ECHA has now published the Final Opinion of the Committee for Risk Assessment (RAC) and Committee for Socio-economic Analysis (SEAC) on the REACH Annex XV dossier proposing restrictions on
intentionally-added microplastics. Details and response form can be found here, the deadline is 01 September 2020:
https://echa.europa.eu/restrictions-under-consideration/-/substance-rev/22921/term
EOSCA has worked jointly with colleagues at IOGP and stake holders within our membership and the industry to provide the most accurate and complete data possible for our industry.
Through these efforts the industry has managed to ensure that the definitions for microplastics are as relevant and targeted as possible, ensuring that the focus is on the emission of microplastics of concern. Industrial sites and uses will be covered by a derogation from the ban, but labelling, communication and reporting requirements are proposed to keep a check on control of continued uses.
The industry has worked to ensure that the proposed communication and reporting requirements are workable in the industry, and at OSPAR OIC 2019, some of the requirements were foreseen and identification of microplastics in HMCS product registrations is now required on the HOCNF. This step will ensure that the information required to meet reporting requirements will be available in the supply chain.
EOSCA and IOGP are working on position statements and consultation responses, and encourage all members and interested parties to respond to the ECHA consultation at the link above.