Abstract

Stakeholder involvement is pivotal EU governance. In this paper, we complete a stakeholder analysis of the European Chemicals Agency's recent Annex XV restriction proposal process on intentionally added microplastics. The aim of this study is to map the interests, influence and importance of active stakeholders in order to understand the arguments being put forward by different stakeholders and provide recommendations to policy-makers on how to ensure a balanced consideration of all stakeholder perspectives. Stakeholders were identified through niche media analysis and by scrutinising comments from the public consultation on the restriction proposal. Their importance and influence were mapped using three approaches: "scale from low to high", "psychometric scale" and "qualitative ranking". We identified 205 different stakeholders out of which 77 were industry and trade associations, 25 were large companies and only four were small and medium-sized enterprises. National authorities and researchers did not comment on the restriction proposal, whilst large companies were very active providing comments. Industry trade associations and sports-related non-governmental organizations articulated anxiety about the costs associated with the implementation of the restriction proposal. Among environmental non-governmental organizations, there was consensus that plastics should be handled like other substances under EU's chemical regulation. Primary stakeholders identified exhibited high importance, but varying degrees of influence, while the opposite applied to the major European institutions. Based on our analysis, we recommend that: The European Chemicals Agency implement measures to include "silent" stakeholders and invite guest experts to participate in their committees on Risk Assessment and Socio-Economic Analysis; Researchers should be more active in the public consultation; and that special emphasis should be put on helping small and medium-sized enterprises. With regards to stakeholder consultation, we find that media analysis is a good supplement to stakeholder analysis and that a more objective top-down measure of stakeholder importance and influence is needed.

Highlights

  • Governments across the world have initiated regulatory action and strategies to combat the growing problem of plastic pollution

  • This action came after a six-month process that started with the European Commission asking the European Chemicals Agency (ECHA) to prepare an Annex XV restriction dossier–and after a public call for information and stakeholder consultation [23]

  • First is a restriction on placing microplastics on their own or in mixtures on the market, which applies for uses that inevitably result in environmental releases

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Summary

Introduction

Governments across the world have initiated regulatory action and strategies to combat the growing problem of plastic pollution. In January 2019, the ECHA submitted what is known as a “registration dossier,” to restrict the use of intentionally added microplastic particles to consumer or professional-use products of any kind [23] This action came after a six-month process that started with the European Commission asking the ECHA to prepare an Annex XV restriction dossier–and after a public call for information and stakeholder consultation [23]. First is a restriction on placing microplastics on their own or in mixtures on the market, which applies for uses that inevitably result in environmental releases This measure must be implemented over a transitional period, to allow sufficient time for stakeholders such as the small and medium-sized enterprises (SMEs) and the industry to comply with the restriction. Detergents that contain polymeric fragrance encapsulation, and”leave-on cosmetic products” (such as moisturiser, make-up, lipstick, hair care and hair-styling products), have a suggested 5- and 6-year transition period, respectively, to allow for reformulation and transition to alternatives

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