The Plastic Pellet Crisis Exposes Weakness in proposed EU Regulation

After yet another container loss, the shores of Galicia, Asturias and Cantabria (Spain), along the Atlantic coast, are under siege from a relentless tide of microplastics. Those small particles washing ashore are plastic pellets, which are the raw material used to manufacture all plastic items.

As a coalition of NGOs, we are raising our collective voice to call for action to stop this environmental catastrophe stemming from the systemic poor handling of plastic pellets throughout the value chain. And this can be achieved with the adoption of ambitious EU legislation.

The Galician NGO, Noia Limpa, was the first to sound the alarm, unveiling the shocking dimension of this plastic pellet pollution. The scale of this issue, resulting from a ship losing several containers at sea, is staggering. Out of over a thousand lost bags, over one hundred filled with pellets have already been found on the Spanish shore, each potentially containing up to a million pieces of plastic pellets. Some bags were torn and leaking small plastic particles – composed of polyethylene and UV stabilizers – into the environment. The greater concern is that the vast majority of the lost bags have not yet been found – they will either drift away and contaminate other regions or remain in the ocean and release their hazardous load.

Once in the ocean, pellets float widely, causing widespread harm to flora and fauna. Their small size makes them nearly impossible to clean up. Moreover, the pellets contain harmful additives, such as UV light stabilizers, and act as toxin magnets and transport mediums for toxic substances, adding to the risks posed to human health and the environment.

This crisis is not isolated to Galicia; it is a European and even a global problem. NGOs have been increasingly reporting plastic pollution cases for years, and as plastic production is expected to rise, this will only escalate dramatically.

This crisis is also not solely a maritime transport issue. It is an illustration of the careless handling of plastic pellets by an entire industrial sector. Plastic pellets are spilled at each stage of the value chain, from production and conversion sites to recycling installations and during transportation. In the European Union alone, an estimated 160,000 tons of plastic pellets are lost annually.

The current events only stress the need for bold EU measures to prevent this pollution and finally hold polluters accountable. It is appalling that, as of now, taxpayers are the ones bearing the cost of the countless incidents of pollution across the EU.

The good news is that European legislation is currently under review, following a proposal for a regulation from the European Commission tabled in October 2023. However, as it stands, the text will be too weak to make a significant difference. Shockingly, while being responsible for the Galician catastrophe, maritime transport is simply exempted from any requirements. Another major flaw is that smaller enterprises from the plastic value chain benefit from symbolic measures which will not be sufficient to prevent pellet spills.

The EU must urgently address this regulatory gap, and the culture of impunity must be crushed. An ambitious and comprehensive regulation is needed.  Thus, prioritizing prevention should be non-negotiable, and accountability for all pellet handlers must be a universal demand – irrespective of a company’s size or a mode of transport, maritime included.

Real change can only be achieved with Members of the European Parliament stepping up and showing political courage under the current mandate. With the EU elections happening only in a few months, current Members of the European Parliament will be judged on their ability to respond in practical terms to the problems faced by European citizens. The time for half-measures and empty promises is over; the citizens demand decisive action now.

We call on the European Parliament to step up in the fight against microplastic pollution by adopting a comprehensive and ambitious regulation.


Break Free From Plastic
Environmental Investigation Agency
European Environmental Bureau
Fauna & Flora International
Gallifrey Foundation
Rame Peninsula Beach Care
Noia Limpa Entre Todos
Surfrider Foundation Spain

Plastic Soup Foundation
Rethink Plastic
Seas at Risk
SOS Mal de Seine
Surfrider Foundation Europe
Ocean Care
Good Karma Projects

Prevention and reuse – the only solution to record levels of packaging waste

The latest Eurostat data on packaging waste, published in October 2023, reaffirms this upward trajectory with a new record of 188.7 kg per capita in 2021 – a 6% increase in waste generation in only one year. The same data also reveals that recycling rates have stagnated since 2010. The packaging sector is now responsible for approximately 59 million tonnes in CO2eq, more than the annual emissions of Hungary. Packaging is also a major driver of virgin resources exploitation – using 40% of plastic and 50% of paper in Europe.

Without action, the EU would see a further 19% increase in packaging waste by 2030. This
reality is incompatible with Europe’s ambitions for climate neutrality and resource efficiency.
The Commission proposal for a packaging and packaging waste regulation (PPWR) responds
directly to this challenge with the goals to:

  • Prevent the generation of unnecessary packaging waste: reduce it in quantity, restrict
    overpackaging and promote reusable packaging solutions;
  • Make all packaging on the EU market recyclable by 2030;
  • Reduce the need for primary natural resource use and create a well-functioning market for
    secondary raw materials (notably plastics).

In this regard, the PPWR offers a necessary pathway to reverse the trend of an ever more
material and carbon intensive packaging sector, while creating real economic opportunities for
truly circular businesses.

In light of the latest official data cited above, opposition to a more pragmatic and systemic
approach to reducing Europe’s dependency on single-use packaging looks increasingly
difficult to defend. However, the PPWR proposal has been one of the most intensely lobbied
files of this political term. Policy makers across institutions have complained about an endless
influx of requests, untransparent studies and increasingly aggressive lobbying strategies. The
attempts to undermine key waste prevention measures of the regulation were, regrettably, not
accompanied by any credible alternatives to tackle the growth of packaging waste.
As a result of this intense negative lobbying, the Parliament’s responsible committees diluted
the ambition of the proposal introducing several exemptions which undermine the Regulation’s
chances to stop the uncontrolled growth of packaging waste.

In November, all members of the European Parliament will choose either to provide a
credible solution to the packaging waste crisis by supporting reuse targets (art. 26) and
tackling unnecessary packaging (art.22 & Annex V), or they will surrender to the
aggressive lobbying of the single-use packaging industry.

FAQ to sort through the trash talk

1) Was the Commission proposal for a packaging regulation too ambitious?

The reduction of packaging waste proposed by the Commission is very modest when compared
with the more than 20% increase in packaging volumes over the last decade. A 5% reduction of
packaging waste by 2030 should also be put in the context of the European climate target to
reduce emissions by 55% by 2030 – which major industrial actors in the packaging sector are
not on track to meet.
The proposal was not disproportionate or excessive: even if all the waste prevention and reuse
measures contained in the draft regulation were to be fully applied, this would still be insufficient
to achieve a 5% reduction of packaging waste generation by 2030. Hence, the regulation
clarifies that Member States will have to take additional measures to meet their waste
prevention targets. The position of the Parliament ENVI Committee further widened this gap by
introducing several loopholes and exemptions on reuse targets and restrictions for unnecessary
packaging, thus undermining the EU chances to stop the growth of packaging waste in a
harmonised way.

2) Do we really need to focus on waste prevention? Can’t recycling be enough?

Recycling – on its own – will not reduce waste levels and is insufficient to reduce Europe’s
material and carbon footprints at the speed and scale needed to achieve our climate and
environmental goals. Also simply substituting one single-use material for another is not a
genuine solution
to the waste crisis.
The rate of packaging waste recycling in the EU has essentially stagnated since 2010. This is
despite many industry initiatives and policies focused on recycling. In other words, any
improvements in recycling have struggled to keep up with growing levels of waste. The EU must
resist the temptation to continue business as usual focusing only on marginal improvements in
waste management as this approach has already proven to be insufficient. Instead, Europe
must develop a comprehensive approach to circular packaging which, alongside ensuring all
packaging is recyclable, prevents the generation of unnecessary waste and scales up reuse.

3) Why don’t we just shift from plastics to single-use paper, it’s green, renewable, recyclable?

Some of the largest polluters in the packaging value chain, led by single-use paper producers
and McDonald’s, conducted a massive lobbying campaign to greenwash throwaway paper as
a sustainable alternative to single-use plastics and reuse. New research proved this is a false

Paper packaging is already the largest packaging waste stream in Europe. With 34 million
tonnes of waste generated in 2021, paper alone makes up for more trash than the two next
largest waste material streams, plastic and glass, combined.

  • Paper packaging is already the largest packaging waste stream in Europe. With 34 million tonnes of waste generated in 2021, paper alone makes up for more trash than the two next largest waste material streams, plastic and glass, combined.
  • Paper packaging used in the HORECA sector is particularly problematic as it is usually
    combined with plastic or chemical coatings, it rarely includes recycled content or is
    successfully recycled into new packaging.
  • The raw materials for paper packaging are increasingly imported from developing countries,
    contributing to global deforestation and water stress. On average, three billion trees are cut
    each year for global paper packaging.

To genuinely prevent waste, the EU must adopt effective rules to address the uncontrolled
growth of single-use packaging, no matter the material it is made of.

4) What is the problem with the current rules of the Packaging & Packaging Waste Directive?

One of the major limitations of the current Directive, and a primary motivation for its revision,
was that it was too vague and unenforceable. As a result, it failed to prevent even the worst
cases of overpackaging, e.g. apples in shrink film and polystyrene trays or excessive empty
space in online deliveries. There is now a risk of repeating the same mistake by introducing
unnecessary derogations, exemptions and loopholes leading to regulatory uncertainty and
undermining the regulation’s practical effectiveness in the Single Market.
The original PPWR proposal already contained many unnecessary derogations and
exemptions. Instead of closing these gaps, this situation was worsened by the position adopted
by the Environment Committee which widened loopholes on key waste prevention measures.
The sweeping and broadly defined derogations introduced, e.g. on art. 26 on reuse (2040
targets not binding anymore) and art. 22 & Annex V on unnecessary packaging (broad
unjustified exemption for paper) undermine their practical implementation and enforcement.
Instead of a patchwork of loopholes to meet lobbying requests, the European Parliament must
deliver a harmonised set of rules that can be practically implemented and enforced to reduce
waste, restrict unnecessary packaging and promote reusable solutions.

5) What has been the impact of the unprecedented lobbying from the throw-away packaging industry?

The packaging regulation has been one of the most intensely lobbied files of this political term.
Policy makers faced an endless influx of untransparent studies and increasingly aggressive
lobbying strategies. This is confirmed by the analysis from InfluenceMap showing significant
opposition from industry groups which is putting the EU’s efforts to address packaging waste at

Since the publication of the proposal, several misleading and unsubstantiated lobbying
arguments have managed to divert attention. This included overinflated fears about the impacts
on hygiene, food waste and existing recycling infrastructures as well as untransparent studies
claiming that single-use packaging would have a better environmental performance than reuse

Despite having been widely debunked by NGOs, scientists and the Commission, these false
arguments have successfully influenced the positions of the Parliament Industry and
Agriculture committees
. The pushback from laggards in the packaging industry, has not only
distracted from the useful discussions on how to improve the proposal, but it also succeeded to
water it down. While all available independent evidence supports more action on waste
prevention, the compromises voted in ENVI Committee show an overall reduction on the level of
ambition. As things stand, the European Parliament is poised to significantly lower the ambition
of this regulation compared to the original proposal, the opposite of the constructive role that
MEPs have played in other Green Deal files.

6) Is reuse really better than single use? What about industry-funded LCAs?

In line with the waste hierarchy, extensive independent scientific literature, illustrates the potential
of reusable packaging systems compared to single use. Well-designed reuse systems can reduce
waste at source, cut energy, emissions, resource and water use, and create jobs and business
opportunities. Evidently these systems must be well-managed and meet a minimum number of
rotations through efficient collection, washing and redistribution to maximise their environmental
Decision-makers should base their decisions on peer-reviewed and independent evidence rather
than on biased studies sponsored by vested interests in order to sow doubt and maintain the
status quo. Regrettably, life cycle assessments commissioned by single use packaging producers
have misled policy makers. These studies have been found to exhibit a clear bias using cherrypicked scenarios, a worrying lack of transparency and unfavorable assumptions against reuse
(return rates, washing and dedicated return journeys). 58 experts in life cycle assessment have
urged caution around using packaging industry-funded LCAs to make general conclusions in the
sector, pointing to their lack of transparency or flawed assumptions.
In the meantime, new evidence has emerged which bolsters the Commission’s proposals on
waste prevention and reuse, in particular for the food and beverages sector. Preliminary
from the Joint Research Centre, show predominantly favourable results for reuse systems
compared to their single use packaging equivalents.

7) What about the socio-economic impacts of the regulation?

The measures included in the PPWR are expected to create 29,000 new green jobs and
generate savings for consumers of around 100EUR per year by 2030. New rules ensuring all
packaging is recyclable will increase the value of waste and thus improve the viability of the
recycling sector. Recycled content targets will also create certainty for investors. In parallel,
scaling up reusable packaging will depend on local job creation and new businesses
throughout Europe to manage reverse logistics and pooling infrastructure.
In contrast, although single-use packaging production (for example for take-away) experienced
rapid growth in recent years, this has rarely resulted in job creation due to high levels of
automation and consolidation in packaging manufacturing. Growing material prices (up 23% in
two years
) will also make reuse increasingly economic. Furthermore, market pressures have
seen a growing share of raw materials (such as paper pulp from Brazil) or finished single-use
packaging (such as finished packaging from China) being imported from outside the EU.
Banning the worst cases of deceptive over-packaging practices, such as false bottoms or
double walls, will also prevent citizens from being misled by unfair practices.

8) Is reusable packaging unhygienic? Is all packaging safe?

It’s important that all packaging is clean and hygienic: this is not dependent on whether the
packaging is single use or reusable
. Safe reusable food packaging systems have been
operating at scale across Europe without incident for decades. Each time we eat from a
ceramic plate in a restaurant we also participate in a reuse system. In the case of refill – where
citizens bring their own packaging – the proposal also allows companies to reject dirty
packaging and the ENVI report removes their liability.
Missing from this debate, however, are concerns around chemical safety of packaging.
Unfortunately, toxic substances are still widely used in many types of food packaging, which is
a significant source of direct exposure of the EU population to harmful substances. The ENVI
report rightfully restricts two of the most problematic chemicals PFAS and BPA and provides
the possibility to further de-toxify packaging where it poses a considerable risk to human

9) Does single-use packaging prevent food waste?

Food waste and packaging waste have grown simultaneously in Europe. On this issue, it
cannot be argued that single-use packaging has helped to reduce food waste levels in a
meaningful way. Following an extensive meta-analysis of 33 life cycle assessment studies,
UN Environment also concluded that shelf-life extending packaging should be reserved for
the foods with the highest environmental impact (such as meat and dairy products), while
products such as fruit and vegetables could mostly be sold without packaging. Many types of
packaging were also shown to increase food waste, such as multipacks which encourage
over purchasing
(such as nets of citrus fruits or bulb vegetables like onions).
In this way, the Commission’s proposal follows the evidence, and it already provides ample
flexibility to guarantee products’ protection, e.g. excluding restrictions for packaging with a
“demonstrated need” to prevent food waste (such as protection for fragile berries).

10) Is it true that reuse will undermine existing investments in recycling?

The business case for recyclers is not only dependent on the total amounts of packaging waste
generated, but – more importantly – on its recyclability, and on the quality and demand for
recycled material. The early warning reports on the 2025 packaging recycling targets reveal that
recycling infrastructure is, in many areas, struggling to keep up both with the volumes of waste,
difficult to recycle designs and materials, and low-quality sorting. Similarly in a response to
concerns from the Italian Parliament
, the Commission explained: “the available infrastructure
including in Italy, are not going to be sufficient to treat all packaging waste”.
Though the new regulation aims at reducing the total amount of waste, it also has the objective
to make all packaging recyclable in an economically viable way by 2030. This increase in
recyclability of waste will offset the reduction in waste generation by rewarding recyclers with
growing volumes of quality materials. In this way, waste prevention measures, including reuse,
do not need to undermine investments in recycling infrastructure. Furthermore, other measures
such as deposit-return systems for single-use and reusable packaging, as well as recycled
content targets will all improve the business case for recyclers.

11) Who actually wants reuse? Is it just an NGO dream?

Establishing re-use systems at scale across Europe is not a utopian idea, but a transition that is
already underway. Reuse now needs fundamental policy support to thrive. Several Member
States – including France, Germany, Portugal, the Netherlands and Luxembourg – have already
implemented policies in support of reuse, including reusable packaging targets and restrictions
on overpackaging. At the same time, across Europe a multitude of dynamic and disruptive
businesses are already operating reusable packaging systems at local, regional and national
level. Local authorities also support the transition to reusable packaging, as this will reduce
public waste management costs which are driven by littering and the uncontrolled growth of
single-use packaging waste.
Without harmonised policy intervention at EU level, however, reuse systems will not reach their
optimum scale and performance and European businesses will not face a level playing field
within the Single Market. This is why a rapidly growing coalition of businesses, cities, and civil
society organisations
is now calling for ambitious reuse targets at the EU level without delays.
Also, more than 100,000 citizens, organisations, businesses and cities had already called for
to become the norm at the beginning of the regulatory process.
The business case of reusable packaging systems is increasingly evident and provides an
unmissable opportunity for Europe’s economy. Instead of pouring precious resources into shortlived throwaway items, efficient reuse systems will enable businesses and consumers to reap
the utility offered by packaging, while preserving value over time. For this to happen, it will be
crucial to deliver clear and ambitious reuse targets for 2030 and 2040 to provide businesses the
confidence to invest and innovate.


ECOS, European Environmental Bureau, Zero Waste Europe and the #BreakFreeFromPlastic members Deutsche Umwelthilfe and Recycling Network Benelux.

NGOs call on EU to urgently address microplastics unintentionally released into the environment

Dear President von der Leyen:

During your 2019 to 2024 Presidency, the EU has made important progress on a variety of environmental priorities. We, the nine undersigned non-governmental organisations, now write to urge you to deliver on your vision to curb microplastic pollution in the European Union and cement your legacy as a global leader in tackling plastic pollution – and microplastic pollution, specifically – with decisive action in the next few months. This would firmly set the EU on the path to meeting its ambitious target of a 30% reduction in microplastic pollution by 2030, as set out in the Zero Pollution Action Plan

If no action is taken, direct emissions of microplastics to the marine environment are expected to more than double globally in the next twenty years from a 2016 baseline. In high-income economies such as the EU, pollution from these microplastic sources is estimated to exceed that from macro-plastics such as single-use plastics and packaging. The scientific evidence on the impacts of microplastics is overwhelming, with studies demonstrating their contribution to pollution and harm to human health and ecosystems

Given the magnitude of microplastic pollution, we commend the Commission for making strides towards curbing the release of microplastics into the environment. The recent adoption of the European Commission’s proposal on the restriction of intentionally-added microplastics by the REACH Committee is a step in the right direction and aligns with the European Chemicals Agency’s findings that microplastics pose an inadequately controlled risk to the environment.  

Nevertheless, microplastics unintentionally released from paints, tyres, pellets, and textiles still require urgent attention: these sources represent the vast majority of microplastic emissions to the environment. We are encouraged to see progress on legislative initiatives to curb emissions from tyres and textiles through Euro 7 and the EU strategy for sustainable and circular textiles, respectively, and see the potential for the Ecodesign for Sustainable Products Regulation to cover sources such as paint, tyres, geosynthetics and textiles. However, after years of delays, we are yet to see the release of a dedicated proposal to reduce microplastic emissions from the aforementioned sources and tackle the release of pellets – the third largest source of microplastic emissions in Europe.  

Pellet loss occurs at every stage of the supply chain, yet loss and spills are preventable by implementing low-cost pellet handling best practices. Since 1991, the plastics industry has derived a set of best practice measures known as Operation Clean Sweep (OCS). However, OCS is a voluntary scheme with a lack of monitoring, compliance, and enforcement mechanisms. Further, only approximately 5% of the European plastics industry has committed to OCS. 

Meanwhile, pellet pollution continues to plague Member States. A study funded by the European Commission estimates that 167,431 tonnes of pellets may be lost to the environment in Europe per year. Tackling pellet pollution is clearly high on the agenda for Member States. In 2021, the OSPAR contracting parties adopted Recommendation 2021/06, emphasising the need to develop and implement pellet loss prevention standards and certification schemes based on best practices, aiming to prevent or significantly reduce plastic pellet loss across the entire supply chain. In a call for ambitious measures, five Member States underscored the need for precautionary measures at the EU level as “national and voluntary measures alone are not sufficient” and that “measures should be taken early in the lifecycle.”  

What is needed now is mandatory, EU-wide legislation that obligates all pellet-handling companies to provide independent verification that pellet loss prevention measures have been implemented, maintained, and monitored for effectiveness. EU-wide action would eliminate this preventable source of microplastic pollution, ensure a level playing field for businesses of all sizes, and demonstrate global leadership in enacting decisive measures to address pellet loss. EU legislation can also serve as a blueprint for action on microplastic and pellet pollution in the ongoing negotiations to develop a legally binding instrument on plastic pollution. 

In conclusion, we urge the European Commission to prioritise the swift release of this crucial proposal, which is vital for delivering the 30% microplastic pollution reduction target, advancing the objectives of the Green Deal before the end of this legislative mandate in 2024, and strengthening Europe’s position as a global leader in addressing plastic pollution.  

Yours sincerely, 

Environmental Coalition on Standards: ECOS   

Environmental Investigation Agency 

Fauna & Flora 


Gallifrey Foundation 

The Pew Charitable Trusts   

Rethink Plastic  

Seas At Risk  

Surfrider Foundation

NGOs Urge Members of European Parliament to Take Urgent Action to Reduce Microplastic Emissions from Tyre Abrasion

23 June 2023

As Members of the European Parliament, your role is pivotal in delivering a 30% reduction in microplastics released into the environment by 2030 as per the EU target set in the Zero Pollution Action Plan. We, the undersigned non-governmental organizations (NGOs), are writing to urge you to take action to address the pressing issue of microplastic emissions from tyre abrasion. Owing to reductions in tailpipe emissions and the shift to zero-emission mobility, it is estimated that by 2050 up to 90% of particulate emissions from road transport in Europe will come from non-exhaust sources—namely tyres and brakes—representing the next frontier for regulatory efforts to improve air quality. Furthermore, non-exhaust vehicle emissions from tyres represent the second-largest quantified source of microplastic emissions in Europe, accounting for an estimated 450,000 to 500,000 tonnes per year, making tyre abrasion limits a priority for protecting both human health and the environment and critical to meeting the 30% reduction target.

Microplastics – plastic particles less than 5mm in size – have been found in human lungs, blood and the placentas of pregnant women. They can cause adverse effects on the reproduction, growth and survival of aquatic organisms, as well as potential negative impacts on soil ecosystems and plant growth. Tyre particles also include a number of harmful chemicals that can leach into the environment and affect human health, including polyaromatic hydrocarbons (PAHs), 6PPD and heavy metals such as zinc and lead. Furthermore, studies have shown a significant association between exposure to airborne particle pollution and human health risks, such as cardiovascular effects and respiratory problems. For tyre wear particles specifically, laboratory studies indicate inflammatory effects on human cells.

Given how critical reducing microplastic emissions is for safeguarding human health and protecting natural ecosystems, the Commission’s proposal for new Euro 7 vehicle emission standards, released in November 2022, seeks to establish tyre abrasion limits for the first time. Under this legislative process, the European Parliament has a new opportunity to protect the well-being of European citizens and our environment.

However, we are concerned by the proposed amendments on Recital 12 and Article 15 put forward by the rapporteur in the Committee on the Environment, Public Health and Food Safety, which aims to bind the measurement methods and proposing tyre abrasion limits to the work being undertaken by the GRBP/GRPE Task Force on Tyre Abrasion, conducted under the UN World Forum for Harmonisation of Vehicle Regulations (WP29). We are supportive of the work underway in WP29 and understand that global alignment on regulation (in particular testing methodologies) reduces complexity for the auto industry. However, requiring full alignment on the timeline and ambition of limits – with a still-to-be developed UN regulation – could unnecessarily delay the work to establish tyre abrasion limits within the EU and result in weak and ineffective pollution limits hence jeopardizing the EU’s ability to meet the reduction target set out in the Zero Pollution Action Plan and infringing on the EU’s sovereignty to set regulation.

We, therefore, call on Members of the European Parliament to empower the European Commission to propose secondary legislation, including the test method and abrasion limits for tyres by December 2024, taking into account findings from the WP29 process where applicable but allowing for higher ambition if the limits set by the UN regulation are weak or faster progress within the EU if there is no agreement or delays at the UN level. This would ensure that the EU is able to establish tyre abrasion limits by the end of 2024, as currently foreseen in the Commission’s Euro 7 proposal.

In addition, we invite the European Parliament to consider amendments to:

  1. Add a reference to the Zero Pollution Action Plan in order to, at a minimum, align future tyre abrasion limits to the targets set out in the plan.
  2. Clarify that type approval of tyres – a process to certify that the product meets specified requirements – will apply to tyre manufacturers and to all new tyres placed on the market, and not just to tyres intended for new vehicles approved under the Regulation.
  3. Request that the Commission prepare a report reviewing the chemical toxicity of tyre particle emissions and propose policy measures accordingly based on the findings of the report.

If adopted, such policy recommendations would mark a significant milestone in addressing microplastic pollution from tyre abrasion, setting a global precedent. Given the projected increase in microplastic emissions from tyres and their proven health and environmental impacts, urgent and binding action at the EU level is needed to address this problem at the source. With ambitious legislation on tyre abrasion, the EU can lead the way to tackle microplastic pollution globally, securing a cleaner and safer environment for all.


“We are now plastic farmers” – the human cost of waste colonialism

Devayani Khare and Pui Yi Wong

Plastic waste exports can have catastrophic impacts on the environment and human rights, especially the right to a clean, healthy and sustainable environment. Plastic waste ends up polluting water, contaminating air, and harming the health of people already facing poverty and marginalization. This is a terrible environmental injustice!

Dr David R. Boyd, UN Special Rapporteur on human rights and the environment.

On December 10, 1948, the Universal Declaration of Human Rights (UDHR) was passed – a milestone document which proclaims the inalienable rights that everyone is entitled to as a human being, irrespective of race, colour, religion, sex, language, political or other opinion, national or social origin, property, birth or other status.

In 2022, 75 years later, 161 countries at the United Nations General Assembly passed a resolution recognising the right to a clean, healthy, and sustainable environment as a human right. Yet, vulnerable communities globally continue to face injustice as a result of plastic waste mismanagement and pollution.

Millions of tonnes of plastic waste are traded globally every year. Several reports show that exported plastic waste often ends up in landfills, is burnt or incinerated as fuel, or is discarded into waterways. This has serious implications for the health and wellbeing of communities living at the fringes of dumpsites or factories, workers in unauthorised plastic waste recycling facilities, as well as the environment.

Here are personal stories of individuals and communities, the disproportionate costs they bear due to waste colonialism, and how their rights to health and a healthy environment have been violated.


In January 2018, China implemented its National Sword Policy to stop most plastic waste imports. Between January and July that year, Malaysia, a tiny country flanking the South China Sea, imported nearly half a million tonnes of plastic waste. What happened, and who is bearing the true costs of this reckless economic move?

Quote Source: The Recycling Myth report, Greenpeace Malaysia, 2018. Quote Source: Lay Peng Pua, Kuala Langat Environmental Action Association.


Rural communities in Indonesia who worked in lush-green maize and paddy fields not so long ago, have turned to waste work today. Places like Kragilan and Bangun village in East Java have become dumpsites, where plastic scraps shipped along with waste paper imports are discarded or incinerated. 

Sifting through plastic scrap has become a community-level cottage industry. Waste pickers and communities living around recycling factories constantly breathe in toxic fumes generated by burning plastic. These images are from Bangun, East Java, Indonesia.

Quote source: DISCARDED: Communities on the Frontlines of the Global Plastic Crisis report, by GAIA. Image credits: Fully Syafi/ECOTON


As awareness increases in some countries across Southeast Asia and restrictions on plastic waste imports are implemented, Turkey has become Europe’s plastic waste destination. 

This resulted in a surge in illegal disposal methods: dumping and burning of imported garbage has been reported in İzmir and İstanbul, with much of the activity centred in Adana.

The recent influx of EU plastic waste imports also contributed to the growth of the plastic recycling sector, harming the health of workers and nearby communities. 

In the past 16 years, there has been a 241-fold increase in plastic waste importation to Turkey – the soil, air and water around dumping sites bear testimony to the chemical poisoning caused by burning plastic waste.

Image credits: Caner Ozkan / Greenpeace (via Basel Action Network on Flickr – CC BY-SA-NC), Human Rights Watch. Quote source: “It’s as if they’re poisoning us”: the health impacts of plastic recycling in Turkey, Human Rights Watch.

The Philippines

In 2014,  the Philippine Commission on Human Rights (CHR) issued a “Fifteen-Point Human Rights Agenda” to uphold “the people’s right to chemical safety” which “acknowledges that trade of toxic wastes, products and technologies, collectively toxic trade, also forms a disincentive towards attaining Zero Waste resource management.”

Human rights defenders have organised protest rallies to defend their right to a healthy environment, drawing attention to the fate of mixed plastic trash being dumped in the country, and even ensuring the repatriation of more than 100 shipping containers back to Canada in 2019 and South Korea in 2020.

Image 1 credits: courtesy Greenpeace Philippines and EcoWaste Coalition, first published in the report: Waste trade in the Philippines: How local and global policy instruments can stop the tide of foreign waste dumping in the country, March 2020.
Image 2 and 3, and quotes: Chinkie Peliño-Golle

Who is responsible?

Perpetrators of waste colonialism must be held accountable for these human rights abuses. The adverse impacts of waste trade on human rights is faced disproportionately by developing countries – to better protect these communities, PLASTIC WASTE TRADE MUST STOP!

We are in the midst of a worldwide plastics crisis. International waste trade creates an illusion of proper recycling, when there is actually a geographical shifting of the plastic waste problem, affecting the rights of the most vulnerable.

A human rights-based approach calls for a vision of plastics policy that aligns with scientific evidence, centres on principles of non-discrimination, accountability and informed participation and gives special attention to the needs of people in vulnerable situations.

Strict controls must be instituted to prevent further pollution and to hold plastics and chemical producers accountable for the damage already caused, including remediation and compensation.Safeguarding the human rights of present and future generations that are compromised by the growing toxification of the planet demands that the international community reverse the plastics crisis.

Dr Marcos A. Orellana, UN Special Rapporteur on toxics and human rights.

What can we do?

This World Human Rights Day, there are glimmers of hope. 

Communities impacted by the negative impact of plastic waste imports from Asia, Africa and Latin America have called for an end to the practice. Countries have tightened controls in attempts to stem pollution from plastic waste imports, while Thailand plans to phase out all imports by 2025

On December 1, the Environment Committee of the European Parliament voted to set a ban on EU plastic waste exports to OECD and non-OECD countries, as part of the revision of the EU Waste Shipment Regulation. The European Parliament Plenary will have to confirm these measures in another vote, followed by the Council. 

Keep up the pressure to ensure the export ban gets confirmed, and that the final decision includes stronger measures against waste dumping within the EU – send this letter to European embassies in your country!

You can also help raise awareness about what’s wrong with plastic waste exports, or better still, sign our #StopShippingPlasticWaste petition!

Further Reading and Resources:

Video: EU decision makers visit pellet polluted petrochemicals site in Ecaussines, Belgium

For over a decade, the town of Ecaussines in Belgium has been facing the destructive impacts of pollution from Plastic Pellets also known as nurdles, spilled by the petrochemical complex present in the area.

160,000 tons of pellets are dumped into the environment every year in Europe 🇪🇺 Last March, Surfrider Foundation Europe and the Rethink Plastic alliance decided to invite decision makers to witness this pollution with their own eyes.

Once again, the industries are proving that the voluntary Operation Clean Sweep initiative is not working to reduce plastic pellet pollution – as shown in other cases such as Tarragona.

Packaging at the core

Packaging at the core of pollution

Overall production of packaging and packaging waste has steadily grown over the past 20 years. In 2018 a record high of 174 kg of packaging waste per person was reached in Europe. Between 2009 and 2019, paper & cardboard were the main type of packaging waste per weight (32.2 million tons in 2019), ahead of plastic and glass (15.4 and 15.2 million tonnes, respectively, in 2019). 

Currently, most packaging in Europe is:

  1. Single-use:  with enormous environmental impacts from production down to waste, including resource extraction; use of raw materials; land, energy, and water use; and CO2 emissions. As levels for single-use packaging continue to rise, current waste management systems cannot cope. 
  2. Warming our planet: Research shows that across their lifespan, plastics account for 3.8% of global greenhouse gas emissions. That’s almost double the emissions of the aviation sector. In order to manufacture just one kilogram of plastic, 3.5 kg of CO2 are emitted into the atmosphere. And incineration of one particular type of plastic packaging (40% of plastic demand) waste amounted to 16 million metric tons of CO2 in 2015.  In 2019, the global production and incineration of plastic (including plastic packaging) emitted more than 850 million metric tons of greenhouse gases — equal to the emissions from 189 five-hundred megawatt coal power plants. 
  3. Putting our health at risk: In Europe alone, over 8,000 chemicals can potentially be used in food packaging, tableware, and other food contact materials, with many of these chemicals linked to cancer, harm reproduction, and hormone disruption. More about chemicals in food contact materials can be found in these infographics.
  4. Wasting our food: 37% of all food sold in the EU is wrapped in plastic packaging. Packaging, which should protect food and increase its shelf life, is often found to be a driver of food waste. Recent research has shown that wrapping fresh products in plastic packaging does not make them last longer, but rather adds to pollution and food waste. The research concluded that when food products were sold loose, and the best-before dates removed, it could save more than 10,300 tonnes of plastic and about 100,000 tonnes of food from being wasted each year – the equivalent of 14 million shopping baskets of food. Packaging often forces people to buy more than they need, while oversized  packaging and packaging items that are difficult to empty also lead to the waste of perfectly edible food. 
  5. Non-recyclable and not recycled: the overwhelming majority of packaging doesn’t get recycled. Most statistics available on the recyclability of packaging are inaccurate, as the current waste management scenarios do not reflect the real conditions of the sector. Just because a product is recyclable does not mean it will be collected, recycled and turned into new materials and products. Most often, waste management infrastructures lack the functionality to deal with different formats of packaging . The greater the mix of materials within the packaging, the lower the overall quality the recycled material becomes. Currently, most single-use packaging placed in the EU market is made out of complex materials; involving different materials or layers, as well as many different types that should not be recycled together. The presence of many chemicals in packaging along with food leftovers also hampers recycling. Furthermore, current recycling statistics do not take into account the inappropriate disposal. 
  6. Traded as waste sent to countries outside Europe: where it is usually burnt, landfilled, or leaked in the environment. The European Union relies heavily on international trade for its overgeneration of plastic and packaging waste. In 2019, the EU exported a monthly average of 150,000 tonnes of plastic waste beyond its borders. In 2017, plastic packaging accounted for 75% of the plastic waste exported (by weight). Since most single-use packaging are not recyclable, they are exported “for recycling” to third countries – mainly to countries in the Global South with significantly more limited waste management infrastructures. In fact, a third of the plastic packaging destined for recycling is shipped outside of EU territory, where control over whether the recycling process actually happens (or happens under the right conditions) cannot be monitored. 

Packaging at the core of the solution

As a principle, packaging that cannot be safely used, reused and recycled at the end of its life should not be produced or placed in the market in the first place. The solution to stop this packaging pollution chain is logical: the less packaging we produce, use, and discard, and the less materials we extract, the better for our environment and society. This is why it is crucial to think upstream: rethinking and redesigning packaging so that these products are toxic-free, circular by design, and contribute to regenerating ecosystems instead of polluting them. 

  1. Reducing and redesigning packaging is key to solving most of the problems above. By eliminating packaging that we don’t need, we can save resources, reduce emissions, and minimise waste. A good example is the French Circular Economy Law  which seeks to reduce single-use plastic packaging and to develop alternatives such as bulk or reusable packaging. As of 1 January 2022, plastic packaging is banned for most fruits and vegetables in France.
  2. Rethinking the purpose of packaging itself helps to not only prevent packaging waste, but also to prevent food waste as consumers can buy exactly what they actually want to consume – not more, not less!  Promoting local and short supply chains, such as farmers’ markets, community supported agriculture schemes, and basket delivery systems have great potential to connect consumers to the production of food in ways that can help to reduce food and packaging waste.
  3. Reusable packaging systems are a crucial element to this equation. The more times a product can be used, the lower its negative environmental impact, regardless of its material. A reusable glass bottle has 85% less emissions than its single-use counterpart; 70% less emissions than a single-use PET bottle; and also 57% less emissions than a single-use aluminium can.  Setting up well-managed pool systems for washing and redistribution of reusable packaging, is a key instrument to make efficient and effective reuse systems work. 
  4. Specifically on safe, toxic-free packaging, EU legislation is required to phase out the most hazardous chemicals and ensure packaging is safe for use, reuse and recycling. Manufacturers can already introduce  innovative solutions and/or by scaling up existing safer solutions for packaging (e.g. avoiding toxic glues and inks, using glass or metal containers for reusable options). 
  5. Sustainable packaging systems and take-back systems such as deposit return schemes (DRS) enable the return of packaging to the system to be preferably reused, or recycled; and it should be among the high-priority solutions and measures to achieve true circularity for packaging. 

By redesigning packaging with circularity in mind, it is possible to reduce uses of hazardous chemicals; reduce food waste; and get rid of 75% of the waste that is currently being exported, thus mitigating climate change impact through the reduction of carbon footprints. It will also allow us to ensure that this packaging is primarily reused and effectively recycled in Europe at the end of its life. 

This blog is based on the Packaging at the Core Paper, as part of our #GetBack and We Choose Reuse campaigns. A visual representation of this blog can be found in these infographics.

WeChooseReuse – Ekologi brez meja succeeds in winning support for reuse from Slovenian decision-makers

With the right support and conditions, reuse can thrive in Europe, and lead to a much needed effective reduction in plastic use and pollution while supporting a healthy environment and society. 

Reuse is a system in which products and packaging accomplish multiple trips or rotations within their life span, by being returned to a producer and re-used for the same purpose in which they were originally conceived, as opposed to single-use products and packaging designed to be disposed of after one use. Successful reuse systems require infrastructures like refill stations, collection points, storage, cleaning facilities and transport to ensure the packaging or product can go back to the producer for reuse or refill. Systems like this have existed before, and they can exist again. Remember the milk man?

That’s why the Rethink Plastic alliance and #breakfreefromplastic movement are calling on EU decision makers to tackle the significant human health and environmental impacts caused by single-use plastics production and waste by supporting reuse and signing the We Choose Reuse commitment

We need everyone on board for the reuse revolution ! The support of EU decision-makers is particularly critical and timely. The EU is currently designing policies that have the potential to  make reuse the new normal in the EU, notably the Ecodesign for Sustainable Products Regulation, the Packaging and Packaging Waste Directive and the EU Taxonomy on sustainable finance. 

For inspiration on how to engage decision-makers, our #breakfreefromplastic Slovenian member Ekologi brez meja offers their effective engagement process, which gained support from three Slovenian MEPs for reuse – Irena Joveva, Milan Brglez and Franc Bogovič


“Gaining support for #WeChooseReuse from almost half of the Slovenian representation in the European Parliament, who represent from different political backgrounds, is a great forecast for reuse in the EU.” shares Public Relations President at Ekologi brez meja Katja Sreš. “We have used the prepared materials by the #WeChooseReuse campaign team and distributed them among all our MEPs with a given deadline for response. “The teams of Irena Joveva, Milan Brglez and Franc Bogovič responded within minutes and once again lent their voice to one of our causes. I am positive if we would be even more persistent and would send out reminders to the others, we would also get on board with the other five members. Nevertheless, this will be our mission in the next decision-makers call to action.” 

There is an appetite for reuse within and beyond the European Union. By actively engaging with MEPs and using the #WeChooseReuse campaign to illustrate the benefits of reusable systems, EBM have set an inspiring example of what can be achieved through effective engagement. 


Want to do the same? We provide plenty of useful resources for reuse policies, from a guide to setting effective reuse targets to recommendations on how the EU can support the grocery retail sector in reducing packaging and plastic pollution. Feel free to use our above assets, and share using #WeChooseReuse for dissemination and amplification. You can also contact [email protected] or via @RethinkPlastic on Twitter and LinkedIn and we’ll help you take the first step! 

The impact of the EU’s plastic waste trade: a Rethink Plastic alliance event in collaboration with MEP Cyrus Engerer

European Parliament, 11 May 12:00 – 14:00 (hybrid event)

What’s the impact of EU plastic waste trade and how can the EU end its damaging practices and achieve a circular economy?

As all eyes are on the revision of the Waste Shipment Regulation, the Rethink Plastic alliance invites you to the European Parliament to this crucial hybrid event calling on the EU to implement a full ban on EU plastic waste exports.


12.00- 12.30: Light lunch provided
12.30 – 12.35: Welcome, introductory remarks from MEP Cyrus Engerer
12.35 – 12.45: Screening extract of documentary The Recycling Myth on illegal exports to Turkey
12.45 – 13.30: Speeches from:

  • Krista Shennum, Fellow, Human Rights Watch
  • Yuyun Ismawati, Founder of the Indonesian NGO Nexus 3 Foundation, Goldman Environmental Prize Winner 2009
  • Sedat Gündoğdu, Associate Professor, Cukurova University
  • Emmanuel Katrakis, Secretary General, EuRIC
  • Lauren Weir, Ocean Campaigner, Environmental Investigation Agency and the Rethink Plastic alliance

13:30 – 13:50: Q&A with the participants, moderated by the Rethink Plastic alliance
13:50 – 14:00 Closing remarks by MEP Cyrus Engerer

You can register here by 5 May. You can join the event online here.

For further information, contact [email protected]