4. Emerging policy intervention and available policy tools to support microplastics mitigation
This chapter documents existing policy action addressing microplastics generated during the lifecycle of textiles and tyres. Secondly, it investigates emerging policy instruments that can be considered to support and advance mitigation action along the lifecycle of products: source-directed, use-oriented, end-of-pipe and end-of-life approaches.
As scientific and public attention on microplastics pollution grows, policymakers are increasingly looking for policy options to better manage current and future environmental and human health risks associated with microplastics. This chapter looks at available policy tools to tackle the challenge of microplastics originating from textiles and tyres, in particular to encourage, incentivise, or mandate the uptake of the mitigation best practices and technologies outlined in the previous chapter. The current state of play on prevailing policy action and industry-led initiatives targeting microfibres and TRWP is outlined in Section 4.2. Then, the chapter discusses selected opportunities to broaden and/or deepen the scope of the existing policy coverage in OECD countries to comprehensively address the challenge at hand. Policy tools are categorised into: i) source-directed approaches (section 4.3.1), ii) use-oriented approaches (section 4.3.2) and iii) end-of-pipe and end-of-life approaches (section 4.3.3).
Several OECD countries have formulated national or sub-national strategies that include measures to address microplastics pollution. Common denominators of existing action plans are, for instance:
the fostering of research on microplastics releases and their potential environmental and human health impacts;
mitigation action to tackle land-based and sea-based sources of marine plastic litter, e.g. waste management policies and single-use plastics policies; and
the regulation of the placing on the market of products that lead to inevitable microplastics leakage, where technological solutions and natural alternatives exist. Notably, an increasing number of countries have banned the use of microbeads in PCCPs (Canada, 2017[1]; France, 2017[2]; GOV.UK, 2018[3]; United States, 2015[4]; Italy, 2017[5]). In the EU, ECHA has proposed wide-ranging restrictions on microplastics intentionally-added to products placed on the EU/EEA market. These are expected to prevent the release of more than 400 000 tonnes of microplastics over 20 years (ECHA, 2019[6]);
For textile-based microfibres and TRWP pollution, policy action has so far focused on providing the foundations for comprehensive and evidence-based mitigation frameworks. In general, existing and planned interventions tend to target several stages of the lifecycle of products. These include facilitating knowledge creation, fostering research, harmonising sampling and characterisation methods and establishing multi-stakeholder information-sharing and collaboration platforms, all of which aim to contribute to the work of identifying and assessing mitigation actions implementable at different stages of the lifecycle of products. More advanced (proposed or implemented) policies generally target mitigation entry points during the use phase, such as household, commercial and industrial laundering. Relevant policy action from governments is presented in Section 4.2.1 and voluntary industry-led initiatives in Section 4.2.2.
4.2.1. Policy action at the national and sub-national level
Several OECD countries have passed (or proposed) legislation primarily aimed at accelerating research, to close knowledge and data gaps on the mechanisms and magnitude of microfibre and TRWP emissions and to identify and assess mitigation measures. Further, as outlined in Chapter 3, the lack of harmonised test methods currently poses challenges for the aggregation and comparison of results on microplastics releases and the effectiveness of solutions. Thus, a number of governments have been mandating or encouraging the development of standardised and harmonised microplastics definitions and methods, including sampling and characterisation methods as well as test standards for tyre tread abrasion and microfibre shedding from products.
Although these measures do not directly contribute to microplastics mitigation, they are essential preconditions for the design, assessment and implementation of evidence-based regulatory, economic and voluntary policy interventions. An example of this is the ongoing work in the European Union to develop a standardised method to measure the tyre tread abrasion rate, based on state of the art available standards and regulations and the work carried out by industry (EU SAM, 2018[7]; EU, 2020[8]). As announced by the European Commission and approved by Regulation 2020/740, the long-term plan is to include the tyre tread abrasion rate into the existing EU Tyre Labelling Scheme, which has been in place since 2012 and currently provides consumers with essential information on the fuel efficiency, safety and noise of tyres placed on the market (EU, 2020[8]).
Existing awareness-raising and consumer education initiatives also contribute to addressing microfibre shedding and tyre wear and help promote “no-regret” mitigation interventions (see Chapter 5). In the case of textile use for instance, less frequent and shorter laundry cycles, low temperatures and the use of softeners can mitigate microfibre emissions, in addition to reducing households’ energy and water consumption and improving the durability of garments. Consumer education and awareness-raising initiatives aim to influence consumer behaviour towards the uptake of best practices for the sustainable use of products. In addition, raising awareness can also lead to further public acceptability for policy action and increased civil society pressure on brands in the fashion and apparel sector to take industrial action.
The US State of Connecticut mandated via the “Act Concerning Clothing Fiber Pollution” the formation of a working group charged with formulating best consumer practices and with educating consumers on the topic of microfibre pollution. Consumer information messages may also be embedded in broader emerging initiatives aimed at fostering behavioural change towards environmentally beneficial practices for product use and maintenance. An example of this is the Swedish #Textilsmart# information campaign, which advises consumers on how to render their textile consumption more sustainable, including with information on microplastics shedding and prevention measures they can implement at home (Swedish EPA[9]).
Although less common, a few regulatory bodies have also introduced or considered minimum standards to mitigate microplastics releases into the environment. Notably, France recently approved an “anti-waste and circular economy” law which, among other things, requires all new washing machines sold from 2025 to have built-in filters to capture microfibres (France, 2020[10]).
Table 4.1 documents selected examples of relevant existing and proposed policies at the national and sub-national level across OECD countries.
4.2.2. Voluntary initiatives
In parallel to government action, a number of voluntary industry initiatives have emerged to mitigate microfibre and TRWP pollution. Industry-led initiatives can have several benefits: they can facilitate information gathering, contribute to accelerating industrial R&D and foster the dissemination of information on the costs and benefits of mitigation solutions. In the context of microfibres and TRWP, industry stakeholders can use their technical knowledge and expertise to accelerate the understanding of the mechanisms and quantities of microplastics emissions and the identification of viable mitigation measures. Further, industry-led initiatives can support and promote policy action and contribute to reaching the objectives mandated or under consideration by governments. In particular, this can be achieved by:
Supporting and participating in research carried out by academics and researchers;
Sharing information and collaborating in international platforms to establish priorities for research and action; and
Sharing product information to consumers or along the value chain, for instance via voluntary labelling schemes or environmental indicators.
In the textile and garment sector, several initiatives and research projects have emerged to close key knowledge and data gaps on microfibres. The Microfibre Consortium facilitates the development of practical solutions for the textile industry to minimise microfibre release to the environment from textile manufacturing and product life cycle (The Microfibre Consortium[19]). To date, the work carried out by the Microfibre Consortium has included the development of a standardised test method and research concerning the influence of various production parameters on shedding behaviours. In the European context, a number of industry associations (International Association for Soaps, Detergents and Maintenance Products, Comité International de la Rayonne et des Fibres Synthétiques, European Outdoor Group, Euratex and the Federation of the European Sporting Goods Industry), have formed a voluntary Cross Industry Agreement. The partnership aims to contribute to the development of international standardised test methods1 to identify and quantify microfibres, share information on the progress of research, knowledge gaps, options and priorities and support and participate in industrial research for the development of feasible and effective solutions (Euratex, n.d.[20]). Further, certain fashion brands have partnered with research organisations to conduct research on microfibre pollution of marine environments and the mechanisms of shedding occurring during laundering (Patagonia, n.d.[21]).
In the tyre manufacturing sector, several companies and industrial associations have also been looking at the issue of TRWP pollution, in particular with regards to opportunities for international cooperation, knowledge sharing and the development of harmonised definitions and measurement standards. The Tire Industry Project (TIP) was established in 2005 by 11 major tyre manufacturing companies, under the umbrella of the World Business Council of Sustainable Development (WBCSD). The TIP aims to identify and implement feasible measures in order to reduce the impact of the life cycle of tyres on the environment, also in the context of microplastics pollution. The European Tyre and Rubber Manufacturers Association (ETRMA) initiated the European Tyre and Road Wear Particle Platform in July 2018. This international multi-stakeholder platform aimed to facilitate research, encourage stakeholder cooperation and knowledge-sharing and explore mitigation options to reduce TRWP pollution. In the European context, the European Tyre and Rime Technical Organization (ETRTO) is working on assessing the feasibility and accuracy of a standard test method for the tyre abrasion rate to propose to the European Commission.
Multi-stakeholder meetings held in the context of the European TRWP Platform identified more than 30 potential mitigation solutions for TRWP pollution. These included interventions to reduce the generation of TRWP (e.g. harmonisation of standard test methods for tyre tread abrasion, research on road abrasion, tyre and road material innovation, awareness campaigns for drivers), as well as options to capture TRWP before these enter the environment (e.g. identifying hotspots for mitigation action, improved road cleaning, implementation of end-of-pipe stormwater management solutions).
Among these, the platform identified a number of measures, which can be prioritised in the short-term:
working on methodologies to develop a test method for the tyre tread abrasion rate as well as analytical methods for TRWP in the environment;
closing knowledge gaps, such as on the composition, occurrence and fate of TRWP in the environment, as well as on the impact of influence factors (e.g. road characteristics) on TRWP generation;
developing permanent platforms to share and disseminate knowledge and create synergies among different research projects;
creating incentives towards eco-driving practices, for instance through awareness raising campaigns; and
identifying hotspots to facilitate the launch of regional pilots and test the relative effectiveness of mitigation solutions.
Source: (ETRMA, 2018[22])
4.3.1. Source-directed approaches
Source-directed policy approaches aim to impose or incentivise measures which prevent the release of pollutants to aquatic, terrestrial and aerial environments and reduce the potential risks for ecosystems and human health. Source-directed action has the advantage of preventing emissions, thus reducing the need for end-of-pipe capture solutions further downstream. In the case of tyres and textiles, source-directed action mainly relates to the implementation of mitigation measures aimed at mandating or incentivising the manufacturing of products containing less toxic components (e.g. non-hazardous dyes employed in textile manufacturing) and with a lower tendency to generate microplastics emissions. Actions aimed at limiting industrial emissions of synthetic polymers and fibres (and the associated chemical substances) also fall in this category.
Table 4.2 summarises various regulatory, economic and voluntary policy tools that can be considered to target the design and manufacturing stage of microplastics emissions originating from tyres and textiles. These are primarily targeted at industry stakeholders along the value chain: textile and apparel manufacturing industries and tyre manufacturing companies. Additionally, regulatory bodies, textile and tyre manufacturing industry associations and other relevant industrial representatives along the apparel and vehicle manufacturing value chain may also contribute to the creation of incentives to minimise industrial emissions and/or to support the development of products leading to lower microplastics emissions.
The following sections describe selected source-directed policy tools in more details and provide a discussion of the relative benefits and barriers to implementation.
Minimum standards, certification systems and labelling and information schemes
Insufficient or inadequate information supply, identified as a barrier to more sustainable production and consumption practices (Laubinger and Börkey, forthcoming[24]), also undermines opportunities to reduce microplastics emissions. The lack of information provision on the shedding propensity of tyres and garments available on the market limits consumers’ ability to make informed purchasing decisions. Also, a lack of information sharing along the value chain may restrict manufacturers’ ability to manage environmental risks associated with a product’s design and production, including those related to microplastics shedding. In the case of textiles, the set of practices which a product has undergone during manufacturing, from fibre production to finishing treatments, will influence its propensity to shed microfibres. However, inadequate information on the product history and content may inhibit manufacturers’ capability to assess the quality of products and the potential to implement eco-design practices.
Once measurement standards for microfibre shedding and tyre tread abrasion are available, it should become possible to differentiate products based on their tendency to emit microplastics. This can allow for the development of standards, certification schemes and labelling and information schemes, a set of interdependent policy tools which could be employed to incentivise eco-design and to help overcome the existing barriers related to the paucity of reliable and effective information supply.
Minimum standards can be considered to restrict the worst performing textile products and tyres from being sold on the market, in order to minimise the contribution of the products with the largest emissions and incentivise producers to implement eco-design manufacturing practices and technologies (Eunomia, 2018[25]). In addition to textiles and tyres, minimum standard requirements could also be conceived for complementary products, as discussed in Section 4.3.2 for washing machines. These could be designed in two ways: a) technology standards mandating the adoption of certain identified eco-design practices or banning the use of harmful manufacturing processes, or b) performance standards setting a maximum threshold for microfibre shedding or tyre tread abrasion. Distinctive benefits would need to be considered, typically as regards to incentives for innovation. In general, performance standards are preferable as these allow for greater flexibility to search for the cheapest options to reach the set pollution reduction goals. In turn, where specific design characteristics and manufacturing processes have been identified as particularly harmful to microplastics mitigation, technology standards can provide a low-cost option to abate emissions.
Certification schemes may be introduced to establish the set of criteria (standards) against which the product is being judged. For instance, business could certify (either autonomously or via third-party testing) the tendency of intermediary or final products to shed microfibres (for garments) or to undergo tread abrasion (for tyres). These could provide the basis for compliance with minimum performance standards or for information provision via mandatory or voluntary labelling schemes detailed below.
Environmental Labels and Information Schemes are policies and initiatives that aim to provide information to external users about one or more aspects of the environmental performance of a product or service (Gruère, 2013[26]). These can be employed to provide aggregated and simplified information to consumers on the microplastics shedding propensity of products placed on the market via consumer-oriented labels (B2C), or to facilitate the information flow between businesses via business-to-business (B2B) information systems to enable the uptake of eco-design practices (Laubinger and Börkey, forthcoming[24]).
Minimum standards, certification schemes, labels and information systems can be deployed in conjunction to facilitate the flow of information relating to the environmental performance of tyres and textile products, incentivise the uptake of mitigation options at the production stage and stimulate market development and innovation. A more detailed assessment of relevant considerations in the design and implementation of these policy tools is presented in Annex 4.A. In particular, two options are discussed: a) B2B information systems to facilitate the information flow on the characteristics, content and microfibre shedding propensity of intermediary and final products along the textile and apparel supply chain, and b) minimum standards and B2C certification and labelling schemes for both vehicle tyres and textile products.
Best Available Techniques
Best Available Techniques (BAT) are state-of-the-art techniques for the prevention and control of industrial emissions, developed at a scale that enables them to be implemented under economically and technically viable conditions. A growing number of governments use BAT to set legally binding emission levels and other conditions in environmental permits for industrial installations.2 The permit conditions are usually established based on a range of legally binding BAT-associated environmental performance levels.3 In the EU, these are set out in BAT reference documents (BREFs).
In the context of microplastics pollution originating from tyres and textiles, BAT could be employed to minimise releases occurring during industrial processes. Potentially, there might also be value in exploring the opportunities for taking a value chain approach when introducing BAT in industrial operations, to encourage the uptake of manufacturing practices that optimise textile products and tyres for lower microplastics release during use. For instance, the removal of microfibres (e.g. via industrial pre-washing under controlled conditions) is an example of a practice which can reduce industrial emissions as well as emissions during the first washes done by the consumer. A more detailed assessment of the potential benefits and relevant implementation considerations for taking a BAT-based approach to microplastics leakage is outlined in Annex 4.A.
Due Diligence in the Garment and Footwear Sector
Due Diligence can facilitate the implementation of sustainable production practices and improve data flows and transparency. The OECD Due Diligence Guidance for Responsible Supply Chains in the Garment and Footwear Sector (i.e. “the Guidance”) helps enterprises implement the due diligence recommendations contained in the OECD Guidelines for Multinational Enterprises along the garment and footwear supply chain in order to prevent and address the potential and actual negative human and labour rights, environmental and integrity impacts of their activities. It supports the aims of the OECD Guidelines to ensure that the operations of enterprises in the garment and footwear sector are in harmony with government policies to strengthen the basis of mutual confidence between enterprises and the societies in which they operate. The Guidance promotes a set of non-binding, practically-oriented principles on how companies should carry out risk-based due diligence with an emphasis on constructive collaborative approaches to complex challenges.
Water pollution is considered a prevalent sector risk in the garment and footwear sector. The Guidance contains a section on water pollution, which outlines steps to be implemented to identify potential and actual harms and to cease, prevent, or mitigate risks related to water pollution. In general, companies are expected to conduct ongoing, proactive and reactive risk-based due diligence, including to pick up on emerging environmental risks. The Guidance also encourages companies to collaborate at a sector level to pool knowledge, share information and scale up effective measures, although cross-industry collaboration does not alter the responsibility of the individual enterprise to identify, prevent or mitigate harm.
While microfibre pollution is not specifically targeted in the existing Guidance, Due Diligence approaches can help companies understand their exposure to microplastics harm in their value chain, take action to cease, prevent and mitigate the impact, as well as to monitor and report on this process. In considering the environmental impacts of a product across its full life cycle, it may be necessary for a company to also take action to prevent, cease and mitigate harm downstream in the value chain, for example by providing washing instructions to end consumers to reduce the water impacts, or by taking preventative action to reduce microplastics shedding and pollution (OECD, forthcoming[27]).
Environmental taxes and mandatory charges
Market-based instruments,4 such as environmental taxes and mandatory charges, could also be considered to incentivise the development and uptake of best manufacturing practices in line with reduced microplastics leakage. In general, market-based instruments allow for flexibility in the way production processes are adapted in response to price signals and thus can deliver environmental improvements at a lower cost than regulatory interventions. Further, taxes could be earmarked to cover the costs of mitigation and pollution prevention, such as support for further research and R&D initiatives, for the costs of improved wastewater and stormwater treatment or for the implementation of use-phase mitigation technologies (e.g. microfibre filters for washing machines).
The implementation of market-based policies would require a careful consideration of several policy design aspects, particularly the setting of policy targets and the price signals. Two main alternatives exist in this sense, each entailing different advantages and disadvantages:
Taxes or charges based on the propensity of tyres and textiles to shed microplastics are likely to be effective at incentivising the uptake of mitigation measures in line with the eco-design of products, as well as at encouraging research and development in material and product design to minimise shedding. These could apply either to producers and importers or to consumers. The main drawbacks of implementing price signals on final products are the extensive information requirements to assess the tendency of products to shed microplastics and the high monitoring costs that would be necessary for the intervention to be effective.
Alternatively, market-based measures could be designed to target microfibre pollution indirectly, via taxes or charges on the synthetic content of textiles and garments. These could target either intermediate materials, i.e. the plastics input during manufacturing or the manufactured good, i.e. the synthetic content of the final product. Relying on a proxy for microfibre shedding may facilitate implementation and simplify compliance checks, as information on product content is readily measurable and usually already available (e.g. fibre content in existing product labels for textile products). However, this may come at the cost of a significant loss of policy efficiency. Most importantly, taxes targeting the synthetic content would not discern between different plastic materials and their propensity to emit microplastics and thus would not necessarily incentivise the development of eco-design solutions for synthetic-based textiles. In addition, they could also create incentives to shift to natural alternatives with higher environmental footprints.
Overall, given the potentially high monitoring requirements and implementation costs and the paucity of data to measure microplastics emissions and the associated risks, it remains to be seen whether market-based policies are feasible and adequate policy tools to incentivise eco-design practices in line with microplastics mitigation. These may become more viable as an effective policy tool in conjunction with regulatory efforts (e.g. minimum standards, or mandatory certification) and once the knowledge on hazards and the effectiveness of mitigation options improves. As the lifecycles of vehicle tyres and textile products also bear several environmental consequences other than the emission of microplastics, the risks of potential burden-shifting would need to be carefully assessed in the design of market-based policies.
4.3.2. Use-oriented approaches
Use-oriented policy approaches aim to impose or encourage the prevention or reduction of microplastics emissions occurring during product use and their release into the environment. These include measures aimed at preventing the abrasion of products containing synthetic polymers, as well as options to prevent the leakage of the emitted microplastics into the environment. Although use-oriented policy approaches have not yet been comprehensively included in policy frameworks targeting microplastics pollution, some have been considered by countries looking to reduce emissions of use-based secondary microplastics.
The use phase is perceived as a particularly relevant point for mitigation action for several reasons. Firstly, several mitigation options implementable at the use stage have the advantage of being already available and relatively easy to implement, in comparison to relevant source-directed and end-of-pipe options. This is the case for instance of microfibre filtering devices for washing machines, when compared to changes in textile design or to potentially-costly upgrades in wastewater treatment plants. Secondly, certain measures which can prevent the emissions of microfibres and TRWP, i.e. best laundering practices and eco-driving practices, can usually be implemented at low costs and also lead to additional environmental benefits (i.e. lower fuel consumption during driving, lower water and energy consumption for laundering).
Table 4.3 summarises various use-oriented policy instruments, most of which are aimed at the general public, industrial laundering facilities and washing machine manufacturers. The following paragraphs describe some of these policy instruments relevant to either foster the uptake of best use practices or the implementation of mitigation technologies.
Minimum standards
Existing incentives may be insufficient to promote the development and implementation of mitigation technologies identified in Chapter 3. Adoption rates remain low, also due to a lack of independent testing carried out to assess and compare the effectiveness of different options in real-life conditions. In this sense, the introduction of regulatory or financial incentives can accelerate the development, testing and uptake of technological solutions.
Minimum standards could be introduced to set eco-design requirements for complementary products that influence microplastics release during the use phase of textiles and tyres. To date, minimum standards have been considered in particular to mandate the adoption of filtering technologies for microfibres in washing machines (Swedish EPA, 2019[28]). For instance, the European Parliament has called on the Commission to include assessments on the release of microplastics into the aquatic environment in eco-design measures, where appropriate and to introduce mandatory requirements for microplastic filters in the next review of the Ecodesign Directive for household washing machines and washer dryers (EP, 2018[29])
Microfibre capturing and filtering devices
The analysis outlined in Chapter 3 suggests that there are several elements which need to be taken into consideration in the design of policies mandating the adoption of filtering technologies for washing machines:
Scientifically sound evidence should inform the setting of the standards criteria for filters, for instance the mesh size of filters and the acceptable effectiveness rate. Standardised definitions and clear requirements for filters are needed to enable the development of technological solutions.
Options that minimise the additional financial and maintenance costs for consumers are expected to be more feasible to implement. This includes built-in filters as well as low-cost and low-maintenance add-on filters and consumer products. Furthermore, since the effectiveness of the use of filters is highly dependent on how these are maintained and operated (see Section 3.2.2), it will be crucial that their introduction is accompanied by the provision of consumer information on adequate maintenance and disposal.
Potential conflicts with other relevant environmental and climate targets (e.g. energy use, water use) should be assessed and prevented. In this sense, industry cross-collaboration between filter and washing machine producers, as well as with research organisations, is essential to ensure that built-in or add-on devices are compatible with household (or industrial) appliances and that they adequately respond to user needs.
The cost-effectiveness of implementing filters is likely to be dependent on the specific mitigation entry points (e.g. household-level or commercial/industrial level), the characteristics of the technology (e.g. type of filtering device, effectiveness, costs of implementation) and the end-of-pipe capture infrastructure in place (e.g. the presence of on-site pre-treatment of industrial effluents, type of urban wastewater treatment technologies employed, likelihood of CSOs, method of sludge disposal). In general, context-specific assessments will need to be carried out in order to identify potential pollution hotspots for microfibres and assess whether the implementation of ad-hoc filtering technologies is cost-effective.
Public information campaigns and consumer-oriented labelling schemes
As discussed in Chapter 3, the way products are handled and used can greatly affect the degree of microplastics shedding occurring from products. Since insufficient information and consumer awareness is one of the key barriers to the adoption of use-oriented mitigation solutions for microfibres and TRWP, consumer education and awareness-raising campaigns may play a major role in encouraging behavioural change. Information provision can increase the environmental awareness of the public, the adoption of use-oriented mitigation measures, public acceptance for policy measures requiring behavioural change, as well as the attention of businesses to emerging environmental issues.
Information initiatives can take multiple forms, from public information campaigns and publications for targeted groups to mandatory or voluntary product labels. Selected examples are outlined below:
Communication campaigns on microfibre shedding and tyre tread abrasion can be included into existing public awareness schemes on plastic pollution, sustainable consumption of textiles, or sustainable transport practices. For instance, information on TRWP emissions for different transportation modes could be included into existing awareness-raising campaigns to promote more sustainable transport habits. Information campaigns can also be designed to target specific microplastics mitigation options. An example of this is the communication campaign launched by the Dutch government to educate drivers on correct tyre pressure and suitable tyre types. The campaign resulted in 250 000 extra cars with the right tyre pressure in 2019, which prevented an estimated 5-10 tonnes of microplastic releases into water bodies (Dutch Government, 2020[13]).
Consumer best use and maintenance guidelines could also be incorporated into existing labels or information provision tools. In the textile sector, standardised textile care labels already exist and are mandatory in several countries (ISO, 2012[30]). These sewn-in labels provide consumers and laundry professionals with information on the adequate product washing and care practices. It has been suggested that washing guidelines in line with best practices to mitigate microfibre shedding could be included into existing sewn-in labels (Eunomia, 2018[25]). Similar initiatives already exist: for instance, the clevercare logo is a voluntary initiative which uses sewn-in labels to direct consumers to best eco-care practices to extend garment lifetimes and minimise water and energy consumption (GINETEX, n.d.[31]).
The provision of salient information during the use of products can foster the uptake of best use and maintenance practices. For instance, in the case of road transport, the provision of real-time information on fuel consumption on passenger vehicles can encourage the adoption of eco-driving practices and contribute to TRWP mitigation, in addition to reducing GHG emissions and air pollution. As an example, the ongoing uCARe project aims to investigate strategies to reduce the overall pollutant emissions of the existing combustion engine vehicle fleet via the provision of simple and effective tools to decrease individual emissions to drivers (uCARe[32]).
4.3.3. End-of-pipe and end-of-life approaches
End-of-pipe solutions include water treatment processes that aim to preserve water quality by removing contaminants from used water resources before these are reintroduced into the environment. As outlined in Chapter 3, end-of-pipe measures relevant for microplastics pollution are mainly wastewater treatment, proper disposal of wastewater sludge and the collection and management of stormwater and road runoff.
Although improvements in product design and the implementation of mitigation best practices and technologies during product use could substantially reduce emissions, mitigation upstream cannot entirely prevent microfibre shedding and tyre tread and alleviate pollution. Thus, while end-of-pipe measures alone cannot suffice to solve the problem of microplastics and other micropollutants in water (for instance, because end-of-pipe capture has difficulty in retaining smaller particles and because some microplastics are emitted into air), they may constitute necessary complements to action at source to reduce the overall risks associated with microplastics pollution.
End-of-life measures may also be relevant for microplastics pollution mitigation. As the mismanagement of plastic waste contributes to microplastics emissions, it is likely that the mismanagement of waste textiles and tyres (for instance via illegal incineration, dispersal in the environment, or landfilling) also contributes to the release of microplastics into air, water and soil. In this sense, policies aimed at preventing the mismanagement of waste textiles and tyres could also contribute to reducing microplastics generation and leakage. Relevant policy instruments include the setting of more stringent requirements for the collection and management of used textiles and tyres to improve reuse and recycling, as well as policy interventions which target microplastics emissions from artificial sport turfs (see also pre-procurement purchasing groups detailed in Table 4.2).
Table 4.4 summarises various end-of-pipe policy instruments for microplastics mitigation, as well as selected policy tools relevant for the end-of-life management of textiles and tyres.
The availability of funding to finance investments in end-of-pipe infrastructure or to adapt to updated water quality regulation is a crucial concern for water utilities. The costs of upgrading wastewater treatment technologies to comply with future stricter requirements for wastewater and drinking water treatment could amount to several billions euros per year in investment in advanced water treatment technologies and additional operational costs (EurEau, 2019[33]).
Several options exist to finance WWTP upgrades, including: public taxes, wastewater tariffs, charges passed onto the manufacturing industries, or a combination thereof (OECD, 2019[34]). For instance, Switzerland has implemented a wastewater tax to partially fund the upgrade of approximately 120 WWTPs to remove 80% of contaminants of emerging concern (mainly pharmaceutical residues) from wastewaters by 2040 (OECD, 2019[34]). Taxes on inputs, such as product charges and other proxies for pollution, could also be used to raise funds for investments in water quality infrastructure and management.
Funding mechanisms should also be considered to finance improvements in stormwater management infrastructure. For instance, stormwater charges for stormwater pollution from impervious surface runoff in urban areas can incentivise reductions in stormwater runoff and finance a greater proportion of urban land to be connected to a drainage system with stormwater treatment. Payments for Ecosystem Services can be explored to fund the restoration of selected green infrastructure, such as wetlands, for stormwater treatment and flood management.
Extended producer responsibility (EPR) may be a relevant option for facilitating and financing microplastics pollution prevention at several levels of the product lifecycle, from production to end-of-life and end-of-pipe capture. This is discussed in the next section.
Extended Producer Responsibility
Extended Producer Responsibility (EPR) is an environmental policy approach in which a producer’s responsibility for a product is extended to the post-consumer stage of a product’s life cycle. More than 400 EPR systems are currently in place in OECD countries and beyond, mainly with the policy objective of increasing waste recovery and recycling (OECD, 2016[35]). EPR schemes allow producers to exercise their responsibility for end-of-life products, either by providing the financial resources required and/or by taking over the operational and organisational aspects of the process from municipalities.
EPR policy is consistent with the Polluter-Pays Principle in so far as financial responsibility for treating end-of-life products is shifted from taxpayers and municipalities to producers and, ultimately, consumers. Where implemented, it generates financial resources to deal with the end-of-life costs of products. Additionally, EPR schemes may also create economic incentives for producers to minimise the environmental impact of products. This may include redesigning products to facilitate their end-of-life handling or avoiding using materials that may pose risks to human health or the environment, to improve recyclability and minimise environmental hazards. In some cases, EPR schemes have been designed to provide a framework where industry stakeholders can collaborate and share information, which can facilitate the identification of ways to minimise the costs of pollution mitigation overall.
EPR schemes hold some potential for microplastics mitigation (EurEau, 2019[33]). First, EPR fees could be employed to finance improvements and upgrades of both wastewater and stormwater management, including expanding WWT capacity and upgrading existing plants, improving street and roadside cleaning, and implementing infrastructure for the treatment of stormwater and road runoff. Second, EPR schemes with advanced fee modulation (Laubinger et al., forthcoming[36]) could potentially provide incentives to producers to improve textile and tyre eco-design, for instance by employing less hazardous materials during manufacturing and investing in R&D to develop products which are less prone to microplastics shedding.
Although EPR schemes generally bear significant implementation costs, these could be particularly attractive policy tools for microplastics pollution mitigation where EPR schemes for the management of end-of-life management of tyres and textile products already exist. Several OECD countries have EPR schemes and other end-of-life management schemes (e.g. take-back obligations) in place to facilitate the separate collection and environmentally sound handling of used tyres (see Chapter 2). In France, an EPR schemes for textiles which puts the responsibility on companies to manage textile waste has also been in place since 2008.
References
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[7] EU SAM (2018), Microplastic Pollution: The Policy Context, https://op.europa.eu/s/plSs.
[25] Eunomia (2018), “Investigating options for reducing releases in the aquatic environment of microplastics emitted by (but not intentionally added in) products - Interim Report”, Report for DG Environment of the European Commission, p. 335, https://doi.org/10.1002/lsm.22016.
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[10] France (2020), LOI n° 2020-105 du 10 février 2020 relative à la lutte contre le gaspillage et à l’économie circulaire, http://www.legifrance.gouv.fr/eli/loi/2020/2/10/TREP1902395L/jo/texte.
[2] France (2017), Décret n° 2017-291 du 6 mars 2017 relatif aux conditions de mise en œuvre de l’interdiction de mise sur le marché des produits cosmétiques rincés à usage d’exfoliation ou de nettoyage comportant des particules plastiques solides et des bâtonnets ouatés à usage domestique dont la tige est en plastique.
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[30] ISO (2012), ISO 3758:2012 Textiles – Care labeling code using symbols.
[5] Italy (2017), Legge n 205 del 27 dicembre 2017. Bilancio di previsione dello Stato per l’anno finanziario 2018 e bilancio pluriennale per il triennio 2018-2020..
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[36] Laubinger, F. et al. (forthcoming), “Modulated fees for extended producer responsibility schemes (EPR)”, OECD Environment Working Papers.
[41] Legal Information Institute (n.d.), 49 CFR 575.104 Uniform Tire Quality Grading Standards.
[16] New York State Assembly (2018), Bill No. A01549.
[44] OECD (2019), “Best Available Techniques (BAT) for Preventing and Controlling Industrial Pollution, Activity 3: Measuring the Effectiveness of BAT Policies”, Environment, Health and Safety, Environment Directorate, http://www.oecd.org/chemicalsafety/risk-management/measuring-the-effectiveness-of-best-available-techniques-policies.pdf.
[34] OECD (2019), Pharmaceutical Residues in Freshwater: Hazards and Policy Responses, OECD Studies on Water, OECD Publishing, Paris, https://dx.doi.org/10.1787/c936f42d-en.
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[45] OECD (2017), Report on OECD Project on Best Available Techniques for Preventing and Controlling Industrial Chemical Pollution - Activity I: Policies on BAT or Similar Concepts Across the World, OECD Publishing, Paris, http://www.oecd.org/chemicalsafety/risk-management/policies-on-best-available-techniques-or-similar-concepts-around-the-world.pdf.
[35] OECD (2016), Extended Producer Responsibility: Updated Guidance for Efficient Waste Management, OECD Publishing, Paris, https://dx.doi.org/10.1787/9789264256385-en.
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[4] United States (2015), Microbead-Free Waters Act of 2015.
Business-to-business information sharing along textile and apparel value chains
Transparency on the composition and characteristics of input materials and products is important for companies downstream to manage environmental risks associated with the products they manufacture and place on the market. Textile and apparel value chains are complex and globally dispersed, which makes it difficult to keep track of individual manufacturing processes a product has undergone and to identify environmental hotspots. As a result, clothing manufactures, fashion brands and other stakeholders downstream often have incomplete or inadequate information on the content and characteristics of intermediary and/or final products.
In the context of microfibre mitigation, paucity of information for different actors along the value chain leads to a number of market inefficiencies:
Manufacturing companies may be exposed to information deficiencies on the content and characteristics of intermediary products and the manufacturing practices employed at previous stages of the value chain. This may constrain the potential to quantify the shedding propensity of the final product and provide accurate information to consumers.
Poor information on the materials and chemical substances employed at earlier stages may also pose a barrier to the implementation of best manufacturing practices. For instance, whereas preliminary washing has been identified as a potential mitigation measure for microfibres, lack of information on the history of the product and the substances it may release during washing, may hinder adequate handling.
Information asymmetries may also be detrimental to progress in research and development, in particular with regards to the identification and assessment of mitigation solutions implementable during design and manufacturing. Research efforts may be constrained by poor traceability of products available on the market and limited transparency over the material and chemical content and the manufacturing practices these have undergone.
Business-to-business (B2B) information systems can be useful tools to improve the transparency of products and to address information asymmetries along the supply chain on the quality of intermediary products. A variety of B2B information systems and metrics that address other sustainability aspects have been developed in the textile sector, such as the manufacturing restricted substances list (MRSL) to facilitate chemicals management (detailed in Box 2.1) and the Oeko-Tex Standards, which allow brands, retail companies and manufacturers to monitor and communicate environmental sustainability achievements across the supply chain (Oeko-Tex, 2019[37]).
Information schemes could be developed to share information relevant to assess the microfibre shedding propensity of final garments along value chain actors. Ideally, quality controls for microfibre shedding would apply to textile products at all processing stages. Where this is difficult or costly to implement, for instance because fibre and textile production occurs in small enterprises in emerging economies, third-party testing can be employed further downstream to certify the performance of imported products. As legislation (e.g. the EU REACH regulation) generally puts the responsibility for managing the environmental footprint of products on brands downstream, the introduction of voluntary or mandatory certification schemes of B2B information systems can also enable the development of regulatory policy and facilitate compliance by fashion brands downstream (Laubinger and Börkey, forthcoming[24]).
As microfibre pollution is only one of the environmental issues associated with textile production and use, it may be preferable to include microfibre information into existing schemes which take a holistic, lifecycle approach to environmental impacts. An example of such a B2B information scheme is the Higg Index, a suite of assessment tools which allows brands, retailers and manufacturers in the apparel and footwear industry to measure environmental, social and labour impacts across the lifecycle of products. The Higg Materials Sustainability Index (MSI) is used as a B2B tool to measure the environmental footprint of apparel products based on metrics on hazardous chemicals, water use, energy and deforestation (Sustainable Apparel Coalition, 2019[38]). Microplastics are recognised as an important environmental impact aspect to be included into LCA methods such as the Higg MSI, however its incorporation will only become possible once standardised methodologies for microfibre shedding are available.5
Business-to-consumer information schemes and product standards
Absence of information on the shedding propensity of tyres and garments available on the market limits consumers’ ability to discern products based on their environmental performance. The provision of consumer-oriented information on microfibre shedding propensity of textiles and on the rate of tyre tread abrasion can help address several existing market inefficiencies and environmental externalities associated with microplastics leakage. Although several other criteria also influence consumers’ purchasing decisions, the provision of this information is expected to steer consumption towards products with a higher resistance to microplastics shedding (Eunomia, 2018[25]). 6In turn, the implementation of B2C information and labelling schemes is also expected to trigger a shift at the production stage towards tyres and textile products with a lower propensity to release microplastics.
The design and implementation of information systems for microfibre shedding and tyre tread abrasion would differ depending on the context and specific objectives to be targeted. Labelling schemes could be designed to map the resistance of products to microplastics shedding on a scale. Examples of this are the EU’s energy labelling and eco-design regulations (A***-E, previously A-G), the Japanese Tyre Labelling Scheme (AAA-D) and the US Uniform Tire Labelling Grading (AA-C)7 (EU, 2017[39]; JATMA, 2009[40]; Legal Information Institute, n.d.[41]). Alternatively, B2C certification labels can be employed to indicate that a product meets certain predetermined environmental criteria (e.g. European Union Eco-Label, Nordic Swan Ecolabel). In addition to labelling schemes, information on the shedding propensity of products could also be included via other information provision tools, such as product packaging and additional garment tags or stickers.
Integrating microplastics information into existing information schemes may be the most cost-effective option. Given the low weight of microfibre and TRWP pollution relative to other selection criteria for textiles and tyres (environmental, quality, or safety concerns), the issue may not justify creating an additional labelling scheme. Also, information on microfibre shedding or tyre tread abrasion may be most salient to the consumer if provided in conjunction with other relevant information on the overall environmental footprint of the product. Even where microfibre information cannot be easily provided as part of existing certification and labelling schemes, options that take a holistic perspective on the environmental footprint of the lifecycle of products should be preferred.
In parallel to labelling schemes, product standards could be introduced to set eco-design requirements for textiles and tyres placed on the market. These could be designed in two ways: a) technology standards mandating the adoption of certain identified eco-design practices or banning the use of harmful manufacturing processes, and b) performance standards setting maximum thresholds for microfibre shedding or tyre tread abrasion.
Technology and performance standards are not mutually exclusive and could also be implemented in conjunction, depending on the context and identified mitigation solutions. Performance standards allow for greater flexibility to search for the cheapest options to reach the set pollution reduction goals. In turn, where certain manufacturing processes have been identified as particularly harmful to microplastics mitigation, technology standards can provide a low-cost option to abate emissions. An important aspect in the design of minimum standards is that these must be dynamic in nature in order to allow and incentivise innovation and eco-design. For instance, where performance standards are introduced in conjunction with labelling schemes mapping the microfibre shedding propensity or tyre tread abrasion rate on a alphanumerical scale, this can be used to set and regularly update the threshold for the acceptable performance of products.
Several options exist to establish the certification criteria against which products should be judged to determine whether it complies with minimum standards or to grant it a labelling classification. The most cost-effective option is likely to be the use of self-certifications to attest the expected performance of products based on standardised testing (Eunomia, 2018[25]). For instance, under the EU Tyre Labelling Regulation, the performance of tyres is self-certified in accordance with EU standardised tests.
The OECD is not familiar with any jurisdictions that, to date, have published BAT and BAT-associated environmental performance levels (BAT-AEPLs) concerning the release of microplastics. In the European Union, industrial emissions of microplastics (specifically synthetic fibres and releases plastic pellets along the industrial supply/production chain) are within the scope of the Industrial Emissions Directive (IED), the EU BAT legislation (EU, 2010[42]; EU SAM, 2018[7]). No relevant BAT and BAT-AEPLs have been defined on this parameter, also due a lack of data, harmonised measurements and monitoring on industrial microplastics releases. However, the Technical Working Group in charge of regularly reviewing the BREF for the Textile Industry has recently decided to collect information on microplastic from various studies to be included in the relevant BREF, possibly preparing for the determination of BAT on microplastic in future revisions (EC, 2018[43]).
Benefits of a BAT-based approach
A BAT-based approach to microplastics emissions could bring several benefits:
Evidence-based standards: The process to determine BAT is based on a comprehensive collection and exchange of information on existing pollution prevention and control techniques and other relevant data, such as emissions data. The information collection is followed by a thorough assessment of the technical, environmental and economic aspects of existing techniques. As a result, the process to determine BAT and the associated emission levels is rooted in evidence as well as expert judgement. Consequently, BAT-based emission limit values are more likely to result in emissions reduction than those solely based on other benchmarks such as environmental quality standards.
A holistic approach to environmental protection: studies show that the implementation of BAT can ensure considerable reductions in industrial emissions and thus important savings to society and industry, as a result of improved environmental management of industrial operations. Furthermore, all OECD member countries are recommended to implement an integrated pollution prevention and control (IPPC) approach (OECD, 1991), i.e. covering emissions to air, water and soil alike. BAT can contribute to the implementation of such an approach, to ensure that pollutants are mitigated rather than shifted between different environmental media.
Multi-stakeholder dialogue: In order to determine BAT and associated emission levels, countries or regions usually set up sector-specific Technical Working Groups, typically consisting of experts from industry, government and environmental NGOs. This allows stakeholders to build a mutual understanding of industrial operators’ key environmental challenges and of the means to address these. Thanks to the multi-stakeholder dialogue, BAT-based permit conditions reflect a balance of interests. This approach also tends to increase the acceptability of permit conditions across stakeholders involved, including industry operators.
Level playing field: by aligning environmental performance requirements across industrial installations in each country or region, BAT-based permitting creates a level playing field for industry.
Cost-effective upgrade of industry: when determining BAT, the Technical Working Groups usually consider the costs and advantages of candidate techniques, in order to identify those that reduce the environmental impacts of industrial operations in a cost-effective manner without hampering other aspects of the operations. Moreover, while there may be a cost associated with the implementation of BAT for industrial operators, the introduction of BAT enables an upgrade of industrial operations, making installations greener and potentially also more resource-efficient.
Flexibility at the implementation stage: Although the emission levels associated with BAT are legally binding, the BAT per se are usually not prescriptive. This implies that industrial operators are free to choose whatever technique they find suitable to prevent or control emissions, provided that they reach compliance with the emission limit values set by environmental permits.
Possible steps forwards
In order to ensure the introduction of BAT for the prevention and control of microplastic releases during industrial operations or further down in the lifecycle of products, governments would have to establish relevant BAT and BAT-AEPLs in BREFs and set legally binding permit conditions for industrial installations on that basis. These could be implemented through the following steps:
Identify microplastic releases as a key environmental issue to be considered during the drawing up or review of BREFs pertaining to relevant industrial activities, such as textile production;
for the selected sectors, collect data on 1) available techniques for prevention and control of microplastic releases occurring during manufacturing, as well as on reported industrial releases, and/or 2) best available manufacturing techniques for the prevention of MP release during product use;
following the information collection, determine BAT for prevention and control of microplastic releases based on a comprehensive evaluation of the environmental, economic and technical aspects of available techniques, conducted by sector-specific Technical Working Groups consisting of experts from government, industry and NGOs;
derive ranges of legally binding BAT-associated emission levels and other associated environmental performance levels (BAT-AEPLs), e.g. related to the release of pre-production plastic emissions, tyre abrasion under standard use; and
in compliance with the ranges of BAT-AEPLs, determine permit conditions pertaining to microplastic releases for industrial installations at local/national permitting authorities.
Notes
← 1. The CIA-produced test method for microfibre shedding has been submitted for approval to the CEN Working on Microplastics, an entity charged with setting standardized test methods for the determination of the release, identification and evaluation of microplastics from textile sources, during manufacture and use.
← 2. The OECD’s BAT reports (OECD, 2017[45]; OECD, 2018[46]; OECD, 2019[44]) provide information on policies based on BAT or similar concepts in the European Union, Chile, Israel, Korea, New Zealand, the United States, the People’s Republic of China, India, the Russian Federation and EECCA countries.
← 3. BAT-associated environmental performance levels (BAT-AEPLs) encompass BAT-associated emission levels (BAT-AELs) as well as other performance levels, such as those related to consumption of material, water or energy, the generation of waste, abatement efficiency on pollutants and duration of visible emissions.
← 4. Extended Producer Responsibility could also hold some potential for the mitigation of microplastics shedding from products, as discussed in 4.3.3. The implementation of EPR with advanced fee modulation would likely face the same information challenges than market-based instruments such as environmental taxes.
← 5. According to the OECD Due Diligence Guidance for the Garment and Footwear Sector, companies have a responsibility to take action to identify, prevent, and mitigate risks to water quality, regardless of whether specific environmental harms are incorporated into existing voluntary initiatives.
← 6. A recent survey carried out in the European Union found that there is strong consumer demand for information about tyre tread abrasion rates (Eunomia, 2018[25]).
← 7. The US Uniform Tire Labelling Grading already includes a numerical index for tyre wear. However, since the reference tyre on which tread wear is measured differs for each brand, this measure cannot be used to compare tyres of different brands placed on the market.