IOGP input to the consultation on restricting the use of intentionally added microplastics

This document provides IOGP’s input to the consultation submitted by the European Chemicals Agency’s (ECHA) on restricting the use of intentionally added microplastics.

Context

Intentionally added microplastic particles are used in a range of products placed on the EU market, such as certain types of fertilizers, plant protection products, leave-on, and rinse-off cosmetic products, household and industrial detergents, cleaning products and paints.

Some chemicals used in applications and processes by the oil and gas industry contain microplastics, as defined by ECHA in the proposed restriction. The usage of such chemicals is relatively modest, and therefore, the potential contribution from our sector to reach the ECHA target will be limited. However, when possible, we are committed to seek available substitutes to decrease microplastics releases to the environment.

Key Points

• We strongly emphasize the need to include a lower size limit in the ‘microplastics’ definition, given the existing analytical and measurement limitations unable to demonstrate that there are no microplastics of very small sizes present and therefore making any subsequent compliance challenging
• We strongly support the derogation from the restriction for “substances or mixtures containing microplastics for use at industrial sites” applicable to all industrial uses of microplastics, including onshore and offshore oil and gas sites
• We strongly recommend that microplastics releases to the environment are incorporated into the already well-established environmental reporting practices under the supervision of the national Competent Authorities, making it more efficient and cost-effective
• We strongly recommend that a reporting deadline for downstream users is aligned with national environmental reporting practices aiming to be the end of May rather than the unachievable end of January

• Introduction
• IOGP key messages
• Oil&Gas industry and sector usage of microplastics
• Definition of ‘microplastics’
• Derogation for ‘industrial site’
• Instructions for use and disposal
• Reporting requirement
• Substitution
• Final Remarks