Ms Siobhán Dean:

Yes. I thank the joint committee for this opportunity to consult on the prohibition of certain products containing plastic microbeads Bill 2018. The Irish Cosmetics Detergents and Allied Products Association is the IBEC group representing Irish companies engaged in the manufacture, distribution and sale of cosmetics, detergents and allied household products. The cosmetics and detergent sector takes the issue of plastic aquatic litter seriously and shares the overarching goals of the Government and European Union to address this challenge. I am joined today by Mr. John Chave, director general of Cosmetics Europe, a European trade association representing more than 4,500 companies and national associations in the cosmetics and personal care sector in Europe.

The cosmetics and detergent sector has taken positive action on the occurrence of plastic microbeads in the marine environment. Building on voluntary initiatives taken by its individual members companies, on 21 October 2015, Cosmetics Europe issued the following recommendation to its members:

In view of the public concerns expressed over plastic debris in the marine environment, and given the availability of alternative materials, Cosmetics Europe recommends its membership to discontinue, in wash-off cosmetic products placed on the market as of 2020: the use of synthetic, solid plastic particles used for exfoliating and cleansing that are non-biodegradable in the marine environment.

Results of 2018 datacollected by Cosmetics Europe show that between 2012 and 2017, the European cosmetics industry phased out as much as 97.6 % of plastic microbeads used for exfoliating and cleaning purposes in rinse-off cosmetics and personal care products. The European industry is on track to achieve 100% phase-out of plastic microbeads by 2020. Our voluntary action was taken in spite of it being widely acknowledged that the cosmetics sector is a minor potential contributor. Studies estimate a potential contribution of between 0.1% and 2% of the total aquatic plastic litter. This potential minor contribution is ever decreasing as progress has been made towards the completion of the phase-out of plastic microbeads. In fact, by far the largest potential contributors to microplastic marine litter are from the breakdown of bigger plastics, for example, car tyres, plastic pellets and microfibres from clothes.

Similar to personal care products, the use of microbeads in home care products is very limited and is further decreasing as several companies have already announced their intention to reformulate their product in a more environmentally friendly way.

In the 2016 European Commission study to support the development of measures to combat a range of marine litter sources, detergents and maintenance products were not identified as key contributors to marine plastic litter.

The sector traditionally makes limited use of materials that could qualify as microplastics. In acknowledgment, however, of the potential litter stemming from secondary microplastics during the washing of synthetic textiles, the industry is actively engaged in a cross-industry agreement, through the European Free Trade Association, with European industry associations representing the global value supply chain of garments and their maintenance. The agreement, which is referred to in the European Commission's strategy for plastics, supports the need for further investigation and a better understanding for the prevention of microplastics released into the environment during the washing cycle. It also aims to find feasible solutions based on science and research that can be effectively applied by industry, consumers and authorities.

In conclusion, voluntary actions taken by the industry are proving extremely effective at removing plastic microbeads from products. Any proposed ban of microbeads in detergents and rinse-off personal care products must be supported by clear definitions to operate effectively. The proposed definition of microbeads in the general scheme is too broad and, as a result, would prevent Irish manufacturers manufacturing rinse-off cosmetics and detergent products that would otherwise be permitted in EU countries. It would also remove many products on the Irish market until they were reformulated. The business and consumer impacts in the general scheme, however, do not take this into account. Pending the outcomes of the European Chemicals Agency REACH restriction process, it is essential for the smooth functioning of the European Single Market not to create regulatory barriers to trade. We encourage the scope of any proposed regulatory measures to align with existing member state legislation, such as is in place in Britain and pending in Northern Ireland, to avoid disadvantaging the Irish manufacturing industry.