Article published in July/August issue of European Rubber Journal
In its mission statement, the European Chemical Agency (ECHA) has as a central remit the "sustainable management of chemicals for the benefit of citizens and the environment."
But the 10 June decision of its committee for risk assessment (RAC) recommending a ban on rubber and elastomer-based infill in synthetic pitches seems seriously out-of-kilter with this worthy aim.
Issuing the decision, ECHA stated that microplastic-infill releases from artificial turf pitches "could amount to 16,000 tonnes per year" and that "a ban would be more effective than risk management measures in preventing environmental releases in the long term."
But the infill-migration figure is based on incorrect assumptions about the extra infill which is added to pitches annually, EMEA Synthetic Turf Council (ESTC) technical director Alastair Cox pointed out.
"That is roughly a tonne per year and, with 17,000 pitches across Europe, it is easy to see how the ECHA came up with 16,000 tonnes/year," said Cox.
As he explained, the extra tonne a year is to compensate for infill-compaction caused by players running on the pitches as well as rain – not because the rubber has left the pitch.
And, converting fields to organic infill would cost at least €60,000 each, so that operators would incur costs of nearly €1 billion if only 60% of existing fields were to be redone.
Moreover, without rubber infill, over 13,600 existing pitches would deteriorate more rapidly, become unsafe and have to be replaced prematurely, said Cox.
The extra cost of resurfacing sports fields much sooner could bring the total costs to over €1.5 billion, the technical director noted.
Unlike rubber granulate, which is heavier than water, alternatives like cork and coconut shell, are readily removed from pitches by rain. Also, they cannot be used in colder regions and need regular watering in hot countries, which is often impractical.
Instead of a ban, therefore, ESTC says containment barriers and drainage filters could restrict the release of synthetic infill from fields to about 10 grams per pitch a year.
Overall, given the shorter lifespan, higher maintenance needs and limited capacity of natural grass fields, a ban would massively reduce opportunities for people to participate in sport across the EU, concluded Cox.
For the European Tyre & Rubber Manufacturers' Association (ETRMA) another critical consideration is the impact the ban would have on end-of-life tire (ELT) recycling: some 527,000 tonnes of ELTs – 30% of market share – are used as infill materials in Europe.
In the case of a ban, this volume would need to be used in other applications or into energy recovery in clear conflict with EU waste hierarchy principles, said Fazilet Cinaralp, ETRMA secretary general.
Labelling the ECHA's proposed ban as "incomprehensible and counter-intuitive" the UK's Tyre Recovery Association (TRA) warned that the decision if implemented would set back tire-recycling efforts "by a generation."
The proposal "flies in the face of reason" stated TRA secretary general Peter Taylor, arguing that it "is contrary to the ideals and objectives of the circular economy as well as undermining the values of the waste hierarchy."
The ban, he added, will hinder the development of innovative uses for recycled rubber and leave incineration as one of the few available disposal options for post-consumer tires.
"As such [the proposed ban] is economically and environmentally illiterate and we must, as an industry, unite to fight it," Taylor commented.
Within the ECHA's decision-making process, the ban proposal can still be reversed, or derogations introduced to allow the continued use of synthetic infills on pitches with effective containment measures.
The concern is that, in its mission to stamp out microplastics, the EU agency will be less swayed by scientific evidence or even common sense and reach for the red card.