Input SEAC Microplastics Public Consultation

EPDLA is committed to the protection of the environment and human health and supports efforts to minimize emissions of microplastics. However, it is highly unlikely that dispersion polymers enter the environment in microplastic form and thus, no data on the findings of dispersion polymers as microplastic in the environment are available. All data in the microplastic restriction are based on theoretical calculations on emissions into household waste water and would assume the unrealistic direct emission of household waste water into the environment. Therefore, covering dispersions with the microplastic restriction would create no benefit for human health nor the environment and could lead to substitution by environmentally and toxicologically less beneficial technologies.

Polymer dispersions and lattices are an environmentally beneficial technology that helps to achieve the Commission goal for a less toxic environment.
Polymer Dispersions greatly help reduce Waste and Costs for maintenance by increasing Durability and Useful Life of Products.
Dispersions require specific methods for characterization, especially for the state of matter of the polymer and an adequate lower limit of the particle size to enable the analysis of mixtures.
The beneficial contribution of dispersion technology to e.g. workplace hygiene, indoor air quality and the environment would be counteracted by an inappropriate negative perception of this technology if labelled as “Microplastics”. Such general blacklisting needs to be avoided.
Some markets will move back to environmentally less favorable alternatives using toxicologically dangerous, reactive or solvent based systems to avoid the burden and negative image of a microplastic label. The negative impact to human health and environment would outweigh the benefits of the restriction.
For aforementioned reasons EPDLA believes that polymer dispersions and lattices should be excluded from the microplastics restriction because the restriction of polymer dispersions would not create a benefit for human health and environment but would rather lead to enhanced use of environmentally and toxicologically less beneficial technologies, i.e. regrettable substitutions.