COMMISSION STAFF WORKING DOCUMENT EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT REPORT Accompanying the document Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on preventing plastic pellet losses to reduce microplastics pollution
Date: 2023-10-16
Institutions: Directorate-General for Environment, European Commission
Subjects: carriage of goods, chemicals legislation, environmental impact, handling, plastic waste, plastics, pollution control, prevention of pollution, supply chain

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  EN 

   EUROPEAN COMMISSION  Brussels, 16.10.2023  SWD(2023) 333 final  COMMISSION STAFF WORKING DOCUMENT  EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT REPORT  Accompanying the document Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL  on preventing plastic pellet losses to reduce microplastics pollution {COM(2023) 645 final} - {SEC(2023) 346 final} - {SWD(2023) 330 final} - {SWD(2023) 332 final}  
 
 
A. Need for action 

What is the problem and why is it a problem at EU level? 

Plastic  pellets,  due  to  their  nature  and  size,  are  regarded  as  microplastics.  Microplastic  pollution  is 
increasingly a  source  of  public  and  scientific  concern.  Microplastics  are present  in the environment 
due to (1) the degradation of larger pieces of plastic improperly discarded, disposed of or abandoned 
in  the  environment,  (2)  the  use  of  products  containing  intentionally  added  microplastics  and  (3) 
unintentional  releases  of  microplastics.  This  initiative  aims  to  address  one  source  of  these 
unintentional  releases  following  a  preliminary  investigation  to  identify  and  characterise  the  main 
sources.  

This  initiative  focuses  on  plastic  pellets,  the  umbrella  term  used  to  refer  to  the  raw  material  for  all 
plastic  products  which  can  come  in  different  forms  (pellets,  flakes,  powders,  etc.).  If  lost  to  the 
environment, pellets constitute the third largest source of microplastic released into the environment. 
This  study  estimates  that  between  52  and  184  thousand  tonnes  of  pellets  are  lost  each  year  (2019 
figures).  Once  in  the  environment,  pellets  are  almost  impossible  to  capture,  extremely  mobile  and 
known to be eaten by a range of organisms and animals, causing harm to biodiversity and ecosystems, 
and  potentially  to  human  health.  Pellets  can  disintegrate  into  smaller  particles,  which’s  potential  to 
cause  harm may be even greater due to their higher number and smaller size.  Pellet losses occur at 
every stage of the supply chain (producers, converters, recyclers, transport and storage providers, tank 
cleaning stations) mainly due to poor pellet handling practices and are therefore largely avoidable. 

These poor pellet handling practices are the result of several factors:  

-  There is a lack of awareness throughout the supply chain about the volume of these losses, 

their impacts and how to prevent them;  

-  There  is  no  economic  incentive  to  reduce  pellet  losses,  as  the  damage  caused  is  not 

internalised in the price of pellets; and  

-  There  is  no  current  regulatory  framework  comprehensively  tackling  the  handling  of  pellets 

across the supply chain.  

What should be achieved? 

This initiative makes a substantial contribution to deliver on the commitments made in the European 
Green Deal, the Plastics Strategy, the Circular Economy Action Plan, and the Zero Pollution Action 
Plan. It aims to reduce microplastic-related pollution by preventing and reducing pellet losses to the 
environment that are due to current handling pellet practices. This translates into 3 specific objectives:  

(1)  Reduce and prevent pellet losses to a level consistent with the Commission’s  30% reduction 
target for microplastics released into the environment by 2030 (compared to 2016 levels);  

(2)  Improve information on the magnitude of pellet losses throughout the supply chain; and  

(3)  Ensure  the  appropriate  mitigation  of  impacts  of  related  measures  on  SMEs  involved  in  the 

supply chain.  

What is the value added of action at the EU level (subsidiarity)? 

Pellet pollution is a transboundary issue due to the mobility of pellets in the environment as well as 
the cross-border nature of pellet handling activities and supply chains. National action alone cannot 
address  this  problem,  while  EU-level  action  will  ensure  a  high  level  of  environmental  protection 
throughout the EU.  

EU-level  action  will  prevent  the  fragmentation  of  the  internal  market  by  ensuring  all  operators  are 
subject to the same rules, thus levelling the playing field. It will help cover the entire supply chain and 
will be more cost-effective than sector-specific or national actions.  

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B. Solutions 

What are the various options to achieve the objectives? Is there a preferred option? 

Based  on  a  literature  review  and  stakeholder  input  (to  the  Inception  Impact  Assessment,  the  Open 
Public Consultation (OPC) and the targeted SME survey), four policy options were considered: 

Option 1: Mandatory standardised methodology to measure pellet losses;  

Option  2:  Mandatory  requirements  (based  on  industry  best  practices  e.g.  ‘Operation  Clean 
Sweep’) to prevent and reduce pellet losses in a new EU law, with mandatory certification of 
companies, and 3 sub-options with lighter requirements for:  

2a: micro-companies;  
2b: micro- and small companies;   
2c: micro-, small and medium companies;   

Option 3: Improved packaging for pellet logistics; and 

Option 4: EU target to reduce pellet losses. 

The preferred option was constructed by combining the most cost-effective and appropriate options, 
in  terms  of  their  expected  environmental,  economic  and  social  consequences,  their  administrative 
cost, and their effectiveness, efficiency, coherence and proportionality. 

The  preferred  policy  option  is  a  combination  of  Option  1  (mandatory  standardised  methodology  to 
measure  pellet  losses)  and  sub-Option  2b  (mandatory  requirements  in  a  new  EU  law  with  lighter 
requirements for micro- and small companies). Option 1 will improve information on the magnitude 
of  pellet  losses  throughout  the  supply  chain  (objective  2).  Sub-Option  2b  will  directly  reduce  the 
amount of pellets lost to the EU environment (objective 1) while mitigating any impacts on SMEs in 
the supply chain (objective 3).  

The reduction potential of each policy option was estimated and expressed using a range due to some 
uncertainty around the baseline for pellet losses. However, the comparison of the different options is 
relatively certain as it shows how options rank. 

What are different stakeholders' views? Who supports which option? 

During the OPC, around 80% of respondents agreed that microplastic pollution were hazardous to the 
environment  and  human  health.  A  majority  agreed  there  was  improper  handling  in  current  pellet-
related activities and 87% called for an EU-level comprehensive legislative system for pellet-handling 
companies. 

NGOs  strongly  support  the  establishment  of  harmonised  mandatory  requirements  at  the  EU  level. 
Producers also consider that these requirements would be easy and fast to implement, as long as they 
are  built  on  their  existing  certification  scheme  (Operation  Clean  Sweep).  Recyclers  also  favor  EU-
level  requirements  to  ensure  a  level  playing  field.  Converters,  mainly  made  up  of  SMEs,  reported 
some requirements would be difficult to implement due to limited resources.  

During the targeted SME survey, micro- and small companies indicated that the costs of complying 
with  certain  mandatory  requirements  would  be  too  burdensome  for  them  and  a  majority  of 
respondents named financial support and a measurement standard as support measures that would best 
help them tackle pellet losses.  

The  preferred  option  is  therefore in  line  with  stakeholders’  views  and  should  be  acceptable  to  both 
relevant stakeholders and the general public.  

C. Impacts of the preferred option 

What are the benefits of the preferred option? 

The measures in the preferred option ensure that the entire pellet supply chain within the EU is subject 

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to the same mandatory requirements. It is expected to contribute to a 60-83% reduction in the volume 
of pellets released into the environment (25 – 141 thousand tonnes/year), thus contributing to around a 
quarter of the Commission’s 30% overall reduction target for microplastics releases by 2030. 

The  reduction  in  pellet  losses  benefits  the  environment  and  the  economy  (e.g.  through  increased 
attractiveness  for  tourists  and  more  fishing  harvest  due  to  fewer  pellets  in  the  environment).  In 
addition, it constitutes a precautionary measure against a potential risk to human health. The costs are 
also lower for local communities in affected areas who do not have to finance the clean-up of losses.  

In addition, there is better data on pellet losses available thanks to the measurement standard. 

For businesses, there are some cost savings as they only have to apply one measurement standard, and 
they lose fewer pellets. A level playing field thanks to only one set of mandatory requirements also 
benefits them.   

What are the costs of the preferred option? 

The  proposed  measures  are  expected  to  cost  businesses  an  additional  EUR  376  to  491  million  per 
year, because businesses need to adapt their prevention and reduction measures. Businesses also need 
to  finance  the  external  auditing  and  certification  of  their  measures  and  then  to  notify  public 
authorities. While the measurement standard entails initial adjustment costs ranging between EU 1.3 
and 3.2 million, in the long run its implementation saves businesses money because businesses only 
have to apply one measurement process in order to comply with the  separate  reporting requirement 
under the REACH Regulation on pellet losses.  

Public  authorities  in  the  Member  States  face  some  extra  processing  and  enforcement  costs  as  they 
need to set up a public register of certified companies and ensure compliance with the regulation. This 
however is balanced by savings due to clean-up avoidance. 

Consumers  might  face  a  minor  increase  in  the  cost  of  plastic  products  if  pellet  producers  do  not 
absorb the slight increase in pellet costs.  

What are the impacts on SMEs and competitiveness? 

The pellets supply chain has a large share of SMEs. While producers and recyclers are mostly large 
companies,  around  89%  of  converters  and  around  96%  of  logistics  are  estimated  to  be  SMEs.  To 
evaluate the impact of the preferred option on SMEs, a targeted survey was undertaken. From the 330 
respondents,  a  majority  reported  that  a  lighter  version  of  the  mandatory  requirements  would  be 
acceptable. This was taken on board through the application of sub-Option 2b, which reduces the level 
of  requirements  for  micro  and  small  companies  (e.g.  a  lower  frequency  of  external  auditing,  no 
obligation  to  invest  in  certain  expensive  pieces  of  equipment  or  procedures).  As  requested  by  the 
respondents  to the  survey, the  preferred  option  includes  financial  &  non-financial  support for  these 
smaller  operators  and  lays  out  the  possibility  of  giving  them  more  time  to  adapt  to  the  new 
requirements.   

Regarding the competitiveness of the EU plastic pellets sector more generally, the estimated costs of 
the preferred option represent about 0.13% of the EU plastics sector turnover, therefore not presenting 
a significant threat to the sector’s competitiveness. While the impacts could be more severe for SMEs, 
the lighter requirements for these operators should help mitigate these effects. Measures only apply to 
operations  within  the  EU.  This  will  have  a  very  minor  negative  impact  on  the  international 
competitiveness  of  EU  operators.  However,  EU  operators  will  be  at  an  advantage  if/when  other 
countries  adopt  similar  requirements,  e.g.,  through  an  international  agreement  such  as  the  Global 
Treaty on Plastic Pollution.  

Will there be significant impacts on national budgets and administrations? 

There will be minor costs (EUR 313 000 for the first year and EUR 125 000 per year for the EU) 
associated with the processing of the reporting on external auditing and enforcement of the regulation. 

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Will there be other significant impacts? 

No. 

Proportionality? 

The  assessment  of  this  initiative  showed  that  the  preferred  option  does  not  go  beyond  what  is 
necessary to achieve the objectives of the initiative. It aligns with what industry had indicated would 
be  appropriate  to  effectively  reduce  pellet  losses  and  includes  lighter  requirements  for  micro  and 
small  companies  who  had  indicated  the  necessity  of  this.  The  preferred  option  will  significantly 
reduce unintentional microplastic releases, thus generating benefits for the environment, and possibly 
human health, which outweigh the additional associated costs.  

D. Follow up 

When will the policy be reviewed? 

The  overall  30%  reduction  target  for  microplastics  released  into  the  environment  is  set  for  2030. 
Progress  towards this target  will  be  assessed  every  two  years  (2024, 2026,  2028,  2030) in the  Zero 
Pollution monitoring report. Following the 2030 report, a review of the initiative could take place.  

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