Dr Chris Sherrington, Head of Environmental Policy & Economics at Eunomia Research and Consulting, shares his thoughts on possible ways of reducing the loss of plastic pellets to the environment.
What are plastic pellets?
When plastics are produced, they typically take the form of a pellet, powder or flake – “pellet” is often used as a term that covers all three forms. Pellets are used as input material by plastics converters who convert the pellets into plastic components, products and packaging.
Pellets are also known as “nurdles” or “mermaids’ tears”, which gives a clue as to the fate that befalls billions of these pellets each year. At every point along the supply chain, these pellets (and powders and flakes) can be spilt, and if not successfully recovered they will be lost to the wider environment.
Plastic pellets: What’s the challenge?
Estimates show that between 52,140 tonnes and 184,290 tonnes of pellets were lost to the environment in the EU in 2019. One kg of pellets comprises circa 50,000 individual pellets, meaning there are approximately 50 million in a tonne. If we take a broadly mid-point estimate for the above tonnage figures, of 100,000 tonnes, that’s 5 trillion pellets.
The fact that pellets enter the terrestrial and aquatic environment as a result of both chronic and acute losses is well understood. This is not a new problem, as is clearly stated on the website of the US-based Plastic Industry Association.
The problem of pellet loss has been known since the 1980s, with the US Environmental Protection Agency (EPA) and the Centre for Marine Conservation (now known as the Ocean Conservancy) “detecting plastic pellets in US waterways from the Atlantic to the Pacific”.
In 1986, SPI: The Plastics Industry Trade Association (now known as the Plastics Industry Association) established the Resin Pellet Task Force to “educate the plastics industry [….] about the negative consequences of plastic pellets in the marine environment.”
Estimates show that between 52,140 tonnes and 184,290 tonnes of pellets were lost to the environment in the EU in 2019.
In 1991, the industry-led Operation Clean Sweep (OCS) initiative was created by SPI, with companies signing a pledge to work towards zero plastic pellet loss. Shortly after this, in 1992, a study by the USEPA was published identifying sources of pellet loss and making several recommendations.
In 2015, the OCS programme was implemented in Europe. 2024 marks 38 years since the establishment of the Resin Pellet Task Force, 33 years since the creation of OCS, and 9 years since the implementation of OCS in Europe, yet chronic and acute loss of pellets still appears to be widespread.
The main reason for this is that while best practice measures to prevent pellet loss through minimising the risk of spills and ensuring clean-up of spills are well understood, they have not been comprehensively implemented.
A voluntary approach, such as OCS, is likely to always be limited in its uptake in the absence of overwhelming public/customer pressure and/or the credible threat of regulation. To the extent that it does lead to change, it can be expected to be more widely adopted by firms that are already acting more responsibly, and by firms with a higher public profile.
It can reasonably be expected that less responsible firms and those with a lower public profile will not be as likely to make changes if they are only voluntary not mandatory.
It seems that the situation is one where the affected industry:
- Acknowledges that there is a problem – indeed this has been the case since the 1980s.
- Has identified the interventions needed at a facility level in the transport and handover of pellets but cannot achieve widespread compliance across the wider supply chain.
What can we do about it?
In a 2018 report for the European Commission, Eunomia recommended implementing a supply chain approach. This would require companies placing plastics on the market – starting with firms placing the largest amount of plastics on the market – to ensure that their entire plastics supply chain, including all logistics operations, has implemented best practice measures to prevent pellet loss.
These best practice measures would build on those developed in Operation Clean Sweep guidance, with an improved emphasis on the safe transport of pre-production plastics.
The brand owners would be able to demonstrate their compliance with this best practice through the use of one of several accredited, independent, privately operated certification organisations, with independent audits repeated annually to ensure continued compliance.
Such an approach would ensure vertical integration in pellet management practices at the interface between the different stages, such as producers to transporters, and from transporters to converters.
Significantly, due to the incorporation of extra-EU supply chains (as the focus is on plastic goods placed on the EU market, regardless of where they are made), there would be no disadvantage for EU producers, transporters and converters relative to those outside the EU who are selling to the EU market.
This approach was subsequently taken up by the OSPAR Commission in their Recommendation 2021/06 on the reduction of plastic pellet loss into the marine environment. Meanwhile, the European Commission has published its proposal, presented in October 2023, for a regulation on preventing plastic pellet losses.
This is based on a slightly different approach, with a focus on regulating facilities and transport within the EU, and with several exclusions and reduced requirements for smaller operators. The proposal will now be discussed by the European Parliament and the Council before being finalised.
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