As European regulations on sustainability reporting continue to evolve, it is becoming increasingly important for companies to disclose information about the environmental impact of their operations, including microplastic emissions. According to the European Commission's report „EU Action Against Microplastics”[1] As of 2023, the main sources of unintentional microplastic emissions in the European Union include paints (including coatings), tires, plastic pellets, synthetic textiles, geotextiles, and, to a lesser extent, detergent capsules.
The purpose of this article is to present the main challenges associated with reporting microplastics under the ESRS standards, which hinder the accurate reporting of these emissions.
What is required in the ESRS
Regulation No. 2023/2772, establishing European Sustainability Reporting Standards (ESRS), in the ESRS E2 section on pollutants, introduces a requirement to disclose information regarding plastic microbeads. According to the ESRS E2-4 standard, if microplastics are deemed material as a result of a materiality assessment, the entity should report the quantity of microplastics. The level of detail required for disclosures is not strictly defined. Organizations disclose both plastic microbeads generated as a result of their own operations and those produced or used in products.
Under the new, simplified ESRS standards, entities should disclose only the quantities of virgin microplastics they produce or use in their products, as well as the amount of microplastics directly released into the environment.
Challenges in Measuring Microplastic Emissions
The first major challenge is the difficulty in identifying and measuring sources of microplastics. Unlike many traditional pollutants, microplastic emissions are not always directly linked to the manufacturing process. They can arise at various stages of a product’s life cycle, including during use, material wear and tear, or transportation. In practice, this means that the entire value chain must be analyzed, which requires advanced monitoring methods and close cooperation with suppliers and customers.
The second challenge is the lack of uniform measurement and reporting methodologies. Although European regulations increasingly address the issue of microplastics, in many cases there are still no widely accepted standards that allow for an unambiguous quantitative determination of emissions. As a result, entities often have to rely on estimates, models, or scientific research findings, which can lead to significant differences in reporting practices among companies and across economic sectors.
Another challenge is the limited availability of data in the supply chain. Microplastics may originate from materials, components, or processes carried out by external business partners. To accurately report their environmental impact, companies must collect data from numerous entities that often do not yet have the appropriate measurement systems or reporting procedures in place.
An additional problem is the high variability of secondary microplastic emissions, resulting from the properties of the materials and how the products are used. Emissions generated during production could be relatively predictable if the manufacturing processes and materials were fully reproducible. In practice, however, microplastic emissions depend on many factors, such as the chemical composition of materials, their quality, processing methods, and product usage conditions.
Synthetic textiles
Synthetic textiles are a good example. Materials such as polyester, acrylic, and nylon differ in their physical and chemical properties, and they often occur as blends with varying percentage compositions. The formation of microplastics is also influenced by clothing production and sewing techniques, which can increase or decrease the material’s susceptibility to wear and tear. Another important factor is how the products are used, especially the washing process. The frequency of washing, water temperature, spin speed, and even the type and amount of detergent used can significantly affect the amount of plastic microparticles released. For this reason, estimating microplastic emissions by companies in the apparel industry is particularly difficult.
Car Tires
Another significant source of microplastics is car tires. It is estimated that tire wear and road surface wear account for between 25% and 39% of microplastics entering the environment. In this case as well, there are no uniform indicators that would allow for a precise estimation of emissions. This is because the amount of microplastics generated depends on many variables, such as vehicle weight, driving style (e.g., frequent sudden braking or acceleration), road surface condition, and weather conditions.
Summary
All of these factors make reliable and comparable reporting on microplastics under the ESRS standards a significant challenge for organizations. The development of measurement methodologies, greater data availability, and further clarification of regulatory requirements will be key to improving the quality of disclosures in this area.
Some initiatives related to microplastic assessments are already being carried out by organizations such as The Microfibre Consortium, which combine scientific research with practical applications in the supply chain. The organization’s goal is to offer solutions to apparel manufacturers to transform textile production processes. To learn more, Contact us.
Footnotes
[1] European Commission: Directorate-Director-General for the Environment, EU action against microplastics, Publications Office of the European Union, 2023, https://data.europa.eu/doi/10.2779/917472
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