The European Chemicals Agency (ECHA) has launched public consultation on the restriction dossier for microplastics intentionally added to products.
ECHA Consultation May Have Serious Implications for Tyre Recycling
In the framework of the EU plastics strategy and at the request of the European Commission, the European Chemicals Agency (ECHA) prepared a restriction dossier under the European regulation on registration, evaluation, authorisation and restriction of chemicals (REACH). It targets intentionally added microplastics in products.
The dossier was published on ECHA‘s website on 30 January and passed conformity check in March. ECHA launched a public consultation seeking views and general comments from stakeholders on the dossier, as well as on a number of specific questions.
ECHA‘s restriction dossier provides for a wide-ranging definition of microplastics. It defines microplastics as solid-polymer-containing particles, to which additives or other substances may have been added, and where ≥ 1% w/w of particles have (i) all dimensions 1nm ≤ x ≤ 5mm, or (ii), for fibres, a length of 3nm ≤ x ≤ 15mm and a length to diameter ratio of >3.
The dossier proposes to ban certain consumer and professional uses, while other uses would be subject to labelling/information requirements and annual reporting. Microplastics covered by the dossier have multiple applications, including in agriculture, horticulture, cosmetic products, paints, coatings, detergents, maintenance products, medical and pharmaceutical applications, oil and gas sectors, etc. ECHA has estimated that the impact of this restriction will be significant. Emission reduction obtained through the restriction would amount to 400.000 tonnes of microplastics and cost € 9.4 Billion over the next 20 years.
In terms of tyre recycling this could apply to any end product that uses particles less than or equal to 5mm. The ECHA consider the polymers in tyre materials to be microplastics.
The restriction dossier will now be scrutinised by the risk assessment and socio-economic analysis committees of ECHA as well as by the enforcement forum, including the on-going public consultation. If your sector is affected by the restriction please follow the process closely and submit your contribution during the public consultation. The consultation is open until 20 September 2019, although ECHA encourages early submission to facilitate consideration by the committees.
The ECHA committees will formulate their opinions and send them to the European Commission, expected in spring 2020. It is then up to the Commission to propose to amend the REACH Regulation if the restriction meets the legal requirements.
Note to UK Recyclers – Regardless of Brexit, this WILL impact upon your business, so do respond to the consultation whilst you can.