Microplastics in coatings, adhesives and sealants: How to be compliant?

 
The 17th of October 2023 the Restriction on Synthetic Polymer Microparticles (SPM), commonly called "Microplastics", has entered into force (Commission Regulation (EU) 2023/2055). The Restriction imposes the ban on placing on the market of SPM on their own or in mixtures, when intentionally added, in concentration equal to or greater than 0,01 % by weight. In order to be identified as microplastics, polymer particles must meet specific morphological, dimensional and chemical-physical characteristics. A guideline for the identification of microplastics as well as for the application of the regulatory requirements is expected to be published in the following months by the European Chemical Agency (ECHA). Understandably, the lack of a published guideline is, for now, cause of concern for the European polymer community, due to the fact that the ban already applies for some market sectors and due to the upcoming regulatory deadlines for others. The new Restriction aims to prevent the release to the environment of about half a million tons of microplastics thus contributing to reduce microplastics pollution by 30% by 2030 in the framework of the Zero Pollution Action Plan. Nevertheless, the new rule will largely impact chemical industries which will have to find eco-friendly alternatives to the microplastics currently added to their products and/or, depending on the market sector involved, will have to meet regulatory obligations. With regards to coatings, adhesives and sealants, inks and construction products, most microplastics will be permanently bound in a solid matrix (film) once correctly applied during end use. According to Paragraph 5 of the Commission Regulation (EU) 2023/2055, those products will not be covered by the ban but will be subject to derogation thus imposing regulatory actions to the companies involved starting from October 2025. For example, in order to be fully compliant with the Restriction, if covered by the Paragraph 5 derogation, suppliers of coatings, adhesives and sealants, inks and construction products containing microplastics will be required to communicate downstream the "Instructions for use and disposal" as well as to notify ECHA on the presence of microplastics on their products. They need to provide data on the polymers like identity, quantities, uses and releases, among others. These regulatory obligations will inevitably generate incremental costs for the industries as well as significant extra-work. Therefore, in order to be prepared for the 2025 deadlines and for the following years regulatory needs, it is important for the industries to be aware of the impact of the restriction on their supply chain and to fully understand the chemical properties and the end uses of their products. The presentation will describe the general terms of the Restriction, will elucidate aspects related to the identification of microplastics and testing strategy for the characterization of the same. Important focus will be given to the understating, practical examples, implications and regulatory obligations for paints, coatings, adhesives and sealants, inks and construction products containing microplastics.