Exploring the Essential Use Concept for Primary Microplastics Regulation in the EU

Abstract

With the increasing prevalence of plastic pollution, including microplastics (MPs, particles <5 mm), the pursuit of safer and more sustainable alternatives gains increasing traction. While a substantial portion of MPs in the environment arises from the degradation of plastic litter and the wear of polymer-containing materials (secondary MPs), deliberate incorporation of MPs in certain products (primary MPs) also represents a considerable source, and targeted measures can be implemented to minimize human exposure and environmental releases. Improved policies for managing macroplastic waste help mitigate secondary MPs, but addressing primary MPs requires distinct strategies. Globally, various approaches, such as bans or restrictions on primary MPs, have been proposed, including the recent EU regulation under REACH, which groups intentionally added MPs together based on their diverse uses and properties. However, applying the Essential Use Concept (EUC) provides a more refined regulatory approach; balancing environmental health, technical feasibility, and innovation. This perspective explores the potential, challenges, and limitations of implementing the EUC for primary MPs. By examining four use cases─controlled-release medicines, agricultural seed coatings, personal care products, and artificial turf infill─we highlight how the EUC can prioritize essential and beneficial applications while phasing out nonessential uses.