The Confederation of the European Paper Industries supports the aim of the Proposal to restrict “intentionally added microplastics”, but we are concerned that despite the improvements already made during the process, the proposal still contains several issues that require more attention.
Therefore, we do not support the approval of the proposal by the SEAC and RAC Committees as it stands and would ask to amend it considering some concerns explained in this paper
Due to wide scope of the restriction proposal, its potential effects should have been evaluated more carefully during the process. The SEAC assessment should have focused on the proportionality of the restriction proposal towards all industry and other stakeholders that have not been reviewed. REACH obligations apply regardless of the exemptions provided, and therefore all suppliers and users of polymers are bound by these obligations. The industry would be indirectly obliged to perform several new studies to identify the targeted substances, especially regarding the complex biodegradability criteria and the lack of existing studies on the subject. The concrete risk for the EU paper and board making is that our raw materials would fall under the strict reporting requirements for polymers, whereas the imported paper and board volumes containing the same or similar polymers in their recipe would enter the EU market without this administrative burden resulting in an unlevel playing field, displaced risk of micro-plastics and loss of competitiveness of EU industry.
Full statement is available here.