Environmental Pollution xxx (2017) 1e11

Contents lists available at ScienceDirect

Environmental Pollution
journal homepage: www.elsevier.com/locate/envpol

From macro- to microplastics - Analysis of EU regulation along the life

cycle of plastic bags*
Ida M. Steensgaard a, Kristian Syberg b, Sinja Rist a, Nanna B. Hartmann a,
Alessio Boldrin a, Steffen Foss Hansen a, *
a
Technical University of Denmark, DTU Environment, Miljoevej Building 113, 2800 Kgs, Lyngby, Denmark
b
Roskilde University, Department of Science and Environment, Universitetsvej 1, Building 11.2, 4000, Roskilde, Denmark

a r t i c l e i n f o a b s t r a c t

Article history: Plastic pollution and its environmental effects has received global attention the recent years. However,
Received 25 October 2016 limited attention has so far been directed towards how plastics are regulated in a life cycle perspective
Received in revised form and how regulatory gaps can be addressed in order to limit and prevent environmental exposure and
10 January 2017
hazards of macro- and microplastics. In this paper, we map European regulation taking outset in the life
Accepted 2 February 2017
Available online xxx
cycle perspective of plastic carrier bags: from plastic bag production to when it enters the environment.
Relevant regulatory frameworks, directives and authorities along the life cycle are identified and their
role in regulation of plastics is discussed. Most important regulations were identified as: the EU chemical
Keywords:
Marine litter
Regulation, the Packaging and Packaging Waste Directive including the amending Directive regarding
Plastic bags regulation of the consumption of lightweight plastic carrier bags, the Waste Framework Directive and the
Microplastics Directive on the Landfill of Waste. The main gaps identified relate to lack of clear definitions of categories
Regulation of polymers, unambitious recycling rates and lack of consideration of macro- and microplastics in key
pieces of legislation. We recommend that polymers are categorized according to whether they are
polymers with the same monomer constituents (homopolymers) or with different monomer constituents
(copolymers) and that polymers are no longer exempt from registration and evaluation under REACH.
Plastics should furthermore have the same high level of monitoring and reporting requirements as
hazardous waste involving stricter requirements to labelling, recordkeeping, monitoring and control over
the whole lifecycle. Finally, we recommend that more ambitious recycle and recovery targets are set
across the EU. Regulation of the consumption of lightweight plastic carrier bags should also apply to
heavyweight plastic carrier bags. Last, the Marine and Water Framework Directives should specifically
address plastic waste affecting water quality.
© 2017 Elsevier Ltd. All rights reserved.

1. Introduction discharge will increase by one order of magnitude by 2025

Plastics are used in a wide range of products and production
processes, ranging from packaging, textiles, construction, auto-
motive to paints (Andrady, 2011). The rise in global production over
the last few decades has induced a huge increase in plastic waste
and has led to a continuous accumulation of plastic litter in the
environment (Andrady, 2011; Wright et al., 2013; Eriksen et al.,
2014; Co
zar et al., 2015). Given the expected future demand and
discharges of plastic, it is estimated that marine plastic litter
* the most common types being low-density polyethylene (LDPE)
This paper has been recommended for acceptance by Maria Cristina Fossi.
* Corresponding author.
E-mail address: sfha@env.dtu.dk (S.F. Hansen).
(Jambeck et al., 2015).
It is estimated that around 80% of marine litter, with plastics
being the main component, originates from land-based sources
including beach litter (OSPAR, 2014; Andrady, 2011). Once various
types of plastic litter reach the marine environment they are frag-
mented and degraded into smaller pieces (Ivar do Sul and Costa,
2014). Plastics are produced from inorganic and organic raw ma-
terials and are formed from long chains of polymeric molecules
(Ivar do Sul and Costa, 2014). The polymer polyethylene (PE) is one
of the most widely used synthetic polymers in the world (Ivar do
Sul and Costa, 2014). There are several types of PE with some of
and high-density polyethylene (HDPE) accounting for 17.5% and
12.1% of the European plastic production, respectively

http://dx.doi.org/10.1016/j.envpol.2017.02.007
0269-7491/© 2017 Elsevier Ltd. All rights reserved.

Please cite this article in press as: Steensgaard, I.M., et al., From macro- to microplastics - Analysis of EU regulation along the life cycle of plastic
bags, Environmental Pollution (2017), http://dx.doi.org/10.1016/j.envpol.2017.02.007
2 I.M. Steensgaard et al. / Environmental Pollution xxx (2017) 1e11
(PlasticsEurope, 2015a). PE is found to be present in 79% of marine
litter in the oceans (Hidalgo-ruz et al., 2012). LDPE and HDPE have
densities lower than that of water (1 g/cm3). Lightweight plastic
litter is subject to wind driven transport, thereby reaching different
marine and coastal environments (Ivar do Sul and Costa, 2014;
Wright et al., 2013). Buoyancy of the plastic litter in water in-
creases ocean driven transport and makes the polymer subject to
UV-radiation and higher temperatures in the water surface,
increasing fragmentation (Ivar do Sul and Costa, 2014).
It is well established that marine species are widely affected by
plastic littered in the ocean (GESAMP, 2015). It is estimated that
hundreds of marine species already are affected by marine plastic
litter ranging from species of higher trophic levels, such as: turtles,
fish, whales and crabs (e.g. Wright et al., 2013; GESAMP, 2015;
Lo€nnstedt and Eklo € c, 2016) to lower trophic levels, like
zooplankton (e.g. Reisser et al., 2014; Cole et al., 2013; Browne et al.,
2008). While numerous studies have investigated the ingestion and
accumulation of macro- and meso-plastics in aquatic animals, the
effects of the small-sized plastics, so-called microplastics (MPs), is a
newer but rapidly expanding area of research (Cole et al., 2013; Von
Moos et al., 2012; Cole and Galloway, 2015; Moira et al., 2015;
Herzke et al., 2016; Lo € nnstedt and Eklo
€c, 2016). MPs are most
commonly defined as plastic particles less than 5 mm in size
(Arthur et al., 2009) although other definitions exist. As a result of
marine plastic litter fragmenting, MPs tend to accumulate in the
environment, thereby becoming of particular concern (Andrady,
2011; Ivar do Sul and Costa, 2014).
Concerns regarding trophic transfer of MPs between marine
species and the ability of MPs to concentrate persistent organic
pollutants (POPs) is currently emerging. Studies have observed a
transfer of MPs from meso-to macrozooplankton, as well as from
mussels to crabs, though no biomagnification of particles has yet
been detected within the food chain (Farrell and Nelson, 2013;
Seta€la
€ et al., 2014). Transfer of adhered contaminants such as
POPs or other hydrophobic contaminant from ingested MPs to
marine biota has been shown in several studies. Whether this
causes adverse effects and presents an environmentally important
exposure route for pollutants to organisms is still debated (Syberg
et al., 2015; Herzke et al., 2016; Koelmans et al., 2016).
One major source of marine plastic litter e and ultimately MPs -
that has recently received attention in Europe (EU) is plastic carrier
bags. Plastic carrier bags are manufactured mainly from LDPE
(Andrady, 2011). Several countries have already included bans or
taxes on use of plastic bags, which have resulted in up to 90% use
reduction in their use in EU countries (Convery et al., 2007).
However, not all countries implement the same levels of taxes or
regulations and concerns have been raised that littering of plastic
carrier bags might be a large source of plastic litter pollution in the
oceans (Co
zar et al., 2014).
Significant effort has gone into studying the occurrence and
effects of plastic litter. Research, pursuing to understand the limi-
tations of the legislative frameworks, that aim at limiting the
emissions of plastics and MPs into the environment, is a newer area
of scientific interest. This topic is vitally important because plastics
are persistent in the aquatic environment: once the litter has
reached the ocean, the pollution will persist for many years since
degradation processes are very slow. Plastic will typically break
down to micro- or even nano-sized plastic particles and only un-
dergo full mineralisation after a prolonged time period. The
degradation into small fragments and distribution across the globe,
makes oceanic clean up extremely difficult if not impossible. The
best option to reduce plastic pollution is therefore to explore how
and where in the life cycle (LC) of plastics the problem can be
tackled further, before it ends as marine litter.
The overall objective of this paper is to assess to which extend
Please cite this article in press as: Steensgaard, I.M., et al., From macro- to microplastics - Analysis of EU regulation along the life cycle of plastic
bags, Environmental Pollution (2017), http://dx.doi.org/10.1016/j.envpol.2017.02.007
current European regulation properly address and prevent the
continuous discharges of marine plastic litter and provide recom-
mendations on how to cope with gaps in existing legislation.
2. Method
In this study, we first used an incremental approach to map the
steps along a LC of a plastic bag with a specific focus on European
production, use and legislation. In order to map the life cycle of a
plastic bag, we completed a bibliographic survey of the literature,
published between 1990 and June of 2016 in the database ‘Web of
Science’ using a combination of different keywords including e.g.
“plastic* þ legislation” and other relevant keyword combinations.
The literature was then reviewed with regard to environmental fate
and behaviour of plastics at each step of the LC. This included
detailed mapping of each step of the LC i.e. the raw materials used
for production, the manufacturing process, the use/reuse, and
waste/recycling, excluding fate of plastic once released into the
environment. Different types of so-called biodegradable and oxo-
biodegradable plastic bags also exist, but are considered to be
outside the scope of this paper.
Secondly, the relevant legislations at each step of the LC were
mapped with the aim to investigate and analyse any potential gaps
that should be addressed. The fate and behaviour of plastic litter,
once in the environment, was excluded from our regulatory anal-
ysis as we argue that plastic litter should be addressed before
entering the environment. Information regarding current legisla-
tion was identified in the Official Journal of the European Union and
EUR-Lex (http://eur-lex.europa.eu/homepage.html) in regard to
polymers, marine litter and MPs as well as by consulting the
websites of relevant European institutions e.g. The European
Parliament, The European Commission, The Council of the Euro-
pean Union, DG Environment, DG Sanco, DG Grow, the European
Environment Agency (EEA) and the European Chemicals Agency
(ECHA).
3. Mapping the steps in a life cycle of a plastic bag
Five steps were identified in the LC of a plastic bag: 1) Raw
material used in production; 2) Manufacturing process; 3) Use/
reuse; 4) Waste/recycle; and 5) Discharge to environment. The
specific amounts of plastics were estimated for the individual steps
of the LC, whenever sufficient information was available. This LC is
not intended as an evaluation of the environmental impact on an
overall scale, but is specific to concern caused by marine plastic
litter.
3.1. Step 1: raw materials used in production and release of plastic
pellets from production
The first step of the LC of a plastic bag relates to the raw material
used in the manufacturing of plastic as well as losses of plastic
pellets from the production site or during transport (see Fig. 1).
Plastic bags are most often made from PE, which is produced
using petrol and crude oil (Hammer et al., 2012) and around 4% of
global oil production is used for plastic production (British Plastic
Federation, 2008). It is estimated that 0.9 kg of crude oil is
needed to produce one liter petrol (Nordell, 2007), which in turn is
used to produce 0.57e0.72 kg (average 0.6 kg) of PE. According to
PlasticsEurope (2015b), the demand for the PE polymer is currently
18.4 Mt/year accounting for approximately 30% of the plastic
consumed in the EU (PlasticsEurope, 2015b). This corresponds in
total to 16.56 Mt crude oil, and 18.4 million liters petroleum.
The volunteer-based global monitoring program “International
Pellet Watch” aims at monitoring organic pollutants in pellets
 I.M. Steensgaard et al. / Environmental Pollution xxx (2017) 1e11 3

Fig. 1. Life cycle of plastic bags mapping the different steps and elements that influence the fate and behaviour of plastic bags through their life cycle (LC). (Nordell, 2007, FRIDA,
2016, PlasticsEurope, 2015a, Sundt et al., 2014, European Commission, 2011b, Eriksen et al., 2014). (*) Not quantifiable.

found on seashores around the world (Pelletwatch, 2016). Data
from the program has a broad geographical coverage and illustrates
that marine pollution with plastic pellets is a global problem. This is
in accordance with recent studies indicating a substantial acci-
dental spillage of plastic pellets to the environment from the plastic
industry. In the United Kingdom this spillage reaches estimated
amounts of 5e53 billion pellets each year (FRIDA, 2016), corre-
sponding to 0.001e0.01% of the total plastic pellet production. A
differentiation of plastic pellet types is not ascribed for in the study
(FRIDA, 2016).
3.2. Step 2: manufacturing of plastic bags
Lightweight plastic bags are more widely used than heavy-
weight plastic bags (European Parliament and the Council, 2015)
and in the EU plastic bags are mainly produced from LDPE pellets,
as this polymer is very flexible and clear. The EU production of LDPE
is 9 Mt/yr, accounting for 17.5% of the total plastic production; in
total, 39.5% of EU plastic production demand is used for packing
(PlasticsEurope, 2015a). HDPE is used in producing high-weight
plastic bags, which are thicker and reused more often as they are
more durable. HDPE accounts for 12.1% of the EU plastic production,
with a demand of 5.5 Mt/yr (PlasticsEurope, 2015a). Several addi-
tives are added to the polymer used in the production of plastic
bags, to obtain the desired properties. For instance, when used for
packaging (e.g. plastic bags)anti-static agents and colourants are
added to HDPE. For LDPE the additives include slip promoters,
colourants and antistatic agents (OECD, 2009).
3.3. Step 3: use/reuse of plastic bags
European recycling rates are generally low and usage rates per
capita high for lightweight plastic bags. Based on an EU Commis-
sion Report (2013a), Sundt et al. (2014) estimated that in 2010 every
EU citizen used on average 198 plastic carrier bags. This amounts to
a total of 98.6 billion bags (both lightweight and heavyweight),
corresponding to 1.1 Mt of plastic used solely for plastic bags pro-
duction. Approx. 92% of light-weight bags are single-use (European
Commission, 2013b). After use, the bags are disposed as waste or
lost directly to the environment. It is estimated that improper
handling and disposal of carrier bags result in about 88.200 t of
plastic littered to the marine environment in EU each year (Sundt
et al., 2014).
The use of both single- and multiple-use plastic bags is country
specific within the EU, and varies significantly within the different
EU Member States. Estonia, Hungary, and Latvia are leading with
consumption rates of more than 450 bags per citizen per year in
2010 (Barbie
re, 2015). Conversely, countries such as Denmark and
Finland almost entirely rely on multiple-use (heavy-weight) plastic
bags, thereby having per-capita consumption rates below 100 bags
per year (Barbie
re, 2015).

Please cite this article in press as: Steensgaard, I.M., et al., From macro- to microplastics - Analysis of EU regulation along the life cycle of plastic
bags, Environmental Pollution (2017), http://dx.doi.org/10.1016/j.envpol.2017.02.007
4 I.M. Steensgaard et al. / Environmental Pollution xxx (2017) 1e11
3.4. Step 4: waste/recycle of plastic bags
When it comes to end-of-life management, PlasticsEurope
(2015a) estimated that 69% of the collected plastic waste was
recovered in 2015 through material recycling (30%) and energy
recovery (39%). Despite efforts to recover plastics, 31% of the plastic
waste was still disposed of in landfills (PlasticsEurope, 2015a).
There are currently large differences in the landfill rates of plastics
in the EU countries. Several countries such as Switzerland, Ger-
many, Austria, Luxembourg, Belgium, Denmark, Sweden,
Netherlands and Norway have banned landfilling of plastics
(PlasticsEurope, 2015a). In these countries, landfills now receive
less than 5% of the plastic waste, while the rest (i.e. >95%) is sent to
either material or energy recovery (PlasticsEurope, 2015a). In the
top five countries (Switzerland, Germany, Austria, Luxembourg and
Belgium) 99-96% is recycled and/or energy recovered and only
1e4% is landfilled (PlasticsEurope, 2015a). In other countries,
plastic waste is still completely disposed of in landfills. Examples
are Malta, Cyprus, Greece, and Bulgaria, where >75% of the plastic
was disposed in landfills in 2015. The other European countries all
report recycling rates for plastic in the order of 20e30%.
3.5. Step 5: discharge to environment
When end-of-life plastic is not properly collected and managed,
there is a possibility that it is lost/discharged to the environment,
thereby potentially ending up as marine litter. Marine litter from
land-based sources, such as plastic bags, can be transported from
land by: run-offs from rivers; discharge in effluents during heavy
rain-fall or storm water; discharge from solid household waste,
tourism at beaches and others (Hammer et al., 2012). Activities
from ocean-based-sources will also contribute to marine litter, but
are less relevant in regards to plastic bags loss. It is estimated that
8% of the manufactured plastic bags are littered to the ocean in the
EU (Sundt et al., 2014), which correlates with the high rates of
plastic bags found as marine litter in the EU (European
Commission, 2011b), and that PE is found to be present in 79% of
marine litter (Hidalgo-ruz et al., 2012).
Among the EU water bodies, the north-western Mediterranean
was estimated having the highest levels of marine litter on average,
with just under 20 items of litter per hectare (ranging between
0 and 78 items). Of these 20 plastic waste items (microplastic not
included), about 15 of them were plastic bags (European
Commission, 2011b). A study by Co
zar et al. (2015), reported an
average density of 1 plastic item per 4 m2 in the Mediterranean Sea,
corresponding to a total load of 1000e3000 t of floating plastic. The
plastic debris found in the Mediterranean surface waters was in
general dominated by millimeter-sized fragments, but also showed
a proportion of large plastic objects, which was higher compared to
oceanic gyres. This indicates a closer connection with pollution
sources, as the Mediterranean Sea is enclosed between several
countries (Co
zar et al., 2015). About 5.9% of all particles were
classified as films, which mainly stem from plastic packaging, like
plastic bags or pieces hereof (Co
zar et al., 2015). The high use rate of
plastic carrier bags in the EU increases the risks of loss into the
environment during all stages of the LC. The losses are likely greater
in highly populated areas, where concentrations of both marine
litter and MPs are also found to be higher (Hammer et al., 2012).
Eriksen et al. (2014) estimated global plastic pollution by oceano-
graphic modelling of floating plastic debris dispersal. Raw data to
the model was plastic debris collected directly from transects
during expeditions in the five sub-tropical ocean gyres. A total of
268,940 tons and 35,540 tons in MP size-range (0.33e4,75 mm)
were estimated. In the Mediterranean Sea, the modelled amount of
was 23,150 tons plastic debris is estimated.
Please cite this article in press as: Steensgaard, I.M., et al., From macro- to microplastics - Analysis of EU regulation along the life cycle of plastic
bags, Environmental Pollution (2017), http://dx.doi.org/10.1016/j.envpol.2017.02.007
4. Applicable regulations along the life cycle of plastic bags
In total, we identified 11 directives; one regulation; one action
plan; one initiative; and one green paper of relevance (see Fig. 2).
For each piece of the relevant directives, regulation, etc. iden-
tified, we analysed their scope with respect to plastic waste to
identify what might be done to address current limitations, if any.
4.1. Step 1: raw-material extraction and spill of plastic pellets
During step 1 of the LC of a plastic bag, i.e. the raw-material
extraction needed for the manufacturing of plastic, the Raw Ma-
terial Initiative (RMI) (SEC/2008/2741) is of relevance. The RMI aims
to ensure continuous access to raw materials in the future in the EU
(European Commission, 2008a; European Commission, 2011a). The
RMI is built on 3 pillars: 1) Ensuring access to raw materials under
conditions similar to other industrial competitors; 2) enforcement
of framework conditions that foster sustainable supply of raw
materials from EU sources; 3) promotion of increased resource ef-
ficiency and recycling (European Commission, 2008a p. 5e6). The
RMI is a non-legally binding policy document. The European
Parliament has adopted a resolution demanding that the Com-
mission elaborate, monitor and review policies regarding raw
materials. This includes implementing reduction targets and calling
for a high effort for resource efficiency and recycling (Küblbo €ck,
2013).
Spills of PE and release of plastic pellets in general from pro-
duction is of particular concern. In Europe, the Industrial Emissions
Directive lays down the rules on integrated prevention and control
of pollution arising from industrial activities (European Parliament
and the Council, 2010). According to the Directive, the rules are
“designed to prevent or, where that is not practicable, to reduce
emissions into air, water and land” as well as “to prevent the gen-
eration of waste”. As the production of plastic materials (specified
to include polymers, synthetic fibres and cellulose-based fibres) are
listed in Annex I of the Directive, and hence within the scope of the
Directive, Member States have to take necessary measures to
ensure that industrial installations are operated in accordance to
the principles of taking all appropriate preventive measures against
pollution, best available techniques are applied, no significant
pollution is caused and that the generation of waste is prevented
(European Parliament and the Council, 2010, Article 11). Member
States are furthermore to ensure that the general binding rules
applicable for installations based on the best available techniques
without prescribing the use of any technique or specific technology
(European Parliament and the Council, 2010, Article 17).
When issuing a permit under the Industrial Emissions Directive,
Member States shall ensure that it includes at least appropriate
requirements ensuring protection of the soil and groundwater and
measures concerning the monitoring and management of waste
generated by the installation as well as emission limit values for
substances listed in Annex II, which contains the list of polluting
substances. Plastics are not listed in Annex II. However emission
limits also apply to polluting substances not listed in Annex II,
which are “likely to be emitted from the installation concerned in
significant quantities, having regard to their nature and their po-
tential to transfer pollution from one medium to another”
(European Parliament and the Council, 2010).
The use of best available techniques (BAT) plays a key role in the
Directive. For polymers, Reference Document on Best Available
Techniques in the Production of Polymers is of relevance (European
Commission, 2007). It covers processes and techniques in the
production of different polymers. Mentioned techniques include.
Environmental Management Systems, process-integrated tech-
niques and end-of-pipe measures. These are claimed to generally
 I.M. Steensgaard et al. / Environmental Pollution xxx (2017) 1e11 5

Fig. 2. European regulation influencing the LC of plastic bags for all steps in their LC. Each of the steps in the LC is noted from 1 to 5. The applicable legislations for each steps, are
shown behind/next to the step. The legislations highlighted in bold, are the ones considered of highest importance.

have potential for achieving a high level of environmental protec-
tion in the polymer industries, but focus is primarily on emission of
dust, volatile organic compounds and chemical oxygen demand as
well as inert waste and hazardous waste. For BAT when it comes to
e.g. water pollution prevention, specific recommendations are
made such as: pipes and pumps placed above ground; pipes placed
in ducts accessible for inspection and repair. The Reference docu-
ment does not mention polymers in regard to emission to air, water
or soil. For wastewater treatment, the reference document notes
that various techniques exist to treat waste water e.g. biotreatment,
sedimentation, flotation and that the most appropriate techniques
have to be selected to treat the waste water depending on the waste
water effluent and its composition, and the plant operation.
Another Reference Document on Best Available Techniques of
potential relevance is on “Common waste gas and waste water
treatment/management systems in the chemical sector”. A working
draft of this Reference Document is available, but it is work in
progress and does not include any information about Best Available
Techniques to limit emissions of polymers. Instead, it repetitively
recommends and discusses the benefits of the use of polymer as a
typical adsorbent. For instance, in regard to waste water treatment/
management, polymer addition for various types of sludge and for
various methods of dewatering when it comes to Sludge treatment
techniques (JRC, 2016).
4.2. Step 2: regulation of the manufacturing of polymers and plastic
bags
During the manufacturing of polymers and plastic bags, three
major pieces of legislation apply and one action plan, is of rele-
vance. This includes the European Regulation on the Registration,
Evaluation, Authorization and Restriction of Chemicals (REACH)
(EC, 1907/2006), the Directive on Good Manufacturing Practice
(2023/2006/EC), the Directive on Plastic materials and Articles (10/
2011/EC) and the action plan ‘Closing the loop e An EU action plan
for the circular economy’ from the European Commission (2015b).
4.2.1. REACH
REACH mentions both monomers and polymers (ECHA, 2012).
While in principle REACH covers polymers, there are in practice no
requirements for the two first steps - registration and evaluation -
which are core elements of REACH, as polymers are currently
exempt from both (ECHA, 2012 p. 8). The EU does not differentiate
between new polymers and existing polymers, which are therefore
all exempt from registration and evaluation under REACH “… until
those that need to be registered due to the risks posed to human
health or the environment can be selected in a practicable and cost-
efficient way on the basis of sound technical and valid scientific
criteria”. Instead the importer and/or producer of the polymer must
(if not already registered by another operator) conduct a registra-
tion to the European Chemical Agency (ECHA) of the monomer if
“the polymer is made up of more than 2% or more of the monomer
substance(s), and the total quantity usage of the monomer shall
exceed more than 1 t per year” (European Parliament and the
Council, 2006; ECHA, 2012).
The possibility of cost-efficient registration of polymers under
REACH was investigated by Postle et al. (2012) and De Toni et al.
(2014) for the European Commission. Postle et al. (2012) exam-
ined a range of options for the registration of polymers manufac-
tured or imported only at 1 to 10 t substances under REACH. In total,
eleven different options were considered, ranging from the current
requirements under REACH to requiring the similar toxicological
and ecotoxicological data as for substances manufactured or im-
ported in 10 t or more. De Toni et al. (2014) investigated more

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bags, Environmental Pollution (2017), http://dx.doi.org/10.1016/j.envpol.2017.02.007
6 I.M. Steensgaard et al. / Environmental Pollution xxx (2017) 1e11
practical methods of registering polymers, possibly implementing
new approaches under REACH. De Toni et al. (2014) assessed two
alternate approaches: 1) grouping the polymers into relevant so-
called “families” reducing the cost by avoiding duplication
testing; 2) classifying certain polymers as Polymers of Low Concern
(PLC), which are deemed to have insignificant human - and envi-
ronmental impacts, hence having less regulatory requirements (De
Toni et al., 2014).
By the first approach, polymers are divided into two main cat-
egories, namely polymers with the same constituents and polymers
with different constituents. Polymers with the same constituents are
considered to be the same monomers and other substances
belonging to the polymer structure. These can be subdivided into 3
cases: 1) Structurally identical polymers; 2) Polymers which qre
considered as one substance under the Dangerous Substance
Directive; and 3) Polymers with incremental and constant change
across the group. For polymers with different constituents a
distinction is made between 1) change in counter-ion and 2)
change with a similar monomer (De Toni et al,. 2014).
The second approach focusses on determining if a polymer is a
so called “Polymer of Low Concern” (PLC) based on, for instance,
whether the polymer is a cationic polymer, its molecular weight
and oligomer content and whether there is information on human
and/or environmental hazard classification under the EU CLP
regulation for a) the candidate polymers or b) one or more
monomers or other substances in the candidate polymer (De Toni
et al., 2014).
4.2.2. Classification labelling and packaging (CLP)
In the CLP Directive, a polymer is defined as a substance char-
acterized by a sequence of one or more monomer units and a
monomer unit is defined as reacted from a monomer substance in a
polymer. This means that in the classification of a polymer, the
classification of all the constituents should be taken in account
including the unreacted monomers. In Article 14 of the CLP, specific
rules for classification of mixtures are outlined. This includes any
substances, which may form oligomers or polymers at low con-
centration (European Commission, 2008b). The monomer of PE,
Ethene, is in the ECHA Classification and Labelling inventory and is
classified under the CLP as Aquatic Chronic 3 under the hazard
statement H412 (ECHA, 2015b), where this category indicates a
lethal concentration for 50% of the organisms (LC50) at a concen-
tration between >10 and  100 mg/l (European Commission,
2008b).
4.2.3. Plastics and regulation of packaging and food contact
materials
A number of directives are relevant to plastics in packaging and
food contact materials. The Directive on good manufacturing practice
[…] (2023/2006/EC) of products intended to come into contact with
food includes packaging plastic materials such as plastic carrier
bags and sets specific manufacturing goals to assure a good quality
control system and to assure that the plastic follows the steps of the
quality control system (European Commission, 2006). Also, the
Directive on plastic materials and articles […] (10/2011/EC) regulates
plastic materials and polymers in contact with food such as plastic
bags. Restrictions and specifications regarding migrations limits
into food are defined (European Commission, 2011a,b,c). The
directive also specifies the thresholds according to the form and
composition of plastic/polymer, e.g. nano-form, which shall
explicitly be authorized and mentioned, indeed different polymers
being approved to be used as additives or polymer production aid
(European Commission, 2011a,b,c).
Please cite this article in press as: Steensgaard, I.M., et al., From macro- to microplastics - Analysis of EU regulation along the life cycle of plastic
bags, Environmental Pollution (2017), http://dx.doi.org/10.1016/j.envpol.2017.02.007
4.2.4. Action plan from European Commission e a circular economy
Whereas REACH and the CLP are legally binding and can be
considered hard law, an example of a soft law initiative for plastics
is the action plan for the Circular Economy launched by the Euro-
pean Commission. The action plan emphasises the implementation
of a circular economy in the EU, focusing on different priority areas
of which plastics is one (European Commission, 2015a,b).
The Commission focuses on plastics in the circular economy by
addressing more innovative strategies in plastic manufacturing.
Issues on how to improve recyclability, biodegradability, reducing
the presence of hazardous chemical additives and significant
reduction of marine litter are included (European Commission,
2015a,b). This action plan is intended to be implemented into the
different innovative projects which is under the umbrella of the
EU's Horizon 2020 research programme furthermore acting as an
instrument to define Sustainable Development Goals (SDGs) for the
EU by 2030 (European Commission, 2015a,b).
4.3. Step 3: regulation of the use and reuse of plastic bags
The main directives regarding use and reuse of plastic bags are
the Packaging and Packaging Waste Directive 94/62/EC (PPWD), and
the amending Directive (EU) 2015/720 as regards reducing the
consumption of lightweight plastic carrier bags. The amendment
was a result of a published Green Paper “On a European Strategy on
Plastic Waste in the Environment” from the European Commission,
which discusses strategies to cope with the increasing amount of
plastic waste in the environment and raised substantial concern
about consumption of light-weight plastic carrier bags (European
Commission, 2013a,b,c; European Parliament and the Council
2015a).
The PPWD is the main directive of relevance for the reuse of
plastic waste and covers industrial, commercial, office, shop, ser-
vice, household or any other level of use of plastics. The directive
specifies reuse targets in Article 6: by 2008, at least 22.5% of the
plastic packaging should be reused. This target should be met by
individual Member States, which are thus responsible for the
implementation of the necessary initiatives at the local level
(European Parliament and the Council, 1994). In a Directive pro-
posal amending Directive 94/62/EC, the European Commission
(2014) suggested higher recycling targets for plastic packaging
waste, namely 45% by 2020 and 60% by 2025. The proposed
Directive received a very favourable impact assessment (Hestin
et al., 2015), but was subsequently redrawn by the Commission
(European Commission, 2015a) as the Commission intended to
replace it with a more ambitious one in 2015 (European Parliament,
2016), which, however, has yet to be published.
In 2015, the Directive 94/62/EC was amended with the Directive
(EU) 2015/720, in order to reduce the consumption of lightweight
plastic carrier bags defined as having “… a wall thickness below 50
mm”. The directive requires EU member states to take measures on
the consumption of these bags on a national level by the 26 of
November 2016, aiming at reducing consumption to 90 bags per
person by 2019, and to 40 by 2025, which is set as the future
maximum annual consumption (European Parliament and the
Council, 2015; Kasidoni et al., 2015; European Commission,
2013c). The Directive furthermore obligates Member States to
conduct a life cycle assessment of the lightweight plastic carrier
bags by May 2017 and obligates the EU Commission to make
revision to the Directive if the Directive, should it prove not to be
sufficiently effective, by November 2021.
4.4. Step 4: regulation of waste and recycling of plastic bags
There are three main directives relevant to handling and
 I.M. Steensgaard et al. / Environmental Pollution xxx (2017) 1e11
recycling waste (besides the packaging directive mentioned above),
namely the Waste Framework Directive (2008/98/EC), the Directive
on the Landfill of Waste (1999/31/EC) and Urban Waste Water
Treatment Directive (91/271/EEC) (see Fig. 2).
The Waste Framework Directive 2008/98/EC (WFD) directs
Member States on how to correctly manage their wastes (European
Parliament and the Council, 2008b). Specifically, it outlines the
waste management principles and requirements and introduces
the waste hierarchy, which prioritizes prevention as the most
preferable waste management option, followed by reuse/recycling,
other recovery methods, and finally disposal/landfilling. The WFD
requires Member States to separately collect and sort a significant
share of paper, metal, plastic and glass by 2015 (European
Parliament and the Council, 2008b). In the WFD, new recycling
and recovery targets are set for plastic aiming at facilitating reuse
and recycle of minimum 50% of the total plastic mass from
households by 2020. (European Parliament and the Council,
2008b). The Directive also aims for an improvement of infrastruc-
ture for recycling and reuse of materials including plastics. In order
to meet the WFD targets, the Member States are allowed to
implement extended producer responsibility (EPR) requirements to
make it the producer's responsibility to manage and finance the
treatment of the waste.
The Directive on the Landfill of Waste (1999/31/EC) was imple-
mented in 1999 to prevent negative impacts of the landfills to e.g.
groundwater, surface waters and human health. It defines three
classes of landfills, as for 1) hazardous waste, 2) non-hazardous
waste and 3) inert waste. Currently there are no limits to the
amounts of plastic wastes (e.g. plastic bags) that can be landfilled as
non-hazardous waste within the Directive of Landfill of Waste (The
Council of the European Union, 1999), but several Member States
have individually implemented threshold limits for disposal of
plastic in landfills (PlasticsEurope, 2015c). Protection of nearby soil,
coastal- and fresh waters must also be accounted for when location
and implementation/design of the landfill are decided on, hereby
minimizing the environmental impacts (The Council of the
European Union, 1999).
Since 2011, policy-makers have been discussing the imple-
mentation of an EU legal instrument to enhance the sorting, recy-
cling and recovery of plastic (European Commission, 2013b). In the
action plan from the European Commission (European
Commission, 2015a,b), a smarter collection and sorting of plastics,
is said to be of critical concern to divert plastics away from high
landfill and incineration rates. Within the last decade, banning of
plastic landfilling in several Member States, including Germany,
Denmark, Sweden and Austria, has led to a successful increase in
the recovery of plastic waste within these countries.
Besides being disposed as solid waste, a significant amount of
plastic ends in urban wastewater systems (see Fig. 1). The Urban
Waste Water Treatment Directive (91/271/EEC) aims at ensuring the
maintenance and protection of aquatic life and the environment,
setting thresholds for the discharge of wastewater to the environ-
ment so that adverse effects such as e.g. eutrophication are averted
(European Commission, 1991). Plastic, in the form of MPs, is often
present in the receiving water body from Waste Water Treatment
Plants (WWTP) (Magnusson et al., 2014), but the Directive does not
entail any requirements when it comes to the amount of plastic in
the effluent.
4.5. Step 5: regulation of discharge of plastic litter into the
environment
Discharge of marine litter in form of plastic waste is one of the

zar et al. 2014).
major focal points in the plastic pollution debate (Co
Three main directives are of importance with respect to marine
Please cite this article in press as: Steensgaard, I.M., et al., From macro- to microplastics - Analysis of EU regulation along the life cycle of plastic
bags, Environmental Pollution (2017), http://dx.doi.org/10.1016/j.envpol.2017.02.007
7
plastic litter, such as plastic bags, namely the Marine Strategy
Framework Directive (MSFD) (2008/56/EC), The Directive on Port
Reception […] (2000/59/EC) and The Water Framework Directive
(2000/60/EC).
The MSFD specifically focusses on restoring the marine envi-
ronment and protecting it against an increase in marine litter and
has led to actions being taken by several Member States (European
Parliament and the Council, 2008a). For instance, Denmark,
established “the Danish Marine Strategy” in 2012 (Lassen et al.,
2015), which includes a monitoring programme investigating ma-
rine litter at beaches, sea floor and analysis of MPs in sediments and
macro e and microplastic ingestion of biota (Strand et al., 2015).
Whereas the MSFD outlines the European strategy for marine
water, the Water Framework Directive (WaFD) (2000/60/EC) ap-
plies to surface waters (i.e. lakes, rivers, transitional waters (estu-
aries)), coastal waters (up to one nautical mile from land) and to
groundwater (European Parliament and the Council, 2000b).
Similarly, to the MSFD, the aim is to achieve good water status,
covering both “good ecological status” and “good chemical status”.
However, marine litter is not included within the chemical and
biological quality criteria (European Parliament and the Council,
2000b).
Finally, the Directive on Port Reception […] (2000/59/EC) is rele-
vant as it aims to reduce pollution of both sea and coastlines caused
by shipping and cargo residues (European Parliament and the
Council, 2000a). Shipping was identified as an important source
of marine plastic litter in the early 1990s, with an estimated
contribution of around 6.5 Mt (Cole et al., 2013). The legislation
states that all ports must have a sufficient handling plan and waste
reception, so that waste can be successfully delivered and managed,
instead of discharged at sea/coastlines (European Parliament and
the Council, 2000a). The type and amount of waste and residues
delivered and/or remaining on board, and percentage of maximum
storage capacity must be stated. This includes plastic, which falls
under the category ‘garbage’ (European Parliament and the Council,
2000a). According to an action plan from the European Commission
(European Commission, 2015a,b) the current Directive may be
revised to improve port reception facilities for receiving marine
litter from ships.
5. Discussion and recommendations
In the current paper, the possibility of adapting existing legis-
lation when it comes to plastics litter was investigated along the LC
of a plastic bag. Based on a thorough analysis of the legislative
documents, as described in the previous section, significant limi-
tations in the European legislation were found in the regulatory
frameworks applicable in the steps of the LC. Below we present the
identified gaps as well as ways of addressing these gaps. Table 1
outlines the most relevant regulatory directives, and outlines the
limitations identified of each of the regulations, directives, etc.
analysed above. Table 1 also outlines a set of recommendations that
should be implemented in order to address the current limitations
of existing legislation regarding plastic litter; while these recom-
mendations are discussed in detail later in the text.
One of the regulations that should be revised is the Industrial
Emissions Directive. The Industrial Emissions Directive currently
requires Member States to take the necessary measures to ensure
that industrial installations are operated in a way that all appro-
priate preventive measures are taken against pollution. Member
States furthermore have to ensure that emission limit values for
polluting substances are set for substances not listed in Annex II
and which are likely to be emitted. Neither can be said to be the
case when it comes to plastics and we therefore recommend that
polymers are added to Annex II, which contains the list of polluting
8 I.M. Steensgaard et al. / Environmental Pollution xxx (2017) 1e11
substances so that the focus on taking preventive measures against
pollution are also aimed at plastics. Current Reference Document
on Best Available Techniques in the Production of Polymers should
be updated so that the focus of the document also includes con-
siderations in regard to limiting emission of plastics and not only
dust, VOC, etc. Best Available Techniques for how to limit emissions
of polymers (including plastic pellets) should be included in the
working draft on Reference Document on Best Available Techniques
on “Common waste gas and waste water treatment/management
systems in the chemical sector”.
Another regulation that should be revised is REACH. REACH is
based on the principle that the producers are to generate (eco)
toxicological information about the substances that they produce
and/or import and the need for regulation or prohibitions of
chemical uses are based on this information. As discussed in our
analysis above, polymers are generally exempt from registration
under REACH. With the registration, producers and importers of
chemical substances have to submit a technical dossier containing
an assessment of risks and possible hazards associated with the use
of the substance (ECHA, 2015a). Being exempt from registration,
this information is not generated by the producers/importers of
polymers. At the same time, scientific literature is emerging
describing the intake and entanglement of marine species by
plastic litter with less information available on their adverse effect.
While the polymer itself might not be hazardous, on-going research
focuses on whether MPs could work as a vector for POPs and other
organic contaminants present in the water column (e.g. Syberg
et al., 2015; Koelmans et al., 2016). Hazardous additives might
also be a matter of concern, if they are added to enhance the
properties of the polymer, and if the addition of these additives
would result in the polymer having to be considered and registered
as a mixture as described in Section 4.2.1 of REACH. To increase the
data generation on potential negative effects of plastics to humans
and the environment, and at the same time ensure that the burden
of proof is on the producers/importers, it is recommended that the
REACH registration requirements are implemented for polymers
just as for regular chemicals.
According to REACH, polymers are currently exempted from
registration due to the “lack of a practicable and cost-efficient way”
to select the polymers that should be registered. We recommend
that the proposal by De Toni et al. (2014) to group polymers should
be adopted, thereby dividing polymers into polymers with the same
constituents, i.e. the same monomers and other substances
belonging to the polymer structure, and polymers with different
constituents as this seems to be the only manner in which to ensure
that all members of a group have similar environmental and health
risks (De Toni et al. 2014). A REACH registration would then be
needed for each group of polymers that are considered to be either:
1) structurally identical, 2) which are considered as one substance
under the Dangerous Substance Directive, 3) which have a similar
incremental and constant change across the group, 4) which have
similar structural properties and the counter-ions are similar or 5)
which have only slight change in the monomer structure that are
known not to change the toxicity profile. The burden of providing
evidence for “sameness” within a group of polymers would fall on
the registrant just as it is the case for regular chemicals. As
persistency is a key factor to the risk that a polymer will pose to the
environment e.g. the ocean, a set of criteria should be developed to
enhance the overall risk determination, as REACH already has for
chemicals which are tested for Persistency, Bioaccumulation and
Toxicity (PBT) (ECHA, 2014). Such criteria should further account
for the fact that plastics might pose physical risk as well as the more
traditional chemical risk that REACH mainly concerns.
Based on our analysis we recommend that also the PPWD
should be revised. In the PPWD a recycling target for plastic
Please cite this article in press as: Steensgaard, I.M., et al., From macro- to microplastics - Analysis of EU regulation along the life cycle of plastic
bags, Environmental Pollution (2017), http://dx.doi.org/10.1016/j.envpol.2017.02.007
packaging of 22.5% has been set for individual Member States. This
target was set back in 1994, is relatively low and should be updated.
We recommend that the target for recycling is increased to at least
50% by 2020 and 75% in 2025, similar to the target set in the WFD in
order to ensure that they are up-to-date and that there is consis-
tency across EU policies on recycling of plastic. These higher targets
should be implemented as soon as possible as indications are that
the overall impact of such higher target would not only limit the
amounts of plastic released into the environment but also save
considerable amounts of greenhouse gas emissions, create thou-
sands of indirect and direct jobs within the EU economy and at
quite moderate and certainly feasible costs (European Commission,
2013c; Hestin et al., 2015).
We recommend that the target for recycling is increased to at
least 50% by 2020, similar to the target set in the WFD. An addi-
tional directive regarding regulation of the consumption of light-
weight plastic carrier bags was recently added to the PPWD with
the aim to address the high consumption rates of single-use plastic
bags in the EU. This directive provides clear lines for the future use
targets, and we recommend expanding the scope and aim of this
directive to include heavy-weight plastic bags as well, as these are
also widely used in the EU. The reason for only including light-
weight plastic bags up until now is that they are of higher concern,
because they are less reused and more frequently transported to
the marine environments due to their lightweight. The directive
states that it is possible to discuss and revise the targets by 2021,
but we recommend that these discussions are initiated already now
and ended within a much shorter timeframe e.g. 2018. Thereby, if it
turns out that the regulation is not sufficiently effective, taxes or
fees can be implemented to ensure that less plastic bags are used by
2021. A transition to fabric carrier bags should also be encouraged
as it could ensure the demand within reasonable costs. As a follow-
up on the directive, an LC assessment has to be conducted by 2017
according to Directive (EU) 2015/720 and it is important that this LC
includes an assessment of MP formation from degradation/frag-
mentation of the lightweight as well as heavyweight bags, and that
a test of persistency of both types of plastic bags prior to degra-
dation/fragmentation is included.
Poor waste management on land is one of the major problems of
the marine plastic litter pollution and our analysis shows that this
issue needs to be addressed. It is expected that approximately 80%
of the marine plastic litter originates from land-based sources
(OSPAR, 2014). To decrease the concentrations of MPs in the ocean,
it is necessary to decrease the amount of marine plastic litter, as
well as the continuous discharge to the ocean from land-based
sources. The recycle rates in the WFD are set to 50% by 2020 for
household waste (European Parliament and the Council, 2008b).
Latest information from 2012 shows that 62% were recycled and
recovered overall where recycling accounted for 26%
(PlasticsEurope, 2015a).
Waste recycling and recovery has increased in the recent years
in the EU. We recommend that recycling targets are set not only for
household waste, but expanded to the overall waste. Further opti-
mization of the resource efficiency could be induced by limiting the
amounts of plastic currently disposed in landfills, an aspect, which
is yet not regulated at the EU level although national bans exist. In
some of the EU Member States, a ban has been implemented on
plastics in landfills, which has shown to be very effective: the
countries with ban on plastic landfilling have considerably high
plastic recovery rates around 90e95% (PlasticsEurope, 2015a). We
therefore recommend that this ban is implemented across the EU as
it would not only stop the drainage of raw materials, but also
encourage more efficient recovery and limit the release of MPs from
landfills, thereby ensuring better water quality in waterbodies near
landfills.
 I.M. Steensgaard et al. / Environmental Pollution xxx (2017) 1e11 9

Table 1
Applicable regulations in regards to the steps of the LC of plastic bags, their limitations, and an overview of suggested amendments.

Framework Step in LC Regulation task Limitation Recommendations

Industrial Emissions Directive
Registration Evaluation and
Authorization of Chemicals
(REACH)
Packaging and Packaging Step 3: Use/reuse &
Wwaste Ddirective (PPWD) Step 4: Waste/recycle
Additional Directive 2015/720 Step 3: Use/reuse
to PPWD regarding regulation
of the consumption of light
weight plastic carrier bags
Waste Framework Directive
(WFD)
Directive on the Landfill of Waste Step 4: Waste/recycle
Marine Strategy Framework
Directive (MSFD)
Water Framework Directive
(WaFD)
Step 1: Raw materials Prevent or reduce emissions into air, Does not focus on
used in production and water and land
release of plastic pellet
from production
Step 2: Manufacturing Ensure safety of monomers and
polymers to human and
environment.
Regulate all the plastic packaging and Current recycling target Set recycling target to at least 50% by 2020 and
packaging waste placed on the
marked.
Reduction leading to an annual
consumption level of light-weight
plastic bags to 90 per person in 2019, regulation is not
and 40 per person by 2025.
Step 4: Waste/recycle Regulates the correct managing of
waste.
By 2020 50% of household plastic
waste must be recycled.
Reduce negative impacts of the
landfills to e.g. groundwater, surface plastic, which can be put landfills.
waters and human health.
Step 5: Regulates the protection and
Discharge to restoration of the marine
environment environment.
Aiming for GEnS.
Step 5: Ensure good ecological quality
Discharge to elements in the relevant water
environment bodies.
Add plastics to Annex II
limiting emission of Reference Document of BAT on Polymers
polymers, but e.g. VOC, should include consideration for how to limit
COD and hazardous emissions of polymers
waste BAT on waste water treatment of plastics
should be included in the working draft on
Reference Document on BAT on “Common
waste gas and waste water treatment/
management systems in the chemical sector”
The steps I and II A clearer definition of polymer compositions.
evaluation and Categorize polymers in a more systematic way.
registration (Article 2(9)) Include registration and evaluation step of
does not apply to polymers.
polymers.
22.5% of plastic covering 75% in 2025.
each Member State
territory.
A discussion to revise the Implement the same reduction plan for heavy-
targets in 2021, if the weight plastic bags.
In the LC assessment of light-weight bags,
effective. which shall be conducted in 2017, include the
assessment of MP formation from the bags.
Recycling targets only Implemented recycle targets set for 2020 to
applies to household whole Member State territory.
plastic waste. Implement a monitoring and reporting system
for plastic litter similar to that for ‘hazardous
waste’.
Include a test of persistency to indicate
polymers of higher concern
No limits for amount of Implement regulation on plastic levels used in
into landfills. Ban plastic in landfills in countries, which have
the technological possibility to recover and
recycle instead.
MPs are not Implement MP monitoring in the MFSD as a
implemented when part of achieving GEnS.
reaching GEnS.
Marine litter not Include both marine litter and MPs to be
included in chemical and monitored as chemical and biological criteria
biological criteria quality quality elements.
elements.

To further strengthen the control over plastic waste, we suggest
that it is monitored and recorded internationally in the same way as
‘hazardous waste’ in the WFD (European Parliament and the
Council, 2008b). The WFD outlines that Member States must take
necessary action to ensure that the production, treatment, storage,
collection and transportation of hazardous waste is handled in
conditions ensuring that human health and the environment is not
endangered, e.g. without causing risk to water or animals
(European Parliament and the Council, 2008b). By monitoring and
reporting plastic waste in a similar way, safety to the environment
and human health is increased. Rochman et al. (2013) have simi-
larly suggested for plastic to be termed as ‘hazardous’. As this would
be rather extensive to implement this for all polymer types, a
mapping and grouping of the most hazardous and/or persistent
polymer types should be the outset, with an intention to imple-
ment to all polymer types over time. GESAMP (2015) also argues
that there is a great potential in more adequate controls to be in
place, to ensure a reduction of plastic waste streams and that
recycling is implemented sideways with development of innovative
and effective solutions.
Finally, we recommend a series of revisions to be made to the
MSFD and the WaFD. The MSFD has defined 11 descriptors that will
lead to ‘Good Environmental Status’ (GEnS). Descriptor 10 states
that property and quantity of marine litter should not cause harm
to the costal and marine environment. There is a need to make a
clear definition of the term “harm”. The literature is rich on marine
organisms entangled or affected by ingesting marine plastic litter.
For instance, GESAMP (2015) have documented that more than 250
species are affected by marine plastic litter. We believe that the only
manner to avoid harm is to reduce the quantity of marine litter all
together and we hence recommend that the MSFD reflects this. In
the WaFD marine litter is not included despite the fact that the
WaFD has the same aim as MSFD i.e. achieving ‘Good Environ-
mental Status’. We therefore recommend that monitoring of ma-
rine litter including MPs are included in the WaFD, and that their
presence in the ocean at threshold level, would reflect poor bio-
logical quality.
In conclusion, our analysis of existing legislation along the LC of
plastic bags highlights several opportunities to further address the
challenges of plastic litter. In summary, we recommend that:
1 Plastics are added to Annex II of the Industrial Emissions
Directive, which contains the list of polluting substances.
2 Within the Industrial Emissions Directive, the Reference
Document of BAT on Polymers should include considerations
on how to limit emissions of polymers (including plastic
pellets). Also, BAT on waste water treatment of plastics
should be included in the working draft on the Reference

Please cite this article in press as: Steensgaard, I.M., et al., From macro- to microplastics - Analysis of EU regulation along the life cycle of plastic
bags, Environmental Pollution (2017), http://dx.doi.org/10.1016/j.envpol.2017.02.007
10 I.M. Steensgaard et al. / Environmental Pollution xxx (2017) 1e11
Document on BAT on “Common waste gas and waste water
treatment/management systems in the chemical sector”.
3 Polymers are registered under REACH just as regular chem-
icals of risk from plastics including emphasize on persistency
and physical hazardous effects.
4 The polymers are grouped into polymers with the same
constituents and polymers with different constituents,
whereas the physical form must be reported.
5 The target for recycling is increased to ‘50% or more’ by 2020
in the Packaging Waste Directive (PPWD), similar to the
target set in the WFD, in order to update recycling targets
and ensure consistency across EU policies on recycling of
plastic.
6 The scope of the additional Directive regarding regulation of
the consumption of light weight plastic carrier bags is
expanded to include heavy-weight plastic bags.
7 Discussion and revision of targets for recycling of plastic
carrier bags in Directive (EU) 2015/720, which are set to be
revised in 2021, should be initiated now and ended by 2018.
8 The Life Cycle Assessment, that is to be conducted by 2017
under Directive (EU) 2015/720 on lightweight plastic carrier
bags, should include an assessment of MP formation from
degradation/fragmentation and of persistency of both types
of plastic bags (lightweight and heavyweight) before degra-
dation/fragmentation begins.
9 The recycle rates set to 50% by 2020 for only household waste
by WDF are expanded to all waste sources.
10 A ban on plastic landfilling is implemented across of the
whole EU as this has been shown to improve plastic recycling
rates.
11 Plastics undergo monitoring and reporting requirements
similar to hazardous waste, and a more polymer specific
testing of persistency and degradation is implemented in the
overall evaluation.
12 The MSFD is revised to reflect the notion that the only
manner to reduce the occurrence of plastic marine litter is to
reduce the quantity of marine litter all together.
13 Marine litter and MPs are included in the assessment of ‘good
water quality’ in the WaFD.
14 Marine litter is included as a quality criteria element in the
MSFD, as the presence of too high amounts of plastic litter
must be seen as poor/bad water status.
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Further Reading
PlasticsEurope, 2016. Plastics - the Facts 2015: an Analysis of European Plastics
Production, Demand and Waste Data. http://www.plasticseurope.org/whatis-
plastic/types-of-plastics-11148/elastomers.aspx (Accessed 05.06.2016).