For many years there has been an increase in the consumption of plastic. When it’s not disposed of correctly it breaks down into tiny particles that do not biodegrade. It’s a major environmental issue, every year about 42 000 tons of microplastics are released into the Environnement. The European Chemicals Agency (ECHA) has been working since January 2019 on a restriction for products containing microplastics. Listen to our Assurance in Action podcast dedicated to Sustainable Cosmetics to understand better the impact of this coming legislation on the cosmetic industry. Our experts Claire Chaumonnot and Elodie Garnier explain what this restriction is about !
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Hello everyone, welcome to Assurance in Action podcast. Today’s podcast is dedicated to cosmetic industry and is part of our Sustainable Cosmetic series. This episode will be focusing on microplastics.
For many years there has been an increase in the consumption of plastic. When it’s not disposed properly it break down into small particles that do not biodegrade.
And as you must know, It’s a major environmental issue, every year about 42 000 tons of microplastics are released in the Environnement.
In January 2019 the ECHA worked on a restriction for products containing microplastics. This restriction will be examined by the European parliament this year.
The proposal aims to ban microplastics in products such as cosmetics, detergents, fertilisers and other. So According to ECHA, the ban of microplastics would prevent the release of 500,000 tons of microplastics into the environment and this over a 20-year period.
My name is Claire and I am accompanied today by Elodie.
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Hi everyone, and thanks for the introduction. Claire and I are regulatory experts within Intertek Assuris team. As mentioned, the main topic of this podcast will be the microplastic and more precisely, we will focus on the upcoming regulation : the microplastic restriction proposal Annex XV.
First of all, Claire, can you tell us what is a microplastic ?
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Yes, sure. So a microplastic is a material consisting of solid polymer containing particles to which additives or other substances may have been added and where than more 1% into weight of particles have all their dimensions between 100 nanometers and 5 millimeters or for fiber, the length is between 3 nanometers and 15 millimeters and length to diameter has a ratio superior to 3.
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OK, I see. Thank you. This is a wide definition. Now, are there any exemptions maybe to this definition?
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Yes indeed, there are three exemption, so the first one are natural polymers which have not been chemically modified as defined in the Article 3(40) of the REACh regulation. The second one concerns also the biodegradable polymer and finally the third one is the polymer with water solubility superior to 2g/L.
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So if a polymer is biodegradable, it is not concerned by the microplastic definition. But what is really a biodegradable polymer ?
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A biodegradable polymer is a polymer which can be decomposed naturally by microorganism. Several methods exist to measure the percentage of biodegradability during a period and set up an acceptable limit. So the Annex XV mentioned some methods to refer to:
The first method is the OECD 301 or 306. They are methods for ready biodegradable - where we must reach 60% of biodegradability in 28 days. Then we have the OECD 301 and 306 modified that can be extended to 60 days. And finally we have the OECD 302 C of inherently biodegradability, where we must reach 70% of biodegradability in 40 days.
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OK. I better understand. Thank you. And what about the solubility in water, can we measure the water solubility for a polymer?
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Yes, we can and there are test conditions to follow. So we must have a temperature of 20 degrees Celsius, a pH of seven and a concentration of 10g/Liter and the duration of the test is 24 hours. There are also methods that must be used. It is the OECD 120 or the OECD 105 and the substance must be analyzed under conditions closest to their marketing in term of shape, size and surface area, and the test must be carried out under the conditions closest to their marketing tests.
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Very interesting. So if I summarize, we can now evaluate each project in order to know if they contain microplastic. And according the new restriction proposal in Annex XV, the product won't be allowed on the EU market if it contains microplastics. I would like also to highlight a specific point mentioned in the restriction for cosmetics: a microplastic or a mixture containing a microplastic ingredient may be placed on the market if it meets those two conditions: if it is used on an industrial site in paragraph 4(a) and if the physical properties of the microplastic are permanently modified during the end use such that the polymers no longer fulfill the definition of a microplastic. It is mentioned in paragraph 5(b).
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I'm not sure to understand. Could you please give me some more details?
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It means that if the microplastic ingredient loose its microplastic criterion during the manufacturing process of the final product or during the end use then the product containing a microplastic can be placed on the market
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And is it that simple or something else must be done?
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Those two specific points called derogation are subject to reporting and/or labelling obligations managed by the ECHA. It will depend on the derogation and the user of the material if it is for example the manufacturer, the distributor or even the downstream user.
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And what are those reporting and labeling obligations?
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So the the reporting is for industrial downstream user using microplastics derogated from paragraph 4 (a). But also for suppliers placing on the market a microplastic derogated from paragraph 5, for professional or consumer use.
Each year, a detailed report has to be sent to ECHA with some specific points, like a description of the uses of microplastic in the previous calendar year and for each use they need information about the polymer identity and also an estimate of the quantity of microplastic released to the environment.
Regarding the labeling, it is for suppliers of a substance or mixture containing a microplastic derogated from paragraph 4(a), 4(b), 4(d), 4(e) and even 5. The aim of the labeling is to provide any relevant instructions for use to avoid releases of microplastic to the environment.
The instructions must be clearly visible, legible, indelible and in the official language of the Member State where the substance or mixture is place on the market. The use of pictograms is also possible.
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And do you know when this restriction will be published?
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The publication is expected by the end of 2022.
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Ah, OK. So that's really soon.
So as you must have understood it, this restriction will have a huge impact in cosmetics. So it's really important to anticipate it and assess the impact. Not all raw materials containing polymer are microplastics, but it's really important to evaluate through the microplastic definition. Solutions exist to help you with the new coming regulation. So I invite you to contact us if you need support. Thank you Elodie, for this great conversation about microplastic in cosmetic products. And thank you to all of you for listening to us.
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Thanks for listening. Bye.