NGO position paper | REACH registrations should include consideration of polymers’ contribution to micro- and nanoplastics burden in the environment

Summary - Contamination of our environment by micro/nanoplastics is constantly increasing and a growing body of evidence has started shedding light on the diverse harmful effects which could be caused by micro/nanoplastics exposure in living organisms, including people. Despite the growing awareness that failure to address this problem might have catastrophic consequences for environmental and human health, both the industry initiatives and regulatory actions that have been initiated in the EU so far have not yet provided any viable solutions to this problem. Therefore, further regulatory actions are urgently needed. One such option could be to include the consideration of secondary micro/nanoplastics’ problematic into the discussion about the upcoming registration of polymers under REACH. Specifically, generation of micro/nanoplastics should be regarded as an inherent hazardous property of plastic polymers. The extent of micro/nanoplastics generation is influenced by both the physico-chemical properties of a given polymer and the external impacts experienced by the respective material/article during its lifecycle. Based on these characteristics, a polymer’s contribution to secondary micro/nanoplastics burden in the environment could be estimated, followed by a proper risk assessment and decisions on potential risk mitigation actions, where necessary. However, for most polymers currently produced or imported into the EU, even the minimal data necessary for such estimation are currently lacking. Therefore, we suggest that a polymer’s contribution to micro/nanoplastics burden should be addressed by a dedicated criterion when identifying polymers requiring registration, and that data necessary to estimate such contribution should be requested to be routinely submitted as part of a polymer’s (pre)-registration package.

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