ Collection and treatment of road run-off
The potential impacts on human health will be affected to the degree that the microplastic emissions
are no longer released into soil or end up in water bodies.
▪ Intelligent road cleaning
The potential impacts on human health from less microplastic emissions will be proportional to the
achieved reductions.
Illustrative example of the impacts and cost-effectiveness of collection of road runoff
An illustrative example comprises the installation of a filter at road gullies that collects the road
runoff. The possible cost-effectiveness of this measure can be illustrated by estimating the costs of
measures under different circumstances. It should be noted that local specific conditions can vary and
the following calculations are illustrative.
Based on data from a project on improved collection and treatment of road runoff in Berlin275
, the
following assumptions can be applied. The area that one gully drains is assumed to be 400 m2. The
investment cost of a filter system that can retain 50% of microplastic emission is EUR 2000276
and
the lifetime of the filter system is assumed to be 20 years. The annual maintenance costs are EUR
120277
. Based on these assumptions, the annualised investment costs can be estimated at EUR
130278
, so the total annual costs are EUR 250 per gully. The resulting costs for different road
examples are illustrated below.
275
Barjenbruch, Matthias „DSWT - Dezentrale Reinigung von Straßenabflüssen - Projekt im Berliner
Umweltentlastungsprogramm UEPII/2“ / final report Berlin 2016
276
Ibid
277
Ibid
278
The BR suggested discount rate is 3% and here a lifetime of 20 year is applied.
368
Table 32: Illustrative examples of potential costs of installation of filter systems in road gullies
Road section of 1 km Road width[(*)
Area Number of gullies Total annual costs in EUR
500 AADT 10 meter 10000 25 6,361
5,000 AADT 10 meter 10000 25 6,361
50,000 AADT 20 meter 20000 50 12,722
100,000 AADT 20 meter 30000 75 19,082
Source: Own calculations.
(*) The assumptions are that each lane including shoulder etc. is about 5 meter in width.
The annual amount of TWP is estimated using the standard emission rates. The filter is assumed to
provide 50% efficiency, meaning the 50% of the microplastic will be retained in the filter.
To complete the illustrative example, the benefits of the gully filters installed at roads with different
traffic loads has been assessed and is presented in the following table.
Table 33: Illustrative examples of potential benefits of treatment for different scenarios and overall cost-
effectiveness
Road section of 1
km
TWP emission reduction in kg per
year
Total costs of
treatment
Cost-
effectiveness
500 AADT 6,400 15 435
5,000 AADT 6,400 150 44
50,000 AADT 12,700 1,460 9
100,000 AADT 19,100 2,920 7
Source: Own calculations.
The illustrative example shows that for the busiest roads, the measure might be cost-effective. As
noted, the filter system for road run-off will prevent the emission to soil and water if the sludge from
the filters is managed in a safe way, for example, incinerated. The costs of filter sludge incineration
are not included in the above calculation.
The above calculation indicates that it will only be cost-effective to install such a filter on the busiest
urban road. There are no data on how much of the urban emissions are from such roads.
It should be noted that such filter systems are not likely to be cost-effective for rural roads. Not only
are traffic volumes often low, but additional investment in collection systems will be needed.
TYR#3: Modulated fees in EPR for tyres.
What would be the costs of the measure?
The administrative costs would comprise:
• Setting up the organisation that should manage the EPR
• Running costs of the organisation managing the EPR
Currently, the majority of Member States (20 MSs) have set up an EPR for the end-of-life
management of used tyres. These existing EPRs could be expanded to include tyre wear. Then, there
369
would be a modulated fee where each manufacturer pays a fee differentiated by the level of abrasion.
For the Member States with currently no EPR, there would be an initial cost of setting up and
operating the system (noting that some of these appear to have some form of taxation in place
covering end-of-life management of used tyres). For existing systems, the additional operating costs
would be very limited. For new systems, the operating costs would have to be financed by the
collected fee.
For all the companies placing tyres on the market, the costs would be:
• Testing of tyres in order to determine the fee (testing costs would be as defined under measure
TYR#1)
• Payment of the fee
The cost burden of the importers and manufacturers will therefore primarily depend on the fee level.
The fees are likely to be passed on to the consumers, so the costs will lead to price increases for the
tyres, where the tyres with the highest abrasion rates will be more expensive.
The current EPR systems seem to vary with respect to organisational setup. In several Member States,
there are more than one Producer Responsibility Organisation (PRO)279
. It would therefore require
further actions at the level of Member State authorities and industry to define and agree on set-up
that could include tyre wear.
What would be the benefits of the measure?
The measure would provide benefits in several ways:
• Give manufacturers/importers an incentive to innovate to sell tyres with less emissions (to
reduce their fee and thereby costs of the tyres)
• Give consumers an incentive to change to tyres with less tyre wear (assuming the fee would
be passed on to the price of the tyre)
• Provide funding for road design and maintenance, collection and treatment of road run-off,
intelligent road cleaning (see measure TYR#7) and/or other measures to capture and treat
microplastic emissions from tyres.
It is not possible to quantify the total potential. Assuming the fee would be passed on the consumers
and that it would be differentiated by emission rates, the measure might achieve reductions
comparable with the effects of measure TYR#1 on type-approval although likely towards the lower
end of the range unless fees were set very high. The likely impacts are highly uncertain and depend
on the levels at which any fees are set.
The collected fees would then provide funding for the collection and treatment of road run-off,
awareness-raising and/or other measures to capture and treat microplastic emissions from tyres. It is
difficult to estimate how much this funding would be able to increase the collection and treatment of
road run-off.
279
See for example: Winternitz, K, Heggie, M & Baird, J 2019, 'Extended producer responsibility for waste tyres in the
EU: Lessons learnt from three case studies – Belgium, Italy and the Netherlands', Waste Management, vol. 89, pp.
386-396. https://doi.org/10.1016/j.wasman.2019.04.023
370
Economic impacts
The economic impacts will include the costs of expanding existing EPR schemes or setting up a new
EPR scheme to cover the issue of tyre wear. The collected fees will be paid by the manufacturers but
will be passed on to the consumers of the tyres. How much the consumers will be impacted will
depend on the level of the fee.
Environmental impacts
The environmental damages are estimated to be reduced by the same order of magnitude as the
reduction of the tyre wear. Potentially, this measure might lead to reductions of around 5% (lower
end of the range for TYR#1) depending on the level of the fee and how much it would be
differentiated by abrasion rate of the individual tyre.
The detailed environmental impacts cannot be assessed. The tyre wear comprises different particle
sizes and has different content of hazardous substances. There are no data on the detailed composition
of particle size and substances in the current emissions. Therefore, the impacts of the reduction of
emissions cannot be estimated (see also the discussion on the health effects).
The reduction in emissions will be proportional for all the environmental compartments. No
significant impacts are expected on waste, efficient use of resources or climate change.
Social impacts
The social impacts include potential human health impacts associated with microplastic emissions.
If the measure would achieve emission reductions in the order of 5-25%. As discussed in the problem
definition, the emissions of tyre wear contain a large number of chemical substances with varying
levels of toxicity. A study has estimated the difference in a weighted toxicity index of a factor of 4
between the most and the least toxic tyre280
. The health impacts will therefore depend on how the
limit values are defined. If they include particle size and toxicity, the health impacts could be
significantly reduced. If the criteria only focus on total tear wear mass, then there is a potential risk
of an increase in the negative health impacts.
TYR#1: Emission limit value for particles from tyre wear/abrasion
It should be noted that there are significant uncertainties attached to the assessment. The following
factors are most important for understanding the nature of the assessment and the inherent
uncertainties.
• Test methods: Currently, the test methods for tyres are under development. Before a
standardised test has been developed and agreed upon, the estimated reduction potentials are
based on currently applied test approaches which vary between different studies. They might
therefore give different results than what will be the case when a standard test method has
been implemented.
• Volumes of different tyres sold (type, model, size) and their usage (i.e. vehicle kilometres
driven).
• Costs of tyres and regulatory costs: As the test is not yet agreed upon, the costs for compliance
with the test requirements and type approval are not yet known. Whether compliance with the
280
Emission Analytics / PEW report (2022) - Research report - Tire chemical composition and wear emissions
371
future test requirements might lead to significant additional costs cannot be estimated using
current evidence and will be evaluated in detail in Euro 7. The thorough analysis that will be
required for setting limits in Euro 7 will also take into account potential R&D costs in order
to change the tyre formulation and design in order to comply with the new limits and expected
cost increases in the tyre price by the different materials/composition.
Therefore, the estimated values are uncertain, but the assessment provides the order of magnitude
estimates based on current evidence for most of the measures.
Key assumptions:
• The emissions calculation, as presented in section 5 underpins the assessment of impacts on
emissions as well as costs. The estimation is based on emission factors disaggregated by type
of vehicle and the total km by urban roads, rural roads and motorways.
• The distribution of the emissions by environmental compartment, as described in section 4
underpins the assessment of any changes to where the emissions are released to.
• Where costs are annualised, the relevant lifetime is included, and the discount rate is 3%281
.
• The average lifetime of a tyre is assumed to be between 5-10 years (and depends on driving
styles and mileage).
The measures will affect either the emission factors by vehicle types or the distribution of emissions
by environment compartment.
What would be the costs of the measure?
The implementation of the measure would include the following potential cost elements:
• Compliance costs for type approval and market surveillance
• R&D Costs for tyre manufacturers of changing their design in case their tyres fail to comply
with emission limits
• Cost premium of producing compliant tyres (if applicable)
Each of these cost elements is discussed below.
The cost of the type-approval procedure is one of the cost elements to be considered for this measure.
Introducing an emission limit will require a type-approval procedure for all tyres placed on the EU
markets. Data from the assessment of testing of tyres on safety, noise, and energy efficiency suggest
costs in the order of EUR 5 000 - 10 000 per type of tyre282
. The Eunomia (2018) study assessed and
estimated the costs of introducing a type-approval requirement. The study estimated testing costs in
the order of EUR 5 000 – 10 000, but it could be up to EUR 40 000283
. Information from the industry
indicates that type approval costs would be in the order of EUR 15 000284
. The higher value is because
the test is likely to be on-the-road tests. To reflect the uncertainties in what exactly the final testing
281
BR Tool#64 Discount factors
282
SWD(2018) 189 final
283
Hann, S., Sherrington, C., Jamieson, O. et al., Investigating options for reducing releases in the aquatic environment
of microplastics emitted by (but not intentionally added in) products, Eunomia report for the Directorate-General for
Environment, 2018.
284
Personal communication from ETRMA, April 2022
372
method(s) will entail, this assessment assumes a range of EUR 5 000 - 15 000 with a mid-point of
EUR 10 000.
The next step is to estimate the total costs associated with type approval and the cost impact for each
tyre placed on the market. This impact depends on how many tyres are supplied for each specific
type and tyre brand. Therefore, more popular tyres will be less cost impacted.
The Eunomia 2018 study found, through using different databases containing the individual tyre
brands and types, that there are between 2 500 and 30 000 individual types of tyres (types and brands).
Feedback provided by ETRMA285
suggested that, on average, manufacturers renew their ranges every
four years (or longer for some tyre types). ETRMA also provided a “worst case” estimate of tyres
requiring type approval of around 1,700 each year. Taking this as an upper estimate and using the
Eunomia lower estimate (but divided by four to derive an annual figure), the total costs of type
approvals can be estimated and are presented in the table below.
Table 34: Total costs of tyre type approval costs (per year)
Costs per type approval in EUR
Number of tyre models (brand and type) 5,000 10,000 15,000
625 3 125 000 6 250 000 9 375 000
1,700 8 500 000 17 000 000 25 500 000
Source: Own calculation
According to the ETRMA database, the annual sales of tyres amounts to 325 million. Based on that
the approximate cost impact per tyre sold on the market can be estimated assuming that all additional
costs for type approval would be passed on to the consumer. This is done by dividing the total type
approval costs by the total number of tyres sold.
Table 35: Average additional cost per individual tyre of type approval costs
Type approval costs EUR per type of tyre
Number of tyre models (brand and type) 5,000 10,000 15,000
625 0.01 0.02 0.03
1 700 0.03 0.05 0.08
Source: Own estimation
It means that the additional costs will vary between EUR 0.01 to EUR 0.08 per tyre. It is, in any case,
a relatively low additional cost. This would amount to less than 0.1% of the price of an average
tyre286
.
The introduction of type approval for tyre abrasion would require some market surveillance by the
Member State authorities in order to ensure that only tyres meeting the requirements are being placed
285
Personal communication from ETRMA, June 2022
286
Assuming a price around EUR 100 per tyre.
373
on the market. Such surveillance will already be done by the Member States to check for other
requirements; therefore any additional time and cost burdens are expected to be minimal.
The next cost elements to consider include:
• Costs for tyre manufacturers of changing their design in case their tyres fail to comply with
emission limits
• Cost premium of producing compliant tyres (if applicable)
Manufacturers will have to ensure that all the tyres they produce comply, and that may require a
redesign of certain tyres. It should be noted that the tyre industry is constantly developing tyre designs
aimed at improving tyre performance based on R&D activities. The design of tyres includes balancing
and optimising a large number of performance criteria. The additional costs for adjusting the tyre
design to comply with the type approval specifically for abrasion are highly uncertain and cannot be
quantified.
There are also no detailed statistics that can allow for an assessment of the cost difference between
tyres with low or high abrasion rates, and discussions with the industry have not revealed any obvious
price differentials linked to abrasion rates. The ADAC study indicates that both low and high rates
of TWP are found in different price segments of the tyre market. It is, therefore, not necessarily the
case that tyres with lower abrasion rates are more expensive to produce and, therefore, more
expensive for the consumers. Consultation with the industry has also not identified any evidence of
lower abrasion tyres costing more. Therefore, for this assessment, no additional costs are assumed
for producing compliant tyres.
The last cost-related element to consider is that of a potential longer lifetime of the tyres with lower
abrasion rates. There is no strict correlation between abrasion rate and lifetime (mileage of a tyre). A
longer lifetime of tyres can be achieved by improving the quality of the material and adding to the
thread depths and mass. It means that there could be examples of tyres where poorer material is
causing the high abrasion rate but also a higher lifetime due to design characteristics. There are no
data to undertake a detailed assessment of this aspect.
It is assumed the additional costs for producers to comply with a type approval regulation will be
passed on to the tyre price. Savings from a longer lifetime might partially offset the additional costs
of tyres, although this is highly uncertain, as discussed above.
Therefore, the costs expected for this measure are those associated with type approval which gives
costs between EUR 3 and 26 million per year depending on the final costs of the test method and
number of tyre models to be tested each year.
What would be the benefits of the measure?
A few studies have assessed the reduction potential of setting emissions standards that prevent the
worst-performing tyres from being placed on the market. For example, a study by ADAC that tests
passenger car tyres regularly has compared abrasion rates with safety performance across several
different tyre models, sizes and types. They conclude that it is possible to find tyres with low emission
rates and sufficient safety performance. The emission reductions from the best performing tyres to
the average are about 15-30% in all the tested tyre categories (summer/winter and tyre sizes).
374
Table 36: ADAC tyre testing abrasion rates
Type of tyres Average in g/1000 km Lowest abrasion rate % Difference
Summer tyres
185/65/R15 95 60 37
205/55/R16 115 80 30
225/40/R118 130 110 15
Winter tyres
185/65/R15 110 85 23
195/65/R15 140 100 28
205/55/R16 120 85 29
Source: ADAC
Another study is by Emissions Analytics 2022287
. They have measured a sample of 13 tyres, whether
the wear rate varies between 38 mg/vkm and 89 mg/vkm288
. The average of the 13 tyres was 65
mg/vkm. The absolute values cannot be compared as the testing methods might vary. However, the
study indicates that the tyres with the lowest abrasion rate are around 37% lower than the average,
and the tyres with the highest abrasion rates are 33% above the average. The distribution of the total
tyre sales (and their subsequent usage) by abrasion rate for both studies (ADAC and Emissions
Analytics) is not known.
The estimated reduction potential will depend on the testing method. As an official testing method is
still only under development, it might be that the reduction potential will turn out differently when a
standard test method is finally agreed upon. Another factor is that increased focus on the abrasion
rate and the potential definition of the limit values for abrasion might lead to innovation given even
lower abrasion rates. There could be merit in considering phased limits which tighten over time as
the manufacturers produce new, lower abrasion models.
A study by RIVM289
has assessed the likely impacts of this measure (amongst others) on reducing
emissions from tyres based on a review of available literature and traffic and vehicle statistic for the
Netherlands. The study estimates a reduction potential in the order of 5-15% out of the total emissions
from tyre wear.
Based on the above discussion, a range in the order of 5-25% is estimated as the reduction potential.
The low end of the range is based on the above considerations on what removing the worst-
performing tyres would mean on the total emissions combined with the RIVM study results. The high
end of the range is based on a higher degree of ambition and would require the replacement of at least
50% of current tyre types with lower-emitting ones.
The estimated emission reductions for TYR#1 is shown in the table below. The range is estimated to
be between 29,000 and 143,000 tonnes per year.
287
Emissions Analytics 2022 Tire chemical composition and wear emissions
288
There is one value of 161 which for this assessment is excluded as it very much different from rest of the tyres.
289
A.J. Verschoor and E. de Valk, RIVM 2017, Potential measures against microplastic emissions to water, RIVM
Report 2017-0193
375
Table 37: Estimated emission reductions for TYR#1 – annual emissions in tonnes
2020 2030
Effect of measure Total emissions Total emissions Emissions
with measure
Effect of measure
Low (5%) 450 000 570 000 541 500 28 500
High (25%) 450 000 570 000 427 500 142 500
Based on the estimated costs and the estimated reduction potential, the cost-effectiveness of the
measure can be estimated. This is estimated to be between EUR 41 and 612 per tonne of microplastic
emission reduction (depending on assumptions). There are also likely to be additional benefits in
terms of a longer lifetime of lower abrasion tyres, although there is limited evidence to quantify this,
and the industry has noted290
that tyre lifetime is not just a function of tread but also overall tyre
structure and integrity.
Economic impacts
The economic impacts are summarised in the table below based on the above analysis. Economic
impacts are expected to be weakly negative overall, with some additional costs for manufacturers.
These costs are likely to be passed on to the consumers of tyres.
290
ETRMA, personal communication, April 2022.
376
Table 38: Economic impacts of TYR#1
Impact category Qualitative
scoring of
impact
Affected
stakeholders
Description of impact
Operating costs and
conduct of business
- Importers and
manufacturers of
tyres
It might cost more to produce compliant
tyres (although the evidence does not
seem to indicate this), but the cost
increase will affect all manufacturers
and importers. Hence it can be passed
on to the consumer prices.
Administrative burdens on
businesses
- Importers and
manufacturers of
tyres
The estimated cost of type-approval per
tyre is in the order of EUR 5 000 to 15
000 based on the costs of different
options for the testing method.
Operation / conduct of
SMEs
- /0 Few SMEs would
be affected
Tyre manufacturers are generally larger
companies and hence, limited impacts
on SMEs.
Functioning of the internal
market and competition
0 Importers and
manufacturers of
tyres
The cost impacts are moderate and
affect all importers and manufacturers
of tyres. Hence the internal market and
the level of competition should not be
affected.
Public authorities: Change
in costs to authorities for
administrative, compliance
and enforcement activities
- Member State
competent
authorities
This measure will only require
resources in the phase of introducing the
measure.
Public authorities: Change
in costs to the Commission
- European
Commission and
EU institutions
This measure will only require
resources in the phase of introducing the
measure.
Innovation and research -/+ Manufacturers of
tyres
There will be an incentive to innovate to
comply with emission limits, and this
might take R&D resources away from
R&D in other aspects of tyre
performance. Unclear whether there are
trade-offs or synergies.
Third countries and
international relations
+/- Third countries The measure will require third-country
manufacturers to comply.
Consumers and household 0 Households The potential impacts on tyre prices are
uncertain but are expected to be limited.
Environmental impacts
Overall, the emission reduction is estimated in the order of 5-25% (between 28,500 to 142,500 tonnes
per year) and the environmental damages are estimated to be reduced by the same order of magnitude.
The detailed impacts cannot be assessed. The tyre wear comprises different particle sizes and has
different content of hazardous substances. There are no data on the detailed composition of particle
size and substances in the current emissions. Therefore, the impacts of emissions reduction cannot
be estimated (see also the discussion on the health effects).
377
The reduction in emissions will be proportional to all of the environmental compartments. No
significant impacts are expected on waste, efficient use of resources or climate change.
Social impacts
The social impacts primarily include human health impacts. There are two components to consider:
• Potential health impacts from reduced emissions of microplastics
• Possible impacts on road safety leading to more casualties
Overall, the emission reduction is estimated in the order of 5-25%. As discussed in the problem
definition, the emissions of tyre wear contain a large number of chemical substances with varying
levels of toxicity. A study has estimated the difference in a weighted toxicity index of a factor of 4
between the most and the least toxic tyre291
. The health impacts will therefore depend on how the
limit values are defined. If they include particle size and toxicity, the health impacts could be
significantly reduced. If the criteria only focus on total tear wear mass, then there is a potential risk
of an increase in the negative health impacts.
The safety of the tyres could potentially be compromised, but it depends on how the measure is
implemented (and the level at which a limit value is set) and the choice of the consumers. However,
there is a minimum standard for safety, so the introduction of a limit value for abrasion cannot lead
to tyres with safety characteristics below the type-approval requirement292
. Furthermore, the ADAC
study has shown that there are already tyres on the market with low abrasion with no compromises
for safety. Therefore, no reduction in safety is expected.
No impacts on employment are expected considering the relatively low-cost impacts and the fact that
any additional costs would likely be passed on to the consumer.
TYR#2: Emission labelling of particles released from tyre wear
What would be the costs of the measure?
The introduction of TWP emission labelling requires – just as the measure on type-approval above –
that standardised test methods have been developed. As described above under TYR#1, such a test
method is being developed, and it is considered to be available (and needed) before introducing TWP
labelling of tyres. Hence, the implementation of the measures would include the following costs:
• Costs for tyre manufacturers of having their tyres tested
• Cost of changing the label
• Consumer information campaigns
There will be a cost of having each type of tyre labelled. The cost of testing is assumed to be similar
to the costs of type-approval described above the TYR#1(but if both measures are combined, then
testing costs here would be zero as already accounted for in 4f). The cost of the testing has been
estimated to be in the order of EUR 5 000 to 15 000 per type of tyre. It has been estimated to mean
additional costs per tyre at a level between EUR 0.01 and 0.08 depending on how many individual
tyres are produced and sold for a given type as well as the final choice of test method; see Table 128.
291
Emission Analytics / PEW report (2022) - Research report - Tire chemical composition and wear emissions
292
See Type Approval Regulation (EC/661/2009) Annex B
378
Tyre manufacturers would not have to redesign their tyres, but the label will give an incentive to
improve the design in order to achieve a better scoring on the criteria.
The final cost element is related to the modification of the label to include the abrasion rate. Eunomia
(2018) concludes that the costs of modifying the label will be marginal when compared to the price
of each tyre sold on the market. The Commission’s Staff Working Document accompanying the
proposed revision of the Tyre Labelling Directive provides some estimates of the costs to
manufacturers of revising the existing labels293
. This assumes a one-off cost of EUR 40 million for
the readjustment of label classes and reprinting labels. The costs for incorporating abrasion classes /
levels in the label have been assumed to be similar to this.
In addition, it is assumed that some level of consumer information campaigns would be delivered to
maximise the benefits of the measure and ensure that consumers understand what the labels are
showing. Based again on the estimates developed for the revision of the Tyre Labelling Directive,
this is assumed to be a one-off cost of around EUR 12 million.
Therefore, the total costs associated with the measure (excluding type approval which is
included within 4f) are around EUR 52 million (one-off) equating to around EUR 6 million per
year when annualised over 10 years.
For the motorist, the measure will not lead to additional costs as it will still be possible to purchase
any tyres (although it is likely that manufacturers would pass on the above costs in tyre prices). If the
label includes the mileage of the tyre, the consumer will be able to see whether a low abrasion tyre
would also be the better choice from a financial perspective.
What would be the benefits of the measure?
The effect of a label depends on how the consumers will react, which is difficult to assess. The level
of information that is provided will affect the impacts of the label e.g. whether consumer awareness
information campaigns are launched.
Eunomia (2018) has assessed the uptake and effect of introducing a TWP label. The study refers to
the observed effects of the labels on energy efficiency and wet grip, where the annual changes have
been in the order of 1% improvement for energy efficiency (in total across all tyres due to changes
in consumer purchase behaviour). While energy efficiency improvements have a financial
implication for vehicle users and wet grip has a safety aspect, tyre abrasion is much more abstract for
the consumer (unless a clear link to tyre lifetime / durability could be established and communicated).
Therefore, the reduction potential of the label is estimated to be much lower, between 0.1-0.2%
annual improvement on overall tyre microplastic emissions, which, if introduced in 2025, could give
a total reduction of 0.5-1% in 2030.
Table 128: Estimated emission reductions for TYR#2
2022 2030
Effect of measure Total emissions Total emissions Emissions with measure Effect of measure
Low (0.5%) 450 000 570 000 567 150 2 850
High (1%) 450 000 570 000 564 300 5 700
293
Available from : https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/1460-Evaluation-and-
potential-revision-of-the-EU-tyre-labelling-scheme_en
379
The costs-effectiveness of the measure is estimated in the order of EUR 1 100-2 100 per tonne
reduced emissions of TWP.
Economic impacts
The main economic impact is the costs of having all type of tyres tested to determine the label rating.
While the testing costs might turn out differently from what is the current estimate when the final
testing method has been developed and agreed, it is unlikely to be of a different order of magnitude.
These costs are described and included under TYR#1. Costs for changing the label and information
campaigns are expected to be around EUR 6 million per year.
The testing and label cost will firstly be borne by the manufacturers/retailers but is then expected to
be passed on to the consumer in the price of the tyre. For the consumers, it means a marginal increase
in the price of the tyre. Therefore, it is not expected to have any significant impacts on consumers.
Costs for information campaigns are expected to fall to the Member States and Commission.
It may be most effective to consider including the abrasion rate alongside impacts on tyre lifetime as
lower abrasion rates may equate to an increase in tyre lifetime, thus saving consumers money. This
is considered to be a much greater driver for consumer purchasing than microplastic emissions294
.
The effect of a label depends on how the consumers will react, which is difficult to assess. The level
of information that is provided will affect the impacts of the label e.g. whether consumer awareness
information campaigns are launched.
Eunomia (2018) has assessed the uptake and effect of introducing a TWP label. The study refers to
the observed effects of the labels on energy efficiency and wet grip, where the annual changes have
been in the order of 1% improvement for energy efficiency (in total across all tyres due to changes
in consumer purchase behaviour). While energy efficiency improvements have a financial
implication for the vehicle users and wet grip has a safety aspect, tyre abrasion is much more abstract
for the consumer (unless a clear link to tyre lifetime / durability could be established and
communicated). Therefore, the reduction potential of the label is estimated to be much lower,
between 0.1-0.2% annual improvement on overall tyre microplastic emissions, which, if introduced
in 2025, could give a total reduction of 0.5-1% in 2030.
Impacts on other economic impact categories are expected to be similar as for TYR#1.
Environmental impacts
Overall, the emission reduction is estimated to be in the order of less than 1% and the environmental
damages are estimated to be reduced by the same order of magnitude. The detailed environmental
impacts cannot be assessed. The tyre wear comprises different particle sizes and has different content
of hazardous substances. There are no data on the detailed composition of particle size and substances
in the current emissions. Therefore, the impacts of the reduction of emissions cannot be estimated
(see also the discussion on the health effects).
The reduction in emissions will be proportional for all of the environmental compartments. No
significant impacts are expected on waste, efficient use of resources or climate change.
294
https://ec.europa.eu/info/sites/default/files/energy_climate_change_environment/overall_targets/documents/tyre-
label_final-report_0.pdf
380
Social impacts
The social impacts primarily include potential human health impacts. There are two components to
consider:
• Potential health impacts from reduced emissions of microplastics
• Possible impacts on road safety leading to more casualties
Overall, the emission reduction is estimated to be in the order of less than 1%. As discussed in the
problem definition, the emissions of tyre wear contain a large number of chemical substances with
varying levels of toxicity. A study has estimated the difference in a weighted toxicity index of a factor
of 4 between the most and the least toxic tyre295
. The health impacts will therefore depend on how
the limit values are defined. If they include particle size and toxicity, the health impacts could be
significantly reduced. If the criteria only focus on total tear wear mass, then there is a potential risk
of an increase in the negative health impacts.
The safety of the tyres could potentially be compromised, but it is not likely. There are minimum
standards for safety, so the introduction of a label for abrasion rate cannot lead to tyres the safety
characteristics below the type-approval requirement296
. It is not likely that consumers will be more
inclined to buy tyres where the safety performance is low if a tyre abrasion rate label would be
introduced. Therefore, no reduction in safety is expected.
No impacts on employment are expected considering the relatively low-cost impacts and the fact that
any additional costs would likely be passed on to the consumer.
TYR#6: Regular wheel alignment to minimise tyre wear
What would be the costs of the measure?
The costs of this measure relate to ensuring the wheels are aligned as part of the regular vehicle
roadworthiness inspection. Some Member States seem to have this included as a mandatory
requirement as part of regular vehicle inspections (at least France, Ireland and Spain297
) although
there is very limited data on the national practices across all of the EU27 for this particular check and
therefore, it is difficult to estimate the costs (so costs and benefits presented below may be
overestimates if more Member States already require such checks). Furthermore, the share of cars
which may have wheels / axis that are not aligned is not known. RIVM (2017) refers to studies that
suggest that potentially a large share of cars needs this adjustment. The estimate for the Netherlands
is that it could affect between 20% to 40% of the total car stock. They estimate that the level of
abrasion could be around 10% higher for vehicles with poor alignment. It means that if these
estimates would apply to the EU27, the total reduction potential would be between 2% - 4% (in
practice it is lower as some Member States already require such checks).
To assess the cost-effectiveness of this measure, the following assumptions have been used. The cost
of testing for the alignment would be in the order of EUR 20 and in case the axis would need
adjustment that would cost around EUR 40298
. It is assumed that 30% of the inspected cars and vans
needs the adjustment every 4 years. This gives a total cost of around EUR 1.2 billion per year
295
Emission Analytics / PEW report (2022) - Research report - Tire chemical composition and wear emissions
296
See Type Approval Regulation (EC/661/2009) Annex B
297
Personal communication from the International Motor Vehicle Inspection Committee (CITA), July 2022.
298
Expert estimates based on information from car repair shops
381
assuming all Member States apply the measure (except for France, Ireland and Spain who already
require such checks).
The alignment of wheels would also have an impact on the energy use of the car or van. The RIVM
(2017) study suggests that it is in the same order as for abrasion rates i.e. 10%. Assuming that 30%
of existing cars and vans would need adjustment, this would give a potential fuel saving for the fleet
of around 1.6% (as new cars and vans are excluded). This equates to a financial saving of around
EUR 1.5 billion per year299
. The potential saving for tyre costs is highly uncertain so has not been
quantified but would increase the cost savings further.
Total estimated costs and cost savings are presented in the table below.
Table 39: Estimated total costs and cost savings for TYR#6 in 2030 (million Euros)
Cost element One-off costs Recurring costs Total annualised costs
Testing and alignment costs 0 1,176 1,176
Fuel savings 0 -1 526 -1 526
Total costs 0 -350 -350
Overall there is expected to be a net cost saving associated with this measure due to the potential fuel
savings that may be realised. These equate to a cost-effectiveness of EUR -28 900 to -57 700 per
tonne of microplastics reduced i.e. a saving overall. If fuel savings are excluded, then the cost-
effectiveness is EUR 96 400 to 193 700 per tonne of microplastics reduced.
What would be the benefits of the measure?
Based on RIVM (2017) the emission reductions per car or van which is subject to an adjustment of
misaligned wheel would be around 10%. Assuming that the vehicle drives 12 000 km per year, the
savings can be estimated to be around 0.12 kg per car.
As discussed above, the RIVM also estimated the share of vehicles with misalignment to be between
20 and 40%. This leads to annual emission reduction of 2% to 4% for cars and vans and 1.1% to
2.1% for the fleet overall (taking into account that some Member States already require such checks).
Table 40: Estimated emission reductions for TYR#6
2022 2030
Effect of measure Total emissions Total emissions Emissions
with measure
Effect of measure
1.1% reduction 450,000 570,000 563,928 6,072
2.1% reduction 450 000 570 000 557 856 12,144
299
Based on vehicle kilometre data from Eurostat, average fuel economy figures from the IEA Fuel Economy in the
European Union analysis and average fuel costs from the EEA (available from https://www.eea.europa.eu/data-and-
maps/daviz/nominal-and-real-fuel-prices-6#tab-chart_1).
382
In addition to the reductions in microplastic emissions, improvements in fuel efficiency, discussed
above, could also lead to a reduction in CO2 emissions of around 6,610 kt in 2030. The CO2 savings
can also be valued and equate to around EUR 661 million per year300
. There would also be benefits
for the reduction of exhaust emissions of air pollutants (for ICEVs).
Economic impacts
The main direct economic impacts would be the costs for motorists to have the wheel alignment
checked at the roadworthiness inspection and the alignment adjusted where needed. The inspection
is mandatory when the car is four years old and then at least every four years301
. The additional costs
at the inspection could be around EUR 20 every four years. For those where adjustment would be
needed, there would be another EUR 40 to be paid. Total costs would be in the order of EUR 1.2
billion in annual costs.
A side-effect of wheel alignment is reduced energy consumption and lower tyres costs due to longer
lifetimes. These will lead to cost savings for the motorists. As described above, these have been
estimated to be in the order of EUR 1.5 billion per year due to fuel savings, although these are highly
uncertain due to limited evidence on the proportion of vehicles that operate with misaligned tyres.
Environmental impacts
Based on the RIVM (2017) study, the reduction potential could be estimated in the order of 1.1% to
2.1% for the fleet overall (taking into account that some Member States already require such checks).
If testing of alignment is already mandatory in more Member States than those identified, the
potential would be less. The environmental damages would be reduced by the same order of
magnitude (as would costs).
The reduction in emissions will be proportional for all the environmental compartments. The measure
would also reduce energy consumption. It means a positive impact on climate change as in 2030 a
significant share of passenger cars would still be with internal combustion engines. Reductions in
CO2 emissions of around 6,610 kt may be realised in 2030.
No significant impacts are expected on waste.
Social impacts
The social impacts include potential human health impacts. Overall, the emission reduction is
estimated in the order of 1.1% to 2.1% for the fleet overall (taking into account that some Member
States already require such checks). Any potential health impacts are estimated to be reduced by the
same order of magnitude.
300
Based on average fleet emission factors from EEA analysis and expectations for the future
(https://www.eea.europa.eu/ims/co2-performance-of-new-passenger). The avoided CO2 cost is based on the Update
of the External Costs of Transport, with a central value for the short-and-medium-run costs (up to 2030) of EUR
100/tCO2 equivalent for external costs of climate change (https://op.europa.eu/en/publication-detail/-
/publication/9781f65f-8448-11ea-bf12-01aa75ed71a1)
301
There are Member States with more frequent inspections.
383
TYR#5: Enhanced monitoring of tyre pressure
What would be the costs of the measure?
Tyre Pressure Monitoring Systems (TPMS) are already required on new cars and vans (and have
been since 2014), and will be in the future for trucks. This measure includes two elements:
• Change the calibration of the systems for new vehicles being placed on the market so that it
gives a warning with smaller deviations from the optimal pressure levels (exact threshold to
be determined based on a more in-depth technical assessment).
• Information campaigns to make all motorists aware of the importance of having the right
pressure (as it has several benefits).
Changing the systems to provide a warning at a lower threshold is not expected to entail any
significant costs for new cars and vans. However, an in-depth technical assessment would need to be
undertaken at an EU level to determine the feasibility of changing the threshold considering the
uncertainties associated with the existing systems. Both indirect and direct systems are currently
applied across the EU and the uncertainties associated with the systems differ. Engagement with
relevant stakeholders has not identified any clear evidence on whether or not it is feasible to tighten
the current threshold so further investigations are necessary. Furthermore, if deemed feasible to
tighten the thresholds, then such an assessment would need to consider the optimal level at which the
thresholds should be set taking into account levels of tyre abrasion, the sensitivity and accuracy of
the systems and likely driver behavioural response. This has been assumed as a one-off cost of EUR
1 million.
The main effect will only be achieved if motorists are aware of the importance of having the correct
pressure. Therefore, information campaigns would be useful to actually achieve the desired effects.
Such campaigns can differ in scope and scale of effort, and with more effort, more impacts are
expected to be achieved. Assuming the campaign would cost in the order of EUR 0.8 million per
Member State302
, the total costs would be around EUR 22 million one-off costs for a campaign across
the EU. If such campaigns could be done at EU level or based on material produced for all Member
States, it might be possible to reduce the costs.
By having the right pressure, energy consumption will also decrease and the lifetime of the tyres
would increase. It means that motorists that frequently drive with tyres at low pressure will save on
fuel and tyre costs if they make sure to regularly fill tyres with air. Fuel consumption is estimated to
increase by 1% every 2,9 psi / 0.2 bar the tyre is under-inflated303
. Current TPMS systems should
alert the driver when the pressure drops by 20%304
. If we assume that the system would be changed
to alert the driver when tyre pressure drops by 10% instead (actual figure to be determined via an in-
depth technical assessment) and the average car tyre has a recommended pressure between 2 and 2.2
bars (when cold)305
then the impact (benefit) on fuel consumption could be around 1%.
However, this is based on the assumption that all drivers would refill their tyres when the warning
shows. Recent surveys have shown that with the current systems (which are much less sensitive than
302
Data from Danish Road Safety organisation that runs multiple campaigns indicating that the average costs of a
campaign is 6 million DKK. (https://www.ft.dk/samling/20191/almdel/TRU/bilag/418/2218983/index.htm)
303
https://unece.org/DAM/trans/doc/2007/wp29grrf/ECE-TRANS-WP29-GRRF-62-inf17e.pdf
304
https://op.europa.eu/en/publication-detail/-/publication/e96ed45b-d8a8-11e8-afb3-01aa75ed71a1
305
Review of selected tyres available on the market.
384
they would be under this measure) some drivers still ignore such warnings306
. TNO (2013)307
considered a low and high response scenario, with the latter assuming the user always responds to
TPMS warnings and the former around half respond. The high response scenario is not considered
realistic here; therefore, a range of 50-75% of users responding to TPMS alerts has been assumed.
Considering the introduction of the measure in 2025 and around 25% of cars and vans in 2030 having
such a system, this would give a potential fuel saving for the fleet of around 0.1-0.2%. This equates
to a financial saving of around EUR 124 to 210 million per year308
. The potential saving for tyre costs
is highly uncertain, so it has not been quantified but would increase the cost savings further.
Total estimated costs and cost savings are presented in the table below.
Table 41: Estimated total costs and cost savings for TYR#5 in 2030 (million Euros)
Cost element One-off costs Recurring costs Total annualised costs
Technical assessment 1.0 0.0 0.1
Information campaigns 21.6 0.0 7.6
Fuel savings (low) 0.0 -124.4 -124.4
Fuel savings (high) 0.0 -210.7 -210.7
Total costs (low) 22.6 -124.4 -116.7
Total costs (high) 22.6 -210.7 -203.0
Overall there is expected to be a net cost saving associated with this measure due to the potential fuel
savings that may be realised. These equate to a cost-effectiveness of EUR -7,470 to -39,130per tonne
of microplastics reduced, i.e. a saving overall. If fuel savings are excluded, then the cost-effectiveness
is EUR 500 to 1500 per tonne of microplastics reduced.
What would be the benefits of the measure?
The effect of the measures is difficult to estimate as the share of cars and vans driving with tyres with
sub-optimal tyre pressure is not known. RIVM (2017) refers to older data on the share of both heavy-
duty vehicles and cars, indicating that a large share of vehicles is operated with tyres with sub-optimal
pressure. The RAU project (see Figure 4) suggests that the effect of the tyre pressure on microplastic
emissions is 30-40%, but it is unclear how low the pressure should be before such an effect
materialises. RIVM (2017) estimates that the reduction potential could be 10-20%, but the uptake by
the motorist is key for achieving the full potential.
Here is assumed that, in combination with information campaigns, the measure can achieve around
a 10-20% reduction in microplastic emissions, which, when combined with the share of cars and vans
expected to have the new threshold applied by 2030 (25%) and an assumption that 50-75% of users
respond to TPMS alerts, gives a total microplastic reduction of around 0.9-2.7%.
306
https://www.transportenvironment.org/wp-content/uploads/2021/07/Report%20-
%20EU%20drivers%20at%20risk%20of%20under-inflated%20tyres.pdf
307
https://ec.europa.eu/clima/system/files/2017-03/tno_2013_final_report_en.pdf
308
Based on vehicle kilometre data from Eurostat, average fuel economy figures from the IEA Fuel Economy in the
European Union analysis and average fuel costs from the EEA (available from https://www.eea.europa.eu/data-and-
maps/daviz/nominal-and-real-fuel-prices-6#tab-chart_1).
385
Table 42: Estimated emission reductions for TYR#5
2022 2030
Effect of measure Total emissions Total emissions Emissions with measure Effect of measure
0.9% reduction 450 000 570 000 564 813 5 187
2.7% reduction 450 000 570 000 554 382 15 618
In addition to the reductions in microplastic emissions, improvements in fuel efficiency, discussed
above, could also lead to a reduction in CO2 emissions of around 540 to 910 kt in 2030. The CO2
savings can also be valued and equate to around EUR 54 to 91 million per year309
. There would also
be benefits for the reduction of exhaust emissions of air pollutants (for ICEVs).
Economic impacts
The main direct economic impacts will be the costs of undertaking an in-depth technical assessment
to determine the optimal level at which the systems should be set (assumed as a one-off cost of EUR
1 million) and the costs for undertaking information campaigns to raise awareness amongst
consumers (assumed to be around EUR 22 million one-off costs for a campaign across the EU).
Changing the systems to provide warning at a lower threshold is not expected to entail any significant
costs for new cars and vans.
Having the optimal level of tyre pressure will reduce energy consumption and lead to a longer lifetime
of the tyres. These will lead to cost savings for motorists. As described above, these have been
estimated to be in the order of EUR 124 to 210 million per year due to fuel savings, although these
are highly uncertain and depend on the reaction of the consumer to a more sensitive TPMS.
Environmental impacts
Overall, the emission reduction is estimated in the order of 0.9-2.7% in 2030 (increasing in future
years as more vehicles have the new threshold applied) and the environmental damages are estimated
to be reduced by the same order of magnitude.
The reduction in emissions will be proportional for all the environmental compartments. The measure
would also reduce energy consumption. It means a positive impact on climate change as in 2030 a
significant share of passenger cars would still be with internal combustion engines. Reductions in
CO2 emissions of around 540 to 910 kt may be realised in 2030 depending on consumer behaviour.
No significant impacts are expected on waste.
309
Based on average fleet emission factors from EEA analysis and expectations for the future
(https://www.eea.europa.eu/ims/co2-performance-of-new-passenger). The avoided CO2 cost is based on the Update
of the External Costs of Transport, with a central value for the short-and-medium-run costs (up to 2030) of
EUR100/tCO2 equivalent for external costs of climate change (https://op.europa.eu/en/publication-detail/-
/publication/9781f65f-8448-11ea-bf12-01aa75ed71a1)
386
Social impacts
The social impacts include potential human health impacts from reduced emissions of microplastics.
Overall, the emission reduction is estimated in the order of 0.9-2.7% in 2030, and any potential health
impacts are estimated to be reduced by the same order of magnitude.
Having the correct tyre pressure may also have marginal impacts (benefits) on safety and noise, but
they cannot be further quantified.
7.3 Impact of measures for textiles
Table 43 shows the comparison between all measures evaluated to reduce microplastic emissions
from textiles.
Table 43: Comparison of measures for textiles
Measure Estimated
reduction
potential
Estimated
Cost-
effectiveness
(EUR/tons
reduced/year)
Other
environmental
impacts
Other
economic
impacts
Social
impacts
% Ktons/
year
TEX#8: Raising
awareness on
best practices for
consumers of
textiles
Not
quantified
small
TEX#9:
Mandatory label
showing
textiles’
emissions of
microplastics
Not
quantified
small
> 411 000 Costs are
likely to be
passed on to
consumers
TEX#7:
Modulated fees
in EPR for
textiles
Not quantified Costs are
likely to be
passed on to
consumers
in higher
prices.
TEX#2):
Restrict oil-
based synthetic
fibres for certain
applications
26 353
(1 420 –
51 285)
202 000 €/t
(103 000 –
3 747 000 €/t)
Negative impact
on water
consumption &
biodiversity
Reduction of
microplastic
pollution in
marine
environment, air
and soil
Costs are
likely to be
passed on to
consumers in
higher
prices
387
Measure Estimated
reduction
potential
Estimated
Cost-
effectiveness
(EUR/tons
reduced/year)
Other
environmental
impacts
Other
economic
impacts
Social
impacts
% Ktons/
year
TEX#3: Restrict
synthetic fibres
& fabrics with
high releases of
microplastics
28
%
17 168
(923 – 33
412)
176 000
(90 000 –
3 265 000)
Negative impact
on water
consumption and
biodiversity
Reduction of
microplastic
pollution in
marine
environment, air
& soil
Costs are
likely to be
passed on to
consumers in
higher prices
TEX#4:
Mandatory
prewashing of
textiles before
placing on the
market
854
(96 – 1 613)
1 802 000
(955 000 –
16 102 085)
TEX#5: Specific
wastewater
treatment in
textile
production
plants
8% 4 024 (287
– 7 760)
143 000
(74 000 –
2 000 000)
Negative impact
on water
consumption and
CO2 emissions
Reduction of
microplastic
pollution in
marine
environment, air
and soil
Costs are
likely to be
passed on to
consumers in
higher prices
TEX#6:
Compulsory
filters for
washing
machines
5%
3 087
(635 –
5539)
2 627 000
(1 464 000 –
12 764 000)
Negative impact
on water
consumption and
CO2 emissions
Reduction of
microplastic
pollution in
marine
environment
Costs are
likely to be
passed on to
consumers in
higher prices
TEX#1:
Standardised
methodology to
quantify
microplastics
releases from
textiles
388
Table 44Table 44 shows the comparison of the impacts of the measures assessed to reduce
microplastic emissions from textiles.
Table 44: Summary of impacts for measures for textiles
Policy measure Environmental impact Economic impact Social impact
TEX#8: Raising
awareness on best
practices for
consumers of
textiles
The communication
campaign will raise
awareness about
microplastic releases, but it
is uncertain how and if it
will influence the consumer
decision about purchases
and washing/drying
practices.
Cost estimated to be EUR
449 million per year; it
will depend on the level of
ambition of the
communication campaign.
Job creation in the
communication sector
TEX#9:
Mandatory label
showing textiles’
emissions of
microplastics
Reduction of microplastic
releases if the label would
influence the consumer
purchase decision in favour
of textiles releasing less
microplastics.
Between 1.41 and 1.72
billion euros per year,
depending mainly on the
testing costs.
Increase in costs for
consumers (EUR 0.06) per
clothing put on the market)
as the producers might pass
it on.
Job creation in labelling
and certification
companies
TEX#7:
Modulated fees in
EPR for textiles
Tool to combine with other
measures
EPR cost (PRO, MS,
companies): The additional
cost of this measure might
be relatively low since will
it only add the inclusion
microplastics in the criteria
for modulation of textile
fees.
SMEs
Public authorities
Consumers and
households
TEX#2: Restrict
synthetic fibres for
certain
applications
Microplastic release
reduction (26 353 t/year)
Environment (climate
change)
Total cost (5.3 billion
EUR/year)
Consumers and
households
TEX#3: Restrict
synthetic fibres &
fabrics with high
releases of
microplastics
Microplastic release
reduction (17 168 t/year)
Environment (water,
biodiversity)
Material cost (3 billion
EUR/year)
SMEs
Public authorities (only
short-term)
Third countries
Consumers and
households
389
Policy measure Environmental impact Economic impact Social impact
TEX#4:
Mandatory
prewashing of
textiles before
placing on the
market
Microplastic release
reduction (854 t/year)
Environment (water, climate
change)
CAPEX (washing and
drying machines)
OPEX (water, energy,
detergent, labour)
Total cost (1.54 billion
EUR/year)
SMEs
Public authorities
Third countries
Consumers and
households
TEX#5: Specific
wastewater
treatment in textile
production plants
Microplastic release
reduction (4 024 t/year)
Environment (water quality,
climate change)
CAPEX
OPEX (energy)
Total cost (594 million
EUR/year)
SMEs
Public authorities
Third countries
Consumers and
households
TEX#6:
Compulsory filters
for washing
machines
Microplastic release
reduction (3 087 t/year)
Environment (water, climate
change)
CAPEX (filters)
OPEX (water and energy)
Total cost (8.1 billion
EUR/year)
Public authorities (only
short-term)
Already in place France
(applicable from 2025)
Consumers and
households
TEX#1:
Standardised
methodology to
quantify
microplastics
releases from
textiles
No emission reduction per
se but helpful in other
measures and knowledge
improvement
Administrative cost (expert
group and companies):
0.85 million EUR/year
Cost of testing the
materials between EUR
10 000 and 20 000
There could be new
jobs in the R&D sector
(private company or
research organisations)
unless developed by
the existing research
staff
The impact of each measure is outlined below.
TEX#8: Raising awareness on best practices for consumers of textiles
What would be the costs of the measure?
The cost will be the labour cost to run the communication campaign in the EU.
390
What would be the benefits of the measure?
The benefit would mainly be raising consumer awareness and may lead to a small reduction of
microplastic releases.
Economic impacts
The table below details the data about the administrative cost of the communication campaign.
Table 45: Data to estimate the communication campaign administrative cost
Description Data Unit Source
Days of work to communicate in the EU 1 350 days Assumption based on
expert judgement
Overheads 11 % Assumption based on
expert judgement
Average hourly labour cost in the "Information and
communication" sector (EU 27)
39.40 EUR/hour Eurostat (2020)
Average EU number of working hours per day 8.12 hours/day
Considering an average of 50 days of work for each Member State in the EU27, the total cost of a
communication campaign would be around EUR 449 000 per year. These campaigns could also take
place at the Member-State level and be financed by the EPR schemes.
The cost will depend on the level of ambition of the communication campaign. In comparison with
other measures, the cost would always be low.
Environmental impacts
The communication campaign will raise awareness about microplastic releases, but it is uncertain
how and if it will influence the consumer decision about purchases and washing/drying practices.
Research310
shows that price is the most influencing factor in consumer purchasing decisions.
However, according to the Eurobarometer survey311
, more than half of respondents think that
educating people on how to reduce their plastic waste is very important (58%). It is expected that the
emission reduction potential of this measures is rather low.
Social impacts
No significant social impacts are expected.
TEX#9: Mandatory label showing textiles’ emissions of microplastics
What would be the costs of the measure?
The cost of a mandatory label is composed measure of three parts:
310
For example: Sanad, R. A. (2016). Consumer attitude and purchase decision towards textiles and apparel products.
World, 2(2016), 16-30.
311
Attitudes of European citizens towards the Environment (Eurobarometer 2019).
391
• Tests
• Audits
• Label
The tests and audits cost to apply to each textile collection while the label to each piece of textile.
This measure will only require the resources of public authorities in the phase of introducing the
measure. SMEs will be affected as textile production is not limited to larger companies. The measure
will require third-country companies to comply with placing textiles on the EU market. Consumers
and households will be affected by this measure as they will likely support the cost of the label.
What would be the benefits of the measure?
The benefits would be a reduction of microplastic releases if the label would influence the consumer
purchase decision in favour of textiles releasing less microplastics. Brands would also feel the need
to reduce releases in order to improve their rating in terms of microplastic releases and this would
have impacts along the textiles value chain.
Economic impacts
Table 46: Assumptions to estimate the costs of a mandatory label
Description Data Unit Source
Total cost of the tests 660 EUR per
collection
Assumption based on Bureau Veritas prices in
ADEME (2020), Définition de critères d’éco-
modulation applicables à la filière REP
TLC312
.
1 440 EUR per
collection
Audit cost for a label 1 700 EUR per
collection
EU Ecolabel
2 000 EUR per
collection
EU Ecolabel
Labelling cost (just the
label)
0.03 EUR/
pieces
Bilateral discussion with industry.
Administrative cost 11% % Assumption based on expert judgement
Number of collections put
on the market in the EU
25 157 780 000 pieces JRC, Environmental Improvement Potential of
textiles (IMPRO Textiles), January 2014.
Average number of
pieces per collection
100 000 pieces per
collection
ADEME (2020), Définition de critères d’éco-
modulation applicables à la filière REP TLC313
The total average cost of the label is around EUR 1.56 billion per year. The cost range varies between
EUR 1.41 and 1.72 billion per year, depending mainly on the uncertainty of the test costs.
312
https://librairie.ademe.fr/dechets-economie-circulaire/4561-definition-de-criteres-d-eco-modulation-applicables-a-
la-filiere-rep-tlc.html
313
https://librairie.ademe.fr/dechets-economie-circulaire/4561-definition-de-criteres-d-eco-modulation-applicables-a-
la-filiere-rep-tlc.html
392
By assuming that the higher bound consumption change would be that 10 % of the population would
change their purchase behaviour and therefore reduce the total microplastic releases from textiles by
10 %, even without taking the additional material cost into account, it would correspond to an average
cost of 411 000 EUR/t of avoided microplastics.
If the measure TEX#9 “Mandatory microplastic label for textile” is combined with the variation of
measure “TEX#1 Create a standardized measure to quantify microplastics emissions on the life-
cycle”, the cost would be reduced from EUR 1.56 billion per year to EUR 795 million per year. This
is due to the fact that the variation of TEX#1 already implies the existence of a standard and respective
testing costs.
Environmental impacts
The label will raise awareness about microplastic releases but is it uncertain if the label will influence
the consumer decision. Research314
shows that price is the most influencing factor in consumer
purchase decisions. Also, brands would be incentivised to reduce releases to improve their rating and
promote their image as sustainable producers.
Assuming that the higher bound consumption change would be that 10 % of the population would
change their purchase behaviour and therefore reduce the total microplastic releases from textiles by
10 %, the average microplastic releases reduction would be 3 808 t per year. However, if the switch
happens to natural fibres, other impacts (see other measure TEX#2) would increase, in particular,
related to land use and biodiversity.
Social impacts
The consumer would bear the label cost in the end. The average label cost per piece of textile put on
the EU market is EUR 0.06.
TEX#7: Modulated fees in EPR for textiles
What would be the costs of the measure?
An EPR leads to an administrative cost for several actors:
• Producer responsibility organisations (PROs)
• Companies
• Member States
The EPR would lead to the use of resources for public authorities and to an administrative burden for
companies (including SMEs). The consumer will likely support the cost of the EPR system.
What would be the benefits of the measure?
The benefits depend heavily on how the microplastic component of the EPR is implemented.
314
For example: Sanad, R. A. (2016). Consumer attitude and purchase decision towards textiles and apparel products.
World, 2(2016), 16-30.
393
The EPR could reduce microplastic releases if the modulated fees provided incentives for companies
to reduce microplastic releases and if the EPR fees financed microplastic releases reduction measures.
Economic impacts
The table below details the data for the EPR administrative cost.
Table 47: Data to estimate the EPR administrative cost
Description Data Unit Year Source
Entities placing on the
market
Number of marketers in
the EU – textiles
160 000 2020 Euratex
Number of marketers in
the EU - washing
machines
27 Gifam
One time shot to organise
EPR - companies
0.001 FTE - Feasibility of an EPR system for micro-
pollutants
(070201/2020/837586/SFRA/ENV.C.2)
Annual FTE for EPR -
companies
0.001 FTE 2000 Fost plus study2
Overheads for the
companies, EPR
11% 2021 Feasibility of an EPR system for micro-
pollutants
(070201/2020/837586/SFRA/ENV.C.2)
PROs
Number of FTE for the
EPR
183 FTE 2021 Feasibility of an EPR system for micro-
pollutants
(070201/2020/837586/SFRA/ENV.C.2)
One shot consultancy cost
to organise the EPR
1 235 000 EUR Feasibility of an EPR system for micro-
pollutants
(070201/2020/837586/SFRA/ENV.C.2)
Number of days for
financial audit per PROs
and of the quality of the
declaration and statistics
of the PRO members
50 days/
year
- Feasibility of an EPR system for micro-
pollutants
(070201/2020/837586/SFRA/ENV.C.2)
Member State
Number of days per
Member State to control
for EPR
20 days/
year
- Feasibility of an EPR system for micro-
pollutants
(070201/2020/837586/SFRA/ENV.C.2)
General
Average annual EU FTE
admin cost
52 309 EUR/
FTE
2021 Eurostat
Average annual EU FTE
financial and insurance
activities
82 430 EUR/
FTE
2021 Eurostat
394
Description Data Unit Year Source
Average EU number of
working hours per day
7.98 h/day 2021 Eurostat
Average EU number of
working days per year
230 Days
/year
2000 Fost plus study315
Amortisation of the one-
shot cost
20 years - Feasibility of an EPR system for micro-
pollutants (070201/2020/837586/SFRA/ENV.C.2)
The total administrative cost of an EPR for textiles would be around EUR 21.1 million per year.
PROs and companies would bear most of the cost; respectively EUR 11.2 and 9.8 million per year.
The share of the costs of the Members States would be EUR 0.14 million per year. However, this
measure is not about setting up a new EPR, but including microplastics in an existing one. To include
a cost component, we have estimated that taken into account microplastics would cost 5% of the total
cost for the EPR, thus a set up cost of around EUR 1 million. Currently, there is already an EPR for
textiles in France. An EPR for textiles is expected in the following years in the Netherlands and
Sweden. The cost of the measure could therefore be a bit lower, but it would not change the impact
calculations, and the cost of this measure is negligible compared to most of the other measures.
The EU Strategy for Sustainable and Circular Textiles includes proposing of an EU wide EPR with
modulated fees. This will be established in the revision of the Waste Framework Directive and
evaluated in the respective IA. Therefore the additional cost of this measure might be relatively low
since it will only add the inclusion microplastics in the criteria for modulation of textile fees.
Environmental impacts
The environmental impact depends heavily on the way the microplastic release component is
included in the EPR. The eco-modulated fee could provide incentives for microplastics reduction
and/or the impact of another measure that the EPR would finance.
The environmental impacts are difficult to be estimated, as they will depend on the level of the
modulated fees. If textiles with high emissions have higher fees, microplastics emission of those
would decrease. In measure TEX#2, we analyse a restriction of synthetic fibers. A modulated fee will
always have a much lesser effect than such a total ban (restriction). Supposing a perfect price
elasticity, we can assume that cost efficiency would be similar, but the order of magnitude of the
reduction much lower and the measure more proportionate.
Fees could be used to improve technology and wastewater treatment. While technology improvement
can have a significant effect over the medium to long term, it is to be expected that the level of the
fees will be too low to have an important improvement in microplastic capture in wastewater.
Social impacts
No significant social impacts are expected for the administrative costs.
315
RDC Environment, Emploi et investissements liés aux activités de collecte sélective, tri et recyclage des projets FOST
PLUS, 2000
395
The cost of the EPR system will likely be supported by the consumer, but the administrative cost is
very limited (on average less than EUR 0.001 per piece of textile).
TEX#2: Restrict synthetic fibres for certain applications
What would be the costs of the measure?
The economic cost is the cost difference of the switch of fibres (cotton, wool, flax, viscose, polyester,
acrylic, polyamide, polypropylene).
When comparing the production costs of textiles made from the different fibres, the significant
difference comes from the prices of these fibres. The change in production process is not considered
significant for the total cost316
but investments may be required in some cases.
This measure will only require resources of public authorities in the phase of introducing the measure.
SMEs will be affected as textile production is not limited to larger companies. The measure will
require third country manufacturers to comply when placing textiles on the EU market.
What would be the benefits of the measure?
This measure acts on the emission of microplastics during production, wearing, washing and drying
according to the proportion of synthetic materials in clothing.
Economic impacts
The costs associated with the foregone synthetic fibres were compared to those associated with the
additional natural fibres, and the total cost of the measure was computed.
Table 48: Prices of fibres
Fibre Data Unit317
Source
cotton 2.59 EUR/kg IndexMundi
wool 10.75 EUR/kg IndexMundi
flax 3.11 EUR/kg Indexbox
viscose 3.68 EUR/kg Fiber2Fashion
polyester 1.23 EUR/kg Fiber2Fashion
acrylic 2.32 EUR/kg Fiber2Fashion
polyamide 2.78 EUR/kg Plasticker
polypropylene 1.40 EUR/kg Plasticker
316
The yarn represents more than 50 % of the total fabric cost (Handfield, R., Sun, H., & Rothenberg, L. (2020).
Assessing supply chain risk for apparel production in low cost countries using newsfeed analysis. Supply Chain
Management: An International Journal.).
317
The used exchange rates were taken from the European Central Bank.
396
The total cost of the measure is EUR 5.3 billion per year. It corresponds to 202 000 EUR/t of avoided
microplastics on average (lower bound: 103 000 EUR/t; higher bound: 3 747 000 EUR/t).
In addition, further assessment is still needed on the possible scalability of production and
competitiveness.
Environmental impacts
The measure allows an average reduction of 26 353 tonnes per year (lower bound reduction: 1 420
tonnes per year, higher bound reduction: 51 285 tonnes per year).
The environmental analysis carried out on the production of raw materials (fibre production) shows
an increase in the impact of water consumption between the baseline scenario and measure 1a
(+37%). This increase is linked to the increase in the proportion of cotton. Indeed, cotton production
involves intensive use of water (Luján-Ornelas C. et al., A Life Cycle Thinking Approach to Analyse
Sustainability in the Textile Industry:A Literature Review, Sustainability 2020, 12, 10193).
Figure 37: Water use for the production of textile raw materials (quantities of textiles: 9 million tonnes)
The figure only shows the production of fibres. The other stages of the life cycle (production, use,
distribution, end of life) are also impacted by the change of raw materials (e.g. different dyeing,
different care conditions) but the main impact is the raw material production. (ETC, Microplastic
pollution from textile consumption in Europe, February 2022).
The following figure shows the global warming impact of clothing production (including the
production of raw materials).
397
Figure 38: Impact on climate change due to the production of fabric from different fibres types
For the production of raw materials, cotton and polyester have a similar impact on climate change.
Cotton has a lower impact than polyester in the production of the fabric (pretreatment to printing and
dyeing). Thus, cotton fabric has a lower impact than polyester fabric.
Figure 39: Impact on ecosystem diversity due to the production of fabric from different fibre types
The impact on ecosystem diversity is bigger for most natural fibres (viscose, flax and cotton) than
for synthetic fibres.
Biodiversity was assessed qualitatively in the T-shirts PEFCR pilot318
as there is currently no
adequate indicator to express impacts on biodiversity319
.
318
Sandrine Pesnel, Jérôme Payet (Cycleco) on behalf of the Technical Secretariat of the T-shirts PEFCR pilot, Product
Environmental Footprint Category Rules (PEFCR) T-shirts, February 2019.
319
Technical Helpdesk, Mark Goedkoop, Issue Paper - Addressing biodiversity in the Environmental Footprint pilots,
May 2015.
398
Activities related to clothing production contribute to the impact on biodiversity. Mainly, it focuses
on raw material extraction and production of natural and synthetic fibres. Five potential pressures
constitute an important effect on biodiversity: loss and degradation of natural habitats,
overexploitation of biological resources, pollution and excessive nutrient loads, climate change and
invasive alien species on the ecosystem320
.
The relations between raw material and their consequences on biodiversity are described in the
following list:
Raw material for natural fibres (from crops) as cotton, hemp, flax, etc.:
− extensive area cropland could cause degradation and fragmentation of habitats;
− use of large amount of water with a significant impact on the ecosystem, for instance
cotton production uses more water consumption than flax or hemp;
− chemical product as fertilizers or pesticides and other agricultural chemicals
contributing to excessive nutrient lead in soil and water.
Raw material for natural fibres (from animals) as wool, silk, etc:
− impact from multiple land uses affect to degradation and fragmentation of natural
habitats, however, for the production of silk the area extension impact is limited by way
of cultivation;
− the livestock production pollution impact could come from pesticides used to protect
animals from parasites (for wool);
− climate change impact has as its source the fossil fuel used in the agrochemicals
production, the farming and distribution of feed crops, as well as the own livestock.
Raw material for artificial or regenerated fibres as viscose:
− lack of management of natural forests and plantations could occasion degradation and
fragmentation of habitats;
− utilisation of agrochemical in forest plantations and the pulp mill could discharge
pollutants into soil and water;
− loss of forest and use of energy contribute to the climate change impact.
Raw material for synthetic fibres as polyester: only the areas exploitation for non-renewable
sources and energy use contribute to impact the pressures mentioned before.
There are different production processes to obtain viscose. The impact on global warming and human
toxicity varies greatly depending on the production method (production of the wood pulp and
chemical process to obtain the viscose) (Li Shen et al., Environmental impact assessment of man-
made cellulose fibres; Changing Markets Foundation, Dirty Fashion – How pollution in the global
textiles supply chain is making viscose toxic, June 2017).
Social impacts
The economic cost of the measure per piece of clothing is approximately EUR 0.21 which is likely
to be passed on to consumers in price rises.
320
IUCN (International Union for Conservation of Nature), Biodiversity Risk and Opportunities in the Apparel Sector,
2016
399
There are also potential health impacts from reduced emissions of microplastics.
TEX#3: Restrict synthetic fibres & fabrics with high releases of microplastics
What would be the costs of the measure?
The economic cost is the cost difference of the switch of fibres (cotton, wool, flax, viscose, polyester,
acrylic, polyamide, polypropylene) like for measure TEX#2: Restriction of all synthetic fibres for
certain applications. The price of the fibres is detailed in Table 48.
When comparing the production costs of textiles made from the different fibres, the significant
difference comes from the prices of the fibres. The change in the production process is not significant.
This measure will only require the resources of public authorities in the phase of introducing the
measure. SMEs will be affected as textile production is not limited to larger companies. The measure
will require third-country manufacturers to comply when placing textiles on the EU market.
What would be the benefits of the measure?
This measure acts on the emission of microplastics during production, wearing, washing and drying
according to the proportion of synthetic materials in clothing.
Economic impacts
The costs associated with the foregone synthetic fibres were compared to those associated with the
additional natural fibres, and the total cost of the measure was computed. The assumption taken is
thus a complete switch from these “high release synthetic fibres” by natural fibres. Hereunder is a
variation with a switch from these fibres to “low release synthetic fibres”.
The total cost of the measure is around EUR 3 billion per year. It corresponds to 176 000 EUR/t of
avoided microplastics on average (lower bound: 90 000 EUR/t; higher bound: 3 265 000 EUR/t).
Environmental impacts
The measure allows an average reduction of 17 168 tonnes per year (lower bound reduction: 923
tonnes per year, higher bound reduction: 33 412 tonnes per year).
The environmental analysis carried out on the production of raw materials (fibre production) shows
an increase in the impact of water consumption between the baseline scenario and measure 1b
(+23%). The explanation is the same as for measure TEX#2: Restrict synthetic fibres for certain
applications.
400
Figure 40: Water use for the production of textile raw materials (quantities of textiles: 9.0 million
tonnes)
As for measure TEX#2: Restrict synthetic fibres for specific applications, the other stages of the life
cycle are also impacted by the change of raw materials, but the main impact is the raw material
production.
Social impacts
The economic cost of the measure per piece of clothing is approximately EUR 0.12 which is likely
to be passed on to consumers in price rises.
There are also potential health impacts from reduced emissions of microplastics.
Variation of the measure
For the type of clothes with high releases of microplastics, synthetic fibres could be replaced by
synthetic fibres with lower microplastic releases (instead of natural or artificial ones). The total
economic cost to replace knitted polyester with acrylic for those clothes would be EUR 670 million
per year. The measure variation allows an average reduction of 1 249 tonnes of microplastics per
year (lower bound reduction: 134 tonnes per year, higher bound reduction: 2 365 tonnes per year).
The microplastic release reduction is low because there is no reduction for production and wearing
as there is no specific emission data per synthetic fibre despite the fact that these life-cycle steps are
significant in terms of microplastic releases. This variation measure is not cost-effective as it leads
to EUR 536 000 per of avoided microplastics on average (lower bound: 283 000 EUR/t; higher
bound: 4 998 000 EUR/t).
If we assume that the microplastic release reduction for production and wearing would be the same
as for washing (around 15 %) by replacing knitted polyester with acrylic, the measure variation will
allow an average reduction of 5 877 tonnes of microplastics per year (lower bound reduction: 318
tonnes per year, higher bound reduction: 11 436 tonnes per year). It corresponds to an average cost
of 114 016 EUR/t of avoided microplastics (lower bound: 58 592 EUR/t and higher bound: 2 109
597 EUR/t). This estimation is not based on scientific evidence but on an approximate extrapolation.
401
If we assume that the microplastic release reduction for production and wearing would be the same
as for washing (around 15 %) by replacing knitted polyester with acrylic, the measure variation would
allow an average reduction of 5 877 tonnes of microplastics per year (lower bound reduction: 318
tonnes per year, higher bound reduction: 11 436 tonnes per year). It corresponds to an average cost
of 114 000 EUR/t of avoided microplastics (lower bound: 59 000 EUR/t and higher bound: 2 110
000 EUR/t). This estimation is not based on scientific evidence but on an approximate extrapolation.
TEX#4: Mandatory prewashing of textiles before placing on the market
What would be the costs of the measure?
The main costs would be the operating cost and conduct of business (CAPEX and OPEX) to prewash
the textiles before placing them on the market.
This measure will require the resources of public authorities in the phase of introducing the measure
and to organise the audits to control the certification schemes. SMEs will be affected as textile
production is not limited to larger companies. The measure will require third-country manufacturers
to comply when placing textiles on the EU market.
What would be the benefits of the measure?
This measure acts on the emission of microplastics during washing and drying with an assumed
reduction of microplastic releases of 11% (assumption based on Textile Mission (2021) Textiles
Mikroplastik reduzieren - Erkenntnisse aus einem Interdsziplinären Forschungsprojekt).
Economic impacts
The main cost impacts are:
Capital expenditures:
o industrial washing machines
o dryer machines
Operational expenditures:
o energy consumption (gas, electricity)
o water consumption
o labour
Table 49: Data to estimate the costs of prewashing
Description Data Unit Source
Number of production
plants in the EU
160 000 plants Euratex (2019)
Number of production
plants outside the EU
for the EU market
201 739 plants Assumption based on European Environment
Agency and Statista data
EU textile production 6 900 000 tonnes/year European Environment Agency (2020)
Worldwide textile
fibres production
109 000 000 tonnes/year Statista (2020)
402
Description Data Unit Source
Textiles imported into
the EU in 2020
8 700 000 tonnes/year European Environment Agency (2020)
Industrial washing
machine price (capacity
of 50kg)
7 200 EUR Taizhou Haifeng Machinery Manufacturing
Co,.
Assumption based on expert judgement -
Running time of 30 minutes
Water consumption -
washing machine
15 l/kg of textiles
Gas consumption -
washing machine
1.925 MJ/kg of textiles
Electricity
consumption - washing
machine
0.08 kWh/kg of
textiles
Dryer machine price
(capacity of 50kg)
54 000 EUR Taizhou Haifeng Machinery Manufacturing
Co,.
Assumption - running time of 30 minutes
Gas consumption -
washing machine
4 MJ/kg of textiles
Electricity
consumption - washing
machine
0.42 kWh/kg of
textiles
Average lifetime -
Industrial dryer and
washing machine
12 years Assumption based on literature
Water price (EU) 4.01 EUR/m³ Economic Information and Forecasting
Office(BIPE), French Federation of Water
Enterprises (FP2E), 7th edition of the study on
public water and sanitation services in France
and abroad (2020)
Water price (Asia) 0.68 EUR/m³ CEIC, Price monitoring center
Electricity price (EU) 0.14 EUR/kWh Eurostat (2020) for EU27, IA electricity
consumption without taxes
Electricity price (Asia) 0.11 EUR/kWh Global petrol prices
Gas price 0.00695 EUR/MJ Eurostat (2019)
FTE 0.000050 per
washing/drying
cycle
Assumption based on expert judgement - 5
minutes per washing/drying cycle
Average yearly labour
cost for manufacturing
sector (EU)230
51 091 EUR/year Eurostat (2020
Average yearly labour
cost for manufacturing
sector (non-EU)
11 590 EUR/year Trading economics
Detergent consumption 10 g/kg European Commission - Best Environmental
Management Practice (2017)
Detergent price 0.15 EUR/kg
403
The energy cost (including gas and electricity) represents the biggest part of the cost, 40% for EU
plants and 56% for plants outside the EU.
Figure 41: Prewashing step costs
The total cost of a prewashing step would be around EUR 1.54 billion per year. It would cost around
EUR 856 million per year for plants in the EU and EUR 684 million per year for plants exporting to
the EU from outside of the EU.
This cost is a higher bound cost because we supposed that textiles are not prewashed in the baseline
as we do not have data about the numbers of plants and the amount of textiles that is already
prewashed before placing on the market.
It corresponds to an average cost of 1 802 000 EUR/t of avoided microplastics (lower bound: 955
000 EUR/t and higher bound: 16 102 085 EUR/t).
Environmental impacts
The measure equates to an average reduction of 854 tonnes per year (lower bound reduction: 96
tonnes per year, higher bound reduction 1 613 tonnes per year).
The main impacts on global warming are related to energy consumption (electricity and heat) for
washing and drying321
. Considering a European consumption of 9 million tonnes of textiles, the
impact on GHG emissions for prewashing is 8 364 kt CO2 eq. It corresponds to around 0.93 kg CO2
eq/kg of clothing. For the whole life cycle, this represents an increase of about 2% of the climate
change impact of textiles.
321
Electricity mix of Asia is used to model prewashing outside Europe. Heat is produced from natural gas.
0
100
200
300
400
500
600
700
800
900
EU Non EU
milion
€/year
Dryer and washing machine Detergent
Energy Water
Labour
404
Figure 42: Impact of prewashing on climate change
The main impact on water use is related to water consumption during the washing. Considering a
European consumption of 9 million tonnes of textiles, the impact on water use for prewashing is 1.44
billion m³. It corresponds to around 160 l/kg of clothing.
Figure 43: Impact of prewashing on water use (measure 3)
Social impacts
The average economic cost of the measure per piece of clothing is EUR 0.06 which is likely to be
passed on to consumers as a price increase.
There are also potential health impacts from reduced emissions of microplastics.
405
TEX#5: Specific wastewater treatment in textile production plants
What would be the costs of the measure?
The main costs would be the operating cost and conduct of business (CAPEX and OPEX) to have a
wastewater treatment tackling microplastics in textile production plants.
We do not have data about the number of plants that already have a wastewater treatment system that
is effective in limiting microplastic releases. The costs and benefits of this measure are higher bound
estimations because we assumed that none of the plants is equipped with wastewater treatment to
limit microplastic releases.
This measure will require the resources of public authorities in the phase of introducing the measure
and to organise the audits to control the certification schemes. SMEs will be affected as textile
production is not limited to larger companies. The measure will require third-country manufacturers
to comply when placing textiles on the EU market.
What would be the benefits of the measure?
This measure acts on the emission of microplastics during production and is assumed to reduce
emissions of microplastics by 25% during production (assumption based on expert judgement).
Economic impacts
The table below details the data to compute the costs of this measure.
Table 50: Data to estimate the costs of wastewater treatment in production plants
Description Data Unit Source
Number of production
plants in the EU
160 000 plants Euratex ( 2019)
Number of production
plants outside the EU for
the EU market
201 739 plants
Assumption based on European Environment
Agency and Statista data
EU textile production 6 900 000 tonnes/year European Environment Agency (2020)
Worldwide textile fibres
production
109 00 000 tonnes/year Statista (2020)
Textiles imported into the
EU in 2020
8 700 000 tonnes/year European Environment Agency (2020)
CAPEX - Textile
wastewater machine price
21 420 EUR Gongyuan Environmental Equipment
Average lifetime of the
machine
15 years Assumption based on review of literature
Electricity 29 000 000 MJ/year
WP08, E. N. E. A. Life Cycle Assessment of
silk-and charged silk yarn in I09 company.
Electricity price (EU) 0.14 EUR/kWh
Eurostat (2020) for EU27, IA electricity
consumption without taxes
Electricity price (Asia) 0.11 EUR/kWh Global Petrol prices
406
The total cost of introducing specific wastewater treatment in textiles production plants would be
EUR 594 million per year. It would cost EUR 267 million per year for plants in the EU and EUR 327
million per year for plants exporting to the EU from outside the EU.
The cost for the plants in the EU is a higher bound as some plants may already have a wastewater
treatment plant that is effective in limiting microplastic releases.
It corresponds to an average cost of 143 000 EUR/t of avoided microplastics (lower bound: 74 000
EUR/t and higher bound: 2 000 000 EUR/t).
Figure 44: Specific wastewater treatment in production plants cost
The CAPEX of a wastewater treatment represents more than 85% of the total annual cost.
Environmental impacts
The measure equates to an average reduction of 4 024 tonnes per year (lower bound reduction: 287
tonnes per year, higher bound reduction: 7 760 tonnes per year).
In addition to reducing the microplastic releases from the textile industry, adding a new filter system
in textile plants could also improve water quality by removing other pollutants from, for example,
the textile dyeing process.
Introducing additional wastewater treatment will incur additional energy usage. Considering a
European consumption of 9 million tonnes of textiles, the impact on global warming for wastewater
treatment is 1 044 kt CO2 eq. It corresponds to 0.12 kg CO2 eq/kg of clothing.
407
For the whole life cycle, this represents an increase of about 0.2% of the climate change impact of
textiles.
Figure 45: Impact of wastewater treatment in production plants on GHG emissions
Social impacts
The economic cost of the measure per piece of clothing is estimated to be EUR 0.02 which is likely
to be passed on to consumers as a price increase.
There are also potential health impacts from reduced emissions of microplastics.
TEX#6: Compulsory filters for washing machines
What would be the costs of the measure?
The main cost would be the cost to equip the washing machines with microplastic filters.
Filters will be mandatory on new washing machines in France from 2025, but this was not considered
in the baseline. Therefore, the benefits and costs would be around 15 % smaller by taking the French
policy measure into account.
This measure will only require the resources of public authorities in the phase of introducing the
measure. SMEs will not be affected as washing machine producers are larger companies. The
measure will require third-country washing machine producers to comply when placing washing
machines on the EU market. This measure will also require communication to consumers in order to
avoid inadequate filter maintenance. This is complementary with measure TEX#8: Raising awareness
on best practices for consumers of textiles.
What would be the benefits of the measure?
This measure acts on the emission of microplastics during washing with an assumed efficiency of an
external filter of 89%.
408
Economic impacts
Table 51: Data to estimate the cost of washing machine filters
Description Data Unit Source
Number of washing machines sold
in the EU per year (2018/2019)
27 700 000 pcs Applia (2019)
Number of washing machines in
the EU
195 000 000 pcs Eurostat (2019)
Cost of an internal filter - Xfiltra 100 EUR Industry assumption during a
bilateral interview
Efficiency - Xfiltra 78% % Napper, I. E., Barrett, A. C., &
Thompson, R. C. (2020). The
efficiency of devices intended to
reduce microfibre release during
clothes washing. Science of The
Total Environment, 738, 140412.
Lifetime - Xfiltra 12.5 years Assumption - the lifetime is equal to
the washing machine one
Cost of an external filter -
Guppyfriend washing bag
30 EUR OECD (2021), Policies to Reduce
Microplastics Pollution in Water:
Focus on Textiles and Tyres, OECD
Publishing, Paris.
Efficiency - Guppyfriend washing
bag
54% % Napper, I. E., Barrett, A. C., &
Thompson, R. C. (2020). The
efficiency of devices intended to
reduce microfibre release during
clothes washing. Science of The
Total Environment, 738, 140412.
Lifetime-washing bag 0.25 year The washing bag can last for a
minimum of 50 cycles, and there are
on average of 20 cycles per month
per household
Cost of an external filter - Filtrol
160
141 EUR Filtrol
Replacement Filter Bag 13.4 EUR Filtrol
Efficiency - Filtrol 160 89% % Microfiber Policy Brief 2019 -
Rochman Lab
Lifetime - Filtrol 1 year For 253 cycles
Yearly electricity consumption for
laundry washing
160 per household
in kWh
Pakula, C., & Stamminger, R.
(2010). Electricity and water
consumption for laundry washing by
washing machine worldwide.
Energy efficiency, 3(4), 365-382.
Yearly water consumption for
laundry washing
10 per household
in m3
Water consumption for one cycle 60 Litres Assumption based on literature
Energy consumption for one cycle 1 kWh/cycle Assumption based on literature
Additional water use 39 % Association of Home Appliance
Manufacturers (AHAM)
Additional run time 15 %
409
Figure 46: Cost of microplastic filters for washing machines
It would cost around EUR 8.1 billion to equip all washing machines with an internal microplastics
filter based on current costs. It corresponds to an average cost of 2 627 000 EUR/t of avoided
microplastics (lower bound: 1 464 000 EUR/t and higher bound: 12 764 000 EUR/t).
The costs are likely to decline as the technology is relatively new. There is probably improvement
potential to reduce the filter production cost and also to reduce the increased consumption during its
use (water and electricity).
Environmental impacts
The measure equates to an average reduction of 3 087 tonnes per year (lower bound reduction: 635
tonnes per year, higher bound reduction 5 539 tonnes per year)) based on a filter efficiency of 89 %.
The microplastic release reduction is relatively low because the microplastic releases of washing are
small compared to those at the other life-cycle steps (mainly production and wearing).
The following figure shows the impact on GHG emissions associated with 1 wash322
. The increase
in the impact on GHG emissions is mainly related to the increase in electricity consumption (linked
to the additional run time)—the impact increases by 18%.
According to the IMPRO Textile study, the use phase accounts for 45% of the life cycle impact of
the product on global warming. The washing accounts for 56% of climate change impact for the use
phase. Washing, therefore, accounts for 25% of the product's life cycle impact on global warming.
For the whole life cycle, the use of a filter represents an increase of about 1 to 2% of the climate
change impact of textiles (increase depending on the number of wash cycles).
322
Depending on the product, there can be up to 104 washes (Impro Textiles)
410
Figure 47: Impact of microplastic filters for washing machines on GHG emissions
The following figure shows the impact on water use associated with 1 wash. The increase in the
impact is mainly related to the increase in water consumption. The impact increases by 27%.
Figure 48: Impact of microplastic filters for washing machines on water use
Social impacts
The economic cost would lead to an additional cost of EUR 0.24 per washing cycle supported by
consumers.323
323
Based on 174 washing cycles per year (AISE).
411
The cost of the filter would represent between 28 and 40 % of the average price of a 7 kg washing
machine324
. As mentioned previously, the cost of the filters is likely to decline as the technology is
relatively new.
There are also potential health impacts from reduced emissions of microplastics.
TEX#1: Standardised methodology to quantify microplastic releases from textiles
This measure was developed in response to the knowledge gaps we identified around the precise
measurement of microplastic emissions. Developing a standardised measurement methodology will
enable the development of reduction-specific measures at a later stage.
What would be the costs of the measure?
The one-shot costs of creating a standard are divided into two parts:
• The administrative costs of elaborating the standard (EUR 850 000)
• The costs of conducting tests for companies (EUR 10 000-20 000)
This measure will only require the resources of public authorities in the phase of introducing the
measure.
What would be the benefits of the measure?
This measure will benefit all other measures on textiles as the release of microplastics during the life
cycle of synthetic textile is a critical knowledge gap. The indirect benefits will also include the
awareness-raising of the textile value chain actors and consumers. If an EPR system is implemented,
the eco-fee can also be modulated according to the volume of microplastic release and respective
actors' contributions. It is already a necessary step to measure any reduction measure's success rate.
This measure would be necessary to support other measures (TEX#9 Mandatory label showing
textiles’ emissions of microplastics).
Economic impacts
The table below details the data to compute the cost of developing the standard.
Table 52: Assumption and data to estimate the costs of developing and implementing a standard
Description Data Unit Source
Number of people working full time necessary to elaborate the
standard between 8 and 36 months325
7.25 People ISO website
Mean cost of labour in EU of one engineer working full-time 39.5 EUR/hour Eurostat
Number of hours per week in a full-time job 40.6 hours/week Eurostat
Number of marketers in the EU - textiles 160 000 Number Euratex
Number of marketers in the EU - washing machines 27 Number Gifam
324
Based on an average 7 kg wahsing machine price of EUR 360. ADEME. F. Michel, T. Huppertz, J. R. Dulbecco et J.
Lhotellier, RDC Environment. décembre 2019. Evaluation économique de l’allongement de la durée d’usage de
produits de consommation et biens d’équipements– Rapport. 148 pages.
325
The ISO technical committee on the environmental aspects of plastics is comprised of 29 members (the national
standardization organisation). We assume that each member contributes 0.25 FTE to work on the committee.
412
Description Data Unit Source
Fraction of companies conducting tests for elaborating the
standard
5 % Assumption
Number of engineers necessary per company to conduct the
tests
1 person Assumption
Mean worked hours per day in the EU by a full-time employee 8.12 hours/day Eurostat
Number of hours necessary per company to conduct the tests 24 Hours Assumption
based on expert
judgement
The total cost of the measure on average, is one-shot cost of EUR 8.5 million. The methodology
would be relevant for at least 10 years. This would lead to an annualised cost of EUR 0.85 million.
Once the standard is developed, there will be the additional cost of testing the materials (only once
per material). This cost was evaluated to range between EUR 10 000 and 20 000 by expert
judgement.
Environmental impacts
No significant environmental impacts are foreseen.
It will raise awareness on microplastic release for the companies that participate to the elaboration of
the standard.
Social impacts
No significant social impacts are foreseen326
.
Variation
In addition to the development of a methodology to quantify microplastic emissions on the life-cycle,
a variation of the measure would be to make the application of the standardized methodology
mandatory for the companies putting a lot of pieces of textiles on the EU market. This would imply
tests, audits and reporting on the microplastic emissions on the whole life-cycle.
Focussing on the companies putting a lot of pieces of textiles on the market is more cost effective as
those companies usually have a large number of pieces per collection. This implies that the cost is
spread on more textile pieces compared to smaller companies with have usually a lower number of
pieces per collection. This would also spare SMEs.
In France, based on producer responsibility organisation for textile (Refashion/Eco TLC) data, the
14% of the biggest companies based on the number pieces of textiles put on the market put 95% of
the textile’s pieces327
. If we apply this proportion to pieces put on the market in the EU with an
average number of pieces by collection of 100 000, the average cost of the test to quantify
microplastic emissions of the life-cycle stage and the audits would be EUR 769 million per year.
326
The total cost of the measure per piece of clothing is EUR 0.0003.
327
ADEME (2020), Définition de critères d’éco-modulation applicables à la filière REP TLC
(https://librairie.ademe.fr/dechets-economie-circulaire/4561-definition-de-criteres-d-eco-modulation-applicables-a-
la-filiere-rep-tlc.html)
413
Seen the huge number of piece, a sampling approach seems to be warranted. A sample of 10% of the
market (biggest companies) could be tested every year, leading to a cost of EUR 77 million per year.
If the tests would be realised on all the textiles put on the market, the cost would be like the labelling
measure as the cost of the label itself is insignificant (EUR 1.56 billion). It seems however
disproportioned to apply this measures to all.
Table 53: Assumption and data to estimate the costs of tests, audits and reporting of microplastic
emissions
Description Data Unit Source
Total cost of the tests 660 EUR per collection Assumption based on Bureau
Veritas prices in ADEME (2020),
Définition de critères d’éco-
modulation applicables à la filière
REP TLC328
.
1 440 EUR per collection
Audit cost for a label 1 700 EUR per collection EU Ecolabel
2 000 EUR per collection EU Ecolabel
Administrative cost 11% % Assumption based on expert
judgement
Number of pieces put on
the market in the EU
25 157 780 000 pieces JRC, Environmental Improvement
Potential of textiles (IMPRO
Textiles), January 2014.
Average number of pieces
per collection
100 000 pieces per
collection
ADEME (2020), Définition de
critères d’éco-modulation
applicables à la filière REP
TLC329
.
7.4 Impact of measures for paints
Table below shows the comparison between all measures evaluated to reduce microplastic emissions
from paints.
328
https://librairie.ademe.fr/dechets-economie-circulaire/4561-definition-de-criteres-d-eco-modulation-applicables-a-
la-filiere-rep-tlc.html
329
https://librairie.ademe.fr/dechets-economie-circulaire/4561-definition-de-criteres-d-eco-modulation-applicables-a-la-
filiere-rep-tlc.html
414
Table 54: Comparison of measures for paints
Measure Estimated
reduction potential
Estimated Cost-
effectiveness
(EUR/tons
reduced/year)
Other
environmental
impacts
Other economic
impacts
Social
impacts
% Ktons/
year
PNT#2a:
Mandatory label
on paint lifetime
and plastic
content
1-2.5% 3.5 – 6.5
190–354 EUR/kg
(1 240 million
EUR/ 3.5-6.5 kt)
Potential other
negative impacts,
e.g. CO2
emissions
Cost for paint
producers that may
be borne by
customers
PNT#3a:
Promote
mineral paint in
the architectural
sector
Not
relevant
0kt -
Reduction of
microplastics
released into
environment
Negative impact on
paint costs for paint
producers that may
be borne by
customers. Minimal
impact expected is
because most
polymer-based
producers will not
switch to mineral-
based products
through a voluntary
scheme
PNT#5: Good
practices for
paint
application in
all sectors
Low Low Low
Reduction of
microplastics
released into
environment
PNT#4:
Deposit-return
scheme for paint
containers
0% 0 kt
(increase
in
circularity)
-
54 -1 000 million
EUR/year
/ 0 kt
Positive impacts
in terms of
circularity of
paints (increased
reuse and
recycling)
Negative impact on
paint cost for paint
producers that may
be borne by
customers
PNT#2b:
Threshold on
lifetime and
plastic content
for paints
Not
quantified
Reduction of
microplastic
release into
environment
Cost for paint
producers that may
be borne by
customers
PNT#3b:
Restrict
polymer-based
paints in the
architectural
sector
Not
quantified
PNT#1:
Standardised
methodology of
paint lifetime
-
415
The table below shows the comparison of the impacts of the measures assessed to reduce microplastic
emissions from paints.
Table 55: Summary of impacts for measures for paints
Policy measures Environmental impact Economic impact Social impact
PNT#2a:
Mandatory label
on paint lifetime
and plastic
content
Reduction of microplastic
releases as the label would
raise the knowledge of
paint-related microplastics
pollution and it would
encourage the consumers to
take a better decision.
Negative impact on paint
cost for paint producers that
may be borne by customers
Job creation in labelling
and certification
companies
PNT#3a: Promote
mineral paint in
the architectural
sector
Microplastic release
reduction (71 kt, non-
incremental)
Risk of increased CO2
emissions
Material costs limited if
applied through
ecolabel/GPP. If
implemented through a ban,
very high material costs due
to complete change of
production line, for >95% of
architectural paint sector.
SMEs
Consumers and
households
PNT#5: Good
practices for paint
application in all
sectors
Reduction of microplastics
release from paints into
environment
PNT#4: Deposit-
return scheme for
paint containers
1.5 kt reduction of
microplastics release
Limited economic impact No social impact
PNT#2b:
Threshold on
lifetime and
plastic content for
paints
Reduction in microplastic
emissions
Potential increase in paint
toxicity, negative CO2
impacts and increase in
waste generation
Negative impact on paint
cost for paint producers that
may be borne by customers
No social impact
PNT#3b: Restrict
polymer-based
paints in the
architectural
sector
Reduction in microplastic
emissions
Proper LCA needed to assess
environmental footprint
Negative impact on paint
cost for paint producers that
may be borne by customers
Job creation, albeit
limited
416
PNT#1:
Standardised
methodology of
paint lifetime
No emission reduction per
se but helpful in other
measures and knowledge
improvement
Material cost 100-500 k
EUR
There could be new
jobs in the R&D sector
(private company or
research organisations)
unless developed by
the existing research
staff
The impact of each measure is outlined below.
PNT#2a: Mandatory label on paint lifetime and plastic content
The measure can be associated with a product authorization to enter the EU market, or it can be just
left as a labelling requirement (see measure PNT#2b).
The overall economic impact is related to the standardization of the assessment methodology of paint
lifetime and plastic content. The R&D departments of the paint producers should already be aware
of the lifetime of their product in various conditions. This is the kind of information generally used
for issuing a warranty of the paint product when requested by the client, which guarantees, for
example, that the paint will not blister or peel from properly prepared and primed surfaces and will
not wear down or weather to expose the previously painted surface. See, for example
https://www.dunnedwards.com/products/lifetime-warranty/. Seemly, as the paint producers know the
composition of their paint formulations, they should be able to report the plastic content once the
definition of plastic in paint is released.
The real difficulty and potential cost are associated with the necessity of having standard protocols
for the lifetime assessment and a unique/unambiguous definition of plastic content in paint so that
different products can be compared to each other. This could entail some scientific research costs but
mostly should be administrative.
The labels though, should be changed to comply with the new regulation. The labelling could be
managed as part of the continuous ongoing redesign from product innovation so the costs could be
reduced.
To provide some indications, we refer to Assessment and Review of Directive 2004/42/EC, Annex 26,
an estimate of re-labelling cost for decorative paint done by CEPE, which estimates a total re-
labelling cost for decorative paints to be 740 million euros, considering 4000 companies in the EU
with 1,000-2,000 sku’s (Stock keeping units) each.
This estimate could be lowered if the compliance deadline to the measure would be set within a
couple of years (and not immediate), because the relabelling would be facilitated by the normal life
cycle of the products.
The amending of the proper legislation and the cost for monitoring compliance and reporting should
be minor.
What would be the costs of the measure?
• Cost of developing the standard methodology for assessment of paint plastic content
• Cost for paint producers to change the design of their label
417
What would be the benefits of the measure?
The emission pathways and sources that are indirectly targeted by this measure are:
1) paint used on the architectural exterior (by substitution with mineral-based paint),
2) paint used on the architectural interior (by substitution with less plastic-intense paint).
3) improper disposal of unused paint (for non-industrial applications, i.e., marine leisure DIY
and architectural),
Point 1)
Currently, mineral paint covers 10% of the architectural paint market in Germany and Austria. In
comparison, in all other European countries, the share is likely to be between 0.5 and 2% (from
communication with a producer of silicate-based paints).
Mineral paint is used on the mineral substrate but not on wood and metal since it breaks under tensile
forces.
We currently estimate that there is 171 kt of plastic used in architecture paint applied on the exterior
concrete or mineral substrate; of these, 49 kt are leaked to the environment.
According to a mineral-based paint producer, the main hurdles to further market penetration are
reputation (silicate-based paint used to be a two-component system that was difficult to apply), and
price, as they are on average 10-20% more expensive than organic polymer-based paints.
In order to understand how plastic content labelling will impact consumer behaviour, we can look at
the packaging and textiles sectors.
70% of European consumers are actively taking steps to reduce their use of plastic packaging330331
Plastic packaging consumption in EU-28 + NO/CH was 20.3 Mt in 2017 (PlasticsEurope, 2018),
20.4 Mt in 2018 (PlasticsEurope, 2019), and 20.1 Mt in 2019 (PlasticsEurope, 2020). Therefore,
there has been a decrease in plastic packaging consumption of 1% in 2018-2019. Packaging paper &
board consumption in Europe also decreased by 0.4% in 2018-2019, from 41.51 Mt in 2018 to 41.35
Mt in 2019 (CEPI, 2020)
In the textile sector, the use of fossil-based fibres has increased in recent years, while the use of cotton
has remained constant332
. In the textile sector, the use of fossil-based fibres has increased in recent
years, while the use of cotton has remained constant.
Based on these figures from the packaging and textiles industry, it is unlikely that more than 2% of
consumers will switch to mineral-based paint within a year, based solely on the plastic content
information. Mineral-based paints have almost twice the lifetime of regular paint, which should also
affect consumer behaviour, but we cannot assess the impact on sales. Overall, given the fact that the
current market share of mineral-based paint is 0.5-10% in Europe, we could estimate that 0% to 3%
of consumers would switch from plastic-based to mineral-based paint based on labelling information
only in a year.
330
https://www.twosides.info/documents/research/2020/packaging/European-Packaging-Preferences-2020_EN.pdf
331
https://www.twosides.info/documents/research/2020/packaging/European-Packaging-Preferences-2020_EN.pdf
332
https://textileexchange.org/wp-content/uploads/2021/08/Textile-Exchange_Preferred-Fiber-and-Materials-Market-
Report_2021.pdf
418
In conclusion, the plastic reduction demand for exterior paint on the mineral substrate could be a
maximum of 5.1 kt in a year (3% of 171 kt), and the related plastic pollution would decrease by 1.5
kt (3% of 49 kt). Over the years, given the longer lifetime, one should also see a reduction in paint
demand as a whole, and it would be more or less of the same order of magnitude.
Point 2)
Currently, we assume 719 kt of plastic is used every year for architectural interior paint. Of these, 42
kt are released to the environment in the form of microplastic
For interior paint, we have not investigated specific alternatives to standard polymer-containing
paints, but it should be possible to decrease the paint lifetime by decreasing the plastic content, and
this should not affect the paint demand since interior paint in currently repainted instead for aesthetic
reasons.
If we assume that products are available that have half of the plastic content and that 0-3% of the
consumer would prefer them to the current formulations (based on assessment at point 1), we obtain
a maximum leakage reduction of 0.6 kt.
The benefits assessed above are minimal, as they lead, at most, to a 3% of the Architectural paint
microplastic leakage (yearly).
Point 3)
The amount of plastic contained in unused paint from the architectural sector is 58.1 kt, while from
marine leisure DIY, it is around 3 kt. In the baseline assessment, we assumed that unused paint is
never improperly disposed of in Europe. However, a stakeholder from the architectural paint industry
considered that disposal of unused architectural paint in the drainage system has a high probability
for DIYers and a medium probability for professionals.
We make the following assumptions:
• If the plastic content label is sufficiently visible, 50% to 90% of the consumers will become
aware of the fact that there is plastic in paint
• 90%-100% of the consumers that are aware that paint contains plastic will not improperly
dispose of it. In fact, at the European level, the littering rate of disposable plastic items is
around 7%333
, while the littering rate of multi-use items is much lower <0.01%.
As a result, between 45% and 90% of the unused plastic in the paint targeted by the measure, i.e.,
61kt, would not be improperly disposed of, for a range of 27 – 55 kt. At the moment, though, we
consider in our baseline assessment that this paint is already properly disposed of.
333
Timothy Elliott, R. B., Chiarina, D., Laurence, E., Chris, S., Ayesha, B., Mathilde, B., & Hilton, M. (2018).
Assessment of measures to reduce marine litter from single-use plastics. ICF Consulting Services Limited and
Eunomia, M. European Commission, Brussels
419
Economic Impact
Table 56: Economic impact of the measure
Impact category Qualitative
scoring of
impact
Affected stakeholders Description of impact
Operating costs and
conduct of business
- Paint producer Cost of testing the products with the
standard methodology.
Cost relative to the design and
implementation of new label
Administrative
burdens on businesses
- Paint
producers/importer
Some costs might be due to changes in the
internal policy of the companies due to
the necessity to be compliant with the
labelling regulations.
Operation / conduct of
SMEs
- Small paint producers Performing the assessment with the
standardized methodology might be an
economic burden for small producers
who might not have adequate equipment.
Providing open access or special
agreements with testing facilities at the
EU (or member state) level might be a
valuable strategy to ensure compliance
with the rules.
Functioning of the
internal market and
competition
+ Paint producers/
importers
The measure will probably favour the
paint producers and importers who
provide more environmentally friendly
products.
Public authorities:
Change in costs to
authorities for
administrative,
compliance and
enforcement activities
- Member State
competent authorities
or European
Commission
Cost of amending the existing regulation
or creating a new one
Monitoring and reporting: at this stage is
unclear whether the monitoring will be
run at the EU or Member State level.
Innovation and
research
+ Paint maintenance
professionals
The measure will be an incentive to
develop more environmentally friendly
paint products.
Third countries and
international relations
- Paint producers in
third countries
Will be affected as only the paints which
are compliant with the EU regulation on
the labels can enter the market.
Consumers and
household
+ Paint maintenance
professionals and
DIYers
The potential impacts on paint prices are
uncertain, but it is possible that the
economic burden of product testing at the
producer’s level might be reflected in the
cost of the paint itself.
420
Environmental Impact
Without enforcement (thresholds and fee system) is challenging for the measure to have a substantial
environmental benefit. But in the best-case scenario, the label would raise the knowledge of paint-
related plastic pollution (mostly for the DYI sector), and it would encourage the consumers to use
the best paint system for their needs maximising the lifetime minimizing plastic content when
possible.
There could be an increase in CO2 emissions if the reduction of plastic content happens through
substitution with material with a higher CO2 footprint. Similarly, we cannot exclude that the
substituting materials will be more toxic.
Finally, there could be an increase in waste generation due to the testing needed to assess the paint
properties.
Social impact
No social impact is expected.
PNT#3a: Promote mineral paint in the architectural sector
This measure can be applied with a voluntary scheme such as ECOLABEL or GPP.
What would be the costs of the measure?
• The costs related to the amendment of the ECOLABEL regulation or the GPP
• The costs for the producers of mineral paint to apply for the label and include it on their
product
What would be the benefits of the measure?
In measure PNT#2a an estimate is proposed to assess the impact of label showing plastic content of
paint on the sales of mineral based paint, which has polymeric content below 5%. This estimate is
based on consumer purchasing trends in the past years of plastic products in favour of an alternative
material. We cannot use the same estimate here as the ECOLABEL would not display information
regarding plastic content, furthermore the ECOLABEL is a voluntary label.
Overall, we envision minimal impact as most polymer-based producers will not switch to mineral-
based products through a voluntary scheme.
Economic Impact
Table 57: Economic impact of the measure
Impact category Qualitativ
e scoring
of impact
Affected
stakeholders
Description of impact
Operating costs and
conduct of business
- Mineral paint
producer
Cost of inserting the new label on the paint
can
Public authorities: Change
in costs to authorities for
administrative, compliance
and enforcement activities
- European
Commission
Cost of changing the ecolabel Regulation
421
Environmental Impact
No impact expected.
Social impact
No impact foreseen.
PNT#5: Good practices for paint application in all sectors
This measure is not dependent upon any measure. This measure is voluntary.
What would be the costs of the measure?
The costs of the measure are:
1. The cost of researching good practices for the various paint sectors is estimated to be around
EUR 100k - 500k, based on the level of ambition.
2. The cost for the paint professionals and relevant stakeholders of implementing those good
practices (e.g., by purchasing a different type of paint removal machinery, etc.)
The latter depends on changes made, but as it is a voluntary measure, we assume that a professional
will undertake it only if it leads to an economic advantage (e.g., an increase in business volume due
to stronger appeal for costumer of less polluting techniques). So the actual economic impact is
expected to be minimal.
For the marine sector, in particular, good practices for ship maintenance could be more expensive in
terms of technology (e.g., water treatment to capture microplastic, robotic vacuum technology for
paint removal), the time required to adopt them (e.g., vacuum cleaning of the drydock before re-
floating is more time consuming than just re-floating without cleaning), and training of the paint
maintenance professionals. The costs would ultimately be bear by the ship owners and by the paint
maintenance professionals.
In the last 10 years, only 1-3% of the commercial world fleet was built in Europe, but 36% of the
world fleet belongs to Europe (UNCSTAD). If ship-building capacity is taken as a proxy for ship-
maintenance capacity, the implication is that European commercial ships undergo maintenance
overwhelmingly outside of Europe. Conversation with stakeholders from the shipping sector concurs
with this assessment.
Estimating the monetary cost of this measure is very difficult as it depends entirely on the actual list
of good practices – and relative technologies – that will be set up, but to make an estimation one can
say that the main cost that overshadows all other costs will be that of upgrading the current
technologies in shipyards in order to capture microplastic releases during paint removal (the last two
voice costs). There are two options:
1. Blasting is done with vacuuming technologies that prevent paint emissions
2. Blasting is done with wet technologies, without dust formation, and then membranes are used to
filter the paint residues from the water
422
Option 1.
There are already technologies that do vacuum blasting, and the cost of the technology itself is
competitive. The main challenge vacuum technologies are facing, especially for dry-docking, is
productivity, i.e. how many square meters per hour they clean from paint residues. According to
exchanges with stakeholders that develop vacuuming technology, the best way to have high
productivity is using a robotic solution, which currently is able to clean 10 m2
/h (but could go up to
30-40 m2
/h).
On the other hand, hydro blasting technologies (no capturing) can clean up to 300 m2
/h 334
In the table below, we summarise the key figures impacting the costs of drydocking.
Table 58: Factors impacting the costs of drydocking.
The part of the boat that needs more intense cleaning and repainting is the one below the waterline.
The below-water surface area can vary from 10,000 m2
for a Panamax, to 60,000 m2
, for an Ultra
Large Crude Carrier.
This means that with one hydro-blasting machine, the ship can be cleaned in 33-200 h, or 3.3-20
days, assuming a 10h working schedule. Drydocking usually lasts 10-20 days335
, meaning that paint
maintenance lasts all throughout the drydocking period. Since the current vacuuming technologies
are 30 times slower, it would take them 1 000-6 000 h to clean a ship. If this was done by a single
machine, on a 10h shift, the drydocking would last 100-600 days. Data collected from one of the
biggest shipyards in the Persian Gulf show that dry-docking costs varied from 30 000-60 000 $/day
in 2008-. Given the high daily drydocking cost, it is imperative in order for paint vacuum capturing
technologies to be competitive, to use more machines in parallel. The main cost would be renting
additional machines, at a cost of EUR 100/day each. Considering the scenario that 30 machines would
be needed (to compensate for the 30x lower productivity), the cost increase would be EUR 3 000/day.
Since maintenance would last 3.3-20 days336
, the overall cost increase per drydocking period would
be EUR 10 000 – 60 000. This excludes the cost of having a person operating the machine; given that
the technology is robotic, it is not clear what the impact would be. On the other hand, we are assuming
a working schedule of 10 h a day, which with robotic technology could (is) probably higher, reducing
the number of days needed for the rental.
334
(http://www.gimsid.ro/aplicatii/Industria%20navala/Hammelmann/Shipcleaning.pdf).
335
Apostolidis, A., Kokarakis, J., & Merikas, A. (2012). Modeling the Dry-Docking Cost-The Case of Tankers. Journal
of Ship Production & Design, 28(3)
336
2012 (Apostolidis, A., Kokarakis, J., & Merikas, A. (2012). Modeling the Dry-Docking Cost-The Case of Tankers.
Journal of Ship Production & Design, 28(3).)
423
Considering that there are 1.8 million commercial ships (UNCTAD, 2017), that 36% belong to EU-
27 countries and that 3% undergo maintenance in EU-27 every 4 years, there would be around 5000
ships undergoing maintenance in the EU every year.
The total costs would be at least 50-300 million EUR/year, with the current productivity.
Option 2
If hydro-blasting is used instead, then the water should be filtered from the paint residuals before re-
emitting it to surface water. Sending to a wastewater treatment plant should be discouraged since the
paint would end up in oil.
Ultrafiltration units exist that filter particles in the range of 0.01-0.1 microns. Their operating costs
is 0.235-0.338 $ per m3
of water filtered337
.
Ultra-high water jetting technologies that can operate at around 300 m2
/h use 85 l/min of water
338
Therefore, filtering the water emitted in one hour would cost from 1,200-1,700 $/h. Since it takes
33-200 h to clean the bottom of a ship during dry-docking with this technology, the overall operating
cost would be 40-340 k EUR/ship.
Using the same estimate of the number of ships maintained in EU-27, the total operating costs would
be between 200-1 700 million EUR/year, depending on the boat size and the number of boats.
A further cost would be the creation of a European certification for those paint professionals that
follows the guidelines. This cost is expected to be a bit minimal with respect to the rest.
What would be the benefits of the measure?
The benefits in terms of microplastic pollution reduction are potentially high, as the good practices
would cover losses at both applications, removal (maintenance) level, and surface preparation, which
impacts wear & tear. Nevertheless, since this is a voluntary measure, the expected compliance is low.
For the marine sector, there are 40 kt/year of microplastic emissions to ocean and waterways due to
maintenance of EU commercial vessels. Since only 1-3% of the maintenance takes place in EU-27,
the measure could potentially tackle 0.4 – 1.2 kt of micro-plastic emissions. Nevertheless, we
estimate that applying this measure only at EU-27 level (with either a voluntary or a mandatory
approach) will not lead to any change in the status quo, as commercial ship will choose to dock
outside of the EU where maintenance will be cheaper.
337
Drouiche, M., Lounici, H., Belhocine, D., Grib, H., Piron, D., & Mameri, N. (2001). Economic study of the treatment
of surface water by small ultrafiltration units. Water SA, 27(2), 199-204
Yoo, S. S. (2018). Operating cost reduction of in-line coagulation/ultrafiltration membrane process attributed to
coagulation condition optimization for irreversible fouling control. Water, 10(8), 1076.).
338
Shipcleaning.pdf (gimsid.ro)
424
Economic Impact
Table 59: Economic impact of the measure
Impact category Qualitative scoring of
impact
Affected stakeholders Description of impact
Public authorities:
Change in costs to the
Commission
- European
Commission / and EU
institutions
Cost for the European
Commission of defining the
good practices.
Environmental Impact
The implementation of good practices would also reduce the emission of biocides contained in
antifouling paint.
On the other hand, the use of more advanced technologies or better water management filters and
systems could lead to an increase in CO2 emissions.
Social impact
No social impact is foreseen by this measure.
PNT#4 Deposit-return scheme for paint containers
What would be the costs of the measure?
• Cost for paint producers and importers who should pay the development and maintenance of
the system
• Cost of reporting paint quantities put on the market and collected
• Cost of funding research and study to assess improper disposal of paint and related
microplastic pollution
• Cost of setting up improved collection schemes such as DRS scheme (e.g., cost of economic
analysis to set up the financial scheme behind the EPR scheme - financial incentives, how
much is the fee, how much is the reward, how much are the running costs) or door-to-door
collection.
• Running cost of the organization managing the collection scheme: cost for establishing
collection systems; collection and transport, administrative costs, public communication,
and awareness-raising on waste prevention and collection, appropriate surveillance of the
system
• Cost of promoting recycling of unused paint
Unused paint is often considered as special/hazardous waste and like waste oil, chemicals and spent
batteries; for example, in several countries (e.g. Belgium and Denmark), it is successfully being
collected with the goal of proper disposal or recycling 339
The overall cost of running EPR scheme for
unused paint could be estimated, making a parallel with waste oil. The two products are similar at
339
Formation Gestionnaires de déchets, module 2b, Déchets dangereux, Alain Vassart, Mike Van Acoeyen (Arcadis),
Environment Brussel and GOOD PRACTICE ODENSE: Hazardous Waste Collection October 2014,
425
several levels: hazardous waste, and liquid, used both in professional and household settings, hold
some intrinsic value but might need to be treated to be used again.
For waste oils, EPR schemes already exist for several European countries340
, from their review we
can estimate that the cost of measure PNT#4 in EU will be between 54 million and 1 billion euros
per year
To that, the administrative costs, the costs to perform for economic analysis and to develop the
framework of the EPR itself have to be added. Drawing a parallel with the costs estimated for an EPR
scheme for the Pharmaceutical and Cosmetic Industry in Europe, we can assume they will be in the
order of 16 million euros at the EU level.
What would be the benefits of the measure?
It will be possible to compute the benefits of the measures solely in terms of microplastic pollution
reduction once phase one is completed and a better understanding exists especially on the improper
disposal of unused paint. Then depending on the effectiveness of the measures put in place (e.g.
citizens awareness campaign, collection scheme), it will be possible to assess the reduction in
microplastic pollution341
.
Based on the current estimates, the measure would target around 85 kt of plastic from unused paint
in EU-27.
Even if the fee is applied to the plastic content, it is expected that this will not drive change in the
product design, as the fee would be too low to drive change.
Economic Impact
Table 60: Economic impact of the measure
Impact category Qualitative
scoring of
impact
Affected stakeholders Description of impact
Operating costs and
conduct of business
- Paint
producer/importers
Pay the fee to the PRO (running
economic impact) to finance
knowledge creation, as well as the
collection and management of unused
paint and the reduction of improperly
disposed paint
Administrative burdens
on businesses
-/0 Paint
producers/importers
Cost of reporting the plastic content
input on the market.
340
Development of Guidance on Extended Producer Responsibility (EPR)”, 2014 by BIO by Deloitte, in collaboration
with Arcadis, Ecologic, Institute for European Environmental Policy (IEEP), Umweltbundesamt (UBA).
https://www2.deloitte.com/content/dam/Deloitte/fr/Documents/sustainability-services/deloitte_sustainability-les-
filieres-a-responsabilite-elargie-du-producteur-en-europe_dec-15.pdf
341
https://www.akzonobel.com/en/media/latest-news---media-releases-/akzonobel-launches-recycled-paint-to-help-
close-loop-on-waste
426
Impact category Qualitative
scoring of
impact
Affected stakeholders Description of impact
Functioning of the
internal market and
competition
- Paint producers/
importers
The paint producers/importers that
input more plastic on the market are
penalized (pay more through the fee
payment scheme).
Public authorities:
Change in costs to
authorities for
administrative,
compliance and
enforcement activities
- Member State
competent authorities or
European Commission
Running cost of the EPR operator
(including monitoring and reporting).
Public authorities:
Change in costs to the
Commission
- European Commission /
and EU institutions
This measure will only require
resources in the phase of introducing
the measure.
Third countries and
international relations
- Paint producers in third
countries
Will be indirectly affected because
importers have to pay based on how
much plastic they import.
Consumers and
household
0 Paint maintenance
professionals and
DIYers
The potential impacts on paint prices
are uncertain but are expected to be
limited.
Environmental Impact
If a deposit-return scheme is put in place, there could be a CO2 impact related to the transport of the
recovered paint, but it could be minimised by matching purchases of new paint with taking back of
removed paint.
A potential positive environmental impact could be the development of recycling technologies for
unused paint and an increase in circularity.
Social impact
There are no social impacts foreseen for this measure.
PNT#2b: Threshold on paint lifetime and plastic content for paints
This measure depends on measure PNT#2a to be implemented first.
Product authorisation in the European market depends on compliance with thresholds to regulate an
upper bound for plastic content and a lower bound for paint lifetime.
Once it becomes clear, by paint sector (marine, architectural, road markings, etc.) and its sub-
categories (e.g., architectural interior, exterior-concrete, exterior-wood), what are the ranges of
plastic content (%) and lifetime for the different paint formulations available for the market,
427
regulators can decide to ban from the market products that have a high plastic content and/or a
lifetime much shorter than that of the painted object.
What would be the costs of the measure?
Additional cost with respect to measure PNT#2a:
• Cost of defining thresholds based on paint properties for entering EU markets and creating
appropriate legislation
• Cost of defining and applying a fee system for non-compliant products
Besides the costs which are common to both the application framework of the measure, we can
indicate the cost of defining thresholds as the one of a highly qualified consulting company: 100-500
k EUR, one time.
Cost for paint producers of adapting the paint formulation to match the new requirements: 500 k
EUR per paint formulation342
or 0.4% of sales value343
, i.e. EUR 500 million.
What would be the benefits of the measure?
The benefits of the measures will depend on which types of paint formulations are currently available
on the market.
Road markings - case study
For example, in the case of road markings, there are currently 4 main paints formulations: solvent-
based (17.3% plastic, 1-2 years lifetime), water-based (16.6% plastic, 1-2 years lifetime),
thermoplastics (16% plastics, 3-5 years lifetime) and cold plastics (35% plastic, 3-5 years lifetime).
Here, the plastic contents are taken from the Eunomia report Hann, et al. (2018), while the lifetime
are taken from Barbara, K. R., & Nicholas, D. O. D. D. (2018). Development of the EU Green Public
Procurement (GPP) Criteria for Paints, Varnishes and Road Markings. Technical Report with final
criteria. If these values were to be confirmed, once the standardised methodology is established, the
preferred road marking type would be thermoplastics, as it has the lowest plastic content and the
longest lifetime.
Currently, given the market distribution of the different road markings formulations (Hann et al.
2018), the polymer content in (dry) road markings paint is 16.6%, and the lifetime – weighted by the
plastic content – is 3.3 years. If only thermoplastics were used, the polymer content would be 16%
and the lifetime 4 years.
The microplastic leakage reduction can be approximated as: Leakage reduction = leakageold *
reduction rate,
Reduction rate = (1 - repaint%) *( 1 – plasticnew / plasticold )
+ repaint% * ( 1 - plasticnew / plasticold * lifetimeold / lifetimenew )
In this case: leakageold = 20 kt, plasticnew = 16%, plastic%old = 16.6%, lifetimeold = 3.3 years,
lifetimenew = 4 years. The “repaint %” indicates how much of the paint put on the market is used for
342
https://circabc.europa.eu/sd/a/2d163ccc-f496-44af-9b6a-8fd2006a4d5e/Final
343
https://ec.europa.eu/environment/archives/air/pdf/paint_solvents/decopaint.pdf),
428
re-paint jobs. We don’t currently have this quantity, but we could estimate it to be at least 50% in
Europe, given the road lifetime versus the paint lifetime.
The leakage reduction in this case would be 20 kt * 12% = 2.4 kt.
Architectural exterior – case study
If we apply the equation above to a scenario in which all exterior architectural paint is replaced with
silicate-based paint, we will obtain:
Leakageold = 49 kt, plasticnew = 5%, plastic%old = 20%, lifetimeold = 10 years, lifetimenew = 20 years,
(repaint % = 50%)
Leakage reduction = 49 kt * 81% = 39 kt
Total estimate
Let us assume that through legislation, it would be possible, every few years, to decrease the plastic
content by 5%, and increase the lifetime by 5%, on all paint formulations besides antifouling paint,
which has been excluded from the measure. In this case, the reduction rate could be:
Reduction rate = (1 - repaint %) * (1 – 0.95) + repaint % * (1 – 0.95 * 1/1.05)
Let us assume the repaint share varies between 0% and 100%, then the range in reduction rate would
be between 5% and 10% every year.
Currently, the total microplastic leakage from paint is estimated at 482 kt, but 50kt comes from
antifouling paints, and another 154 kt comes from other marine paint applied on European ships
outside the EU. Therefore, this measure could target 278 kt of microplastic leakage by reducing it by
5% to 10%. The corresponding leakage reduction would be 14–26 kt. Every year, the label
requirements are made more stringent by 5%, and the leakage would be further reduced by 5-10%.
According to CEPE, it took 4 years to develop a new paint formulation in 2009 344
; therefore, we
could assume thresholds to become more stringent every 4 years.
Economic Impact
The specific costs for measure #2b are the ones of #2a with the addition of the following:
Table 61: Economic impact of the measure
Impact category Qualitative
scoring of
impact
Affected
stakeholders
Description of impact
Technological
development / digital
economy
-- Paint producers The threshold imposed for market
authorisation will require paint companies
to adapt their production lines.
344
European Commission Service Contract N°070307/2007/483710/Mar/C3 Implementation And Review Of Directive
2004/42/Ec (European Directive Limiting The Voc Content In Certain Products – Current Scope: Decorative Paints
And Varnishes, Vehicle Refinishing Products) Final Report
http://ec.europa.eu/environment/air/pollutants/pdf/paints_report.pdf
429
Environmental Impact
It is possible that the measure will have adverse environmental impacts if, for example, a paint has a
longer lifetime, a smaller plastic content, but higher toxicity or higher CO2 impact.
The enforcement provided by the thresholds and fee system will most definitely have an
environmental benefit in terms of microplastic pollution reduction.
But, if the thresholds on maximum plastic content were imposed, the compositions of the paints
would need to change to provide the same (or improved) performances, by definition. Therefore,
since we are talking about new formulations that may not exist at the moment, there is no way to
predict how those would look like in terms of environmental impact (one possibility out of many:
lower plastic content, same lifetime but more toxic degradation products once released in the
environment).
We state here that a different (not quantifiable) environmental impact is a possibility, such as
increased toxicity.
There could be negative CO2 impacts and an increase in waste generation due to the testing needed
for the assessment of the paint properties.
Social impact
No social impact is expected.
PNT#3b: Restrict polymer-based paints in the architectural sector
What would be the costs of the measure?
• Administrative and legal costs associated with the creation of the limitation regulation or ban
• Costs for the paint producers to produce more mineral paint (investments and shift in
production volumes)
• Increased costs for asset owners or managers (the ones that buy the paint products) because
the mineral paint is more expensive than the dispersive one (based on organic polymer
binders)
• Cost of a monitoring and reporting protocol to verify compliance with the new regulations
• Costs for asset owners in the form of a fee if found non-compliant
From discussions with mineral paint producers, it appears that silicate-based paint (which is by far
the kind most available on the market) is 10-20% more expensive than dispersion paints. Their cost
definitely influences their usage, and it will represent a burden on the consumers. Nevertheless, the
lifetime is significantly elongated with respect to dispersion paint (almost twice as much). The life-
cycle cost seems thus to be lower for silicate-based than polymer-based paints.
Another cost to consider is the market development for such paints. In Europe, the market share of
mineral paint appears to be, on average, between 0.5 - 2% (both and value), with the highest value in
Germany at 10%.
430
What would be the benefits of the measure?
The microplastic leakage reduction can be approximated as:
Leakage reduction = leakageold * reduction rate,
Reduction rate = (1 - repaint%) *( 1 – plasticnew / plasticold )
+ repaint% * ( 1 - plasticnew / plasticold * lifetimeold / lifetimenew )
In this case: leakageold = 49 kt, plasticnew = 5%, plastic%old = 20%, lifetimeold = 10 yrs, lifetimenew = 20
years, (repaint % = 50%). The “repaint %” indicates how much of the paint put on the market is used
for re-paint jobs. We don’t currently have this quantity, but we could estimate it to be at least 50%.
Therefore, the leakage reduction of exterior architectural paint (excl. wood and metal substrates)
would be:
Leakage reduction = 49 kt * 81% = 39 kt
If the measure was to be extended to interior paint as well, we could compute the leakage reduction
using the following parameters:
Leakage reduction = 49 kt * 81% = 39 kt
Leakageold = 42 kt, plasticnew = 5%, plastic%old = 20%
We remove from the equation the part related to the increased lifetime because repaint practices on
interior paint are not due to paint system failure.
Reduction rate = (1 – 5%/ 20%) = 75%
Leakage reduction = 32 kt
Total leakage reduction = 71 kt
Economic Impact
Table 62: Economic impact of the measure
Impact category Qualitative
scoring of
impact
Affected
stakeholders
Description of impact
Operating costs and
conduct of business
- Paint producer Cost related to product design and
investments for improving or adding
production of mineral paint to their list
of products.
Functioning of the internal
market and competition
+ Paint producers/
importers
The paint producers/importers that
already produce mineral paint will
have an economic advantage.
431
Public authorities: Change
in costs to authorities for
administrative,
compliance and
enforcement activities
- Member State
competent
authorities or
European
Commission
Cost of the creation of the
regulation/ban.
Technological
development / digital
economy
-- Paint producers The ban on mineral paint will require
paint companies to adapt their
production lines.
Innovation and research + Paint maintenance
professionals
The measure will be an incentive to
develop and use mineral paint in place
of the more plastic intensive dispersion
paint.
Consumers and household 0 Paint maintenance
professionals and
DIYers
There will be potential impacts on
paint prices due to the higher cost of
the mineral paint, but they are most
likely balanced by the longer lifetime
of the paint layer itself.
Environmental Impact
This measure will most definitely have an environmental benefit in terms of microplastic pollution
reduction as it promotes the use of less plastic-intensive paint for one of the biggest sectors in terms
of paint consumption, the architectural one. The environmental footprint of shifting the production
from polymer-based paint should be assessed through a proper LCA (Life Cycle Assessment).
Social impact
Product design will also be incentivised. This might create new job positions in R&D, although this
impact is estimated to be quite small.
PNT#1: Standardised methodology of paint lifetime
This measure was developed in response to the knowledge gaps we identified around the precise
measurement of microplastic emissions. Developing a standardised measurement methodology will
enable the development of reduction-specific measures at a later stage.
This measure does not depend upon any other measure but it is necessary for the application of the
measures PNT#2a and PNT#2b.
What would be the costs of the measure?
Cost of a scientific task force to define paint lifetime and how to measure it in a consistent way for
various types of applications
The cost then should be relative to the hiring of a scientific committee and/or consultancy firm to
define the guidelines for the standard methodology of testing. Considering a highly qualified
consultancy firm, this cost could be EUR 100k-500k. Once the standard is developed, there will be
the additional cost of testing the materials (only once per material). This cost was evaluated to range
between EUR 10 000 and 20 000 by expert judgement.
432
What would be the benefits of the measure?
This measure will benefit all other measures on paints as the release of microplastics during the life
cycle of paints is a critical knowledge gap. The indirect benefits will also include the awareness-
raising of the paints value chain actors. If an EPR system is implemented, the eco-fee can also be
modulated according to the volume of microplastic release and respective actors' contributions. It is
already a necessary step to measure any reduction measure's success rate. This measure is essential
to the implementation of measure PNT#2.
Economic Impact
Table 63: Impact of the measure
Impact category Qualitative
scoring of
impact
Affected stakeholders Description of impact
Operating costs and conduct of
business
0 Paint producer No cost
Administrative burdens on
businesses
Paint
producers/importers
No cost
Operation / conduct of SMEs 0 Paint producers No cost
Functioning of the internal
market and competition
0 Paint producers/
importers
No cost
Public authorities: Change in
costs to authorities for
administrative, compliance and
enforcement activities
- European Commission Cost related to the creation
of the scientific task force
and remunerating their
job.
Public authorities: Change in
costs to the Commission
0 European Commission /
and EU institutions
No cost
Innovation and research + Paint maintenance
professionals
No cost
Technological development /
digital economy
0 No cost
Macroeconomic environment 0 No cost
Third countries and international
relations
+ Paint producers in third
countries
No cost
Consumers and household 0 Paint maintenance
professionals & DIYers
No cost
Environmental Impact
Mildly positive indirect environmental impact is foreseen due to the fact that the discussion around
the plastic definition can help clarify important points for other scientific studies and policy creation
on the microplastic pollution issue as well.
Social impact
No social impact is foreseen.
433
7.5 Impact of measures for detergent capsules
Table below shows the comparison between all measures initially evaluated to reduce microplastic
emissions from capsules.
Table 64: Comparison of measures for capsules
Measure Estimated
reduction
potential
Estimated
Cost-
effectiveness
(EUR/tons
reduced/year)
Other
environmental
impacts
Other economic
impacts
Social
impacts
% Ktons/
year
CAP#2: Apply
current
biodegradability
standards to
detergent capsules
Uncertain,
with
possibly
high
potential
5 060
(4 140
–
5 980)
2 207
(1 739-2 676)
Full
biodegradation
is ensured and
reduction of
microplastic
pollution
Negative impact on
industry, depending on
the applicable standard
(Costs associated with
the effort to redesign
their products to
comply with new
standards)
CAP#1:
Standardised
methodology to
quantify
microplastics
released from
detergent
capsules
CAP#3: Redesign
biodegradability
standards for
detergent
capsules
Table below shows the comparison of the impacts of the measures assessed to reduce microplastic
emissions from capsules.
434
Table 65: Summary of impacts for measures for capsules
Policy Option Environmental impact Economic Impact Social impact
CAP#2: Apply current
biodegradability
standards to detergent
capsules
Reduction of plastic
emissions from water-
soluble plastics are
difficult to estimate, but
possible high potential
Estimated increased
production cost of EUR
7.2 - 16 million/year
(initial assessment)
CAP#1: Standardised
methodology to
quantify microplastics
released from
detergent capsules
No emission reduction
per se but helpful in
other measures and
knowledge
improvement
EUR 100k-500k There could be new jobs
in the R&D sector
(private company or
research organisations)
unless developed by the
existing research staff
CAP#3: Redesign
biodegradability
standards for detergent
capsules
Reduction of plastic
emissions from water-
soluble plastics
Standard development
costs of EUR 500 000 -
1 million, and increased
production cost (likely
higher than CAP#2).
Other impacts not
assessed
Possible jobs in the R&D
sector. Other impacts not
assessed
The impact of each measure is outlined below.
CAP#2: Apply current biodegradability standards to detergent capsules
This measure will enable ultimate biodegradation of PVOH and related mixtures during and after
wastewater treatments.
What would be the costs of the measure?
Applying the measure may come at a certain cost as water-soluble plastic producers will have to
adapt some of their products to the biodegradation standard. The exact costs are difficult to assess,
because it depends on the exact application of the standard. The standard could for example be
applied according to its adaptation for polymers (i.e. without the application of the 10-day window).
Some of the additional costs to redesign their products could be estimated to be around 20% of the
actual prices of detergent capsules based on technical discussions with some stakeholders (AISE
members).
Knowing that the actual price of water-soluble plastics derived from PVOH for detergent capsules is
around 2-4 EUR/kg and the annual volume of PVOH put on the market is at the low end 18 000 tons,
thus the total cost to redesign their products would be EUR 7.2 million, or at the high end, the volume
being 20 000 tons, the total cost would be EUR 16 million in order to comply with this measure. It
might be expected that this cost would decrease due to innovation.
435
Therefore: 2EUR/kg * 18 000 tons * 20% = 7 200 000 EUR
Emission reduction potential: 4 140 – 5 980 tons
Cost efficiency, low end: 7 200 000 EUR / 4 140 tons= 1739 EUR per tonne
Cost efficiency high end: 16 000 000 EUR / 5 980 tons = 2676 EUR per tonne
This is thus only an initial assessment. As mentioned above, economic costs are difficult to assess
and depend on the exact application of the standard.
What would be the benefits of the measure?
As soon as this measure is enforced, PVOH pollution is expected to reduce. While the exact extend
of the reduction of microplastic releases is unknown, the maximum potential is full biodegradation,
this would then result in an emission reduction potential of 4140 – 5980 tons/year.
Economic impacts
Table 66: Economic impact of the measure CAP#2
Impact category Qualitative
scoring of
impact
Affected stakeholders Description of impact
Operating costs and conduct of
business
- Water-soluble plastic
producers
EUR 7.2 – 16 million /
year
(initial assessment)
Public authorities: Change in
costs to authorities for
administrative, compliance and
enforcement activities
- Member State
competent authorities
or European
Commission
Costs associated with the
effort to implement these
standards at the national
level
Further analysis is also needed to estimated possible other economic impacts.
Environmental impacts
This measure is expected to have a positive impact on the environment in terms of the reduction of
microplastic releases from water-soluble plastics. Adopting good practices for water-soluble plastics
can give a real chance to properly manage the water-soluble plastics during wastewater treatment.
Social impacts
There are no social impacts foreseen.
CAP#1: Standardised methodology to quantify microplastics releases from detergent capsules
This measure was developed in response to the knowledge gaps that were identified around the
precise level of microplastic emissions. Developing a standardised measurement methodology will
enable the development of reduction-specific measures at a later stage.
This measure aims to increase the knowledge about PVOH’s pathway to the different environmental
compartments it may reach after being released from households. Currently, there is a lack of
understanding regarding the compartment (sludge or water bodies) in which PVOH finally ends up
and the repartitioning between them. This is an issue specifically when it comes to testing for the
436
biodegradability of PVOH because the complete biodegradation of PVOH in natural conditions and
after WWTP has not been demonstrated yet. Its degradation depends on environmental conditions as
well as on the microorganisms present, and it is important to identify in which environmental
compartments PVOH end up.
What would be the costs of the measure?
Its cost would be that of developing a sampling procedure as well as performing the sampling and
analysing it. This cost would be borne by the Commission and should be then relative to the hiring
of a scientific committee and/or consultancy firm to define the guidelines for the standard
methodology of testing. Considering a highly qualified consultancy firm, this cost could be EUR
100 000-500 000. Once the standard is developed, there will be the additional cost of testing the
materials (only once per material). This cost was evaluated to range between EUR 500 and 1000 per
sample.
What would be the benefits of the measure?
This measure will provide information on the release of microplastics by using detergent capsules
since this is a critical knowledge gap that has been identified. The indirect benefits will also include
raising awareness of the detergent capsule value chain actors and consumers. It is already a necessary
step to measure any reduction measure's success rate. It would further increase our knowledge and
understanding of PVOH’s degradation.
Economic impacts
Table 67: Economic impact of the measure
Impact category Qualitative
scoring of
impact
Affected
stakeholders
Description of impact
Operating costs and
conduct of business
0 Detergent
manufacturers
The use of optimized/enhanced compositions
used for water-soluble films will probably come
at a neutral cost as detergent manufacturers are
innovating to improve their products because of
the demand of sustainable products. However,
they need to contribute for the development of
the method which would entail minor costs.
Operating costs and
conduct of business
0 Water-soluble
plastic producers
Having a measurable harmonised method will
enable them to design better water-soluble films.
Operating costs and
conduct of business
0/- Wastewater
management
companies
The method itself will not impact the wastewater
treatment companies but would enable them to
estimate better the proportion of soluble plastics
in the waste water.
Public authorities:
Change in costs to
authorities for
administrative,
compliance and
enforcement activities
- Member State
competent
authorities or
European
Commission
Public authorities could finance or supervise the
development of the method, e.g. through national
standardisation bodies.
Public authorities:
Change in costs to the
Commission
- European
Commission &
EU institutions
Cost for the European Commission to fund the
research for the development of the method.
437
Impact category Qualitative
scoring of
impact
Affected
stakeholders
Description of impact
Innovation and
research
+ Scientific
community
The measure will deepen the understanding of
the release of PVOH through detergent capsules.
Environmental impacts
This measure is expected to offer a better understanding about the impact of water-soluble films in
the real environment. It will enable to select the most appropriate water-soluble plastic compositions
with no adverse impact.
Social impacts
There are no social impacts foreseen.
CAP#3: Redesign biodegradability standards for detergent capsules
Here, a biodegradability standard would be re-designed, which would reflect the different
environmental compartments and the associated conditions that PVOH coming from detergent
capsules may encounter after it is released from WWTP. It would reflect the varying temperature
conditions, presence (or absence) of the required microorganisms, and selectivity of the
microorganisms (will it still degrade PVOH when in the presence of other competing food sources?).
What would be the costs of the measure?
The cost of setting up this measure would be borne by industry. It would consist in developing other
testing procedures reflecting the natural environmental conditions met by PVOH once it is released.
The cost was evaluated to be comparable to that of other similar measures and range between EUR
500 000 and 1 million. (For geotextiles (GEO#1), the cost of developing a standard would be EUR
0.63 million and EUR 2.85 million. For, CAP#1, this cost would be EUR 100 000-500 000.)
The above described measure (CAP#2: Apply current biodegradability standards to detergent
capsules) is expected to have an impact on producers. It is likely that the impact of this measure
(CAP#3) would be larger, as biodegradability criteria would be more stringent. This measure
(CAP#3) can for instance lead to a ban of products already on the market. As at this moment, it is not
clear how much such a new biodegradability standard would affect which PVOH grades would be
compliant, it is also difficult to estimate the cost and other impacts, such as on the SMEs that produce
these capsules.
What would be the benefits of the measure?
After the protocol has been developed and declared the right standard to evaluate PVOH’s
biodegradability, the standard has a potential for a full emissions reduction. However, the
development of the standard alone will have a limited impact.
Economic impacts
A summary of the impacts is given in the table below.
438
Table 68: Economic impact of the measure CAP#3
Impact category Qualitative
scoring of
impact
Affected
stakeholders
Description of impact
Operating costs and
conduct of business
-- Water-soluble plastic
producers
Water-soluble plastic producers will have
to set up new standards and replace their
PVOH grades were needed.
Public authorities:
Change in costs to the
Commission
- European
Commission and EU
institutions
Cost for the European Commission to
support the development of the new
standards
Innovation and
research
+ Scientific community The measure will deepen the
understanding of the fate of PVOH grades
in the different natural compartments.
Environmental impacts
This measure is expected to have a positive impact on the environment in terms of the reduction of
plastic emissions from water-soluble plastics. The adoption of this measure for water-soluble plastics
can give a real chance to the collection and good management of water-soluble plastics.
Social impacts
There are no social impacts foreseen.
7.6 Impact of measures for geotextiles
Table below shows the comparison between all measures evaluated to reduce microplastic emissions
from geotextiles.
Table 69: Comparison of measures for geotextiles
Measure Estimated
reduction
potential
Estimated
Cost-
effectiveness
(EUR/tons
reduced/year)
Other
environmental
impacts
Other economic
impacts
Social
impacts
% Ktons/
year
GEO#2:
Guidelines for
geotextile use
18 – 74% 2 880 –
11 840
15 – 272 EUR/t No impact on
already installed
geotextiles
Negative impact on
costs for
geotextiles users
(municipalities,
construction
companies)
GEO#3: Use
biodegradable
geotextiles for
specific
applications
Not
quantified
439
GEO#4: Establish
geotextile classes
according to
emissions of
microplastics
25 – 85% 8 340
(3 360 –
13 320)
27.5
(20 – 351
EUR/t)
No impact on
already installed
geotextiles
Reduction of
microplastic
pollution in
marine
environment, air
and soil
Negative impact on
costs for
geotextiles users
(municipalities,
construction
companies)
GEO#1:
Standardised
methodology to
quantify
microplastics
released from
geotextiles
Table 70Table 70Table below shows the comparison of the impacts of the measures assessed to
reduce microplastic emissions from geotextiles.
Table 70: Summary of impacts for measures for geotextiles
Policy Option Environmental impact Economic Impact Social impact
GEO#2: Guidelines
for geotextile use
Microplastic release
reduction by 2 880
tonnes and up to 11 840
tonnes
Between EUR 174 000 -
785 000 for developing
the guidelines
No social impact
GEO#3: Use
biodegradable
geotextiles for
specific applications
Reduction in
microplastics released
from the use of polymer-
based geotextiles in
short-term applications
Increased product prices
for end-users
No social impact
GEO#4: Establish
geotextile classes
according to
emissions of
microplastics
Reduction in
microplastics released,
especially combined
with 2c
Increased burden for
geotextile manufacturers
leading to higher prices
No social impact
GEO#1:
Standardised
methodology to
quantify
microplastics
released from
geotextiles
No emission reduction
per se but helpful in
other measures and
knowledge
improvement
One-shot cost of
developing the standard
0.63- 2.85 million euros.
Cost of testing the
materials is between
EUR 2 500 per test
There could be new jobs
in the R&D sector
(private company or
research organisations)
unless developed by the
existing research staff
The impact of each measure is outlined below.
440
GEO#2: Guidelines for geotextile use
This measure would be for the EC to support the development of guidelines by the industry regarding
how to properly install geotextiles to achieve a certain goal while minimising microplastic releases.
These guidelines would cover three main areas:
• What should be the polymer used for certain applications?
• What should be the manufacturing process?
• How should the geotextile be installed?
This could take the form of a decision tree accompanied by a set of guidelines specific for each case
What would be the costs of the measure?
The cost of this measure is expected to be mostly borne by the entity that will develop the guidelines
(European Commission or the industry). The cost of this measure is expected to be between EUR
174 000 -785 000.
Indirectly, the cost of geotextile solutions may be increased due to the additional requirements for
installing them to reduce microplastic releases while still achieving the desired mechanical
properties. So an indirect impact of this measure would be to increase the cost of coastal erosion
protection systems for municipalities, for example.
What would be the benefits of the measure?
This measure would enable the use of geotextiles for coastal erosion protection applications (and
others, although this is the application expected to release most microplastics) in optimal conditions,
which would reduce the microplastic releases significantly from newly installed geotextiles.
When the guidelines are in place, the reduction in microplastic releases may not be significant as it
depends on the will of users to follow or not the guidelines. The industry estimate it to range between
60 and 80% but we consider it will be much lower 20-30%. However, this reduction would only
concern the newly installed geotextiles; the previously installed materials exposed to the environment
would continue to release microplastics. Therefore, we estimate that it would reduce microplastic
releases by 2 880 tonnes and up to 11 840 tonnes.
Economic impacts
The economic impacts are expected to be twofold:
• Economic impact for the industry: they will be the ones developing the guidelines; this
would require full-time equivalents from the industry association (the EAGM345
in the EU
or the IGS346
if the guidelines are developed at a scale broader than the EU). Additional
costs would be incurred by testing the materials and installing said materials together with
the sampling of microplastics to ensure that the guidelines effectively reduce microplastic
releases.
• Economic impacts for consumers / users: it is expected that these guidelines will require
that higher quality materials are used and that they are adequately protected. This will most
likely increase the cost of using geotextile solutions instead of their alternatives (rocks,
345
European Association of Geotextile manufacturers
346
International Geotextile Society
441
concrete structures, etc.). However, these economic impacts are expected to be reduced.
Environmental impacts
Environmental benefits are expected from this measure. Indeed, the guidelines will be designed with
the goal of reducing microplastic releases. Thus, once they are in place, the emissions are expected
to be significantly decreased. However, there are two caveats to this positive effect:
• It is possible that the guidelines may suffer from a significant delay from the industry during
development, which would postpone the potential reduction of microplastic releases from
this measure.
• All geotextiles which were installed before the publication of these guidelines will still
release microplastics into the environment. Even more so, after they have been weathered
by the environment, there is currently no scheme to remove geotextiles when they reach
their end-of-life.
Social impacts
No social impact
GEO#5: Use biodegradable geotextiles for specific applications
Some geotextile materials are used to keep plants in place while they root. These materials are used
for applications which are by definition short-lived and which will be impossible to recover once the
plants have grown through them. Therefore, enforcing the mandatory use of biodegradable and bio-
based materials made of jute, coco fibres, or others should significantly reduce microplastics from
these materials.
What would be the costs of the measure?
This measure would increase the cost of the materials used for vegetation placement because
biodegradable fibre geotextiles are more expensive than their non-biodegradable counterparts. In
most cases, a biodegradable fibre has a natural origin, although not always. So, the cost for
municipalities would increase. Moreover, members of the industry would suffer losses from the
inability to sell their products, so an adaptation period will be necessary.
What would be the benefits of the measure?
There would be a reduction of microplastic releases from the use of polymer-based geotextile for
short-term applications.
Economic impacts
The main economic impact will be on the end users as they will bear the additional costs of the
biodegradable material, compared to the non-biodegradable ones.
Environmental impacts
This measure is expected to have a good positive impact on the environment in terms of the reduction
of microplastic release as biodegradable in natural environment. Biodegradation will have to be
supported by an appropriate standard.
Social impacts
There are no social impacts foreseen.
442
GEO#4 Establish geotextile classes according to emissions of microplastics
In the Construction Products Regulation (CPR), material classes can be defined through delegated
acts depending on the quality/strength requirements for a given construction product. A similar
system could be used for geotextiles: geotextile materials, depending on their manufacturing method,
polymer type, and additive content (type of additive and concentration), could be classified according
to quality standards based on the measurement protocols developed under 5f. Then, requirements
regarding the minimum material class to use depending on the application would be made available,
and only the accredited materials could be used for these applications.
What would be the costs of the measure?
The measure would need GEO#1 to be implemented before, in order to quantify the microplastic
releases from geotextiles. The measure’s cost would be due to developing the different material
classes as well as testing the geotextiles to determine their class and defining for what application
can a certain class of geotextile be used.
What would be the benefits of the measure?
This measure is expected to reduce microplastic releases from the installation of new geotextiles, and
it is expected to reduce the emission faster than 2c (guidelines for geotextile applications) because it
is expected to be implemented faster through a regulatory action than what the industry could do.
The geotextiles may still be exposed to harsh environmental conditions, especially to weather events
of unpredictable scale such as storms and could release some microplastics.
Economic impacts
It is expected to increase the impact on manufacturers to fulfil the class labelling obligations of the
CPR. Increase costs of geotextile will also impact the cost for installing geotextiles for final users
(e.g. municipalities, public works companies, landfill management companies etc. However, during
the stakeholder consultation on levels and classes of performance (Article 27, Article 60) of the CPR,
64% of the respondents indicated no impact for establishing classes of performance and threshold
levels in relation to the essential characteristics of construction products, some stakeholders believed
that the process for establishing classes will be more time consuming and onerous.347
Environmental impacts
The reduction of microplastic releases is expected to be higher than 2c but in combination with 2c
the reductions will be higher.
Social impacts
There are no social impacts foreseen for this measure.
GEO#1: Standardised methodology to quantify microplastics released from geotextiles
This measure was developed in response to the knowledge gaps that were identified around the
precise measurement of microplastic emissions. Developing a standardised measurement
methodology will enable the development of reduction-specific measures at a later stage.
This measure aims to develop a protocol to effectively measure microplastics released from
geotextiles over the life cycle. There is evidence that microplastics are emitted from geotextiles;
however, the quantification of such emissions still eludes researchers. Indeed, a systematic approach
347
RPA (2015) Analysis of implementation of the Construction Products Regulation, DG GROW, European
Commission
443
to microplastic sampling for geotextile particles in the environment currently does not exist.
Moreover, since geotextiles are installed in various ways and for a wide range of applications, there
would be some value in systematically taking samples to measure microplastic releases to the
environment from different materials and installation methods.
The main goal of this measure would be to increase our understanding of the issue by developing a
measurement methodology valid for measuring microplastic releases from different geotextile
sources. E.g., different materials (PET, PP, etc.), different manufacturing processes (woven, non-
woven, etc.). This should cover the complete life-cycle, i.e. producing geotextiles, their use in
applications and end-of-life management.
Currently, there are tests used to evaluate the degradation of geotextiles from different weathering
agents (UV light, temperature variation, water/saltwater,348
oxygen exposure349
or
abrasion350
).351,352,353
The ISO 22182 test method simulates abrasion impacts on geotextiles and
geotextile-related products such as that caused by the movement of rocks in an embankment or
transport of sediment in rivers. This test can be used as a performance test by comparison of
mechanical and/or additionally hydraulic properties before and after abrasion impact. Though not
intended for assessing microplastic release, it could potentially simulate the development of abrasion-
resistant geotextiles.354
These methods do yield results which are currently used for the determination
of geotextiles’ lifetime expectancy. Still, they may not reflect the weathering power of the natural
environment, especially when these affect the geotextiles conjointly. A recently published study
highlighted the destructive effect that interacting weathering agents could have on geotextile aging:355
“The results, among other findings, showed the existence of relevant interactions between the
degradation agents and showed that the reduction factors obtained by the traditional methodology
were unable to represent accurately (by underestimating) the degradation occurred in the
geotextile.”
What would be the costs of the measure?
The costs would be split into two:
First, there would be the cost of developing the methodology (EUR 630 000-2 850 000).
Second, there would be the cost of testing the materials (EUR 2500/sample).
The estimated cost of developing the standard is shown in the below.
348
EN 12447, Geotextiles and Geotextile-Related Products-Screening Test Method for Determining the Resistance to
Hydrolysis in Water, European Committee for Standardization, Brussels, Belgium, 2001.
349
EN ISO 13438, Geotextiles and Geotextile-Related Products-Screening Test Method for Determining the Resistance
to Oxidation, European Committee for Standardization, Brussels, Belgium, 2004.
350
ISO 22182 :2020, Geotextiles and geotextile-related products — Determination of index abrasion resistance
characteristics under wet conditions for hydraulic applications
351
EN 14030, Geotextiles and Geotextile-Related Products-Screening Test Method for Determining the Resistance to
Acid and Alkaline Liquids, European Committee for Standardization, Brussels, Belgium, 2001.
352
EN 12224, Geotextiles and Geotextile-Related Products-Determination of the Resistance to Weathering, European
Committee for Standardization, Brussels, Belgium, 2000.
353
EN 12226, Geosynthetics—General Tests for Evaluation following Durability Testing, European Committee for
Standardization, Brussels, Belgium, 2012.
354
Maisner et al. (2019) Geosynthetics in traffic infrastructure construction in contact with groundwater and surface
water – Environmental aspects. Georesources Journal (special issue)
355
Carneiro, José Ricardo et al. "Laboratory Evaluation Of Interactions In The Degradation Of A Polypropylene
Geotextile In Marine Environments". Advances In Materials Science And Engineering, vol 2018, 2018, pp. 1-10.
Hindawi Limited, doi:10.1155/2018/9182658. Accessed 2 May 2022.
444
Table 71: Assumptions and data to estimate the costs of developing and implementing a standard
Description Data Unit Source
Number of people working full time necessary to
elaborate the standard between 12 and 36 months356
7.25 people ISO website
Mean cost of labour in EU of one engineer working
full-time 39.5 EUR/hour Eurostat
Number of hours per week in a full-time job 40.6 hours/week Eurostat
Number of Geotextile manufacturers in the EU 34 Number
Total EU members of the
IGS and EAGM
Fraction of companies conducting tests for
elaborating the standard 5 % Assumption
Therefore, the one-shot cost of developing the standard would be in the range of EUR 0.63 million
and EUR 2.85 million depending on the time it takes to develop the measurement standard.
In addition, once the standard is developed, there will be the additional cost of testing the materials
(only once per material). This cost will be about 2,500 euros per test357
according to ISO 22182.
What would be the benefits of the measure?
This measure will benefit all other measures as the release of microplastics during the life cycle of
geotextiles is a critical knowledge gap. The indirect benefits will also include the awareness-raising
of the geotextile value chain actors and users of geotextiles. If an EPR system is implemented, the
eco-fee can also be modulated according to the volume of microplastic release and respective actors’
contributions. It is already a necessary step to measure any reduction measure’s success rate. Such
information will also be useful in restricting the use of specific geotextiles in certain applications,
such as coastal erosion, navigable waterways, etc.
This could be used to support further legislative development based on the evidence of microplastic
releases from geotextiles. Another development could be to increase the industry’s awareness about
the emissions of microplastics from their materials. This would be exhibited by the industry focusing
their efforts on developing new materials releasing fewer microplastics as well as considering
microplastic releases whenever they develop geotextiles. Finally, this increased knowledge could be
used to improve any type of recommendation regarding which material and manufacturing process
to use for certain geotextile applications, as well as their installation requirements, as the results of
this measure’s test could point towards certain combinations releasing more than others.
Economic impacts
The economic impacts are expected to be limited because the cost of developing the sampling and
testing protocols would be borne by the Commission.
356
The ISO technical committee on the environmental aspects of plastics is comprised of 29 members (the national
standardization organisation). We assume that each member contributes 0.25 FTE to work on the committee.
357
https://materialtestinglab.org/
445
Environmental impacts
The direct environmental impacts are expected to be very limited, given that this measure is targeted
at increasing our understanding of the issue. However, the secondary environmental impacts could
be significant, especially if the industry takes up the practice of designing their products with the
reduction of microplastic releases in mind.
Social impacts
There are no social impacts foreseen.
7.7 Overview of possible measures to improve source characterisation
The study of the six sources of unintentional microplastics has shown that many knowledge gaps still
exist in the precise measurement of emissions. These knowledge gaps make the implementation of
several measures impossible in the short term as it’s not possible to define them (e.g. reduction
targets) or evaluate their impact adequately.
Consequently, several measures that aim at increasing the knowledge of microplastic releases
through the development of standards and methodologies in all sectors but tyres are recommended
and presented in the table below.
These measures do not allow any reduction of microplastic releases per se; therefore, their cost-
effectiveness cannot be assessed. Unlike other measures, the cost would be one-shot. They should be
seen as enablers for other measures.
Table 72: Horizontal measures
Measure Estimated cost
TEX#1: Standardised methodology to quantify microplastics releases
from textiles
EUR 850 000
Testing cost EUR 10 000-20 000
PNT#1: Standardised methodology of paint lifetime EUR 100 000 - 500 000
Testing cost EUR 10 000 -20 000
CAP#1: Standardised methodology to quantify microplastics released
from detergent capsules
EUR 100 000 – 500 000
Testing cost: EUR 500-1000 per sample
GEO#1: Standardised methodology to quantify microplastics released
from geotextiles
EUR 630 000 - 2 850 000
Testing cost about EUR 2 500 per sample
7.8 Abatement curve of assessed measures
The cost-effectiveness of individual measures was assessed as far as possible with the best available
data. This has allowed for a ranking of the measures in terms of the cost to abate a tonne of
microplastics. The abatement curve for all measures evaluated is shown in the figure below. The
average or most plausible value is used for each measure, knowing that there is uncertainty about the
data, depending on the source and measure, as explained in the annexes.
446
Figure 49: Abatement curve of all evaluated measures358
As the order of magnitude of the cost-effectiveness of the measure is different, a zoom of selected
measures is displayed in the figure below.
Figure 50: Abatement curve of evaluated options with cost effectiveness inferior to 6 k EUR/t
microplastics/year
358
TYR#5 and TYR#6 may have positive impacts in terms of fuel savings for customers.
447
8. RATIONALE FOR NOT YET PURSUING THE MEASURES FOR SOURCES: PAINTS, TYRES, TEXTILES,
DETERGENT CAPSULES, GEOTEXTILES
This section explains why the analysis of policy measures targeting five of the major sources of
unintentional releases of microplastics were not pursued in this SWD. Indeed, the Commission’s
original mandate when this exercise begun was to assess all major sources of unintentional releases
of microplastics. For this reason, these sources were examined and measures were identified. The
preliminary analysis presented in Annex 15 shows that there is potential to reduce and prevent
unintentional microplastics releases from sources such as paints, tyres, synthetic textiles, detergent
capsules and geotextiles. However, the analysis also demonstrates that existing and upcoming policy
instruments are better suited to tackle the unintentional microplastics releases from some of these
sources, subject to additional information on cost-effectiveness, more sustainable alternatives, and
the impacts and footprint of alternative actions. On a number of other sources, more information is
needed in order to better understand their patterns and frame the most appropriate interventions.
Paints – Paints are widely used and on average 37% plastic polymer-based, making them a
significant source of microplastic releases. While shifting towards mineral paints would help reduce
microplastic releases, it is not clear yet if this would lead to an increase of other environmental
impacts. The full environmental profile andlife-cycle assessments of polymer and mineral paints are
not available yet. Once this information is obtained, requirements on microplastics in paints could be
introduced via the Ecodesign for Sustainable Products Regulation (ESPR)359
, where paints is one of
the twelve priority products.
Tyres – Tyre abrasion leads to the release of microplastics. It emerged during our analysis that these
releases are already being targeted in the EURO 7 Regulation proposal360
and may be addressed by
a delegated act under the Tyre Labelling Regulation.361
Synthetic textiles – Most apparel is now made out of plastic fibres and releases microplastics. Some
key challenges encountered in the course of the assessment are that microplastic releases from
synthetic fibres occur throughout the value chain, that most of their production takes place outside of
the EU, and that there is not sufficient data regarding the profiles of different synthetic fibres and
fibre combinations in terms of microplastic releases. Subject to a better understanding of releases
from synthetic textiles thanks to a standardised measurement methodology, along with more life-
cycle data of alternatives’ impacts, relevant measures could be introduced in the framework of the
Ecodesign for Sustainable Products Regulation as announced in the EU Strategy for Sustainable and
Circular Textiles. Such an approach will ensure the environmental sustainability challenges of
textiles are addressed in a coherent and integrated way.
Detergent capsules – Laundry and dishwasher detergent capsules often rely on a dissolvable plastic
film to dispense their product during the wash. However, this film could cause microplastic pollution
if not completely biodegradable. More information on this possible lack of biodegradation is needed.
Subject to scientific evidence pointing towards a need for biodegradability criteria, future action
could be taken under the proposed Detergents Regulation through the adoption of delegated acts.
359
Proposal for a regulation of the European Parliament and of the Council COM/2022/142 final establishing a
framework for setting ecodesign requirements for sustainable products and repealing Directive 2009/125/EC.
360
Proposal for a regulation of the European Parliament and of the Council COM/2022/586 final on type-approval of
motor vehicles and engines and of systems, components and separate technical units intended for such vehicles, with
respect to their emissions and battery durability (Euro 7) and repealing Regulations (EC) No 715/2007 and (EC) No
595/2009.
361
Regulation (EU) 2020/740 on the labelling of tyres with respect to fuel efficiency and other parameters, amending
Regulation (EU) 2017/1369 and repealing Regulation (EC) No 1222/2009.
448
Geotextiles – Geotextiles are a source of microplastic releases as they are mostly synthetic, used in
harsh conditions and not removed at the end of their service life. However, data on their uses and
profile in terms of degradation and microplastic releases is scarce. Once more data is available, future
action could be taken in the framework of the Construction Products Regulation.362
Horizontal measures for all five sources – In order to bridge the data gaps on the unintentional
release of microplastics from the above five sources, standardised measurement measures could be
pursued through Research and Innovation Programmes by funding relevant research projects or under
the Standards Regulation.363
In particular for sources of microplastics that were already relatively
known such as for tyres and textiles, this process is already ongoing.
362
Regulation (EU) No 305/2011 laying down harmonised conditions for the marketing of construction products and
repealing Council Directive 89/106/EEC.
363
Regulation (EU) No 1025/2012 on European standardisation, amending Council Directives 89/686/EEC and
93/15/EEC and Directives 94/9/EC, 94/25/EC, 95/16/EC, 97/23/EC, 98/34/EC, 2004/22/EC, 2007/23/EC,
2009/23/EC and 2009/105/EC and repealing Council Decision 87/95/EEC and Decision No 1673/2006/EC.


EN EN
EUROPEAN
COMMISSION
Brussels, 16.10.2023
SWD(2023) 332 final
PART 2/3
COMMISSION STAFF WORKING DOCUMENT
IMPACT ASSESSMENT REPORT
Combatting microplastic pollution in the European Union
Accompanying the document
Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE
on preventing plastic pellet losses to reduce microplastic pollution
{COM(2023) 645 final} - {SEC(2023) 346 final} - {SWD(2023) 330 final} -
{SWD(2023) 333 final}
Offentligt
KOM (2023) 0645 - SWD-dokument
Europaudvalget 2023
1
TABLES OF CONTENTS
ANNEX 1: PROCEDURAL INFORMATION............................................................................................. 4
1 LEAD DG, DECIDE PLANNING/CWP REFERENCES.................................................................... 4
2 ORGANISATION AND TIMING........................................................................................................ 4
3 CONSULTATION OF THE REGULATORY SCRUTINY BOARD ................................................. 5
4 MAIN LITERATURE SOURCES USED ...........................................................................................17
ANNEX 2: STAKEHOLDER CONSULTATION (SYNOPSIS REPORT) ................................................33
1 INTRODUCTION ...............................................................................................................................33
2 CONSULTATION STRATEGY .........................................................................................................33
3 MAPPING OF STAKEHOLDERS .....................................................................................................34
4 OPEN PUBLIC CONSULTATION ....................................................................................................35
4.1 Scope and Objective.................................................................................................................35
4.2 Data Preparation.......................................................................................................................35
4.3 Clustering of Responses and Special Processing .....................................................................36
4.4 Open Answer Questions and Campaign Identification ............................................................36
4.5 Methodologies Employed.........................................................................................................37
4.6 Part I. Respondent Profile ........................................................................................................38
4.7 OPC Results .............................................................................................................................40
5 STAKEHOLDER WORKSHOPS .....................................................................................................104
5.1 First stakeholder workshop: 16 September 2021 ...................................................................104
5.2 Second series of thematic stakeholder workshops: 22, 24, 25 November 2021.....................104
5.3 Third stakeholder workshop: 17 February 2022.....................................................................105
5.4 Fourth stakeholder workshop: 17 March 2022.......................................................................105
5.5 Fifth stakeholder workshop: 21 March 2022..........................................................................106
5.6 Sixth stakeholder workshop dedicated to Member States representatives: 23 March 2022 ...106
5.7 Seventh stakeholder workshop on pellets: 12 December 2022 ..............................................106
6 SME CONSULTATION....................................................................................................................106
7 BILATERAL CONSULTATIONS....................................................................................................106
ANNEX 3: WHO IS AFFECTED AND HOW? ........................................................................................107
1 PRACTICAL IMPLICATIONS OF THE INITIATIVE ON PELLETS ...........................................107
2 SUMMARY OF COSTS AND BENEFITS ......................................................................................111
3 RELEVANT SUSTAINABLE DEVELOPMENT GOALS..............................................................116
ANNEX 4: ANALYTICAL METHODS ...................................................................................................117
1 METHODOLOGY USED FOR THE INITIATIVE ON PELLETS .................................................117
2 OVERVIEW OF METHODOLOGICAL STEPS..............................................................................120
ANNEX 5: COMPETITIVENESS CHECK ...............................................................................................122
1 OVERVIEW OF IMPACTS ON COMPETITIVENESS ..................................................................122
2 ASSESSMENT AND EXPLANATION............................................................................................122
ANNEX 6: LEGISLATION AND ACTIONS RELEVANT TO REDUCING PELLET LOSSES TO THE EU
ENVIRONMENT ..............................................................................................................................123
2
1 EU POLICIES....................................................................................................................................123
1.1 The REACH restriction on intentionally added microplastics ...............................................123
1.2 The Marine Strategy Framework Directive (MSFD) .............................................................124
1.3 The Urban Wastewater Treatment Directive and its revision.................................................125
1.4 The Sewage Sludge Directive ................................................................................................126
1.5 The Industrial Emissions Directive ........................................................................................126
1.6 The Waste Framework Directive ...........................................................................................127
2 ACTIONS IN MEMBER STATES ...................................................................................................127
3 INTERNATIONAL ACTIONS ON PELLETS.................................................................................129
4 MULTILATERAL ACTIONS...........................................................................................................130
5 VOLUNTARY ACTIONS ON PELLETS ........................................................................................132
5.1 Industry actions ......................................................................................................................132
5.2 NGO activities........................................................................................................................135
ANNEX 7: MICROPLASTICS AND PELLETS IN THE ENVIRONMENT...........................................137
1 WHAT ARE MICROPLASTICS?.....................................................................................................137
1.1 Methodological challenges: lack of standardisation and reliable data....................................138
1.2 Monitoring..............................................................................................................................138
2 WHAT ARE THE IMPACTS OF MICROPLASTICS AND PELLETS? ........................................139
2.1 Impacts on the environment ...................................................................................................139
2.2 Climate impacts......................................................................................................................142
2.3 Human health impacts............................................................................................................143
2.4 Economic impacts ..................................................................................................................146
ANNEX 8: PROBLEM DEFINITION – PELLET LOSSES TO THE EU ENVIRONMENT..................147
1 PROBLEM DEFINITION .................................................................................................................147
1.1 The pellet supply chain ..........................................................................................................147
1.2 Pellet losses ............................................................................................................................149
1.3 Pellet pathways.......................................................................................................................154
1.4 Scale of the problem...............................................................................................................155
1.5 Chronic losses in reference year.............................................................................................159
2 ADVERSE IMPACTS.......................................................................................................................161
3 PROBLEM DRIVERS.......................................................................................................................161
3.1 Market failures .......................................................................................................................161
3.2 Regulatory failures.................................................................................................................161
4 OBJECTIVE ......................................................................................................................................163
4.1 General objectives..................................................................................................................163
4.2 Specific objectives..................................................................................................................163
ANNEX 9: BASELINE..............................................................................................................................164
1 THE PELLET SUPPLY CHAIN .......................................................................................................164
2 HOW WILL PELLET LOSSES EVOLVE IN 2030?........................................................................165
2.1 Existing and forthcoming EU legislation ...............................................................................165
2.2 National and international initiatives......................................................................................166
3
2.3 Industry initiatives..................................................................................................................167
2.4 The baseline ...........................................................................................................................169
ANNEX 10: POLICY OPTIONS TO REDUCE PELLET LOSSES .........................................................171
1 METHODOLOGY TO IDENTIFY MEASURES.............................................................................171
2 SCREENING OF MEASURES.........................................................................................................172
3 FINAL LIST OF MEASURES / OPTIONS ......................................................................................174
4 THE INTERVENTION LOGIC ........................................................................................................177
ANNEX 11: IMPACTS OF POLICY OPTIONS TO REDUCE PELLET LOSSES .................................178
1 IDENTIFICATION AND SCREENING OF IMPACTS...................................................................178
2 OPTION 1: MANDATORY STANDARDISED METHODOLOGY TO MEASURE PELLET LOSSES
...........................................................................................................................................................181
3 OPTION 2: MANDATORY REQUIREMENTS TO PREVENT AND REDUCE PELLET LOSSES IN
A NEW EU LAW ..............................................................................................................................184
4 OPTION 3: IMPROVED PACKAGING FOR LOGISTIC OF PELLETS .......................................195
5 OPTION 4: EU TARGET TO REDUCE PELLET LOSSES ............................................................199
6 SUMMARY OF THE IMPACTS......................................................................................................202
ANNEX 12: IMPACTS ON SMES............................................................................................................203
1 IDENTIFICATION OF AFFECTED BUSINESSES ........................................................................203
2 GENERAL CONSULTATION OF SMES........................................................................................203
3 TARGETED SME CONSULTATION..............................................................................................204
3.1 Summary of the results...........................................................................................................204
3.2 Details of the results: analysis of estimated costs...................................................................209
3.3 Other detailed results..............................................................................................................211
4 MEASUREMENT OF THE IMPACT ON SMES ............................................................................216
5 MINIMISING NEGATIVE IMPACTS ON SMES...........................................................................217
ANNEX 13: PRODCOM CODES USED TO QUANTIFY PELLET PRODUCTION, EXPORT AND
IMPORT INTO THE EU IN 2020.....................................................................................................221
ANNEX 14: OTHER SOURCES OF MICROPLASTICS IDENTIFIED BUT NOT RETAINED............223
1 ALL IDENTIFIED SOURCES..........................................................................................................223
2 SOURCES NOT RETAINED FOR ANALYSIS ..............................................................................224
2.1 Fragmentation of ‘macro’ plastics in the environment...........................................................224
2.2 Sewage sludge........................................................................................................................226
2.3 Brake Pads..............................................................................................................................227
2.4 Artificial / synthetic turf.........................................................................................................227
2.5 Cast rubber surfaces for playgrounds.....................................................................................228
2.6 Fishing Gear...........................................................................................................................229
2.7 Agriculture plastics ................................................................................................................229
2.8 City Dust ................................................................................................................................230
2.9 Shoe soles...............................................................................................................................231
2.10 Cooking utensils and scouring pads .......................................................................................231
2.11 Additional sources identified through stakeholder interactions .............................................232
4
Annex 1:
Procedural information
1 LEAD DG, DECIDE PLANNING/CWP REFERENCES
The preparation of this file was led by the Directorate–General: DG Environment (ENV). It was
included as the following items in the DECIDE/Agenda Planning database: PLAN/2020/8355 - ENV
- Measures to reduce microplastic pollution.
2 ORGANISATION AND TIMING
The initiative is a deliverable under the European Green Deal and was further set out in the Circular
Economy Action Plan1
(CEAP).
The Inception Impact Assessment Roadmap was published in 2020.
The Call for Evidence2
was published on 30 November 2021 with a feedback period until 18 January
2022.
The Open Public Consultation3
was published on 22 February 2022 with a feedback period until 18
May 2022.
The Inter Service Steering Group (ISSG) for the Impact Assessment was set up by the Secretariat-
General (SG). It included the following DGs and services: AGRI (Agriculture), BUDG (Budget),
CLIMA (Climate Action), CNECT (Communications Networks, Content and Technology), COMM
(Communication), COMP (Competition), EMPL (Employment, Social Affairs and Inclusion), ENER
(Energy), ESTAT (Eurostat), FISMA (Financial Stability, Financial Services and Capital Markets
Union), FPI (Foreign Policy Instruments), GROW (Internal Market, Industry, Entrepreneurship and
SMEs), I.D.E.A. (Inspire, Debate, Engage and Accelerate Action), INTPA (International
Partnerships), JRC (Joint Research Centre), JUST (Justice and Consumers), MARE (Maritime
Affairs and Fisheries), MOVE (Mobility and Transport), OLAF (European Anti-Fraud Office),
REGIO (Regional and Urban policy), RTD (Research and Innovation), SANTE (Health and Food
Safety), SJ (Legal Service), TAXUD (Taxation and Customs Union) TRADE (Trade), NEAR
(Neighbourhood and enlargement) as well as EEAS (European External Action Service). Meetings
were organised between autumn 2021 and spring 2023.
The ISSG discussed the Inception Impact Assessment and the main milestones in the process, in
particular the consultation strategy and main stakeholder consultation activities, key deliverables
from the support study, and the draft Impact Assessment report before the submission to the
Regulatory Scrutiny Board.
1
European Commission, Commission communication - A new Circular Economy Action Plan For a cleaner and
more competitive Europe; COM(2020)98 final, 2020.
2
European Commission, Commission call for evidence - Microplastics pollution: measures to reduce its impact on the
environment, 2022 (https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12823-Microplastics-
pollution-measures-to-reduce-its-impact-on-the-environment/feedback_en?p_id=27539989).
3
European Commission, Commission public consultation - Microplastics pollution: measures to reduce its impact on the
environment, 2022 (https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12823-Microplastics-
pollution-measures-to-reduce-its-impact-on-the-environment/public-consultation_en).
5
3 CONSULTATION OF THE REGULATORY SCRUTINY BOARD
In January 2022, the authors consulted the Regulatory Scrutiny Board (RSB) about the Impact
Assessment (IA) during an upstream support meeting.
The RSB received the draft version of the IA report on 17 October 2022. Following the meeting with
the RSB on 16 November 2022, the RSB gave a negative opinion on 18 November 2022. The opinion
included recommendations that were addressed in the revised IA report as outlined in the table below.
The major recommendation of the RSB was to restructure the scope of the IA around pellets, where
it had previously equally considered the other identified sources of unintentional microplastic
releases (paints, tyres, textiles, geotextiles and detergent capsules). Contextual information and
preliminary analyses of these sources can now be found in Annex 15 of this IA.
The revisions to this IA were also the subject of an additional Inter Service Steering Group meeting
on 05.05.2023.
Table 1: RSB recommendations and how they were addressed
RSB Comment How the comment has been addressed
Main Points in the RSB’s first opinion
The report does not set out the exact scope of the
initiative. It is not clear upfront on the issues that
will be dealt with in parallel and future initiatives.
It does not sufficiently explain the coherence with
other legislation.
The report’s structure has been completely revised to
streamline the scope of the analysis and make clear
from the beginning that pellets are the focus of the
impact assessment. The introductory text makes this
clear, and also indicates the reasons for targeting
pellets: sufficient information and best handling
practices are available and existing EU legislation
does not specifically address pellets as a form of
pollution along the entire supply chain. It mentions
the other sources that had also been initially
investigated, and explains why those sources are no
longer dealt with in the main body of this IA.
The other pieces of legislation and related initiatives
are covered in section 2.3.2, as well as Annex 6, 8 and
9.
The objectives of the initiative are not specific
enough and do not clearly relate to the problems.
The report is not clear on how much this initiative
is expected to contribute to the 30% reduction
target.
Due to the change in scope, the problems have been
revised and made specific focussing on pellets. The
objectives have also been further specified. The
intervention logic graph in section 4.3 provides a
clear overview of this initiative’s objectives and the
problem it aims to tackle i.e. poor handling of pellets.
Pellet losses account for 7-10% of total microplastic
releases to the EU environment (intentional and
unintentional), being the third largest source of
releases as calculated by this IA. The preferred option
(i.e. Option 2.b) would lead to an estimated reduction
potential of 25 142 – 140 621 tonnes of pellet losses.
6
Therefore, it would lead to an estimated 60-83%
reduction in total pellet microplastic releases, which
averages at around 7% in total microplastic releases.
This option is therefore expected to contribute
roughly to 1/4th
of the 30% overall reduction target
set out in the Zero Pollution Action Plan.
The presentation of measures and options is not
sufficiently clear or focused on the precise
problems to be tackled by this initiative. The
impact analysis is not sufficiently clear and the
level of uncertainty is not defined.
Due to the revised structure, the measures analysed
have been reduced and are now specific to the
problem of poor handling of pellets and subsequent
harmful losses. Section 5.2. describes the identified
four policy options and then sections 6 & 7 assess
their impacts including on the different stakeholder
groups, and how they compare.
The levels of uncertainty (mainly related to
measuring pellet losses and to the reduction potential
of ongoing pellet initiatives) are clearly expressed
and taken into account in section 5.1 where the
baseline is explained.
The presentation of stakeholder views is too
general and does not allow to understand their
different views.
Annex 2 on the consultation of stakeholders has been
completed to better present stakeholder views and
provide more insight into how this initiative is
perceived. To further deepen our understanding of
SMEs’ opinions, an additional survey targeting only
SMEs was carried out between January and March
2023. The results of this survey are captured in Annex
12 and where relevant throughout the report, notably
under each option assessed.
Points on what to improve from the first opinion
The report should clearly frame the scope of the
initiative in its wider context, better describing its
boundaries and limits. It should clearly describe
why it focuses on unintended emissions at source
level and discuss why, for example, the
degradation of macroplastics is not considered as
in scope.
It should clearly describe and analyse the
problems posed by microplastics released in the
environment. It should present the risks to human
health and the environment, including climate
impact. This analysis should be supported by solid
evidence. Where such evidence is lacking or is
uncertain, the report should indicate this clearly
and discuss the robustness of the available
evidence.
Section 1 has been revised to clearly explain the
political and legal context where unintentional
microplastic releases at source had been identified as
a priority. Once in the environment, such releases are
almost impossible to capture and their mobility across
all environments is an aggravating factor. Therefore
end-of-pipe measures are all but effective. The IA
explains that a legislative framework is already in
place to reduce the presence of macroplastics in the
environment, which is the most effective way of
tackling the degradation of macroplastics as a source
of microplastics. It also covers the upcoming REACH
restriction proposal targeting intentionally added
microplastics. This first section also clearly states that
the scope of this initiative is now reduced to pellet
losses at source level.
Section 2.2.1 outlines the adverse impacts of pellet
losses on the environment, the climate, human health
and the economy. Further information on these
7
impacts are provided in Annex 7. Specifically, the
report, clearly states that there is no scientific
consensus with regards to the health impacts of
pellets (and microplastics more generally), while
explaining why the application of the precautionary
principle is warranted (due to the observation of
microplastics throughout the human body and food
chain).
The report should better describe the existing and
on-going relevant initiatives to enable a better
understanding of the problems and their scale
posed by different sources of microplastics.
The dynamic baseline should include other EU
initiatives, measures already taken by Member
States, industry-led initiatives, and best practices
around circularity.
It should set out the overlap and complementarity
with existing initiatives in reaching the 30%
reduction target and clearly present the specific
contribution of this initiative to meeting the target.
The revised IA now only focuses on pellet losses
where there is a market and regulatory gap,
demonstrated in section 2.3.2.
The baseline has been revised to ensure that all
existing initiatives that might contribute to reduce
pellet losses (i.e. the French legislation, the industry-
led OCS certification scheme and the SQAS
assessment scheme) are taken into account according
to their estimated reduction potential – this is clearly
explained in section 5.1 and then further detailed in
Annex 9. The limited contribution of the upcoming
REACH restriction proposal as to pellet losses (i.e.
improving data but not effectively reducing pellet
losses) is also explained in that Annex.
As laid out in section 4.2, the contribution to the 30%
overall reduction target set out in the Zero Pollution
Action Plan is now one of the specific objectives of
this IA, and of the accompanying legislative proposal.
The preferred option, which builds on industry-led
efforts, is expected to contribute to 1/4th of the 30%
overall reduction target set out in the Zero Pollution
Action Plan.
The REACH restriction is expected to contribute to a
500 000 tonnes reduction in microplastic releases
over 20 year. Initiatives on tyres would possibly
contribute to a 10% reduction (with a considerable
range, depending on the final measures decided). This
leaves a gap (probably around 10%) to reaching the
30% overall reduction target, which will eventually
be dealt with via future initiatives. This initiative
should also act as a market signal making products
which release microplastics less popular, thus market
transformation through demand-side.
The report should clarify upfront that only one
specific sectorial issue together with a limited
horizontal one will be tackled in this initiative and
the issues related to microplastics releases from
other sources are left to future or parallel
initiatives, subject to further analysis. The specific
objectives are not precise enough to link them
The scope of the current IA has been completely
revised, so only the specific issue of pellet losses is
being dealt with. The preliminary analysis for the
other sources can now be found in Annex 15. As a
result of this change in scope, the objectives are now
much more specific to the problem identified with the
8
accurately to the revised set of specific problems.
They should be expressed in more SMART terms.
poor handling of pellet losses. The main pellet
objective is formulated in SMART terms.
Following a comprehensive problem definition
and a clear and redefined scope of this initiative,
the report should present those measures that
remain useful for tackling the specific problems
to be addressed by the initiative, discarding all
measures clearly outside the scope upfront. It
should then present a clear and consistent
intervention logic showing how alternative set of
measures could deliver on the refined set of
specific objectives.
Section 2 lays out the problem definition for the
specific problem of pellet losses, following the
revised scope of the IA. Section 4 defines the general
and specific objectives of the IA. Section 5 then
presents in detail the measures and policy options
identified as relevant to tackle pellet losses, and
includes a graph of the intervention logic. The
measures relating to the other sources have all been
moved to Annex 15.
The report should revise the impact analysis so that
it follows the redefined scope of the initiative. It
should analyse the impacts of the remaining
measures in sufficient depth and be clear about the
stakeholder groups affected.
It should ensure analytical consistency throughout.
It should present the methodologies used for
assessing the measures, comparing them and
constructing the preferred option. The level of
certainty in the analysis and conclusions should be
clear.
The identified four policy options of relevance to the
issue of pellet losses are outlined in Section 5, and
their impacts on the environment, economy and
society, as well as administrative burden for public
authorities are assessed in Section 6. Insights into
stakeholder opinions are also provided for each
option.
The various policy options are then directly compared
in a summary table in Section 7. The methodology
used to construct the preferred option is described in
Annex 4, which explains the various assumptions that
have been made notably to calculate chronic pellet
losses and the estimated reduction potential of
ongoing pellet initiatives. The resulting preferred
option is outlined in Section 8.1. The measures
proposed in this option are the ones that, in the short
term and with a view of contributing to 30% overall
reduction target, are possible to implement at the light
of the present state of knowledge and in an
economically cost-effective way.
The views of the different stakeholders should be
discussed throughout the report from the scope of
the initiative, the problem definition to the
proposed options and their impacts. Dissenting
views need to be presented and discussed in the
main report.
Stakeholder views have been mainstreamed
throughout the revised version of the IA. Section 2.1
outlines stakeholders’ unanimous support for the
need for action against microplastics. Section 6
assesses the impact of each policy option and includes
stakeholders’ opinions (where known). Annex 2 has
been revised so further information is available about
the results of the stakeholder consultation. An
additional survey was undertaken during January-
March 2023 to specifically target SMEs handling
pellets and collect their views on possible actions to
reduce pellet losses. The results of this survey are
used throughout the IA and summarised in detail in
Annex 12 (including dissenting views). Sub-options
2.a, 2.b and 2.c were conceived and assessed
specifically to take account of these results.
9
The revised version of the IA report was submitted to the RSB on 17.05.2023. The RSB consequently
gave a positive opinion with reservations on 12.06.2023. The opinion included recommendations,
outlined in the table below.
RSB Comment How the comment has been addressed
(B1) The report does not sufficiently justify why only measures for pellets are proposed at this
stage and not for other sources, given that the precautionary principle is invoked.
(C1) The report should
reinforce the narrative as
to why this impact
assessment focusses
solely on pellets given
that it states that the need
to act is justified by the
precautionary principle.
The text and structure in section 1 (pp. 10-12) was changed to clarify why
pellets are the sole focus of this initiative and highlight several factors that
justify the application of the precautionary principle and allow for immediate
action:
• Contrary to other sources of microplastics unintentionally released, for
which an EU legal framework exists or is being negotiated with the
European Parliament and the Council, there is no existing or forthcoming
EU legislation specifically preventing and reducing pellet losses as a form
of pollution occurring along the entire supply chain in the EU. The
proposal would remedy a loophole in the current EU legislative
framework;
• Sufficient evidence is available documenting the problem and the impacts,
justifying intervention and allowing the design of specific policy measures,
while this is not yet the case for most other sources of unintentionally
released microplastics;
• Contrary to other sources of microplastics unintentionally released, pellet
losses are due to poor handling and therefore largely preventable today in
a cost-effective manner. No changes to product or consumer behaviour are
required to prevent and reduce pellet losses. They are the third source of
releases and account for 7-10% of microplastics unintentionally released
in the EU.
• Techniques to prevent pellet losses are already available to economic
operators at an acceptable cost; and
• Preventing and reducing pellet losses now does not impede any future
action on other sources later, as there is no interference between the
different sources of microplastics.
The report should clarify
what additional
information would be
needed to trigger action
for the other sources of
unintentional
microplastic pollution to
improve the analysis.
The changes brought to this section of the report provide further clarity on why
the other sources were not pursued in the context of this impact assessment. In
particular, the changes point to (1) the importance of the data gaps preventing
effective policy action on paints, textiles, detergent capsules and geotextiles at
this moment in time; and (2) the existing EU legislative framework or to
legislative proposals currently being negotiated by the co-legislators which
would allow specific measures to be taken on all other identified sources. In
particular:
• the Construction Product Regulation and its proposed revision for paints
and geotextiles;
• the Euro 7 proposal for a Regulation to tackle microplastic releases from
tyres by defining abrasion limits for the placing on the market and the
existing Tyre Labelling Regulation for the labelling of tyres;
10
• the current Ecodesign Directive and the proposal for an Ecodesign for
Sustainable product regulation to address microplastics from textiles, and
possibly paints;
• delegated acts under the future revision of the Detergents Regulation to
tackle releases from detergent capsules if new scientific evidence points to
the need).
This is reflected in the updated conclusions of the preliminary analysis
undertaken for the other sources, which can be found in Box 1 & Annex 15.
(C2) The report should
discuss the contribution
of action on pellets to
solving the entire
problem of microplastics
released in the
environment, including
from the degradation of
macroplastics and define
the relative scale of the
microplastics from
pellets problem. It should
discuss if taking
measures on pellets first
would be most effective
and efficient to reach the
target of 30% reduction
of microplastics from the
Action Plan or if
measures on other
sources would be more
urgent and contribute
more to this target.
Box 6 (Contribution of the preferred option to the Zero Pollution Action Plan
target) has been added to section 8.2 (pp. 60) specifically addressing the
contribution of the ‘pellets’ proposal towards the Zero Pollution Action Plan
target. Pellet losses currently account for 7-10% of the microplastics released
into the EU environment. It is estimated that the preferred option would result
in a 60-83% decrease in these releases. Therefore, it could contribute to
achieving a quarter of the target. This is a high contribution relative to its share
of microplastic releases (up to a tenth), demonstrating why it is an effective
course of action. In addition, this reduction does not require any costly product
design changes, but rather the consistent application of existing pellet handling
best practices at all stages of the supply chain and by all actors (not just a few
as it is now). The preferred option would help bridge a regulatory and market
gap to achieve this across the supply chain.
There is potential to reduce microplastic releases from sources other than
pellets but for the reasons presented in the report, it is not appropriate to pursue
them in this initiative. However, based on the data available, a preliminary
investigation shows a high cost-effectiveness of measures to reduce pellet
losses compared to measures for the other sources (see the abatement curves
in Figures 83 and 84). Measures on pellets are clearly ‘no regret’ measures
therefore. The contribution of tyres would further need to be estimated within
the context of the EURO 7 Regulation proposal. Regarding paints, textiles,
detergent capsules and geotextiles, further data is first needed to allow for
effective measures, where necessary, to be drawn up. Only then, their
contribution to the target can be fully estimated, which can be done in the
context of relevant, upcoming impact assessments. In contrast, enough
evidence was available to justify action on pellets and estimate its contribution
to the target.
Moreover, it should
clarify if this 30% target
refers to microplastics in
general (including
degradation of
macroplastics) or if it is
for intentionally and
unintentionally added
microplastics, i.e.
excluding degradation
from macroplastics.
The introduction of the report has been reworked (pp.9) to clarify that
degradation of macroplastics is not addressed as a source in this impact
assessment. The 30% reduction target does not apply to microplastics
generated by the degradation of macroplastics improperly disposed of into the
environment. This is because it is not possible to estimate the volume of
microplastics from this source and the most effective policy action is reducing
the presence of macroplastics in the environment. The Zero Pollution Action
Plan therefore includes a 50% reduction target on marine litter which will help
contribute to tackling this source.
(C3) The report should
further discuss the
magnitude of the
environmental impact of
Further evidence has been added to the report to further explore the adverse
impacts of microplastics in the environment, on climate and on human health
both in the section 2.3 (pp. 21-24) and Annex 7. The introductory text (pp. 21)
has also been reworked to highlight the uncertainties surrounding the health
11
pellets and the reliability
of the estimates,
including reference to
scientific studies to
support anecdotal
evidence. It should
identify the potential
harmful climate and
human health impacts
from pellets specifically
and be clear about the
strength of scientific
evidence in this area,
justifying the invocation
of the precautionary
principle.
impacts of microplastics, which do not preclude the application of the
precautionary principle. Further explanations have also been provided (pp. 21)
to justify the use of studies that are more general to microplastics to explain
the harm of pellets. Indeed, there is a lack of data specific to the adverse
impacts of pellets (apart to a certain extent for those related to the ingestion of
pellets by a range of marine and costal species like sea turtles, seabirds and
shellfish),but as they are a subset of microplastics, it is assumed that most of
their impacts are comparable to those of microplastics more generally. In this
context, it should be underlined that approximately 80 % of all plastic raw
materials produced are approximately 2 mm to 5 mm in diameter, therefore
well within the usual size of microplastics (up to 5mm). Of the remaining 20%,
a significant portion is even smaller than 2 mm, such as powders, and a minor
part can be slightly bigger. In particular, the portion with the smallest size can
have an impact on health.
(B2) The design of the options does not bring out clearly all available policy choices.
(C4) The design of
options should bring out
clearly the available
policy choices. On the
one hand, the report
should identify and
clarify which actors in
the supply chain are
responsible for most
losses.
The estimated losses for the different actors in the value chain have been added
to section 2.2 (pp. 20). This IA found that logistics contribute to the most losses
(27 870 – 111 480 tonnes, followed by converters (15 600 – 46 800 tonnes),
producers (7222 – 21 665 tonnes) and recyclers (1448 – 4345 tonnes). This
results in between 52 140 tonnes and 184 290 tonnes of pellets lost to the
environment in the EU in 2019, equivalent to 0.08% to 0.28% of total pellet
volumes in the EU. A detailed table is added to Annex 8.
It should be more
specific on the measures
proposed, in particular,
on the operational
controls, the equipment
and the lighter regimes
for SMEs, and consider if
more targeted alternative
options would be feasible
regarding some of these
measures.
Box 4 (Overview of the measures and procedures included in the preferred
option) has been added to the report to provide a clear overview of the measures
included in the preferred option (pp. 56-57). It differentiates between micro-,
small, medium and large enterprises to clarify the lighter requirements
designed for small and micro- companies, in light of the concerns these firms
have raised during the consultation targeting SMEs handling plastic pellets
(producers, converters, recyclers and transporters/logistics - cf Annex 12). It
was determined that the burden would also be too significant for enterprises
with capacities below 1 000 t (the average volume handled by small
companies). The consultation also indicated that medium enterprises did not
require lighter requirements.
The design of options was based on best practices already applied in industry,
by both large companies and SMEs, in particular for Option 2 where these best
practices become mandatory requirements. In line with their current
application by the industry (e.g. under Operation Clean Sweep), these
requirements were considered a package (regrouping essential actions under
prevention, containment and clean-up) and the option of assessing each
individual requirement was not considered. The wide variety of actors in the
supply chain would make it very complicated to determine which actors could
be relieved of certain requirements, what the cost implications would be, and
what impact each of these requirements would have on pellet loss reduction.
Nevertheless, the possibility of lightening these requirements for smaller firms
was assessed due to results of the SME survey. This was done in the form of
12
sub-options under Option 2. Further reflections have since led to possible
additional lighter requirements, which are explained in box 5 (but which are
not part of the preferred option).
It should explain how
these measures go
beyond existing
environmental
management systems.
Existing environmental management systems do not explicitly cover pellet
losses. Industry’s existing voluntary scheme on pellets, Operation Clean
Sweep (OCS), is of direct relevance to pellet losses. The measures in Option 2
do not go beyond OCS’s best practices. However, OCS has been mainly taken
up by larger companies who produce pellets, meaning most of the pellets value
chain does not abide by these best practices. In addition, it is difficult to assess
the successful implementation of OCS and therefore whether it is significantly
reducing pellet losses, although some evidence shows that at certain OCS
signatories’ sites, pellet losses continue. Option 2 addresses these issues by
ensuring all actors in the supply chain are subject to these requirements (thus
preventing free riders and levelling the playing field) and enforcing
implementation of the requirements (thus reducing pellet losses to the
environment).
On the other hand, if
combinations of options
are considered necessary
to tackle all identified
problems (such as Option
1 and 2b and potentially
different requirements
within option 2b) these
should be identified up-
front and subsequently
compared to the other
options.
The description of Option 1 (pp. 36) has been updated to clarify that this Option
would be beneficial to the success of all of the other options and should feature
in the Preferred Option. This has also been clarified in Section 7 where the
different options are compared. Indeed, Option 1 should be pursued because it
addresses the information failure problem driver. Therefore, its combination
with other Options will allow for a more comprehensive response to the
identified problems. In addition, Option 1 is complementary to the other
Options as it would allow for their effective implementation. A standard
methodology is essential to monitor the implementation of Option 2 and the
evolution of pellet losses. It would facilitate the comparison of different
packaging solutions for pellets, under Option 3. It would also be a necessary
condition to set up an EU target under Option 4.
Additional wording has also been added to the description of Option 2 (pp. 37)
to clarify that lighter requirements were only considered for SMEs (sub-
options 2a, 2b and 2c) because large operators did not raise any concerns about
the economic burden of complying with mandatory requirements. Indeed, large
operators had indicated (see stakeholder consultation, the reaction of
PlasticsEurope) that implementation of such requirements would be relatively
straight forward and quick as long as they built on existing industry best
practices (e.g. Operation Clean Sweep).
(B3) The impact analysis is not sufficiently developed. The comparison of options is not based
on an assessment of their effectiveness, efficiency, coherence and proportionality.
(C5) The report should
further clarify and
develop the impact
analysis. It should
quantify the costs to
businesses related to the
implementation (testing
and reporting) of the
mandatory standardised
methodology to measure
pellet losses or better
explain why it is
The cost of reporting pellet losses is already accounted for in the REACH
restriction on pellets; this proposal brings no additional reporting costs.
Further costs related to the definition of a mandatory standardised
methodology by mandating CEN to work on a harmonised standard would be
paid by the European Commission. These costs are described under Option 1
in the range of 1.3 to 3.2 EUR million in the sections 6.1 (pp. 42) and 8.2.1
(pp. 59), in Annex 3 and Annex 11.
Again, the implementation costs incurred to use the common standard, once
this is developed and tested, are already considered under the upcoming
REACH restriction (as part of the reporting costs) and do not need to be taken
into account here as the scope of companies is basically the same (the REACH
restriction encompasses all uses, while the upcoming pellet proposal would be
13
considered that those
costs are accounted for
under the upcoming
REACH proposal given
the likely broader scope
of businesses covered by
this initiative.
limited to uses above 5 tonnes). These costs would consist of the costs for the
companies to set up specific reporting systems and for the public authority to
set up verification and evaluation systems.
It should also quantify
the costs to businesses of
the notification of the
outcomes of the
certification to
demonstrate compliance
with the defined
mandatory requirements
to prevent and reduce
pellet losses or better
explain why those costs
are considered
“minimal”.
There might also be minor reporting costs that were added to the section 6.2
(pp. 47) and in annex 11 (188 000 € per year) for the economic operators (to
notify the outcome of the certification), as reporting already exists under
REACH.
The report should make
an effort to further
quantify and monetise
the expected benefits. It
should monetise the
estimated reduction in
CO2 emission.
Due to their nature, it is very difficult to monetise the expected benefits: on the
environment through improved ecosystems and biodiversity; on the economy
through improved eco-systems services; on the sector itself via for instance
modernised equipment or reduced waste; on society via reduced costs for
monitoring or clean up. There is no data available that would allow further
quantification or monetisation of the expected benefits. However, the
estimated reduction in CO2 emissions has been monetised and added in the
section 6.2 (pp. 45), table 7 (pp. 49) and in Annex 11. Under Option 2 and its
sub-options 2a-2c, the reduction of pellet losses is expected to lead to an
emission reduction of 84 to 583 ktCO2e, leading to savings of 8 – 58 M
EUR/year.
It should also explore
whether it is possible to
monetise the expected
reduction in the spill
clean-up costs and
improvements in work
safety.
There is no data available on the costs of spill clean-ups. Pellet spills refer to
situations where pellets escape their primary containment. These spills do not
necessarily result in losses to the environment if they are contained inside the
operating boundaries. However, the costs of cleaning up spills are considered
to be minor, especially when compared to the costs of cleaning up losses (i.e.
when the pellets are no longer contained and released into the environment)
where efficiency will be much lower. Only limited anecdotal evidence is
available on the costs of pellet loss clean-ups making it impossible to
extrapolate an EU-wide estimation.
It should provide clear
overview tables of costs
and benefits. The report
should better explain the
qualitative scoring of the
environmental, economic
and social impacts. As
most of the impacts are
not monetised, it should
justify the conclusions on
The summary tables, highlighting the impacts of each policy option in section
6, have been reworked to clarify the benefit to cost assessments for each option.
These assessments are not absolute but relative to the other options to allow
for more effective comparison of the different options. Table 4 presents the
coding used to classify the impacts, and the benefit to cost ratios.
14
“Low”, “Medium” and
“High” Benefit Cost
Ratios for each option.
(C6) Once the impact
analysis is improved, the
report should compare all
relevant (combinations
of) options in terms of
effectiveness, efficiency,
coherence and
proportionality and
present this comparison
in a clear comparison
table.
The report now includes a new table 11 comparing each option’s effectiveness,
efficiency, coherence and proportionality (section 7, pp. 55). Text has also been
added to the “summary” of the assessment of the individual options’ impacts
to clarify their effectiveness, efficiency, coherence and proportionality. A
simple scoring system has been used to assess each option along the
dimensions of effectiveness, efficiency, coherence and proportionality. These
assessments are based on each option’s relative costs, economic,
environmental and social impacts, laid out in Section 6.
It should better justify the
selection of the preferred
option given the high
uncertainties around the
scale of the problem and
their impacts. These
uncertainties should be
clearly set out throughout
and included when
addressing and
qualifying the costs and
benefits of the measures.
Relevant text has been added to section 6 (pp. 40) and section 8.1 (pp. 50). The
report emphasises that the data on pellet losses is the most uncertain, and that
there is a degree of uncertainty regarding the efficiency of the measures. This
is due to a lack of reliable and comparable data on pellet losses at source. A
degree of uncertainty remains around the impact of the policy options on pellet
losses as the baseline pellet loss data is based on incomplete data, as
highlighted and addressed by the use of ranges to present pellet losses. The
preferred option includes a standardised measurement methodology to tackle
this information failure and ensure better data is available. The quantification
of the costs and comparison of different options has a higher degree of certainty
as it is based on data provided by industry which are relatively well informed
due to the existing implementation of the OCS-scheme. Therefore, the
comparison of the different options is relatively certainty as it shows, how
options rank.
When selecting the
preferred option, the
report should better
justify its proportionality.
Relevant text has been added to section 8.1 (pp. 57). The report concludes that
this preferred option is a case of formalising best practices in industry which
will have an important positive impact on the issue of microplastic releases.
Box 4 (overview of the measures and procedures included in the preferred
option) has also been added to this section to further clarify the contents of the
option, including the different regimes for different sized operators, thus
emphasising the efforts put into ensuring the preferred option is proportional.
Small and micro companies will benefit from lighter requirements to reduce
the costs of the requirements, and further schemes to support these SMEs will
be set up. Overall, the costs are low compared to the turnover of the supply
chain (estimated cost of option 2b would represent about 0.13% of the EU
plastics sector turnover), while still representing a clear cost to the smaller
firms. However, the benefits to the environment, to human health and to
affected economies and communities are undeniable. It will also be an
important contributor to the achievement of the Zero Pollution Action plan
target for a 30% reduction in microplastic releases.
It should explain how it
was concluded that the
benefits significantly
outweigh the costs given
that the monetised costs
Additional text has been added to section 8.1 (pp. 56) to clarify how the
preferred option was constructed. It sets out that the preferred option was
selected in light of the impacts of microplastics, including pellets, on the
environment and possibly health, and that the benefits of significantly reducing
microplastic releases (1/4th
) would outweigh the additional costs for industry.
15
are much higher than the
monetised benefits.
(B4) The analysis of the impacts on SMEs and EU sector competitiveness is inadequate.
(C7) The concerns of
SMEs, even for the
lighter regimes, should
be highlighted
throughout the report.
Relevant text has been added to the sections 6 (pp. 48) and 8 (pp. 60), along
with Annexes 3 and 11, to highlight the concerns raised by SMEs which were
collected during the targeted SME survey. These concerns included a lack of
staff/time, a lack of information on risks and solutions and a lack of financial
resources, making certain mandatory requirements too burdensome. The
upfront investment costs and costs per tonne of pellets handled are more
significant for SMEs, especially for micro-and small enterprises, relative to
other enterprises. References to these concerns are made throughout the report
and most notably in the sections outlining the impact of each option on SMEs.
In light of these, lighter requirements for micro- and small companies were
deemed essential to mitigating the impacts on these smaller players present
throughout the value chain. These lighter requirements also complement
existing EU programmes and support mechanisms which will help SMEs
implement these requirements (COSME, Enterprise Europe, InvestEU,
Horizon). National support could also be provided through Cohesion policy
and NEXTGEN EU.
The report should explain
why not all SMEs would
be included in the lighter
regime, in particular in
light of the response of
SME stakeholders to the
specific consultation.
Relevant text has been added to the section 8.2.2 to clarify why medium
companies have not been included in the lighter regime. The targeted SME
survey showed that it was micro & small companies who expressed the main
concerns about the burden of complying with any mandatory requirements (see
Annex 12). In addition, the cost analysis carried out in the context of this
impact assessment confirmed that the costs were much less burdensome for
medium companies. The preferred option therefore only has lighter
requirements for micro & small companies, as well as larger companies who
handle less than 1000 tonnes of pellets every year. This threshold was selected
because it corresponds to the average volume handled by small companies.
The report should
analyse the impact of the
preferred option on
international
competitiveness of the
sector as well as SME
competitiveness.
A new annex assessing the impact of the preferred option on international and
SME competitiveness (Annex 5) has been added to the report to specifically
address concerns about competitiveness. It emphasises that:
• The costs of the preferred option would represent about 0.13% of the EU
plastics sector turnover (2021 was EUR 405 billion) and are considered to
be limited.
• The additional costs are likely to have a very minor negative impact on the
international competitiveness of the EU pellet producers, as their
competitors outside the EU will not be subject to the requirements (although
logistical operators importing pellets will have to comply within the EU).
• There will be some cost savings as a result of reduced losses to the
environment (as pellets are a raw material).
• EU companies will have a first mover advantage if/when other countries
adopt similar requirements, e.g. through an international agreement such as
the Global Plastic Treaty.
• The proposal will make a positive impact on the capacity to innovate as
different actors of the value chain will develop solutions to minimise pellet
spills in order to optimise their costs for controlling pellet losses.
• The proposal includes lighter requirements for micro and small companies
and for all companies with pellet capacities below 1000t and a longer
16
implementation period for medium companies to mitigate any potential
impacts on their competitiveness, as well as support actions for SMEs.
For the development of
the measuring
methodology, full
coherence with REACH
requirements should be
further discussed.
Relevant text has been added to the section 5.2.1 to explicitly state that the
methodology will need to be fully in line with REACH requirements. In
addition, the report now clarifies that the scope of the companies covered by
the REACH reporting requirements for pellet losses is similar to this proposal
with the exception that this proposal only applies to uses above 5 tonnes.
Other
(C8) The report should
quantify the
administrative costs and
differentiate those that
are in scope of the ‘One
In, One Out’ approach.
The administrative costs for public authorities and businesses have been further
detailed in section 8.2.1 and Annex 3, where they are classified into recurrent
and one-off costs. This allows for a clearer identification of administrative
costs associated with the Commission’s one-in-one-out policy. Relevant text
has also been added to section 6.2 and in Annex 11.
The administrative costs for businesses are associated with internal
assessments, external auditing and certification. There will also be minor costs
for notifying the public authority of the certification. For micro- and small
companies (and companies with a capacity of less than 1000t/year) will be
subject to lighter requirements that are described in the new box 4. Costs for
internal assessment, external audit and/or certification and notification are
expected to be EUR 44 million: internal assessment for businesses – EUR 30.8
million; carrying out external audit and/or application for certificate – EUR
12.9 million; notification (i.e. filling forms and tables) – EUR 0.2 million;
setting up systems in businesses for administrative procedures to report pellet
losses – EUR 0.1 million (for annualised total net present value over the five
year period).
For public authorities, administrative costs, the processing costs are estimated,
including data collection, verification, correction, and enforcement to be EUR
313 000 (total annualised one-off administrative costs of EUR 36 700,
discounted at 3% over 10 years) for the first year and EUR 125 000 per year
for the whole EU. These costs will vary across Member States as it would be
higher for larger ones and lower for smaller ones.
(C9) As the report is now
focused on pellets, this
approach should be
coherently adopted in the
annexes, which should
also focus on supporting
the assessment for this
specific source.
To better reflect the scope of this report, the investigation initially undertaken
for the other sources (paints, tyres, pellets, textiles, geotextiles) has been
moved to the very last annex (Annex 15). Annex 15 can help serve as a basis
for future research into paints, pellets, textiles and geotextiles, as well as guide
future analysis and impact assessments for measures tackling microplastic
releases. Annex 15 also provides information about the relative merits of action
on pellets (compared to other sources) as asked for by the Board. The detailed
analysis in the other annexes focuses on pellets.
17
4 MAIN LITERATURE SOURCES USED
ADAC (2021) Tyre abrasion: wear and burden on the environment / 31940 RMU
Air Quality Expert Group (2019) Non-Exhaust Emissions from Road Traffic. Available from:
https://uk-
air.defra.gov.uk/assets/documents/reports/cat09/1907101151_20190709_Non_Exhaust_Emissions_
typeset_Final.pdf
AISE (2022) Report on SOLUBLE FILMS IN SINGLE-DOSE DETERGENT PRODUCTS:
Information on their purpose, technical characteristics, testing and usage (April 2022)
AISE (2020) A.I.S.E.’s pan-European habits survey 2020, 2020
AISE (2018) A.I.S.E. Pan-European Consumer Habits Survey 2017, 2018
Alava, J.J. et al. Microplastics and Macroplastic Debris as Potential Physical Vectors of SARS-CoV-
2: A Hypothetical Overview with Implications for Public Health. Microplastics 2022, 1, 156–166.
https://doi.org/10.3390/microplastics1010010
Alfonso, María B. et al. (2021) "Continental Microplastics: Presence, Features, And Environmental
Transport Pathways". Science Of The Total Environment, vol 799, 2021, p. 149447. Elsevier BV,
doi:10.1016/j.scitotenv.2021.149447. Accessed 25 Mar 2022.
Allen, S. et al. (2021) "Evidence Of Free Tropospheric And Long-Range Transport Of Microplastic
At Pic Du Midi Observatory". Nature Communications, vol 12, no. 1, 2021. Springer Science And
Business Media LLC, doi:10.1038/s41467-021-27454-7. Accessed 25 Mar 2022.
Alonso Raposo et al. (2019) The future of road transport, EUR 29748 EN, Publications Office of the
European Union, Luxembourg, 2019, ISBN 978-92-76-14319-2, doi:10.2760/524662, JRC116644.
Apostolidis, A., Kokarakis, J., & Merikas, A. (2012). Modelling the Dry-Docking Cost-The Case of
Tankers. Journal of Ship Production & Design, 28(3)
Arthur, C., Bamford, H. & Baker, J. (2009) ‘Proceedings of the International Research Workshop on
the Occurrence, Effects and Fate of Microplastic Marine Debris. Sept 9-11, 2008’. NOAA Technical
Memorandum NOS-OR&R-30.
As You Sow, ‘Plastic Pellet Pollution’, 2021 (https://www.asyousow.org/our-work/waste/plastic-
pellets).
Baensch-Baltruschat et al. / Science of the Total Environment 733 (2020) 137823
Bai, Xue et al. (2022) "Weathering Of Geotextiles Under Ultraviolet Exposure: A Neglected Source
Of Microfibers From Coastal Reclamation". Science Of The Total Environment, vol 804, 2022, p.
150168. Elsevier BV, doi:10.1016/j.scitotenv.2021.150168. Accessed 21 Mar 2022.
Bertling, Jürgen; Zimmermann, Till; Rödig, Lisa (2021) Kunststoffe in der Umwelt: Emissionen in
landwirtschaftlich genutzte Böden, Oberhausen, Fraunhofer UMSICHT 220 Seiten
18
Bhashyam, S. et al. (2021). Microplastics in the marine environment sources, impacts and
recommendations. Research@THEA
BIO by Deloitte (2014) Development of Guidance on Extended Producer Responsibility (EPR)”,
2014 by , in collaboration with Arcadis, Ecologic, Institute for European Environmental Policy
(IEEP), Umweltbundesamt (UBA).
https://www2.deloitte.com/content/dam/Deloitte/fr/Documents/sustainability-
services/deloitte_sustainability-les-filieres-a-responsabilite-elargie-du-producteur-en-europe_dec-
15.pdf
Boag et al. (1999) The pathology of interstitial lung disease in nylon flock workers. Am J Surg Pathol.
Boomerang Alliance (2015), Submission into Senate Inquiry on the Threat of Marine Plastic, October
2015
Boulter, P. G. (2006) Review of emission factors and models for road vehicle non-exhaust particulate
matter.“ Project Report PPR0065, Department for the Environment, Food and Rural Affairs, Scottish
Executive, Welsh Assembly Government, and the Department of Environment in Northern Ireland,
2006.
Brennecke, D., Duarte, B., Paiva, F., Caçador, I. and Canning-Clode (2016) J. Microplastics as vector
for heavy metal contamination from the marine environment. Estuar. Coast. Shelf Sci. 2016, 178,
189–195.
Byrne, Dominic et al. (2021) "Biodegradability Of Polyvinyl Alcohol Based Film Used For Liquid
Detergent Capsules". Tenside Surfactants Detergents, vol 58, no. 2, 2021, pp. 88-96. Walter De
Gruyter Gmbh, doi:10.1515/tsd-2020-2326. Accessed 16 Nov 2021
BSI Knowledge, ‘Plastic pellets, flakes and powders. Handling and management throughout the
supply chain to prevent their leakage to the environment. Specification - PAS 510:2021101’, 2021
().
Cai Y, Mitrano DM, Heuberger M, Hufenus R, Nowack B (2020) The origin of microplastic fiber in
polyester textiles: The textile production process matters, Journal of Cleaner Production
California Assembly (2020), A.B. 1952.
California Assembly (2018), A.B. 129.
California Environmental Protection Agency, ‘Preproduction Plastic Debris Program’, 2008
(https://www.waterboards.ca.gov/water_issues/programs/stormwater/plasticdebris.shtml).
Carneiro, José Ricardo et al., 2018, "Laboratory Evaluation Of Interactions In The Degradation Of
A Polypropylene Geotextile In Marine Environments". Advances In Materials Science And
Engineering, vol 2018, 2018, pp. 1-10. Hindawi Limited, doi:10.1155/2018/9182658. Accessed 28
Mar 2022.
CBD – Secretariat of the Convention on Biological Diversity and the Scientific and Technical
Advisory Panel – GEF (2012): Impacts of Marine Debris on Biodiversity: Current Status and
Potential Solutions. In: CBD Technical Series No. 67, 61 pages.
19
CEDR (2016) Management of contaminated runoff water: current practice and future research needs
Chand, R.; Rasmussen, L.A.; Tumlin, S.; Vollertsen, J. (2021) The occurrence and fate of
microplastics in a mesophilic anaerobic digester receiving sewage sludge, grease and fatty slurries,
Science of the Total Environment 2021, 798, 149287
Changing Markets Foundation (2021) Fossil fashion, 2021
Chronopoulos G., Cakmak, G. E., Tempany, P., Klein, G., Brinkmann, T., Zerger, B., & Roudier, S.
Best Available Techniques (BAT) Reference Document on Surface Treatment Using Organic
Solvents including Preservation of Wood and Wood Products with Chemicals.)CircularInnoBooster
Fashion and Textile project (2021) Second-hand fashion, a new impetus for clothing consumption,
2021
Cole, M.; Lindeque, P.; Halsband, C. & T.S. Galloway (2011): Microplastics as contaminants in the
marine environment: A review. In: Marine Pollution Bulletin 62: 2588-2597
Draft COMMISSION REGULATION (EU) …/… of XXX amending Annex XVII to Regulation
(EC) No 1907/2006 of the European Parliament and of the Council concerning the Registration,
Evaluation, Authorisation and Restriction of Chemicals (REACH) as regards synthetic polymer
microparticles. Comitology Register (europa.eu), Accessed on 15 March 2023.
Connecticut, S. (2018), Substitute House Bill No. 5360,
http://www.cga.ct.gov/2018/ACT/pa/2018PA-00181-R00HB-05360-PA.htm.
Correia Prata Joana, João P. da Costa, Armando C. Duarte, Teresa Rocha-Santos (2019) Methods for
sampling and detection of microplastics in water and sediment: A critical review, TrAC Trends in
Analytical Chemistry, Volume 110, 2019, Pages 150-159, ISSN 0165-9936,
https://doi.org/10.1016/j.trac.2018.10.029.
Cox et al. (2020) Human consumption of microplastics. Environ. Sci. Technol. 2019, 53, 12, 7068–
7074
Danopoulos, E., Twiddy, M., West, R., & Rotchell, J. (2022). A rapid review and meta-regression
analyses of the toxicological impacts of microplastic exposure in human cells. Journal Of Hazardous
Materials, 427, 127861. doi: 10.1016/j.jhazmat.2021.127861
DAWE (2021), National Plastics Plan 2021.
Décret no 2021-461 du 16 avril 2021 relatif à la prévention des pertes de granulés de plastiques
industriels dans l’environnement.
Deltares and TNO (2016) Emissieschattingen Diffuse bronnen Emissieregistratie - Bandenslijtage
wegverkeer
Diaz et al. (2020) European vehicle market statistics 2020/21
Dibke et al. (2021) Microplastic Mass Concentrations and Distribution in German 39 Waters by
Pyrolysis–Gas Chromatography–Mass Spectrometry/Thermochemolysis Reveal Potential Impact of
Marine Coatings: Do Ships Leave Skid Marks? https://doi.org/10.1021/acs.est.0c04522
20
Directive 2010/75/EU on industrial emissions (integrated pollution prevention and control) (recast)
Dixon, N. et al. (2016) "Sustainability Aspects Of Using Geotextiles". Geotextiles, 2016, pp. 577-
596. Elsevier, doi:10.1016/b978-0-08-100221-6.00026-7. Accessed 4 May 2022.
Dris et al. (2017) A first overview of textile fibres, including microplastics, in indoor and outdoor
environments. Environ Pollut.
Dris et al. (2015) Microplastic contamination in an urban area: a case study in Greater Paris.
Environmental Chemistry.
Dutch Government (2020), “Towards Osaka Blue Ocean Vision: G20 Implementation Framework
for Actions on Marine Plastic Litter” https://www.naturvardsverket.se/amnesomraden/plast/om-
plast/mikroplast/
Dutch Ministry of Infrastructure and Water Management, ‘Monitoring of pellets and mesoplastic
fragments on Dutch beaches in 2021: a pilot study‘, 2022
(https://puc.overheid.nl/rijkswaterstaat/doc/PUC_721767_31/1/)
Dusza, H.M. et al, ‘Uptake, Transport, and Toxicity of Pristine and Weathered Micro- and
Nanoplastics in Human Placenta Cells’, Environmental Health Perspectives, Vol; 130, No 9, 2022
(https://ehp.niehs.nih.gov/doi/10.1289/EHP10873).
EC Group of Chief Scientific Advisors (2019) Environmental and health risks of microplastic
pollution
ECHA (2022) "Microplastics - ECHA". Echa.Europa.Eu, 2022, Microplastics - ECHA (europa.eu)
Accessed 14 Apr 2022.
EDANA (2022) "Nonwovens Markets". Default, 2022, https://www.edana.org/nw-related-
industry/nonwovens-markets. Accessed 21 Mar 2022.
EEA (2019) ETC/WMGE, Textiles and the environment in a circular economy, November 2019
Emission Analytics / PEW report (2022) - Research report - Tire chemical composition and wear
emissions
Еsiukova, Elena & Chubarenko, Boris & Simon, Franz. (2018). Debris of geosynthetic materials on
the shore of South-Eastern Baltic (Kaliningrad Oblast, Russian Federation).
Essel, Roland et al. (2014) Sources of microplastics relevant to marine protection, Report for Federal
Environment Agency (Germany), November 2014
Expertmarketresearch.Com (2022) “Global Plastic Market Report And Forecast 2022-2027”.
https://www.expertmarketresearch.com/reports/plastic-market. Accessed 24 Mar 2022.
ETRMA. (2019) Circular Economy. Available at: https://www.etrma.org/key-topics/circular-
economy/
21
ETRMA. (2018) End of Life Tyres Management – Europe 2018 Status: https://www.etrma.org/wp-
content/uploads/2020/09/Copy-of-ELT-Data-2018-002.pdf
Eunomia (2016), Report for Fidra on Study to Quantify Pellet Emissions in the UK, March
2016GESAMP. (2015). Microplastics in the ocean. A global assessment. GESAMP, The Joint Group
of Experts on Scientific Aspects of Marine Environmental Protection, Working Group 40.
EurEau, ‘Microplastics and the water sector’, 2019 (https://www.eureau.org/resources/briefing-
notes/3940-briefing-note-on-microplastics-and-the-water-sector/file); Koelmans, A., Hazimah
Mohamed Nor, N., Hermsen, E., Kooi, M. et al., ‘Microplastics in freshwaters and drinking water:
Critical review and assessment of data quality‘, Water Research, Vol. 155, 2019, pp. 410-422.
European Chemicals Agency, Opinion of the Committee for Risk Assessment and Opinion of the
Committee for Socio-economic Analysis on an Annex XV dossier proposing restrictions on
intentionally-added microplastics, ECHA/RAC/RES-O-0000006790-71-01/F and
ECHA/SEAC/RES-O-0000006901-74-01/F, 2020, p.49
(https://echa.europa.eu/documents/10162/a513b793-dd84-d83a-9c06-e7a11580f366).
European Commission, Commission evaluation – Water pollution: EU rules on urban wastewater
treatment (update), 2022 (https://ec.europa.eu/info/law/better-regulation/have-your-
say/initiatives/12405-Water-pollution-EU-rules-on-urban-wastewater-treatment-update-_en).
European Commission (2020) Regulation (EU) 2020/740 of the European Parliament and of the
Council of 25 May 2020 on the labelling of tyres with respect to fuel efficiency and other parameters,
amending Regulation (EU) 2017/1369 and repealing Regulation (EC) No 1222/2009 (Text with EEA
relevance)
European Commission (2019) Commission staff working document. Evaluation of the Council
Directive 91/271/EEC of 21 May 1991, concerning urban waste-water treatment {SEC(2019) 448
final} - {SWD(2019) 701 final}. https://ec.europa.eu/environment/water/water-
urbanwaste/pdf/UWWTD%20Evaluation%20SWD%20448-701%20web.pdf
European Commission (2019) Review study on household tumble driers, June 2019
European Commission (2018) SWD 254 final Commission Staff Working Document: Reducing
Marine Litter: action on single use plastics and fishing gear, Accompanying the document « Proposal
for a Directive of the European Parliament and of the Council on the reduction of the impact of certain
plastic products on the environment »
European Commission/Eunomia (2016), Report to DG Environment on Study to support the
development of measures to combat a range of marine litter sources, January 2016
European Committee for Standardization (2012) EN 12226, Geosynthetics—General Tests for
Evaluation following Durability Testing, European Committee for Standardization, Brussels,
Belgium, 2012.
European Committee for Standardization (2004) EN ISO 13438, Geotextiles and Geotextile-Related
Products-Screening Test Method for Determining the Resistance to Oxidation, European Committee
for Standardization, Brussels, Belgium, 2004.
22
European Committee for Standardization (2001) EN 12447, Geotextiles and Geotextile-Related
Products-Screening Test Method for Determining the Resistance to Hydrolysis in Water, Brussels,
Belgium, 2001.
European Committee for Standardization (2001) EN 14030, Geotextiles and Geotextile-Related
Products-Screening Test Method for Determining the Resistance to Acid and Alkaline Liquids,
European Committee for Standardization, Brussels, Belgium, 2001.
European Committee for Standardization (2000) EN 12224, Geotextiles and Geotextile-Related
Products-Determination of the Resistance to Weathering, European Committee for Standardization,
Brussels, Belgium, 2000.
European Environment Agency, ‘Microplastics from textiles: Towards a circular economy for
textiles in Europe’, 2022 (https://www.eea.europa.eu/publications/microplastics-from-textiles-
towards-a).
European TRWP Platform (2019) Way Forward Report
Eurostat data on number of companies in the production of plastic in primary forms and turnover
(https://ec.europa.eu/eurostat/databrowser/view/SBS_SC_OVW__custom_5884920/default/table?la
ng=en).
Federal Ministry of Food and Agriculture (2021) BioSinn – Products for Which Biodegradation
makes sense, Renewable Carbon publication, edited in May 2021
Fibre2Fashion (2017), Man-made fibres driving growth
Folkö Amanda (2015) Quantification and characterization of fibres emitted from common synthetic
materials during washing, Report for Käppala, 2015.
French Senate (2021) Amendement n°2143 au projet de loi relatif à la lutte contre le dérèglement
climatique, 10 juin 2021
Gebbe et al. (1997) Quantifizierung des Reifenabriebs von Kraftfahrzeugen in Berlin
Geilenkirchen et al. (2020) Methods for calculating the emissions of transport in the Netherlands
German Federal Ministry for Economic Cooperation and Development (2019), Circular Economy in
the Textile Sector
Gewert B, Plassmann MM, MacLeod M. 2015. Pathways for degradation of plastic polymers floating
in the marine environment. Environ Sci Process Impacts 17:1513–1521
Good Karma Projects, New report out exposes alarming impacts of plastic pellets across Europe,
2020 (https://goodkarmaprojects.org/2020/11/20/new-report-out-exposes-alarming-impacts-of-
plastic-pellets-across-europe/?lang=en).
Grand View Research Inc (2022) Geotextiles Market Size & Share, |Industry Report, 2020-2027.
(2022). Retrieved 6 January 2022, from https://www.grandviewresearch.com/industry-
analysis/geotextiles-industry
23
Grand View Research Inc (2014) https://www.estormwater.com/grand-view-research-forecasts-
global-geotextiles-market
Grigoratos T, Martini G. (2014) Non-exhaust traffic related emissions – Brake and tyre wear PM.
EUR 26648. Luxembourg (Luxembourg): Publications Office of the European Union; 2014.
JRC89231Kosuth et al., (2018) Anthropogenic contamination of tap water, beer, and sea salt,
https://doi.org/10.1371/journal.pone.0194970
Group of Chief Scientific Advisors, Scientific opinion on the environmental and health risks of
microplastic pollution, April 2019.
Hann et al. (2018) Investigating options for reducing releases in the aquatic environment of
microplastics emitted by (but not intentionally added in) products
Hollman, P.C.H.; Bouwmeester, H.; Peters, R.J.B. (2013) Microplastics in Aquatic Food Chain:
Sources, Measurement, Occurrence and Potential Health Risks; RIKILT-Institute of Food Safety:
Wageningen, The Netherlands, 2013; No. 2013.003.
Hurley, R., & Nizzetto, L., ‘Fate and occurrence of micro(nano)plastics in soils: Knowledge gaps
and possible risks’, Current Opinion in Environmental Science & Health, Vol. 1, 2018, pp. 6-11,
Elsevier BV.
International Baltic Earth Secretariat (2020) 3rd Baltic Earth Conference Earth system changes and
Baltic Sea coasts, accessed October 15, 2021
International Pellet Watch - Where can we find the plastic resin pellets? (pelletwatch.org/where)
International Union for Conservation of Nature, ‘Primary Microplastics in the Oceans: A Global
Evaluation of Sources’, 2017 (https://portals.iucn.org/library/sites/library/files/documents/2017-
002-En.pdf).
ISO (2020) ISO 22182 :2020, Geotextiles and geotextile-related products — Determination of index
abrasion resistance characteristics under wet conditions for hydraulic applications
IUCN (2017), Primary Microplastics in the Oceans: A Global Evaluation of Sources, February 2017
IUCN (2016) Biodiversity Risk and Opportunities in the Apparel Sector
Jenner et al. (2022) Detection of microplastics in human lung tissue using μFTIR spectroscopy.
Science of The Total Environment, Volume 831
Johannesson, M., & Lithner, D. (2022). Potential policy instruments and measures against
microplastics from tyre and road wear: mapping and prioritisation
Joint Group of Experts on the Scientific Aspects of Marine Environmental Protection (GESAMP),
Global assessment on microplastics in the ocean, Joint Group of Experts on Scientific Aspects of
Marine Environmental Protection, 2015.
JRC (2019) Best available techniques (BAT) Reference Document for the Textiles Industry, 2019
24
JRC (2014) Environmental Improvement Potential of textiles (IMPRO Textiles), January 2014.
Julinova M. et al. (2018) Water-soluble polymeric xenobiotics – Polyvinyl alcohol and
polyvinylpyrrolidon – And potential solutions to environmental issues: A brief review J. Environ.
Management 2018, 218, p. 6027
K 2022 - Trend Report Europe https://www.k-
online.com/en/Media_News/Press/Technical_article/K_2022_-_Trend_Report_Europe
Kieran D. Cox, Garth A. Covernton, Hailey L. Davies, John F. Dower, Francis Juanes, and Sarah E.
Dudas (2019) Human Consumption of Microplastics. Environmental Science & Technology 2019 53
(12), 7068-7074 DOI: 10.1021/acs.est.9b01517
KIMO, ‘Plastic pellets spill pollutes Danish, Norwegian, Swedish coastlines’, 2020
(https://www.kimointernational.org/news/plastic-pellets-spill-pollutes-danish-norwegian-swedish-
coastlines/).
Kole PJ, Löhr AJ, Van Belleghem FGAJ, Ragas AMJ (2017). Wear and Tear of Tyres: A Stealthy
Source of Microplastics in the Environment. Int J Environ Res Public Health. 2017;14(10):1265.
Published 2017 Oct 20. doi:10.3390/ijerph14101265
Klein et al. (2019) Methods for calculating the emissions of transport in the Netherlands.
Kreider, Marisa L., Julie M. Panko, Britt L. McAtee, Leonard I. Sweet, und Brent L. Finley (2010)
Physical and chemical characterization of tire-related particles: Comparison of particles generated
using different methodologies.“ Science of The Total Environment, Vol. 408, 2010: 652-659
Lacroix C. et Huvet A. (2019) Table ronde n°1 : Devenir et gestion dans les ports et les milieux
littoraux – introduction scientifique : caractérisation de la pollution et risques associés. Conférence
Journée Plastiques et Environnement 27-28 juin 2019
Lares, Mirka et al. (2018) "Occurrence, Identification And Removal Of Microplastic Particles And
Fibers In Conventional Activated Sludge Process And Advanced MBR Technology". Water
Research, vol 133, 2018, pp. 236-246. Elsevier BV, doi:10.1016/j.watres.2018.01.049. Accessed 22
Oct 2021.
Lassen, C., S. Foss Hansen, K. Magnusson, F. Norén, N. I. Bloch Hartmann, P. Rehne Jensen, T.
Gissel Nielsen and A. Brinch (2015). Microplastics - Occurrence, effects and sources of releases to
the environment in Denmark.
Lechner, Aaron, and David Ramler (2015) "The Discharge Of Certain Amounts Of Industrial
Microplastic From A Production Plant Into The River Danube Is Permitted By The Austrian
Legislation". Environmental Pollution, vol 200, 2015, pp. 159-160. Elsevier BV,
doi:10.1016/j.envpol.2015.02.019. Accessed 28 Mar 2022.
Lei, L.; Hu, X.; Yue, P.L.; Bossmann, S.H.; Göb, S.; Braun, A.M. (1998) Oxidative degradation of
poly vinyl alcohol by the photochemically enhanced Fenton reaction. J. Photochem. Photobiol. A
Chem. 1998, 116, 159–166.
25
Leslie, H.A., (2014) Review of microplastics in cosmetics. Scientific background on a potential
source of plastic particulate marine litter to support decision-making. V.U. Institute for
Environmental Studies, Amsterdam.
Leslie, Heather A. et al. (2022) “Discovery And Quantification Of Plastic Particle Pollution In
Human Blood”. Environment International, 2022, p. 107199. Elsevier BV,
doi:10.1016/j.envint.2022.107199. Accessed 28 Mar 2022.
Li, J.; Zhang, K.; Zhang, H. (2018) Adsorption of antibiotics on microplastics. Environ. Pollut. 2018,
237, 460–467.
Loubet et al. (2021) Life cycle inventory of plastics losses from seafood supply chains:Methodology
and application to French fish products. Science of the Total Environment
Lyn, T.E., ‘Sinopec pledges help to clear Hong Kong plastic spill’, Reuters, 2012
(https://www.reuters.com/article/us-pollution-hongkong-sinopec-idUSBRE8780I920120809).
https://www.reuters.com/article/us-pollution-hongkong-sinopec-idUSBRE8780I920120809
Maisner et al. (2019) Geosynthetics in traffic infrastructure construction in contact with groundwater
and surface water – Environmental aspects. Georesources Journal (special issue)
Marketsandmarkets (2022) "Geotextile Market Size & Share | Global Industry Forecast To 2022&|
Marketsandmarkets". Marketsandmarkets.Com, 3399,
https://www.marketsandmarkets.com/Market-Reports/geotextiles-market-492.html. Accessed 21
Mar 2022.
Mason, Sherri A. et al. (2018) “Synthetic Polymer Contamination In Bottled Water”. Frontiers In
Chemistry, vol 6, 2018. Frontiers Media SA, doi:10.3389/fchem.2018.00407. Accessed 25 Mar 2022.
Mato Y, Isobe T, Takada H, Kanehiro H, Ohtake C, Kaminuma T. (2001). Plastic resin pellets as a
transport medium for toxic chemicals in the marine environment.
Methacanon, P., Weerawatsophon, U., Sumransin, N., Prahsarn, C., & Bergado, D. (2010). Properties
and potential application of the selected natural fibers as limited life geotextiles. Carbohydrate
Polymers, 82(4), 1090-1096. doi: 10.1016/j.carbpol.2010.06.036
Miao, Lingzhan, Peifang Wang, Jun Hou, Yu Yao, Zhilin Liu, Songqi Liu, Tengfei Li, Distinct
community structure and microbial functions of biofilms colonizing microplastics, Science of The
Total Environment, Volume 650, Part 2, 2019, Pages 2395-2402, ISSN 0048-9697,
https://doi.org/10.1016/j.scitotenv.2018.09.378.
Ministry of Environment and Food of Denmark; Microplastics: Occurrence, effects and sources of
releases to the environment in Denmark, Environmental project No. 1793, 2015
Miszkowska A, Lenart, A & Koda, E. (2017) Changes of Permeability of Nonwoven Geotextiles due
to Clogging and Cyclic Water Flow in Laboratory Conditions doi:10.3390/w9090660
Müller, Werner W, and Fokke Saathoff (2015) "Geosynthetics In Geoenvironmental Engineering".
Science And Technology Of Advanced Materials, vol 16, no. 3, 2015, p. 034605. Informa UK
Limited, doi:10.1088/1468-6996/16/3/034605. Accessed 21 Mar 2022.
26
Nola.com, ‘No cleanup planned as millions of plastic pellets wash up along Mississippi River and
flow to the Gulf’, 2020 (https://www.nola.com/news/environment/article_b4fba760-e18d-11ea-
9b0b-b3a2123cf48b.html).
Nova Institute (2023) Bio-based Building Blocks and Polymers Global Capacities, Production and
Trends 2022–2027 https://renewable-carbon.eu/publications/product/bio-based-building-blocks-
and-polymers-global-capacities-production-and-trends-2022-2027-short-version-pdf/
OCS (2019) OCS-Progress-Report-2019-Web-LR-151020.pdf (opcleansweep.eu)
Norén, F. & Ekendahl, S. (2009) Microscopic Anthropogenic Particles in Swedish Waters: many
more than believed. Schwerin, Germany: Helsinki Commission
OECD (2022) Global Plastics Outlook: Policy Scenarios to 2060
OECD (2021) Policies to Reduce Microplastics Pollution in Water: Focus on Textiles and Tyres
https://www.oecd-ilibrary.org/environment/policies-to-reduce-microplastics-pollution-in-
water_7ec7e5ef-en
OECD (2021) Modulated fees for Extended Producer Responsibility schemes (EPR), OECD
Environment Working Papers No. 184
OECD (2020) Non-exhaust Particulate Emissions from Road Transport
OECD (2009) Emission Scenario Document On Adhesive Formulation, 2009
OPC Clean Sweep - www.opcleansweep.eu
OSPAR (2021) Guidelines in support of Recommendation 2021/06 on the reduction of plastic pellet
loss into the marine environment https://www.ospar.org/documents?v=46269
OSPAR (2018) Background document on pre-production plastic pellets, 2018,
https://www.ospar.org/documents?v=39764. Accessed 12 Apr 2022.
OSPAR (2017) Assessment document of land-based inputs of microplastics in the marine
environment, 2017. Accessed March 28, 2022, from: https://www.ospar.org/documents?v=38018
Partow, H.L., C., Le Floch, S., & Alcaro, L. (2021) X-PRESS PEARL MARITIME DISASTER SRI
LANKA REPORT OF THE UN ENVIRONMENTAL ADVISORY MISSION JULY 2021. 2021,
UN Environmental Advisory Mission
Paruta et al. (2022) Plastic Paints the Environment, EAEnvironmental Action 2022, ISBN 978-2-
8399-3494-7
Peano et al. (2020) Plastic Leak Project. Methodological Guidelines.
Persson et al. (2022) Outside the Safe Operating Space of the Planetary Boundary for Novel Entities.
(2022). Environmental Science & Technology. Retrieved from
https://pubs.acs.org/doi/10.1021/acs.est.1c04158
27
Pew Research (2022) Emission Analytics / PEW report (2022) - Research report - Tire chemical
composition and wear emissions
Pew Research (2020) Breaking the waves, Pew Charitable Trusts and SystemiQ
https://www.systemiq.earth/wp-
content/uploads/2020/07/BreakingThePlasticWave_MainReport.pdf
Pimentel et al. (1975) Respiratory disease caused by synthetic fibres: a new occupational disease.
Thorax 30
"Plastic Pellets — As You Sow". As You Sow, 2021, https://www.asyousow.org/our-
work/waste/plastic-pellets. Accessed 21 Oct 2021.
Plastics Europe (2017) Operation Clean Sweep® Report
Plastics Europe (2021) Plastics the Facts https://plasticseurope.org/wp-
content/uploads/2021/12/Plastics-the-Facts-2021-web-final.pdf
Plastics Recyclers Europe, Plastics Recycling Industry in Europe: Mapping of Installed Plastics
Recycling Capacities 2021 Data, 2023
Plastic Soup Foundation _ Do clothes make us sick? 2022
Prambauer, M., Wendeler, C., Weitzenböck, J., & Burgstaller, C. (2019). Biodegradable geotextiles
– An overview of existing and potential materials. Geotextiles And Geomembranes, 47(1), 48-59.
doi: 10.1016/j.geotexmem.2018.09.006
Prata et al., Methods for sampling and detection of microplastics in water and sediment: A critical
review, TrAC Trends in Analytical Chemistry, 2019, 110: 150-159.
Qing-Zhou Wang, Nan-Nan Wang, Ming-Lang Tseng, Yu-Man Huang, Ning-Li Li, (2019) Waste
Tire Recycling Assessment: Road Application Potential and Carbon Emissions Reduction Analysis
of Crumb Rubber Modified Asphalt in China, Journal of Cleaner Production (2019),
https://doi.org/10.1016/j.jclepro.2019.119411
Ragusa, Antonio et al. (2021) “Plasticenta: First Evidence Of Microplastics In Human Placenta”.
Environment International, vol 146, 2021, p. 106274. Elsevier BV,
doi:10.1016/j.envint.2020.106274. Accessed 28 Mar 2022.
RDC Environment (2000) Emploi et investissements liés aux activités de collecte sélective, tri et
recyclage des projets FOST PLUS, 2000
République Française (2021) Décret no 2021-461 du 16 avril 2021 relatif à la prévention des pertes
de granulés de plastiques industriels dans l’environnement.
Rethink Plastic alliance (2021) PLASTIC PELLETS UNDER REACH: Strengthening requirements
to enable effective supply chain legislation, Position Paper, March 2021,
https://rethinkplasticalliance.eu/wp-content/uploads/2021/04/plastic_pellets_under_reach.pdf
Accessed 14 April, 2022.
28
Revell et al., Direct radiative effects of airborne microplastics, Nature, 2021, 598: 462–467. Center
for International Environmental Law (CIEL) (2019). Plastic & Climate: The Hidden Costs of a Plastic
Planet
Rochman (2019) Rethinking microplastics as a diverse contaminant suite – Environmental
Toxicology and Chemistry – Wiley Online Library
Rockström, J., W. Steffen, K. Noone, Å. Persson, F. S. Chapin, III, E. Lambin, T. M. Lenton, M.
Scheffer, C. Folke, H. Schellnhuber, B. Nykvist, C. A. De Wit, T. Hughes, S. van der Leeuw, H.
Rodhe, S. Sörlin, P. K. Snyder, R. Costanza, U. Svedin, M. Falkenmark, L. Karlberg, R. W. Corell,
V. J. Fabry, J. Hansen, B. Walker, D. Liverman, K. Richardson, P. Crutzen, and J. Foley. 2009.
Planetary boundaries:exploring the safe operating space for humanity. Ecology and Society 14(2):
32. [online] URL: http://www.ecologyandsociety.org/vol14/iss2/art32/
Rodrigues et al., Microplastic contamination in an urban estuary: Abundance and distribution of
microplastics and fish larvae in the Douro estuary, Science of The Total Environment, 2019, 659:
1071-1081.
Rolsky, Charles, and Varun Kelkar (2021). "Degradation Of Polyvinyl Alcohol In US Wastewater
Treatment Plants And Subsequent Nationwide Emission Estimate". International Journal Of
Environmental Research And Public Health, vol 18, no. 11, 2021, p. 6027. MDPI AG,
doi:10.3390/ijerph18116027. Accessed 16 Nov 2021.
Royer, Sarah-Jeanne et al. “Production Of Methane And Ethylene From Plastic In The Environment”.
PLOS ONE, vol 13, no. 8, 2018, p. e0200574. Public Library Of Science (Plos),
doi:10.1371/journal.pone.0200574. Accessed 28 Mar 2022.
Ryan, P. G. (2008) ‘Seabirds indicate changes in the composition of plastic litter in the Atlantic and
south-western Indian Oceans’. Marine Pollution Bulletin
Ryberg, Morten W. et al. (2019) “Global Environmental Losses Of Plastics Across Their Value
Chains”. Resources, Conservation And Recycling, vol 151, 2019, p. 104459. Elsevier BV,
doi:10.1016/j.resconrec.2019.104459. Accessed 25 Mar 2022.
Sanad, R. A. (2016). Consumer attitude and purchase decision towards textiles and apparel products.
World, 2(2016), 16-30.
Scholz, Philipp et al. (2021) "Environmental Impact Of Geosynthetics In Coastal Protection".
Materials, vol 14, no. 3, 2021, p. 634. MDPI AG, doi:10.3390/ma14030634. Accessed 21 Mar 2022.
Schonberger, H.; Baumann, A.; Keller, W. (1997) Study of microbial degradation of polyvinyl
alcohol (PVA) in wastewater treatment plants. Am. Dyest. Report. 1997, 86, 9–18.
Schwabl, Philipp et al. (2019) “Detection Of Various Microplastics In Human Stool”. Annals Of
Internal Medicine, vol 171, no. 7, 2019, pp. 453-457. American College Of Physicians,
doi:10.7326/m19-0618. Accessed 28 Mar 2022.
Schymanski et al., (2018), Analysis of microplastics in water by micro-Raman spectroscopy: Release
of plastic particles from different packaging into mineral water,
https://doi.org/10.1016/j.watres.2017.11.011
29
Seas at Risk (seas-at-risk.org) - Microplastic pollution in the marine environment and its climate
implications: how to overcome the impacts?
Secretariat of the Convention on Biological Diversity, ‘Impacts of marine debris on biodiversity:
Current status and potential solutions’, CBD Technical Series, No 67, 2012.
Sheavly et al. (2007) Marine Debris & Plastics: Environmental Concerns, Sources, Impacts and
Solutions
Shopova et al., ‘Risk assessment and toxicological research on micro- and nanoplastics after oral
exposure via food products’, EFSA Journal, 2020 https://doi.org/10.2903/j.efsa.2020.e181102
Sivan A. 2011. New perspectives in plastic biodegradation. Curr Opin Biotechnol 22:422–426
SOLAS(2002) Chapter VII. Carriage Of Dangerous Goods". Rise.Odessa.Ua, 2022
http://rise.odessa.ua/texts/solas02_glVIIe.php3. Accessed 12 Apr 2022.
Sommer, F., Dietze, V., Baum, A., Sauer, J., Gilge, S., Maschowski, C. and Gieré, R. (2018). Tire
Abrasion as a Major Source of Microplastics in the Environment. Aerosol Air Qual. Res. 18: 2014-
2028. https://doi.org/10.4209/aaqr.2018.03.0099Sun et al. (2019) Microplastics in wastewater
treatment plants: Detection, occurrence and removal. Water Research
SQAS (2022) Questionnaire and Guidelines, 2022, Accessed April 15, 2022, from:
https://www.sqas.org/downloads/core2022/SQAS%202022%20Core%20Questionnaire%20and%2
0Guidelines%20(English).docx
Sun, W.; Chen, L.; Wang, J. (2017) Degradation of PVA (polyvinyl alcohol) in wastewater by
advanced oxidation processes. J. Adv. Oxid. Technol. 2017, 20.
Sundt, P.; Schulze, P-E.; Syversen, F. (2014) Sources of microplastics-pollution to the marine
environment. Norwegian Environment Agency (Miljødirektoratet)
Surfrider Foundation Europe, Rethink Plastic, 2020. “Plastic giants polluting through the back door”
TextileMission (2021) Microplastics of Textile Origin - A Holistic View: Optimized Processes and
Materials, Material Flows and Environmental Behavior, https://bmbf-plastik.de/en/joint-
project/textilemission
The Guardian, ‘Sri Lanka faces disaster as burning ship spills chemicals on beaches’, 2021
(https://www.theguardian.com/world/2021/may/31/sri-lanka-faces-disaster-burning-ship-spills-
chemicals-beaches).
"The Industrial Emissions Directive - Environment - European Commission". Ec.Europa.Eu, 2022,
https://ec.europa.eu/environment/industry/stationary/ied/evaluation.htm. Accessed 14 Apr 2022.
The Nature Conservancy, Bain & Company (2021) Toward eliminating pre-consumer emissions of
microplastics from the textile industry, 2021
30
Timothy Elliott, R. B., Chiarina, D., Laurence, E., Chris, S., Ayesha, B., Mathilde, B., & Hilton, M.
(2018). Assessment of measures to reduce marine litter from single-use plastics. ICF Consulting
Services Limited and Eunomia, M. European Commission, Brussels
Tromp, Peter et al. (2021) Comparison and improvement of analytical techniques for quality data on
TWP in the environment / Setac Europe 2021
Turner A. (2021) Paint particles in the marine environment: An overlooked component of
microplastics, https://doi.org/10.1016/j.wroa.2021.100110)
Two Oceans Aquarium, ‘The Great Nurdle Disaster: What to do if you find nurdles’, 2017
(https://www.aquarium.co.za/blog/entry/the-great-nurdle-disaster-what-to-do-if-you-find-nurdles).
https://www.aquarium.co.za/blog/entry/the-great-nurdle-disaster-what-to-do-if-you-find-nurdles
TyreWearMapping (2021) Digitales Planungs- und Entscheidungsinstrument zur Verteilung,
Ausbreitung und Quantifizierung von Reifenabrieb in Deutschland. Final Report 19F2050A-C
UN Environment (2018) Mapping of global plastics value chain and plastics losses to the
environment with a particular focus on marine environment
United Nations Environment Programme, ‘X-Press pearl maritime disaster Sri Lanka – Report of the
UN Environmental Advisory Mission’, 2021 (https://www.unep.org/resources/report/x-press-pearl-
maritime-disaster-sri-lanka-report-un-environmental-advisory-mission).
US Congress (2021) Break Free from Plastic Pollution Act of 2021, accessed October 21, from: Text
- H.R.2238 - 117th Congress (2021-2022): Break Free From Plastic Pollution Act of 2021 |
Congress.gov | Library of Congress
US Department of Agriculture (1995) Geotextiles, A special Application of biofibers Retrieved 13
January 2022, from https://www.fpl.fs.fed.us/documnts/pdf1995/engli95a.pdf
US Environmental Protection Agency, ‘Industrial Stormwater fact sheet: Sector Y: Rubber,
Miscellaneous Plastic Products, and Miscellaneous Manufacturing Industries’, 2006
(https://www3.epa.gov/npdes/pubs/sector_y_rubberplastic.pdf).
USEPA (1992) Plastic Pellets in the Aquatic Environment: Sources and Recommendations
Venghaus et al. (2021) RAU - "Reifenabrieb in der Umwelt" Abschlusskonferenz "Plastik in der
Umwelt" (20./21.04.2021)
Venghaus et al. (2021) Report "Tire Wear in the environment - RAU" Berlin, 2021 BMBF-Vorhaben,
Förderkennzeichen 13NKE011A
Verschoor A.J. and E. de Valk, RIVM (2017) Potential measures against microplastic emissions to
water, RIVM Report 2017-0193
Verschoor et al. (2016) Emission of microplastics and potential mitigation measures
Vogelsang et al. (2019) Microplastics in road dust – characteristics, pathways and measures
31
Wang, W. et al., ‘Environmental fate and impacts of microplastics in soil ecosystems: Progress and
perspective’, Science of the Total Environment, Vol. 708, 2020.
Water Briefing. (2016, November 7). Sewage sludge: new research warns over microplastics in soil.
WBCSD. (2019) Global ELT Management. Available at:
https://docs.wbcsd.org/2019/12/Global_ELT_Management%E2%80%93A_global_state_of_knowl
edge_on_regulation_management_systems_impacts_of_recovery_and_technologies.pdf
WBCSD. (2018) Managing End-of-Life Tires. Available at:
https://docs.wbcsd.org/2018/02/TIP/End_of_Life_Tires-Full-Report.pdf
WHO (2019) Microplastics in drinking-water. Geneva: World Health Organization; 2019. Licence:
CC BY-NC-SA 3.0 IGO.
Welden, Natalie A.C., Phillip R. Cowie (2016) Environment and gut morphology influence
microplastic retention in langoustine, Nephrops norvegicus, Environmental Pollution, Volume 214,
2016, Pages 859-865, ISSN 0269-7491, https://doi.org/10.1016/j.envpol.2016.03.067.
Werner S; Budziak A; Van Franeker J; Galgani F; Hanke G; Maes T; Matiddi M; Nilsson P;
Oosterbaan L; Priestland E; Thompson R; Veiga J; Vlachogianni T. Harm caused by Marine Litter.
EUR 28317 EN. Luxembourg (Luxembourg): Publications Office of the European Union; 2016.
JRC104308.
Westerschelde-plastic-nurdles-versie-definitief-21-11-2021-2.pdf (plasticsoupfoundation.org)
Wheatley, Q.; Baines, F., (1976) Biodegradation of polyvinyl alcohol in wastewater, AATCC, 1976,
8, 28
Wicke et al. (2015) Relevanz organischer Spurenstoffe im Regenwasserabfluss Berlins. Hg. v.
Kompetenzzentrum Wasser Berlin. Kompetenzzentrum Wasser Berlin.
Wik, Anna et al. (2009) Occurrence and effects of tire wear particles in the environment – A critical
review and an initial risk assessment, Environmental Pollution, Volume 157, Issue 1, 2009, ISSN
0269-7491, https://doi.org/10.1016/j.envpol.2008.09.028.
Winternitz, K, Heggie, M & Baird, J (2019) 'Extended producer responsibility for waste tyres in the
EU: Lessons learnt from three case studies – Belgium, Italy and the Netherlands', Waste
Management, vol. 89, pp. 386-396. https://doi.org/10.1016/j.wasman.2019.04.023
Wood et al. (2021) Support to the evaluation of the Sewage Sludge Directive – Exploratory Study
Final Report
Wright S.L. et al., ‘Atmospheric microplastic deposition in an urban environment and an evaluation
of transport’, Environ Int, Vol. 136, 2020.
WWF (2019) Solving plastic pollution through accountability, 2019, Accessed 28 Mar 2022. From:
http://awsassets.panda.org/downloads/solving_plastic_pollution_through_accountability_eng_sprea
d.pdf.
32
Www3.Epa.Gov, 2021, https://www3.epa.gov/npdes/pubs/sector_y_rubberplastic.pdf. Accessed 21
Oct 2021.
Ya-Qi Zhang, Marianna Lykaki, Mohammad Taher Arajoula, Marta Markiewicz, Caroline Kraas,
Sabrina Kolbe, Kristina Klinkhammer, Maike Rabe, Robert Klauer, Ellen Bendt and Stefan Stolte
(2021) Microplastics from textile origin – emission and reduction measures, Institute of Water
Chemistry, June 2021
33
Annex 2:
Stakeholder consultation (Synopsis report)
1 INTRODUCTION
The Impact Assessment accompanying the revision of this proposal included a thorough consultation
process that included various consultation activities. During the process, the measures proposed for
this proposal were consulted with stakeholders through bilateral meetings and stakeholder workshops
(general and thematic). Furthermore, an Open Public Consultation and a Targeted Experts Survey
and seven Stakeholder workshops have been conducted.
These consultation activities aimed to engage with stakeholders, inform them about the progress of
the ongoing analysis, and gather information for the analysis. The starting point for these activities
was the consultation strategy which was presented in the inception report. The main consultation
activities included an Open Public Consultation (OPC), several workshops and bilateral consultation
with different stakeholders. Initially, the consultation activities focused on the unintentional release
from three sources: 1) plastic pellets; 2) synthetic textiles; and 3) tyre abrasion. Later, the activities
were extended to three additional sources, viz. paints, detergent capsules, and geotextiles.
A summary of these consultation activities is presented below.
2 CONSULTATION STRATEGY
The consultation had the objective of gathering data and information to close the gaps in knowledge
related to the following:
• sources, pathways and impacts of microplastics on the environment as well as the potential
impact on human health;
• identification of measures to reduce the release of microplastics in the environment, e.g.
labelling, standardisation, certification, voluntary and regulatory measures;
• views on possible reduction measures; and
• possible impacts of these measures on different stakeholders.
Through consultation activities, information was gathered on the state of awareness and knowledge
of the general public regarding microplastic pollution and more information from experts and
stakeholders involved directly or indirectly linked to microplastics release and on who can play an
active role in reducing it.
The consultation strategy included these five main elements:
• Stakeholder identification and mapping;
• Open public consultation (OPC) (12-week long), with both closed and open-ended questions
and the possibility to upload/send additional material;
• Several workshops with stakeholders; and
34
• Interviews with selected stakeholders to clarify and/or complement the information received
through the targeted stakeholder survey.
3 MAPPING OF STAKEHOLDERS
In the initial steps relevant stakeholders were identified. A dedicated website4
for the underpinning
study for this impact assessment was created where interested stakeholders could register; in total
327 stakeholders registered through the website. Some stakeholders are common to the six sources,
while others are specific to each source area. The following are the views of the main groups of
stakeholders:
• Competent authorities in Member States: Some Member States (e.g. France) have already
started taking actions in this regard, and consulting them is crucial to ensure a coordinated
effort to efficiently reduce microplastic pollution. In addition, the Convention for the
Protection of the Marine Environment of the North-East Atlantic (the OSPAR Convention)
has adopted a recommendation on pellets as well as guidelines.
• Relevant economic actors along the value chain of the three sources (manufacturers, users,
transporters, etc. covered by individual companies and trade associations). Being one of the
main actors, they could provide an in-depth understating of microplastics release in the
environment and potential reduction measures. Both voluntary commitments and business
initiatives need to be understood as there are different industry initiatives that have already
been set up by industry members to reduce and/or prevent microplastic pollution.
• Civil society organisations: Some NGOs are raising awareness about microplastic pollution
and conducting monitoring at local, national and/or international levels.
• Certification bodies and monitoring organisations: There is still a lack of standardised
methods for monitoring microplastics. These organisations can provide information on what
can be achieved with the current state of analytical methods and information on
standardisation efforts.
• Academia, research and think tanks: Microplastic pollution is an active field of research,
and this has helped raise awareness about the impacts of this pollution. They will be able to
contribute the latest research evidence and help bridge the science-policy interface.
• EU Citizens: User behaviour is an important issue in the case of textiles, tyres, paints and
capsules and consulting citizens could provide useful insights on this aspect.
4
European Commission, Website dedicated to ‘Study on unintentional release of microplastics’, 2021
(https://microplastics.biois.eu).
35
4 OPEN PUBLIC CONSULTATION
4.1 Scope and Objective
This public consultation aims to support the European Commission’s initiative on microplastic
pollution. This initiative focuses on microplastics that are unintentionally released into the
environment such as resulting from the use of a product, for instance by fragmentation or abrasion.
It focuses on the sources with the highest known releases:
1. Plastic Pellets (intermediate materials used for the fabrication of plastic items)
2. Synthetic Textiles
3. Tyre Abrasion
4. Paints, including Architectural and Marine Paints, Road Markings
5. Geotextiles (used for civil engineering works such as road construction, coastal erosion
prevention, drainage, etc.)
6. Detergent Capsules for Laundry and Dishwashers.
This initiative does not address:
• Intentionally added microplastics to products (e.g., cosmetics, detergents, fertilisers
coatings): they are subject to a separate initiative under the REACH Regulation.
• Microplastics resulting from the fragmentation of macroplastics: they are addressed by
existing legislation such as the Single Use Plastics Directive.
This public consultation will help gather data and information to close the gaps in knowledge related
to the following:
• Sources, pathways, and impacts of microplastics on the environment and on human health;
• Identification of measures to reduce the release of microplastics in the environment, e.g.,
labelling, standardization, voluntary and regulatory measures, behavioural change; and
• Views on possible reduction measures.
4.2 Data Preparation
In total, 411 responses were received, and 410 responses were used for the final analyses, see in Table
2: Final analyses of the received responses. Based on the division of the survey in various sections,
some of which were not mandatory to answer, the team employed standard and specific cleaning
procedures. Standard procedures consist of dealing with null values and spurious entries, where a
respondent may have skimmed through the questionnaire without providing consistent answers. The
team also employed a split and pivot to separate and transpose the responses of multiple-choice
questions in individual rows.
36
Table 2: Final analyses of the received responses
Cleaning Criteria Number
Total Raw Responses 411 (100%)
Number of responses omitted due to spurious personal information 0 (0%)
Number of responses omitted due to being duplicates 0 (0%)
Number of responses omitted for blank or unmeaningful submissions 1 (~2%)
Number of responses requiring altered metadata/stakeholder types 0 (0%)
Responses after Primary Cleaning 410
4.3 Clustering of Responses and Special Processing
The general section of the questionnaire detailed demographic information of the respondents, along
with the sources of microplastic emissions that they would like to answer for, with each source having
a detailed section later. Hence, the team had to first split and transpose respondents who answered
for multiple sources and filter inconsistent answers.
Moreover, the division of general and expert sections of the questionnaire implies that respondents
will skip the expert sections if they do not have technical knowledge on the specific industry in
question. Here, we encounter primarily two responses for further processing – null values and
responses marked I don’t know/Not Applicable. Since the design of the questionnaire did not separate
the latter response, the team was not able to filter spurious entries from the ones where the respondent
knows the industry but does not know the answer to specific questions.
The cleaning problem at hand is further accentuated because of the low number of responses in the
expert section – in general, nulls/I don’t know accounted for more than 50% of the total responses
and hence, omitting them across all sections will not be valuable.
Table 3: Special Cleaning of the Data
Cleaning Criteria Number
Sample Size after Primary Cleaning 410 (100%)
Total number of responses after splitting multiple entries 410 (100%)
Number of responses omitted for duplicates after splitting multiple entries 0 (0%)
General Range of Responses in the Expert Sections after filtering 35-154 (8.5% -38%)
Number of responses requiring altered metadata/stakeholder types 0 (0%)
Total Responses for Analysis 410 (100%)
4.4 Open Answer Questions and Campaign Identification
The survey across all sections extracted other information and general comments on specific
questions for measures to prevent microplastic emissions, if the respondent believes that more options
can be assessed apart from the ones outlined in the survey. Here, the data extracted is qualitative and
open ended. Hence, we need to highlight duplicate responses and plagiarized comments that are
37
usually meant for lobbying purposes and to skew the distribution of responses. Using Tableau Prep,
we remove duplicates and null values from the dataset using aggregation and filtering. Owing to the
non-mandatory nature of the questions, a vast majority of the responses for open-text questions were
nulls (~60-80%). Hence, textual and thematic duplicates that account for more than 2 responses per
question were excluded from analysis. Moreover, irrelevant or comments duplicated from the
questions themselves were excluded from thematic analysis. A detailed breakdown of the responses
is provided in the thematic analysis.
4.5 Methodologies Employed
4.5.1 Analysis of Closed Questions
The questionnaire in general uses a five-pronged scale of agreeability ranging from completely agree
to completely disagree with another response for respondents that do not possess sufficient
knowledge to reply. The questionnaire is divided into four sections:
1. General information about the respondent
2. General views and opinions on microplastic and prevention measures
3. Specific sections on each highlighted source of microplastic emissions and prevention
measures (subsections A-F)
4. Questions directed at all sources of microplastic emissions and prevention measures
The analysis of the consultation responses is purely descriptive, using visuals such as pie and stacked
bar charts for composition of respondents based on demographics and general responses. For the bulk
of the questionnaire including the expert sections, the team has employed highlighted tables. Such
tables are quite informative as they are colour coded based on the observed frequency of the
agreeability scale used for each question – the highest frequency of agreeability is coded with the
deepest shade. Based on highlighted tables, one can immediately infer the general attitude towards
an aspect of microplastic emissions and associated policy measures. For questions that outline a list
of potential policy measures, the tables are broadly segregated into themes wherever applicable to
enable a better understanding of thematic measures. Tables for each question per section are
captioned with the number of respondents and an associated brief on frequencies as percentages of
total count.
4.5.2 Analysis of Open Text Questions
The questionnaire includes 15 open text questions where respondents can provide more information
about their attitude and position on a specific aspect of microplastics and associated policy. In such
questions, respondents primarily are asked to provide more information if they agree with other
aspects of microplastics than those specifically identified in the question. The thematic analysis of
responses is done manually with the following broad steps:
Step 1: Exploring an analytical framework and discovering general content. We identified
keywords and an inspection of the topics relating to the key word. Then, we logically deduce
general topics for inclusion into the analytical framework. We also highlight and discard the
presence of campaigns and duplicate/plagiarized responses in absolute number and
percentage of total count. The purpose of this analytical framework is to ensure that the
analysis is rooted in and builds upon core topics of interest.
38
Step 2: Revising keywords and exploring themes. We revisit the keywords defined in Step 1
and check for dominating correlations among them. Recurrent and similar keywords are
discarded or merged to form another synonymous keyword. Based on the assignment
outlined, we then segment responses based on the frequency of the keyword embedded in it
using tables with grand totals.
4.6 Part I. Respondent Profile
This section summarizes the distribution of respondents across Europe and other general indicators
of their demographics such as the percentage share of stakeholders, composition of organization
respondents, and sources of microplastic emissions answered for. Figures 7-9 visually detail the
same.
Most respondents were from France and Germany, with an equal split of about 28%, followed by
Italy and Spain with 14% and 6% respectively.
EU citizens represented the highest share in total responses (30%), followed by company/business
organisations (20%), business associations (18%), consumer and environmental NGOs (14%) and
academic/research institutions (10%). Public authorities represented 4% of the respondents, and non-
EU citizens and other respondents 2% each, as shown in Figure 2.
Among Company/Businesses Organizations, respondents were divided into four groups depending
on company size. Micro enterprises (1-9 employees) were represented by 24%, small enterprises (10-
49 employees) 11%, medium enterprises (50-249 employees) 15%, large-sized companies
(employing 250 or more employees) about 50%. A full breakdown of companies by size is presented
in Figure 3.
Most respondents wished to address Textiles as a source of microplastic emissions (21%), followed
by Pellets (19%) and Detergent Capsules (17%). Paints and Tyres were addressed by 15% of the
respondents while Geotextiles by 11%.
39
Figure 1: Composition of Responses by Country and Sources Answered
Figure 2: Distribution of Responses, Total
40
Figure 3: Size of Organisations
4.7 OPC Results
The following section details visuals and summarizes the responses received within each section of
the questionnaire. The highlighted tables are populated and aggregated by stakeholder composition.
The summary following each table briefly explains general attitudes for each aspect of microplastics
by country of origin with the highest responses. Creating visuals for attitudes by country has been
omitted due to low response shares and the lack of a representative sample.
4.7.1 Part II. General Public
1. Please indicate to which extent you agree with the following concerns as to microplastic pollution
(N=410)
a) Overall, 76% of EU citizens agree with the hazardous nature of microplastic emissions,
while about 16% somewhat agree. About 91% of NGOs, 67% of research institutions and 56%
of business organisations completely recognise the hazards of microplastics. EU citizens
(67%) completely agree with the harmful effects of microplastics on humans via ingestion
and inhalation, whereas about 19% somewhat agree. About 41% and 20% of business
organisations completely and somewhat agree on the same. More details on health concerns
are shown in Figure 4.
b) NGOs (88%), research institutions (77%), public authorities (69%), EU citizens (70%) and
non-EU citizens (90%) completely agree with the long-distance transmission of
microplastics, while 58% of business organisations and 24% of business associations
completely agree to the same.
c) Among EU citizens 75% and NGOs 88% completely agree with the persistence of
microplastics. About 48% of business organisations and about 31% of business associations
agree completely with the same. More details on the accumulations and persistence of
microplastics are shown in Figure 5.
d) Regarding the harmful economic effects of microplastics, EU citizens overall were spread
out across the scale, where about 43% completely agree, 15% somewhat agree, and 29%
41
maintain a neutral stance. Business associations showed a similar pattern, and around 50% of
business organisations agreed or somewhat agreed, while 65% of NGOs completely agreed
with the statement.
e) Around 25% of Company/Business Organisations and Public Authorities completely agree
with plant assimilation of microplastics while 68% of NGOs and 43% or EU Citizens are in
the same scale.
Figure 4: Microplastic Pollution: Health Concerns
42
Figure 5: Microplastic Pollution: Accumulation and Persistence
43
Table 4: Microplastic Pollution: Other Concerns – Plants Assimilate Microplastics and Microplastics
Harm the Economy
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
24% 6% 42% 14% 10%
Business associations 13% 6% 43% 11% 5% 4%
NGOs 68% 17% 2% 12%
Academic/Research
Institutions
17% 2% 12% 18% 38% 5%
Public Authorities 25% 31% 6% 19%
EU citizens 43% 5% 22% 8% 16% 4%
Non-EU citizens 90% 10%
Others 50% 20% 10% 20%
Plants Assimilate Microplastics
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
29% 4% 20% 11% 21% 11%
Business associations 15% 7% 29% 14% 8% 13%
NGOs 65% 2% 14% 4% 12% 4%
Academic/Research
Institutions
21% 23% 3%
Public Authorities 31% 31% 13% 6%
EU citizens 43% 5% 10% 19% 15% 5%
Non-EU citizens 80% 10% 10%
Others 50% 10% 30% 10%
Microplastics Harm the Economy
44
2. To reduce microplastics pollution, how and at what level should the action be (N=410)
There is an overwhelming agreement among all stakeholders to undertake action at all levels of
authority. Almost all respondents agree with voluntary measures (64%), regulatory measures (87%)
and international action (95%).
Figure 6: Agreement on the Level of Measures
45
3. To what extent would you agree to buy a product that releases less microplastics, even if it costs
more? (N=357)
a) There is general agreement on buying a variety of products if they’re made to be sustainable
but expensive, except Business Association where more than 50% remained neutral.
b) Academic/Research Institutions (75%) completely agree to buy sustainable clothing and
around 70% of EU citizens and NGOs and 47% of Company/Business Organisations are on
the same opinion.
c) Most of all stakeholders completely or somewhat agree to buy sustainable furniture,
sustainable detergent capsules, sustainable painted products, sustainable paints and sustainable
tyres at higher prices while Business associations remain rather neutral. More details are show
in Table 5 and Table 6.
Table 5: Sustainable Choices for Households (1-3): Would you buy sustainable clothing at higher
prices? – Would you buy sustainable furniture at higher prices? – Would you buy sustainable detergent
capsules at higher prices?
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
47% 27% 3% 19% 3%
Business associations 32% 56% 2% 9%
NGOs 69% 2% 17% 3% 7%
Academic/Research
Institutions
76% 8% 3% 14%
Public Authorities 67% 25% 8%
EU citizens 72% 2% 6% 18% 2%
Non-EU citizens 80% 20%
Others 50% 20% 10% 20%
Would you buy sustainable clothing at higher prices?
46
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
38% 3% 27% 8% 18% 5%
Business associations 30% 56% 5% 5% 2%
NGOs 68% 2% 17% 3% 8%
Academic/Research
Institutions
62% 8% 8% 14% 5%
Public Authorities 50% 25% 8% 17%
EU citizens 67% 3% 2% 7% 17% 3%
Non-EU citizens 80% 20%
Others 60% 20% 20%
Would you buy sustainable furniture at higher prices?
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
49% 27% 5% 17%
Business associations 28% 60% 4% 5%
NGOs 68% 2% 20% 3% 5%
Academic/Research
Institutions
73% 8% 5% 8%
Public Authorities 67% 25% 8%
EU citizens 72% 2% 6% 5% 14% 2%
Non-EU citizens 80% 20%
Others 60% 20% 20%
Would you buy sustainable detergent capsules at higher prices?
47
Table 6: Sustainable Choices for Other Durables (1-3): Would you buy sustainable painted products at
higher prices? – Would you buy sustainable paints at higher prices? – Would you buy sustainable tyres
at higher prices?
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
38% 6% 27% 8% 17% 3%
Business associations 23% 5% 56% 2% 9% 2%
NGOs 47% 2% 19% 20% 8% 2%
Academic/Research
Institutions
62% 8% 5% 19%
Public Authorities 50% 25% 8% 8%
EU citizens 63% 2% 4% 11% 19% 2%
Non-EU citizens 80% 20%
Others 60% 20% 20%
Would you buy sustainable painted products at higher prices?
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
42% 3% 26% 8% 14% 6%
Business associations 26% 2% 56% 2% 7% 4%
NGOs 63% 2% 19% 7% 8%
Academic/Research
Institutions
65% 8% 3% 19%
Public Authorities 50% 25% 8% 8%
EU citizens 63% 3% 4% 7% 21% 1%
Non-EU citizens 90% 10%
Others 50% 20% 10% 20%
Would you buy sustainable paints at higher prices?
48
4.7.2 Part III. Expert Section
Part III contains questions for which expert knowledge is required, but all types of respondents are
welcome to respond. It includes questions on the sources of microplastics pollution being assessed
by the European Commission (pre-production pellets, tyre wear particles, synthetic textiles, paints,
geotextiles, and detergent capsules) and on the policy measures reducing unintentional release of
microplastics.
Note: Based on the pattern of responses, it appears from preliminary analysis that all Business
Associations (n=12) tend to skew responses using neutral or moderate scales. While open text
comments cannot throw conclusive light on the issue, this can appear as a campaign and must be
examined and further discounted.
4.7.2.1 Pre-Production Pellets (N=164)
1. To what extent would you agree with the following weaknesses on how current systems deal with
pellets?
a) Most of Public Authorities (75%), NGOs (76%), Academic/Research Institutions (67%)
and EU Citizens (64%) and half of the Company/Business Organisations completely or
somewhat agree on the lack of risk assessment of pellet handling activities by
companies, however, Business Associations are more widespread on the scale and
maintain a rather neutral stance. (See Table 7)
b) Most NGOs (74%), Company/Business Organisations (52%), Academic/Research
Institutions (75%) and EU Citizens (51%), completely or somewhat agree on the lack of
independent audit policies, but Business Associations and Public Authorities remain
neutral. (See Table 7Table 7)
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
43% 1% 30% 5% 16% 5%
Business associations 28% 2% 58% 2% 5% 4%
NGOs 69% 17% 3% 8% 2%
Academic/Research
Institutions
73% 5% 14% 3%
Public Authorities 67% 25% 8%
EU citizens 69% 2% 4% 7% 16% 2%
Non-EU citizens 80% 10% 10%
Others 50% 20% 30%
Would you buy sustainable tyres at higher prices?
49
c) NGOs, Business Associations and Company/Business Organisations stay rather neutral
on the lack of economic incentives while half of Academic/Research Institutions and
EU citizens completely agree. (See Table 7)
d) NGOs (64%) completely agree with the improper handling of pellet-related activities
and with the improper transferring protocols while other stakeholders remain rather
neutral. (See Table 8)
e) NGOs (68%), Public Authorities (54%) and Company/Business Organisations (41%)
completely or somewhat agree on improper worker training while Business
Associations remain neutral. (See Table 8)
f) NGOs (65%) completely agree on improper sealing of packages and on improper
handling of pellets, while Business Associations, Company/Business Organisations and
Public Authorities maintain a neutral position. (See Table 8)
g) NGOs (68%) completely disagree while other stakeholders remain rather neutral on the
expensive cost of prevention equipment. (See Table 9)
h) There is general agreement among almost all stakeholders for the lack of accounting
for pellet discharge. Business Associations mostly however completely or somewhat
disagree with the statement. (See Table 9)
50
Table 7: Specific Shortfalls (1-3): Lack of Risk Assessment of Pellet Handling Activities by Companies;
Lack of Independent Auditing and Lack of Economic Incentives
Contribution As Completely agree
Completely
disagree
I don't know/Not
applicable
Neither agree nor
disagree
Somewhat agree
Somewhat
disagree
Company/Business
Organisations
34.48% 20.69% 3.45% 10.34% 17.24% 13.79%
Business associations 36.36% 9.09% 13.64% 22.73% 18.18%
NGOs 69.49% 1.69% 16.95% 3.39% 6.78%
Academic/Research Institutions 33.33% 16.67% 33.33% 8.33%
Public Authorities 67% 25.00% 8.33%
EU citizens 47.17% 5.66% 13.21% 3.77% 16.98% 5.66%
Non-EU citizens 100%
Others 66.67% 33%
Company/Business
Organisations
34.48% 20.69% 17.24% 6.90% 17.24% 3.45%
Business associations 18.18% 22.73% 13.64% 22.73% 9.09% 13.64%
NGOs 67.80% 25.81% 6.45%
Academic/Research Institutions 50.00% 25.00% 25.00%
Public Authorities 36.36% 36.36% 27.27%
EU citizens 39.62% 5.66% 18.87% 13.21% 11.32%
Non-EU citizens 67% 33.33%
Others 33.33% 67%
Company/Business
Organisations
31.03% 17.24% 10.34% 24.14% 17.24%
Business associations 13.64% 27.27% 9.09% 22.73% 13.64% 9.09%
NGOs 19.35% 9.68% 25.81% 29.03% 12.90%
Academic/Research Institutions 50.00% 8.33% 8.33% 25.00% 8.33%
Public Authorities 45.45% 9.09% 18.18% 18.18%
EU citizens 56.60% 9.43% 3.77% 9.43% 11.32% 1.89%
Non-EU citizens 100%
Others 67% 33.33%
Lack of Risk Assessment of Pellet Handling Activities by Companies
Lack of Independent Auditing
Lack of Economic Incentices
51
Table 8: Operational Issues (1-5): Improper Transferring Protocols; Improper Worker Training;
Improper Storage Protocols; Improper Sealing of Packages and Improper Handling
Contribution As Completely agree
Completely
disagree
I don't know/Not
applicable
Neither agree nor
disagree
Somewhat agree
Somewhat
disagree
Company/Business
Organisations
20.69% 17.24% 24.14% 3.45% 24.14% 10.34%
Business associations 27.27% 18.18% 13.64% 22.73% 13.64%
NGOs 64.52% 25.81% 3.23% 6.45%
Academic/Research Institutions 16.67% 33.33% 8.33% 41.67%
Public Authorities 27.27% 36.36% 9.09% 18.18%
EU citizens 24.53% 7.55% 26.42% 13.21% 11.32% 9.43%
Non-EU citizens 67% 33.33%
Others 100%
Company/Business
Organisations
20.69% 17.24% 13.79% 6.90% 20.69% 17.24%
Business associations 9.09% 31.82% 13.64% 9.09% 18.18% 18.18%
NGOs 61.29% 25.81% 6.45% 6.45%
Academic/Research Institutions 25.00% 33.33% 16.67% 25.00%
Public Authorities 45.45% 27.27% 18.18% 9.09%
EU citizens 33.96% 5.66% 20.75% 9.43% 18.87% 5.66%
Non-EU citizens 67% 33.33%
Others 100%
Company/Business
Organisations
17.24% 20.69% 24.14% 3.45% 20.69% 13.79%
Business associations 36.36% 13.64% 13.64% 4.55% 27.27%
NGOs 64.52% 25.81% 3.23% 6.45%
Academic/Research Institutions 16.67% 33.33% 25.00% 16.67% 8.33%
Public Authorities 18.18% 45.45% 18.18% 18.18%
EU citizens 20.75% 11.32% 24.53% 13.21% 16.98% 7.55%
Non-EU citizens 67% 33.33%
Others 100%
Improper Transferring Protocols
Improper Worker Training
Improper Storage Protocols
52
Contribution As Completely agree
Completely
disagree
I don't know/Not
applicable
Neither agree nor
disagree
Somewhat agree
Somewhat
disagree
Company/Business
Organisations
13.79% 17.24% 20.69% 10.34% 17.24% 20.69%
Business associations 4.55% 31.82% 22.73% 13.64% 9.09% 18.18%
NGOs 64.52% 25.81% 3.23% 6.45%
Academic/Research Institutions 25.00% 25.00% 25.00% 25.00%
Public Authorities 27.27% 36.36% 18.18% 18.18%
EU citizens 32.08% 5.66% 13.21% 15.09% 15.09% 13.21%
Non-EU citizens 67% 33.33%
Others 33.33% 67%
Company/Business
Organisations
31.03% 31.03% 13.79% 6.90% 6.90% 10.34%
Business associations 31.82% 18.18% 13.64% 4.55% 27.27%
NGOs 64.52% 25.81% 3.23% 6.45%
Academic/Research Institutions 25.00% 25.00% 16.67% 25.00% 8.33%
Public Authorities 36.36% 9.09% 27.27% 18.18% 9.09%
EU citizens 26.42% 7.55% 24.53% 7.55% 20.75% 5.66%
Non-EU citizens 100%
Others 100%
Improper Sealing of Packages
Improper Handling
53
Table 9: Miscellaneous Operational Issues (1-2): Expensive Prevention Equipment and Not Accounting
for Pellet Discharge
2. To what extent would you agree with the following non-regulatory measures improving voluntary
schemes?
a) There is general agreement with all stakeholders that the industry should prioritize
preventive measures. Most of the NGOs (63.16%), Academic/Research Institutions
(100%), EU citizens (67.92%), Non–EU citizens (100%), and Public Authorities
(63.64%) completely agree that clearer public reporting, transparency and tracking of
progress measures improve voluntary schemes. (See Table 10)
b) Most of the Academic/Research Institutions (58%), EU citizens (49.6%) and Non–EU
citizens (100%) completed agree, while Businesses Associations (40%) completely
disagree with an initiative on the industry to create a remediation fund. (See Table
10)
c) All stakeholders completely or somewhat agree on independent auditing. (See Table
11)
d) Academic/Research Institutions (92%), Company/Business Organisations (59%),
Business Associations (59%) and EU citizens (61%) completely or somewhat agree on
the importance of multi stakeholders’ governance, while 42% EU Citizens completely
agree on the same. (See Table 11)
Contribution As Completely agree
Completely
disagree
I don't know/Not
applicable
Neither agree nor
disagree
Somewhat agree
Somewhat
disagree
Company/Business
Organisations
13.79% 20.69% 24.14% 13.79% 10.34% 13.79%
Business associations 4.55% 22.73% 31.82% 18.18% 22.73%
NGOs 3.23% 67.74% 22.58% 3.23% 3.23%
Academic/Research Institutions 16.67% 33.33% 25.00% 16.67% 8.33%
Public Authorities 9.09% 9.09% 36.36% 36.36% 9.09%
EU citizens 11.32% 9.43% 39.62% 15.09% 11.32% 5.66%
Non-EU citizens 33.33% 67%
Others 100%
Company/Business
Organisations
37.93% 13.79% 3.45% 10.34% 20.69% 10.34%
Business associations 18.18% 13.64% 13.64% 13.64% 36.36%
NGOs 70.97% 22.58% 6.45%
Academic/Research Institutions 83.33% 16.67%
Public Authorities 54.55% 9.09% 18.18% 18.18%
EU citizens 62.26% 7.55% 7.55% 1.89% 11.32% 3.77%
Non-EU citizens 100%
Others 33.33% 67%
Expensive Prevention Equipment
Not Accounting for Pellet Discharge
54
Table 10: Industry Measures (1-3): Industry to Prioritise Preventive Measures; Industry to Create
Remediation fund and Public Reporting
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
59% 7% 31% 3%
Business associations 55% 14% 32%
NGOs 65% 26% 3% 6%
Academic/Research
Institutions
67% 8% 8% 17%
Public Authorities 64% 18% 18%
EU citizens 72% 2% 2% 4% 13% 4%
Non-EU citizens 67% 33%
Others 33% 67%
Industry to Prioritise Preventive Measures
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
31% 24% 21% 10% 7% 7%
Business associations 14% 41% 18% 9% 14% 5%
NGOs 26% 19% 3% 6% 6%
Academic/Research
Institutions
58% 17% 25%
Public Authorities 36% 9% 36% 9%
EU citizens 49% 11% 8% 11% 15% 2%
Non-EU citizens 100%
Others 33% 67%
Industry to Create Remediation fund
55
Table 11: Miscellaneous Measures (1-2): Independent Auditing and Multi Stakeholders' Governance
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
32% 7% 11% 18% 29% 4%
Business associations 32% 5% 9% 23% 32%
NGOs 63% 21% 5% 5% 5%
Academic/Research
Institutions
100%
Public Authorities 64% 9% 18% 9%
EU citizens 68% 6% 19% 4%
Non-EU citizens 100%
Others 67% 33%
Public Reporting
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
38% 7% 3% 14% 28% 7%
Business associations 45% 5% 23% 23% 5%
NGOs 68% 26% 6%
Academic/Research
Institutions
83% 8% 8%
Public Authorities 64% 18% 9% 9%
EU citizens 64% 2% 9% 4% 13% 2%
Non-EU citizens 100%
Others 33% 67%
Independent Auditing
56
3. To what extent would you agree with the following regulatory measures for pellet loss
prevention?
a) Business Associations and Company/Business Organisations are widespread on the
agreement scale while for other stakeholders there is general agreement on the need for
EU legislation to set up a comprehensive system for pellet handling companies. (See
Table 12)
b) There is a general agreement (completely or somewhat agree) among all stakeholders
for international measures. The same inference applies to extended producer
responsibility where only Business Associations (50%) remain rather neutral. (See
Table 12)
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
38% 3% 21% 14% 21%
Business associations 36% 5% 5% 32% 23%
NGOs
44% 6% 28% 17% 6%
Academic/Research
Institutions
50% 8% 42%
Public Authorities 27% 36% 27%
EU citizens 42% 4% 11% 15% 19% 2%
Non-EU citizens 67% 33%
Others 100%
Multi Staleholders' Governance
57
Table 12: Regulatory Measures (1-3): International Approaches; Extended Producer Responsibility
and EU Legislation for Pellet Handling
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
48% 3% 21% 24% 3%
Business associations 32% 27% 23% 18%
NGOs 87% 10% 3%
Academic/Research
Institutions
67% 8% 25%
Public Authorities 73% 9% 18%
EU citizens 79% 2% 2% 13% 2%
Non-EU citizens 100%
Others 33% 67%
International Approaches
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
41% 10% 7% 10% 14% 17%
Business associations 23% 27% 14% 9% 14% 9%
NGOs 90% 10%
Academic/Research
Institutions
75% 25%
Public Authorities 64% 9% 9% 9% 9%
EU citizens 75% 2% 2% 4% 9% 4%
Non-EU citizens 100%
Others 33% 67%
Extended Producer Responsibility
58
4. Open Text Comments
a) Respondents (n=1) maintain that the main issue is awareness of pellets as hazardous
substances. As an application, they consult on using International Maritime
Dangerous Goods (IMDG) Codes on pellet transportation with contingency plans for
safe transport along with emergency policies among companies to manage pellet spills.
b) Another respondent (n=2) agrees on improper management at the plant and
transportation network. Apart from legislative penalties, they consult on tracers for
pellets to pinpoint producer responsibility during transport. There also exists awareness
that the level of measures undertaken are voluntary at the industry level, which
needs more control to ensure compliance.
c) There is another suggestion (n=1) on balancing legislative compliance between
consumers and producers, where the respondent observes the incidence of excessive
burden on EU producers.
d) There is disagreement (n=1) on the extent of knowledge among public authorities of
the modus operandi of the industry as well as the concepts of extended producer
responsibility.
4.7.2.2 Tyre Wear Particles (N=154)
1. To what extent would you agree with the following measures to reduce microplastic emissions
from tyres?
a) All stakeholders completely or somewhat agree to have tyres designed to reduce
abrasion. (See Table 13)
b) There is support among most stakeholders to propose labelling of tyres in terms of
abrasion, whereas Business Associations (42%) remain neutral. (See Table 13)
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
38% 21% 7% 3% 17% 14%
Business associations 23% 36% 14% 18% 9%
NGOs 81% 10% 10%
Academic/Research
Institutions
50% 8% 42%
Public Authorities 91% 9%
EU citizens 66% 6% 8% 17% 2%
Non-EU citizens 100%
Others 67% 33%
EU Legislation for Pellet Handling
59
c) All stakeholders completely or somewhat agree on legal limits on tyre abrasion (see
Table 14)
d) Businesses associations (52%), Company/Business organisations (55%) and EU citizens
(52%) completely agree on requirements on road infrastructure while
Academic/Researchers Institutions (46%) and Public Authorities (55%) somewhat
agree. (See Table 14)
e) All stakeholders completely or somewhat agree on the capture and treatment of road
run-off water where NGOs are split between agreement (44%) and disagreement (40%).
All stakeholders completely or somewhat agree for improvements in road cleaning in
high-emission spots. (See Table 15)
f) Businesses Associations, NGOs and EU citizens somewhat or completely agree with
implementing AI and advanced assisted driving technologies, whereas
Academic/Researchers Institutions and Public Authorities are neutral or somewhat
agree. (See Table 15)
60
Table 13: Design Parameters (1-2): Tyres Designed to Reduce Abrasion and Labelling of Tyres in terms
of Abrasion
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Company/Business
Organisations
72% 28%
Business associations 42% 37% 21%
NGOs 95% 3%
Academic/Research
Institutions
54% 8% 38%
Public Authorities 67% 22% 11%
EU citizens 70% 4% 7% 7% 13%
Non-EU citizens 100%
Others 100%
Tyres Designed to Reduce Abrasion
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Company/Business
Organisations
50% 6% 44%
Business associations 37% 42% 21%
NGOs 85% 3% 3% 10%
Academic/Research
Institutions
62% 38%
Public Authorities 56% 11% 11% 22%
EU citizens 59% 4% 9% 7% 20%
Non-EU citizens 100%
Others 100%
Labelling of Tyres in terms of Abrasion
61
Table 14: Regulations (1-3): Legal Limits on Tyre Abrasion; Requirements on Road Infrastructure and
Higher Fees in Extended Producer Responsibility
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
53% 12% 12% 24%
Business associations 68% 16% 16%
NGOs 95% 3% 3%
Academic/Research
Institutions
54% 31% 15%
Public Authorities 44% 11% 11% 33%
EU citizens 59% 4% 9% 4% 20% 4%
Non-EU citizens 100%
Others 100%
Legal Limits on Tyre Abrasion
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
56% 6% 33%
Business associations 53% 11% 11% 16% 11%
NGOs 25% 8% 43% 15% 10%
Academic/Research
Institutions
23% 23% 46% 8%
Public Authorities 11% 22% 56% 11%
EU citizens 52% 2% 4% 11% 22% 9%
Non-EU citizens 100%
Others 25% 25% 25% 25%
Requirements on Road Infrastructure
62
Table 15: Tech Improvements (1-3): Improve Road Cleaning in High Emission Spots; Artificial
Intelligence and Advanced Driver Technology and Capture and Treat Road Run-Off Water
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
50% 22% 11% 11% 6%
Business associations 37% 42% 5% 16%
NGOs 80% 3% 13% 5%
Academic/Research
Institutions
38% 8% 23% 31%
Public Authorities 33% 67%
EU citizens 65% 7% 2% 11% 15%
Non-EU citizens 100%
Others 50% 50%
Higher Fees in Extendedd Producer Responsibility
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
44% 11% 11% 28%
Business associations 53% 11% 21% 11%
NGOs 23% 3% 13% 55% 5%
Academic/Research
Institutions
54% 23% 23%
Public Authorities 44% 22% 11% 22%
EU citizens 65% 2% 9% 11% 13%
Non-EU citizens 100%
Others 25% 75%
Improve Road Cleaning in High Emission Spots
63
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
39% 17% 22% 6% 11%
Business associations 11% 5% 21% 58% 5%
NGOs 13% 5% 8% 15% 55% 5%
Academic/Research
Institutions
15% 15% 15% 31% 15% 8%
Public Authorities 11% 44% 44%
EU citizens 30% 13% 11% 17% 24% 4%
Non-EU citizens 100%
Others 50% 50%
Artificial Intelligence and Advanced Driver Technology
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
50% 6% 22% 17%
Business associations 21% 11% 58% 11%
NGOs 33% 3% 13% 13% 40%
Academic/Research
Institutions
54% 8% 38%
Public Authorities 44% 11% 11% 33%
EU citizens 67% 2% 4% 9% 17%
Non-EU citizens 100%
Others 50% 50%
Capture and Treat Road Run-Off Water
64
1. Open Text Comments
a) Responses (n=2) include an emphasis on improving public transport to reduce traffic
congestion and regulate demand for private vehicles, along with better management of
freight transport.
b) Another respondent points out potential emission issues with the measures listed on
the survey – the intentional and inevitable nature of tyre production vis-à-vis
microplastic emissions, AI as a redundant solution, and further contamination from
cleaning roads with brushes.
4.7.2.3 Synthetic Textiles (N=154)
1. During which phase of the life cycle, microplastics emissions from textiles are the most
significant?
a) Most stakeholders believe that emissions from manufacturing of synthetic fibres,
thread, yarn, and other raw material for garment production are very significant
while the response of Business Associations is spread across the significance chart. (See
Table 16)
b) All stakeholders believe that emissions from garment production are very significant
while the responses of Business Associations and EU citizens’ responses are spread
across the significance scale. (See Table 16)
c) Emissions from pre-wash cycles after production are very significant for all the
stakeholders. (See Table 16)
d) On the consumer end, garment wear contributes significantly to emissions for most EU
Citizens (62%), while Business Associations (40.6%), and Public Authorities (44.4%)
find it very little significant. (See Table 17)
e) All stakeholders overwhelmingly attribute use-phase washing cycles as a very
significant contributor to microplastic emissions while use-phase drying cycles as a
source is more distributed in scale of significance – 70.8% of Academic/Researchers
Institutions find it very significant and 44% of Public Authorities find it little significant.
(See Table 17)
f) A garment’s end of life holds high significance for the stakeholders in terms of
emissions. Here, only Public Authorities (44%) believe it is completely insignificant.
(See Table 17)
65
Table 16: Production and Consumer Usage I (1-3): Manufacturing of Synthetic Fibres, Thread, Yarn,
other Raw Materials for Garment Production; Emission from Garment Production and Emission from
Pre-Wash Cycles after Production
Contribution As
Completely
insignificant
Very little
significant
Somewhat
significant
Very
significant
I don't
know/Not
applicable
Company/Business
Organisations
3% 10% 23% 50% 15%
Business associations 31% 28% 22% 19%
NGOs 4% 10% 67% 18%
Academic/Research
Institutions
8% 29% 50% 13%
Public Authorities 30% 20% 40% 10%
EU citizens 3% 12% 22% 41% 22%
Non-EU citizens 10% 10% 70% 10%
Others 33% 50% 17%
Manufacturing of Synthetic Fibres, Thread, Yarn, other Raw Materials for Garment
Production
Contribution As
Completely
insignificant
Very little
significant
Somewhat
significant
Very
significant
I don't
know/Not
applicable
Company/Business
Organisations
3% 8% 30% 40% 20%
Business associations 34% 25% 25% 16%
NGOs 2% 18% 57% 22%
Academic/Research
Institutions
26% 52% 22%
Public Authorities 11% 33% 44% 11%
EU citizens 1% 15% 27% 33% 24%
Non-EU citizens 20% 70% 10%
Others 33% 50% 17%
Emission from Garment Production
66
Table 17: Production and Consumer Usage II (1-4): Emission from Garment Wear; Emission from Use-
Phase Washing Cycles; Emission from Use-Phase Drying Cycles and Emission from Garment End of
Life
Contribution As
Completely
insignificant
Very little
significant
Somewhat
significant
Very
significant
I don't
know/Not
applicable
Company/Business
Organisations
2% 2% 17% 63% 15%
Business associations 6% 31% 50% 13%
NGOs 2% 8% 76% 14%
Academic/Research
Institutions
4% 25% 58% 13%
Public Authorities 20% 70% 10%
EU citizens 6% 27% 76% 19%
Non-EU citizens 30% 70%
Others 17% 83%
Emission from Pre-Wash Cycles after Production
Contribution As
Completely
insignificant
Very little
significant
Somewhat
significant
Very
significant
I don't
know/Not
applicable
Company/Business
Organisations
5% 15% 25% 43% 13%
Business associations 3% 41% 28% 19% 9%
NGOs 2% 55% 24% 18%
Academic/Research
Institutions
22% 35% 39% 4%
Public Authorities 44% 44% 11%
EU citizens 6% 17% 20% 36% 21%
Non-EU citizens 10% 20% 60% 10%
Others 17% 67% 17%
Emission from Garment Wear
67
Contribution As
Completely
insignificant
Very little
significant
Somewhat
significant
Very
significant
I don't
know/Not
applicable
Company/Business
Organisations
5% 24% 61% 10%
Business associations 25% 44% 28% 3%
NGOs 18% 71% 10%
Academic/Research
Institutions
25% 75%
Public Authorities 20% 70% 10%
EU citizens 1% 4% 25% 53% 16%
Non-EU citizens 10% 90%
Others 100%
Emission from Use-Phase Washing Cycles
Contribution As
Completely
insignificant
Very little
significant
Somewhat
significant
Very
significant
I don't
know/Not
applicable
Company/Business
Organisations
15% 24% 44% 17%
Business associations 19% 41% 31% 9%
NGOs 2% 2% 41% 35% 20%
Academic/Research
Institutions
4% 25% 71%
Public Authorities 11% 44% 33% 11%
EU citizens 6% 13% 21% 41% 19%
Non-EU citizens 40% 50% 10%
Others 17% 17% 50% 17%
Emission from Use-Phase Drying Cycles
68
2. To what extent would you agree with the following measures to reduce microplastic emissions
specifically from clothing, carp fabrics for furniture and similar?
a) During Design or Production Phase –
Business Associations and Public Authorities somewhat agree to a restriction of all
synthetic fibres for certain applications and those with high microplastic content while
63% and 85% EU Citizens are respectively of the same opinion. (See Table 18)
Among all stakeholders there is complete agreement on product design requirements and
specific waste-water treatment in production plants. (See Table 19)
Business Associations are spread across agreement scale on mandatory pre-washing before
market placement while 45% Academic/Researchers Institutions and 56% EU Citizens
completely agree. (See Table 19)
There is majority agreement among stakeholders on emissions limit during production and
emissions limit on textiles on the EU Market. (See Table 20)
b) During Use-Phase –
Most stakeholders completely or somewhat agree on consumer awareness, washing
machine filters, and laundry emission limits. (See Table 21)
c) Transversal Policies –
Contribution As
Completely
insignificant
Very little
significant
Somewhat
significant
Very
significant
I don't
know/Not
applicable
Company/Business
Organisations
5% 5% 21% 46% 23%
Business associations 3% 6% 19% 38% 34%
NGOs 2% 10% 67% 20%
Academic/Research
Institutions
4% 38% 42% 17%
Public Authorities 44% 11% 11% 33%
EU citizens 3% 9% 20% 46% 22%
Non-EU citizens 10% 90%
Others 17% 33% 33% 17%
Emission from Garment End of Life
69
There is overwhelming agreement among all stakeholders for all measures listed in the
questionnaire. (See Table 21)
Table 18: During design and production phase I (1-2): Restriction of all Synthetic Fibers for Certain
Applications and Restriction on Synthetic Fibers with High Microplastic Content
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
30% 28% 3% 10% 23% 8%
Business associations 15% 45% 9% 12% 12% 6%
NGOs 61% 6% 6% 8% 12% 6%
Academic/Research
Institutions
33% 17% 17% 13% 21%
Public Authorities 30% 10% 10% 30% 20%
EU citizens 63% 4% 1% 4% 24% 3%
Non-EU citizens 80% 20%
Others 67% 17% 17%
Restriction of all Synthetic Fibers for Certain Applications
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
51% 7% 5% 5% 22% 10%
Business associations 27% 12% 9% 9% 24% 18%
NGOs 82% 8% 10%
Academic/Research
Institutions
63% 29% 8%
Public Authorities 60% 10% 30%
EU citizens 86% 1% 1% 12%
Non-EU citizens 100%
Others 83% 17%
Restriction on Synthetic Fibers with High Microplastic Content
70
Table 19: During design and production phase II (1-3): Product Design Requirements; Specific Waste
Water Treatment in Production Plants and Mandatory Pre-Washing before Placing on the Market
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations 66% 2% 2% 27% 2%
Business associations
48% 9% 12% 27% 3%
NGOs
90% 2% 8%
Academic/Research
Institutions 75% 8% 13% 4%
Public Authorities
70% 10% 20%
EU citizens
80% 1% 4% 13% 1%
Non-EU citizens
60% 40%
Others
50%
50%
Product Design Requirements
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations 65% 3% 5% 25% 3%
Business associations
39% 3% 9% 42% 6%
NGOs
90% 2% 8%
Academic/Research
Institutions 83% 4% 8% 4%
Public Authorities
89% 11%
EU citizens
77% 3% 16% 4%
Non-EU citizens
70% 30%
Others
83% 17%
Specific Waste Water Treatment in Production Plants
71
Table 20: During design and production phase III (1-2): Emission Limit During Production and
Emission Limit on Textiles in the EU Market
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
48% 15% 3% 10% 25%
Business associations 24% 9% 15% 15% 21% 15%
NGOs 71% 4% 6% 2% 14% 2%
Academic/Research
Institutions
46% 4% 13% 25% 13%
Public Authorities 40% 10% 50%
EU citizens 57% 3% 9% 10% 20% 1%
Non-EU citizens 30% 10% 10% 50%
Others 50% 17% 17% 17%
Mandatory Pre-Washing before Placing on the Market
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
58% 5% 5% 10% 20% 3%
Business associations 21% 9% 18% 15% 21% 15%
NGOs 57% 4% 37% 2%
Academic/Research
Institutions
54% 8% 33% 4%
Public Authorities 40% 10% 50%
EU citizens 70% 1% 7% 22%
Non-EU citizens 70% 30%
Others 33% 67%
Emission Limit During Production
72
Table 21: Use phase and transversal policies (1-3): Consumer Awareness; Filters in Washing Machines
and Regulate Emissions from Laundries
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
65% 5% 5% 10% 13% 3%
Business associations 24% 9% 15% 18% 18% 15%
NGOs 86% 6% 8%
Academic/Research
Institutions
50% 4% 13% 29% 4%
Public Authorities 30% 30% 40%
EU citizens 77% 1% 1% 6% 13% 1%
Non-EU citizens 80% 10% 10%
Others 50% 17% 33%
Emission Limit on Textiles in the EU Market
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
80% 2% 2% 15%
Business associations 47% 6% 6% 41%
NGOs 49% 4% 45% 2%
Academic/Research
Institutions
67% 4% 25% 4%
Public Authorities 20% 10% 60% 10%
EU citizens 87% 3% 3% 6% 1%
Non-EU citizens 70% 30%
Others 100%
Consumer Awareness
73
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
63% 2% 17% 17%
Business associations 36% 3% 21% 33% 6%
NGOs 41% 31% 27% 2%
Academic/Research
Institutions
42% 4% 25% 25% 4%
Public Authorities 40% 10% 40% 10%
EU citizens 75% 6% 3% 1% 12% 3%
Non-EU citizens 70% 10% 20%
Others 33% 67%
Filters in Washing Machines
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
56% 2% 5% 5% 32%
Business associations 27% 3% 24% 12% 30% 3%
NGOs 43% 4% 2% 51%
Academic/Research
Institutions
50% 13% 33% 4%
Public Authorities 50% 10% 30% 10%
EU citizens 79% 6% 1% 4% 10%
Non-EU citizens 90% 10%
Others 67% 17% 17%
Regulate Emissions from Laundries
74
3. Open Text Comments
a) Responses emphasize the incontrollable release of microplastics and the intentional
spill over of emissions from microplastics during production. Improvements include
sustainable materials such as polyester.
b) Apropos washing cycles of textiles, one respondent proposes incineration methods for
microplastics that end up in waste-water treatment plants because filters in washing
machines are insufficient for full treatment.
c) Other measures include taxation on polluting textiles and emphasis on eco-conception
and regulations on fast fashion.
d) Among design related regulations, suggested measures include recycling modifications
for single type textiles and strict limits/possible phase out of elastane in fabrics.
e) One respondent claimed that pre-use washing of fabrics before market placement
reduces microplastic emissions more significantly than use-phase washing and hence,
they emphasize this measure over others. This highlights the need to include
microplastics as an important step of Life-Cycle Assessment for textiles.
4.7.2.4 Paints (N=98-105)
a. During which phase of the life cycle, microplastics emissions from paints are the most
significant?
Initial spray painting and end of life hold high significance for the stakeholders in terms of
microplastic emissions. However, for spray painting, Academic/Researcher Institutions are
split between believing it to be very little significant (42%) and very significant (42%) and
59% of NGOs believe that it is somewhat significant. (See Table 22)
b. Wear and tear of paints from –
Wear and Tear from Infrastructure, Cars, and Buildings hold very high significance among
many stakeholders. NGOs, Academic/Research Institutions, Public Authorities, EU citizens
believe that wear and tear from Cars, Infrastructure are significant while Business
Associations do not find it to be significant. (See Table 23)
Almost all stakeholders believe that roads, ships, and boats are significant for wear and tear
while the opinion of Business Associations and Company/Business Organisations is spread
across the significance scale. (See Table 24)
c. Emissions from the maintenance of –
Maintenance emissions from ships and boats are very significant for most stakeholders
except Business Associations and Companies/Business Organisations. (See Table 25)
NGOs, Business Associations and Companies/Business Organisations are split between
significance and insignificance for maintenance emissions from cars. NGOs (59%) and
Academic/Research Institutions (57%) find maintenance emissions from infrastructure to
be somewhat significant while Public Authorities (57%) and EU citizens (43%) gave a neutral
response. (See Table 26)
Almost all stakeholders find maintenance emissions from roads and buildings to be
significant. However, Business Associations (50%) and Companies/Business Organisations
(42%) gave a neutral response on the significance scale for the maintenance emissions from
roads. (See Table 26)
75
Table 22: Life cycle emissions (1-2): Initial Spray Painting and Paint End of Life
Contribution As
Completely
insignificant
I don’t
know/Not
applicable
Somewhat
significant
Very little
significant
Very
significant
Company/Business
Organisations
4% 26% 9% 43% 17%
Business associations 6% 28% 6% 44% 17%
NGOs 19% 59% 4% 19%
Academic/Research
Institutions
14% 43% 43%
Public Authorities 43% 43% 14%
EU citizens 3% 38% 26% 10% 23%
Non-EU citizens 100%
Others 50% 50%
Initial Spray Painting
Contribution As
Completely
insignificant
I don’t
know/Not
applicable
Somewhat
significant
Very little
significant
Very
significant
Company/Business
Organisations
22% 26% 13% 4% 35%
Business associations 17% 28% 11% 33% 11%
NGOs 11% 11% 78%
Academic/Research
Institutions
14% 86%
Public Authorities 43% 43% 14%
EU citizens 3% 33% 8% 3% 54%
Non-EU citizens 70% 100%
Others 50% 50%
Paint End of Life
76
Table 23: Wear and tear I (1-3): Wear and Tear from Cars; Wear and Tear from Infrastructure and
Wear and Tear from Buildings
Contribution As
Completely
insignificant
I don’t
know/Not
applicable
Somewhat
significant
Very little
significant
Very
significant
Company/Business
Organisations
26% 17% 17% 22% 17%
Business associations 50% 25% 13% 13%
NGOs 7% 67% 11% 15%
Academic/Research
Institutions
14% 57% 29%
Public Authorities 57% 43%
EU citizens 5% 35% 19% 14% 27%
Non-EU citizens 100%
Others 100%
Wear and Tear from Cars
Contribution As
Completely
insignificant
I don’t
know/Not
applicable
Somewhat
significant
Very little
significant
Very
significant
Company/Business
Organisations
9% 22% 26% 30% 13%
Business associations 13% 25% 19% 38% 6%
NGOs 15% 56% 30%
Academic/Research
Institutions
29% 29% 43%
Public Authorities 57% 14% 14% 14%
EU citizens 41% 16% 5% 38%
Non-EU citizens 75% 50% 100%
Others
Wear and Tear from Infrastructure
77
Table 24: Wear and tear II (1-2): Wear and Tear from Roads and Wear and Tear from Ships and Boats
Contribution As
Completely
insignificant
I don’t
know/Not
applicable
Somewhat
significant
Very little
significant
Very
significant
Company/Business
Organisations
4% 26% 22% 30% 17%
Business associations 18% 29% 18% 29% 6%
NGOs 7% 7% 4% 81%
Academic/Research
Institutions
29% 43% 29%
Public Authorities 43% 29% 29%
EU citizens 3% 42% 16% 8% 32%
Non-EU citizens 100%
Others 50% 50%
Wear and Tear from Buildings
Contribution As
Completely
insignificant
I don’t
know/Not
applicable
Somewhat
significant
Very little
significant
Very
significant
Company/Business
Organisations
17% 17% 35% 30%
Business associations 25% 25% 38% 13%
NGOs 11% 7% 81%
Academic/Research
Institutions
14% 29% 57%
Public Authorities 29% 14% 14% 43%
EU citizens 3% 35% 16% 46%
Non-EU citizens 100%
Others 100%
Wear and Tear from Roads
78
Table 25: Maintenance emissions I (1-3): Maintenance Emission from Ships and Boats; Maintenance
Emission from Cars and Maintenance Emission from Infrastructure
Contribution As
Completely
insignificant
I don’t
know/Not
applicable
Somewhat
significant
Very little
significant
Very
significant
Company/Business
Organisations
22% 17% 26% 35%
Business associations 6% 25% 50% 19%
NGOs 7% 93%
Academic/Research
Institutions
14% 86%
Public Authorities 25% 25% 13% 38%
EU citizens 3% 32% 16% 3% 46%
Non-EU citizens 100%
Others 100%
Wear and Tear from Ships and Boats
Contribution As
Completely
insignificant
I don’t
know/Not
applicable
Somewhat
significant
Very little
significant
Very
significant
Company/Business
Organisations
27% 23% 14% 9% 27%
Business associations 25% 25% 31% 19%
NGOs 49% 4% 45%
Academic/Research
Institutions
14% 86%
Public Authorities 25% 25% 50%
EU citizens 38% 16% 5% 41%
Non-EU citizens 7% 7% 85%
Others 50% 50%
Maintenance Emission from Ships and Boats
79
Contribution As
Completely
insignificant
I don’t
know/Not
applicable
Somewhat
significant
Very little
significant
Very
significant
Company/Business
Organisations
36% 23% 14% 23% 5%
Business associations 44% 25% 19% 13%
NGOs 41% 31% 27%
Academic/Research
Institutions
29% 57% 14%
Public Authorities 57% 43%
EU citizens 8% 38% 16% 16% 22%
Non-EU citizens 100%
Others 50% 50%
Maintenance Emission from Cars
Contribution As
Completely
insignificant
I don’t
know/Not
applicable
Somewhat
significant
Very little
significant
Very
significant
Company/Business
Organisations
27% 23% 18% 14% 18%
Business associations 19% 25% 31% 13% 13%
NGOs 15% 59% 26%
Academic/Research
Institutions
57% 29% 14%
Public Authorities 57% 14% 14% 14%
EU citizens 43% 22% 5% 30%
Non-EU citizens 100%
Others 50% 50%
Maintenance Emission from Infrastructure
80
Table 26: Maintenance Emissions II (1-2): Maintenance Emission from Buildings and Maintenance
Emission from Roads
Contribution As
Completely
insignificant
I don’t
know/Not
applicable
Somewhat
significant
Very little
significant
Very
significant
Company/Business
Organisations
24% 19% 14% 19% 24%
Business associations 18% 24% 18% 35% 6%
NGOs 7% 11% 4% 78%
Academic/Research
Institutions
29% 29% 43%
Public Authorities 29% 43% 14% 14%
EU citizens 3% 39% 18% 11% 29%
Non-EU citizens 100%
Others 50% 50%
Maintenance Emission from Buildings
Contribution As
Completely
insignificant
I don’t
know/Not
applicable
Somewhat
significant
Very little
significant
Very
significant
Company/Business
Organisations
10% 43% 5% 24% 19%
Business associations 6% 50% 19% 19% 6%
NGOs 7% 19% 74%
Academic/Research
Institutions
43% 29% 29%
Public Authorities 29% 43% 14% 14%
EU citizens 3% 38% 11% 8% 41%
Non-EU citizens 100%
Others 50% 50%
Maintenance Emission from Roads
81
d. How much do you agree with the following measures to reduce microplastic pollution due to
paints, depending on the application?
a) Among most stakeholders, there is complete agreement on the Promotion of alternative
solutions without paint to reduce microplastic pollution. However, Business Associations
(52%) and Companies/Business Organisations (40%) completely disagree. (See Table 27)
b) Most of the stakeholders agree with the measure of Including aspects of microplastics in
EU ecolabel and Green Public Procurement to reduce microplastic pollution. (See Table
27)
c) Almost all stakeholders agree on the measures of Regulated Dust Protection and Capture
for key industries and Regulation of plastic shares in paints to reduce microplastic
pollution while Business Associations (47%) completely disagree with the measure of
Regulation of plastic shares in paints. (See Table 28)
d) Business Associations (42%) completely or somewhat disagree, and Companies/Business
Organisations (56%) completely or somewhat agree for Increasing the share of
biodegradable plastics in paint as a measure to reduce microplastic pollution. While
Academic/Research Institutions (42%) completely disagree and the rest of stakeholders
completely or somewhat agree with the measure. (See Table 29)
e) Most of the stakeholders agree with the measure of Increasing Application yield and
Improving Lifetime of paints while NGOs (55%) are neutral about the measure to reduce
microplastic pollution. (See Table 29)
f) Most of the stakeholders agree with the measures of Dust cover improvements and Capture
scrap road markings to reduce microplastic pollution. (See Table 30)
g) Most of the stakeholders agree on the measure of Gypsum waste management in
construction and demolition waste while NGOs (55%) and Public Authorities (50%) take a
neutral stance. (See Table 31)
h) EU Citizens are broadly in agreement over all measures listed in the question.
82
Table 27: Paint Emission Measures: Promotion and Awareness (1-3): Promotion of Alternative
Solutions without Paints; Awareness of Unused Purchases and Include Aspects of Microplastics in EU
Ecolabel and Green Public Procurement
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
32% 41% 9% 14% 5%
Business associations 21% 53% 16% 5% 5%
NGOs 30% 4% 4% 63%
Academic/Research
Institutions
29% 14% 14% 14% 29%
Public Authorities 63% 13% 25%
EU citizens 67% 8% 3% 15% 5% 3%
Non-EU citizens 100%
Others 50% 50%
Promotion of Alternative Solutions without Paints
83
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
27% 14% 18% 41%
Business associations 39% 6% 11% 6% 33% 6%
NGOs 15% 4% 19% 15% 48%
Academic/Research
Institutions
14% 14% 14% 43% 14%
Public Authorities 38% 13% 13% 13% 25%
EU citizens 59% 13% 5% 8% 13% 3%
Non-EU citizens 100%
Others 50% 50%
Awareness of Unused Purchases
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
41% 27% 5% 5% 14% 9%
Business associations 26% 32% 5% 16% 11% 11%
NGOs 89% 4% 7%
Academic/Research
Institutions
29% 14% 43% 14%
Public Authorities 50% 13% 13% 25%
EU citizens 77% 5% 3% 5% 8% 3%
Non-EU citizens 100%
Others 50% 50%
Include Aspects of Microplastics in EU Ecolabel and Green Public Procurement
84
Table 28: Paint Emission Measures: Regulation and Operational Improvements (1-2): Regulate the
Share of Plastic in Paints and Regulate Dust Protection and Capture for Key Industries
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
27% 23% 14% 14% 14% 9%
Business associations 21% 47% 16% 11% 5%
NGOs 85% 15%
Academic/Research
Institutions
14% 14% 57% 14%
Public Authorities 50% 13% 13% 13% 13%
EU citizens 68% 3% 8% 5% 13% 5%
Non-EU citizens 100%
Others 50% 50%
Regulate the Share of Plastic in Paints
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
43% 4% 30% 22%
Business associations 33% 6% 11% 33% 17%
NGOs 85% 12% 4%
Academic/Research
Institutions
43% 57%
Public Authorities 63% 25% 13%
EU citizens 70% 3% 8% 8% 11%
Non-EU citizens 100%
Others 50% 50%
Regulate Dust Protection and Capture for Key Industries
85
Table 29: Paint Emission Measures: Regulation and Operational Improvements (contd., 1-4): Increase
Biodegradable Paint Content; Increase Application Yield; Increase Lifetime of Paint and Localised
Preventive Maintenance
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
26% 4% 4% 30% 35%
Business associations 21% 21% 11% 26% 21%
NGOs 15% 11% 59% 15%
Academic/Research
Institutions
14% 43% 14% 14% 14%
Public Authorities 38% 38% 25%
EU citizens 65% 5% 3% 5% 18% 5%
Non-EU citizens 100% 30%
Others 50% 50%
Increase Biodegradable Paint Content
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
18% 5% 9% 18% 36% 14%
Business associations 26% 16% 11% 16% 32%
NGOs 15% 19% 56% 11%
Academic/Research
Institutions
29% 14% 14% 14% 29%
Public Authorities 50% 25% 25%
EU citizens 56% 8% 3% 10% 21% 3%
Non-EU citizens 100%
Others 50% 50%
Increase Application Yield
86
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
27% 14% 32% 27%
Business associations 37% 5% 42% 16%
NGOs 67% 7% 11% 15%
Academic/Research
Institutions
43% 14% 14% 29%
Public Authorities 75% 25%
EU citizens 58% 8% 10% 20% 5%
Non-EU citizens 100%
Others 50% 50%
Increase Lifetime of Paint
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
36% 23% 36% 5%
Business associations 32% 26% 5% 32% 5%
NGOs 81% 7% 7% 4%
Academic/Research
Institutions
29% 14% 14% 43%
Public Authorities 38% 38% 13% 13%
EU citizens 56% 8% 10% 23% 3%
Non-EU citizens 100%
Others 50% 50%
Localised Preventive Maintenance
87
Table 30: Paint Emission Measures: Operational Improvements (1-3): Use Technologies Increasing
Dust Cover; Capture Scrapped Road Markings and Capture and Treat Road Run-Off Water
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
45% 9% 45%
Business associations 32% 11% 21% 37%
NGOs 81% 15% 4%
Academic/Research
Institutions
57% 14% 29%
Public Authorities 25% 75%
EU citizens 58% 5% 8% 26% 3%
Non-EU citizens 100%
Others 50% 50%
Use Technologies Increasing Dust Cover
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
52% 26% 4% 17%
Business associations 26% 47% 5% 21%
NGOs 81% 7% 11%
Academic/Research
Institutions
57% 29% 14%
Public Authorities 50% 25% 13% 13%
EU citizens 54% 10% 10% 23% 3%
Non-EU citizens 100%
Others 100%
Capture Scrapped Road Markings
88
Table 31: Paint Emission Measures: Operational Improvements (contd., 1-2): Cleaning Shipyards Prior
to Refloating of Ships and Boats and Gypsum Waste Management in Construction and Demolition
Waste
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
41% 41% 9% 9%
Business associations 16% 5% 37% 32% 11%
NGOs 19% 4% 11% 63% 4%
Academic/Research
Institutions
86% 14%
Public Authorities 50% 25% 13% 13%
EU citizens 67% 8% 10% 15%
Non-EU citizens 100%
Others 100%
Capture and Treat Road Run-Off Water
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
45% 18% 27% 9%
Business associations 37% 26% 16% 21%
NGOs 81% 19%
Academic/Research
Institutions
57% 14% 29%
Public Authorities 50% 25% 13% 13%
EU citizens 72% 8% 3% 18%
Non-EU citizens 100%
Others 100%
Cleaning Shipyards Prior to Refloating of Ships and Boats
89
4.7.2.5 Detergent Laundry and Automatic Dishwasher Capsules (N=35-42)
Some of these capsules have a plastic shell around the detergent that consists of polyvinyl alcohol
(PVA), a synthetic polymer, intended to dissolve in water, but that may not fully biodegrade, leaving
microplastics in the environment. The Detergents Regulation, currently under revision, already
regulates certain aspects of biodegradability of these capsules
a. Please provide any information regarding this shell and its biodegradability in wastewater and
its treatment, including possible releases of microplastics. (Open Text Comments)
i. While responses recognize the extant use of PVA in capsule shells, one response highlights
recent advances in using Casein, a milk protein, as a polymeric film which is water-soluble
and biodegradable. The comment encourages the recognition and further examination of other
alternatives apart from PVA shells.
ii. Another response highlights examining proper definitions of biodegradability in legislation
and regulation of microplastic emissions that include a temporal and location-based
degradation limit.
b. If there would be sufficient evidence about the microplastics emissions of detergent capsules, to
which extent would you agree with the following measures?
i. Almost all the stakeholders completely or somewhat agree of all the measures listed in the
Table 32.
ii. However, Business Associations were neutral on the measures of Incentivise Eco-friendly
Alternatives and Improve Waste-Water Treatment Plants. Public Authorities were neutral
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
36% 23% 23% 18%
Business associations 32% 5% 26% 16% 21%
NGOs 15% 22% 56% 7%
Academic/Research
Institutions
43% 14% 14% 29%
Public Authorities 25% 50% 13% 13%
EU citizens 64% 8% 5% 15% 8%
Non-EU citizens 100%
Others 100%
Gypsum Waste Management in Construction and Demolition Waste
90
on the measures of Improve Waste-Water Treatment Plants and Monitoring of PVA in
Waste-Water Treatment Plants. (See Table 32)
iii. All stakeholders completely or somewhat agree with the measures of restriction of non-
biodegradable water-soluble capsule shells, protocol to address the biodegradability of
dissolvable capsule shells in real life conditions and extended producer responsibility.
Business Associations are neutral with the measure of restriction of non-biodegradable
water-soluble capsule shells. (See Table 33)
Table 32: Emissions of detergent capsules I (1-4): Consumer Awareness; Incentivise Eco-Friendly
Alternatives; Monitoring of PVA in Waste-Water Treatment Plants and Improve Waste-Water
Treatment Plants
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
47% 13% 40%
Business associations 71% 7% 21%
NGOs 29% 4% 7% 61%
Academic/Research
Institutions
67% 33%
Public Authorities 33% 11% 33% 22%
EU citizens 79% 2% 19%
Non-EU citizens 100%
Others 50% 50%
Consumer Awareness
91
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
60% 13% 27%
Business associations 29% 7% 43% 21%
NGOs 25% 43% 7% 11% 14%
Academic/Research
Institutions
50% 17% 17% 17%
Public Authorities 78% 11% 11%
EU citizens 89% 2% 9%
Non-EU citizens 100%
Others 50% 50%
Incestivise Eco-Friendly Alternatives
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
43% 21% 29% 7%
Business associations 7% 21% 7% 57% 7%
NGOs 11% 11% 7% 68% 4%
Academic/Research
Institutions
50% 17% 17% 17%
Public Authorities 22% 22% 22% 22% 11%
EU citizens 77% 2% 17% 4%
Non-EU citizens 100%
Others 50% 50%
Monitoring of PVA in Waste-Water Treatment Plants
92
Table 33: Emissions of detergent capsules II (1-3): Protocol to Address the Biodegradability of
Dissolvable Capsule Shells in Real Life Conditions; Extended Producer Responsibility and Restrict
Non-Biodegradable Water Soluble Shells for Capsules
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
40% 7% 7% 13% 20%
Business associations 21% 7% 43% 14% 14%
NGOs 14% 7% 11% 14% 50% 4%
Academic/Research
Institutions
50% 17% 17% 17%
Public Authorities 11% 33% 33% 22%
EU citizens 77% 4% 17% 2%
Non-EU citizens 100%
Others 50% 50%
Improve Waste-Water Treatment Plants
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
64% 7% 7% 21%
Business associations 71% 7% 7% 14%
NGOs 36% 7% 7% 50%
Academic/Research
Institutions
67% 17% 17%
Public Authorities 67% 22% 11%
EU citizens 89% 2% 4% 4%
Non-EU citizens 100%
Others 50% 50%
Protocol to Address the Biodegradibility of Dissolvable Capsule Shells in Real Life Conditions
93
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
50% 14% 7% 7% 21%
Business associations 50% 21% 14% 7% 7%
NGOs 43% 4% 4% 50%
Academic/Research
Institutions
67% 33%
Public Authorities 44% 22% 11% 22%
EU citizens 83% 2% 13% 2%
Non-EU citizens 100%
Others 50% 50%
Extended Producer Responsibility
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
73% 7% 20%
Business associations 43% 14% 36% 7%
NGOs 89% 7% 4%
Academic/Research
Institutions
50% 17% 33%
Public Authorities 89% 11%
EU citizens 91% 9%
Non-EU citizens 100%
Others 100%
Restrict Non-Biodegradable Water Soluble Shells for Capsules
94
c. Open Text Comments
All unique responses received agree on regulating use by households, where suggestions include
promotion of manual dish washing and prohibition of plastic pot cleaners. Comments also
mention regulation of detergent discharge into water bodies.
4.7.2.6 Geotextiles (N=49-112)
1. How much do you agree with the following measures to reduce microplastic pollution from
geotextiles?
1.1. Most stakeholders completely agree with the following measures, Regulate the type of
fibre or polymer used and Promote alternatives and eco-friendly materials, to
reduce microplastic pollution while Business Associations are split on the agreement
scale (40% agreement; 45% disagreement). (See Table 34)
1.2. Business Associations completely or somewhat disagree (50%) with the measure to
regulate the range of applications while the rest of the stakeholders agree. (See Table
34)
1.3. Business Associations and Public Authorities take a neutral stance with the measure of
regulating emission limits while the rest of the stakeholders completely or somewhat
agree. (See Table 35)
Table 34: Emissions from Geotextiles I (1-3): Regulate the Types of Polymers and Fibers Used; Regulate
the Range of Applications for Geotextiles and Promote Alternatives
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
47% 7% 13% 27% 7%
Business associations 30% 40% 15% 10% 5%
NGOs 87% 4% 9%
Academic/Research
Institutions
43% 14% 43%
Public Authorities 33% 11% 11% 44%
EU citizens 83% 3% 3% 7% 3%
Non-EU citizens 75% 25%
Others 67% 33%
Regulate the Types of Polymers and Fibers Used
95
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
60% 13% 13% 13%
Business associations 15% 30% 15% 20% 20%
NGOs 83% 4% 4% 9%
Academic/Research
Institutions
43% 29% 29%
Public Authorities 33% 11% 11% 44%
EU citizens 71% 3% 3% 16% 6%
Non-EU citizens 75% 25%
Others 33% 67%
Regulate the Range of Applications ofr Geotextiles
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
56% 25% 6% 6% 6%
Business associations 25% 50% 5% 15% 5%
NGOs 96% 4%
Academic/Research
Institutions
57% 43%
Public Authorities 44% 11% 11% 33%
EU citizens 77% 3% 6% 10% 3%
Non-EU citizens 100%
Others 67% 33%
Promote Alternatives
96
Table 35: Emissions from Geotextiles II (1-2): Promote Eco-Friendly Materials and Regulate Emission
Limits
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
69% 25% 6%
Business associations 45% 5% 45% 5%
NGOs 96% 4%
Academic/Research
Institutions
57% 14% 14% 14%
Public Authorities 67% 11% 11% 11%
EU citizens 81% 6% 13%
Non-EU citizens 100%
Others 100%
Promote Eco-Friendly Materials
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
53% 7% 27% 13%
Business associations 21% 26% 5% 26% 16% 5%
NGOs 78% 4% 9% 9%
Academic/Research
Institutions
43% 29% 14% 14%
Public Authorities 11% 11% 33% 33% 11%
EU citizens 83% 3% 13%
Non-EU citizens 75% 25%
Others 67% 33%
Regulate Emission Limits
97
a. How much do you agree with the following statements related to the applications of geotextiles?
i. Geotextiles for Coasts
Almost all Public Authorities and EU citizens take a neutral stance when it comes to the types
of geotextiles that can protect the coast – either woven, non-woven, or made with natural
fibres. (See Table 36)
Businesses Associations, on the other hand, are in complete agreement of the efficacy of
geotextiles of all types. NGOs completely agree (70%) for geotextiles made with natural
fibres to protect the coast from erosion. They mostly disagree with non-woven geotextiles
(60%) and woven geotextiles (60%). (See Table 36)
Table 36: Coastal Erosion (1-3): Non-Woven Geotextiles can Protect Coasts from Erosion; Woven
Geotextiles can Protect Coasts from Erosion and Geotextiles from Natural Fibres can Protect Coasts
from Erosion
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
53% 7% 27% 7% 7%
Business associations 56% 17% 17% 11%
NGOs 4% 61% 17% 17%
Academic/Research
Institutions
14% 29% 14% 29% 14%
Public Authorities 13% 13% 50% 25%
EU citizens 13% 17% 50% 7% 7% 7%
Non-EU citizens 67% 33%
Others 33% 33% 33%
Non-Woven Geotextiles can Protect Coasts from Erosion
98
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
47% 7% 27% 13% 7%
Business associations 59% 18% 24%
NGOs 4% 61% 17% 17%
Academic/Research
Institutions
29% 14% 29% 29%
Public Authorities 13% 13% 50% 25%
EU citizens 21% 17% 48% 7% 7%
Non-EU citizens 67% 33%
Others 33% 33% 33%
Woven Geotextiles can Protect Coasts from Erosion
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
50% 25% 6% 6% 13%
Business associations 6% 11% 28% 11% 44%
NGOs 70% 17% 9% 4%
Academic/Research
Institutions
14% 14% 14% 43% 14%
Public Authorities 38% 13% 50%
EU citizens 42% 35% 6% 10% 6%
Non-EU citizens 25% 25% 25% 25%
Others 33% 33% 33%
Geotextiles from Natural Fibers can Protect Coasts from Erosion
99
ii. Geotextiles for Roads
All Academic/Researchers Institutions and Public Authorities remain neutral when it comes
to the types of geotextiles that can be used to build roads – either woven, non-woven, or
made with natural fibres. (See Table 37)
Businesses Associations on the other hand, are in complete agreement of the efficacy of
geotextiles of all types except natural fibres where they weakly agree (43%). (See Table 37)
EU Citizens (45%) largely prefer geotextiles made with natural fibres as material to build
roads. While they are mostly neutral on woven and non-woven geotextiles. NGOs completely
disagree on woven (60%) and non-woven (60%) geotextiles while completely agree on natural
fibres. (69.5%) (See Table 37)
Table 37: Road Construction I (1-3): Woven Geotextiles can be Used to Build Roads; Non-Woven
Geotextiles can be Used to Build Roads and Geotextiles from Natural Fibres can be Used to Construct
Roads
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
53% 7% 20% 7% 7% 7%
Business associations 58% 16% 21% 5%
NGOs 4% 61% 17% 17%
Academic/Research
Institutions
14% 14% 29% 29% 14%
Public Authorities 25% 13% 63%
EU citizens 20% 10% 50% 7% 10% 3%
Non-EU citizens 33% 33% 33%
Others 33% 33% 33%
Woven Geotextiles can be Used to Build Roads
100
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
60% 7% 20% 7% 7%
Business associations 53% 16% 16% 16%
NGOs 4% 61% 17% 17%
Academic/Research
Institutions
14% 14% 14% 43% 14%
Public Authorities 25% 13% 63%
EU citizens 17% 10% 50% 3% 7% 13%
Non-EU citizens 33% 33% 33%
Others 33% 33% 33%
Non-Woven Geotextiles can be Used to Build Roads
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
57% 7% 21% 14%
Business associations 39% 28% 11% 6% 17%
NGOs 70% 17% 9% 4%
Academic/Research
Institutions
14% 14% 14% 29% 29%
Public Authorities 13% 13% 75%
EU citizens 45% 39% 6% 6% 3%
Non-EU citizens 50% 25% 25%
Others 33% 33% 33%
Geotextiles from Natural Fibers can be Used to Construct Roads
101
iii. All Public Authorities and EU citizens are neutral for the non-existence of alternatives to
geotextiles for drainage while NGOs (82%) and Academic/Research Institutions (57%)
completely or somewhat agree with the statement. (See Table 38)
Table 38: Road Construction II
4.7.3 Part IV. All Addressed Sources: Pellets, Synthetic Textiles, Tyres, Geotextiles, Detergent
Capsules and Paints
1. How much do you agree with the following measures to reduce microplastic pollution in general?
(N=357)
a) Apart from Business Associations who are neutral, all other stakeholders at large completely
agree with a common system to monitor and report microplastic release throughout the
lifecycle of the source. All stakeholders completely or somewhat agree on the measure on
specific waste-water treatment in urban wastewater plants to reduce microplastic pollution.
(See Table 39)
b) There is an overwhelming support for international agreements across all stakeholders.
Business Associations are neutral and almost all other stakeholder groups completely or
somewhat agree on specific wastewater treatment in recycling plants to reduce the
microplastic pollution. (See Table 40)
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
6% 13% 31% 25% 19% 6%
Business associations 17% 17% 39% 28%
NGOs 74% 17% 9%
Academic/Research
Institutions
43% 14% 29% 14%
Public Authorities 25% 50% 13% 13%
EU citizens 13% 13% 50% 13% 7% 3%
Non-EU citizens 33% 33% 33%
Others 33% 33% 33%
There are no Alternatives to Geotextiles for Drainage
102
Table 39: General Emissions I (1-2): Common System to Monitor and Report Microplastic Releases
throughout Life-Cycle and Specific Waste Water Treatment in Urban Waste Water Plants
Contribution As Completely agree
Completely
disagree
I don't know/Not
applicable
Neither agree nor
disagree
Somewhat agree
Somewhat
disagree
Company/Business
Organisations
43.04% 11.39% 11.39% 2.53% 30.38% 1.27%
Business associations 25.00% 22.06% 11.76% 10.29% 26.47% 4.41%
NGOs 77.97% 3.39% 18.64%
Academic/Research Institutions 70.27% 8.11% 21.62%
Public Authorities 43.75% 12.50% 12.50% 18.75% 12.50%
EU citizens 66.67% 1.71% 1.71% 5.98% 22.22% 1.71%
Non-EU citizens 80.00% 20.00%
Others 60.00% 10.00% 30.00%
Company/Business
Organisations
46.91% 2.47% 18.52% 2.47% 28.40% 1.23%
Business associations 32.84% 2.99% 20.90% 11.94% 23.88% 7.46%
NGOs 42.37% 5.08% 11.86% 11.86% 28.81%
Academic/Research Institutions 56.76% 8.11% 24.32% 10.81%
Public Authorities 25.00% 18.75% 6.25% 31.25% 18.75%
EU citizens 69.75% 0.84% 2.52% 5.88% 19.33% 1.68%
Non-EU citizens 100%
Others 40.00% 10.00% 10.00% 10.00% 30.00%
Common System to Monitor and Report Microplastic Releases throughout Life-Cycle
Specific Waste Water Treatment in Urban Waste Water Plants
103
Table 40: General Emissions II (1-2): Specific Waste Water Treatment in Recycling Plants and
International Agreements
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
43% 1% 19% 6% 29% 1%
Business associations 25% 1% 39% 10% 22% 1%
NGOs 47% 2% 3% 8% 14% 25%
Academic/Research
Institutions
57% 6% 6% 31%
Public Authorities 44% 19% 13% 25%
EU citizens 76% 2% 3% 19%
Non-EU citizens 90% 10%
Others 40% 20% 10% 30%
Specific Waste Water Treatment in Recycling Plants
Contribution As
Completely
agree
Completely
disagree
I don't
know/Not
applicable
Neither
agree nor
disagree
Somewhat
agree
Somewhat
disagree
Company/Business
Organisations
56% 5% 7% 32%
Business associations 42% 10% 15% 31% 1%
NGOs 54% 2% 5% 24% 15%
Academic/Research
Institutions
84% 5% 11%
Public Authorities 63% 6% 25% 6%
EU citizens 80% 1% 6% 13% 1%
Non-EU citizens 90% 10%
Others 70% 10% 20%
International Agreements
104
2. Please provide any additional information regarding microplastics and the reduction of
emissions, in particular for paints, geotextiles, and detergent capsules. (Open Text Comments)
While responses in this section are along the lines of those described in Section 6.1.2.1 (d.), one
comment further accentuated the monitoring of and recognition of microplastic emissions at the
industrial site level, while also suggesting the development of up-to-date databases on sustainable
and eco-friendly alternative raw material. There is also a mention of studying fishing nets in
agriculture as a major emitter of microplastics.
3. Please provide any information if a significant fraction of the release might be in form of very
fine particles (smaller than 1 micron, also called nano plastics), either in general, either for one
of the specific sources, and the consequences that might have on possible measures. (Open Text
Comments)
In general, valid responses mention a lack of research for nano plastics, especially in terms of
their rate of degradability (or lack thereof) vis-à-vis microplastics and their rate of accumulation
over time.
One response claims that paints and tyres contribute the most to the emission of nano plastics.
There is also a need to examine forest ecosystems and micro-organisms where a lot of emissions
are bioaccumulated over time, especially for nano plastics.
5 STAKEHOLDER WORKSHOPS
To complement the OPC, several online stakeholder workshops were organised to inform and engage
stakeholders.
5.1 First stakeholder workshop: 16 September 2021
This first workshop had over 150 attendees from the industry, including SMEs, NGOs, Member
States, and researchers. It presented the overall context of the European Strategy for Plastics in a
Circular Economy as a part of Circular Economy Action Plan (CEAP) as well as the series of
initiatives to tackle all types of plastics in general and microplastics in particular.
The presentation of the study was made along with the problem definition specific to the three sources
(pellets, tyres, and textiles). The discussion also focused on additional sources of microplastics on
which the study could focus.
5.2 Second series of thematic stakeholder workshops: 22, 24, 25 November 2021
This workshop was of three half-day dedicated sessions, each dealing with a specific source. The
goal of this workshop was to update the participants on the state of the analysis and to identify
possible measures to reduce the unintentional release of microplastics, including pellets, into the
environment. A background note was sent out in advance to all participants to enable a useful
discussion.
The participants were split into 4 groups to increase participation and discussion. The groups
performed two activities:
1. Identification of measures and classification into different categories and vote from the
participants on which were their preferred measures to reduce emissions to the environment.
105
2. Analysis of the 20 measures which received the most votes using a matrix of effectiveness
against technical feasibility. The scale was from 0 to 5, with 0 being an ineffective measure
or a non-feasible measure and 5 being an extremely effective measure to tackle emissions or
a measure that could be easily implemented.
• 22 November 2021 – Textiles
Overall, 155 measures (including duplicates and measures that could be grouped together) were
identified by 44 participants (actively involved in the activities) out of more than 152 participants in
total to the workshop.
• 24 November 2021 – Tyres
Overall, 205 measures (including duplicates and measures that could be grouped together) were
identified by 49 participants (actively involved in the activities) out of more than 80 participants in
total to the workshop.
• 25 November 2021 – Pellets
Overall, 173 measures (including duplicates and measures that could be grouped together) were
identified by 41 participants (actively involved in the activities) out of more than 70 participants in
total to the workshop.
After the breakout sessions, a plenary session was organised where the measures were presented and
discussed with stakeholders.
5.3 Third stakeholder workshop: 17 February 2022
This workshop focused on the new sources (paints, detergent capsules and geotextiles) as the scope
of the analysis was expanded to these sources. It was attended by more than 100 participants. The
presentation of the analysis was made along with the problem definition specific to the new sources.
The methodological approach was explained to stakeholders and inputs were requested.
5.4 Fourth stakeholder workshop: 17 March 2022
The goal of this workshop was to update the participants on the state of the analysis and to identify
possible measures to reduce unintentional release of microplastics, including pellets, into the
environment. A background note was sent out in advance to all participants to enable a useful
discussion. It was organised in 3 breakout sessions, one each on paints, detergent capsules and
geotextiles.
The paint session was attended by 42 participants and 61 ideas about potential measures were
collected.
The geotextiles session was attended by 28 participants and 58 ideas about potential measures were
collected.
The detergent capsules session was attended by 25 participants and 9 ideas about potential measures
were collected.
After the breakout sessions, a plenary session was organised where the measures were presented and
discussed with stakeholders.
106
5.5 Fifth stakeholder workshop: 21 March 2022
This workshop presented the progress on tyres, pellets and textiles, in particular the screening of
measures and initial analysis of impacts of these measures. The workshop was attended by more than
200 participants.
5.6 Sixth stakeholder workshop dedicated to Member States representatives: 23 March 2022
This dedicated workshop presented the progress on all six sources and feedback was collected from
MS representatives. The meeting was attended by 27 participants including participants from the
Commission.
5.7 Seventh stakeholder workshop on pellets: 12 December 2022
This dedicated workshop engaged in an in-depth discussion on baseline and policy options related to
pellets. The meeting was attended by 53 participants covering NGOs, industry, and some Member
States.
6 SME CONSULTATION
As an important part of the pellets volume is handled by SMEs, a dedicated SME consultation was
carried out. The results can be found in Annex 12.
7 BILATERAL CONSULTATIONS
Extensive consultations were made with stakeholders (in particular, industry representatives relevant
for the six sources, NGOs, as well various Commission services and other EU organisations such as
EEA). An online tracker was maintained on the status and outcome of these meetings, which was
regularly shared with DG ENV.
The objective of these meetings was to collect feedback on different steps of the analysis and seek
additional data and evidence. The excel file indicating these consultations was made available
through Teams.
107
Annex 3:
Who is affected and how?
1 PRACTICAL IMPLICATIONS OF THE INITIATIVE ON PELLETS
This annex sets out the practical implications of the preferred option for the various types of
stakeholders concerned. The table below summarises such implications. This is followed by a
summary per impact (economic, environmental, social), and overview tables for the preferred option.
Stakeholders
Businesses and
the economy at
large
Businesses will benefit from the reduction of pellet losses and, therefore, from the
reduction of adverse impacts linked to pellet losses. Reducing pellet losses will have
positive knock-on economic effects on pellet businesses including reduced waste, less
legacy pellet pollution, modernised equipment, improved staff awareness, reduced
fire risk and improved reputation. On reduced waste, the analysis has demonstrated
that for businesses owning the pellets, there would be an economic gain of EUR 25-
141 million, thanks to the 25-141 thousand tonnes of pellets that would not
be lost anymore (1000 EUR/t). It will also save annually 98 000 – 551 000 tonnes
of GHG emissions. It is also expected that the playing field will be levelled, thus
reinforcing the position of companies applying measures vis-à-vis companies that do
not apply such measures, which would be beneficial for the sector as a whole.
In areas that are particularly affected by pellet losses, reducing such losses will also
have positive knock-on economic effects on commercial fishing and agriculture as
well as recreation and tourism.
At the same time, Option 1 “Mandatory standardised methodology” will have one-off
costs for developing and testing the methodology that would have a higher impact on
SMEs. Option 2b “Mandatory requirements” will entail direct compliance costs for
every pellet handling company. In particular, the option will entail both adjustment
(e.g. investing in equipment) and administrative (e.g. notifying certification) costs, as
well as charges (i.e. auditing and certification by independent private bodies). The
pellet industry will bear these costs. As it is already moving towards both the
application of measures and a system of external auditing and certification, the direct
economic costs will only be higher than those envisaged in the baseline for those firms
that will not take actions in the meanwhile. In addition, this option foresees a series
of mitigation measures (Option 2b) to alleviate the direct economic costs on the micro
and small companies present in the pellet supply chain to mitigate concerns from
SMEs (e.g. lack of staff/time, lack of information on risks and solutions and lack of
financial resources). These measures will prevent these actors, who only represent a
minor share of pellet losses, to make these costly investments which would have
limited environmental benefits. It can thus be recommended.
There would be cost savings thanks to the single harmonised measurement
methodology to assemble the loss data and lower verification costs (option 1). The
subsequent implementation costs of this methodology will be for industry, but they
are already fully covered by their reporting obligation under the new REACH
restriction. Therefore, the additional reporting under Option 2b (compliance) would
result only in a very minor cost.
The analysis undertaken shows that the market benefits of reducing pellet losses
outweigh the costs of the measures needed to meet mandatory requirements.
108
Public
authorities/admini
strations
Under Option 1, there will be costs for developing the harmonised measurement
methodology, which could be borne by industry and/or public authorities. There could
be cost for public authorities to assemble the loss data.
Under option 2, increasing the stringency of requirements and of implementation can
be expected to lead to an increase in direct administrative and enforcement costs on
public authorities (e.g. public register, data collection, verification, correction and in
the case of non-compliance, corrective measures and, where relevant, penalties).
End Users Citizens, consumers and the society in general will benefit from better understanding
of pellet losses under Option 1. Option 2b “Mandatory requirements” will result in a
reduction of pellet losses to a level consistent with the Commission’s overall
microplastic releases reduction target of 30% by 2030, thus bringing overall benefits
for citizens, consumers and the society in general.
Economic impacts on businesses - summary
Impact
categories
Qualitative
scoring of
impact
Affected
stakeholders
Description of impact
Adjustment
costs and
conduct of
business
- Pellet
manufacturers
(virgin pellets),
plastics recyclers
(recycled
pellets), pellet
convertors,
pellet
transporters and
storage operators
There will be additional costs to put in place
measures to prevent and contain pellet spills and
losses. However, as the industry is already
moving towards an OCS certification scheme, a
part of industry will have anticipated these
additional costs.
Operators (including SMEs) will also benefit
economically thanks to modernised equipment,
improved reputation, reduced waste and a level
playing field.
Administrative
burdens on
businesses
- Same as above The administrative burden will increase because
of reporting requirements for the certification
scheme, beyond the existing voluntary scheme.
Operation /
conduct of
SMEs
- /0 SMEs represent
a significant
share of the
pellet supply
chain, especially
converters and
logistics, and
will be affected
The impact will be in terms of measures needed
to prevent and contain pellet spills and losses
and reporting requirements for the certification
scheme. Option 2b sets lighter requirements for
micro- and small enterprises.
Functioning of
the internal
market and
competition
0 All actors in the
pellet supply
chain
If action is taken at EU level, the functioning of
the internal market can be improved (same
obligations on every operator, level playing
field among them). The additional estimated
cost of option 2b would represent about 0.13%
of the EU plastics sector turnover, which would
have a minor impact on its competitive
advantage.
109
Impact
categories
Qualitative
scoring of
impact
Affected
stakeholders
Description of impact
Public
authorities:
Change in costs
to authorities for
compliance and
enforcement
activities
0/- Member State
competent
authorities
The impact would be low or negative.
Depending on their pellet responsibilities (data
collection, verification, correction and
enforcement), they will need to manage the
monitoring, enforcement and receive the data
from companies, so there might be additional
human resources needed.
Public
authorities:
Change in costs
to the
Commission
- European
Commission /
and EU
institutions
There might be costs involved with the
development of a measurement standard, but
there are cost savings in the existing reporting
obligations towards ECHA.
Innovation and
research
-/+ Researchers The development of a measurement standard
(under option 1) will improve knowledge on
plastic pellet losses.
Third countries
and
international
relations
+/- Third countries No direct effects expected. As with other
legislation, third countries could set up similar
measures as a consequence of this initiative.
Consumers and
household (end
users)
0/- Households Measures could lead to a very slight increase in
the price of plastic pellets, and therefore plastic
products. However, industry might choose to
absorb this increase, meaning consumers would
not be impacted.
110
Environmental impacts - summary
Impact
category
Qualitative
scoring of
impact
Affected
stakeholders
Description of impact
Quality of
natural
resources
+++ General
public
Reduced pellets loss to the environment will results in
a better quality of natural resources, improved eco-
systems, improved biodiversity and improved services
for the economy and society (e.g. fisheries), with the
general public being the affected group.
Efficient use
of raw
materials
+ Plastic
industry
Less pellet losses leads directly to the more efficient
use of pellets
International
environmental
impacts
++ General
public, sea
food
industry
Pollution caused by pellet loss affects both cross-
border river basins and the seas and is, therefore, an
important international impact. Reduced pellet loss
will therefore lead to improved ecosystems and
biodiversity globally.
Waste
production,
generation
and recycling
and its impact
on land use
+ Wastewater
treatment
companies
Potentially
tourism and
agricultural
sectors
The accumulation of pellets may impact wastewater
treatment infrastructure. If not properly managed,
pellets can pile up in certain areas (such as coastal
areas) and negatively impact other activities (tourism).
As well as agriculture as around half of the sludge
from wastewater is applied on agricultural land.
Climate
change
+ No specific
group is
impacted
Reducing pellet loss will lead to less GHG emissions,
as less plastics will be needed. There could be indirect
effects on plankton growth.
Social impacts - summary
Impact
category
Qualitative
scoring of
impact
Affected
stakeholders
Description of impact
Public
health and
safety
+ Public &
pellet value
chain
employees
There are potential health impacts caused by
microplastics, thus a reduction in pellet loss will
reduce risks to human health. Fewer pellet spills will
also increase safety at work.
Affected
populations
+ Populations
in affected
areas
Reducing pellet losses will alleviate negative effects
on affected populations, for example, by improving
tourism, recreation, agriculture, and fishing.
Employment + Plastics
industry &
public
authorities
The measures will create more job opportunities in the
plastic sector, and more widely in public authorities if
additional resources are required for the compliance
checks.
111
2 SUMMARY OF COSTS AND BENEFITS
The following table outlines the benefits, both direct and indirect, of the preferred option.
I. Overview of Benefits (total for all provisions) – Preferred Option
Description Amount Comments
Direct benefits
Reduction in pellet
losses
Measures under the preferred option could
potentially result in the reduction of pellet
losses to the environment in the range of
25 142 to 140 621 tonnes by 2030, which
will reduce adverse impacts on water
resources (both marine and freshwater and
management wastewater).
As the reduction potential of all
measures under the preferred option
cannot be calculated, this estimation
is conservative. All stakeholders
will benefit because this will result
in better environmental quality.
Improved
understanding of
pellet loss pathways
and mechanisms in
reaching the
environment
The measurement standard and reporting
will improve the availability of data on pellet
losses.
This benefit will be mostly for the
industry and public authorities. This
will be of much use in designing
better products, monitoring the
effectiveness of reduction measures.
Creation of a level-
playing field
Option 2b will create a level playing field
among different actors within the plastic
value chain. It will also bring a competitive
advantage to the EU industry by improving
its global reputation around environmental
protection and moving towards a circular
economy. Better pellet management will
increase the image of the EU industry.
It could also negatively affect the
competitiveness of the EU industry
if a downstream actor in the value
chain imports pellets from outside
the EU, which could be cheaper in
the absence of regulatory
requirements.
Indirect benefits
Safer work
environment
The measure will reduce the amount of pellet
spills and benefit the safety of employees
working throughout the pellet chain by
reducing their chances of falling. As a result,
there will be fewer work accidents
contributing to a safer work environment.
Healthier soil The measure will reduce the quantities of
pellets in soil due to less losses through direct
spills or through the use of sewage sludge as
a fertiliser.
112
Benefits to ecosystem
services
The measure will reduce the quantities of
pellets in affected areas, having knock-on
effects on sectors such as tourism and
recreation (increased attractivity of the
region), fisheries (less pellets being absorbed
by marine animals) and agriculture (less
pellets being released on soils).
Reduced costs for
affected populations
The measure will reduce the need for local
populations to finance clean-up operations
following a spill.
(1) Estimates are gross values relative to the baseline for the preferred option as a whole (i.e. the impact of individual
actions/obligations of the preferred option are aggregated together); (2) Please indicate which stakeholder group is the
main recipient of the benefit in the comment section;(3) For reductions in regulatory costs, please describe details as to
how the saving arises (e.g. reductions in adjustment costs, administrative costs, regulatory charges, enforcement costs,
etc.;).
The following table provides an overview of the costs of the preferred option.
113
II. Overview of costs – Preferred option
Citizens/Consumers Businesses Administrations
One-off Recurrent One-off Recurrent One-off Recurren
t
Action
(a)
Direct
adjustment costs
No one-off
cost
A possible
minor
increase in
the price of
pellets could
be passed on
to the
downstream
users and,
ultimately
citizens
because of
an increase
in the price
of plastic
products.
The businesses
need to adapt
their operations
and
administrative
procedures to
the new
requirements by
the preferred
option.
Developing the
measurement
standard (option
1) will entail
adjustment costs
between EUR
1.3 – 3.2
million,
however
compensated by
recurrent
savings in using
a single method
and in reporting.
Costs for
applying the
methodology
developed
under option 1
for
monitoring
however
compensated
by recurrent
savings on
reporting.
Actions for
implementing
pellet loss
reduction
measures
(EUR 332 to
447 million of
pellets
handled
during
production,
processing or
logistics
operations).
Businesses
could choose
to absorb
these or pass
them on to
consumers.
Administra
tions
would
potentially
directly
support the
investment
s needed to
develop
new
methodolo
gies and
standards
(option 1).
Administr
ations will
need to
ensure the
enforceme
nt of EU
law on
pellets and
review the
reports
submitted.
Direct
administrative
costs
None None
Setting up
systems in
businesses for
administrative
procedures to
report pellet
EUR 43.9
million from
the costs for
internal
assessment
(EUR 30.8
million),
external audit
and/or
certification
and
Setting up
systems in
Member
States for
administrat
ive
procedures
(EUR 36
Costs
(EUR 125
000) for
enforceme
nt and
analysis of
the
reported
data.
114
losses (EUR 0.1
million 5
).
notification
(EUR 12.9
million), and
minor costs
(EUR 0.2
million) for
data
collection,
verification,
correction and
enforcement,
but more cost
savings
expected in
the existing
reporting.
700 6
),
including
setting up a
register of
certified
companies.
Direct
regulatory fees
and charges
None None
None Only if public
authorities
decide to put
fees in place.
None None
Direct
enforcement
costs
None None
Putting in place
administrative
procedures.
Minor costs
for
notification.
Putting in
place
administrat
ive
procedures
, including
measures
for
ensuring
complianc
e.
Costs for
enforceme
nt and
analysis of
the
reported
data.
(1) Estimates (gross values) to be provided with respect to the baseline; (2) costs are provided for each identifiable
action/obligation of the preferred option otherwise for all retained options when no preferred option is specified; (3) If
relevant and available, please present information on costs according to the standard typology of costs (adjustment costs,
administrative costs, regulatory charges, enforcement costs, indirect costs;).
5
Total initial cost are EUR 0.5 million for businesses, which have been annualised over a 5 year period using a discount
rate of 3% (0.5 hour for medium and large businesses and 0.25 hour for small and micro businesses and using EU
average wages (29 €/hour)). It is estimated that the internal assessment is already covering most of the related cost.
6
Total initial cost are EUR 313 000 million for public authorities, which have been annualised over a 10 year period
using a discount rate of 3% (50 person days in average for each Member State using EU average wages (29 €/hour)).
115
III. Application of the ‘one in, one out’ approach – Preferred option
[44 M€]
One-off
(annualised total net present
value over the relevant period)
Recurrent
(nominal values per year)
Total
Businesses
New administrative
burdens (INs)
Setting up systems in
businesses for administrative
procedures to report pellet
losses (EUR 0.1 million7
).
Costs for internal assessments,
external auditing and certification
of about EUR 43.9 million:
- internal assessment – EUR 30.8
million
- external audit and/or certificate –
EUR 12.9 million
- filling forms and tables – EUR
0.2 million (for notifying public
authorities of the certification).
EUR 44 mln €
Removed
administrative
burdens (OUTs)
None None None
Net administrative
burdens*
EUR 0.1 mln € EUR 43.9 mln € EUR 44 mln €
Adjustment costs**
The businesses need to adapt
their operations and
administrative procedures to
the new requirements by the
preferred option.
Developing the measurement
standard (option 1) will entail
adjustment costs between EUR
1.3 – 3.2 million, however
compensated by recurrent
savings in using a single
method and in reporting.
Costs for applying the methodology
developed under option 1 for
monitoring however compensated by
recurrent savings on reporting.
Actions for implementing pellet loss
reduction measures (EUR 332 to 447
million of pellets handled during
production, processing or logistics
operations).
Businesses could choose to absorb
these or pass them on to consumers.
Citizens
New administrative
burdens (INs)
None None None
Removed
administrative
burdens (OUTs)
None None None
Net administrative
burdens*
None None None
Adjustment costs** None
A possible minor increase in the
price of pellets could be passed on to
the downstream users and, ultimately
citizens because of an increase in the
price of plastic products.
7
Total initial cost are EUR 0.5 million for businesses, which have been annualised over a 5 year period using a discount
rate of 3% (0.5 hour for medium and large businesses and 0.25 hour for small and micro businesses and using EU
average wages (29 €/hour)). It is estimated that the internal assessment is already covering most of the related cost.
116
Total administrative
burdens***
EUR 0.1 mln € EUR 43.9 mln € EUR 44 mln €
(*) Net administrative burdens = INs – OUTs;
(**) Adjustment costs falling under the scope of the OIOO approach are the same as reported in Table 2 above. Non-
annualised values;
(***) Total administrative burdens = Net administrative burdens for businesses + net administrative burdens for citizens.
3 RELEVANT SUSTAINABLE DEVELOPMENT GOALS
The following table sets out the Sustainable Development Goals which are of relevance to the
preferred option.
III. Overview of relevant Sustainable Development Goals – Preferred Option
Relevant SDG Expected progress towards the Goal Comments
SDG 14 – Conserve and
sustainably use the
oceans, seas and marine
resources for sustainable
development
A reduction in the amount of pellet losses to
the marine environment.
SDG 2 – Ensure healthy
lives and promote well-
being for all at all ages
Reduced microparticles from degradation and
fragmentation of pellets also contribute to air
pollution that is one of the causes for
respiratory diseases. Similarly, reducing
pellets losses into water will also ensure a less
polluted food chain.
SDG 12 - Ensure
sustainable consumption
and production patterns
Reducing pellet losses leads to a more
efficient use of resources (here, pellets) and
thus more sustainable production patterns.
117
Annex 4:
Analytical methods
1 METHODOLOGY USED FOR THE INITIATIVE ON PELLETS
The methodology to develop this initiative follows the Commission Better Regulation Guidelines.
These guidelines place an emphasis on the need for analysis to rely on evidence-based knowledge
and scientifically robust methods.
There are significant knowledge gaps in the field of pellet losses, but it is an active field of research,
and new evidence is appearing every day in scientific journals, national policy and international
initiatives from multilateral organisations (e.g. OECD, UN), industry-led voluntary initiatives and
civil society organisations. Main assumptions used in this impact assessment are presented below.
Stakeholders were consulted to ensure the plausibility of these assumptions.
All calculations were done for a base year, 2030.
Assumptions for pellet production in the EU
The data sources and assumptions used to estimate the total quantity of pellet production volumes
and projections until 2030 are the following:
• 2019 is taken as the base year, as 2020 is an outlier because of COVID, and we are seeing
positive growth trends again from 2021;
• For virgin pellets, the projections are made from 2019 figures8
; a growth rate of 0.9% per
year is assumed till 20309
;
• The source for recycled pellets production data (2019-2021) is Plastic Recyclers Europe; a
growth rate of 5.6% per year is assumed10
;
• The source for bio-based pellets production data (2019-2021) is Plastics Europe; for a growth
rate CAGR of 14% for 2022-202711
, and the same trend is assumed to continue till 2030;
• Pellets imports and exports figures for virgin pellets are from Eurostat; a growth rate of 0.9%
is assumed till 2030.
Assumptions for quantifying chronic pellet losses
There is no harmonised methodology for measuring pellet losses. Neither pellet loss measurements
have been made at different steps of the value chain, nor are any systemic monitoring and reporting
data available within the Member States or the industry to calculate the pellet losses. Hence, it is
impossible to establish exact figures on pellet losses at each step because it depends on the installation
size, actors involved, management practices, etc., and all these aspects are very heterogeneous in the
8
Plastics Europe changed the calculation method in 2021, excluding adhesives, paints and coatings, thus not used to
be coherent with previous year estimates and also with import/export figures
9
Plastics Europe and SystemIQ
10
K 2022 - Trend Report Europe https://www.k-online.com/en/Media_News/Press/Technical_article/K_2022_-
_Trend_Report_Europe
11
Nova Institute (2023) Bio-based Building Blocks and Polymers Global Capacities, Production and Trends 2022–2027
https://renewable-carbon.eu/publications/product/bio-based-building-blocks-and-polymers-global-capacities-
production-and-trends-2022-2027-short-version-pdf/
118
EU. Approaches to quantifying the amount of pellets entering the environment typically apply a ‘loss
rate’ to the pellet volume handled. Robust empirical evidence is scarce to inform a ‘loss rate’ at
different steps. However, the greater the number of steps at which pellets are handled, the greater the
opportunities for loss.
The following loss rates were assumed for calculating the losses occurring at four major steps:
production, processing, recycling and logistics. It is estimated that losses happen at a higher rate at
processing and recycling installations because of relatively small installations and a large number of
steps than at production ones, and at an even higher rate during logistics operations.
• Production: 0.01% - 0.03%
• Processing: 0.02%-0.06%
• Recycling: 0.02%-0.06%
• Logistics: 0.03%-0.12%
These rates account for the major handling steps in production, processing, recycling and logistics
phases and do not take account of other handling steps occurring in other phases (e.g. distribution),
for which no information is available. These figures are, therefore, at the same time uncertain due to
the lack of a standardised methodology to measure pellet losses and scarce data.
Pellet loss calculations were made using these ranges of pellet loss ratios (lower and higher figures)
for the four types of operations, namely virgin pellet production, recycling, pellet processing and
logistics. These pellet loss ratios are applied to the volume of pellets handled during different steps
of the plastic value chain.
Table 41: Pellet losses (tonnes per year) per sector and per size of the companies in 2030
Micro Small Medium Large Total
Production 0 0 0 8051 – 24 153 8051 – 24 153
Waste
management,
including
recycling
0 0 0 2743 – 8228 2743 – 8228
Conversion 727 – 2182 2909 – 8727 6644 – 19 930 8284 – 24 852 18 564 – 55 691
Logistics
2801 – 11 203 5334 – 21 334 8372 – 33 488 16 314 – 65 258 32 821 – 131 283
Total
3528 – 13 385 8243 – 30 061 15 015 – 53 418 35 392 – 122 491 62 178 – 219 355
Impact of existing initiatives in reducing pellet losses
The assumptions used for estimating the impact of the voluntary initiatives (OCS certification and
RecyClass) and legislation in Member States (France) in terms of reduction of pellet losses in 2030
are the following.
119
• Production: 90% of the total virgin pellet volume produced (by the members of Plastics
Europe) and 5% for the non-Plastics Europe members will be certified compliant against OCS
new rules and will be effectively implementing such rules with a success rate ranging from
60% to 80%;
• Recycling: 20% of the total recycled pellet volume will be certified compliant against
RecyClass pellet provisions and will be effectively implementing the new provisions with a
success rate ranging from 40% to 60%;
• Processing: 30% of the total volume processed will be certified compliant against OCS’ new
rules and will be effectively implementing such rules with a success rate ranging from 40%
to 60%;
• Logistics: 40% of the total volume handled by logistics companies will be SQAS assessed
and will be effectively implementing such a scheme with a success rate ranging from 40% to
60%.
• French legislation: It will cover about 85% of the French pellet volume (about 10% of the EU
volume), leading to a 60-80% pellet loss reduction in 2030.
Assumptions taken in the calculation of the impacts of certain options
The assumptions used for estimating the costs of the measures for the relevant industry were based
on data from the industry and Eurostat and are the following:
• Converters: The average costs for a small, medium and large converting enterprise, were
calculated based from the converting industry data. They were based on Belgium and West-
European figures. A correction factor (based on the relation between a Belgium and EU
average salary) was used. The costs for the micro-enterprises were extrapolated from the three
other categories.
• Producers: Large enterprise costs for converters were applied to plastic producers (including
virgin and recycled plastics, export and import) as they are generally large companies.
• Logistics: It was also assumed that the structure of the whole transport sector (goods) could
be applied on the subsector of transport dealing with pellets. The same assumption was made
to the storage providers. The costs for the logistics operators (transport and storage providers,
cleaning stations) were based on the basic assumption that the measures needed to be taken
by a logistics enterprise are largely similar to a plastic converter enterprise. As an important
part of the cost are related to personnel, it was assumed that an enterprise with the same
number of persons would occur the same cost structure, and this for the main types: micro-,
small, medium and large enterprises. Assumptions per industry (for each enterprise type):
o storage providers, the same cost as for converters;
o transport providers, no costs related to equipment and investments, only to personnel,
external auditing and miscellaneous. It was assumed that 50% of the micro-enterprises
in the transport sector will be subject to additional costs.
o no additional costs for tank cleaning stations as those dealing with pellets are already
complying with SQAS which has similar requirements.
As the industry has already started implementing some of the proposed measures through their
voluntary programs, such as OCS CS and RecyClass, some of these costs will already be incurred in
the business-as-usual scenario, i.e. under the baseline. For this, the average of the assumptions used
under “Impact of existing initiatives in reducing pellet losses” were used.
120
The total cost for enterprises was then calculated based on the volume (tonnes) of pellets handled by
enterprise type. For the plastic converters and producers, it was calculated on a per tonne basis, using
cost figures for a typical plant for each enterprise type. For the transport and storage providers, it was
calculated per enterprise within each enterprise type. The cost calculation was made using ranges
(lower and higher figures). Therefore, lower figure of the cost scenario is linked with lower figure of
the pellet reduction scenario and higher costs are linked to higher pellet reduction. Therefor one
should compare lower figure of a range of one option with the lower figure of a range of another
option, (or the higher figure of a range over the different options).
Uncertainties and data gaps
The principal uncertainty comes from the loss rates used for production, recycling, processing, and
logistics. There are uncertainties regarding the potential success of existing and upcoming measures
on the reduction of pellet loss.
There are data gaps on the structure of the sector (except for converters and producers), as well as
on the exact costs and benefits that should be attributed under the different options, leading to some
uncertainties. However, this could be solved using the assumptions as explained before.
There are very few data available on the packaging used within the sector, and the impact packaging
has on pellet losses.
2 OVERVIEW OF METHODOLOGICAL STEPS
1. The first step was to define the problem for which extensive desk research was conducted, as well
as workshops with stakeholders and experts. The objective was to identify the main sources of
microplastics and their relative contribution to microplastics present in the environment. While
three main sources (pellets production and use, tyre abrasion, and synthetic textiles) were evident
from the existing knowledge, more research and consultation led to the addition of three sources
in the scope of this initiative: paints, detergent capsules, and geotextiles. These six sources were
chosen due to the magnitude of their contribution to microplastic releases in the environment.
Overall, these six sources cover up around 90% of the total microplastic emissions in the EU.
2. While this initiative in the end only focusses on pellets, analytical work was first undertaken for
all the sources identified. The analytical work on the other sources (paints, tyres, geotextiles,
textiles and detergent capsules) is presented in Annex 15 and shows that there is potential to
reduce and prevent unintentional microplastic releases from these 5 sources. In line with Better
Regulation guidelines, they were not pursued here as the preliminary analysis demonstrated that
existing or forthcoming instruments were better suited to targeting those sources, and/or that
additional data needs to be collected on cost-effectiveness and on the impacts of alternatives. A
major conclusion of this preliminary analysis is the lack of established methodology to estimate
the amount of microplastics released of these six product groups.
3. The information collected on pellets was, however, deemed sufficient for action to be taken.
Especially, as there is currently no existing EU legislation specifically addressing plastic pellets
as a form of pollution occurring along the entire supply chain.
4. While analysing pellets’ contribution to microplastic releases, a major problem was identified:
current practices for handling pellets lead to losses at each stage in the supply chain, causing
adverse environmental and (potential) human health impacts.
5. Deriving from this problem, several problem drivers were identified, namely market failure due
to prices not reflecting negative externalities, market failure in the shape of imperfect information,
and regulatory failure as existing EU legislation does not address pellets sufficiently.
121
6. The problem and its drivers led to the overall objective to prevent and reduce pellet losses to the
environment that are due to current handling pellet practices at all stages of the supply chain.
Three more specific objectives were also set out: reduce pellet losses to a level consistent with
the 30% reduction target for microplastic releases by 2030 set out by the EU Zero Pollution
Action Plan, improve information on pellet losses, and ensure appropriate mitigation of impacts
for SMEs.
7. To achieve these objectives, it was essential to identify policy options that could reduce pellet
losses. These options were selected based on available literature and input from stakeholders,
either bilateral or in stakeholder workshops, including a workshop organised in December 2022
to specifically address pellets, the related baseline and preferred option. Information provided in
response to the Inception Impact Assessment and the Public Consultation was also taken into
account along with the findings of a survey carried out between January and February 2023
targeting only SMEs active in the pellet supply chain.
8. The measures within these policy options had previously been selected been selected from a first
long list of measures, according to the screening criteria of the Better Regulation Guidelines and
in coordination with stakeholders and the Inter-Service Consultation group.
9. Following the assessment of the different options in terms of their environmental, economic and
social impacts on different stakeholders and society, these options were compared, and a preferred
option was constructed.
10. To calculate the impact for the enterprises, who are dealing with the plastics pellets in the supply
chain, data from industry and Eurostat was taken into account.
122
Annex 5: Competitiveness Check
1 OVERVIEW OF IMPACTS ON COMPETITIVENESS
Aspect of competitiveness Magnitude
(++, +, 0,, -, -- or n.a.)
Reference to
description in main
IA report or annex
Costs and prices - Sections 6 and 8.2
Annexes 3 and 11
Capacity to innovate N/A N/A
International competitiveness - Sections 6 and 8.2
Annexes 3 and 11
SME competitiveness - Section 8.2.3
Annex 12
2 ASSESSMENT AND EXPLANATION
The turnover of the plastics sector in the EU27 in 2021 was EUR 405 billion. Therefore, the additional
estimated costs of the preferred option would represent about 0.13% of the EU plastics sector
turnover and are considered to be limited. The costs are expected to be greater in the short term but
lower in the longer term once the appropriate systems and processes are in place and training
undertaken. There will be some cost savings as a result of reduced losses to the environment (as
pellets are a raw material). The proposal will encompass all actors in the pellet supply chain creating
a level playing field in the EU. Some sectors currently impacted by pellet losses will benefit from the
proposal e.g. agriculture, tourism.
The additional costs are likely to have a very minor negative impact on the international
competitiveness of the EU pellet producers, as their competitors outside the EU will not be subject
to the requirements (although logistical operators importing pellets will have to comply within the
EU). However, the EU companies will have a first mover advantage if/when other countries adopt
similar requirements, e.g. through an international agreement such as the Global Plastic Treaty.
The proposal will make a positive impact on the capacity to innovate as different actors of the value
chain will develop solutions to minimise pellet spills in order to optimise their costs for controlling
pellet losses.
A targeted SME consultation was undertaken to understand the potential impacts of different options
for SMEs including on their competitiveness. Feedback indicated that the direct economic impacts
of all the requirements would be too high to be sustainable for micro and small companies, as well
as companies with capacities below 1000t. As a result, the proposal includes lighter requirements for
SMEs to mitigate potential impacts by setting less obligations (e.g. no internal assessment) for micro-
and small companies and a longer implementation period for medium companies. There is a balance
to be sought between the magnitude of cost effects on SMEs, and reducing pellet losses. We believe
that the preferred option reaches the appropriate balance, but should the college want to go further,
additional lighter requirements (not foreseen in sub-option 2b) are assessed and outlined in Box 4
and Box 5. These might help reduce administrative costs for micro-, small and medium companies,
along with carriers transporting pellets, but will increase pellet losses.
123
Annex 6:
Legislation and actions relevant to reducing pellet losses to the EU
environment
1 EU POLICIES
1.1 The REACH restriction on intentionally added microplastics
A REACH restriction dossier has been in preparation since 2018 on intentionally added
microplastics, covering also some aspects related to pellets. The Commission published a proposal
for a restriction under Annex XVII of REACH. It was adopted on 25 September 202312
. The EU-
wide restriction covers intentionally added microplastics in multiple applications including
agriculture, horticulture, cosmetic products, paints, coatings, detergents, maintenance products,
medical and pharmaceutical applications, and rubber infill in artificial sport surfaces. It is estimated
that the proposed restriction could result in a reduction in microplastics emissions of about half a
million tonnes including infill material over 20 years, at an estimated total cost of up to 19 billion
euros.
Pellets are very partially covered by the REACH restriction on microplastics intentionally added to
products13
. The restriction does not prevent the placing on the market of pellets but does foresee
lighter measures for so-called ‘derogated’ uses, meaning uses of microplastics at industrial sites,
including plastic pellet sites, where releases can be prevented through risk management measures.
These lighter measures are namely an ‘instructions for use and disposal’ requirement along the supply
chain, and a ‘reporting’ requirement. The latter applies to pellets manufacturers and downstream
users14
and aims to gather information on three aspects:
a) the uses of such microplastics;
b) the generic identity of the polymers used; and
c) an estimate of the quantity of microplastics released to the environment on an annual basis, via a
prescribed electronic format.
12
Commission Regulation (EU) …/… amending Annex XVII to Regulation (EC) No 1907/2006 concerning the
Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) as regards synthetic polymer
microparticles.
13
European Chemicals Agency, Opinion of the Committee for Risk Assessment and Opinion of the Committee for
Socio-economic Analysis on an Annex XV dossier proposing restrictions on intentionally-added microplastics,
ECHA/RAC/RES-O-0000006790-71-01/F and ECHA/SEAC/RES-O-0000006901-74-01/F, 2020, p.49
(https://echa.europa.eu/documents/10162/a513b793-dd84-d83a-9c06-e7a11580f366).
14
In REACH, ‘downstream users’ are defined as “any natural or legal person established within the Community, other
than the manufacturer or the importer, who uses a substance, either on its own or in a mixture, in the course of his
industrial or professional activities. A distributor or a consumer is not a downstream user. A re-importer exempted
pursuant to Article 2(7)(c) shall be regarded as a downstream user”. Concretely, pellet converters, recyclers as well
as storing operators who own the pellets would be considered as downstream users under REACH. Transporters are
not all downstream users but emissions during transport would also need to be reported by the relevant downstream
user. Instead, would not be covered by the reporting obligation: distributors, storing operators who store the pellets
for third parties, retailers and consumers. A transitional period of 24 months is set for the entry into force of the
reporting requirement.
124
The reported information on all ‘derogated’ uses would help identify high releases and prioritise them
for further regulatory risk management. However, as they apply to all ‘derogated’ uses, these lighter
measures are generally defined and not specific to each single ‘derogated’ use. Also, they do not help
as such to effectively reduce pellet losses or prevent them (e.g. they are not a requirement on their
handling), and the reporting requirement is not based on a methodology to measure pellet losses (it
was left to the industry to develop a methodology).
Moreover, where ‘instructions for use and disposal’ and ‘reporting’ requirements are proposed, a
largely qualitative analysis of expected incremental costs to industry was presented based on the
arguments that the effort needed to fulfil these requirements is expected to be limited and that
sufficient time is given to the industry to established the efforts needed. In its conclusions, the
Committee for Socio-economic Analysis (SEAC) agrees that the costs incurred to provide
‘instructions for use and disposal’ is likely to be moderate as cost effective communication tools are
available, the extent of information required is limited and the transition period give actors sufficient
time to smoothly implement the requirements. Instead, for the reporting requirement, the total costs
of reporting could be substantial as the number of companies affected is likely to be large. SEAC
considers that there are different options to reduce such costs, e.g. by excluding certain actors (small
or micro-sized companies) from the requirement or by setting a threshold for microplastics volumes
used or released to be reported. However, SEAC cannot draw a firm conclusion on how these
different options would compromise the value of information obtained and hence the benefits of
reporting in terms of facilitating better risk management. Moreover, SEAC considers that for certain
actors in the supply chain, e.g. manufacturers of microplastics, a shorter transition period, i.e. 12
months, seems to be justified.
The Commission received the final ECHA opinion on the restriction proposal on 23 February 202115
.
Following discussions with Member States, the Commission published its restriction proposal on 30
August 2022, and it was voted in the REACH Committee on 26 April 2023. The proposal was adopted
on 25 September by the Commission.
1.2 The Marine Strategy Framework Directive (MSFD)
The Marine Strategy Framework Directive (MSFD) addresses the monitoring and assessment of the
impacts of microlitter, including microplastics, in coastal and marine environments in a way that they
can be linked to sources16
. Currently, an update of the first MSFD guidance on monitoring marine
litter guidance document is under development in view of harmonised methodologies, including to
the monitoring of the presence and distribution of plastic pellets along the coastline. However, this
work does not include specific requirements concerning the prevention or reduction of pellet losses
at the source.
15
European Chemicals Agency, Opinion of the Committee for Risk Assessment and Opinion of the Committee for
Socio-economic Analysis on an Annex XV dossier proposing restrictions on intentionally-added microplastics,
ECHA/RAC/RES-O-0000006790-71-01/F and ECHA/SEAC/RES-O-0000006901-74-01/F, 2020, p.49
(https://echa.europa.eu/documents/10162/a513b793-dd84-d83a-9c06-e7a11580f366).
16
“…micro-litter shall be monitored in the surface layer of the water column and in the seabed sediment and may
additionally be monitored on the coastline. Micro-litter shall be monitored in a manner that can be related to point-
sources for inputs (such as harbours, marinas, waste-water treatment plants, storm-water effluents), where feasible.”
125
1.3 The Urban Wastewater Treatment Directive and its revision
The Urban Wastewater Treatment Directive (UWWT Directive) aims to protect the water
environment from the adverse effects of discharges of urban wastewater and from certain industrial
discharges.
In October 2022, the Commission adopted a proposal for a revised UWWT Directive which contains
provisions on microplastics (including pellets). The revised Directive proposes to monitor
microplastics in UWWT plants (including in sludge). It also contains new requirements on storm
water and urban runoff management (see Article 5 and Annex 15), which will have an impact on
microplastics.
Microplastics found in domestic wastewaters originate from the washing of textile, tyre abrasion on
the roads, detergent capsules, and also from the bad handling of plastic pellets during transport when
spilled pellets can reach urban wastewater through urban runoff entering combined sewer systems.17
Heavy rains may lead to overflows which bypass the treatment facilities and result in releases of
pellets and other (micro)plastics to the environment. If properly implemented, the revised UWWTD
is expected to cut microplastics emissions by 9% from stormwater overflows by 2040. However, this
estimate excludes the amount of microplastics coming back to environment with the sewage sludge.
Most large pellet producers are connected to industrial wastewater treatment plants but some small
recyclers and processors are connected to UWWT plants18
. If a spill happens within these connected
facilities, they may enter the urban wastewater collecting system and reach Urban Wastewater
Treatment plants.
Microplastics, including pellets, would appear to be relatively well captured in urban wastewater
treatment plants,19
where it is retained in sludge. The UWWTD revision also includes additional
treatment requirements for larger facilities20
meaning more microplastics, including pellets, will be
captured in sludge in the future. The most common use of sludge is to spread it on agriculture so
about half of microplastics captured in urban wastewater treatment facilities will be released into the
environment. Sludge, however, also contains valuable nutrients which are beneficial for agriculture,
so the revised UWWTD will seek to avoid the pollution of sludge, notably by proposing to track and
trace industry wastewater that is not easily treatable in conventional treatment plants (Art. 14 and
Art. 20).
Although we do not have exact estimates, only a minor part of plastic pellets would seem to be
captured by the urban sewage system and only when connected to urban wastewater treatment. This
revision would therefore have a limited impact on the overall reduction pellet losses to the
environment.
17
Hann, S., Sherrington, C., Jamieson, O. et al., Investigating options for reducing releases in the aquatic environment
of microplastics emitted by (but not intentionally added in) products, Eunomia report for the Directorate-General for
Environment, 2018.
18
As informed by recyclers
19
According to the UWWTD impact assessment, 80.5% of microplastics are captured after primary treatment, 97.5%
after secondary treatment and 99.2% after tertiary treatment.
20
The revision of the UWWTD introduces mandatory tertiary treatments for all larger facilities treating a load equal to
or greater than 100 000 p.e. (population equivalent). All agglomerations with a p.e. of 1.000 or more (compared to
2.000 p.e. and more in the existing Directive), are obliged to proceed to two treatments.
126
1.4 The Sewage Sludge Directive
The Sewage Sludge Directive (SSD) covers the use of sewage sludge in agriculture, while preventing
harmful effects on soil, waters, vegetation, animals, and humans. The Directive prohibits the use of
untreated sludge on agricultural land unless it is injected or incorporated into the soil. It also requires
that sludge is used in such a way that plants’ nutrient requirements are satisfied and that the soil and
surface and groundwater quality is not impaired. Microplastics are not addressed in the current
Directive.
Recent research from the Norwegian Water Institute estimated that “between 110 000 and 730 000
tonnes of microplastics are transferred every year to agricultural soils in Europe and North
America”.21,22
The Sewage Sludge Directive is currently under evaluation. During this evaluation, the concept of
source control, i.e. targeting substances such as microplastics and micropollutants at source, was
widely supported by stakeholders to improve circularity in the wastewater treatment sector. Indeed,
if sludge and/or water is reused, stakeholders highlighted that pollution must be tracked and prevented
at source. It is not yet clear however which measures will be proposed in its future revision, and
whether these would target microplastic pollution.
Other water legislation
The recast of the Drinking Water Directive (DWD), the update of the Groundwater Directive (GWD)
and the Environmental Quality Standards Directive (EQSD) all include provisions related to
downstream microplastics monitoring. Methodologies to monitor microplastics under the DWD will
be further developed, to the extent possible, for use in groundwater, surface waters and coastal waters.
Once a harmonised monitoring methodology is in place, microplastics may be included in the surface
and groundwater watch lists and may be monitored. Subsequently, harmonised monitoring data on
microplastics will be collected during a period of at least 2 years resulting in quality standards for
microplastics in surface and groundwater. As for the drinking water, the Commission should adopt
(by delegated acts) a methodology to measure microplastics by 12 January 2024 with a view to
including them on the watch list. In addition, the Commission will submit, no later than 12 January
2029, a report on the potential threat to sources of water intended for human consumption from
microplastics, pharmaceuticals and, if necessary, other contaminants of emerging concern. The report
will also address the potential associated health risks.
1.5 The Industrial Emissions Directive
The Industrial Emissions Directive (IED)23
regulating prevention and control of pollution arising
from industrial activities in large industrial installations is only partially suited to address pellet losses
as a form of pollution occurring along the entire supply chain. While activities like the production of
polymeric materials on an industrial scale fall under the scope of the IED, other activities like the
conversion, storage or transport of pellets, usually operated by small and medium enterprises, are not
covered. Moreover, the BAT Reference Document (BREF) for the production of polymers was
adopted in 2007 and does not address the specific issue of pellet losses.
21
Hurley, R., & Nizzetto, L., ‘Fate and occurrence of micro(nano)plastics in soils: Knowledge gaps and possible risks’,
Current Opinion in Environmental Science & Health, Vol. 1, 2018, pp. 6-11, Elsevier BV.
22
Water Briefing. (2016, November 7). Sewage sludge: new research warns over microplastics in soil.
23
Directive 2010/75/EU on industrial emissions (integrated pollution prevention and control) (recast)
127
1.6 The Waste Framework Directive
The Waste Framework Directive (WFD)24
lays down basic waste management principles and
imposes general obligations to Member States to take measures to prevent waste generation. As for
industrial production and manufacturing those measures shall, at least, contribute to reducing waste
generation, considering the best available techniques adopted under the IED. Pellets may become
waste as a substance or object which the holder discards intentionally or unintentionally.
Member States shall establish waste prevention programmes setting out waste prevention measures.
Examples of possible measures to be adopted by Member States addressing industrial production and
distribution are listed in the Directive and include the provision of information on waste prevention
techniques intending to facilitate the implementation of best available techniques by industry, the
organisation of training of competent authorities as regards the insertion of waste prevention
requirements in permits under the WFD and the IED, the inclusion of measures to prevent waste
production at installations not falling under the IED, awareness campaigns or the provision of
financial, decision making or other support to businesses, especially small and medium-sized
enterprises, the use of voluntary agreements, or sectoral negotiations in order that the relevant
businesses or industrial sectors set their waste prevention plans and the promotion of creditable
environmental management systems.
According to Article 29 (5) of the WFD, the Commission shall adopt guidelines to assist Member
States in preparing their programmes and preventive measures.
The generic provisions mentioned above have not resulted in any significant reduction of pellet losses
and there is however no specific action or measure included in the WFD focussing on pellets.
2 ACTIONS IN MEMBER STATES
Several EU27 member states have been conducting research on microplastic (including pellets)
emissions and some of them have even implemented measures to tackle pellet loss as presented in
Table 42.
For example, France and Austria have taken legislative measures to curb this pollution.
The French legislation25
covers businesses making and handling pellets in quantities higher than 5
tonnes including logistic platforms but not transporters. The threshold has been reduced from what
initially proposed i.e. 10 tonnes following public consultation. Businesses are subject to equipment
and procedural obligations to prevent the loss and leakage of pellets, and are required to be regularly
audited by independent and accredited certification bodies26
. Obligations remain of a relatively
generic nature. For instance, a business must identify areas where pellets are more likely to spill,
check that the packaging used is designed to minimise the risk of spills and train and raise awareness
24
Directive 2008/98/EC of the European Parliament and of the Council of 19 November 2008 on waste and repealing
certain Directives (https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02008L0098-20180705).
25
Décret no 2021-461 du 16 avril 2021 relatif à la prévention des pertes de granulés de plastiques industriels dans
l’environnement [Decree n. 2021-461 of 16 April 2021 related to the prevention of the leakage of industrial plastic
pellets into the environment], Journal official “Lois et Décrets” no. 0092 du 18 avril 2021 [JORF] [Official journal
“Laws and Decrees” no. 0092 of 18 April 2021], 18 April 2021, Fr.
26
Décret no 2021-461 du 16 avril 2021 relatif à la prévention des pertes de granulés de plastiques industriels dans
l’environnement [Decree n. 2021-461 of 16 April 2021 related to the prevention of the leakage of industrial plastic
pellets into the environment], Journal official “Lois et Décrets” no. 0092 du 18 avril 2021 [JORF] [Official journal
“Laws and Decrees” no. 0092 of 18 April 2021], 18 April 2021, Fr.
128
among staff. As a unique transparency measure, the company must make the summary of the auditing
report available on its website. The Decree entered into force on January 1, 2022 for new sites, while
for existing sites, it will enter into force in 2023, at the same time as equipment obligations.
The Austrian government has set a threshold for the emissions of filterable substances (pellets are
considered filterable substances) to the environment. 27
However, the emission level (30mg/L)
allowed is significant since companies can release up to 94.5 tonnes of pellets annually into the
environment.28
This legislation does not address pellets directly but rather “filterable substances”, to
which pellets belong. In light of the high volume of pellets losses allowed, it seems that the current
Austrian legislation on wastewater emissions is not sufficient to reduce pellet loss.
In 2021, in response to a clear call for sufficiently reliable and comparable data on pellets at the
European level from OSPAR and the European Task Group for Marine Litter, the Netherlands carried
out a pilot monitoring project29
showing that significant amounts of pellets and mesoplastics are
present on Dutch beaches30
. In view of these encouraging first results, they will continue the
monitoring in coming years. Apart from this monitoring activity, there is no Dutch scheme or process
to tackle pellet losses. Denmark launched a monitoring program, as a part of the Danish Marine
Strategy (2018-2024), including monitoring of marine litter, analyses of microplastic in sediments,
as well as analyses of macro and microplastics in the stomachs of two fish species31
.
In 2022, the Flemish Authorities consulted with stakeholders on techniques and measures to prevent
and reduce plastic losses and which Best Available Techniques (BAT) to select. On the basis of this
consultation, they hope to produce recommendations for Flemish environmental legislation (general
binding rules and specific environmental permit conditions). In a recent meeting with the
Commission, an OVAM representative reported that “there are pellet losses around the Port of
Antwerp”. In recognition of this, the Port of Antwerp has been running the Antwerp Zero Pellet Loss
Platform since 2017, to optimize the implementation of the European plastic industry voluntary
programme called ‘OCS’ (see under industry initiatives), in the port of Antwerp.
Spain’s actions are limited to promoting the implementation of the recently launched European
plastic industry’s voluntary certification scheme called ‘OCS certification scheme’ (see under
industry initiatives). Other countries are similarly relying on the industry efforts in this field.
In Sweden, the 2020 guidelines on measures to minimise microplastic emissions from manufacturing
and management of plastics are still used.32
In order to promote upcoming standards and certification
schemes to reduce the loss of plastic pellets throughout the entire plastic supply chain, there are plans
27
Lechner, A. and Ramler, D., ‘The Discharge Of Certain Amounts Of Industrial Microplastic From A Production Plant
Into The River Danube Is Permitted By The Austrian Legislation’, Environmental Pollution, Vol. 200, 2015, pp. 159-
160. Elsevier BV.
28
Lechner, Aaron, and David Ramler. "The Discharge Of Certain Amounts Of Industrial Microplastic From A
Production Plant Into The River Danube Is Permitted By The Austrian Legislation". Environmental Pollution, vol
200, 2015, pp. 159-160. Elsevier BV, doi:10.1016/j.envpol.2015.02.019. Accessed 28 Mar 2022.
29
Dutch Government, Policy Programme on (micro) plastics – European Marine Strategy Framework Directive, 2020
(https://g20mpl.org/partners/netherlands).
30
Dutch Ministry of Infrastructure and Water Management, ‘Monitoring of pellets and mesoplastic fragments on Dutch
beaches in 2021: a pilot study‘, 2022 (https://puc.overheid.nl/rijkswaterstaat/doc/PUC_721767_31/1/)
31
Ministry of Environment and Food of Denmark; Microplastics: Occurrence, effects and sources of releases to the
environment in Denmark, Environmental project No. 1793, 2015
32
Swedish Government, ‘Microplastics’, 2022 (https://www.naturvardsverket.se/amnesomraden/plast/om-
plast/mikroplast/).
129
to revise the Swedish guidelines to make them more comprehensive and include more actors along
the plastic pellet value chain.
Table 42: Selected actions in Member States
Countries Measure
Austria Threshold for the emissions of filterable substances (including pellets)
Belgium
(Flanders)
Environmental permit system to be put in place/ Best Available Techniques
Examining the option of an environmental management system with possible
certification
Denmark Monitoring
Waiting for OCS certification scheme implementation and Commission’s proposal
France Law adopted providing minimum obligations to prevent pellet losses for all actors in
the supply chain along with mandatory external auditing
Netherlands Research program on mitigation measures to avoid microplastic emissions, including
from pellets, and monitoring
Waiting for OCS certification scheme implementation
Spain Promoting OCS certification scheme implementation
Sweden Revision of current guidelines to make them more comprehensive and include more
actors across the supply chain.
3 INTERNATIONAL ACTIONS ON PELLETS
Some countries, outside of the EU, have also started taking actions against pellet losses, as captured
in Table 43.
In 2021, the British Standards Institution published the Publicly Available Specification (PAS) PAS
510:202133
. This PAS is for use by any organisation of any size in any part of the supply chain that
handles pellets, including raw material manufacturers, distributors, storage facilities, recyclers,
transporters, and plastics processors. It builds on the groundwork laid by the industry-led Operation
Clean Sweep® (OCS) programme (see under industry initiatives) by creating a standardised and
consistent approach to risk management and the containment of pellets in order to prevent losses to
the environment throughout the plastic supply chain34
. The PAS may be considered for further
development as a British standard or constitute part of the UK input into the development of a
European or International standard on pellets.
33
Plastic pellets, flakes and powders. Handling and management throughout the supply chain to prevent their leakage
to the environment. Specification - PAS 510:2021101
34
The PAS provides requirements in the following areas: a) Organizational responsibilities; b) Leadership and
commitment; c) Competence, training and awareness; d) Risk assessment of pellet loss to the environment; e)
Operational controls, i.e. prevention, containment and clean-up, procurement and suppliers; f) Internal and external
communication; g) Performance evaluation, i.e. monitoring and documentation, auditing and verification of
conformity; h) Improvement, i.e. internal and external non-conformity and corrective action, and continual
improvement.
130
The USA has enforced the “Break Free from Plastic Pollution Act of 2021”,35
prohibiting the
emissions of pellets to wastewater, spills and runoff from plastics production facilities. Three years
from when the senate passed the Bill (on 26 March 2021), Best Available Technology Economically
Achievable (BAT) and New Source Performance Standards (NSPS) regarding pollution prevention
will have to be available. Under the current regime, pellet manufacturers must obtain a National
Pollutant Discharge Elimination System (NPDES) permit to produce pellets. The permit comes with
a set of Best Management Practices (BMPs) that aim to prevent pellet losses to the environment.36
Prior to this national Bill, the Assembly Bill (AB) 258, which became effective in 2008, added
Chapter 5.2 to Division 7 of the California Water Code, section 13367, entitled “Preproduction Plastic
Debris Program.”37
It enables the Regional and State Water Board to perform compliance inspections
on pellets production, transportation and handling, enforcing action, in particular, to improve storm
water discharges. They also facilitate multi-stakeholders actions, such as meetings between pellets
producers and environmental action groups.
Table 43: Selected international actions
Countries Measure
UK New PAS 510:2021 technical specifications provides requirements for the handling and
managing of plastic pellets, flakes and powders throughout the supply chain to prevent spills,
leaks and losses to the environment.
USA The “Break Free from Plastic Pollution Act of 2021”,38
prohibiting the emissions of pellets
to wastewater, spills and runoff from plastics production facilities.
Any plastic sector company needs to get a National Pollutant Discharge Elimination System
(NPDES) permit to produce pellets. The permit comes with a set of Best Management
Practices (BMPs) that aim to prevent pellet losses to the environment.39
USA
(California)
The California Water Code, section 13367, entitled “Preproduction Plastic Debris
Program.”40
enables the Regional and State Water Board to perform compliance inspections
on pellets production sites, transportation vehicles and during handling operations.
4 MULTILATERAL ACTIONS
Multilateral action targeting pellets is so far limited to the OSPAR Convention for the Protection
of the Marine Environment of the North-East Atlantic. This Convention is an international legal
instrument bringing together 16 signatories to coordinate the protection of the North-East Atlantic
35
US Congress, Break Free from Plastic Pollution Act of 2021, H.R. 2238, 2021 (https://www.congress.gov/bill/117th-
congress/house-bill/2238/text).
36
US Environmental Protection Agency, ‘Industrial Stormwater fact sheet: Sector Y: Rubber, Miscellaneous Plastic
Products, and Miscellaneous Manufacturing Industries’, 2006
(https://www3.epa.gov/npdes/pubs/sector_y_rubberplastic.pdf).
37
California Environmental Protection Agency, ‘Preproduction Plastic Debris Program’, 2008
(https://www.waterboards.ca.gov/water_issues/programs/stormwater/plasticdebris.shtml).
38
US Congress, Break Free from Plastic Pollution Act of 2021, H.R. 2238, 2021 (https://www.congress.gov/bill/117th-
congress/house-bill/2238/text).
39
US Environmental Protection Agency, ‘Industrial Stormwater fact sheet: Sector Y: Rubber, Miscellaneous Plastic
Products, and Miscellaneous Manufacturing Industries’, 2006
(https://www3.epa.gov/npdes/pubs/sector_y_rubberplastic.pdf).
40
California Environmental Protection Agency, ‘Preproduction Plastic Debris Program’, 2008
(https://www.waterboards.ca.gov/water_issues/programs/stormwater/plasticdebris.shtml).
131
marine environment. In 2021, signatories adopted the non-binding Recommendation 2021/0641
to
reduce the loss of plastic pellets in the marine environment. The recommendation invites contracting
parties to promote pellet loss prevention standards and certification schemes according to a specific
hierarchy of measures i.e. prevention, mitigation, cleaning and reporting. It provides minimum
requirements for certification schemes to de developed. Detailed guidelines were also approved. This
impact assessment builds on this non-binding recommendation, as explained in the relevant parts.
In particular, the Recommendation contains the following guidance:
Pellet handling standards:
o Documentation of an Organisation’s Responsibilities identifying which are the
operations during which spills can and cannot occur;
o Management should demonstrate leadership to prevent pellet losses;
o Training and awareness-raising of employees;
o Risk assessment of pellet losses to be done by all members of the supply chain;
o Operational controls are to be established by the business to prevent spills (by
avoiding unnecessary handling and having best handling practices in place), mitigate
and contain spills whenever they occur, and clean up spills after they have occurred;
o Businesses should implement procurement policies relating to pellet handling;
o Implemented measures should be communicated by businesses;
o Businesses’ performances regarding pellet loss prevention measures should be
evaluated regularly; and
o Businesses should improve their practices whenever they are non-conform.
A pellet certification scheme:
o It should be international to ensure a level playing field for all businesses;
o A database should be created to form a public Register storing all data related to the
scheme;
o The management and governance of the scheme should be developed and managed
by an independent organisation;
o To be certified, any site must have been audited first and passed an appropriate
standard;
o Joining the scheme should be simple;
o The auditing should be regular and performed by an independent accredited auditor;
o The certification body should be independent and well trained in the standard they are
auditing; and
o The scheme should acknowledge that a company has been accepted or that an update
has occurred.
The first full implementation report is due in January 2025. However, an interim report on the
progress made will be published in 2024. OSPAR shared a preliminary interim report in February
41
www.ospar.org/convention/strategy
132
2023 and the actions reported by the Member States that are parties to the OSPAR Convention are
presented in Table 42.
In March 2022, the second session of the 5th
United National Environment Assembly unanimously
adopted resolution 14: End Plastic Pollution: towards an international legally binding instrument42
(hereafter referred to as the resolution). The preamble to the resolution highlights that “plastic
pollution includes microplastics”. This inclusion indicates that that intergovernmental negotiating
committee (INC) will have to consider how to address microplastics in a forthcoming global
agreement.
In May 2019, the Conference of the Parties to the Basel Convention adopted a decision by which it
amended Annexes II, VIII and IX of the Convention in relation to plastic waste. A Plastic Waste
Partnership was created with the aim, among other things, to significantly reduce and eliminate waste
discharge of plastics and microplastics in the environment.
The OECD Council Recommendation on Water calls for Adherents to prevent, reduce and manage
water pollution from all sources, while paying attention to pollutants of emerging concern, such as
microplastics.
In the International Maritime Organization (IMO), a Correspondence Group on Marine Plastic
Litter from Ships looked at measures that could be relevant in reducing the environmental risks
associated with the maritime transport of plastic pellets. While three primary measures including
packaging were identified as particularly relevant (and a voluntary circular to this effect was drafted
as a guidance document), the Group was not in a position to conclude on the most appropriate
instrument for mandatory measures43
. The Group noted that experience gained from the
implementation of the voluntary measures could be useful in the further consideration of the most
appropriate instrument for mandatory measures.
A similar international initiative is ongoing on containers lost at sea, and discussions are held on the
possibility of making the information on containers lost at sea available publicly (to date, sufficient
information is reported only to insurance companies). If retained, this measure would allow for a
better understanding of the scale and magnitude of pellets lost at sea and would facilitate liability
identification and compensation arrangements in line with the polluter pays principle.
5 VOLUNTARY ACTIONS ON PELLETS
5.1 Industry actions
The problem of pellet losses has been known about since the 1980s with the US Environmental
Protection Agency (EPA) and the Center for Marine Conservation (now known as the Ocean
42
United Nations Environment Assembly, Resolution – End plastic pollution: towards an international legally binding
instrument, UNEP/EA.5/Res.14, 02.03.2022.
43
The three primary measures identified as relevant are: Packaging provisions for plastic pellets carried at sea;
Provisions for notifying the carrier so that containers containing plastic pellets can be identified; Stowage provisions
for freight containers containing plastic pellets. Among the options for mandatory measures, the Group considered
the three following options/instruments: Assignment of an individual UN Number (class 9) for plastic pellets
transported at sea in freight containers (UN Number); Amendment to Appendix I of MARPOL Annex III that would
recognize plastic pellets as a “harmful substance” (Harmful substance); A new chapter to MARPOL Annex III that
would prescribe requirements for the transport of plastic pellets in freight containers without classifying the cargo as
a harmful substance/dangerous goods.
133
Conservancy) “detecting plastic pellets in US waterways from the Atlantic to the Pacific”44
. In 1986,
SPI (the US Plastics Industry Trade Association, now known as the Plastics Industry Association)
established the Resin Pellet Task Force to “educate the plastics industry [….] about the negative
consequences of plastic pellets in the marine environment”. In 1991 the industry-led Operation Clean
Sweep (OCS) initiative was created by SPI, with companies voluntarily signing a pledge to work
towards zero plastic pellet losses.
Since 2015, the European plastics manufacturing industry has also progressively adopted the
international Operation Clean Sweep® (OCS) programme as a voluntary free pledge.45
Under this
programme, each company making or handling pellets recognises the importance of making zero
pellet losses and 1) improves worksite set-up to prevent and address spills; 2) creates and publish
internal procedures to achieve zero pellet loss; 3) provides employee training and accountability for
spill prevention, containment, clean-up and disposal; 4) audits performance regularly; 5) complies
with all applicable local and national regulations governing industrial pellet containment; 6)
encourages partners to pursue the same objectives. Recommendations on how to deliver on each of
these six actions are given in the form of a manual. The Operation Clean Sweep® (OCS) manual
contains in particular the following guidelines to help plastics industry operations managers reduce
the loss of pellets to the environment:
Under ‘Work site set-up’:
• Pave loading/unloading areas where unavoidable spills occur to facilitate clean-up
• For clean-up in gravel yards, consider fitting vacuums with screen or mesh on intake hoses to
collect pellets without disturbing gravel
• Provide catch trays for use at all car/truck unloading valves
• Use bulk-handling equipment that is designed to minimise pellet leakage
• Install central vacuum systems where practical
• Install connecting hoses equipped with valves that will close automatically when the
connection is broken
• Properly empty and seal bulk containers (rail or truck) after unloading
• Assure proper handling when storing and removing waste pellets
• Seal expansion joints in concrete floors with flexible material to avoid pellet accumulation in
hard to clean spaces
• Conduct routine inspections and maintenance of equipment used to capture and contain
pellets
• Install zero loss containment systems wherever necessary to prevent pellets from escaping
plant boundaries
• Place screening in all storm drains
• Install baffles, skirts and booms in containment ditches or ponds
• Finally, ensure that employees have ready access to: Brooms, dustpans, rakes, etc., Heavy-
duty shop vacuums for inside use, Portable shop vacuums for outside use, Catch trays or
traps, Wide-mouth sample collection jars or poly-bags, Tape for repairing bag or box damage,
Scrap pellet containers, Procedures you expect them to undertake and checklists to assist in
follow-through, Forklift clean-up kit.
44
Document Display | NEPIS | US EPA; Plastics Industry Association (2016) Operation Clean Sweep Celebrates 25
Years, available at https://www.plasticsindustry.org/article/operation-clean-sweep-celebrates-25-years
45
https://www.opcleansweep.eu/
134
Then, under ‘Prevention, Containment & Clean-up Procedures’, best practices are provided for each
handling step, namely: Cleaning Empty Tank Railcars and Trucks; Top Loading; Sealing Loading
Railcars/Trucks; Storing at Intermediate Sites; Valve Opening; Completing Unloading; Sampling;
Sealing Valves; Sampling from unloading tubes; Sampling from top hatches; Selecting Packaging
Materials; Bags: Filling and Handling; Bags: Emptying and Disposal; Octabins.
According to the industry, preventive measures taken separately have estimated pellet loss prevention
efficiency ranging from 59% to 97%46
, while mitigation measures taken separately have estimated
pellet loss prevention efficiency ranging from 81% to 95%. These measures must not be used alone
but in unison to achieve a satisfactory reduction of losses to the environment.
While best practices measures are generally well understood, they have not been comprehensively
implemented. As of April 2023, 2548 companies have committed to OCS47
. This figure includes all
PlasticsEurope’s members (adherence to OCS is mandatory for the members of this association) but
only a very small number of converters and transporters. Regarding converters, only 2% of all EuPC’s
members have committed to OCS (1,000 converters out of a total of close to 50,000). Regarding
transporters, some 500 transport companies are OCS signatories. As no precise reporting has been
made available within OCS, it is not possible to say whether those who have committed have also
effectively or fully implemented the programme, with some evidence showing the opposite. Both
acute and chronic pellet incidents have been reported to continue over the last years, including at sites
that are OCS signatories48
.
Recognising the low take-up of OCS by the industry and the increasing rate of pellet losses, European
plastic manufacturers (PlasticsEurope) and converters (EuPC) announced plans in 2019 to go beyond
the OCS programme and develop a voluntary certification scheme building on OCS, including
requirements, third-party, independent auditing, certification and some level of transparency (all
aspects not foreseen under the current OCS programme). In January 2023, the new scheme was
officially launched by its promoters based on the preparatory work carried out by a Supervisory Board
gathering producers, converters, representatives of some Member States (Scotland, Germany and
Spain), one NGO (Fauna & Flora International), some certification bodies (Aenor and Tuv-Nord) as
well as one European Institution (the European Parliament). Representatives of the European
Commission, the European Chemical Transport Association (ECTA) and Cefic took part in the
discussions as observers.
According to the scheme owners, OCS CS is aimed at “controlling and documenting compliance of
companies throughout the entire supply chain with requirements aiming for a minimisation of pellet
losses across the entire plastic supply chain. It will also support the effective, harmonized and
quantifiable implementation of the OCS programme”. Companies will be invited to comply with
requirements from the following categories:
• Commit to making zero loss of pellets, flakes, and powder a priority;
• Improve worksite set to prevent and address spills, meaning site risk assessments;
46
Confidential data provided by EUPC from their documents used to setup the OCS certification scheme.le
47
Idem
48
Regarding chronic pellet losses in the Netherlands, Belgium and Spain, see
https://www.plasticsoupfoundation.org/wp-content/uploads/2022/03/Westerschelde-plastic-nurdles-versie-
definitief-21-11-2021-2.pdf; https://surfrider.eu/en/learn/news/ecaussinnes-belgium-surfrider-foundation-tackles-
industrial-plastic-granules-1211028228325.html; https://goodkarmaprojects.org/2020/11/20/new-report-out-
exposes-alarming-impacts-of-plastic-pellets-across-europe/?lang=en.
135
• Create and publish internal procedures to achieve zero pellet loss goals meaning documented
procedures, including, for instance, description of roles and responsibilities, but also
recording, investigation and follow-up of incidents and effectiveness of procedures,
equipment and instructions in place;
• Provide employee training, including theory and practical hands-on exercises and
accountability for spill prevention, containment, clean-up and disposal;
• Audit performance regularly, meaning internal audits;
• Comply with all applicable local and national regulations governing pellet containment; and
• Encourage partners to pursue the same objectives to be monitored, for instance, via the % of
contracts containing an OCS clause.
Compliance will be verified at site level by third-party, independent auditors. Once successfully
audited, companies will be certified compliant and will have the name of the company and the site
location listed in a public register. The certification will be valid for 3 years after the date of the first
audit, subject to an annual control audit. First audits were foreseen as of April 2023.
5.2 NGO activities
Several environmental non-governmental organisations (NGOs), such as Fidra, Fauna and Flora
International (FFI), SOS Mal de Seine, are also working to reduce pellet losses. These organisations
have implemented monitoring programs and engaged with authorities and the industry to promote
good practices when handling pellets. Fidra has been working with the plastics industry since 2012
to raise awareness and collaborates with trade associations, decision-makers and regulators to
identify solutions that will build upon Operation Clean Sweep® (OCS). FFI has engaged with the
plastics industry and with regulators in the UK and across Europe to promote wider uptake and
implementation of OCS since 2012 and has encouraged the introduction of annual compliance audits
and open reporting that feed into yearly OCS membership renewal (rather than automatic
membership for life) to enable all stakeholders to see which companies have fully implemented best
management practices for preventing pellet loss at their sites. SOS Mal de Seine is in contact with
the French Ministry of Environment and participates in raising awareness around plastic pellet losses.
Several other NGOs are also actively involved in promoting awareness and regulatory action at the
European level. Since 2018, NGO As You Sow has challenged seven of the largest pellets
manufacturers to report any pellet spills happening in their facilities49
. The companies agreed to do
so; however, public reporting has not been done yet50
.
49
As You Sow, ‘Plastic Pellet Pollution’, 2021 (https://www.asyousow.org/our-work/waste/plastic-pellets).
50
Evidence gathered by the NGOs include:
Dutch Ministry of Infrastructure and Water Management, ‘Monitoring of pellets and mesoplastic fragments on Dutch
beaches in 2021: a pilot study‘, 2022 (https://puc.overheid.nl/rijkswaterstaat/doc/PUC_721767_31/1/);
Rethink Plastic Alliance, Surfrider Foundation Europe, & Break Free from Plastic, ‘Plastic Giants polluting through
the backdoor’, 2020 (https://rethinkplasticalliance.eu/wp-
content/uploads/2020/12/bffp_rpa_pellets_polluting_through_the_backdoor.pdf);
Greenpeace, ‘Inquinamento Silenzioso – Chi contamina le coste pugliesi con i granuli di plastica?’ [Silent Pollution
– Who is contaminating Puglia’s coastline with plastic pellets?], 2022 (https://www.greenpeace.org/static/planet4-
italy-stateless/2022/07/904ad868-inquinamento-silenzioso.pdf), It;
KIMO, ‘Plastic pellets spill pollutes Danish, Norwegian, Swedish coastlines’, 2020
(https://www.kimointernational.org/news/plastic-pellets-spill-pollutes-danish-norwegian-swedish-coastlines/);
Legambiente & Italian National Agency for New Technologies, Energy and Sustainable Economic Development,
‘First preliminary study on microplastic within Italian lakes‘, 2016
(https://www.legambiente.it/sites/default/files/docs/microplastic_in_italian_lakes_legambiente_2016.pdf);
136
Table 44: Selected Voluntary initiatives (Industry and NGO)
Name Details
Surfrider Field actions on the presence of pellets on beaches, called “pellet hunt”
Rethink plastic
alliance
Microplastics
Seas at Risk Microplastics
Operation
Clean Sweep
(OCS)
Awareness raising, promoting best practices and providing guidance and tools to
implement pellet loss prevention measures. https://www.opcleansweep.eu/. Since 2023,
mandatory certification for members of EU trade association Plastics Europe.
SQAS Alternative system to the OCS for transporters, the section on pellets is still under
development (www.sqas.org)
RecyClass Certification for recyclers, the section on pellets is still under development
(www.recyclass.eu).
Italian National Agency for New Technologies, Energy and Sustainable Economic Development, ‘Environment:
ENEA in the field for the microplastics emergency in Italian lakes‘, 2022 (https://www.enea.it/en/news-
enea/news/environment-enea-in-the-field-for-the-microplastics-emergency-in-italian-lakes);
SOS Mal de Seine, ’Granulés plastiques industriels sur le littoral français’, 2011
(http://maldeseine.free.fr/documents%20granules/RAPPORT_version_WEB.htm);
Mani, T., et al., ‘Repeated detection of polystyrene microbeads in the Lower Rhine River’, Environmental Pollution,
Vol. 245, 2019, pp. 634-641, Elsevier BV.
137
Annex 7:
Microplastics and pellets in the environment
The following section captures the current state of play of research regarding microplastics. It looks
at the definition of microplastics, the impacts on health, the environment and climate, and the
difficulties related to its monitoring. Most of these impacts are related to microplastics in general,
and the impacts of pellets losses to the environment are largely similar. We would generally expect
that the adverse impacts of pellets will be proportional to their part in the total microplastic emissions.
1 WHAT ARE MICROPLASTICS?
Plastics are materials prepared from (semi-)synthetic polymers such as polyethylene,
polyvinylchloride (PVC), polyethylene terephthalate (PET), nylon, rayon and cellulose nitrate that
are generally treated with chemical additives to transform them into plastic products.
Microplastics are plastic particles measuring less than 5 mm and include sub-micrometre particles
called ‘nanoplastics’.
While there is no legally binding definition of microplastics, there is a common understanding on
their general characteristics:51
• synthetic materials with a high polymer content,
• solid particles,
• smaller than 5 mm, and
• not degradable.
The REACH restriction52
for intentionally added microplastics, defines microplastics as “particles
containing solid polymer, to which additives or other substances may have been added, and where ≥
1% w/w of particles have (i) all dimensions 0.1µm ≤ x ≤ 5mm, or (ii) a length of 0.3µm ≤ x ≤ 15mm
and length to diameter ratio of >3. ” This definition excludes polymers with a solubility > 2 g/L. The
size definition of microplastics was discussed at the first international research workshop on the
occurrence, effects and fate of microplastic marine debris in 2008, hosted by NOAA.53 The
participants adopted a pragmatic definition, suggesting an upper size limit of 5 mm. This was based
on the premise that it would include a wide range of tiny particles that could readily be ingested by
biota and such particles that might be expected to present a different kind of threat than larger plastic
items such as entanglement. The minimum size of microplastics is most often defined as 1 μm as this
can be verified by Raman microscopy, but due to methodological constraints of sampling or analysis
limitations, different operational lower size limits, e.g., 10, 100, or 300 μm, are often used.
In Europe, approximately 80 % of all plastic raw materials produced are in the form of round to oval
granules of approximately 2 mm to 5 mm in diameter.54
A relevant part of the remaining 20% is even
51
Leslie, H.A., ‘Review of microplastics in cosmetics: Scientific background on a potential source of plastic particulate
marine litter to support decision-making’, V.U. Institute for Environmental Studies, 2014.
52
EUR-Lex - 32023R2055 - EN - EUR-Lex (europa.eu)
53
Arthur, C., Baker, J. and Bamford, H. (eds), ‘Proceedings of the International Research Workshop on the Occurrence,
Effects, and Fate of Microplastics Marine Debris’, NOAA Marine Debris Program, 2008
(https://marinedebris.noaa.gov/proceedings-international-research-workshop-microplastic-marine-debris).
54
PlasticsEurope, ‘PlasticsEurope Operation Clean Sweep® Report 2017’, 2017
(https://www.opcleansweep.eu/application/files/8316/3456/6233/PlasticsEurope_OCS_progress_report-2017.pdf).
138
smaller than 2mm, such as powders, and a minor part can be slightly taller. It is common sense to
tackle all these pellets together. This will equally avoid any action of the industry to make pellets
slightly taller than 5mm in order to escape possible legislation. Figures from literature often refer to
“pellets”, irrespective of their dimension and shape.
1.1 Methodological challenges: lack of standardisation and reliable data
Although the number of publications on microplastics has increased rapidly in recent years, a
standardised procedure for identifying/quantifying microplastics is still lacking, even though a first
standard describing “Principles for the analysis of microplastics present in the environment” (ISO
24187:2023)55
was recently released. Investigations are generally conducted using different methods,
differing particle size ranges and expressed in different units that cannot be easily converted, making
it challenging to compare results across studies resulting in largely incomparable data between
studies. In a 2019 article, 40 bulk sampling and analysis methods for microplastics were studied and
compared. It presents the general process for microplastic sampling and analysis in four steps:
collection, density separation, digestion, and identification. It observed that each research team used
one out of 2 to 5 different procedures depending on the article and the step (two for collection and up
to five for identification). Hence, the reported abundance of microplastics and respective sources in
the environment have high variability and may differ by several orders of magnitude, making
harmonising sampling and analysis methods one of the biggest challenges when assessing the
evolution of unintended release of microplastics.
As it is a transboundary issue, a bottom-up solution is not possible. A top-down approach assessment
will involve a large number of assumptions, which could further add to the uncertainty. An approach
could be to use case studies to illustrate specific scenarios of the evolution of (unintentionally
released) microplastic load.
In the study, “Rethinking Microplastics as a Diverse Contaminant Suite”56
, the authors strongly
advocate changing the thinking from one contaminant, “microplastic”, to a diverse suite of
contaminants, microplastics, as has been done for pesticides and flame retardants in the past.
1.2 Monitoring
Microplastics’ main pathways into the environment are runoff waters, treated or untreated
wastewater, direct input to water compartments (rivers, lakes, ocean), soil and the air. Their adverse
impacts also depends on the microplastic particles’ shape, size, on the polymer type and on the
additives they contain, therefore gathering information on these microplastics’ characteristics with
regards to their appearance is crucial to better understand the production, occurrence, distribution and
degradation of microplastics. One of the main problems encountered in tackling microplastics is the
insufficient data available on their release and presence in the environment. This information and
knowledge failure is due to the lack of standardised protocols and common data bases. To observe
and analyse microplastics particles in the environment, harmonised measurement protocols must be
established and followed. The MSFD Technical Group on Marine Litter is currently updating the
MSFD Guidance on Monitoring Marine Litter to improve harmonised monitoring of marine litter
55
ISO 24187:2023
56
Rochman, C.M., Brookson, C., Bikker, J., Djuric, N., Earn, A., Bucci, K., Athey, S., Huntington, A., McIlwraith, H.,
Munno, K., De Frond, H., Kolomijeca, A., Erdle, L., Grbic, J., Bayoumi, M., Borrelle, S.B., Wu, T., Santoro, S.,
Werbowski, L.M., Zhu, X., Giles, R.K., Hamilton, B.M., Thaysen, C., Kaura, A., Klasios, N., Ead, L., Kim, J.,
Sherlock, C., Ho, A. and Hung, C. (2019), Rethinking microplastics as a diverse contaminant suite. Environ Toxicol
Chem, 38: 703-711. https://doi.org/10.1002/etc.4371
139
(including microplastics) and to ensure consistency and comparability of monitoring data for the
MSFD. These protocols have to be laid down after considering the steps and aspects detailed below.
1.2.1 Sampling
The sampling of microplastics can take place through direct sampling from water using sieving or
through the collection of sediments. The distribution of microplastics is largely influenced by
geographical, meteorological, and temporal factors thus the sampling time, sampling place, the
sample volume, replications and field blanks are crucial for a uniform classification. The lower the
available sample volume is, the more important replication become to minimise sampling error.
Regarding the sampling method, it is important to specify where the samples were taken.57
1.2.2 Extraction
Various extraction procedures are available based on density separation, filtration, digestion, etc.
Recovery and precision can vary depending on the properties and amount of microplastics present,
the sample matrix and the protocol used. The utilisation of blanks is important to detect and control
contamination by particles during sampling and the analytical procedure.
1.2.3 Analysis
The most common types of analysis are microscopic techniques using Raman or FTIR spectoscropy
and thermo-analytical techniques based on gas chromatography/mass spectroscopy of decomposition
(pyrolysis) products. Prior to measurement, sample preparation is required depending on the sample
and the measurement technique. The limit of an instrument’s detection capacities must also be taken
into account. Polymer libraries provide a means of identifying the polymers present in samples.
2 WHAT ARE THE IMPACTS OF MICROPLASTICS AND PELLETS?
Four types of adverse impacts can be observed from microplastics, such as pellets, finding their
way into the environment: 1) on the environment; 2) on climate; 3) on human health; and 4) on
the economy.
Some of these impacts are related to microplastics in general, including pellets, while others are
specific to pellets. It is to be noted that pellets can also be in the form of powder, thus very small and
thus airborne, as well as slightly bigger than 5 mm in diameter.
2.1 Impacts on the environment
The significant adverse impacts of microplastics on the environment were highlighted in a recent
publication58
that revealed that the 5th
planetary boundary of novel entities had been exceeded.
Chemicals at large, including plastics, have been identified as fulfilling the characteristics of a novel
entity. The planetary boundaries (9 in total) were defined in a 2009 article as the “boundaries within
which we expect that humanity can operate safely”59
.
57
J. C. Prata et al., Methods for sampling and detection of microplastics in water and sediment: A critical review, TrAC
Trends in Analytical Chemistry, 2019, 110: 150-159.
58
https://pubs.acs.org/doi/10.1021/acs.est.1c04158Persson, L., Carney Almroth, B., Collins, C. et al., ‘Outside the safe
operating space of the planetary boundary for novel entities’, Environmental Science and Technology, Vol. 56, No 3,
2022, pp. 1510–1521, American Chemical Society.
59
Rockström, J., Steffen, W., Noone, K. et al., ‘Planetary boundaries: exploring the safe operating space for humanity’,
Ecology and Society, Vol. 14, No 2, Article 32.
140
The presence of microplastics in soil may have effects on soil physicochemical properties. It might
also trigger alterations in physical soil properties including soil bulk density, water holding capacity,
and soil structures and in the soil biota negatively impacting the growth of some plants60
.
Detrimental effects have also been observed on marine biodiversity61,62
. Once in the aquatic
environment, microplastics can impact marine biodiversity in a number of ways. An increasing
number of studies report microplastic ingestion throughout the food chain63,64
. International Pellet
Watch, initiated in 2005 by Hideshige Takada65
and The Great Nurdle Hunt66
, organised by UK
charity FIDRA, both relied on pellet samples collected by citizens to demonstrate that pellet pollution
is a global issue. Indeed, they are highly mobile and have been found thousands of kilometres from
the nearest pellet production or conversion facility67
, including in important Natura 2000 areas68
.
They can carry a wide range of contaminants and microbes which can form a biofilm on their surface,
thus promoting the invasion of alien species in the ocean.69
When pellets are encrusted with tiny
biotas or larvae, the risk of introducing invasive species is increased, putting local native species at
risk70
.
Once released into the environment, pellets can be easily ingested by aquatic wildlife including
marine fish, squid, and different seabirds.71
While only a few studies have focused specifically on the
physiological effects of pellets, numerous laboratory studies have shown how microplastics interact
with aquatic organisms and animals. Many animal species ingest plastic and microplastic, mistaking
it for food – from large mammals, birds and fish to tiny zooplanktons, affecting among others feeding
behaviour, reproduction, and growth, and sometimes leading to death72
. Microplastics can be taken
up by to the organisms at the bottom of the food chain due to their size and ubiquitous distribution in
the open seas and lowest levels of water bodies. Microplastics have been found inside the digestive
tract of more than 100 different species73
.
The Risk Assessment Committee of the European Chemicals Agency (ECHA) also stated74
that
ingestion in laboratory studies has been linked to a diverse range of sub-lethal endpoints, including
60
Wang, W. et al., ‘Environmental fate and impacts of microplastics in soil ecosystems: Progress and perspective’,
Science of the Total Environment, Vol. 708, 2020.
61
P. L. Corcoran, Degradation of Microplastics in the Environment, Handbook of Microplastics in the Environment,
2022, 531–542.
62
N. Kalogerakis et al., Microplastics Generation: Onset of Fragmentation of Polyethylene Films in Marine
Environment Mesocosms, 2017, doi.org/10.3389/fmars.2017.00084
63
Cole, M., Lindeque, P., Halsband, C. and Galloway, T. S., ‘Microplastics as contaminants in the marine environment:
A review’, Marine Pollution Bulletin, Vol. 62, 2011, pp. 2588-2597.
64
Koelmans, A. A. et al., Risk assessment of microplastic particles, Nature Reviews Materials, 7:138–152, 2022.
65
http://www.pelletwatch.org/index.html
66
https://www.nurdlehunt.org.uk
67
Corcoran P. L. et al., A comprehensive investigation of industrial plastic pellets on beaches across the Laurentian
Great Lakes and the factors governing their distribution, Science of the Total Environment, 747:141227, 2020.
68
The unaccountability case of plastic pellet pollution - ScienceDirect
69
Khalid, N. et al., Linking effects of microplastics to ecological impacts in marine environments, Chemosphere, 264:
128541, 2021.
70
Corcoran P. L. et al., A comprehensive investigation of industrial plastic pellets on beaches across the Laurentian
Great Lakes and the factors governing their distribution, Science of the Total Environment, 747:141227, 2020.
71
Corcoran P. L. et al., A comprehensive investigation of industrial plastic pellets on beaches across the Laurentian
Great Lakes and the factors governing their distribution, Science of the Total Environment, 747:141227, 2020.
72
Group of Chief Scientific Advisors, ‘Scientific opinion on the Environmental and Health risks of microplastics
pollution’, Aprile 2019.
73
Secretariat of the Convention on Biological Diversity, ‘Impacts of marine debris on biodiversity: Current status and
potential solutions’, CBD Technical Series, No 67, 2012.
74
ECHA Committee for Risk Assessment (RAC) Committee for Socio-economic Analysis (SEAC), Background
Document to the Opinion on the Annex XV report proposing restrictions on intentionally added microplastics,
(https://echa.europa.eu/documents/10162/2ddaab18-76d6-49a2-ec46-8350dabf5dc6).
141
survival, feeding, growth, reproduction, moulting, malformation, behaviour, photosynthesis,
oxidative stress, enzyme activity, inflammation, gene expression and nutrient cycling. Typical
harmful effects are inner and outer lesions and blockage of the gastrointestinal tract, leading to false
satiation. Concerning micro- and nanoparticles, there are potentially three types of adverse effects
associated with ingestion:
• Physical effects related to consumption are similar to those found for macro plastics (but for
smaller organisms);
• Toxic responses from the release of hazardous substances derived from the additives in plastics
or the toxic contaminants adsorbed on microplastics; and
• The contamination of new media (the environment or animals) by the microorganisms which
develop on the surface of the plastic particles.
There is an emerging concern that microplastics can act as a carrier for microorganisms, including
pathogenic species of bacteria, resulting in an increase in the occurrence of non-indigenous species.75
GESAMP (2015)76
suggests evaluating the potential significance of plastics and microplastics as a
carrier for pathogenic microorganisms77
. Although microplastics do not pose acute fatal effects on
living organisms, they can cause chronic toxicity over the longer term. Due to their physical and
chemical properties, microplastics can absorb and transport numerous organic contaminants such as
polychlorinated biphenyls (PCBs), polycyclic aromatic hydrocarbons (PAH), endocrine disrupting
compounds (EDCs), various pharmaceuticals and heavy metals. Also, microplastics can contain a
complex mixture of chemicals, which may subsequently be released into the environment and
constitute new routes of exposure for organisms.
Specific impacts on the environment from pellets
Pellets have been found in areas including important Natura 2000 areas78
. First of all, the persistence
of a pellet in the aquatic environment may be measured over decades or more, depending on the
polymer type, the types and amounts of additives, and the polymers’ and additives’ reactions to
environmental processes (e.g. weathering, sunlight, wave action)79,80
.
Once in the environment, pellets are known to be eaten by a range of organisms and animals, and
cause harm to biodiversity and habitats. In areas that are badly affected, pellets have been seen
smothering sensitive habitats. Concerning biodiversity, as pellets are mainly constituted of either
polyethylene or polypropylene, once in the aquatic environment81
, they float unless they become
heavily biofouled (the gradual accumulation of organisms such as algae, bacteria, etc, on the plastic)
and then sink and accumulate in sediment. According to Werner et al. (2016), harm is caused by
75
P.J. Landrigan et al., The Minderoo-Monaco Commission on Plastics and Human Health, Annals of Global Health,
Vol. 89, no. 1, pp. 23.
76
Sources, fate and effects of Microplastics in the marine environment: a global assessement
77
Cole, M., Lindeque, P., Halsband, C. and Galloway, T. S., ‘Microplastics as contaminants in the marine environment:
A review’, Marine Pollution Bulletin, Vol. 62, 2011, pp. 2588-2597.
78
The unaccountability case of plastic pellet pollution - ScienceDirect
79
P. L. Corcoran, Degradation of Microplastics in the Environment, Handbook of Microplastics in the Environment,
2022, 531–542.
80
N. Kalogerakis et al., Microplastics Generation: Onset of Fragmentation of Polyethylene Films in Marine
Environment Mesocosms, 2017, doi.org/10.3389/fmars.2017.00084
81
The persistence of a pellet in the aquatic environment may be measured over decades or more, depending on the resin
type, the types and amounts of additives, and the reactions of the resins and additives to environmental processes (e.g.
weathering, sunlight, wave action). P. L. Corcoran, Degradation of Microplastics in the Environment, Handbook of
Microplastics in the Environment, 2022, 531–542. N. Kalogerakis et al., Microplastics Generation: Onset of
Fragmentation of Polyethylene Films in Marine Environment Mesocosms, 2017, doi.org/10.3389/fmars.2017.00084
142
pellets when they float or are in the water column, where they can be eaten by organisms and marine
animals (e.g. seabirds, mammals, and fishes) either intentionally because they are mistaken for food
or unintentionally when filter feeding animals take in seawater82
. Several documented accounts
describe pellet and other plastic ingestion by wildlife, most notably by seabirds and sea turtles83,84,85
.
Seabirds ingest pellets more frequently than any other animal, and approximately one-quarter of all
seabird species are known to ingest pellets. Fulmars frequently ingest floating plastic debris,
including pellets, as they capture prey from the sea surface86
.
Ingestion of pellets as any microplastic can cause physical harm such as internal injuries and impaired
ability to breath, swallow, digest food properly, or immediate death87
. In certain cases, plastic debris
cannot pass through the digestive system, which can lead to malnutrition or starvation by creating a
false feeling of fullness, known as pseudo‐satiation88
.
Finally, it has been demonstrated in studies89
as early as 2001 that pellets, unintentionally released
from the plastic industry to the environment, contained measurable concentrations of hazardous
substances used as additives. These hazardous substances can then enter the food chain, and be a
potential risk for human health.
2.2 Climate impacts
When considering the possible impacts of microplastics (including pellets) on the climate, global
trends suggest that microplastic emissions will continue to increase. Microplastics represent a non-
climatic pressure on ecosystems as carbon and nutrient cycling processes in soil can be greatly
affected by the presence of microplastics and their further decomposition90
(and might therefore lead
to a decreased capacity for GHG absorption). In addition, plastics and microplastics are a source of
GHG emissions, putting additional pressure on the climate. GHGs are emitted throughout the plastic
life cycle, because all related activities (extraction, refining, manufacturing and end of life
management) are carbon intensive. Conventional plastics (based on fossil fuels) produced in 2015
82
Werner S; Budziak A; Van Franeker J; Galgani F; Hanke G; Maes T; Matiddi M; Nilsson P; Oosterbaan L; Priestland
E; Thompson R; Veiga J; Vlachogianni T. Harm caused by Marine Litter. EUR 28317 EN. Luxembourg
(Luxembourg): Publications Office of the European Union; 2016. JRC104308
83
Lacroix C. et Huvet A., ‘Table ronde n°1 : Devenir et gestion dans les ports et les milieux littoraux – introduction
scientifique : caractérisation de la pollution et risques associés’ [Roundtable n°1 : Outlook and management in ports
and coastal environmentas – scientific introduction : the characterisation of pollution and associated risks],
Conférence Journée Plastiques et Environnement associés’ [Conference : Day of plastics and associated
environments], June 2019
(https://enviroplast2019.sciencesconf.org/data/TR1_1_PPT_journe_es_plastiques_et_environnement_Lacroix_Huve
t.pdf).
84
Ryan, P. G., ‘Seabirds indicate changes in the composition of plastic litter in the Atlantic and south-western Indian
Oceans’, Marine Pollution Bulletin, Vol. 56, no. 8, 2008, pp. 1406-1409.
85
Sheavly, S.B. and Register, K.M., ‘Marine Debris & Plastics: Environmental Concerns, Sources, Impacts and
Solutions’, Journal of Polymers and the Environment, Vol. 15, 2007, pp. 301-305.
86
Plastic particles in fulmars | OSPAR Commission
87
Group of Chief Scientific Advisors, ‘Scientific opinion on the Environmental and Health risks of microplastics
pollution’, Aprile 2019.
88
The Convention for the Protection of the Marine Environment of the North‐East Atlantic (OSPAR) Commission,
OSPAR Background document on pre-production plastic pellets, 2018.
89
Mato Y. et al., ‘Plastic resin pellets as a transport medium for toxic chemicals in the marine environment’,
Environmental Science & Technology, Vol. 34, No. 2, 2001, pp. 318-324.
90
Rilling M. C. et al., Microplastic effects on carbon cycling processes in soils, Plos Biology, 2021,
https://doi.org/10.1371/journal.pbio.3001130
143
accounted for 3.8% of total global CO2 emissions, and their share could reach 15% by 205091
. A
more recent study estimates even higher CO2 emissions from plastic production (1.96 Gt of CO2e)92
.
Microplastics are widely found in aquatic environments.93
Their presence may cause more
greenhouse gas emissions as they can negatively affect multiple factors, such as phytoplankton
photosynthesis, which contribute to carbon sequestration.94
Microplastics are widely identified in
aquatic environments.95
The impact of marine plastics on ecosystem responsible for the gas exchange
and circulation of marine CO2 may cause more greenhouse gas emissions. Marine microplastics can
negatively affect phytoplankton photosynthesis and growth, zooplankton and their development and
reproduction, marine biological pump andocean carbon stock. Phytoplankton and zooplankton are
the most important producer and consumer of the ocean.96
Moreover, the climate change effects, e.g. more frequent heavy rainfall events, will exacerbate the
problems linked with releases of those microplastics from urban runoff and stormwater overflows
(SWO). Furthermore, the gradual degradation and fragmentation process of microplastics, when
exposed to ambient solar radiation in ocean waters, may release methane, a potent greenhouse gas,97
and ethylene into the atmosphere, depending on the type of microplastics, though the study also finds
that this is likely to be an insignificant component of the global CH4 budget.
2.3 Human health impacts
Despite more and more research being carried out to understand microplastics’ impacts on human
health, there is still no scientific consensus on these impacts. According to the Risk Assessment
Committee of the European Chemical Agency (ECHA),98
potential effects on terrestrial organisms
in general, and on human health, have not been well studied but include infertility, genetic disruption,
poisoning, reduced feeding and increased mortality in marine organisms and in humans if ingested
in very large quantities. Inhalation of microplastics can provoke severe problems in the lung.
Humans are exposed to microplastics everywhere via food consumption and inhalation. The annual
intake of microplastics by humans has been estimated to range from 70 000 to over 120 000 particles
a year depending on age, gender, region, and consumption99
. This includes an estimated 70 000
particles inhaled in air and 50 000 particles ingested in food and drink.
91
IPCC Working Group III Report: Mitigation of Climate Change (2022) https://www.ipcc.ch/report/sixth-assessment-
report-working-group-3/
92
Cabernard, L., Pfister, S., Oberschelp, C. et al. Growing environmental footprint of plastics driven by coal
combustion. Nat Sustain 5, 139–148 (2022).
93
Phytoplankton response to polystyrene microplastics: Perspective from an entire growth period - ScienceDirect
94
Can microplastics pose a threat to ocean carbon sequestration? - ScienceDirect
95
Phytoplankton response to polystyrene microplastics: Perspective from an entire growth period - ScienceDirect
96
Can microplastics pose a threat to ocean carbon sequestration? - ScienceDirect
97
Royer, S.-J. et al., ‘Production of methane and ethylene from plastic in the environment’, PLoS ONE, Vol. 13, No 8,
2018, Public Library of Science.
98
European Chemicals Agency, Opinion of the Committee for Risk Assessment and Opinion of the Committee for
Socio-Economic Analysis on an Annex XV dossier proposing restrictions on intentionally-added microplastics,
ECHA/RAC/RES-O-0000006790-71-01/F and ECHA/SEAC/RES-O-0000006901-74-01/F, 2020
(https://echa.europa.eu/documents/10162/a513b793-dd84-d83a-9c06-e7a11580f366).
99
Kieran D. Cox, Garth A. Covernton, Hailey L. Davies, John F. Dower, Francis Juanes, and Sarah E. Dudas (2019).
Human Consumption of Microplastics. Environmental Science & Technology 2019 53 (12), 7068-7074 DOI:
10.1021/acs.est.9b01517
144
The consumption of seafood, containing microplastics, is one of the main concerns for humans100
.
There is evidence to suggest that additives such as dyes or plasticisers could cause toxicity,
carcinogenicity and mutagenicity.101,102
Pellets are likely to carry toxic chemicals as well on their
surface since persistent organic pollutants (POPs) such as polychlorinated biphenyls (PCBs),
dichloro-diphenyltrichloroethane (DDT), hexachlorocyclohexanes (HCHs), and polycyclic aromatic
hydrocarbons (PAHs) can be easily adsorbed to their surface and then released over time. 103
The
concentrations of these substances adsorbed onto plastic pellets are highly variable. The health
impacts of POPs are not immediate but result rather from chronic, cumulative and long-term
exposure.104
Microplastics, including pellets would also pass up the food chain through plants which
absorb synthetic contaminants from the soil105
. Human exposure to microplastics through drinking
water is believed to currently be low in Europe106
, but a systematic review of available evidence is
lacking107
. People that predominately drink bottled water may ingest an additional 90 000 particles
of microplastic a year108
. Work is ongoing to produce up-to-date knowledge on the occurrence and
possible toxic effects of ingesting micro- and nanoplastics via food products and beverages to provide
a basis for risk assessment.109
CUSP, the European Research Cluster to Understand the Health
Impacts of Micro- and Nanoplastics is also carrying out research in this area110
.
Although additional research is still required on exposure to airborne microplastics, their prevalence
in urban zones is concerning: one study found microplastics in all urban air samples and identified
92% of them as fibrous.111
Apart from inhaling fibres as fine dust in outdoors environments, humans
are also exposed to indoor airborne microplastic pollution.112
When inhalation rates are high,
100
Cox, K. D. et al., ‘Human consumption of microplastics’, Environmental Science and Technology, Vol. 53, No 12,
2019, pp. 7068–7074.
101
Gasperi, J., et al., Microplastics in Air: Are We Breathing It In?, Current Opinion in Environmental Science & Health,
1–5. 2018. https://doi.org/10.1016/J.COESH.2017.10.002
102
Blackburn, K., Green, D., The potential effects of microplastics on human health: What is known and what is
unknown, Springer, Ambio, 51:518–530, 2021.
103
Corcoran P. L. et al., A comprehensive investigation of industrial plastic pellets on beaches across the Laurentian
Great Lakes and the factors governing their distribution, Science of the Total Environment, 747:141227, 2020.
104
Nadal, M. et al., Climate change and environmental concentrations of POPs: A review, Environmental Research, 143:
177-185, 2015.
105
Sciencealert.com, ‘Study shows how microplastics can easily clim the food chain. Should we be worried?’, 2022
(https://www.sciencealert.com/study-shows-how-microplastics-can-easily-climb-the-food-chain-should-we-be-
worried).
106
WHO (2019) Microplastics in drinking-water. Geneva: World Health Organization; Licence: CC BY-NC-SA 3.0
IGO.
107
EurEau, ‘Microplastics and the water sector’, 2019 (https://www.eureau.org/resources/briefing-notes/3940-briefing-
note-on-microplastics-and-the-water-sector/file); Koelmans, A., Hazimah Mohamed Nor, N., Hermsen, E., Kooi, M.
et al., ‘Microplastics in freshwaters and drinking water: Critical review and assessment of data quality‘, Water
Research, Vol. 155, 2019, pp. 410-422.
108
Cox, K. D. et al., Ibid.
109
Shopova et al., ‘Risk assessment and toxicological research on micro- and nanoplastics after oral exposure via food
products’, EFSA Journal, 2020 https://doi.org/10.2903/j.efsa.2020.e181102
110
CUSP cluster - The European Research Cluster to Understand the Health Impacts of Micro- and Nanoplastics (cusp-
research.eu)
111
Wright S.L. et al., ‘Atmospheric microplastic deposition in an urban environment and an evaluation of transport’,
Environ Int, Vol. 136, 2020.
112
Plastic Soup Foundation _ Do clothes make us sick, 2022. This study found that 30% of the dust captured in air
conditioning filters from dormitories, offices, and living rooms were microplastic fibres, with polyester, rayon, and
cellophane as the dominant polymers. Fibre fragments are released from clothes and indoor textiles through use, wear
and tear, the washing of garments, and drying. Fibres cannot always be cleared, for example by coughing. The
dimensions of the fibres also play a role in toxicity. Thinner fibres are inhalable as their elongated shape allows fibres
to deeply penetrate into the lungs. Longer fibres are more persistent and toxic to lungs cells. Fibres < 0.3 μm wide
and >10 μm long are most carcinogenic.
145
accumulation of microplastics will occur in certain organs impacting their health. This process will
cause chronic inflammation, which is known to be a leading cause of diseases such as cancer, heart
disease, asthma, and diabetes. Both cellulosic and plastic microfibers were found in lung tissue taken
from patients with different types of lung cancer. According to the same study, this may particularly
affect people with a viral infection or children whose lungs are still developing. Also, children under
the age of six inhale three times more microplastics than an average adult.
Several studies on the occupational exposure of textile workers show (as early as 1975113
) that the
inhalation of microplastic fibres from textiles can lead to pulmonary disease such as interstitial lung
disease (linked to nylon flock exposure114
). Chronic exposure to plastic microfibres in urban air,
indoor115
or outdoor116
, also raises concerns about the need for action reducing microplastic emissions
in European cities.
A recent study117
analysed 17 studies on the toxicity of microplastics to human cells establishing
detrimental impacts (including cytotoxic), triggering immune responses, causing oxidative stress, and
the shape of microplastics influencing these negative effects (irregularly shaped microplastics had
more adverse effects than spherical ones). However, it also states that the “overall certainty of the
body of evidence” is low due to the fact that researchers couldn’t access the original data. High levels
of exposure to microplastics are believed to induce inflammatory reactions and toxicity, possibly due
to the additives used to produce the plastic.118
In addition, microplastics could potentially act as
vectors for pathogens and microbes119
.
However, the precautionary principle should be applied since the presence of microplastics in human
stool120
demonstrate intestinal exposure. In addition, some studies seem to suggest that microplastics
can be found in pregnant women’s placenta,121
and more recently, in human blood122
.
113
Pimentel, J. C., Avila, R. and Lourenço, A. G., ‘Respiratory disease caused by synthetic fibres: A new occupational
disease’, Thorax, Vol. 30, No 2, 1975, pp. 204–2019.
114
Boag, A., Thomas V., Fraire, A., Kuhn, C. et al., ‘The pathology of interstitial lung disease in nylon flock workers’,
American Journal of Surgical Pathology, Vol. 23, No 12, 1999, pp. 15–39.
115
Dris, R., Gasperi, J., Mirande, C. et al., ‘A first overview of textile fibres, including microplastics, in indoor and
outdoor environments’, Environmental Pollution, Vol. 221, 2017, pp. 453–458.
116
Dris, R., Gasperi, J., Rochr, V. et al., ‘Microplastic contamination in an urban area: A case study in Greater Paris’,
Environmental Chemistry, Vol. 12, No 5, 2015.
117
Danopoulos, E., Twiddy, M., West, R. and Rotchell, J., ‘A rapid review and meta-regression analyses of the
toxicological impacts of microplastic exposure in human cells’, Journal of Hazardous Materials, Vol. 427, No 6,
2022.
118
Potential Health Impact of Environmentally Released Micro- and Nanoplastics in the Human Food Production Chain:
Experiences from Nanotoxicology | Environmental Science & Technology (acs.org)
119
Microplastics from textiles: towards a circular economy for textiles in Europe — European Environment Agency
(europa.eu)
120
Schwabl, P. et al., ‘Detection of various microplastics in human stool’, Annals of Internal Medicine, Vol. 171, No 7,
2019, pp. 453–457, American College of Physicians.
121
Ragusa, A. et al., ‘Plasticenta: First evidence of microplastics in human placenta’, Environment International, Vol.
146, 2021, Elsevier BV. ; Dusza, H.M. et al, ‘Uptake, Transport, and Toxicity of Pristine and Weathered Micro- and
Nanoplastics in Human Placenta Cells’, Environmental Health Perspectives, Vol; 130, No 9, 2022.
122
Leslie, H. A. et al., ‘Discovery and quantification of plastic particle pollution in human blood’, Environment
International, Vol. 163, 2022, Elsevier BV.
146
2.4 Economic impacts
In addition to the versatile effects on environment, climate and health, there are potentially negative
impacts on the economy as well. Some of these impacts are related to microplastics in general,
including pellets, others to pellets specifically.
The growing evidence/awareness of microplastics’ presence in seafood, salt, honey, fruits, vegetables
and drinking water could undermine consumer confidence and bear economic consequences.
There are potential negative economic impacts on activities such as commercial fishing and
agriculture (e.g. reduced fishing due to impacts of microplastics on marine eco-systems and fauna,
which eats it) as well as recreation and tourism (reduced attractiveness due to impacts of microplastics
on beaches and vulnerable areas like national parks, rivers and lakes123
).
Clean-up costs are often unknown and operations are usually the responsibility of local communities
with a negative impact on their budgets. For example beach clean-ups are estimated to cost EUR1
000 000 per year for the city of Marseille (France)124
. SOS Mal de Seine Association highlighted the
lack of capacity of public authorities to deal with large‐scale pollution of pellets on beaches (e.g.
caused by lost containers). As a matter of fact, clean‐up operations are complex to undertake because
these particles are difficult to see due to their size and that vegetation may hide them. They should
also be carried out within an hour of an incident to prevent widespread pollution by wind, rain, and/or
tides. Monitoring costs of plastic pellet ingestion by species are also unknown. However, the costs
of La Rochelle Aquarium’s monitoring of microplastic ingestion by loggerhead sea turtles was a total
of EUR50 000 over four years. Another pertinent example is the monitoring of microplastic ingestion
by fulmars provided by ornithological groups, which costs EUR33 300 for one winter season.
123
Plastic Giants polluting through the backdoor; Silent Pollution – Who is contaminating Puglia’s coastline with plastic
pellets?; Plastic pellets spill pollutes Danish, Norwegian, Swedish coastlines; Microplastic pollution in the surface
waters of Italian Subalpine Lakes; Granulés plastiques industriels sur le littoral français
124
OSPAR Background document on pre-production Plastic Pellets, 2018
147
Annex 8:
Problem definition – pellet losses to the EU environment
1 PROBLEM DEFINITION
Current practices for handling pellets lead to losses at each stage in the supply chain, causing
adverse environmental and potential human health impacts.
Plastic raw materials come in different forms, including pellets, flakes, powders and in liquid forms,
all referred to collectively as “pre-production plastic pellets”125
. In Europe, approximately 80 % of
all plastic raw materials produced are in the form of round to oval granules of approximately 2 mm
to 5 mm in diameter126
. A relevant part of the remaining 20% is even smaller than 2mm, such as
powders, and a minor part can be slightly bigger. It is common sense to tackle all these pellets
together. This will also ensure pellets that might be slightly bigger will still be subject to possible
legislation, thus avoiding possible attempts by industry to avoid relevant legislation by making pellets
slightly bigger than 5mm. Figures from literature often refer to “pellets”, irrespective of their
dimension.
1.1 The pellet supply chain
Pellets can reach the environment through losses occurring at every stage of the supply chain:
production (virgin or recycled), processing (compounding, masterbatch making, converting, etc.),
logistic operations (transport, storage and tank cleaning), waste management, etc. Therefore, tackling
pellet losses clearly requires a supply chain approach.
The pellet supply chain is complex. Virgin pellets are manufactured at large installations, and then
stored in silos; they are mostly either filled directly into tankers, or packed for transport to conversion
sites, where final plastic products are made. Losses can also occur at recycling facilities, where post‐
consumer plastic waste is recycled back into pellets in order to be reintroduced into the plastic
manufacturing cycle127
.
Box 7: Companies handling pellets
Companies handling pellets are categorised as follows:
• producers who create virgin plastic pellets from oil, gas and other raw materials;
• recyclers who collect, sort, clean and process plastic waste into recycled plastic flakes
or pellets;
• traders/brokers who purchase the plastic material and store it or otherwise handle it
before selling it to converters or exporting;
125
The Convention for the Protection of the Marine Environment of the North‐East Atlantic (OSPAR) Commission,
OSPAR Background document on pre-production plastic pellets, 2018. Technically, according to ISO 472:2013, a
pellet is a “small mass of preformed moulding material, having relatively uniform dimensions in a given lot, used as
feedstock in moulding and extrusion operations”.
126
PlasticsEurope, ‘PlasticsEurope Operation Clean Sweep® Report 2017’, 2017
(https://www.opcleansweep.eu/application/files/8316/3456/6233/PlasticsEurope_OCS_progress_report-2017.pdf).
127
Hann, S., Sherrington, C., Jamieson, O., Hickmann, M., Kershaw, P., Bapasola, A., Cole, G. (2018). Investigating
options for reducing releases in the aquatic environment of microplastics emitted by (but not intentionally added in)
products, Eunomia.
148
• intermediary facilities that handle the plastic material between the producer and the
processor, such as storage and repacking facilities;
• processors who transform the plastic pellets by either mixing them with other materials
to alter their physical properties or by transforming them directly into manufactured
goods (the former are called compounders and the latter converters);
• distributors who sell (a small portion of) the plastic pellets to sectors such as
construction;
• logistic companies; and
• waste management companies.
Producers: in Europe, there are close to 100 large polymer-producing companies that are members
of the trade association “Plastics Europe”.128
These companies produce some 54.8 million tonnes of
virgin pellets per year and represent 90% of the total EU production. In 2021, circa 138,000 people
worked for plastic manufacturers in the EU27. The number of individual enterprises was around
2300. In 2021, plastic manufacturers generated a turnover of EUR 117 billion.
Processors: the situation of the processors is significantly different: the trade association “European
Plastic Converters” (EuPC) totals about 51 national and European industry associations, representing
90% of the total EU processing, equivalent to approximately 48 000 individual companies, out of
which 66% are micro-companies (some 31 400 micro-enterprises handling an average tonnage below
100T and representing an average turnover of EUR 300 000 annually, equivalent to 4% of the total
turnover of the industry)129
. Converters employ 1.3 million people and have an annual turnover of
EUR 269 billion130
.
Processors transform raw pellets by either mixing them with other materials to alter their physical
properties (changing their melting point, colour, insulation properties, etc.) or by transforming them
directly into manufactured goods. The former is called compounders and the latter converters.
Compounders can either be part of a converter’s system to alter their physical properties on the same
site that they are manufacturing the finished product or independent members of the value chain
supplying new pellets (thus adding a link to the value chain where loss is possible).
Transporters: the “European Chemical Transport Association” (ECTA) represents approximately
100 transport companies active in the transport of chemical products including pellets131
. These
ECTA members are the major Logistic Service Providers in this sector in Europe and most of them
are not SMEs. They cover 30% of the total pellet transport in Europe. Beyond ECTA members,
transporters are largely micro and small entreprises, ca. 13 000.
Transporters move plastic pellets from their manufacturing grounds to the facility they will be used
in. Transport occurs by three main delivery mediums: Sea cargo ships; Road lorries; Railways; Air.
Each distribution method uses different types of containers to store plastic pellets, ranging from small
bags (20‐25 kg) to silo trucks (up to 35 t) and large maritime containers. Not all bags are sealed,
airtight and puncture-resistant to prevent damage and tears.
128
Plastics Europe, ‘Membership’ (https://plasticseurope.org/about-us/membership/).
129
European Plastic Converters (EuPC), ‘Organisation’ (https://www.plasticsconverters.eu/).
130
Source Eurostat (20210 figures) for EU-27 (Statistics | Eurostat (europa.eu))
131
European Chemical Transport Association, ‘List of ECTA and ECTA RC* Members 2023’
(https://www.ecta.com/organization/list-of-members/).
149
Other logistic operators: the “European Federation of Tank Cleaning Organizations” (EFTCO)
declares 630 tank cleaning stations in Europe, out of which at least 440 deal with tanks containing
pellets. Also, there would be around 850 warehouses in Europe storing pellets. These companies are
largely micro and small enterprises. They provide intermediary services to the supply chain, aside
from transporters. These intermediary points are important as they represent additional stages at
which pellets are handled and can be lost.
Waste management companies: they collect waste pellets from processors to treat them. Producers,
processors and intermediary facilities typically employ commercial waste management firms to
handle their waste.
Recyclers: in 2021, there were some 730 plastic recycling companies in the EU132
. They occupy
more than 20 000 employees and create a turnover of EUR 8.5 billion annually. In 2021, they
produced 7.6 million tonnes of recycled pellets, while the installed capacity is roughly of 11 million
tonnes. 165 plastic recycling companies are members of the trade association “Plastics Recyclers
Europe” (PRE) regrouping both industry associations and individual companies, mostly large
companies. These companies represent 80% of the EU market installed capacity.
More information on the share of SMEs in the pellet supply chain is presented in Annex 12.
1.2 Pellet losses
While the pellets supply chain is mainly grouped into the above mentioned categories, there are
several intermediate steps where pellet losses can occur, such as:
• Production
o Granulation: cutting with a knife in the water nearby or in the pellet receptacles in
the factory
o Packaging (bagging or tanking)
o Unloading by handling or pneumatic
o Technical problems: pneumatic accidents with plug
o Electrostatic phenomenon
• Compounding (similar steps as for production)
• Processing (conversion or transformation of pellets into products)
o Unloading of pellets
o Delivery in bags, octabins or tanks
o Storage
o Conversion
• Logistics
o Storage in silos by pneumatic
o Palletisation of containers = bags (big bags) or octabins
o Bagging fractionation steps
o Handling pallets of bags or octabins
o Installation of pallets in unconfined storage parking lots
o Loading of pallets on flatbed trailers or in (road) containers
o Chronic losses during road or rail transport and accidental losses
o Chronic losses shipping and accidental losses
132
Plastics Recyclers Europe, ‘Plastics Recycling Industry in Europe: Mapping of Installed Plastics Recycling Capacities
2021 Data’, 2023 (https://www.residuosprofesional.com/wp-content/uploads/2023/03/Plastics-Recycling-Industry-
in-Europe-2023.pdf).
150
o Chronic losses during port handling and accidental losses
Other steps where pellet losses can occur are:
• Waste and cleaning steps
o Operating waste
o Recovery of empty containers for recycling
o Tank washing
o Cleaning of flatbed trailers
• Water used in different processes can also contain pellets
o Granulation water
o Cleaning water
o Recycled water
o Washing water
o Retention water
o others (stormwater, road washing and leaching)
The Commission of the regional convention for the protection of the Marine Environment of the
North-East Atlantic (OSPAR)133
distinguishes the following:
• Pellet spill as a “One-off escape of pellets from primary containment (not necessarily
resulting in loss to the environment)”;
• Pellet loss as a “One-off or prolonged escape of pellets to the environment”.
Spills – if not contained – may end up as “losses” in the environment. A part of these pellets are
recovered (in the wastewater treatment system for example), the other part is considered as lost or
released into the environment.
Figure 7: Pellet losses in the environment
133
OSPAR Commission, ‘Guidelines in support of Recommendation 2021/06 on the reduction of plastic pellet loss into
the marine environment’, 2021 (https://www.ospar.org/documents?v=46269).
151
Pellet losses can be the result of:
1) chronic, ongoing pellet incidents during routine operations. This usually occurs as a result of lack
of awareness and improper training, poor handling and housekeeping practices and due to the absence
of pellet loss preventive and mitigating measures.
2) acute, one-off, pellet incidents. This usually occurs as a result of accidents during transport or
major equipment failures in the absence of pellet loss preventive and mitigating measures.
1.2.1 Chronic pellet losses
Chronic pellet losses typically happen during both bulk and packed loading and unloading operations
at special installations and during transport and logistic operations. The report from the plastics
producers on Operation Clean Sweep134
corroborates this presumption by adding process and mixing
points as other pellet loss hotspots. The report states that: “The majority of companies (97%) have
analysed the sources of potential pellet spills at their facilities and identified that loading and
unloading areas, process and mixing points are the three main locations where pellets losses occur
more often at different sites”.
The main reasons of these losses are the following135
:
• In the production process, the most common causes of pellet losses are the incompletely
sealed conveying systems, damaged or leaky packaging, rail hopper car and bulk truck
cleaning operations, lack of a containment system, failure of the containment system during
heavy rainfall, infrequent or inadequate housekeeping, unsealed or unsecured rail hopper car
valves and the lack of employee awareness.
• During transport, pellet losses occur due to incompletely sealed bags or leaking bag valves,
improper bag storage practices, lack of employee awareness, inadequate training of forklift
operators, infrequent routine maintenance, improperly or inadequately sealed or secured rail
hopper car valves, lack of a containment system or other control mechanisms, improper
handling of pellet cargo at ship docks and aboard ship, overfilling of storage silos,
displacement of the conveyor system ports and accidents of ships carrying pellets.
• In processing facilities, pellet losses can occur because of the lack of communication
between industry management, inadequate employee awareness and training, inadequate
facilities like lack of waste-, or storm-water containment systems in place, careless routine
operations, inadequate housekeeping practices, easily damaged or leaky packaging and
improper unloading and warehousing procedures.
There is evidence of point source input near plastic processing plants, where the abundance of plastic
pellets or powders can be relatively high.136
Chronic pellet incidents have been reported at production
134
Plastics Europe, ‘Operation Clean Sweep® Progress Report 2019’, 2020 (https://plasticseurope.org/knowledge-
hub/operation-clean-sweep-progress-report-2019/).
135
US Environmental Protection Agency, ‘Plastic Pellets in the Aquatic Environment: Sources and Recommendations’,
1992 (http://www.globalgarbage.org/13%20EPA%20Plastic%20Pellets.pdf).
136
Norén, F. & Ekendahl, S., ‘Microscopic Anthropogenic Particles in Swedish Waters: many more than believed’, 2009,
Schwerin, Germany: Helsinki Commission.
152
sites in the Netherlands137
, Belgium138
, Spain139
, the UK coastline, Scotland140
, Denmark141
and
Sweden142
. Logistic platforms like ports are hotspots for pellet losses, and the ports of Rotterdam,
Antwerp and Tarragona have been reported to be heavily polluted locations by several organisations
active in the monitoring of pellet losses143
. An important part of chronic pellet incidents happens also
during the transport of pellets across land (e.g. road and rail), such as in Belgium144
, or during
maritime transport145
.
1.2.2 Acute pellet losses
Acute pellet incidents have happened in industrial facilities in Italy146
and during the transport of
pellets across land, e.g. in France147
and during maritime transport, e.g. in the Netherlands148
or in
Denmark149
. Acute pellet incidents occurring in the form of containers lost at sea result in large
quantities of pellets released directly into the marine environment150
. Some big incidents with
unknown origin have also to be mentioned such as the ones in Southampton, England151
and in the
Loire-Atlantique coastline of France152
among several others in Europe and worldwide153
.
Box 8: Examples of major acute pellet incidents during maritime transport
2012: In Hong Kong, after being blown by Typhoon Vicente on 24 July 2012, some containers
belonging to Chinese oil giant Sinopec which were carrying over 150 tonnes of plastic pellets,
were blown into the sea, washing up on southern Hong Kong coasts, such as Shek O, Cheung
Chau, Ma Wan and Lamma Island. The spill disrupted marine life and was credited with killing
stocks of fish-on-fish farms154
.
2017: A nurdle spill of about two billion nurdles (49 tonnes) from a shipping container in Durban
Harbour required extended clean-up efforts. These nurdles have also been spotted washing up
on the shore in Western Australia155
.
137
Westerschelde-plastic-nurdles-versie-definitief-21-11-2021-2.pdf (plasticsoupfoundation.org)
138
Ecaussinnes (Belgium): Surfrider Foundation tackles industial plastic granules
139
New report out exposes alarming impacts of plastic pellets across Europe - Good Karma Projects
140
Fife beach 'worst' for nurdle pollution - BBC News
141
Tackling sources of Marine Plastic Pollution through effective corporate engagement: a Danish Case Study
142
The unaccountability case of plastic pellet pollution - ScienceDirect
143
Plastic Giants polluting through the backdoor. New report out exposes alarming impacts of plastic pellets across
Europe - Good Karma Projects
144
Ecaussinnes (Belgium): Surfrider Foundation tackles industial plastic granules
145
Sources, fate and effects of Microplastics in the marine environment: a global assessement
146
Nurdle pollution hotspot identified in Italy (nurdlehunt.org.uk)
147
Morbihan. Un camion perd sa marchandise, 28 tonnes de granulés en plastique sur la route (ouest-france.fr)
148
24 million plastic pellets from MSC Zoe on northern Dutch coastline – The Northern Times
149
Plastic pellets spill pollutes Danish, Norwegian, Swedish coastlines – KIMO (kimointernational.org)
150
In 2021, the container ship MV X-Press Pearl caught fire and sank losing approximately 1680 tonnes of plastic pellets
in a single event (some 84 billion pellets). In Europe, in 2020, the MV Trans Carrier lost more than 10 tonnes of
plastic pellets in the German Bight. Plastic pellets spill pollutes Danish, Norwegian, Swedish coastlines – KIMO
(kimointernational.org) 24 million plastic pellets from MSC Zoe on northern Dutch coastline – The Northern Times
151
Plastic pollution at Chessel Bay nature reserve in Southampton | Daily Echo
152
Les plages de la côte Atlantique polluées par une marée de granulés plastiques, l’Etat porte plainte (lemonde.fr)
153
https://www.nurdlehunt.org.uk/nurdle-finds.html
154
Lyn, T.E., ‘Sinopec pledges help to clear Hong Kong plastic spill’, Reuters, 2012 (https://www.reuters.com/article/us-
pollution-hongkong-sinopec-idUSBRE8780I920120809). https://www.reuters.com/article/us-pollution-hongkong-
sinopec-idUSBRE8780I920120809
155
Two Oceans Aquarium, ‘The Great Nurdle Disaster: What to do if you find nurdles’, 2017
(https://www.aquarium.co.za/blog/entry/the-great-nurdle-disaster-what-to-do-if-you-find-nurdles).
https://www.aquarium.co.za/blog/entry/the-great-nurdle-disaster-what-to-do-if-you-find-nurdles
153
2018: A semi-truck crash led to the release of bright blue-coloured nurdles into Pocono Creek
and the waterways of the Lehigh Valley, Pennsylvania.
2020: On 23rd February 2020, the MV Trans Carrier lost more than 10 tonnes of plastic pellets
in the German Bight when the cargo on board moved during a storm, damaging one of the
containers, which broke open156
.
2020: During a thunderstorm on August 20th, a 12 m shipping container with 25 tonnes of
nurdles fell off the CMA CGM Bianca ship into the Mississippi River in New Orleans. No
official clean-up took place157
.
2021: On 2 June 2021, the cargo ship “X-Press Pearl” containing 1680 tonnes of plastics
pellets158
sank off the coast of Sri Lanka, spilling chemicals and microplastic nurdles and causing
the worst environmental disaster in the country's history159
. The actual quantity of pellets lost to
the environment is unknown.
Existing monitoring programs in Europe show the presence of plastic pellets in the marine
environment. In addition to those implemented in the framework of the Marine Strategy Framework
Directive, which requires all Member States to monitor microplastic litter on beaches160
, there are
programs like the Port of Antwerp’s collaboration with PlasticsEurope161
. In the area of the port of
Antwerp, home to 10 pellets producers, in 2017, about 4 tonnes of plastics pellets were collected in
the environment centred on the port area during a citizens’ action, with most pellets found close to
the production plants162
. The Port of Antwerp has been running the Antwerp Zero Pellet Loss
Platform since 2017 with the aim of improving the implementation of the OCS programme in the
port of Antwerp. In 2022, an OVAM representative163
confirmed that “there are still pellet losses
around the Port of Antwerp”.
Since the 1970s, plastic pellets have been observed in marine environments around the world,
including at sites which are not close to petrochemical or polymer industries. These have been
documented using different observation protocols developed by NGOs such as SOS Mal de Seine
and Fidra. This demonstrates that while pellet losses can be concentrated in one geographical area,
they are also extremely mobile and can be dispersed by surface water and sea currents, as well as
through the air.
156
KIMO, ‘Plastic pellets spill pollutes Danish, Norwegian, Swedish coastlines’, 2020
(https://www.kimointernational.org/news/plastic-pellets-spill-pollutes-danish-norwegian-swedish-coastlines/).
157
Nola.com, ‘No cleanup planned as millions of plastic pellets wash up along Mississippi River and flow to the Gulf’,
2020 (https://www.nola.com/news/environment/article_b4fba760-e18d-11ea-9b0b-b3a2123cf48b.html).
158
United Nations Environment Programme, ‘X-Press pearl maritime disaster Sri Lanka – Report of the UN
Environmental Advisory Mission’, 2021 (https://www.unep.org/resources/report/x-press-pearl-maritime-disaster-sri-
lanka-report-un-environmental-advisory-mission).
159
The Guardian, ‘Sri Lanka faces disaster as burning ship spills chemicals on beaches’, 2021
(https://www.theguardian.com/world/2021/may/31/sri-lanka-faces-disaster-burning-ship-spills-chemicals-beaches).
160
In 2016, Spain started the MSFD subprogram on microplastics on beaches, and pellets were detected with an average
concentration of 47.8 pellets/kg or 419.2 pellets/m2. Currently, the MSFD Technical Group on Litter is developing a
protocol for monitoring pellets on beaches.
161
Plastics Europe, ‘Port of Antwerp Activity report 2021’, 2021 (https://plasticseurope.org/knowledge-hub/port-of-
antwerp-activity-report-2021/).
162
Rethink Plastic Alliance, Surfrider Foundation Europe, & Break Free from Plastic, ‘Plastic Giants polluting through
the backdoor’, 2020 (https://rethinkplasticalliance.eu/wp-
content/uploads/2020/12/bffp_rpa_pellets_polluting_through_the_backdoor.pdf).
163
Ovam, Personal communication, 2022.
154
1.3 Pellet pathways
Spilled pellets can reach the environment and become losses through several pathways.
Figure 8: Pellet pathways (solid lines represent pellet movements and dotted lines are loss pathways)
The plastic pellet value chain is not airtight, and there are numerous opportunities for pellets to be
lost into the environment. Pellets are released by the plastics industry at all stages of their life-cycle:
during production, conversion, transport and storage (at every facility they are handled in). When
pellets are spilled, they can reach the environment through two routes:
Direct releases into the environment:
o Aquatic environment: Pellets may be released directly into waterways, during
handling operations, in particular at ports or during cargo transport at sea.
o Land environment: Pellets may be released at site or during transportation due to
leaking packaging or during handling when transferring between different modes of
transportation.
o Air: some pellets are in the form of powder and could be found in air when not
properly contained.
Discharges in wastewater: via rainwater into storm-water drains, or wastewater treatment
systems (WWT).
When pellets are spilled during logistic and shipping operations, they normally reach the environment
directly and end up in water, land, and sometimes air.
Lost pellets may be carried by rainwater into storm-water drains. These transport the water into the
urban wastewater treatment (WWT) plants, when connected, which is approximately 65% of the
cases. The pellets may then be discharged into the aquatic environment through storm-water
discharges or, where the sewage and storm sewers are combined, through WWT discharges.
Normally, stormwater drains are designed to collect and carry rainwater, melted snow, and other
precipitation from the land surface. Stormwater drains are typically separate from wastewater drains,
which carry sewage and other household or industrial wastes to wastewater treatment plants. In some
cases, depending on local regulations and infrastructure, stormwater and wastewater may be
combined in a single drain. Some may discharge directly into nearby water bodies, while others may
flow into retention ponds, infiltration basins, or other types of stormwater management systems. In
155
urban areas, stormwater may also be collected and treated before discharge to reduce the risk of
flooding or water pollution.
When pellets are spilled inside installations where pellets are handled, dry or wet cleaning is possible.
In the case of dry cleaning, pellets are collected and then go to waste management (mostly for
incineration), except for recyclers who collect and put them back in the recycling process. Wet
cleaning pushes pellets to drains. From there, spilled pellets typically reach industrial wastewater
treatment in the case of production installations. Processing and recycling installations are either
linked to industrial or urban wastewater treatment systems.
In industrial wastewater treatment facilities, pellets are mostly captured in sludge and incinerated.
However the effluent may still contain some pellets (particularly, flakes and powders). In urban
wastewater treatment facilities, pellets are also captured in sludge (between 95-99%, depending on
the treatment efficiency). Depending on the sludge management, microplastics are either destroyed
(through incineration, for example) or released into the environment if sludge is spread on agricultural
lands (on average 50% of all sludge in the EU is applied in agriculture as fertilizer). These pellets
may stay in the soil or ultimately reach the aquatic environment (runoff to surface water or through
soil to groundwater). Pellets can also reach water via overflows, bypassing the wastewater facilities.
Therefore, the main pathways of pellets lost are water-related, i.e. urban, rain and storm water for
losses occurring in terrestrial areas and marine water for losses at cargo handling installations at ports
or occurring during cargo transport at sea.
1.4 Scale of the problem
While observable, these losses are not routinely measured, or indeed readily measurable at any
specific step. There is no harmonised methodology for measuring pellet losses. Neither pellet loss
measurements have been made at different steps of the supply chain, nor are any systemic monitoring
and reporting data available within the Member States or the industry to calculate pellet losses.
Hence, it is impossible to establish exact figures on pellet losses at each step because it depends on
the installation size, actors involved, management practices, etc., and all these aspects are very
heterogeneous in the EU.
Efforts to quantify the amount of pellets entering the environment typically apply a ‘loss rate’ as well
as a number of handling steps to the total pellet volume handled. Robust empirical evidence to inform
a ‘loss rate’ or a number of handling steps is scarce. However, the greater the number of steps at
which pellets are handled, the greater the opportunities for loss.
The major handling steps occur at production plants (of both virgin and recycled pellets), processing
installations and during logistic operations, i.e. all loading and unloading operations to transport
pellets from one installation to another including warehouse installations, where pellets are stored
and/or re-packed, and cleaning installations.
Several studies use the figures for pellet losses of 0.01%-0.04% (according to Sundt et al. (2014)164
.
However, this figure is an estimate from just one processor and is based on measurement in the
effluent, so it does not measure losses at other steps of the supply chain, nor emissions happening
otherwise, i.e. direct emissions to air, water and soil. Given the high uncertainty and potential double
counting, rates in the range of 0.001% and 0.1% have been suggested by some studies such as Peano
164
Norway (2014) Sources of microplastic pollution to the marine environment, Report for Norwegian Environment
Agency.
156
et al. (2020)165
. Compared to the total pellet volume, loss estimates in various publications show a
wide variation (see table below), making it difficult to estimate the exact magnitude of the problem166
.
The reason for such a large variation is that the actors involved in the supply chain range from very
small micro-enterprises to large companies and the level of awareness and measures in place to
prevent pellet losses vary considerably. Similarly, the number of handling steps in a typical supply
chain is influenced by the size of the operation, which is often driven by the demand for specific
plastics products and also external factors (e.g. petrol prices, pandemic, economic crisis, energy
price).
During the stakeholder meeting of 12 December 2022, stakeholders overall agreed with the approach
but had diverging opinions on the loss rates (the industry considers them too high) and the number
of handling steps (NGOs consider them too low167
).
OSPAR168
has further detailed the reasons leading to the lack of reliable information as follows:
• Most of the data were collected by interviews or questionnaires and not by measurements;
• The number of companies in the studies is relatively low;
• Different phases of the plastic cycle are involved (transport and production);
• Different companies may be involved (producers, transporters, storage companies and
converters);
• The difference in the definition of pellet loss: some respondents seem to focus on the total
pellet spill. In contrast, other respondents focus on the fraction of pellets that are washed into
the drains or surface waters. An unknown fraction of the lost pellets will be collected and
disposed of with solid waste; and
• Different study designs: For example, the German study estimated resource efficiency
(production yield) by comparing the mass of the feedstock purchased and the mass of the final
product sold, whereas, in other studies, the mass of pellet spills was estimated based on
observations.
Due to the lack of data and awareness, it was difficult to provide exact numbers on pellet loss. This
is well exemplified by the fact that all estimates in literature on pellet losses during the production
phase are based on one single Norwegian plant.
To take into account these uncertainties, a range of loss rates is used to calculate the losses occurring
at four major steps: production, processing, recycling and logistics. It is estimated that losses happen
at a higher rate at processing and recycling installations because of relatively small installations and
large number of handling steps (0.02%-0.06% of the total volume processed/recycled) than at
production ones (0.01%-0.03% of the total volume produced), and at an even higher rate during
transport and logistic operations (0.03%-0.12%) because of pellets normally entering the
environment directly. These rates count for the major handling steps in production, processing,
165
Peano et al., ‘Plastic Leak Project’, 2020 (https://quantis.com/who-we-guide/our-impact/sustainability-
initiatives/plastic-leak-project/).
166
OSPAR, ‘Assessment document of land-based inputs of microplastics in the marine environment’, 2017
(https://www.ospar.org/documents?v=38018 Page 22).
167
Seas at Risk provided a long list of different handling steps where pellet losses could occur, however without any
figures on loss rates.
168
OSPAR Commission, ‘Assessment document of land-based inputs of microplastics in the marine environment’, 2017
(https://www.ospar.org/documents?v=38018).
157
recycling and transport/logistic phases and do not take account of other handling steps occurring in
other phases (e.g. distribution), for which no data is available. These figures are therefore at the same
time uncertain due to the lack of a standardised methodology to measure pellet losses and scarce data,
and conservative. As said, losses depend on the volume handled, type of facility, variability in pellet
handling practices across the sector and Member states, etc. These figures will be improved once the
reporting obligation under REACH (and possibly complemented with a harmonised methodology
under this initiative) is in place.
Pellet loss calculations were made using these ranges of pellet loss ratios (lower and higher figures)
for the four types of operations, namely virgin pellet production, recycling, pellet processing and
logistics. These pellet loss ratios are applied to the volume of pellets handled during different steps
of the pellet supply chain.
The table below presents a recap of the main evidence available to date.
Table 45: Summary of Literature on microplastic emissions due to pellets
Author and Year Area of
Study
Estimate of Pellet Loss Basis of Estimate
OECD (2009)169
USA The emission factor (EF) for dust
emissions from transferring solid powders
is estimated at 5 kg per tonne (0.5%)
This was the default emission factor as
found in a previous USEPA (2006)
model to estimate dust releases from
transferring solid powders, using data
from industries including paint and
varnish formulation, plastic
manufacturing, printing ink formulation,
rubber manufacturing, and chemical
manufacturing
Nova Institute
(2015)170
Germany 0.1 – 1.0% of total plastics production
21000 to 210 000 tonnes/year for
Germany
Estimates of resource efficiency
comparing how much raw material is
needed to make a tonne of manufactured
product
Norway
(2014)171
Norway 0.09% of total plastics production (0.05%
from transport and 0.04% from
processors)
450 tonnes/year for Norway
The transport estimate is based on the
OECD (2009) emission factor for dust
emissions from transferring solid
powders and an assumption that 10% of
this will not be contained by spill control
measures. A Norwegian reprocessor
provided the estimate of 0.04%.
Denmark
(2015)172
Denmark On average, 0.01% of raw material
consumption at plastics facilities.
Maximum 0.0013% of raw material
Estimates were provided by processors
who have joined OCS in a survey
undertaken by the Danish Plastics
Federation. The figures represent the loss
to sewage from within the companies’
169
OECD, ‘Emission Scenario Document On Adhesive Formulation’, 2009
(https://www.oecd.org/officialdocuments/publicdisplaydocumentpdf/?cote=env/jm/mono(2009)3&doclanguage=en)
170
Essel, R. et al., Report for the German Federal Environment Agency ‘Sources of microplastics relevant to marine
protection in Germany’, 2015
(https://www.umweltbundesamt.de/sites/default/files/medien/378/publikationen/texte_64_2015_sources_of_micropl
astics_relevant_to_marine_protection_1.pdf).
171
Sundt, P. et al. Sources of microplastics-pollution to the marine environment, Norwegian Environment Agency
Miljødirektoaret, 2014
172
Lassen et al. Microplastics - Occurrence, effects and sources of releases to the environment in Denmark, The Danish
Environmental Protection Agency, 2015.
158
consumption for processors that have
joined OCS.
Total emissions = 3 to 56 tonnes/year for
Denmark
area (incl. unloading from trucks that
deliver raw materials). The authors
adjust the potential for bias in providing
this information by assuming the average
facility will lose ten times as many
pellets.
Boomerang
Alliance
(2015)173
Australia 1% of domestic production, relating to a
medium scenario of nurdle loss in
domestic production and transport.
10,000 tonnes/year for Australia
The source of this estimate is not given
in the paper – not based on empirical
evidence.
EC/Eunomia
(2016)174
EU 0.04% losses of domestic production from
production, of which 0 – 57% will be
captured in wastewater treatment. 0.05%
losses of domestic production from
transport, of which 10 – 50% will be
captured in some way before they reach
the oceans.
24,000 to 48,450 tonnes/year for Europe.
The data was reported as unreliable /
unrepresentative in the report.
Both pellet loss figures are taken from
the Mepex study. The wastewater
capture is calculated from 63% of EU
population being connected to tertiary
wastewater treatment. In the best case
90% of microplastics are captured in
these facilities and the worst case, no
microplastics are captured. The capture
of losses from transport is an assumption
reflecting the likelihood that pellet spills
that occur during transport – especially
oceanic – will not be captured in a
wastewater treatment system
Eunomia
(2016)175
UK 0.001 – 0.01% loss at each stage (four
stages studied – producers, processors,
storage and transport, offsite waste
management)
105 to 1054 tonnes/year for the UK
Loss rates based on Danish EPA
(Denmark, 2015). The lower bound of
this range assumed that every UK facility
loses no more pellets than the Danish
processors reported that they lost. The
Danish EPA study assumes that the
average facility loses ten times more than
the best performing, but this provided the
highest rate of pellet loss reviewed that
could be used in the study. Instead of
better data, and supported by personal
communication with a Scottish
processor, this estimate was therefore
used for the worst-performing facility,
i.e., the upper bound figure.
Sweden (2016)
176
Sweden Pellet loss is calculated at two points – a
0.04% emission factor is assumed from
plastic pellet production, and a lower and
upper estimate of 0.0005% - 0.01% loss
rate is estimated from pellet handling at
processors. The latter is estimated as net
emission figures (i.e. emissions to the
environment).
The pellet loss from production figures is
taken from the (Norway, 2014) study.
The handling figure is based on
(Denmark, 2015)
173
Boomerang Alliance, Submission to Australian Senate inquiry ‘The threat of marine plastic pollution in Australia’,
2015
(https://assets.nationbuilder.com/boomerangalliance/pages/158/attachments/original/1445317763/Environment_Co
mmunications_marine_plastic_sub77.pdf?1445317763).
174
Eunomia, ‘Report to DG Environment on Study to support the development of measures to combat a range of marine
litter sources’, 2016.
175
Eunomia, ‘Report for Fidra on Study to Quantify Pellet Emissions in the UK’, 2016.
176
Magnusson et al. Swedish sources and pathways for microplastics to the marine environment, Swedish Environmental
Protection Agency, 2016.
159
310-533 tonnes/year for Sweden
IUCN (2017)177
Global Losses are computed at four stages:
production of primary plastics,
manufacturing of plastics, transport on
land (for domestic uses of plastics
products) and water (for interregional
trade of plastics products), as well as
plastic end-of-life. Optimistic
(0.000003%) / central (0.00001) /
pessimistic (0.0001%) of microplastics
losses per stage
Loss rates are wrongly stated to be based
on Fidra 2016. No other basis for the
range of loss rates is provided. Fidra’s
assumption is that in this report there was
a reporting error.
UN
Environment
(2018)178
Global 0,04% losses during production and
processing.
The average value, i.e. 0.005%, (estimate
between 0.0005% and 0.01%.) was used
for estimating losses during loading,
reloading and transportation of the pellets.
30,000 tonnes/year global
The loss rates figures were taken from
Norwegian polystyrene plant where a
loss of 0.4 g/kg was reported (Norway,
2014). This value was used to estimate
losses from the production and
processing of pellets.
The loss of pellets during transport and
handling was calculated based on
(Sweden, 2016) report.
Ryberg et al.
(2019) 179
0,04% losses during Production.
Between 0,001% to 0,01% during
processing.
0,0035% during handling and
transportation.
20,000 tonnes/year global
The study uses four sources to estimate
the losses (Norway, 2014), (Denmark,
2015) (Sweden, 2016) and Eunomia
2016180
Production losses based on (Norway,
2014).
Processing losses based on (Denmark,
2015) and Eunomia 2016
Handling and Transportation losses
based on (Sweden, 2016) and Eunomia
2016
1.5 Chronic losses in reference year
High volumes of pellets are produced and handled every year, both globally and in Europe. There is
a direct relationship between the amount of pellets produced and the amount released in the
environment.
In Europe, in 2019, about 65.3 million tons of pellets (57.9 million tonnes of virgin, 6.5 million tonnes
of recycled, and 0.9 million tonnes of bio-based) were produced in the EU. In the same year, 12.7
million tonnes of pellets were imported to Europe to be converted into final plastic products at a
converting site in the EU, while 14.9 million tonnes of pellets were exported.
177
International Union for Conservation of Nature, ‘Primary Microplastics in the Oceans: A Global Evaluation of
Sources’, 2017 (https://portals.iucn.org/library/sites/library/files/documents/2017-002-En.pdf).
178
Ryberg et al. Mapping of global plastics value chain and plastic losses to the environment, UN Environment, 2018.
179
Ryberg et al. Global environmental losses of plastics across their value chains, Resources, conservation and recycling,
2019 https://doi.org/10.1016/j.resconrec.2019.104459
180
Eunomia, ‘Report for Fidra on Study to Quantify Pellet Emissions in the UK’, 2016.
160
This impact assessment has found that the amount of pellets lost to the environment in the EU
in 2019 can be estimated to be between 52 140 tonnes and 184 290 tonnes (see the table below
for the the value chain), equivalent to 0.08% to 0.28% of total pellet volumes in the EU.
Table 46: Pellets lost (tonnes per year) per sector and per size of the companies
Micro Small Medium Large Total
Production 0 0 0 7222 – 21 665 7222 – 21 665
Waste
management,
including
recycling
0 0 0 1448 – 4345 1448 – 4345
Conversion 611 – 1834 2445 – 7334 5583 – 16 748 6961 – 20 884 15 600 – 46 800
Logistics 2378 – 9513 4529 – 18 116 7109 – 28 436 13 854 – 55 414 27 870 – 111 480
Total 2990 – 11 347 6974 – 25 450 12 692 – 45 185 29 485 – 102 308 52 140 – 184 290
The calculations are explained in Annex 9, on the baseline.
Figure 9 shows the global distribution of pellets losses, as well as the importance of these losses.
Figure 9: Scale of pellet losses at global level181
181
International Pellet Watch, ‘Where can we find the plastic resin pellets?’
(http://pelletwatch.org/where#:~:text=Plastic%20resin%20pellets%20are%20distributed,trash%2C%20wood%2C%
20shell).).
161
2 ADVERSE IMPACTS
Four types of adverse impacts can be observed from pellets finding their way into the environment:
1) on the environment itself; 2) on climate; 3) on human health; 4) and on the economy.
These impacts are described in Annex 7.
3 PROBLEM DRIVERS
There are several market and regulatory failures.
3.1 Market failures
1) Prices do not reflect negative externalities: The activities of economic operators do not
integrate the negative externalities caused by pellets finding their way into the environment,
leading to a suboptimal market outcome. On one side, due to their small size, pellets are easy to
spill; on the other side, it is relatively costly to prevent spills or to clean up after spills as good
handling practices require measures to be taken, such as training of staff. The cost of lost pellets,
incurred by economic operators involved in the production, use and transport of pellets, is not
sufficiently high to motivate a change in behaviour. In addition, once spilled, pellets are
considered contaminated and therefore become waste182
. There are no incentives for economic
operators to integrate the negative externalities caused by pellets finding their way into the
environment.
2) Imperfect information: Economic operators do not have sufficient information to be fully aware
of the pellets which are unintentionally lost from their operations (and of consequential impacts).
This applies notably to the smaller companies present in the pellet supply chain, mostly on the
conversion side. As no systematic monitoring and reporting systems are in place, they are not
aware of quantities released, and because there is no or insufficient awareness raising about the
impacts, they are not aware of the negative externalities. Furthermore, as information on available
preventive and mitigating measures by responsible companies is not sufficiently promoted
throughout the supply chain, they are not aware of possible actions to be taken. Under these
circumstances, it is difficult for economic operators to make sustainable choices when investing
in new equipment, determining their internal procedures and choosing partners along the supply
chain. A lack of specific support for the smallest companies present in the supply chain, especially
on the conversion side, also explains a suboptimal market outcome.
As such, economic operators do not sufficiently integrate concerns about pellet losses in their
operations and no sufficient information about quantities, impacts, actions etc., is routinely sought
or promoted.
3.2 Regulatory failures
Existing EU legislation does not address pellets sufficiently: The absence of specific requirements
to implement best handling practices is arguably the most significant of the problem drivers. While
existing EU regulatory frameworks could be relevant (governing marine litter, water, industrial
emissions, waste, packaging, chemicals and transport activities), they do not specifically address the
issue of pellet losses and their responsible handling to prevent and reduce losses to the environment.
182
Hann, S., Sherrington, C., Jamieson, O., Hickmann, M., Kershaw, P., Bapasola, A., Cole, G. (2018). Investigating
options for reducing releases in the aquatic environment of microplastics emitted by (but not intentionally added in)
products, Eunomia.
162
At the national level, the very large majority of facilities involved in the conversion of pellets or in
logistic operations related to pellets are too small to attract attention and receive routine visits from
environmental regulators as to for instance implementation of waste legislation.
Pellets are very partially covered by the REACH restriction on microplastics intentionally added to
products183
. The restriction proposal does not prevent the placing on the market of pellets but does
foresee lighter measures for so-called ‘derogated’ uses, meaning uses of microplastics at industrial
sites, including plastic pellet sites, where releases can be prevented through risk management
measures. These lighter measures are namely an ‘instructions for use and disposal’ requirement along
the supply chain, and a ‘reporting’ requirement, as outlined in detail in Annex 6. All together, the
reported information on all ‘derogated’ uses would help identify high releases and prioritise them for
further regulatory risk management. However, as they apply to all ‘derogated’ uses, these lighter
measures are generally defined and not specific to each single ‘derogated’ use. Also, they do not help
as such to effectively reduce pellet losses or prevent them (e.g. they are not a requirement on their
handling), and the reporting requirement is not based on a methodology to measure pellet losses (it
was left to the industry to develop a methodology).
The Marine Strategy Framework Directive addresses the monitoring and assessment of the impacts
of microlitter, including microplastics, in coastal and marine environments in a way that they can be
linked to sources184
. Currently, a guidance document is under development in view of a harmonized
method to monitor the presence of plastic pellets along EU coastlines. However, this work does not
include specific requirements concerning the prevention or reduction of pellet losses at source.
The revised Urban Waste Water Treatment Directive (UWWTD)185
proposes to measure
microplastics in the inlets and outlets of the urban WWT plants (including in the sludge) for
agglomerations. The measures proposed in the UWWTD are only end-of-pipe solutions and no
specific requirements concerning the prevention or reduction of pellet losses at the source are
foreseen.
The Sewage Sludge Directive (SSD)186
does not address microplastics. During its evaluation, the
concept of source control i.e. targeting substances such as microplastics and micropollutants at
source, was widely supported by stakeholders in order to improve circularity in the wastewater
treatment sector. Indeed, for the sludge and/or water is to be reused, stakeholders highlighted that
there is a need for tracking and preventing pollution at source.
The recast of the Drinking Water Directive (DWD), the update of the Groundwater Directive (GWD)
and the Environmental Quality Standards Directive (EQSD) all include provisions related to
microplastics monitoring at the end-of-life stage only.
183
Commission Regulation (EU) …/… amending Annex XVII to Regulation (EC) No 1907/2006 concerning the
Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) as regards synthetic polymer
microparticles.
184
EUR-Lex - 32017D0848 - EN - EUR-Lex (europa.eu) “…micro-litter shall be monitored in the surface layer of the
water column and in the seabed sediment and may additionally be monitored on the coastline. Micro-litter shall be
monitored in a manner that can be related to point-sources for inputs (such as harbours, marinas, waste-water treatment
plants, storm-water effluents), where feasible.”
185
Council Directive of 21 May 1991 concerning urban waste water treatment (91/271/EEC) (https://eur-
lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A01991L0271-20140101).
186
Council Directive of 12 June 1986 on the protection of the environment, and in particular of the soil, when sewage
sludge is used in agriculture (86/278/EEC) (https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A01986L0278-20220101).
163
The Industrial Emissions Directive (IED)187
aims to prevent and control pollution arising from
industrial activities in large industrial installations, and is only partially suited to address pellet losses
as a form of pollution occurring along the entire supply chain. While activities like the production of
polymeric materials, such as pellets, on an industrial scale fall under the scope of the IED, other
activities like the conversion, transport or storage of pellets, usually operated by small and medium
enterprises, are not covered. In addition, the BAT Reference Document (BREF) for the production
of polymers was adopted in 2007 and does not address the specific issue of pellet losses.
Waste legislation such as the Waste Framework Directive (WFD)188
and Packaging and Packaging
Waste Directive189
does not specifically address the pellet loss issue as they do not regulate emissions
during the production of products or packaging. The WFD imposes Member States a generic
obligation to take waste preventive measures addressing the industrial generation of waste as pellets
can be. The Commission could adopt guidelines to assist Member States in preparing their
programmes and preventive measures based on the WFD. Nevertheless, the implementation of these
guidelines by Member States is voluntary thus not ensuring the harmonised implementation of
preventive measures throughout the EU and the level playing field among economic operators.
4 OBJECTIVE
4.1 General objectives
The general objective of this initiative is to contribute to the reduction of microplastic-related
pollution by preventing and reducing pellet losses to the environment that are due to current handling
pellet practices at all stages of the supply chain within the EU, thus reducing the adverse
environmental, economic and (potential) human health consequences of pellet pollution..
4.2 Specific objectives
Accordingly, the above general objective translates into three specific objectives:
• To reduce and prevent pellet losses in an economically proportionate manner to a level
consistent with the Commission’s 2030 target of a 30% reduction in both intentional and
unintentional microplastic releases (compared to 2016 levels);
• To improve information on the magnitude of pellet losses throughout the pellet supply chain,
in particular the accuracy of loss estimates, and to raise awareness among relevant actors; and
• To ensure the appropriate mitigation of impacts on SMEs involved in the pellet supply chain.
187
Directive 2010/75/EU of the European Parliament and of the Council of 24 November 2010 on industrial emissions
(integrated pollution prevention and control) (Recast) (annexe 6
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02010L0075-20110106).
188
Directive 2008/98/EC of the European Parliament and of the Council of 19 November 2008 on waste and repealing
certain Directives (https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A02008L0098-20180705).
189
European Parliament and Council Directive 94/62/EC of 20 December 1994 on packaging and packaging waste
(https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A01994L0062-20180704).
164
Annex 9:
Baseline
To develop the baseline for pellet losses to the environment, the following methodology was used
due to a lack of pre-existing harmonised methodology, along with significant knowledge gaps in data
and reporting.
1 THE PELLET SUPPLY CHAIN
In the pellet supply chain, pellet losses can occur at different steps of production, processing, and
logistical activities. It is important to distinguish between the three types of chains detailed below to
consider which activities are relevant. However, the magnitude of pellet losses will depend on the
number of intermediate steps and on pellet handling practices at different facilities.
• For pellets produced and processed in the EU, pellet losses could occur during all three
activities.
• For pellets produced in the EU and exported, pellet losses could occur at the pellet
production facilities and during the logistics for export.
• For pellets imported into the EU and processed in the EU, there could be losses during
import logistics and losses during processing.
The pellets supply chain is mainly grouped into three main categories: production, processing and
logistics. Each step contains several steps where pellets losses can occur (see Annex 8). There is
however hardly any info on the pellet spills and losses at each step. Therefore a different method
needs to be used to estimate pellet losses to the environment.
For production, one also needs to distinguish between virgin pellet production and pellets produced
through plastic recycling (pre-consumer and post-consumer), as recycling plants also include small
facilities and have therefore higher risks of pellet losses.
The data sources and assumptions used to estimate the total quantity of pellets production are the
following:
• 2019 is taken as the baseline year, as 2020 is an outlier because of COVID, and we are seeing
positive growth trends again from 2021;
• For virgin pellets, the projections are made from 2019 figures190
; a growth rate of 0.9% per
year is assumed till 2030191
;
• The source for recycled pellets production data (2019-2021) is Plastic Recyclers Europe; a
growth rate of 5.6% per year is assumed192
;
190
Plastics Europe changed the calculation method in 2021, excluding adhesives, paints and coatings, thus not used to
be coherent with previous year estimates and also with import/export figures
191
Plastics Europe and SystemIQ
192
K 2022 - Trend Report Europe https://www.k-online.com/en/Media_News/Press/Technical_article/K_2022_-
_Trend_Report_Europe
165
• The source for bio-based pellets production data (2019-2021) is Plastics Europe; for a growth
rate CAGR of 14% for 2022-2027193
, and the same trend is assumed to continue till 2030;
• Pellets imports and exports figures for virgin pellets are from Eurostat; a growth rate of 0.9%
is assumed till 2030.
Using these assumptions, the total pellet production is expected to reach about 79 million tonnes in
2030. If we take into account imports and exports, the net volume of pellets used in the EU would be
around 76 million tonnes in 2030. The total figures estimated here are within 1% range compared to
the estimates made by the recent OECD scenario194
that used a modelling approach (see Figure 10).
Figure 10: Pellet production volumes in EU-27 and projections until 2030
2 HOW WILL PELLET LOSSES EVOLVE IN 2030?
To define the projected development of total pellet losses in 2030, consideration was given to the
following: 1) Existing and forthcoming EU legislation; 2) National and international initiatives; 3)
Industry initiatives. These pieces of legislation and initiatives are presented below.
2.1 Existing and forthcoming EU legislation
The existing and forthcoming EU legislation with relevance for pellet losses is described in detail in
Annex 6. This legislation includes the REACH restriction on unintentionally added microplastics,
the Marine Strategy Framework Directive, several pieces of water-related legislation, the Industrial
Emissions Directive and the Waste Framework Directive. Globally this legislation is not explicitly
considered in the baseline as (1) the analysis was done at the same time and it was not clear which
measures would be proposed, or more importantly (2) the measures applying or under consideration
193
Nova Institute (2023) Bio-based Building Blocks and Polymers Global Capacities, Production and Trends 2022–2027
https://renewable-carbon.eu/publications/product/bio-based-building-blocks-and-polymers-global-capacities-
production-and-trends-2022-2027-short-version-pdf/
194
OECD (2022) Global Plastics Outlook: Policy Scenarios to 2060. https://www.oecd.org/publications/global-plastics-
outlook-aa1edf33-en.htm
166
are limited in scope and impact, or generic (mainly reporting, monitoring or provisions for larger
plants only).
2.2 National and international initiatives
A few Member States have already started to introduce measures to tackle pellet losses. These
measures are summarised in Table 47 and presented in detail in Annex 6.
Table 47: Member State actions targeting pellet losses
Country Actions
Austria • Law adopted addressing “filterable substances” to which pellets belong
Belgium
(Flanders)
• Introducing environmental permit system / Best Available Techniques
• Examining an environmental management system with possible certification
Denmark • Monitoring
• Waiting for OCS certification scheme implementation and Commission’s proposal
France • Law adopted providing minimum obligations to prevent pellet losses for all actors in
the supply chain along with mandatory external auditing
The
Netherlands
• Monitoring
• Waiting for OCS certification scheme implementation
Spain • Promoting OCS certification scheme implementation
Sweden • Revising current guidelines to make them more comprehensive and include more actors
across the supply chain
France is the only Member State to have adopted legislation specifically targeting pellet losses. This
legislation covers businesses making and handling pellets in quantities higher than 5 tonnes including
logistic platforms but not transporters. The threshold has been reduced from what initially proposed
i.e. 10 tonnes following public consultation. Businesses are subject to equipment and procedural
obligations to prevent the loss and leakage of pellets, and are required to be regularly audited by
independent and accredited certification bodies195
. Obligations remain of a relatively generic nature.
For instance, a business must identify areas where pellets are more likely to spill, check that the
packaging used is designed to minimise the risk of spills and train and raise awareness among staff.
As a unique transparency measure, the company must make the summary of the auditing report
available on its website. The Decree entered into force on January 1, 2022 for new sites, while for
existing sites, it will enter into force in 2023, at the same time as equipment obligations.
In 2021, the British Standards Institution published the Publicly Available Specification PAS
510:2021196
, for use by organisations of any size across the pellet handling supply chain. It builds on
the industry-led Operation Clean Sweep® (OCS) programme (see Annex 6) by creating a
195
Décret no 2021-461 du 16 avril 2021 relatif à la prévention des pertes de granulés de plastiques industriels dans
l’environnement [Decree n. 2021-461 of 16 April 2021 related to the prevention of the leakage of industrial plastic
pellets into the environment], Journal official “Lois et Décrets” no. 0092 du 18 avril 2021 [JORF] [Official journal
“Laws and Decrees” no. 0092 of 18 April 2021], 18 April 2021, Fr.
196
BSI Knowledge, ‘Plastic pellets, flakes and powders. Handling and management throughout the supply chain to
prevent their leakage to the environment. Specification - PAS 510:2021101’, 2021
(https://knowledge.bsigroup.com/products/plastic-pellets-flakes-and-powders-handling-and-management-
throughout-the-supply-chain-to-prevent-their-leakage-to-the-environment-specification?version=standard).
167
standardised and consistent approach to risk management and containment of pellets197
. The PAS
might be considered for further development as a British standard or constitute part of the UK input
into the development of a European or International standard on pellets.
In 2021, the parties to the Convention for the Protection of the Marine Environment of the North-
East Atlantic (OSPAR) adopted the non-binding Recommendation 2021/06198
to reduce the loss of
plastic pellets in the marine environment by promoting the timely development and implementation
of effective and consistent pellet loss prevention standards and certification schemes for the entire
plastic supply chain. The Recommendation was accompanied by supporting guidelines which set out
essential requirements for standards and certification schemes. The first full implementation report
is due in January 2025, with an interim report due in 2024. A preliminary interim report was
informally shared by OSPAR in February and the actions reported by the Member States that are
parties to the OSPAR Convention are presented in the above Table 47.
In the International Maritime Organization (IMO), a Correspondence Group on Marine Plastic Litter
from Ships looked at measures that could be relevant in reducing the environmental risk associated
with the maritime transport of plastic pellets. While three primary measures including packaging
were identified as particularly relevant to reduce the environmental risks associated with the maritime
transport of plastic pellets (and a voluntary circular to this effect was drafted), the Group was not in
a position to conclude on the most appropriate instrument for mandatory measures199
. The Group
noted that experience gained from the implementation of voluntary measures could be useful in the
further consideration of the most appropriate instrument for mandatory measures.
A similar international initiative is ongoing on containers lost at sea, and discussions are held on the
possibility of making the information on containers lost at sea available publicly (to date, such
information is reported only to insurance companies). If retained, this measure would allow for a
better understanding of the scale and magnitude of pellets lost at sea and would facilitate liability
identification and compensation arrangements in line with the polluter pays principle.
2.3 Industry initiatives
Since 2015, the European plastic manufacturing industry has progressively adopted the Operation
Clean Sweep® (OCS) programme200
as a voluntary pledge to work towards zero plastic pellet losses.
This programme is presented in detail in Annex 6.
197
The PAS provides requirements in the following areas: a) Organizational responsibilities; b) Leadership and
commitment; c) Competence, training and awareness; d) Risk assessment of pellet loss to the environment; e)
Operational controls, i.e. prevention, containment and clean-up, procurement and suppliers; f) Internal and external
communication; g) Performance evaluation, i.e. monitoring and documentation, auditing and verification of
conformity; h) Improvement, i.e. internal and external non-conformity and corrective action, and continual
improvement.
198
www.ospar.org/convention/strategy
199
The three primary measures identified as relevant are: Packaging provisions for plastic pellets carried at sea;
Provisions for notifying the carrier so that containers containing plastic pellets can be identified; Stowage provisions
for freight containers containing plastic pellets. Among the options for mandatory measures, the Group considered
the three following options/instruments: Assignment of an individual UN Number (class 9) for plastic pellets
transported at sea in freight containers (UN Number); Amendment to Appendix I of MARPOL Annex III that would
recognize plastic pellets as a “harmful substance” (Harmful substance); A new chapter to MARPOL Annex III that
would prescribe requirements for the transport of plastic pellets in freight containers without classifying the cargo as
a harmful substance/dangerous goods.
200
www.opcleansweep.eu
168
While best practices are generally well understood, they have not been comprehensively
implemented. As of April 2023, 2548 companies have committed to OCS201
. This figure includes all
PlasticsEurope’s members (these are producers; adherence to OCS is mandatory for the members of
this association). Only 2% of EuPC’s members (converters) have committed to OCS (around 1 000
converters out of 48 000); and only some 500 transport companies. As no precise reporting has been
made available within OCS, it is not possible to say whether those who have committed have also
effectively or fully implemented the programme, with evidence showing the opposite. Both acute and
chronic pellet incidents have been reported to continue over the last years, including at sites that are
OCS signatories202
.
The recent launch of the OCS Certification Scheme (OCS CS) aims to address these issues.
Recognising the low uptake of OCS by the industry, in 2019, European plastic manufacturers
(PlasticsEurope) and converters (EuPC) announced plans to develop a voluntary certification scheme
building on OCS and including requirements, third-party, independent auditing, certification and
some level of transparency (all aspects not foreseen under the current OCS programme). In January
2023, the new scheme was officially launched by its promoters. It is presented in detail in Annex 6.
While going in the right direction, the new scheme constitutes only a partial attempt by the industry
to adopt a genuine supply chain approach and pursue the zero pellet pollution objective effectively.
First of all, while the requirements are in principle applicable to all companies handling pellets, and
all companies can get audited and certified, when fully in place, the new scheme will be required
only for producers (adherence to the existing OCS programme is already mandatory for the members
of PlasticsEurope since 2019203
). Not all producers are members of PlasticsEurope. Thus, the new
scheme will not be binding for key players in the pellet supply chain, such as converters, transporters,
warehousing operators and recyclers.
EuPC, representing converters, found it difficult to make adherence to the new scheme mandatory
for their members (to date, adherence of converters to the existing OCS programme is very low). As
explained in Annex 8, members of EuPC are European and national associations representing close
to 50,000 individual companies, out of which 66% are micro-companies. It is estimated that the
certification process is relatively short for producers, (PlasticsEurope expect all their members to be
certified by the end of 2024, some producers reporting however a longer period before certifying all
their sites), while the process is set to be much longer for converters.
Transporters, warehousing operators and clean tankers are observers of the new OCS certification
scheme and will be assessed (not certified) under the chemical industry’s Safety and Quality
Assessment for Sustainability (SQAS) system, which has contained requirements to tackle pellet
losses starting since March 2023204
. Full alignment between the new OCS certification scheme and
the SQAS system is still pending. In particular, there are no plans currently to force OCS-certified
201
www.opcleansweep.eu
202
Regarding chronic pellet losses in the Netherlands, Belgium and Spain, see
https://www.plasticsoupfoundation.org/wp-content/uploads/2022/03/Westerschelde-plastic-nurdles-versie-
definitief-21-11-2021-2.pdf; https://surfrider.eu/en/learn/news/ecaussinnes-belgium-surfrider-foundation-tackles-
industrial-plastic-granules-1211028228325.html; https://goodkarmaprojects.org/2020/11/20/new-report-out-
exposes-alarming-impacts-of-plastic-pellets-across-europe/?lang=en.
203
OCS becomes an intrinsic part of PlasticsEurope’s DNA - Operation Clean SweepOperation Clean Sweep
(opcleansweep.eu)
204
A first addition to the SQAS assessment questionnaire was made in January 2022. The current version of the
questionnaire is available here
https://www.sqas.org/downloads/ts2022/SQAS%202022%20TS%20Questionnaire%20and%20Guidelines%20Rev
%202%20(English).docx
169
companies to work exclusively with SQAS-assessed transport companies. To date, there are
approximately 3000 transport companies which are SQAS-assessed and even more transport
companies which are non SQAS-assessed. According to the sector, SQAS-assessed transport
companies cover 80% of the total pellet transport of virgin pellet producers in Europe. Clean tankers
are mostly SQAS assessed, while among warehousing operators only a part is SQAS assessed.
To test the new scheme, nine pilot audits covering producers, converters and transporters were held
in 2021 in five countries: Belgium, Netherlands, Portugal, Spain and France. The bodies that
conducted these audits were well-known bodies like Aenor, Bureau Veritas, SGS, etc. All audited
companies failed to pass. The strongest point observed by auditors was a good involvement of
management, while the weakest one was related to the objective of encouraging partners to pursue
the same objectives.
At the end of 2021, FFI decided to resign from the Supervisory Board of the new OCS certification
scheme arguing that it did not fully align with the guidelines of the OSPAR Recommendation
2021/06, and citing issues with the governance of the scheme, the level of transparency, the lack of
a formal standard from a recognised standardisation body, the fact that the whole supply chain is not
captured adequately, and the lack of timelines for compliance. FFI called instead for the introduction
of effective legislation applicable to all pellet handling companies and based on a supply chain
approach to eliminate this source of pollution fully205
.
Recyclers are neither promoters nor observers of the new scheme and have their own certification
scheme in place (RecyClass), which has a section on pellet losses requiring the implementation of a
procedure to prevent leakage within the premises and surrounding of the recycling plant, and ensure
the training of staff. To go a step further, recyclers are conducting a study on potential areas in the
recycling process where microplastics could be generated and released, and on preventive measures.
The recommendations of this study will be used to complete the RecyClass certification scheme’s
pellet loss/microplastics requirements.
2.4 The baseline
All in all, the above national and international initiatives are expected to contribute to very limited
reduction in pellet losses by 2030. France is the only country to have adopted specific national
legislation to prevent pellet losses via legal obligations. The relevant provisions are relatively generic
and do not cover transporters. However, the baseline considers an estimated reduction from it. The
other national initiatives are non-legislative and limited in scope (e.g. research and monitoring
activities). Both the BSI PAS and the OSPAR Recommendation provide for a non-binding
comprehensive set of measures to be taken and are reference documents in the field. However, in
both cases, it is up to the companies or parties to implement such measures, and it was not possible,
at the moment of the impact assessment, to evaluate their precise implementation. The IMO work on
pellets focuses on one aspect only i.e. shipping of pellets, and has resulted so far in voluntary
measures only, with very limited effects up to date.
205
FFI call for the introduction of effective legislation that will require all pellet (flake and powder) handling companies
across the whole supply chain to provide independent verification that pellet loss prevention measures have been
implemented, maintained and monitored for effectiveness towards the goal of zero pellet loss to the environment,
prior to materials being placed on the market. They also call for tighter restrictions on the packaging and labelling of
pellets being prepared for transport to reduce the risk of loss and improve communication. Finally, EU legislation
should complement international maritime legislation for pellets currently being considered by IMO to reduce the
risk of catastrophic pellet pollution at sea.
170
Once fully in place, the new industry-led OCS certification scheme is expected to contribute to some
reduction in pellet losses by 2030. It is difficult to assess the take-up of the new scheme by the
industry, and therefore its effectiveness. This counts equally for similar schemes by the recyclers or
logistics companies (RecyClass and SQAS).
For the baseline, it has been assumed that by 2030:
1. 90% of the total virgin pellet volume produced (by the members of PlasticsEurope) and 5%
for the non-PlasticsEurope members, will be certified compliant against OCS new rules and
will be effectively implementing such rules with a success rate ranging from 60% to 80%;
2. 20% of the total recycled pellet volume will be certified compliant against RecyClass pellet
provisions and will be effectively implementing the new provisions with a success rate
ranging from 40% to 60%;
3. 30% of the total volume processed will be certified compliant against OCS new rules and will
be effectively implementing such rules with a success rate ranging from 40% to 60%;
4. 40% of the total volume handled by logistics companies will be SQAS assessed and will be
effectively implementing such a scheme with a success rate ranging from 40% to 60%; and
5. The French legislation will cover about 85% of the French pellet volume (about 10% of the
EU volume), leading to a 60-80% pellet loss reduction in 2030.
Based on the pellet loss calculations taking into account industry efforts (OCS new rules, RecyClass
and SQAS) and Member State legislation (France), in 2030, there will still be pellet losses in the
range of 42 050 – 170 266 tonnes per year.
Table 48: Emissions in 2030 (in tonnes) considering the impact of ongoing/upcoming initiatives
Low emission scenario High emission scenario
Without considering
ongoing initiatives
62 178 219 355
OCS reduction potential:
• Producers 4 130 - 5 507 12 390 - 16 521
• Recyclers 197 - 296 592 – 889
• Processors 2 005 - 3 007 6 015 - 9 022
• Logistics 4 726 - 7 089 18 905 - 28 357
French legislation 3 171 - 4 228 11 187 - 14 916
Pellet losses in 2030 in the
baseline scenario
42 050 - 47 948 149 651 - 170 266
171
Annex 10:
Policy options to reduce pellet losses
1 METHODOLOGY TO IDENTIFY MEASURES
Measures, i.e. specific technological and behavioural standards/changes affecting pellet losses, were
identified from collected evidence (literature review) and stakeholder consultation (OPC, targeted
interviews and workshops, targeted SME survey).
Overall, 173 ideas were identified during desk research and in the stakeholder workshops conducted
in November 2021 and December 2022. After eliminating the duplicates, the long list of measures
was as follows:
• Development of measurement standards for pellets;
• Voluntary Commitment to industry-led OCS certification scheme;
• Reduction target: devise a reduction target for pellet losses considering the current situation;
• Development of a universal information leaflet and labelling for packaging of plastic pellets
for their transport;
• Training obligations (with regular updates) for all actors in the plastic pellet value chain;
• Ensure that all containers used for transport and storage are environmentally sealed, airtight
and puncture resistant to prevent damage and tears;
• Classify pellets as harmful in the International Maritime Law (MARPOL Annexes III and V
and inclusion of pellets in the International Maritime Dangerous Goods (IMDG) Code as
hazardous or dangerous substances). Slots below deck or in more protected areas would be
used to reduce the risk of container loss at sea;
• Mandatory reporting system for containers lost at sea in international waters. (Not just to
insurance companies);
• Address/sanction big pellet losses under the EU Environmental Crime Directive;
• Support for SMEs, including financial incentives;
• Extended producer responsibility system for pellets / Set up an environmental damage
remediation fund, financed by industry;
• Obligation for all supply chain players to prevent pellet losses through measures embedded
in EU law;
• All installations, producing, converting, handling, transporting etc., can only operate having
an environmental permit issued by a competent authority, by using the EU Industrial
Emissions Directive;
• Independent verification of best practices using well-designed standards and certification
schemes as promoted by the Commission of the regional convention for the protection of the
172
Marine Environment of the North-East Atlantic (OSPAR)206
;
• Prohibition on discharges (zero tolerance threshold similar to Formosa Plastic Consent
Decree).
2 SCREENING OF MEASURES
The identified measures were screened using the criteria defined in the Better Regulation Tool #16.
From the outset, the option of developing standardised methods to measure pellet losses was retained
(Option 1).
Voluntary commitments like the one under the industry-driven OCS and OCS certification scheme
were considered as suitable options to address the identified problem driver ‘Market failure (prices
do not reflect negative externalities)’. In particular, the new industry-led OCS certification scheme
was first retained as an option, then, discarded as the new scheme has in the meantime been launched
by its promoters. Therefore, this impact assessment considers such commitment as part of the
baseline.
The option of developing voluntary verification of best practices using well-designed standards and
certification schemes is ongoing under the work of the Commission of the regional convention for
the protection of the Marine Environment of the North-East Atlantic (OSPAR) and in the framework
of the above mentioned industry efforts. Therefore, this impact assessment considers such
development as part of the baseline. Also, certification is an essential part of Option 2.
Information/awareness raising on the handling of pellets throughout the pellet supply chain, and the
development of a universal information leaflet and labelling for packaging of plastic pellets for their
transport, were considered as suitable options to address the identified problem driver ‘Market failure
in the shape of imperfect information’. However, this impact assessment considers that this would be
better taken up by the mandatory requirements in Option 2.
Training obligations (with regular updates) for all actors in the pellet supply chain were also
considered as a suitable option, however, again, this impact assessment considers that this would be
better taken up by the mandatory requirements in Option 2. Indeed, training is an essential part of
this option.
The possibility of using the Industrial Emissions Directive to address pellet losses at relevant
installations was discarded on the ground of effectiveness, efficiency and relevance. The IED is not
suited to address pellet losses as a form of pollution occurring along the entire supply chain. While
activities like the production of polymeric materials on an industrial scale fall under the scope of the
IED, other activities like the conversion, transport or storage of pellets, usually operated by small and
medium enterprises, are not covered. The permits are primarily designed for large installations with
multiple environmental issues. Moreover, the BAT Reference Document (BREF) for the production
of polymers was adopted in 2007 and does not address the specific issue of pellet losses.
206
https://www.ospar.org/convention/text
173
The possibility of using the Environmental Crime Directive207
to sanction all pellet losses was
discarded on the ground of the limited scope of this legal instrument due to its nature (criminal law)
and therefore not adequate to address all types of unintentional losses.
Supporting SMEs, including via financial incentives, is integrated in option 2 as a way to mitigate
the regulatory burden on SMEs.
The possibility of setting extended producer responsibility schemes and environmental damage
remediation funds, financed by industry, were discarded on the ground of technical feasibility and
relevance. EPR targets a product, while for pellets, we have different types of “producers”, those who
manufacture the pellets, those who transform them into a product etc. Also, EPR aims to tackle the
end-of-life, i.e. when the product becomes waste, while for pellets, it is a diffused pollution issue
along the entire supply chain.
Classifying pellets as a “harmful substance” in the International Maritime Law was seen by some
stakeholders as a positive measure to reduce the environmental risk associated with the maritime
transport of pellets. However, an initiative on this precise issue is currently ongoing in the
International Maritime Organization with the support of the European Union. At the same time, the
Ship Source Pollution Directive is under revision, and one of the options could be to extend the scope
of this Directive to MARPOL Annex III, where pellets could be classified as “harmful substance”.
Therefore, while addressing the maritime transport of pellets by means of more stringent packaging
or stowing provisions may help reduce pellet losses at sea, this impact assessment considers such
initiatives as part of the baseline. The same applies to developing a mandatory reporting system for
containers lost at sea in international waters (initiative ongoing). On these acute pellet incidents,
while losses of pellets coming from containers lost at sea are very visible and impactful on the shores
affected, these losses are estimated not to represent the biggest losses in quantities.
The table below summarises the measures that have been screened out from the evaluation as well as
the reasons for their exclusion.
Table 49: Discarded measures
Problem Area Measure Title Reason for screening out
Market failure/
Information/knowledge
failure
Support for SMEs,
including financial
incentives
This measure is integrated in option 2 as a way to mitigate
the regulatory burden on SMEs.
Market failure /
Information failure
Development of a
universal information
leaflet and labelling for
packaging of plastic
pellets for their transport
The information on good practices exists, but is not well
enough implemented. However, this impact assessment
considers that this would be better taken up by the
mandatory requirements in option 2.
Market failure /
Information failure
Training obligations (with
regular updates) for all
actors from the plastic
pellet value chain
Such obligations would help, but this impact assessment
considers that this would be better taken up by the
mandatory requirements in option 2.
207
Directive 2008/99/EC of the European Parliament and of the Council of 19 November 2008 on the protection of the
environment through criminal law.
174
Market/Regulatory
failure
Extended producer
responsibility (EPR) / Set
up an environmental
damage remediation fund,
financed by industry
This measure is discarded on the ground of technical
feasibility and relevance. EPR targets a product, while for
pellets, we have different types of “producers”, those who
manufacture the pellets, those who transform them into a
product etc. Also, EPR aims to tackle the end-of-life, i.e.
when the product becomes waste, while for pellets, it is a
diffused pollution issue along the entire supply chain.
Regulatory Failure Independent verification
of best practices using
well-designed standards
and certification schemes
as promoted by OSPAR.
The verification of the best practices could be ensured by
the industry-led OCS CS; this impact assessment considers
this as a part of the baseline.
Regulatory failure Prohibition on discharges
(zero tolerance threshold
similar to Formosa Plastic
Consent Decree)
This relates to intentional illegal discharges. This is not a
relevant measure, as pellet loss is an “unintentional”
release.
Regulatory failure All installations,
producing, converting,
handling, transporting
etc., can only operate
having an environmental
permit issued by a
competent authority.
This measure is discarded on the grounds of effectiveness,
efficiency and relevance. The production phase of polymers
is already covered by the Industrial Emissions Directive
(IED) but the concerned BREF was adopted in 2007 and
does not address the specific issue of pellet losses. In
addition, The IED is not suited to address pellet losses as a
form of pollution occurring along the entire supply chain.
Regulatory failure Sanction big pellet losses
under the EU
Environmental Crime
Directive
This measure is discarded on the ground of legal feasibility.
While it may be relevant to sanction big losses of plastic
pellets (causing serious pollution and environmental
impacts), currently, there are no legal obligations in place
or deriving from EU law regarding plastic pellets. Therefore
it is not possible to identify any breach of legislation. The
sanction for duty-holders on the ground would become
possible once such obligations are in place.
Regulatory failure Classifying pellets as a
“harmful substance” in
the International Maritime
Law
An initiative on this precise issue is currently already
ongoing in the International Maritime Organization with the
support of the European Union.
Regulatory failure Developing a mandatory
reporting system for
containers lost at sea in
international waters
Ongoing initiative with the support of the European Union.f
3 FINAL LIST OF MEASURES / OPTIONS
Four options for action were identified.
Option 1: Mandatory standardised methodology to measure pellet losses
Under this option, the Commission initiates the development of a standardised method to measure
pellet losses from the range of relevant pellet-related industrial activities (i.e. production, conversion,
175
recycling, transport and other logistic operations), to be used for the reporting on estimates of
quantities released on an annual basis, as obliged under the REACH restriction. The new standard
will improve the quality of the reporting on the quantities released (one methodology for all instead
of several, different ones) improving the information on the magnitude of pellet losses throughout
the pellet supply chain, while also raising awareness among relevant actors as they can measure pellet
spills and losses and assess their evolution over time.
Currently, there is no standardised methodology to measure pellet losses. It is expected that under
REACH, there will be a reporting requirement on estimates of quantities released on an annual basis
for pellet manufacturers and downstream users208
, but not a methodology. This option would be
developed via the European Standards Organisation (CEN), which typically takes 3-4 years to
complete. The umbrella association of European converters (EuPC) is developing for the OCS
certification scheme signatories a methodology for measuring such losses, named the Bow-tie model,
and this work can serve as the basis of the harmonised methodology. This model focuses on a risk
analysis to identify, at first, the most probable sources of pellets leakages that should be solved in
priority. Once the risk areas have been defined, the model proposes several ways to quantify the
losses based on the available information (e.g. amount of pellets sent to waste) or on amounts of
pellets collected in existing prevention (trays, buckets etc.) and mitigation (vacuum cleaners, filters,
etc.) barriers.
This option addresses the problem drivers of market (imperfect information) and regulatory failures.
Option 2: Mandatory requirements to prevent and reduce pellet losses in a new EU law
Under this option, mandatory requirements are defined and imposed on the entire pellet supply chain
thus maximising the opportunities of preventing and reducing pellet losses. The requirements to
comply with at the site level are based on those already identified by stakeholders in the framework
of the BSI PAS and OSPAR recommendation and the industry-led OCS certification scheme. Firms
will need to provide evidence of the following:
1. The creation and publication of internal procedures such as defining organisational
responsibilities, a pellet loss prevention policy with pellet loss prevention objectives, a regular
risk mapping exercise and corresponding risk management assessment at site level;
2. Competence, training and awareness of staff to prevent, contain and clean up spills including
maintaining a record of spills;
3. Operational controls including preventive, mitigating and clean up measures and equipment;
4. Communication of implemented policies, measures and objectives both within the
organisation and externally, as well as of improvement as reaction to non-conformity.
A risk mapping exercise needs to be performed to identify the leakage potential of all necessary,
handling steps in all high-risk areas and pathways to the external environment. According to industry,
208
In REACH, ‘downstream users’ are defined as “any natural or legal person established within the Community, other
than the manufacturer or the importer, who uses a substance, either on its own or in a mixture, in the course of his
industrial or professional activities. A distributor or a consumer is not a downstream user. A re-importer exempted
pursuant to Article 2(7)(c) shall be regarded as a downstream user”. Concretely, pellet converters, recyclers as well
as storing operators who own the pellets would be considered as downstream users under REACH. Transporters are
not all downstream users but emissions during transport would also need to be reported by the relevant downstream
user. Instead, would not be covered by the reporting obligation: importers, distributors, storing operators who store
the pellets for third parties, retailers and consumers. A transitional period of 24 months is set for the entry into force
of the reporting requirement.
176
special attention should be given to the following areas where there is a high likelihood of loss to the
environment: nearby sewers and drains that do not have any pellet collection facilities or that are not
connected to the facility’s WWTP; in areas with high traffic (e.g. near gates); in areas close to the
fence line; nearby gravelled or non-paved areas; in areas where pellets being spilled or lost may be
picked up by the wind or water (rain and storm water) and transported outside209
. Once this is done,
there needs to be a risk management assessment performed to determine where actions are required
for equipment, best practice handling, mitigation and remediation.
Knowing that the first step should be to avoid all unnecessary handling of pellets, preventive barriers
include “Avoidance of Unnecessary Handling” (as the possibility of minimising the number of
transfer points in the supply chain is the starting point for reducing spill opportunities) and “Best
Practice Handling”. The latter can take the form of collection and retention trays. Mitigation and
clean-up measures can take the form of filters, vacuum systems to remove accumulated pellets, and
tools for immediate cleaning (shovel, broom, brush, vacuum cleaner).
This is also the option of mandatory external auditing and certification. To demonstrate compliance
with the defined mandatory requirements, all pellet handling companies including logistic platforms
and transporters must be externally audited and certified at the site level by independent certifying
bodies selected among accredited organisms, in order to operate. This implementation approach is
consistent with the non-binding OSPAR Recommendation, adopted by OSPAR contracting parties
including the EU and 11 Member States, which promotes certification schemes for the entire supply
chain. It is also fully in line with the polluter pays principle as the cost of the audits would be borne
by the industry itself, and it allows for a harmonised implementation across the EU as a whole,
ensuring a level playing field among operators. Certification obligations will be imposed in a phased
manner. Once externally audited, companies must notify the public authority about the outcome of
the external audit. In the case of non-compliance, they are also responsible for imposing corrective
measures and, where relevant, penalties.
This option does not include reduction targets and it is assumed that over a period of time the
certification process will deliver results. Once the measure under Option 1 is in place, the reduction
targets could possibly be defined. The measure under Option 1 would enable measuring its possible
success rate.
There will be a 5 tonnes/year threshold for the requirements (as done in the existing French
legislation210
- this limit was decided as a consequence of a public consultation in France). It avoids
requiring costly investments with very limited environmental benefits in terms of pellet loss
reduction.
This option addresses the problem drivers of market and regulatory failures.
Option 3: Improved packaging for pellet logistics
This option aims to ensure that all bags and containers used for pellet logistics (transport, storage
etc.) are environmentally sealed, airtight and puncture-resistant to prevent damage and tears, which
could lead to pellet losses. The option imposes the use of specific types of bags and containers for
209
SQAS
210
Décret no 2021-461 du 16 avril 2021 relatif à la prévention des pertes de granulés de plastiques industriels dans
l’environnement [Decree n. 2021-461 of 16 April 2021 related to the prevention of the leakage of industrial plastic
pellets into the environment], Journal official “Lois et Décrets” no. 0092 du 18 avril 2021 [JORF] [Official journal
“Laws and Decrees” no. 0092 of 18 April 2021], 18 April 2021, Fr.
177
pellet handling, transport and storage. It can be set up as an independent legislation or can be
implemented as part of the legal proposal in Option 2.
This option addresses the problem drivers of market and regulatory failures.
Option 4: EU target to reduce pellet losses
This option is to establish an EU reduction target in line with the Commission’s overall microplastic
releases reduction target of 30% by 2030. Each Member State must introduce the necessary
transposing legislation and measures to ensure delivery, including compliance assurance and
reporting by economic operators to track progress against the target. Periodic reporting by competent
national authorities to the Commission would also be necessary to ensure delivery and appropriate
remedial action in case of shortfall in reducing pellet losses.
This needs an established harmonised measuring methodology or standard (Option 1) first. Without
it, it would be challenging to establish a baseline and measure the achievement/non-achievement of
the established target.
4 THE INTERVENTION LOGIC
The diagram below sets out the underlying reasoning of this impact assessment by illustrating the
logical connection between the problem, its drivers the specific objectives and the policy options
which are assessed in Annex 11.
Figure 11: The intervention logic
178
Annex 11:
Impacts of Policy options to reduce pellet losses
1 IDENTIFICATION AND SCREENING OF IMPACTS
The first step in assessing the impacts of a policy option is to identify the significant ones, both direct
and indirect. The following table sets out the impacts that were considered as significant in this impact
assessment.
Table 50: Impact categories and indicators with degree of significance (+, ++, +++)
Broad impact
category
Indicator Significance
Environmental impacts
Quality of natural
resources
Change in quality of ecosystems and biodiversity: reducing pellet
losses improves ecosystems and biodiversity
+++
Efficient use of raw
materials
Change in the efficient use of raw materials: reducing pellet losses
reduces the amount of pellets that become waste (and need to be
recycled)
+
International
environmental
impacts
Change in quality of ecosystems and biodiversity outside the EU due
to transboundary nature of pellet pollution: reducing pellet losses
improves ecosystems and biodiversity globally
+
Climate change Reducing pellet losses has positive effects on plankton and therefore
on climate change
+
Economic impacts
Society & economy
at large
Change costs to society when taking action to reduce pellet losses,
including clean up and monitoring costs, reduced ecosystem services
from activities like commercial fishing and agriculture, tourism and
recreation in areas affected by losses
++
Businesses
including SMEs
Change in benefits to businesses when taking action to reduce pellet
losses, including reduced waste (and reduced value loss for pellets
that are lost) and other economic benefits
Change in costs (adjustment and administrative costs) to businesses
when taking action to reduce pellet losses, including costs for SMEs
present in the supply chain
++
+++
Internal market and
competition
Change in costs due to improper functioning of the internal market
due to internal market fragmentation
+
End users Change (increase) in prices of final plastic products to end users as a
negative knock-on effect of change in costs to businesses
+
EU competitiveness The additional costs are likely to have minor negative impact the
competitiveness of EU pellet producers as their competitors outside
the EU will not be affected
+
Innovation /
Technological
development /
digital economy
The innovation and research impact category covers the impacts on
technological development related to the sectors concerned
+
Social Impacts
Public health &
safety
Effects of measures on public health because of risks to food chain;
effects of measures on safety at work (pellets spilled on the floor)
+
179
Sensitive
populations
Effects of measures on sensitive populations in areas affected by
pellet losses (ports, beaches, protected areas, etc.)
+
Employment Effects of measures on employment (additional job opportunities in
the plastic sector)
+
Administrative burden
Public authorities Change in costs to public authorities in the Member States and to the
European Commission
++
Then, the significant impacts have been examined by indicating whether they are likely to be positive
or negative and which stakeholder groups they are most likely to impact. Colour coding is used to
summarise the impacts referring to the direction (positive or negative) and size (small or large). Note
that for several indicators no extensive quantification has been possible, due to the lack of available
data. In these cases, the assessment is based on expert judgement provided via the underpinning
support study.
Table 51: Coding used to present likely impacts
Score Description
+++ Very significant direct positive impact or benefit
++ Significant direct positive impact or benefit
+ Small direct positive impact or benefit
(+) Indirect positive impact or benefit
+/- Both direct positive and negative impacts, and balance depends on how implemented
0 No impact or only very indirect impacts
(-) Indirect negative impact or cost
- Small direct negative impact or cost
-- Significant direct negative impact or cost
--- Very significant direct negative impact or cost
High High Benefits significantly outweigh costs of measure
Medium Medium Benefits on balance outweigh costs of measure
Low Low Benefits close to or even below costs of measure
Uncertain Potential high benefits, but significant questions as to whether the measure can deliver
outcome
The outcome of this step is the final list of likely impacts.
Table 52: Screening of impacts
Impact Impacts Stakeholder groups impacted Justification for inclusion /
exclusion
Environmental impacts
Quality of
natural
resources
+++ Reduced pellet losses lead to better
quality of natural resources (improved
eco-systems and biodiversity)
The objective is to reduce pellet
losses and related adverse impacts
on the environment, so this is a key
impact category
Efficient use of
raw materials
+ Reduced pellet losses lead to fewer
pellets becoming waste
Less pellet losses leads directly to
the more efficient use of pellets
International
environmental
impacts
++ Reduced pellet losses lead to
improved ecosystems and biodiversity
globally
Pellet pollution is trans-boundary
(it affects both cross-border river
basins and seas) and global pellet
pollution is an important key
impact category
180
Climate change + No specific group is impacted Reducing pellet loss will lead to
less GHG emissions, for example,
during all steps of the plastic value
chain, but as well due to indirect
effects on plankton growth.
Economic impacts
Society &
economy at
large
+ Reduced pellet losses lead to less costs
on society (e.g. clean up costs) and
economy at large (sectors such as
commercial fishing and agriculture,
recreation and tourism)
The objective is to reduce pellet
losses for environmental, societal
and economic reasons
Businesses
including SMEs
-- Industrial operators bear the costs of
taking action to reduce pellet losses.
However, reduced pellet losses lead to
less value loss when pellets are lost for
those owning them, and to other
economic benefits for operators in
general including SMEs (e.g.
modernised equipment, improved
reputation and level playing field
among operators)
The objective is to reduce pellet
losses in an economically
proportionate manner, so this is a
key impact category. Certain costs
could be unbearable for some of
the SMEs present in the pellet
supply chain thus the need for
mitigating measures
Internal market
and
competition
+ A few Member States are starting to
take action to reduce pellet losses
If action is taken at EU level, the
functioning of the internal market
can be improved (same obligations
on every operator, level playing
field among them)
End users - Measures could negatively affect
consumers through price increases.
Measures could negatively affect
consumers through price
increases.
Third countries
and
international
relations
- There could be limited effects on
countries outside of the EU with both
direct and indirect impacts
There could be limited effects on
countries outside of the EU with
both direct and indirect impacts.
Innovation /
technological
development /
digital economy
? Research and innovation institutes and
industry
Development of a common
monitoring methodology and
innovative measures to prevent
and reduce pellet losses
Social impacts
Public health &
safety
+ Reduced pellet losses lead to
improved public health (less polluted
food chain) and safety at work (less
pellets spilled on the floor)
The objective is to reduce pellet
losses and related adverse impacts
on public health, so this is a key
impact category
Affected
populations
+ Reduced pellet losses lead to less
negative effects on populations in
affected areas
Reducing negative effects on
affected populations, e.g. working
in tourism, agriculture, fisheries,
incl. less clean-up costs and health
impacts
Employment + Reduced pellet losses lead to more job
opportunities in the plastic sector
Estimation of job opportunities
Administrative burden
Administrative
burden on
businesses
-- Industrial operators bear the costs of
taking action to reduce pellet losses
including administrative costs
The objective is to reduce pellet
losses in an economically
proportionate manner, so this is a
key impact category
181
The economic impacts are primarily related to the economic costs of implementing the measures, and
the environmental impacts are primarily related to the environmental benefits associated with the
reductions in pellet losses.
Whilst it is not feasible to quantify or value changes in environmental impacts, reductions in pellet
losses will reduce the negative environmental impacts compared to the baseline. In most cases, the
reductions will affect emissions to all environmental compartments. Hence, the environmental
impacts will be more or less proportional to the reduced losses. There will also be associated changes
in GHG emissions, as microplastics releases, including pellets, affect plankton and therefore the
absorption of GHG. Similarly, the social impacts, which include possible negative human health
effects, are also likely to be affected proportionally to the reduction in pellet losses. It means that all
measures have more or less the same types of environmental and social impacts, and only the
magnitude differs.
The approach to the assessment of cost impacts draws on evidence identified during the literature
review and stakeholder consultations. In many cases, the costs are affected by multiple factors, so the
cost estimates presented are generally order of magnitude estimates. Similarly, many factors
influence the assessment of the reduction potential and its likely fulfilments, so the assessment
provides an order of magnitude of the options.
All calculations are made in relation to the baseline for 2030.
2 OPTION 1: MANDATORY STANDARDISED METHODOLOGY TO MEASURE PELLET LOSSES
This option proposes a standardised measurement methodology to be used for the reporting on
estimates of quantities released on an annual basis, as obliged under REACH. This option would also
be beneficial for all the other options as it would allow them to tackle the information failure problem
driver and enable their effective implementation.
Environmental impacts
Under this option, there are no direct reductions of pellet losses, but a standardized methodology
to measure such losses will enable relevant actors to tackle them, thus reducing pellet losses to
the environment. The common standard will improve the quality of the reporting on the quantities
released (one methodology for all instead of several, different ones) improving the information on
the magnitude of pellet losses throughout the pellet supply chain, while also raising awareness among
relevant actors as they can measure pellet spills and losses and assess their evolution over time. It is
already a necessary step to measure any reduction measure's success rate.
This option will benefit all other options as the magnitude of pellet losses is a critical knowledge gap.
Social impacts
Public
authorities: MS
- Member State public authorities (at
local, regional and/or national levels)
depending on pellet responsibilities
(activities of data collection,
verification, correction and
enforcement)
The objective is to reduce pellet
losses in an economically
proportionate manner, so this is a
key impact category
Public
authorities:
European
Commission
- European Commission depending on
pellet responsibilities
The objective is to reduce pellet
losses in an economically
proportionate manner, so this is a
key impact category
182
No significant social impacts are expected.
Economic impacts
This option will entail both costs and savings. The cost of developing (and testing) the methodology
will be one-off and will depend on the time required to develop the methodology. The European
Standards Organisation (CEN) typically takes 3-4 years to complete the process, and has mostly
members from the industry. It could be seen if the industry bears this cost entirely or if the
Commission can support such development through a dedicated study (e.g. the one being conducted
for tyre abrasion). The advantage of the latter approach is more likely if the standard has to be taken
up in legislation.
When developing the common standard, CEN will take into account the methodology that is being
developed under the OCS certification scheme.
Therefore, the cost of this measure will be related to developing a draft method and calibrating it
through the data collected by initial monitoring. It will be important to conduct such monitoring along
the whole supply chain, viz., from pellets production, conversion and recycling, along with transport
and logistic operations between different supply chain steps. Modelling approaches could also be
used to validate different scenarios, e.g. the difference between virgin vs recycled pellet products,
small production facilities vs larger ones, etc.
Table 53: Assumptions used for calculating the costs of Option 1
Description Data Unit Source
Number of people working full time necessary to elaborate the
standard between 12 and 36 months211
7.25 persons ISO website
Mean cost of labour in EU of one expert working full-time 39.5
EUR/hou
r Eurostat
Number of hours per week in a full-time job (48 working weeks/year) 40.6
hours/we
ek Eurostat
Number of companies conducting tests for testing the standard 30 Number Assumption
Number of experts necessary per company to conduct the tests 1 person Assumption
Number of hours necessary per company to conduct the tests 24 hours Assumption
This assessment has estimated the cost of developing the common standard to be between EUR 558
087 (12 months development) and EUR 1 674 263 (36 months development). The testing cost at one
facility will cost about EUR 700-1500 per test, depending on the installation size. Assuming that
about 1 000 installations will test the standard during the development phase, the testing will cost
between EUR 700 000 and 1 500 000. The total would be between EUR 1 258 000 and 3 174 000
(rounded figures). As the common standard would be based on developments under the OSC
certifications scheme, it is estimated that the lower end of the cost estimation is more likely.
Once the standard is operational, it will need to be implemented in the value chain. The application
frequency and sample size of measuring pellet losses will need to be decided and could depend on
company size. The costs for a company will vary depending on the number of installations of the
211
The ISO sub-committee 14 of the technical committee ISO/TC 61 on the environmental aspects of plastics is
comprised of 29 members (the national standardisation organisations).standardization organisation). We assume that
each member contributes 0.25 FTE to work on the committee.
183
company and their size. Furthermore, with time, the application of the standard methodology could
be automatised, and costs brought down.
The implementation costs to be incurred by the industry to use the common standard, once this is
developed and tested, are already considered under the REACH restriction (as part of the reporting
costs) and do not need to be taken into account here. These costs will consist of the costs for the
companies to set up specific reporting systems and for the public authority to set up verification and
evaluation systems212
. There is however no concrete information available at this moment on how
the reporting obligation under REACH would look like in practise (mainly as it has been voted only
recently). Once this information is available, this standardised measurement methodology will need
to be coherent with specific requirements.
At the same time, imposing a standardised methodology to measure pellet losses has the potential to
save costs on different levels:
- The plastic industry is developing a methodology, however, it is not clear how much such a
method would be accepted by the whole value chain. Some partners in the value chain could
develop their own methodology. Some Member States might also develop a methodology on
their own. Under Option 1, there is only one cost for developing the methodology, and not
several.
- More importantly, businesses will have to apply only one methodology in the different parts
of the supply chain and in different countries.
- The verification and evaluation of the reporting by the public authority will be simplified.
While it is difficult to do an exact cost-benefit assessment, the cost savings would be higher than the
development costs for the standard. These cost savings are fully in line with the Communication
COM(2021) 219 final on joining forces to make better laws.
Stakeholder views: Stakeholders generally agree on this option. In the targeted SMEs consultation
conducted early 2023, a standardised methodology to measure pellet spills and losses was mentioned
by 51% of respondents as a support measure that could best help them to take action to reduce pellet
losses. The testing cost of one facility would be about EUR 700 per test, which means a proportionally
greater cost for small compared to large companies. However, these costs are already covered under
the REACH restriction.
Summary: This is the basis for setting up the framework to measure pellet losses and thus
fundamental for monitoring pellet losses and their evolution in the future. It will facilitate and
improve the quality of the reporting under REACH, while also raising awareness among relevant
actors as they can measure pellet spills and losses and assess their evolution over time. While an
exact cost-benefit assessment could not be made, the cost savings are expected to be higher than the
development costs of the standard.
Table 54: Summary of impacts of Option 1
Economic impacts Environmental impacts Social impacts
212
For the Committee for Socio-economic Analysis (SEAC), established under REACH, the total costs of reporting
could be substantial as the number of companies affected is likely to be large. SEAC considers that there are different
options to reduce such costs, e.g. by excluding certain actors (small or micro-sized companies) from the requirement
or by setting a threshold for microplastics volumes used or released to be reported. However, SEAC did not draw a
firm conclusion on how these different options would compromise the value of information obtained and hence the
benefits of reporting in terms of facilitating better risk management.
184
Cost savings No environmental impacts but will contribute to
better monitoring of losses in other options
No relevant impacts are
expected
3 OPTION 2: MANDATORY REQUIREMENTS TO PREVENT AND REDUCE PELLET LOSSES IN A NEW
EU LAW
In this option, imposing mandatory requirements and certification for all pellet handling companies
is the EU’s responsibility. Industry bears the costs of the external auditing and certification. Public
authorities in Member States are responsible, in the case of non-compliance, for imposing corrective
measures and, where relevant, penalties.
As it is a mandatory approach covering the full value chain with explicit requirements, a certification
scheme and a check in case of non-compliance, we estimate that the sector will have a high degree
of compliance (95% of the total virgin pellet volume handled) and will be effectively implementing
such rules with a success rate ranging from 80 to 95% (meaning that pellet losses would reduce with
these percentages).
Economic impacts
In this option, industry costs were calculated based on data input from a survey conducted by the
industry. As the data was based on Belgium’s experience and on a survey answered mainly by
enterprises located in Western Europe, a correction factor was used to apply these costs at the EU
level (EU average wage is 29 EUR/h, Belgium average wage is 41 EUR/h). The correction factor
was applied to all costs, not only for personnel costs as price levels differ across EU Member States
and therefore it would better describe actual additional costs of the measure.
What would be the costs of this option for the sector?
There is little direct information available regarding the costs to companies of taking measures to
adhere with best practice handling. Discussions with stakeholders in the course of this IA suggest
that the costs of implementing Option 2 could be limited as the plastics industry is already moving
towards measures and a system of external auditing and certification based on OCS. Some
transporters and other firms in the logistics chain already implement similar measures as best practice
from a health and safety standpoint. However, some costs could still be significant for some
companies, in particular those that have not introduced any measure to counter pellet losses.
Direct compliance costs for the sector
This option requires that all supply chain actors comply. The cost of this option varies significantly
according to the type of actor (producer, converter, transporter, storage, and recycler) in question,
and to the size of the installation or company. For example, micro and small companies (which
constitute meaning 89% of all converters, but only 20% of turnover) would be significantly affected
by the costs incurred by the upgrade of their facilities, the introduction of procedures including
internal and external audit and the training of their personnel. There is also a significant number of
transport companies needing certification, thus increasing the measure's costs.
a) Producers and Converters
According to estimates from the converting industry, the cost of setting up this option is calculated
as described in the table below. The costs of 100t, 1kt, 10kt and >50kt/year presented above represent
on average the costs for a micro, small, medium and large converting enterprise. The costs for the
micro-enterprises were extrapolated from the three other categories. Large plant costs are also applied
185
to the plastic producers (including virgin and recycled plastics, plastic export and import) as they are
generally large companies. This is consistent with the figure of the plastic production (about 1 FTE
per 500 kt handled)213
.
Table 55: Potential costs incurred by plastic converters
Type of cost
–
Type of enterprise
Plant capacity 100 t
/year
Micro
Plant capacity 1
kt/year
Small
Plant capacity 10 kt
/year
Medium
Plant capacity > 50
kt /year
Large
Resource EUR/
year
Resource EUR/
year
Resource EUR/
year
Resource EUR/
year
Personnel: dedicated
resource
5 persondays/
year @ 303
EUR/day
1 514 20 persondays/
year @ 303
EUR/day
6 055 60
persondays/
year @ 303
EUR/day
18 164 120
persondays/
year @ 303
EUR/day
36 328
Personnel: training
of staff
2.5 x ½
persondays/
year = 1.25
persondays @
303 EUR/day
363 10 x ½
training/year =
5 persondays
@ 303
EUR/day
1 514 30 x ½
training/year
=15
persondays @
303 EUR/day
4 541 70 x ½
training/year
= 35
man/days @
303 EUR/day
10 596
Personnel: internal
audit
1
personday/year
@ 303
EUR/day
303 5 persondays/
year @ 303
EUR/day
1 514 5 persondays/
year @ 303
EUR/day
1 514 5
persondays/
year @ 303
EUR/day
1 514
Cleaning
equipment(vacuum
cleaners, brooms,
shovels)
EUR 4 000
amortised over
6 years
472 EUR 4 000
amortised over
6 years
472 EUR 12 000
amortised
over 6 years
1 415 EUR 12 000
amortised
over 6 years
1 415
Panels, signage EUR 3 750
amortised over
6 years
442 EUR 7 500
amortised over
6 years
884 EUR 7 500
amortised
over 6 years
884 EUR 7 500
amortised
over 6 years
884
Collection and
retention trays,
containment systems
EUR 5 000
amortised over
6 years
590 EUR 10 000
amortised over
6 years
1 179 EUR 30 000
amortised
over 6 years
3 537 EUR 30 000
amortised
over 6 years
3 537
Miscellaneous
external services
(
sewer map etc.)
EUR 5 000
amortised over
6 years
590 EUR 10 000
amortised over
6 years
1 179 EUR 10 000
amortised
over 6 years
1 179 EUR 10 000
amortised
over 6 years
1 179
Cost of auditing
(external)
707 1 061 1 061 1 061
Automated transport
system
17 683
Sewage treatment
systems/
improvement of
sewage/ construction
EUR 50 000
amortised over
10 years
3
537
EUR 100 000
amortised over
10 years
7 073 EUR 150 000
amortised
over 10 years
10 610 EUR 300
000
amortised
over 10 years
21 220
Maintenance cost 354 707 2 829 17 683
213
Personal communication from a main plastic producer
186
Type of cost
–
Type of enterprise
Plant capacity 100 t
/year
Micro
Plant capacity 1
kt/year
Small
Plant capacity 10 kt
/year
Medium
Plant capacity > 50
kt /year
Large
Resource EUR/
year
Resource EUR/
year
Resource EUR/
year
Resource EUR/
year
Cost/year (EUR) 8 870 21 638 45 733 113 098
Cost/tonne (EUR/t) 88.70 21.64 4.57 2.26
The total cost for producers and converters was then calculated based on the volume (tons) of pellets
handled by enterprise type.
In the plastic converters industry, there are ca 48 000 enterprises. The breakdown of converters
according to the size of the plant in 2019 (in 2021, the shares are similar) has been calculated with
Eurostat data and is as follows:
• Micro - 4% of the pellet volume processed
• Small - 16% of the pellet volume processed
• Medium - 36% of the pellet volume processed
• Large - 44% of the pellet volume processed
Although micro-enterprises represent 66% of the enterprises in the processing sector, their overall
turnover accounts for less than 4% of the sector. Both Plastics Europe and PRE have confirmed that
their members are not SMEs. However, recyclers are generally small installations, even if they belong
to a large company.
b) Logistics
Costs for the logistics operators were not available. There are three main parts in logistics:
• Transport,
• Storage or warehouses,
• Cleaning stations.
The cost for these were calculated at enterprise level, based on the basic assumption that the measures
needed to be taken by a firm are largely similar and will mostly depend on the size of the firm. As an
important part of the cost are related to personnel, it was assumed that a firm with the same number
of persons would occur the same cost structure, and this for the main classes: micro-, small, medium
and large enterprises. For the storage providers, the same cost as for converters were taken. For the
transport providers, there are no costs related to equipment and investments, only to personnel,
external auditing and miscellaneous (see the table below).
Table 56: Potential costs incurred by the transport providers per type of enterprise
Type of cost Micro Small Medium Large
EUR/ year EUR/year EUR/ year EUR/ year
Personnel: dedicated resource 1 514 6 055 18 164 36 328
Personnel: training of staff 363 1 514 4 541 10 596
187
Personnel: internal audit 303 1 514 1 514 1 514
Cost of auditing (external) 707 1 061 1 061 1 061
Total 2 887 10 143 25 280 49 498
The total costs for transport was calculated based on the number of firms working in the sector. The
sector structure of the transport sector (all types of goods - rail, road, water and inland water),
according to the number of persons working in the enterprise is as follows 214
:
• Micro - 81% of the transport providers
• Small - 16% of the transport providers
• Medium - 2.6% of the transport providers
• Large - 0.4% of the transport providers
It was assumed that not all micro enterprises in the transport sector will be subject to additional costs
under this option for the following reasons:
• There will be a 5 tonnes/year threshold for the requirements, so not all micro enterprises will
be concerned.
• After setting up new rules for the pellets transport, it is expected that certain enterprises will
no longer transport pellets, especially among micro enterprises, so the costs will not occur.
This is even more the case as in transport the size of the micro enterprises seem smaller than
in converting (e.g. a one truck company).
• Eurostat data estimates the data on micro-enterprises with “low reliability”.
Therefore we assume that only 50% of the micro enterprises will be concerned with the higher
costs under this option.
Based on the transport sector input, about 50 large companies are dealing with pellets, all members
of the European Chemical Transport Association (ECTA). Starting from this figure, the assumptions
above, and assuming that the transport of pellets follows the same division of enterprises as the total
transport, the number of enterprises per size could be calculated, and therefore the costs for the
transport sector.
Based on these calculations, it results that about 4-5% of the transport companies are working with
pellets. We assume that a similar part and enterprises structure for the storage providers or
warehouses (NACE H 52.1) who are dealing with pellets.
There will be no additional costs for tank cleaning stations as the ones, who are dealing with pellets,
are already complying with SQAS which has similar requirements. The profile of these tank cleaning
stations is the following:
214
Eurostat 2021: Nomenclature of Economic Activities (NACE) codes were included – H 49.2 - Freight rail transport,
H 49.4 - Freight transport by road and removal services and H 50.4 - Inland freight water transport. Data for H 50.2.
Sea and coastal freight water transport was not available by Eurostat. For inland water transport, the same structure
as for rail transport was assumed.
188
Table 57: Enterprise structure of cleaning stations (enterprises)
Number of
employees Number % over Total
Less than 10 300 68
10-50 125 28
More than 50 15 4
Total 440 100
It is still possible that additional external auditing would be needed. An audit costs around EUR 707
for a micro-enterprise, and EUR 1061 for small and medium enterprises. In that case, the cost would
be:
440 warehouses x (68% x 707 EUR + 32% x 1061 EUR) = 224 587 EUR
Based on the above, we estimate that, ca 13 000 transport providers, 850 storage or warehouse
providers and 440 cleaning stations are dealing with pellets and will be affected by the requirements.
Note: The analysis is done using a rough estimate of the costs per tonne. However, to deal with pellet
losses, both investments (fixed costs) and variable costs will depend on the progress made by
companies in the meantime through their voluntary commitments. The upfront investment costs will
be relatively more important for SMEs, especially for micro-enterprises than for other enterprises.
Micro-enterprises could therefore merit receiving special attention.
Costs taken up in the base line
As the industry has already started implementing some of the proposed measures through their
voluntary programs, such as OCS CS and RecyClass, some of these costs will already be incurred in
the business-as-usual scenario, i.e. under the baseline. We use the following volume assumptions for
the costs incurred under the baseline:
• about 70% (referring to the efficiency rate of loss reduction) of the 90% of the total virgin
pellet volume produced (by the members of Plastics Europe) and 5% for the non-Plastics
Europe members;
• about 50% (referring to the efficiency rate of loss reduction) of the 20% of the total recycled
pellet volume produced;
• 50% (referring to the efficiency rate of loss reduction) of the 30% of the total volume
processed; and
• 30% (referring to the efficiency rate of loss reduction) of the 40% of the total volume handled
by logistics companies (transport – storage).
These values are based on the ones used to estimate the baseline. Where, in the baseline, a lower and
higher boundary were proposed, the average value was taken here.
Stakeholder views: When consulted in the framework of the open public consultation (Annex 2),
stakeholders agreed that there is improper handling of pellets. The umbrella association of European
converters, EuPC, pointed to limited resources as a barrier to implementing voluntary measures under
the industry-driven OCS programme. More recently, the umbrella association of European
manufacturers, PlasticsEurope, agreed the most effective approach to tackling pellet losses is
mandatory external auditing and certification building on OCS and applied to all actors throughout
189
the supply chain. Producers therefore considered a legislative proposal requiring certification of an
OCS-like pellet loss prevention management system would be very quickly implementable
throughout the whole supply chain because it would benefit from the existing industry initiative and
would reinforce it.
A second consultation targeting all SMEs handling pellets was conducted from January to February
2023 in all EU languages (Annex 12). Based on the 330 replies received, it emerged that for a majority
of respondents, only a lighter version of requirements could be imposed on such companies.
Specifically, they reported that the requirement on the training of staff should be made mandatory in
the same way for all companies, but the obligation of being externally audited and certified should
not be imposed at all on SMEs. The survey also indicated that the direct economic impacts of this
option would be too high to be sustainable for micro and small companies, as well as companies with
capacities below 1000t. Among the various best handling practices, the mandatory use of specific
equipment and of specific packaging (i.e. airtight, puncture-resistant and environmentally sealed)
was identified as the most expensive measure. Generally, the cost per tonne of the measures to be
implemented would become insignificant for companies with capacities above 5000t. Finally,
financial support and standardised methodology to measure pellet losses were identified as the
support that would best help respondents.
In light of the above, three sub-options have been considered and assessed in the form of lighter
requirements for the micro, small and medium companies present in the pellet supply chain (see table
below). A derogation for companies making and handling pellets in quantities lower than 5 tonnes
will also apply in all scenarios. Such an approach will avoid requiring costly investments which
would only deliver very limited environmental benefits in terms of pellet loss reduction.
These lighter requirements are also justified following the principle of proportionality and the need
to match the nature and intensity of a given measure to the identified problem.
Sub-options “Lighter requirements for micro-, small- and medium-enterprises”
From the calculation above, it is clear that the relative cost for an SME are higher than for large
companies. It was therefore estimated that lighter requirements would be needed to alleviate a part
of these costs. This is also consistent with the replies and request received through the stakeholder
consultations.
The lighter requirements assume that:
• There will be no requirement for a sewage treatment system and maintenance;
• Certification requirements will be reduced to 5 years for micro-enterprise and 3 years for
small ones; and
• A reduction of 10% reduction of personnel costs.
With these reduced requirements, we assume that the pellet loss will be 35% higher for converter and
20 % for logistics (for transport, there is no sewage treatment system, thus neither related
requirements) from these companies than under the main scenario. This assumption means that the
other requirements are still the most important ones to reduce pellet losses, but that there is already a
significant increase in pellet loss.
190
Table 58: Costs for lighter requirements for micro, small and medium sized companies for typical plant
capacities
Type of cost
Type of enterprise
Plant capacity 100 t
/year
Micro
Plant capacity 1
kt/year
Small
Plant capacity 10 kt
/year
Medium
Resource EUR/yea
r
Resource EUR/ye
ar
Resource EUR/y
ear
Personnel: dedicated
resource
10%
lower
than main
option
1 362 10% lower
than main
option
5 449 10% lower than
main option
16 384
Personnel: training of staff 327 1 362 4 087
Personnel: internal audit 272 1 362 1 362
Cleaning equipment
(vacuum cleaners,
brooms, shovels)
Same as
main
option
472 Same as
main
option
472 Same as main
option
1 415
Panels, signage 442 884 884
Collection and retention
trays, containment
systems
590 1 179 3 537
Miscellaneous external
services (sewer map etc.)
590 1 179 1 179
Cost of auditing (external)
(normally every year)
Every 5
years
141 Every 3
years
354 Every 3 years 1 061
Sewage treatment
systems/ improvement of
sewage/ construction
No
sewage
treatment
No sewage
treatment
No sewage
treatment
Maintenance cost No
maintena
nce cost
No
maintenan
ce cost
No maintenance
cost
Cost/year (EUR) 4 196 12 242 29 872
Cost/tonne (EUR/t) 41.96 12.24 2.99
As with the main option 2, the equivalence for the logistics sector is made.
The cost of implementing Option 2 would be 742 and the sub-options 2a, 2b, and 2c would be
615, 516 and 479 million EUR/year respectively.
The cost-effectiveness of the options range from 2672 EUR/tonne avoided per year to 26 342
EUR/tonne avoided per year, depending on the sub-option and the lower/higher estimation of losses.
The cost of measures under option 2 and its sub-options vary between sectors (see table below).
191
Table 59: The cost of measures under option 2 and sub-options 2a, 2b and 2c for the value chain (M
EUR/year) (without taking the savings into account)
Option 2 Option 2a Option 2b Option 2c
Plastic converters 616.36 497.70 402.29 365.51
Plastic producers, including recyclers 65.92 65.92 65.92 65.92
Transport providers 51.32 45.42 42.99 42.41
Storage providers 8.12 5.88 5.13 4.68
Total 741.72 614.92 516.32 478.51
Table 59 shows the costs for the different parts of the value chain. However, this does not yet take
into account the benefits of the pellets saved, which are quite important, see the following table,
which is only done for option 2b.
Table 60: Summary of impacts in 2030 of Sub-option 2b per part of the supply chain
Plastic
converters
Plastic
producers,
incl. recyclers
Transport &
storage
Total
Cost of the measure (M€/y) 402.3 65.9 48.1 516.3
Savings from pellet losses (M€/y) 10.1 - 40.7 2.4 – 16.2 16.1 – 91.3 28.6 – 148.3
Net cost to business (M€/y) 375.7 – 491.2*
* It is not possible to calculate the net cost for each part of the supply chain as it is not clear who benefits
exactly from reduced pellet losses. This depends on who owns the pellets and can valorise the savings from
less pellets lost. This is not known for the pellets in transport and storage.
The additional costs are likely to negatively impact the competitiveness of the EU pellet producers
as their competitors outside the EU will not be affected. According to EuPC the turnover of the
plastics sector in the EU27 in 2021 was EUR 405 billion215
. Therefore, this additional estimated cost
of option 2b would represent about 0.13% of the EU plastics sector turnover and would only have a
very minor impact on the competitiveness.
What would be the cost for the public authorities?
The costs arising will depend on the manner it is implemented in Member States. The focus is on
administrative costs, i.e. procedures to follow, monitoring, delays, complaint-handling mechanism,
access to justice, etc. Further costs can be related to competent authorities for the setting up of the
system, i.e. one-off costs at the beginning as well as some costs for the maintenance of the system
and compliance promotion, such as awareness raising, information to stakeholders, training of
officials, developing and providing of guidance and capacity building of public authority officials
and enforcement actions. However, it may not be necessary to set up a new system in Member States
as some of these mechanisms already exist through other legislation, such as IED, Environmental
Liability Directive, Environmental Crime Directive, UWWTD, and synergies could be achieved by
integrating some of the costs for public authorities related to pellet losses. These costs vary
215
https://www.plasticsconverters.eu
192
significantly across Member States depending on the current situation on implementing
environmental legislation.
Further to that, it could be envisaged that the public authorities in the Member States would be
required to hold a public register of certified companies to ensure full transparency and traceability
of the supply chain, including to ensure compliance with the requirements. This registry could done
through an existing system to lower the costs. This would imply separate minor reporting costs (EUR
188 000 per year) for the economic operators (notifying the public authority about the outcome of
the external auditing, as the reporting on the pellet losses to ECHA already will be required), and
processing costs for the public authorities in the Member States. Also, there might be minor additional
costs related to reporting obligations to the Commission to ensure compliance with the regulation as
the Commission could assemble such system. However, this would be a minor task for Member
States as they would have necessary data in the registry.
About 50 person days in average would be needed to set up the system for receiving the notification
from the companies, about 20 days each year for compiling and quality assurance and appropriate
follow-up measures (e.g. enforcement) for each Member State. Using average Eurostat wages (EUR
29/hour), we can estimate the processing costs, including data collection, verification, correction, and
enforcement to be EUR 313 000 (total annualised one-off administrative costs of EUR 36 700,
discounted at 3% over 10 years) for the first year and EUR 125 000 per year for the whole EU. These
cost will vary across Member States as it would be higher for larger ones and lower for smaller ones.
What would be the benefits for the sector?
For businesses owning the pellets, this option could reduce the estimated economic loss of EUR 42
– 170 million coming from about 42 050 – 170 266 tonnes per year tonnes of pellets lost in 2030
(1000 EUR/t, mainly coming from less pellets lost by logistics, but also by producers and converters
as described in Table 48 in Annex 9). (Prices of plastics are fluctuating and depend on the exact
polymer type and the stage of processing).
Benefits for SMEs from implementing the BSI PAS (a system with similar requirement in the UK to
reduce pellet losses) were reported to be:
• modernised equipment thanks to grants they secured;
• less legacy pellet pollution, which had previously been extensive around the sites;
• reduced waste (and lower waste management costs);
• improved staff awareness and training;
• reduced fire risk because proper and regular site assessments revealed build-up of dust in
areas previously unchecked;
• involvement of suppliers/customers – all site visitors are required to read and accept rules
relating to proper pellet management; and
• Improved reputation.
What would the benefits of this option be for the economy at large and society?
Under this option, reducing pellet losses may have positive knock-on economic impacts on sectors
such as tourism. In some coastal areas (such as in the vicinity of Antwerp and Tarragona ports216
),
216
https://surfrider.eu/wp-content/uploads/2020/11/report-pellet-pollution-2020.pdf
193
pellets can be found in significant quantities including in protected areas217
. Their removal would
reinforce the attractivity of these areas for tourism purposes.
Similarly, the reduction of pellet losses into the environment may have positive knock-on economic
impacts on commercial fishing and agriculture, in areas where these activities are particularly
affected by the releases with significant harm to ecosystems and biodiversity. In particular, there will
be fewer pellets lost into the marine environment and, thus, fewer perturbations to all marine
organisms, including economically important organisms such as oyster and seabass218
. Considering
that the ecosystem services provided by the Ocean are estimated to be worth over USD 24 trillion,
the regulation of microplastics and the protection of marine ecosystems and habitats seems to be of
significant importance219
. Similarly, there would be fewer pellets lost in the installations’ wastewater
and in the sludge resulting from their treatment. Consequently, there will be less pellets lost to the
soil after sludge application on agricultural land.
Benefits also include avoided costs to society. Cleaning up pellet pollution and remediation measures
can cause harm to ecosystems as it is almost impossible to specifically remove them without affecting
the environment they are spilled into220
. They are also challenging to local communities in terms of
technological, human and financial resources. For example, it was estimated that beach clean-ups
cost the city of Marseille (France) an average of EUR 1 000 000 per year221
. KIMO Netherlands
reported that the clean-up costs of the 2019 pellet spill of the MSC Zoe in the Wadden Sea would be
approximately EUR 100 000 annually222
. These are obviously only examples. Even if there are no
figures available, the sum of the clean-up costs for the whole EU shore should be much higher.
By applying the costs of the clean-up operations of the 2017 MSC Susanna loss in Durban, South
Africa, (where 35.8 tonnes of pellets were collected over the period of the operation) to an EU
context, each tonne of pellets on average costs EUR 1.21 to EUR 1.82 million to collect.
Environmental impacts
As this option requires that all actors of the supply chain comply with mandatory requirements and
certification (with the only exception of companies making and handling pellets in quantities lower
than 5 tonnes), the main expected environmental impact from this option is a significant reduction
of pellet losses that are likely to be harmful to ecosystems and biodiversity and may affect human
health.
The overall reduction is expected to be between 27 128 tonnes/year (low emission scenario) and
148 879 tonnes/year (high emission scenario), representing a 65% and 87% reduction overall,
respectively (compared to the baseline). It will also save annually 106 – 583 of GHG emissions in
kilotonnes of CO2 equivalent 223
.
When providing for lighter requirements for the smallest or micro-enterprises, the reduction of
pellet losses ranges from 26 730 tonnes/year to 147 227 tonnes/year (105 – 576 ktCO2e). With
lighter requirements for the micro and small enterprises, the reduction of pellet losses ranges from
217
The unaccountability case of plastic pellet pollution - ScienceDirect
218
Zhu, X. et al. (2020) ‘Bioaccumulation of microplastics and its in vivo interactions with trace metals in edible oysters’,
Marine Pollution Bulletin, 154, 111079. doi: https://doi.org/10.1016/j.marpolbul.2020.111079 83 Barboza, L.G.A et
al. (2018) ‘Microplastics cause neurotoxicity, oxidative damage and energy-related changes and interact with the
bioaccumulation of mercury in the European seabass, Dicentrarchus labrax (Linnaeus, 1758)’, Aquatic Toxicology,
195, pp. 49-57. doi: https://doi.org/10.1016/j.aquatox.2017.12.008.
219
WWF Report 2015; Reviving the ocean economy
220
UN Environment; Marine Litter - Socioeconomic Study, 2015
221
OSPAR Background document on pre-production Plastic Pellets 2018
222
Fishing for Litter fleet cleans up after MSC Zoe but who pays the costs? – KIMO (kimointernational.org)
223
Calculation is based on the report ”Plastic leakage and greenhouse gas emissions are increasing - OECD”
194
25 142 tonnes/year to 140 621 tonnes/year (98 – 551 ktCO2e). Similarly, with lighter requirements
for micro-, small and medium-enterprises, the reduction of pellet losses ranges from 21 569
tonnes/year to 125 757 tonnes/year (84 – 492 ktCO2e).
Social impacts
This measure will require additional staff to prevent pellet losses and for training. Applying the same
assumptions made on the share of the volume between small, medium and large factories,
implementing the measure would need from 3772 to 4103 FTE personnel.
Since this option may increase the cost of plastic raw materials, the general public may be impacted
by an increase in the cost of plastic goods. Since plastic is used everywhere, any increase in its cost
will be felt in society. However, the cost increase is likely to be limited as the cost of the measure is
small compared to the turnover of the sector. For large companies, in particular, it is possible that the
manufacturer would absorb such a slight increase in its production costs and that consumers would
be unaffected.
Summary: The introduction of mandatory requirements and certification would result in significant
reductions of pellet losses. The more losses are avoided, the greater the positive impacts are for the
environment and for economic activities like commercial fishing, agriculture, tourism and recreation.
the costs incurred by the sector under Option 2 and its sub-options (without micro/without micro and
small companies/ without micro, small and medium companies) may increase the cost of plastic
goods produced and/or converted in the EU. There would be a cost for public administrations as they
would be in charge of monitoring its implementation, but this would be via a unique instrument i.e.
a public register of certified companies.
This option has less risks as to the probability of reaching the objectives and massively reduces the
number of free riders. The system is set up in a way to limit public costs as it involves third party
auditing and certification. The possibility of a public register of certified companies at national level
would further increase the transparency and traceability of the supply chain, with limited processing
costs for the public authorities in the Member States.
Costs for business are expected to be higher in the beginning as some investments need to be done
and go down afterwards. There will also be a learning curve reducing costs later on.
Table 61: Summary of impacts in 2030 of Option 2 and its sub-options 2a-2c
Option 2 Option 2a: Lighter
requirements for
micro-enterprises
Option 2b:
Lighter
requirements
for micro-and
small
enterprises
Option 2c:
Lighter
requirements
for micro-, small
and medium-
enterprises
Environmental
impacts (i.e.
reduced pellet
losses) (tonnes)
27 128 – 148 879 26 730 – 147 227 25 142 – 140 621 21 569 – 125 757
Environmental
impact (GHG
emission savings)
(tonnes of CO2 eq)
106 210 – 582
890
104 655 – 576 424 98 437 – 550 560 84 446 – 492 366
195
Option 2 Option 2a: Lighter
requirements for
micro-enterprises
Option 2b:
Lighter
requirements
for micro-and
small
enterprises
Option 2c:
Lighter
requirements
for micro-, small
and medium-
enterprises
Economic impacts
Cost of the
measure (M
EUR/year)
742 615 516 479
Savings from the
pellet losses (M
EUR/year)
27 - 149 27 - 147 25 – 141 22 - 126
Net cost to
businesses (M
EUR/year)
593 - 715 468 - 588 376 - 491 353 - 457
Cost-effectiveness
(EUR/tonne/year)
3 982 – 26 342 3 177 – 22 005 2 672 – 19 536 2 805 – 21 186
Savings from
GHG emission
(MEUR/y)^
11 – 58 10 – 58 10 – 55 8 – 49
Other economic
impacts
Public Administrations: increased costs for data collection (i.e. public register) and
overall monitoring of the implementation, intervention in case of non-compliance
(i.e. enforcement of the sanctions)
Citizens: limited increase of the cost of plastics goods
Tourism and recreation: increased attractivity through the reduction of pellets in
coastal areas and other vulnerable areas
Fisheries: fewer pellets released in water and improved ecosystem services due to
fewer pellets absorbed by marine organisms and animals in areas affected
Agriculture: fewer pellets released on soils and improved ecosystem services due
to fewer pellets affecting soil properties in areas affected
Other
environmental
impacts
Society: fewer costs related to clean up and remediation activities by local
communities in affected areas
Social impacts
(jobs in FTE)
4103 4004 3858 3772
Note: 1 tonne of CO2
estimated value is 100 EUR€/t. Therefore, it can add 8 – 58 M EUR€/year in savings.
* Net cost: cost – savings. In every option there are 2 scenarios of the projection of the pellet losses. Therefore,
higher pellet loss reduction refers to lower costs and vice versa.
4 OPTION 3: IMPROVED PACKAGING FOR LOGISTIC OF PELLETS
This option targets in particular the logistics sector operators to prevent losses from transport,
intermediate storage and handling during these operations. The option imposes the use of specific
types of bags and containers for pellet handling, transport and storage and, where relevant, product
design measures. It can be set up as an independent piece of legislation or can be implemented as
part of the legal proposal in Option 2.
196
What would be the costs of this option?
Current packaging materials used to transport pellets are:
• plastic bags (containing up to 25kg of pellets) stacked on pallets with a total weight of up to
1.5 tonnes;
• octabins (cardboard containers containing between 0.5 and 1.3 tonnes of pellets);
• big bags, containing from 0.5 to 1 tonne of pellets;
• containers, containing up to 25 tonnes of pellets; and
• silo trucks, containing up to 35 tonnes of pellets.
These different packaging materials do not present the same pellet loss risks, with plastic bags
holding the most risk for pellet losses and silo trucks the least. As shown in the figures below, silo
trucks have airtight suction mechanisms and the loading and unloading of these trucks leave little
room for pellet spills, but if they are spilled, then they are collected for disposal.
Figure 12: Loading pellets into a silo truck
Source: Schmidt-heilbronn Company
197
Figure 13: Unloading pellets from a silo truck
Source: Schmidt-heilbronn Company
The costs of imposing specific packaging and accompanying measures could be potentially high,
especially for producers, who may have to change their production lines since plastic bags are
automatically filled on-site through their own manufacturing chain. Similarly, logistics operators will
have to adapt their transport and storage approaches depending on the type of packaging.
Plastic bags are the packaging materials which would be targeted first because of their poor resistance
to tears during operations. In its background document on pre-production plastic pellets224
, OSPAR
mentions that plastic bags and octabins could be replaced with reusable rigid HDPE barrels or with
intermediate bulk containers (IBC). IBC Containers’ pricing ranges from EUR 165 up to 4500 225
while HDPE barrels are cheaper and cost between EUR 13 to 40226
depending on their specifications
e.g. size, material, and type of opening. Replacing existing machinery and processes might also
generate extra costs. Another approach could be to use thicker plastic bags which are more resistant
to tears.
224
OSPAR Commission, Background document on pre-production plastic pellets, 2018,
https://www.ospar.org/documents?v=39764. Accessed 12 Apr 2022.
225
www.ibctanks.com/chemical
226
www.hasdrums.com.sg
198
Figure 14: Returnable rigid HDPE barrels Figure 15: Intermediate bulk containers
(IBC)
The IMO Correspondence Group on Marine Plastic Litter from Ships that is looking at how to reduce
the environmental risk associated with the maritime transport of plastic pellets considered packaging
provisions for plastic pellets carried at sea as primary measures to take forward for further
assessment.
However, they acknowledge the high cost of this measure to the industry because production facilities
are already fitted with bagging lines to package pellets. The bags have several advantages over the
rigid containers and the IBC because they enable flexibility in the size of shipments and prevent dust
contamination. Bags are also more suitable to fill up means of transport, and therefore increase freight
loads. This reduces the number of freights so GHG emissions and transport costs would be lower
when using bags.
Data is lacking on:
- the volume of pellet losses due to packaging in general and specific packaging types, and the
share of these losses in the overall pellet loss estimates;
- the market shares of the different types of packaging used for pellet transport; and
- the cost difference between actual packaging and improved packaging.
What would be the benefits of this option?
This option could potentially significantly reduce pellet losses during transport and intermediate
storage, as well as handling during these operations. Also, with increased efficiency in their
processes, the sector would gain from the investments. However, no quantification could be made to
estimate the losses due to torn plastic bags or octabins.
Economic impacts
Due to important data gaps, it was not possible to quantify the direct investment and compliance costs
for the sector deriving from this option.
The cost of this option would probably be high, relative to turnover, but so could the gains in terms
of pellet loss prevention. However, the cost per tonne of pellet losses avoided is expected to be higher
than with Option 2 because it will force the industry to overhaul their production lines to effectively
remove the bagging lines and replace for instance plastic bags with returnable rigid HDPE barrels or
199
with intermediate bulk containers IBC. Imposing thicker more resistant plastic bags could lower such
costs. However, as all these solutions mainly represent an investment cost, smaller enterprises would
be affected more than bigger ones respective to their size.
Environmental impacts
This option would yield positive environmental impacts by reducing pellet losses to the environment;
however, it can also increase CO2 emissions. Indeed, rigid HDPE barrels and IBC do not offer the
same flexibility as plastic bags. When not entirely filled up with material, they increase storage
volume for a given quantity of material, increasing the CO2 emissions incurred by transport. If thicker
bags would be chosen, there would only be a minor increase of GHG emissions (As thicker bags are
used, there is an increase in the amount of plastics used for the bags. This is expected to be minor
compared to the GHG emissions from transport).
Social impacts
There are no social impacts foreseen for this option. However, moving towards more automated
solutions like silo trucks could reduce the number of jobs (more workforce is needed for manual
loading and unloading of pellet containers/bags).
Stakeholder views: While there is no precise information available on the proportion of pellet losses
that can be attributed to poor quality packaging, NGOs often emphasise its relevance. Industry seems
less convinced, especially in light of the expected high costs of improved packaging. The umbrella
association of European manufacturers, PlasticsEurope, considers that more robust packaging of
plastic pellets or prohibiting certain types of packaging does not address the root cause of the
problem, and is not an effective alternative for excluding the transport sector or any other sector in
the plastic supply chain from mandatory provisions.
In the second consultation conducted early 2023 targeting all SMEs handling pellets (Annex 12),
respondents consistently reported the potential high costs of changing the packaging structure. In
particular, it emerged that while two-thirds of respondents consider the use of specific packaging
effective to reduce pellet losses, only 54% do it always or often (and a third never does it or has no
opinion). Views on whether this should become a mandatory requirement are mixed: 33% in favour,
20% in favour if lighter requirements for SMEs, and 27% against, while the use of specific packaging
is estimated as the most costly measure both in terms of person/days and euros/tonne/year. Financial
support was identified as the form of support that would best help respondents, along with a
standardised methodology to measure pellet losses.
Summary: The use of more resistant packaging materials and spill-proof packaging options would
reduce pellet losses throughout the supply chain. However, the impacts differ according to the type
of improved packaging chosen. While switching out plastic bags for barrels would likely present a
greater reduction in losses, it would also increase the GHG emissions and costs of transport, in
addition to require greater investment costs (as infrastructure will need to be replaced). Opting for
thicker more resistant plastic bags would avoid these investment costs and allow for greater volumes
to be transported per unit of transport. This option could be incorporated into a more comprehensive
set of requirements, such as those laid out in option 2. There was not enough data to be able to
calculate the precise costs, but it was estimated that the cost effectiveness of this option would be
lower than for option 2.
5 OPTION 4: EU TARGET TO REDUCE PELLET LOSSES
An emission reduction target for pellet losses will be set under this option. The target can be
ambitious as the plastic production and conversion industry responsible for the OCS certification
scheme believes that a 95% reduction of losses in their facilities is achievable. While this seems
200
correct if all firms would implement, it is not clear if this would be realistic, and if this 95% target is
achievable for the whole sector.
This option can only be implemented if a measurement standard for pellets losses is developed
(Option 1). It would also be useful to gain more knowledge before its implementation, which can be
done through the REACH reporting requirement. A new piece of legislation could be used to create
and enforce a pellet loss reduction target, but it could also be integrated into Option 2.
The target could be set either for the whole plastics industry, or at sector level allowing the supply
chain to optimise processes to achieve the target. In the latter case, there could be differentiated
targets depending on the place in the value chain.
An emission target mechanism could be set up to define and enforce the target by:
• Setting a maximum volume of pellets which can be lost either per unit of pellet
produced/converted/transported in mg/kg or setting a maximum quantity of pellets which can
be lost to the environment; or
• Setting a maximum percentage of the production volume that can be lost, enforced by
measuring the content of catchment devices (e.g. filters) part of the plants' containment
systems and sampling on the plant’s premises and vicinity.
A more sector-oriented approach would require a kind of clearinghouse which would report the pellet
losses every year, as well as close cooperation and engagement from all actors throughout the supply
chain, which is not the case today. (For instance producers and processors are discussing together the
implementation of the OCS certification scheme, but recyclers and logistics operators are still
external to the process. Also, they all have different strategies, ambitions, and means to tackle pellet
losses).
Whatever the approach, the thresholds will need to be refined after additional data is gathered from,
for example, the REACH reporting requirements. Building on the results of this first monitoring
exercise, it will be possible to define an achievable threshold for pellet losses.
Enforcement will be the main difficulty in this option; indeed, sampling protocols for pellet losses
are in development, and there are currently no standards to do so.
This is a medium to long-term option, which should be in phase with the time necessary to identify
the relevant threshold. Indeed, the REACH restriction on intentionally added microplastics was
adopted on 25 September 2023.227
In this restriction, the reporting on estimates of quantities released
is proposed, but there are some limitations, as identified by Rethink Plastic Alliance228
in their
position paper:
• The ECHA restriction does not require the industry to report the tonnages handled, yet, this
would help define a spill rate, which would be useful in defining a possible threshold;
• The ECHA restriction does not provide minimum requirements for the reporting on estimates
of quantities released, but having this information would be essential to provide comparable
data; and
• The entry into force of the reporting requirement takes a long time. In view of voluntary
227
Commission Regulation (EU) …/… amending Annex XVII to Regulation (EC) No 1907/2006 concerning the
Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) as regards synthetic polymer
microparticles.
228
Rethink Plastic alliance, PLASTIC PELLETS UNDER REACH: Strengthening requirements to enable effective
supply chain legislation, Position Paper, March 2021, https://rethinkplasticalliance.eu/wp-
content/uploads/2021/04/plastic_pellets_under_reach.pdf Accessed 14 April, 2022.
201
initiatives, which will include reporting, that the plastic pellet supply chain is putting in place,
the Restriction now includes a 24-month transitional period for the reporting requirement.
The ECHA reporting requirement could be used to define a threshold for pellet emissions to the
environment; however, it may need some improvements depending on the decisions to come
regarding the comments made to the proposal. It will also need some more years before the data
becomes available.
Once the threshold is defined, it could be possible to include it in legislation.
What would be the costs?
The cost of setting the emissions reduction targets would depend on the measurement standard
developed to measure pellet losses accurately. Once developed, the standard would need to be applied
over 12 to 36 months to generate a statistically strong database with and without implementing
prevention, mitigation and clean-up measures. The target could be defined as the result of this
observation phase.
The implementation of the targets are expected to generate the same or similar costs as the
requirements under option 2. Similarly, lighter requirements would be needed for for SMEs,
especially for micro and/or smaller firms to mitigate concerns raised by SMEs (e.g. lack of staff/time,
lack of information on risks and solutions and lack of financial resources – see Annex 12). The
follow-up costs might be higher than under Option 1 as a more stringent system would need to be set
up.
What would be the costs for the public authorities?
The costs of applying the emission reduction targets through legislation would be similar as those
under Option 2.
What would be the benefits?
Pellet losses would be similar as in Option 2. As discussed earlier, this will only be achieved in the
medium to long term as it requires adopting a methodological standard for the quantification of pellet
losses, as well as its testing in various sites of different sizes over a significant period (minimum of
12 months). This option, independently from Option 2, only looks at the objective, and not at the
means to achieve it. The measurement and follow up of such spills and losses will not be feasible
without having the methodology (Option 1).
Therefore this measure is not favoured in the short term.
Economic impacts
The economic impacts of this option will be on the pellets value chain. The cost to adapt procedures
and sites would be comparable to Option 2 as similar prevention, mitigation and clean-up measures
would be implemented. However, accurate monitoring following the measurement standard
developed under Option 1 would be needed to ensure that the emissions targets are respected (not
included in Option 2 which focuses on requirements and certification). Also, the public authorities in
Member States will bear additional costs for compliance and enforcement.
Environmental impacts
Environmental impacts will depend on the already avoided losses through measures such as Option
2 or Option 3, but also on the ambition level set. As compliance checks and verification is estimated
to be more difficult, they are expected to be slightly lower than in option 2.
Social impacts
The main social impact is additional job creation mainly for the industry, and some for the competent
authorities, again relatively similar to option 2.
202
Stakeholder views: This option was not discussed by the stakeholders in detail. It was however
mentioned that setting up a performance monitoring system, essential for such as system, would be
costly.
Summary: Defining an EU emission reduction target for pellet losses, once a mandatory standardised
methodology has been developed, tested and applied, can significantly reduce pellet losses as it
requires preventive, mitigation and clean-up measures to be taken. However, this option, in contrast
with Option 2, only looks at the objective, and not at the means to achieve it. Implementation and
enforcement by the Member States seem more challenging than in Option 2. As this option requires
a performance monitoring system first, its implementation would take time. Therefore this option is
not favoured in the short term.
6 SUMMARY OF THE IMPACTS
The table below illustrates the economic costs of implementing the measures and the environmental
benefits of reducing pellet losses for the four options assessed. Other impacts (costs and benefits) are
also presented.
Table 62: Summary of impacts for the four options
Impacts Assessment and considerations Benefit -
cost
Env Eco Soc Cos
t
Option 1 (+) (+) 0 (+) A mandatory standardised methodology benefits all
other options, implying (development and testing)
costs for the sector. It will result in cost savings as
only one method needs to be developed and applied,
also leading to lower verification costs.
High
Option 2 +++ + + --- Mandatory requirements and certification have the
highest reduction in pellet losses, with the highest
direct compliance costs for the sector.
Medium
2a +++ + + -- The reduction of pellet losses is still very high, but
costs are lower than under Option 2 thanks to lighter
requirements for micro-enterprises.
Medium
2b +++ + + - The reduction of pellet losses is still very high, and
costs are lower than under Option 2a thanks to lighter
requirements for micro- and small enterprises.
High
2c ++ + + - The reduction of pellet losses is lower than under the
other sub-options, and costs are only slightly lower
than under Option 2b due to lighter requirements for
micro-, small, and medium-enterprises.
Medium
Option 3 + - 0 -- Improved packaging reduces pellet losses
throughout the supply chain (not quantified), but
generates more GHG emissions (subject to the
packaging type), while entailing potentially quite
high investment costs for the sector.
Medium
- Low
Option 4 ++ + + --- An EU emission target has potentially a high
reduction of pellet losses, as operators have to adopt
preventive, mitigation and clean-up measures, but
the enforcement might be challenging. Its costs are
comparable than those of Option 2. As it depends on
Option 1, it can only be implemented afterwards,
leading to a delay in implementation time.
Low
203
Annex 12:
Impacts on SMEs
1 IDENTIFICATION OF AFFECTED BUSINESSES
This initiative focuses on the unintentional release of microplastics from plastic pellets. Among pellet
producers, the exact number of SMEs is not known because, in Eurostat, the statistics per enterprise
size are aggregated in a broader category including basic chemicals, fertilisers, plastics and synthetic
rubber229
. In this broader category, SMEs account for 24% of the total turnover. As to pellet
converters, according to Eurostat230
, there are 47 710 companies manufacturing plastic products, out
of which 31 400 are micro-enterprises (66%), 15 410 are small companies and medium-sized
companies (32%), and 900 are large companies (2%). In terms of turnover, the micro-enterprises
represent about 4%, while small companies and medium-sized companies account for 52%, and the
large ones for 44%231
. In addition, for the transport and storage sector in the number of companies
(based on Eurostat 2021 data, see calculation in annex 11): 0.4% large are large enterprises, 3%
medium, 16% small and 81% micro.
Regarding plastic producers, large enterprises represent 76%, while medium-sized enterprises 22%
and small enterprises 2% (note: Plastics Europe estimates that there are only large firms). Among the
730 plastic recycler companies in Europe, half of them are SMEs, and there are several micro-
enterprises.
2 GENERAL CONSULTATION OF SMES
The Commission first consulted SMEs through its open public consultation covering six sources,
including pellets. The consultation period started on 22 February 2022 and ended on 17 May 2022,
lasting 12 weeks. Among the respondents from businesses (about 67% of the 411 respondents) to the
open public consultation, 85 were micro, 54 small and 36 were medium-sized enterprises. The closed-
ended questions didn’t have questions specific to SMEs, and they did not respond to the open-ended
questions.
In addition, five virtual stakeholder meetings were organised, where sectoral business organisations
(Plastics Europe, EuPC, and PRE) participated actively. During the meeting dedicated to the
identification of potential measures on pellets, the following possibilities were suggested by the
business organisations:
• Voluntary implementation of EuCertPlast to prevent pellet loss by recyclers;
• Voluntary commitment to OCS certification scheme by Plastics Europe and EuPC;
• Compounding, masterbatch and converting industry’s voluntary commitment to minimise
pellet losses;
• Use existing waste legislation, where appropriate, to require that pellet handling sites have
adequate measures to prevent plastic pellets from being released to the environment;
229
NACE code [C201]: Manufacture of basic chemicals, fertilisers and nitrogen compounds, plastics and synthetic
rubber in primary forms
230
[C222] Manufacture of plastics products (not sure if it covers only convertors or other plastic product manfacturers)
231
EuPC
204
• Development of universal information leaflet and labelling for packaging of plastic pellets;
• Development of best practice guidelines; and
• Awareness raising and training of the personnel.
Stakeholders consistently highlighted the need for financial support for SMEs. During bilateral
discussions with umbrella organisation EuPC, limited resources were indicated as a barrier to
implementing the voluntary OCS certification.
3 TARGETED SME CONSULTATION
3.1 Summary of the results
A second consultation targeting SMEs that are handling plastic pellets (producers, converters,
recyclers and transporters/logistics) took place via the Enterprise Europe Network from 26 January
to 23 February 2023 in all EU languages. Based on the 330 replies received by 23 February 2023, the
following analysis was made:
• The survey included the following list of nine individual pellet management measures:
1) Get expert advice
2) Undertake external audit/certification
3) Monitor and report annual quantities
4) Use airtight, puncture resistant packaging
5) Have specific equipment
6) Train staff
7) Establish rules and procedures
8) Have specific protocols
9) Identify the risky locations and processes
• Respondents were asked to indicate whether they implemented these measures in their company,
whether they deemed these measures effective to reduce pellet losses, and whether they would be
in favour of making these measures mandatory. For seven measures, a majority was in favour
of making them mandatory under the condition that requirements are lighter for smaller
companies (Figure 18). This was however not the case for: (1) the training of staff (more than
50% are in favour of making this mandatory in any case); and (2) external auditing (49% are
against making it mandatory in any case).
• Respondents were also asked to estimate the costs of the nine pellet management measures, as
well as total combined costs of reducing pellet spills and losses. The analysis of these estimated
costs shows a significant burden for micro and small companies, as well as companies with
capacities below 1 000 t (see Table 63). Important note: as shown in Table 65 and Table 66, there
is some correlation between the company size and the tonnage capacities, however, there is no
perfect correlation; some micro and small companies indicate plastics processing capacities above
1 000 or even 5 000 tonnes per year while some mid-sized or large companies indicate capacities
below this threshold. Among the nine pellet management measures, the use of specific equipment
and of specific packaging232
are identified as the most costly.
• A large majority (86%) of respondents indicated that plastic pellet management is dealt with
as an important or priority matter in their company (Figure 16: Behavioural profile of
respondents on plastic pellet management). Six pellet management measures233
out of nine can be
232
i.e. airtight, puncture resistant and /or environmentally sealed packaging to transport and store pellets
233
i.e. measures related to procedures and protocols, and staff training
205
considered consensual (i.e. more than two-thirds of respondents do them “always” or “often”,
consider them effective and could accept some mandatory requirement – see Figure 16, Figure 17
and Figure 18). However, there is no such consensus on the measures related to monitoring234
and external auditing235
(as well as expert advice236
) (see Figure 16, Figure 17 and Figure 18).
This is coherent, as 67% of respondents do not quantify the spills and losses in their company
(only 30% do so – see Figure 19) and only 22% of respondents have some mandatory
environmental auditing scheme in place (while 38% have a voluntary one and 30% don’t have any
auditing – see Figure 21).
• The specific case of equipment237: over two-thirds of respondents indicated having specific
equipment to reduce pellet losses in their company (“always” or “often”) and consider this
measure to be effective, but views are mixed on whether this measure should become mandatory
(28% of respondents consider it should remain voluntary, 27% think it should be mandatory and
33% mandatory with lighter requirements for SMEs). This is coherent as this is a measure which
respondents estimated as costly. Besides 25% of respondents mention a “lack of financial
resources to buy equipment” as a barrier preventing their company from taking action to reduce
pellets losses, and 52% mention “financial support (e.g. to invest in specific equipment)” as the
measure that could help them the most (Figure 19 and Figure 20).
The specific case of packaging238
: while two-thirds of respondents consider the use of specific
packaging effective to reduce pellets losses, only 54% do it always or often (and a third never
does it or has no opinion). Views on whether this should be mandatory are mixed(33% in favour,
20% in favour if lighter requirements for SMEs, and 27% against), while the use of specific
packaging is estimated as the most costly measure both in person/days and euros/t/year (Table
64).
• Barriers preventing respondents from taking pellet management measures fall into three main
categories (Figure 19): lack of staff/time (55% of respondents), lack of information on risks and
solutions (50%) and lack of financial resources (48%). Financial support comes first as a support
measure that could best help respondents (Figure 20), followed by measures to improve
information (standardised method to assess spills and losses, courses and material, workshops)
and assist respondents (external expertise).
• 60% of the respondents have some external environmental auditing scheme in place
(voluntary or mandatory), and out of these, 61% think this would probably make it easier or
cheaper for them to implement an audit on pellets. In other words, 37% of respondents (61% of
60%) can reasonably expect a limited cost of a new audit on pellets (Figure 21 and Figure 22).
• 71% of respondents know Operation Clean Sweep (OCS) and implement it or intend to do so, and
9% have another similar programme (the most mentioned being the IK voluntary programme
‘Zero Pellet Loss’ in Germany). This means 80% of respondents take or intend to take action
to reduce pellet losses. However, among these 80%, 24% of respondents, who currently
implement OCS, do not indicate their intention to continue implementing OCS Europe in the
future (Figure 25).
234
“Monitor and report annual quantities of spills and losses, including spillage incidents”
235
“Undertake external audit/ certification / inspection on spills and losses”
236
“Get expert advice on the risks and good practices for our company”. This measure is not considered to be made
mandatory.
237
Equipment to reduce pellet spills and losses (e.g. dust remover, vacuum cleaners, protective barriers etc.)
238
Airtight, puncture resistant and /or environmentally sealed packaging to transport and store pellets, e.g. thicker plastic
bags, rigid plastic packaging or well-sealed octabins.
206
Figure 16: Behavioural profile of respondents on plastic pellet management
Figure 17: General opinion of respondents on the efficiency of plastic pellet management measures
0 20 40 60 80 100
Identify the risky locations and processes
Have specific protocols
Establish rules and procedures
Train staff
Have specific equipment
Use airtight, puncture resistant packaging
Monitor and report annual quantities
Undertake external audit/ certification
Get expert advice
% of respondents who do it... (n=330)
Always Often Sometimes Never N/A
0 20 40 60 80 100
Establish rules and procedures
Identify the risky locations and processes
Train staff
Have specific equipment
Have specific protocols
Use airtight, puncture resistant packaging
Get expert advice
Undertake external audit/ certification
Monitor and report annual quantities
% of respondents who think this is... (n=330)
Very/quite effective N.A Not/not very effective
207
c
Figure 18: General opinion of respondents on the importance of possible plastic pellet management
measures
Figure 19: Barriers preventing respondents from taking pellet management measures
Among the other difficulties mentioned, we find a recurring statement around the lack of awareness
(internally or among value chain partners). And the various following items: varied packaging
formats from suppliers, damaged packaging, externalised storage /transport, difficulty to identify
pellet containers among other containers, difficulty to measure the spills and losses, lack of space,
lack of suitable equipment and technology solution.
0 20 40 60 80 100
Train staff
Identify the risky locations and processes
Have specific protocols
Establish rules and procedures
Use airtight, puncture resistant packaging
Have specific equipment
Monitor and report annual quantities
Undertake external audit/ certification
% of respondents who think this should be...
(n=330)
Mandatory Mandatory but lighter for SMEs N.A. Voluntary
208
Figure 20: Support that would best help respondents
Figure 21: Respondents in percentage having external environmental audits in place
3
20
22
25
30
32
33
47
51
52
Other
List of certified supply chain partners
Recognition of voluntary efforts
Additional information on risks
Training courses
External expertise
Meetings/workshops with similar companies
Material to inform/train staff
Standardised methodology to quantify spills and losses
Financial support
Support that would best help respondents
(%, n=330)
38%
22%
30%
10%
Yes, voluntary Yes, mandatory No N.A.
% of respondents who have external
environmental audits in place (n=330)
209
Figure 22: Audit on pellets with external review in place
3.2 Details of the results: analysis of estimated costs
Respondents were asked to estimate the costs in person/days and euros/year of the nine pellets
management measures tested in the survey, plus the total combined costs of reducing pellets spills
and losses in their company. The estimates show large variations, probably because respondents
have a different understanding of the extent/depth of the measures to implement, plus they are starting
from different levels of pellets management. For example, companies that replied “we implement
OCS and will implement OCS Europe”, i.e. companies that probably have already taken substantial
action to reduce pellets losses, have estimated substantially lower investment costs for equipment in
comparison with other respondents (this suggests they have likely already made investments). A
company’s organisation can be another factor. An extreme example comes from a large French
recycler who estimated a total annual cost of EUR 950,000 and explains it as follows: “we have nine
sites that handle plastic pellets overall. In question 9, we did a global estimation where the total
estimated cost is the one of the first year (implementing operational procedures/systems). For the
person/days/year value, we estimated 1 person per site (9 persons in total) on 220 days. This value
includes all the staff involved in a year: QSE, risk analysis, training, audits, controlling, cleaning,
equipment maintenance, etc.”
3.2.1 Total cost of all actions to reduce pellet losses (combined cost)
The average total cost (combined cost) is 115 person /days per year (Table 63). The larger the
company, the higher the person/days (which is coherent, due to the larger operational perimeter).
However, the burden is proportionally more significant for micro and small companies, considering
their limited staff. The average absolute cost is 106 404 euros per year (72 895 when retreated239
).
The burden seems very significant for companies with a capacity below 1 000 tonnes (Table 63)
(this might also be due to estimated investment costs which should be amortized over several years
for a more accurate cost estimation) and significant for companies with 1 000 to 5 000 tonnes
capacity (accounting for 1 - 4% of their total sales), although the number of replies is insufficient for
239
i.e. when removing very high or inconsistent values (e.g. negative/nil values)
25%
36%
14%
7%
12%
7%
Very likely Quite likely Not very likely Not likely at all I don't know No Answer
As you have external review in place, will it be easier and
more affordable to do an audit on pellets? (%, n=199)
210
this latter category to ensure definitive interpretation. The cost per tonne becomes insignificant
beyond this 5 000 tonne threshold. If we assume a selling price of 800-1 800 euros per tonne of
plastics, the extra cost is considerable (3% of sales) for companies processing less than 1 900 to
4 000 tonnes per year, and substantial for companies process less than 5 900 to 13 000 tonnes
per year240. The proportionally higher burden for smaller companies and capacities repeats in
a similar way for all individual pellet management measures (see below).
Table 63: Total cost for all measures (combined cost)
in person days in euros/year/tonne
All data
(n=163)
Retreated*
(n=156)
All data
(n=162)
Retreated239
(n=150)
Average 115 104 Average 984 600
Micro 115 63 0-1kt 2513 1612
Small 73 67 1-5kt 27 14
Mid-sized 142 109 5-10kt 3 3
Large 370 183 10-50kt 7 7
>50kt 3 1
* Inconsistent values (e.g. negative or extremely high) have been removed.
3.2.2 Costs per individual measures to reduce pellet losses
The sum of the costs for the individual measures is 262 person days per year, 130 069 euros/year,
and 1 302 euros/tonne processed per year (Table 64). This is higher than the total combined costs
shown in Table 63, which is coherent as many companies only provided estimates for some of the
measures (i.e. they only selected those individual measures most relevant to their business
operations).
Average values are however not very meaningful: more in-depth analysis shows that costs are
considerable or significant for micro and small companies and for companies with capacities
below 1 000 tonnes, and limited for mid-sized companies or even negligible for large companies
and capacities above 5 000 tonnes.
The use of airtight, puncture-resistant and environmental sealed packaging shows the highest
average costs in both person/days and euros/t/y, with estimated significant costs for all sizes of
company (including 55 euros/t for large companies). Having specific equipment to reduce pellets
losses is the other measure with significant costs whatever the company size (including 20 euros/t for
large companies).
240
This is however a calculation on averages, so to be used carefully. It somehow confirms the order of magnitude.
211
Table 64: Detailed estimated costs per measure
Person
days per
year
(average
)
Absolute
costs/y
(average
)
Costs in euros per tonne processed/y
Average
for all
Micr
o
Smal
l
Mid-
sized
<1000
t
<5000
t
Expert advice 12.57 4443 79 94 107 5 217 2
Identify locations & processes 17.63 4371 89 774 69 13 233 1
Monitor 19.10 4905 94 147 36 17 83 1
Train staff 33.09 10 005 108 747 120 7 283 1
Establish rules & procedures 43.56 8680 113 288 131 33 208 2
External audit 41.20 5956 116 514 202 24 314 2
Have equipment 29.12 37 251 186 1664 112 20 528 12
Have protocols 15.98 3554 199 1987 32 15 515 0,8
Use specific packaging 50.01 50 914 318 2426 148 55 822 11
TOTAL 262.26 130 079 1302
Colour Cost represents X% of selling price of 1 tonne:
35-133%
11-35%
2-10%
<1%
3.3 Other detailed results
The majority of respondents indicated that it is important (49%) or very important (36%) for their
company to reduce pellet spills and losses (Figure 23); however, only 31% quantify the pellet spills
and losses at their site (Figure 24). 47% currently implement OCS Europe, 24% intend to implement
OCS Europe in the futureFigure 25, and 9% implement another similar programme (Figure 25).
212
Figure 23: Importance of reduced pellet spills and losses
Figure 24: Quantifying pellet spills and losses241
241
The data on estimated quantities of spills and losses are not reliable/exploitable for two reasons: 1) limited number of
replies (36 in total, including 22 converters), and 2) it is unclear whether they indicated estimated quantities of spills
or losses, hence replies show too large variations (e.g. from 0.01% to 33% for converters).
36%
49%
5%
6% 4%
Is it important for your company to reduce spills
and losses? (%, n=330)
Very important, this is a
priority for us
Important, we do our best to
reduce spills and losses
We do it when we can, our
priority remains business first
We don't see this as a major
issue for our company
N.A.
31%
67%
3%
Do you quantify spills and losses? (%, n=330)
Yes No N.A.
213
Figure 25: Views on OCS242
Other comments by respondents: Only 30 respondents submitted additional comments that can be
summarised as follows. While they showed clear interest in good practices for zero pellet loss, the
additional comments suggest general concern about the extra costs and burden associated with new
requirements, leading to a potential disruption of the level playing field for EU companies. One
respondent suggests that mandatory certification would only be acceptable to SMEs if available for
free or at a reduced rate. Two respondents stress the improvement potential of packaging. Two
respondents warned against classifying pellets as harmful under IMO. Two respondents plea for the
OCS part of SQAS (note: the management system in place for transport) to become a recognised
standard.
3.3.1 Profile of respondents
Respondents by country are shown in Figure 26. Regarding their business activity, 25 out of 28 respondents
active in transport are in road transport. 41 respondents indicated an “other” activity, and out of these,
37 specified the following: 10 converters, 11 service providers (transport sector, consultancy), 8
companies from other plastics-using sectors (e.g. metal, wood, fertilisers), 3 waste operators, 2
business organisations, 1 distributor, 1 additives manufacturer, and 1 public authority (see Figure
27).
242
The “other similar programmes” mentioned are in-house corporate programmes, ISO14001, EMAS, the IK voluntary
programme ‘Null Granulat Verlust’ (Zero Pellet Loss), “AFNOR certification” and the implementation of the FR
decree (perceived as redundant with OCS, except if OCS prove compliance)
26%
21%
24%
9%
22%
6%
4%
7%
What are your views on OCS? (%, n=330)
We implement OCS
We implement OCS and will
implement OCS Europe
We would like to implement
OCS Europe in the future
We implement another
similar programme
We don't know this
programme
We are not interested in this
programme
Other
N.A.
214
Figure 26: Respondents by country
Figure 27: Respondents by business activity
Figure 28
Per main business activity (%, n=330)
Production of plastic pellets
(virgin)
Converting of plastics pellets
Plastics recycling
Transport of plastic pellets
Storage & handling
(warehousing) of plastic pellets
Other
215
Figure 28: Respondents by company size
311 respondents indicated the annual tonnages they process, see details below in Table 65 and Table
66. Companies that process between 5 000 and 20 000 tonnes/y include 26% of micro and small
companies. Companies processing over 20 000 tonnes/y include 10% of small companies.
Table 65: Average tonnages per size of company
Size of company Number of replies % of replies Average tonnage Lowest Highest
self-employed 2 1% 0 0 0
1-9 31 10% 1140 0 15 000
10-19 29 9% 4261 0 70 000
20-49 73 23% 10 967 0 500 000
50-249 131 42% 52 240 0 3 117 977
>250 45 14% 214 728 0 4 000 000
Table 66: Declared tonnages vs. size of company
Including
Declared tonnage/y Nb of respondents Self empl. Micro Small Mid-sized Large
<1kt 122 2% 22% 43% 28% 5%
1kt<x< 5kt 63 0% 3% 44% 48% 5%
5kt <x<20kt 74 0% 3% 23% 55% 19%
> 20kt 52 0% 2% 8% 50% 40%
0% 5% 10% 15% 20% 25% 30% 35% 40% 45%
Self-employed (no employee)
Between 1 and 9
Between 10 and 19
Between 20 and 49
Between 50 and 249
250 and more
Per size of company (%, n=330)
216
4 MEASUREMENT OF THE IMPACT ON SMES
Option 1: Mandatory standardised methodology to measure pellet losses
The cost of developing a mandatory standardised methodology to measure pellet losses was estimated
to be between EUR 558 000 and 1 674 000. The testing cost of one facility would be about EUR 700
to 1 500 per test which means proportionally greater costs for SMEs and micro-enterprises than for
larger companies. The lower costs are the more likely ones as ongoing OCS+ work can be used as a
basis.
This option will help shed light on the actual volume of losses from SMEs. In the targeted SME
consultation conducted by the Commission in January-February 2023 (see above), a standardised
methodology to assess pellet spills and losses was mentioned by 51% of respondents as a support
measure that could best help them to take action to reduce pellet losses.
66% of plastics converters are micro-enterprises and they account for only 4% of the quantities of
converted pellets. While there is no data on the relationship between pellet loss and company size, it
is likely that micro-enterprises do not account for a significant share of these losses. However, the
costs for smaller companies would be more significant. In the targeted SME consultation, the cost of
monitoring the quantities of pellet spills and losses was estimated to be 19 man/days/year.
Nevertheless, according to REACH restriction, they would still have to report the pellet losses and
having a standardised methodology could simplify the reporting.
Option 2: Mandatory requirements to prevent and reduce pellet losses in a new EU law
The introduction of a mandatory certification scheme for the pellet supply chain as proposed under
the policy Option 2 would have a higher cost impact for micro-enterprises and other SMEs processing
plastic pellets. It would impose concrete obligations on SMEs involved at different steps of the pellet
supply chain, from production to compounding to converting to transport and recycling. These
obligations would be the following:
• Conducting site risk assessments to document pellet handling activities and identify the risk
of spills and losses and their potential impacts. The assessment should identify high-risk areas
and pathways to the external environment and include measures, equipment and procedures
for prevention, containment, handling and clean-up.
• Setting up internal procedures with a zero-pellet loss objective:
- Define roles and responsibilities and routines in case of a pellet spill/loss incident;
- Identify appropriate steps to prevent the reoccurrence of pellet spill/loss incidents;
- Roles and procedures for informing the competent regulatory bodies;
- Instructions for managing the clean-up, the use of clean-up equipment and disposal of
the pellets after an incident in order to prevent impact on the environment; and
- Guidance for good cleaning.
• Employee training and accountability for spill prevention, containment, clean-up and
disposal, including written procedures.
• Regular auditing and performance reporting covering the following aspects:
- effectiveness of the procedures to avoid spills and potential losses into the
environment;
- set intervals to carry out the audits;
- management of any change in the operations of the facility;
217
- compliance with the routine inspection plan inside and outside its physical boundaries
and its effectiveness;
- estimation of the amount of pellets lost per year to track progress towards the objective
of zero pellet loss;
- training and or competence of the internal auditors;
- independence of the internal auditors;
- actions for non-conformities identified in the audits; and
- records of the audits.
The findings of the targeted SME consultation run by the Commission in January-February 2023
indicate a cost between 100 000 and 130 000 EUR/plant on average, with large variations depending
on the company’s business operations and past investments. This might indeed be the case for the
larger firms. This impact assessment calculates the costs for micro-enterprises to around 4 000 EUR,
and 113 000 for the large plants, equally based on figures coming from the converting industry,
formed by many SMEs. Lighter requirements for the smaller firms are proposed.
Option 3: Improved packaging for the transport of pellets
A measure on improved packaging for the transport of pellets means potentially high extra costs.
First, the currently used plastic bags should be replaced by more resistant holders; second, the
automated filling unit of the manufacturing chain would likely need to be adapted or replaced.
Contrary to the cheap price of plastic bags, IBC Container’s pricing ranges from EUR 165 up to
4500243
while HDPE barrels cost EUR 13 to 40244
depending on their specifications e.g. size, material,
type of opening.
In the targeted SME consultation conducted by the Commission in January-February 2023 (see
above), the cost of “using airtight, puncture-resistant and environmentally-sealed packaging to store
and transport pellets” was estimated at 50 man/days/year and 50 914 EUR/year, corresponding to an
average 318 EUR/tonne processed/year. The cost was found to be considerable for companies
processing less than 1 000 tonnes, as well as for micro- and small enterprises, and still significant for
larger companies.
Option 4: EU/national targets to reduce pellet losses
Once a methodological standard for pellet loss assessment is available, an EU (or national) reduction
target for pellet losses could be set, e.g. as an absolute maximum quantity of pellets losses or a
maximum percentage of the processed quantities. Both scenarios imply costs and impacts comparable
to option 2, as similar prevention and mitigation measures would be implemented.
5 MINIMISING NEGATIVE IMPACTS ON SMES
Phased implementation
Phased implementation with a longer implementation period for some companies may give them
more time to adapt and align their compliance actions and investments with their normal business
243
www.ibctanks.com/chemical
244
www.hasdrums.com.sg
218
activities. The costs are slightly reduced where companies have more flexibility to build compliance
into their normal investment cycle.
They could potentially choose to operate their existing facility until the compliance deadline before
replacing it, but the longer-term benefits would be the same.
Size-related exemptions and derogations
Exemptions or derogations could be applied based on:
- the number of employees;
- the annual processing capacities;
- the turnover;
- the EU definitions of micro- and small enterprise245
; and
- a combination of these criteria.
The targeted SME consultation, conducted by the Commission in January-February 2023, suggested
a degree of correlation between company size (micro, small, mid-sized or large) and processing
capacities. The processing capacities tend to increase with size:
- micro-companies who responded to the SME targeted consultation indicated an average
capacity of 1 309 tonnes
- Small companies: 9 446 tonnes
- Mid-sized companies: 50 126 tonnes
- Large companies: 197 245 tonnes
However this correlation between size and tonnages is not perfect: in each size category, there are
companies, including micro and small, that indicated processing capacities above 1 000 or even 5 000
tonnes per year, and some large companies indicated small tonnages (see above).
The targeted SME consultation suggested that the processing capacity of companies (in tonnes per
year) is a key criterion to assess the impact of extra costs related to pellet management on the
profitability. The consultation showed a disproportionate burden and considerable relative costs for
micro and small companies, as well as companies with processing capacities below 1 000 tonnes of
plastic materials per year.
Respondents estimated the total combined costs for implementing all measures at EUR 106 404 on
average. Assuming a selling price per tonne of plastic material between EUR 800 and 1 800, then the
costs would account for more than 3% of turnover for companies processing less than 1 900-4 400
tonnes per year.
In the SME targeted consultation, respondents with capacities below 1 000 tonnes accounted for a
third of all respondents, but only 0.02% of all declared capacities. Respondents with capacities below
5 000 tonnes accounted for 55% of respondents, but only 1.3% all declared capacities.
As a reply to his SME targeted consultation, lighter requirements for micro-enterprises from the scope
of the mandatory certification scheme are part of the preferred option. Marginal quantities of pellets
245
https://single-market-economy.ec.europa.eu/smes/sme-definition_en
219
could be excluded from the scope. The French decree on plastic granulates246
follows a similar logic
where the operators processing less than 5 tonnes of pellets per year are excluded.
The targeted SME consultation also showed that mandatory monitoring of quantities of pellet losses
and mandatory audit would be the least acceptable measures. Lighter requirements can be proposed
for micro-enterprises involved in the production, storage, transport, storage and converting. Also
small enterprises would be required to comply with less demanding requirements and could be given
special assistance.
Financial support
In the targeted SME consultation, conducted by the Commission in January-February 2023, the lack
of financial resources was mentioned by 48% of respondents as a barrier preventing companies from
taking action to reduce pellet losses. Financial support came first as a support measure that could best
help respondents to take action to reduce pellet losses (mentioned by 52% of respondents). The
burden on SMEs could be reduced if Member States provide financial support to certain enterprises
(e.g. micro-enterprises and other SMEs) to help them meet regulatory requirements.
In particular, EU state aid rules allow for:
- state aid with no prior notification to the Commission (“block exemption”) covering up to
50% of consultancy costs in favour of SMEs, 60-70% of training costs, 50-60% (100% in
case of competitive bidding complying with the conditions set out in Article 36(9)) of extra
investment costs for improving environmental protection beyond Union standards in force or
in the absence of Union standards or to comply with Union standards that have been adopted
but are not yet in force at the latest 18 months before their entry into force 247
– the latter two
options seem especially relevant as the preferred option envisages that requirements for
smaller companies could be less demanding or apply at a later date.
- state aid subject to prior notification to the Commission248
covering up to 50-70% of extra
investment costs for projects preventing or reducing pollution in the absence of Union
standards or going beyond Union standards as well as complying with Union standards
adopted but are not yet in force at least 18 months in advance249
.
The financial support can be direct (e.g. loans or support programmes) or indirect (e.g. reduced fees).
This approach would reduce compliance costs for SMEs but increase costs for Member States,
depending on the specific measures adopted.
Non-financial support
The Commission and/or the Member States could provide some other support. In the targeted SME
consultation, lack of staff/time and lack of information on risks and solutions were mentioned as
barriers preventing action to reduce pellet losses by respectively 55 and 50% of respondents.
Coherently, measures to improve information on pellet management (including a standardised
methodology to assess spills and losses, information and training materials, training courses and
246
Décret n° 2021-461 du 16 avril 2021 relatif à la prévention des pertes de granulés de plastiques industriels dans
l'environnement
247
Commission Regulation (EU) No 651/2014 (“General Block Exemption regulation”), in particular Article 18 on
consultancy in favour of SMEs, Article 31 on training aid and Article 36 on investment aids for environmental
protection, including climate protection.
248
Member States may notify to the Commission a scheme (e.g., a national aid measure for SMEs), in which case it
would in principle not be necessary to notify aid for each individual project supported under the scheme.
249
Guidelines on State aid for climate, environmental protection and energy 2022, C/2022/481, Section 4.5 on Aid for
the prevention or reduction of pollution other than greenhouse gases.
220
workshops) came second as support measure that could best help respondents to take action to reduce
pellet losses.
Such support could take the form of advisory services to SMEs. For example, a project could be
supported by the Commission which would:
develop SME-specific guidance and training materials and tools to help compliance with the new
legal requirements. It is essential that these materials and tools are first tested with SMEs, before
being rolled out, to ensure they are clear and relevant to SMEs;
deliver advisory services, e.g. through the Enterprise Europe Network and/or in cooperation with
the relevant business organisations, to help SMEs understand the new legal requirements and
prepare for compliance; and
establish a help desk/expert pool (5-6 contact persons with in-depth expertise of the new legal
requirements and the compliance solutions) to assist first-level advisers and deal with more
difficult questions or issues.
Such support can be open to larger companies but SMEs should be the primary targets, as they have
fewer resources to understand and implement abatement technologies. This option would however
incur costs for the competent authorities and/or the Commission (a first estimated budget could be
around EUR 1 Million for a first project covering points 1 to 3 above).
221
Annex 13:
Prodcom codes used to quantify pellet production, export and import into
the EU in 2020
Item PRODCOM
code
Linear polyethylene having a specific gravity < 0,94, in primary forms 20161035
Polyethylene having a specific gravity < 0,94, in primary forms (excluding
linear) 20161039
Polyethylene having a specific gravity of >= 0,94, in primary forms 20161050
Ethylene-vinyl acetate copolymers, in primary forms 20161070
Polymers of ethylene, in primary forms (excluding polyethylene, ethylene-vinyl
acetate copolymers) 20161090
Expansible polystyrene, in primary forms 20162035
Polystyrene, in primary forms (excluding expansible polystyrene) 20162039
Styrene-acrylonitrile (SAN) copolymers, in primary forms 20162050
Acrylonitrile-butadiene-styrene (ABS) copolymers, in primary forms 20162070
Polymers of styrene, in primary forms (excluding polystyrene, styrene-
acrylonitrile (SAN) copolymers, acrylonitrile-butadiene-styrene (ABS)
copolymers) 20162090
Polyvinyl chloride, not mixed with any other substances, in primary forms 20163010
Non-plasticised polyvinyl chloride mixed with any other substance, in primary
forms 20163023
Plasticised polyvinyl chloride mixed with any other substance, in primary forms 20163025
Vinyl chloride-vinyl acetate copolymers and other vinyl chloride copolymers, in
primary forms 20163040
Polymers of halogenated olefins, in primary forms, n.e.c. 20163090
Polyacetals, in primary forms 20164013
Polyethylene glycols and other polyether alcohols, in primary forms 20164015
Polyethers, in primary forms (excluding polyacetals, polyether alcohols) 20164020
Polycarbonates, in primary forms 20164040
Polyethylene terephthalate in primary forms having a viscosity number of >= 78
ml/g 20164062
Other polyethylene terephthalate in primary forms 20164064
222
Unsaturated polyesters, in primary forms (excluding liquid polyesters,
polyacetals, polyethers, epoxide resins, polycarbonates, alkyd resins,
polyethylene terephthalate) 20164080
Polyesters, in primary forms (excluding polyacetals, polyethers, epoxide resins,
polycarbonates, alkyd resins, polyethylene terephthalate, other unsaturated
polyesters) 20164090
Polypropylene, in primary forms 20165130
Polymers of propylene or of other olefins, in primary forms (excluding
polypropylene) 20165150
Polymers of vinyl acetate, in primary forms (excluding in aqueous dispersion) 20165250
Polymers of vinyl esters or other vinyl polymers, in primary forms (excluding
vinyl acetate) 20165270
Polymethyl methacrylate, in primary forms 20165350
Acrylic polymers, in primary forms (excluding polymethyl methacrylate) 20165390
Polyamide -6, -11, -12, -6,6, -6,9, -6,10 or -6,12, in primary forms 20165450
Polyamides, in primary forms (excluding polyamide -6, -11, -12, -6,6, -6,9, -
6,10 or -6,12) 20165490
Polyurethanes, in primary forms 20165670
Petroleum resins, coumarone-indene resins, polyterpenes, polysulphides,
polysulphones, etc., n.e.c., in primary forms 20165920
Petroleum resins, coumarone-indene resins, polyterpenes, polysulphides,
polysulphones, etc., n.e.c., in primary forms 20165945
Petroleum resins, coumarone-indene resins, polyterpenes, polysulphides,
polysulphones, etc., n.e.c., in primary forms 20165950
Petroleum resins, coumarone-indene resins, polyterpenes, polysulphides,
polysulphones, etc., n.e.c., in primary forms 20165955
Natural and modified natural polymers, in primary forms (including alginic acid,
hardened proteins, chemical derivatives of natural rubber) 20165960
Petroleum resins, coumarone-indene resins, polyterpenes, polysulphides,
polysulphones, etc., n.e.c., in primary forms 20165965
Reclaimed rubber in primary forms or in plates, sheets or strips 22191000
Other compounded rubber, unvulcanised, in primary forms or in plates, sheets
or strip 22192019
223
Annex 14:
Other sources of microplastics identified but not retained
1 ALL IDENTIFIED SOURCES
At the beginning of the analysis, relevant sources of microplastic releases were identified through
literature review, stakeholder workshops and consultations. The table below summarizes the results
of this exercise as of December 2022.
Table 67: Compilation of sources of microplastics
Source Quantity (tonnes/year) EU
Paints 231 000 – 863 000
Tyres 360 000 – 540 000
Pellets 52 140 – 184 290
Road markings (included in paints) 94 358a
according to Eunomia (2018) (20 000
according to EA study)
Artificial turfs (with granules) 18 000-72 000
Textiles 1 649 – 61 078
Geotextiles 6 000-19 750*
Brake pads 53 000
Detergent capsules 4 140 – 5 980
Fishing gear 478 – 4 780
Biobeadsb
1442
Marine paintsc
(included in paints) 1 194 - – 5 970 according to Eunomia (2018) (probably
grossly underestimated, EA study estimated 223 000)
Agricultural plastics 1 000 d
Shoe soles (data for Denmark) 100-1 000 e
. (5.6%e
of the country’s total yearly
microplastics emissions)
Indoor and outdoor building materials of plastic
(data for Denmark)
80-480 (2.9%e
of the country’s total yearly
microplastics emissions)
Cooking utensils and scouring pads (data for
Denmark)
40-380 (2.2%e f
of the country’s total yearly
microplastics emissions)
Cast rubber playground surfaces (data for
Sweden)
16 (0.12% - 0.15%g
of the country’s total yearly
microplastics emissions)
Artificial grass (data for Sweden) 2.4 (0.022% – 0.017%g
of the country’s total yearly
microplastics emissions)
City Dust Not quantified in Europe
Telephone poles and railway sleepers Not quantified
Shipping Not quantified
Cooling water Not quantified
224
Plastic balls used in soft gun games Not quantified
Macroplastics Not quantified
*: This figure is probably a factor 10 too high, see the section on geotextiles (annex 15) for more explanation.
a: Extrapolated from German data,250
neglecting the fact that not all Member States use sludge as a fertilizer
(Germany represents 14% of agriculture production in the EU in value and emits 8380 tonnes of microplastics from
sewage sludge, so 8380/0.14 = 59 857 tonnes).
b: UK data is thought to represent EU data given that the uptake of Biobeads for waste water treatment in the EU is
limited.
c: Recent study suspects a gross underestimation of marine paints emissions to the environment, to the point of
questioning the 80/20 ratio of microplastics emissions coming from land or water sources.251
d: Extrapolated from German data250
(Germany represents 14% of agriculture production in the EU in value, and
uses 139 tonnes of mulching plastics, so 139/0.14 = 1000 tonnes).
e: Calculated using the mean emission of microplastics for that source and the mean total microplastics emission for
Denmark: 9 700 tonnes per year.252
f: Emissions from textile clothes are included in the estimation but should be included in the textile emissions, the
quantities released thus are lower than in the table.
g: Calculated using total microplastics emissions of 10 437 – 13 457 tonnes per year in Sweden253
In Table 67, the results are summarised and ranked according to their contribution to EU
microplastics pollution. The emissions are not given in g per capita because it would not be a good
metric since citizens' habits and industry practices vary widely in the EU. The “ranking” provides
information on the place in the emission hierarchy of microplastic emissions for each source using
the higher estimate of the said contribution to get a worst-case scenario analysis.
The following sources were not retained in our analysis due to a lack of sufficient information being
available.
2 SOURCES NOT RETAINED FOR ANALYSIS
2.1 Fragmentation of ‘macro’ plastics in the environment
In Europe, nearly 26 million tonnes of plastic waste is produced each year254
. Substantial
bibliographical evidence exists on the large accumulation of debris in European seas, sea floors, and
coasts. Different environmental factors such as radiation, heat and mechanical stress lead to the
250
Nabu.De, 2021, https://www.nabu.de/imperia/md/content/nabude/konsumressourcenmuell/210521-
fraunhofer_oekopol_studie_plastik_landwirtschaft.pdf. Accessed 15 Oct 2021.
251
Turner, Andrew. "Paint Particles In The Marine Environment: An Overlooked Component Of Microplastics". Water
Research X, vol 12, 2021, p. 100110. Elsevier BV, doi:10.1016/j.wroa.2021.100110. Accessed 14 Oct 2021
252
Lassen, C., S. Foss Hansen, K. Magnusson, F. Norén, N. I. Bloch Hartmann, P. Rehne Jensen, T. Gissel Nielsen and
A. Brinch, Microplastics - Occurrence, effects and sources of releases to the environment in Denmark, 2015
253
"Mikroplast Från Gjutet Gummigranulat Och Granulatfria Konstgräsytor". Ivl.Se, 2021,
https://www.ivl.se/publikationer/publikationer/mikroplast-fran-gjutet-gummigranulat-och-granulatfria-
konstgrasytor.html. Accessed 14 Oct 2021.
254
EU Plastics Strategy, 2018 (https://environment.ec.europa.eu/topics/plastics_en).
225
fragmentation of larger plastic objects or macroplastics.255
The resulting microplastics are referred to
as secondary microplastics, as opposed to primary microplastics which are plastics manufactured
deliberately in micron-scale sizes.
Maritime plastic litter (including fishing nets), mismanaged plastic waste and macroplastics, and
discarded plastics, can therefore be sources of microplastics due to weathering, photolysis, abrasion
or microbial disintegration. Indeed, in principle, all macroplastics sooner or later degrade into
microplastics.
The fragmentation of macroplastics results in a continuous increase of secondary microplastics in the
environment. In addition to the environmental factors, the fragmentation rate also depends on the
type and composition of macroplastics. Fragmentation must be taken into account when assessing
the long-term presence of microplastics in the environment.256
There is still an important distinction to be made. Macroplastics, when found in the environment, can
fragment in pieces and ultimately end up as microplastics. In this case, it is first the macroplastic that
is discarded into the environment, and therefor policies aiming at reducing discarding these
macroplastics should prevail.
It is also possible that microplastics are released directly, for instance due to the abrasion of the use
of larger plastics, or due to mishandling (e.g. of pellets). This is called the unintentional releases of
microplastics, which is the focus of this analysis.
Combating the issue of macroplastics that are littered or found in the environment requires upstream
policies preventing them from being thrown into the environment, and then solutions to remove those
already in situ. Similarly, the issue of macroplastics’ degradation should be handled before they
degrade into microplastics as existing solutions to remove microplastics are very complex and costly.
Macroplastic pollution is dealt with by various existing and forthcoming policy instruments so
macroplastics as a source of microplastics fall outside of the scope of this IA.
Currently, the following EU-level actions target macroplastic pollution:
- The Plastic Bags Directive (Directive (EU) 2015/720), an amendment to the Packaging &
Packaging Waste Directive, targets the use of lightweight plastic bags which have a wall
thickness below 50 microns. Member States are required to adopt measures either reducing
the annual consumption of lightweight plastic carrier bags or preventing these bags from
being provided free of charge.
- The Single-Use Plastics Directive (Directive (EU) 2019/904) targets macroplastic pollution
by ensuring that single-use plastic products, for which more sustainable alternatives are
available and affordable, cannot be placed on the market. It also applies to products made
from oxo-degradable plastic and fishing gear containing plastic. Specific targets on single use
plastics include a 77% separate collection target for plastic bottles by 2025, increasing to 90%
by 2029, and incorporating 25% of recycled plastic in PET beverage bottles from 2025, and
30% in all plastic beverage bottles from 2030.
255
Gomiero, A., Pierluigi S. & Fabi, G., ‘From Macroplastic to Microplastic Litter: Occurrence, Composition, Source
Identification and Interaction with Aquatic Organisms. Experiences from the Adriatic Sea’, 2018
(https://www.intechopen.com/chapters/63956).
256
Gomiero, A., Pierluigi S. & Fabi, G., ‘From Macroplastic to Microplastic Litter: Occurrence, Composition, Source
Identification and Interaction with Aquatic Organisms. Experiences from the Adriatic Sea’, 2018
(https://www.intechopen.com/chapters/63956).
226
- The Waste Framework Directive (Directive (EU) 2008/98) establishes the waste hierarchy,
placing the priority on waste prevention. Plastics fall within the scope of this Directive and
Member States were required to set up the separate collection of plastics in order to ensure
50% of this waste stream was prepared for re-use and recycling by 2020.
- The EU Water Framework Directive (Directive 2000/60/EC) and the Marine Strategy
Framework Directive (Directive 2008/56/EC) are also of relevance to macroplastic pollution
as they should prevent litter from entering the marine environment. The MSFD also comprises
regular monitoring and assessments of marine litter (including macro- and microlitter) in the
marine environtment, putting in place measuses to achieve or maintain the good
environmental status.
- From 1 January 2021, new EU rules apply also to shipments of plastic waste, including
exports from the EU, imports into the EU and intra-EU shipments. These rules should help
cut down on pollution by ensuring plastic waste is only traded if parties have proved they are
able to deal with it properly.
- In March 2022, the EU was instrumental in the adoption of a resolution for negotiations on a
legally binding global agreement. This agreement will establish an international instrument
to prevent plastic pollution throughout the entire lifecycle. The EU is committed to ensuring
this instrument focuses on upstream measures.
- On 30 November 2022, the Commission made a proposal for a new Packaging and Packaging
Waste Regulation. By revising the existing Packaging and Packaging Waste Directive, the
Commission hopes to reduce the generation of packaging waste, with a particular focus on
plastic-containing packaging.
- The Port Reception Facilities Directive (EU) 2019/883) deals with waste coming from ships.
2.2 Sewage sludge
The microplastics emitted by sewage sludge are not generated by the sludge itself but accumulated
there from other sources. Most of microplastics emitted in households (textile microplastics during
washing and personal care product microbeads in majority) and those released on urban roads (tyre
and brake pad wear particles, pellets when accidents have occurred) end up in wastewater treatment
plants to undergo treatment before release to the environment. Indeed, there, microplastics will be
separated from the inlet stream and caught in the sewage sludge. The microplastics quantities in the
sludge are significant (it was estimated that 8380 tons of microplastics are released yearly from the
use of sewage sludge as fertilizer in Germany alone) and are toxic due to the biofilms that develop
on their surface since they are in contact with a high concentration of organic matter, microorganisms
and bacteria within the sludge.
Since sewage sludge is used as fertilizer and that Germany represents 14% of the EU’s total
agricultural production (in value), an estimation of the total amount of microplastics emitted from
sludge spreading as fertiliser in Europe is: 8380/0.14 = 59857 tons/year. However, this is likely an
overestimate since not all countries spread sludge to fertilise their crops and that in countries where
they do, the agricultural method differ and so may require different quantities of sludge to be spread.
It is estimated that about half of sludge from urban wastewater treatment ends up on agricultural land.
However, the microplastics emitted by wastewater sludge are not generated by the sludge itself but
rather released by it after having been accumulated there from other sources. This makes wastewater
sludge a sink of microplastics and so the best way to reduce emissions of microplastics from sludge
is through preventing microplastics from reaching the wastewater treatment plant altogether. Hence,
sewage sludge is considered a pathway and not a direct source of microplastics.
227
Moreover, there is already a legislation regulating sewage sludge application in agriculture – the
Sewage Sludge Directive. The issue of microplastics will be dealt with by the future revision of the
Sewage Sludge Directive and also the UWWTD.
2.3 Brake Pads
The impact of brake pads is difficult to assess because of the impossibility of distinguishing them
from other particles. Indeed, they are emitted at the same time as tyre wear particles, road wear
particles, and road marking particles. Moreover, they are smaller particles mostly emitted to the
atmosphere112
, rendering them even harder for the sample and thus quantify. Given the quantity of
microplastics emitted by brake pads and their potential adverse effects on human health, and the
uncertainties on the scale of the emitted quantities, it is recommended to have further research into
microplastics emitted from brake pads in order to have more reliable numbers before further action
can be undertaken. Further, the increasing penetration rate of electric vehicles will dramatically
mitigate emissions from brake pads and disks. Electric vehicles, in fact, have a regenerative breaking
system recovering the kinetic (when slowing down) and gravity (when going downhill) energy,
recharging the battery. An average EV, used on a mix path, recovers between 15 and 25% of energy
in this way. Brake pads usually last 4 times more in electric vehicles, compared to internal
combustion ones and disks usually last even more than the vehicle itself.
2.4 Artificial / synthetic turf
Artificial / synthetic can be divided into two categories:
• Artificial turfs containing infill material;
• Artificial turf not containing infill materials (can also be called artificial grass); the same
material is used as artificial grass with and without the granulate infill material.
Synthetic turf is typically used in regions with rainy or extremely dry climatic conditions.
Microplastics from infill material: In order to keep the synthetic fibres in an upright position and
provide the desired elasticity of the field, granulates are often used as infill. This practice is typical
for synthetic football and synthetic rugby pitches.
The total emission from microplastics generated from artificial turfs was between 18,000-72,000 tons
per year. As per the ECHA dossier dated 11th June 2020, 16,000 tons of microplastics are released
per year from artificial rubber granules used as infill in synthetic turf sport pitches. The dossier states
that these are the largest contributors at European level in terms of both quantities of intentionally
added microplastics used and released to the environment. The Commission proposal for a restriction
on intentionally added microplastics includes a ban for the use of granular infill in artificial sport
surfaces, with a transitional period of 6 years. The proposal is currently being discussed in the
REACH Committee and could be adopted in the first half of 2023, after a positive vote in the
Committee and the scrutiny by Council and Parliament. Since infill material is an intentionally added
microplastic is out of the scope of this assessment.
Microplastics released from wear and tear of artificial grass fibres and granulates: Besides the
infill material itself, which is a source of releases of primary microplastics, secondary microplastics
may be formed from wear and tear of the artificial grass fibres with a typical straw length of 3-6 cm.
The synthetic grass mostly consists of plastic fibres attached to a perforated polypropylene or
polyester fabric. A latex-based glue is applied to the fabric, which is then cured. Infill is used between
the fibres in order to stabilise the fibres as well as to achieve the desired functionality.
228
Wear and tear from the granulates may also occur. The use of ethylene-propylene-diene-rubber
(EPDM) for playgrounds, school grounds and sports facilities is also increasing, and their wear and
tear may also release microplastics.
Very little information was found regarding these sources of microplastics.
2.5 Cast rubber surfaces for playgrounds
These surfaces are used to cover playground areas in outdoor facilities, schools and running tracks.
They are made of rubber granules made of either newly manufactured ethylene-propylene-diene-
rubber (EPDM) or recycled SBR from old tyres and bonded with a polyurethane-based adhesive.
Very little information was found regarding these sources of microplastics.
Table 68: Comparison of microplastic releases from different sources
Surface Emissions
(g/m2
*year)
Tons/year
Artificial grass with granules 98 6.9 km2 * 98g / m2/ year = 676 tons / year
Artificial grass without granules 0.4-20 0.451 km2 * 5.3g / m2/ year = 2.4 tons / year
Cast rubber surfaces 0.6-48 1.2 km2 * 13.4g / m2/ year = 16 tons / year
Roads (5500 – 13000 AADT) 56 8 190
Source: Swedish Environment Protection Agency
Hence, artificial grass and cast rubber surfaces should not be priorities of the Commission further
studies. However, the Swedish environment agency points out that extremely emitting cast rubber
surfaces (up to 48g/m2
*year) are low hanging fruits to reduce microplastic releases from these
surfaces and that they should be banned to remove the most polluting surfaces.
Artificial turfs containing granulate infill materials should also not be a priority for the Commission
either since they will be tackled already by the REACH restriction. However, it should be kept in
mind that the restriction is addressing the releases from the artificial infill, not from the artificial
grass.257
Table 69: Microplastic releases from wear and tear of artificial grass
Study Findings
(OSPAR, 2017) 4-6% of fibre release per year. Out of which 0.1-1% is released to surface water.
Estimated release to surface water: 3-42 tons/year for OSPAR countries.
(Ryber et al., 2019) Not identified.
(UN Environment,
2018)
Considered of low importance at global level as the artificial turfs are likely to be
more common in northern countries.
** OSPAR 2017 and EC/Eunomia 2018 consider the Denmark data unrealistic as the average life of
the turf is approximately 10 years.
257
Annex XV addition to REACH Regulation
229
2.6 Fishing Gear
Fishing gear is a big source of marine litter. The microplastic pollution from fishing gear is a result
of:
• Lost or abandoned fishing gear and its subsequent degradation; and
• Weathering of in use fishing gear.
Since fishing gear is a macroplastic already being addressed by the SUP and Fishing Gear Directive
and Port Reception Facilities Directives, it should not be addressed in this study.
Table 70: Microplastic releases from wear and tear of fishing gear
Study Findings
(EC/Eunomia,
2018)
478-4,780 tons/year in the EU.
The report notes that “this estimate is highly speculative, and both the loss rate and
the fishing net data are very uncertain at this stage”.
(OSPAR, 2017) Not quantified.
(Ryber et al., 2019) Identified but not quantified due to lack of data.
(UN Environment,
2018)
Considered important source but could not quantified due to lack of data.
2.7 Agriculture plastics
Plastics are widely used in the agricultural sector, and found in applications such as silage bales, bags
and horticultural foil. As in any sector, there is some loss of material. Weathering and abrasion might
generate small plastic particles from agricultural plastics in use. The particle may be lost to the soil
environment or be transported with the wind. The most likely pathway of releases of plastics from
the agricultural sector is the generation larger pieces of plastics. Such larger pieces might fragment
to smaller pieces generating microplastics in the environment.
The proportion of conventional plastic mulch films that are typically left remaining is not known
(figures in the range of 5-25% are often quoted, but the root of these have no direct link back to a
published scientific study). There is no demonstrable link between common practice resulting in a
particular proportion being left on the field. It is also unclear what is achievable if best practice is
employed and to what extent technological improvements in field removal machinery could achieve.
Anecdotal evidence suggests thicker films will result in less residue, but further study is required to
determine the exact thickness (and therefore strength specification) that would be required.
A recent study258
calculates that if 5-25% mulch film remaining in the fields is averaged across the
EU, the annual use of 83,000 tonnes of mulch film would result in 4,750 -20,750 tonnes of
conventional plastic remaining on agricultural land every year. Several Member States have already
established a collection scheme for these plastics, or are in the process of doing so.
258
Eunomia, 2021. Circabc (europa.eu)
230
Table 71: Microplastic releases from wear and tear of agriculture plastics
Study Findings
(EC/Eunomia, 2018) Identified but not quantified.
(OSPAR, 2017) Not identified.
(Ryber et al., 2019) Identified but not quantified.
(NABU, 2021)23
556 tons/year of plastics for Germany, reduced to 139 tons/year for
microplastics.
(UN Environment,
2018)
Considered of medium importance but could not be identified due to lack of
data.
The amount of microplastics emitted from the agricultural sector is not well quantified, however, the
recent German study indicates that 139 tons of microplastics are emitted yearly in Germany. This
number is to be put in the European context; Germany’s agriculture represents 14 % Europe’s total
production in value in 2019. (A worst-case scenario would be 1 000 tons per year).
The small and uncertain quantity of microplastics released by the European agriculture associated
with its low toxicity may not be significant from unintentional microplastic release perspective.
2.8 City Dust
City dust is a generic name given to several sources that are grouped together because their individual
contribution is small, but they account together for a considerable amount of losses as per some recent
studies. While the UN Environment, study refers to data from IUCN report for calculating the
microplastics generation through city dust, the definition of the city dust varies.
One of the reasons of city dust as a main contributor of microplastic pollution in global studies and
not in the European studies could be attributed to the fact that the losses related to city dust are driven
by population number and regions most associated with this number are Africa, China, India.
Table 72: Microplastic releases from city dust
Study Findings
(Eunomia, 2018) City dust is mentioned in the long list of microplastic sources and includes
indoor dust and road dust only.
(OSPAR, 2017) Mentioned as tyre dust, no quantification found.
(Ryber et al., 2019) Global emissions 500 000 tons/year.
(UN Environment, 2018) Global emissions 650 000 tons/year.
City dust is not a single identified source of microplastics but rather a collection of sources and cannot
be tackled as a single entity. Therefore, to reduce city dust amounts, the efforts could be better focused
on individual sources composing the city dust such as tyre wear particles, textile fibres, combustion
engine particles, etc.
231
Indoor and outdoor building materials of plastic (Floorings, pipes, roof coverings, garden plastic
furniture)
Plasticised as well as hard polyvinyl chloride (PVC) makes up the majority of the plastic building
materials subject to deterioration and weathering. The main sources are believed to be flooring,
roofing and gutters
While indoor microplastics releases typically go to the municipal sewage system, the outdoor parts
are likely to release to the soil, surface water and urban run offs (entering the municipal sewage
system and/or going direct to the local environment).
Table 73: Microplastic releases from indoor and outdoor building material of plastics
Study Findings
(EC/Eunomia, 2018) Mentioned in the long list of microplastic release source. No
quantification found.
(OSPAR, 2017) Not identified.
(Ryber et al., 2019) Included in city dust.
(UN Environment, 2018) Included in city dust.
Although containing flame retardants and other such toxic chemicals, given the lack of reliable
information on the quantity of emissions from these sources, these sources may not need to be
explored further.
2.9 Shoe soles
Soles of footwear are typically made of PVC, polyurethane or synthetic rubber. During wear
microplastics particles are formed. The only finding that quantifies this source is Denmark 2015. The
EC/Eunomia (2018) report refers to the same data.
Table 74: Microplastic releases from wear and tear of shoe soles
Study Findings
(EC/Eunomia, 2018) Identified and quantified only for Denmark.
(OSPAR, 2017) No mention was found except in case of release from shoes after
use of artificial turf.
(Ryber et al., 2019) Included in city dust.
(UN Environment, 2018) Included in city dust.
The data on the quantities emitted by shoe soles is too scarce and too uncertain to enable further
analysis.
2.10 Cooking utensils and scouring pads
Wear and tear in tools, scouring pads and plastic clothes used in kitchens and bathrooms may cause
a release of microplastics directly discharged to sewage.
232
Table 75: Microplastic releases from cooking utensils and scouring pads
Study Findings
(EC/Eunomia, 2018) Kitchen utensils identified in the long list of microplastics.
(OSPAR, 2017) Not identified
(Ryber et al., 2019) Included in city dust.
(UN Environment, 2018) Included in city dust.
The main issue related to microplastic releases from kitchenware are the PFAs emitted from non-
stick pans because of their toxicity. A potential solution to reduce the danger represented by these
emissions could be to enforce a ban of these substances from kitchenware. The lack of information
on the potential released quantities of microplastics makes it difficult further analysis.
2.11 Additional sources identified through stakeholder interactions
Telephone poles and railway sleepers
Plastic substitutes to the wooden or concrete telephone poles and railway sleepers were introduced
in 2009. Microplastic releases from railway sleepers might exist especially from wear and tear but
have not yet been quantified.
No information on quantities of microplastic release from these sources were found. Researchers at
the Dutch RIVM are investigating the microplastic releases and will publish their results, thus if
railway sleepers appear to be a significant source of microplastics, it can be considered.
Shipping
Shipping of goods by cargo worldwide is increasing and shipping activities incur losses of containers
to the sea the 3-year average container loss for the period 2017 – 2019 was 779 containers. These
containers can then release their content to the environment, thus (when containing plastics goods
which is often the case) increasing the amount of plastic waste in the oceans. These plastic emissions
although leading to an increase in the quantity of plastics in the sea are not microplastics directly, the
microplastics will be emitted after the weathering of these plastic waste at sea under the conjugated
effects of abrasion, salt water and UV.
As these are not microplastics resulting from the use phase of the materials nor are they manufactured
as microplastics, this source was not assessed in this study. Moreover, legislative instruments are
already in place to limit these emissions. This issue will be addressed with the transport of pellets.
Cooling water
No quantification of the emissions could be found and only one mention of cooling water as a source
of microplastics was found in the scientific literature. Moreover, the Industrial Emissions Directive
will tackle any emissions from the cooling water since it is an industrial effluent. This leads to the
conclusion the emissions are limited and that there is already a legislative framework in place.
233
Plastic balls used in soft gun games
Microplastics from airsoft guns were mentioned in one article as having been identified in
microplastics sampled on a beach. However, there does not seem to be a big amount of these specific
microplastics released into the environment especially since users of these recreational guns are
aware of the potential harm that plastic beads may have on the environment and so the industry and
the users are shifting towards biodegradable pellets.
Given the lack of data combined with the expected low quantity of microplastics emitted from this
source as well as the industry and players’ shift towards biodegradable pellets, this source may not
be relevant to explore further.
Biobeads
Biobeads or biological aerated flooded filter (BAFF) media are pellet like materials used in
wastewater treatment plants for tertiary treatment. The losses occur because of failures of steel mesh
retainers and because of continuous leaks (one the main manufacturer mentions 1% per year as a
possibility but that if operated correctly there should be no losses). It uses polystyrene beads which
are already known to cause microplastic pollution.
From the information provided by the Cornish Plastic Pollution Coalition, the European biobead
pollution seems to be concentrated in the UK, it is possible that this specific type of BAFF medium
is mostly used there. The emissions at that country’s level may require action but they are no longer
under the Commission’s jurisdiction. In any case, these amounts would not justify launching a study
in the near future, however, given the fact that biobeads bear a biofilm, there is a potential health risk
letting them be released. Being emitted from pathways s (wastewater treatment plants) it should be
possible to tackle these emissions with already in place legislative tools such as the Wastewater
Treatment Directive or the Industrial Emissions Directive.