ETRA Response to ECHA outlines the challenge ahead in the sector.
ETRA Issues Notice on ECHA-RAC Recommendation
The following is the European Tyre Recycling Association’s announcement on the ECHA-RAC recommendation on microplastics, including crumb rubber.
On June 3rd the Risk Assessment Committee (RAC) of ECHA held a meeting to finalise and approve their Opinion on an Annex XV dossier proposing restrictions on intentionally added microplastics. Regarding infill materials for artificial turf, they adopted the option to ban placing the material on the market after a transitional period of six years.
Some clarifications may help to understand what is happening.
EU published its plastics strategy in February 2018
The Commission’s request to ECHA to develop a restriction proposal for microplastics that are ‘intentionally added’ to consumer and professional products
ECHA proposal was Submitted on 11 January 2019
Public consultation of the report "Restriction proposal on intentionally added microplastics" started on 20 March 2019 and ended on 20 September 2019
After the RAC opinion the next step is the opinion of SEAC Committee which is expected in the Autumn of 2020
What happened last week will impact on the ongoing ECHA process and the final decision, posing serious concerns about the future possibility of using rubber infill materials in artificial turf.
The RAC opinion, based on a wrong calculation of the actual release of rubber granulate into the Environment. It is an extreme solution that risks amplifying the problem instead of reducing and then solving it. As a result, it has been overestimated the impact of infill material on the total quantity of Microplastics released into the environment from other bigger and more dangerous sources, diverting the eyes from these situations to sports fields.
On the other hand the importance of rubber infill material for tyre recycling and the sport sector as a whole should not be used as a justification to tolerate irresponsible, unacceptable behaviour from various actors along the chain, diverting their eyes either.
The magnitude of microplastics issue has been under-evaluated, like it happens with certain big risks that are so dangerous to seem unlikely to happen, but they happen.
The above process started in 2018 and will finish in 2021. For a positive conclusion it is necessary a more responsible and cooperative approach from every part involved. The issue is serious, and time is tight.