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Navigating regulatory complexities: Challenges and shifting problem framings in turning microplastics into a European policy object

Published online by Cambridge University Press:  30 March 2026

Ulrike Felt*
Affiliation:
Department of Science and Technology Studies, University of Vienna, Austria
Noah Muenster
Affiliation:
Department of Science and Technology Studies, University of Vienna, Austria
*
Corresponding author: Ulrike Felt; Email: Ulrike.felt@univie.ac.at
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Abstract

Microplastics are widely discussed as a pervasive environmental issue, yet decisive action and turning them into a governable “policy object” has proven to be slow and challenging. This paper investigates the shifting and heterogeneous problem framings of microplastic pollution and the regulatory complexities that emerge from them. Drawing on research from science and technology studies, we analyze how microplastics remained “hidden in plain sight” for decades, obscured by limited scientific standardization, competing problematizations, debates over scientific evidence, widespread cultural imaginaries and economic interests. The research reveals that the path from scientific knowledge to policy action is not linear but a process of co-production, where public concern, scientific capabilities and political agendas continuously reshape one another. We trace the evolution of the issue – from marine pollution to other media, human health and now nanoplastics – highlighting how each shift opens up new questions posing new (regulatory) challenges. The findings demonstrate that effective environmental governance requires more than data; it demands a critical understanding of the complex innovation pathways that produce such residues. We conclude that durable solutions require extended infrastructures of responsibility and care and the development of adaptive institutional frameworks capable of navigating scientific uncertainty and contested values.

Information

Type
Research Article
Creative Commons
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This is an Open Access article, distributed under the terms of the Creative Commons Attribution-NonCommercial licence (http://creativecommons.org/licenses/by-nc/4.0), which permits non-commercial re-use, distribution, and reproduction in any medium, provided the original article is properly cited. The written permission of Cambridge University Press or the rights holder(s) must be obtained prior to any commercial use.
Copyright
© The Author(s), 2026. Published by Cambridge University Press

Author comment: Navigating regulatory complexities: Challenges and shifting problem framings in turning microplastics into a European policy object — R0/PR1

Comments

Dear Editor of Cambridge Prisms: Plastics,

We are pleased to submit our manuscript Navigating regulatory complexities: Challenges and shifting problem framings in turning microplastics into a European policy object , which grows out of my ERC-funded project “Innovation Residues: Modes and Infrastructures of Care for our Longue-durée Environmental Futures”. The grant examines how innovation leaves behind social, material, and environmental “remainders” (which we call innovation residues); within this project, microplastics as a residue of our lives with plastics is one of the three core innovation fields we are examining.

This paper was presented at MICRO24, presentation number: 559629

The article draws on multi-sited ethnographic work done over the past two years (observation at conferences, workshops, and webinars), close readings of significant publications and technical reports, conversations and interviews with researchers and policy makers and analysis of European regulation of microplastics.

We believe that Cambridge Prisms: Plastics is an excellent venue for this article. The journal’s readership spans very different disciplines that address plastics, and this manuscript would like to contribute to a conversation across disciplinary boundaries, seeing the issue of microplastics from a social science (STS) perspective.

Thank you for considering this submission. we would be delighted if the manuscript could be evaluated for publication in Cambridge Prisms: Plastics. Please let us know if any additional information is required.

With best regards,

Univ.-Prof. Dr. Ulrike Felt

Noah Münster, MA

Review: Navigating regulatory complexities: Challenges and shifting problem framings in turning microplastics into a European policy object — R0/PR2

Conflict of interest statement

Reviewer declares none.

Comments

This Is an interesting piece of conceptual work, but the paper, if the authors wish to continue with it as a research piece, needs significant update in terms of reporting on the academic rigour. Otherwise, I suggest positioning it more as a review paper and reframing accordingly. My specific comments below. I look forward to seeing the revised version as I feel this will have a valuable contribution.

Overall view:

This paper is an interesting read and makes a valuable conceptual contribution but needs stronger engagement with real-world governance dynamics to fulfil its stated policy relevance.

Many of the assertions feel quite broad and are not supported by detailed case material. Nor are any of the interview insights quoted or at least brought in or contextualised. So in a number of places there a relationships implied without really demonstrating them. See comment later on re: presentation of results separate from interpretation.

This paper also doesn’t really look at regulation dynamics and barriers and avoids discussing any alternative interpretations of regulatory delay. There is a wealth of interacting influences on policy movement, uptake etc that is discussed or at least acknowledged as a limitation.

As a whole there is also minimal consideration about evidence limitations to this piece of research where the authors do not discuss data gaps, potential bias, any constraints in approach etc. I would suggest this be added in to strengthen the academic rigour of this paper.

It’s apparent to me in the writing style and sentence structures that AI has been used to support the writing of this paper. If this is the case, this should be acknowledged in the methods or elsewhere in the acknowledgements as part of research transparency.

Abstract:

The abstract is enticing to the reader, but doesn’t provide some of the key ingredients of an academic paper in terms of what problem in the literature is being addressed, how the study was conducted, what was actually found and how this advances theory or practice.

In the last sentence, ‘the task ahead is translation….’ – the task for whom?

Introduction:

The intro here frames microplastics as slow to become a “policy object,” but europe has acted in several areas (microbeads, REACH restriction, wastewater initiatives, tyre discussions). So this risks understating the extent of governance activity if not at least acknowledged (even if not extensive yet). This is important for the setup/framing of the paper, despite being discussed later on.

My other concern here is that plastics are primarily framed as part of an ‘innovation society’ but downplays the role of fossil fuel economics and the related regulatory capture risks and industry lobbying that influence the plastics economy as more structural drivers for lack of action. This would be important here especially as it is considered later on in the results/discussion.

P1 L48 – suggest that democratizing is given further explanation – is this as it is relevant to all members of society not just those with financial accessibility given plastics being cheap to produce at scale?

Methods:

The method indicates that interviews were conducted with researchers but does not specify how many interviews were conducted, what the stakeholder or geographic distribution was or the selection criteria for interviewees. Without this, readers cannot judge whether conclusions reflect a narrow perspective or a diverse set of viewpoints. The method also doesn’t identify what the format or nature of the interviews / questions were, and whether ethical approval was sought and approved (given it involves human participants). It all feels relatively untransparent. There also isn’t any detail on the process and protocols of the document analysis (which documents, selection criteria, timeframe, analytical framework etc). I would like to see an overhauled methods the more rigorously reports on the approach adopted.

Results and discussion:

Considering this study used document analysis, observations and interviews, this section does not present the results in a clear analytical way and it becomes thus challenging to interpret what is part of the findings, and what is the authors’ interpretation/positioning thereof. I’d like to see a clearer distinction of these throughout section 3, possibly by restructuring in to clearer separate results and discussion sections, although not necessary – if the authors’ opt to not restructure, the merged section requires much clearer separation of findings, interpretation and the lessons/recommendations that are peppered throughout this section.

P4 L34 – unclear why ‘infrastructures of forgetting’ is bolded.

P4 L54 – Calvino requires a reference. So does Carpenter & Smith.

Last para on page 5 (3.1) brings in lessons here which feel out of place considering how the rest of this section is structured.

P5 L31 – which fieldwork? In what timeframe? Covering what? (to follow on from suggestion re:methods). Disputes between whom?

P5 L54 – “this in turn also explains why regulatory pathways around microplastics remain so contested.” – this needs evidence, examples and/or citations.

P7 L37 – Which Treaty? Do the authors’ mean TEU or TFEU? I think it’s the TFEU but ‘treaty’ is vague and needs specifying.

In the last para on page 7, there’s distinction amongst the intentionally added and unintentionally released microplastics. In the microplastics space, there is also consistent use of the terms primary and secondary microplastics for this same purpose. I think it would be valuable to include these terms at least once in the paper for consistency with the literature and to maintain repeated exposure of terms/ideas if this paper is intended in any way for a policymaker audience.

P8 2nd para – can Europe still be considered a precautionary leader and social-justice guardian given the existing geopolitical climate and environmental regulations? Suggest to find a more recent reference to support these positions, or at least reference to how this is captured by the data collected from this research.

Conclusion:

Without clearly demonstrated findings in the preceding sections it is difficult to determine what is grounded in evidence here or what is opinion-based prescription, and therefore cannot assess/justify the feasibility of these recommendations.

Review: Navigating regulatory complexities: Challenges and shifting problem framings in turning microplastics into a European policy object — R0/PR3

Conflict of interest statement

None

Comments

Article Review (Manuscript No. PLC-2025-0062)

Thank you to the authors and the editors at Cambridge Prisms for the opportunity to review this article. This is a timely piece that critically addresses the messy and complex path to regulating microplastics in the European policy arena from an STS perspective. Central to the authors argument is that innovation writ large needs to be reconceptualised in a way that centres residues and their ‘unintended’ effects that always haunt attempts at innovation. Deploying the lens of co-production, the paper demonstrates the critical importance of paying attention to the co-constitution of microplastics as a problem (how they come to matter, literally and figuratively is inseparable from the political economy and metrological/technical constrains) and the making of microplastics as a European policy object. The analysis successfully draws together a mixed-method account of how microplastics shifted from an issue of limited societal and scientific interest to an issue of global concern, and the unfinished story of how microplastics are interfacing with contemporary European regulatory instruments and discourses. The conclusions offered by the authors are clearly thought-out and follow appropriately on from what has come before.

My recommendation to the Editors is this paper be accepted for publication with minor revisions. While the overall argument is generally convincing and the STS approach is a clear contribution to this burgeoning interdisciplinary literature, I was also searching for some clarity and further explanation on some of the claims put forward by the authors.

Some suggestions as follows:

Page 1, Line 54-57: do innovations only leave “diverse material traces and by-products”? There is an opportunity here to clearly define what is conceptualised as residual. E.G., how does the notion of residue here follow or challenge Boudia’s et al., 2018 typology of residues?

Page 2, Line 4: Murphy’s “regimes of (im)perceptibility” (P2) is deployed without further theorical development. While this is a concept familiar to an STS readership it might not be intelligible to the wider readership of this journal. My sense is that the argument in the paper is fundamentally premised, although implicitly at the moment, on this notion of how all disciplines, instruments and standards measure somethings and not others. In this light, weaving this through the paper would strengthen the argument.

Page 3, Line 39: Microplastics are not just fragments – important to be more precise about the materiality of plastics here.

Page 3, Line 53: Slightly unconvinced by the turn-of-phrase “hidden in plain sight” the authors deploy to describe the prior inattention given the microplastics. Although the argument that microplastics were always ‘present’ but “our instruments, categories, and routines were primed to look past them” (again regimes of perceptibility?), the claim that microplastics are “things that are openly observable yet collectively ignored” (P3) is harder to follow. After all, one of the primary characteristics of micro- and nano-plastics it that they are mostly invisible to direct human observation. Is there an argument for retooling the question (Line 51-52) to ask to whom microplastics are invisible to (Davies, 2019)? For example, Carpenter (2022) himself writes that, in 1972, there was no career in plastic pollution as a marine biologist. To take this at face value for the moment, the story of this socially produced invisibility then seems more complex than the text indicates. What about the role of industrial interference or the politics of research funding in shaping this invisibility?

Page 4, line 15-16: Not clear to the reader why framing the problem of plastics on the petrochemical system would necessarily enable attention onto microplastics given the analysis in the previous paragraph about evidentiary fragility, metrological limitations etc.

Page 4, Line 61: Suggestion to “standardize what counts as evidence sooner” seems a little naïve given that that one of the primary challenges of generating data on microplastics is how they materially resist convention scientific methods of detection and attempts at standardization (and this is something the scientific community has wrangled with for the past 10-20 years)?

Page 6, Line 31-32: Unclear why it is only the shift from micro-to-nano that the process of degradation overtime becomes apparent. What is this shift doing that the macro-to-micro is not?

Page 8, Line 18: Boundary objects refer to more than the politics of naming but that is not necessarily apparent to the reader from the text.

Page 8, Line 51-: Is there scope to extend the first “reflexive move” presented to also be attentive to the ontological politics of microplastics? E.G., how the materiality of microplastics resist attempts at definition?

Page 9, Line 4-5: “Problem-solution packages” could do with a reference to an example of how this is operationalised in practice. (Quotation mark (”) is in the wrong place).

Page 9, Line 23-40: I wonder if there is a misalignment between the first part of the paragraph which outlines how political economy shapes what is “feasible in the now” and the suggestion to adopt a post-normal science approach in the EU context.

Recommendation: Navigating regulatory complexities: Challenges and shifting problem framings in turning microplastics into a European policy object — R0/PR4

Comments

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Decision: Navigating regulatory complexities: Challenges and shifting problem framings in turning microplastics into a European policy object — R0/PR5

Comments

No accompanying comment.

Author comment: Navigating regulatory complexities: Challenges and shifting problem framings in turning microplastics into a European policy object — R1/PR6

Comments

Dear Professor Fletcher,

We are pleased to resubmit our revised manuscript. We would like to thank you and the reviewers for the careful reading and constructive feedback. We have addressed all comments in detail and believe the manuscript has been significantly strengthened as a result. In particular, we have clarified our methodological approach, expanded contextual sections where requested, and sharpened the presentation of our empirical material and analytical contributions. A detailed response to each reviewer comment is provided in the response to decision letter.

We would, however, like to briefly address one issue that arose during review. One reviewer suggested that the manuscript appeared to have been written using AI. We wish to state clearly that the paper was authored by us. As non-native English speakers, we occasionally use language tools (e.g., DeepL) to refine vocabulary and check phrasing choices, but this does not constitute AI-generated writing, nor does it fall under disclosure requirements by journals I have so far published in. I did check the rules of your journal but explanations are not very clear if the use we describe would fall under something we would need to declare. So we did not check the AI box - deepl worked well before AI was “enforced” on it. We were a bit concerned that reviewers simply voice such suspicions as they are confronted with a writing style that they are not used to (there were other indications in the comments of the reviewer that point to a certain disciplinary distance to social sciences). We hope this clarification is helpful and trust that the revised manuscript can be evaluated on its scholarly merits.

Thank you again for your time and consideration. We look forward to your response.

Kind regards

Ulrike Felt & Noah Münster

Review: Navigating regulatory complexities: Challenges and shifting problem framings in turning microplastics into a European policy object — R1/PR7

Conflict of interest statement

Reviewer declares none.

Comments

The paper is much clearer and stronger now that the methods have been clarified.

Review: Navigating regulatory complexities: Challenges and shifting problem framings in turning microplastics into a European policy object — R1/PR8

Conflict of interest statement

None

Comments

Thank you to the authors for the detailed response and for fully engaging with the comments provided. The extensively reworked paper now has a clearer structure that is easier to follow. The methods section showcases the fieldwork conducted and the European context the authors analyse has been brought out in text. Overall, the argument that microplastics have moved from ‘hidden in plain sight’ to becoming a European policy object has also been clarified in this rework.

Some minor comments to address but otherwise I can recommend the manuscript for publication.

P3 L13: Are the authors alluding to detection thresholds, toxicological exposure thresholds or both?

P3-4: References Felt 2021 and Ghoddousi & Page 2020 may be the wrong way round?

P4-5: Still unsure whether the ‘largely unnoticed’ diagnosis of microplastics is too universalising. Who is the ‘we’ in subtitle 3.1?

P6 L38-39: Quote from interviewee could be refined (cut the “being”?)

P7 L3: Matters of care as ‘what we should do’ is not necessarily my reading of Puig de la Bellacasa. Given that there is limited room to discuss the ontological and ethical move from facts to care here, my suggestion would perhaps be to rewrite the sentence centring what is in the brackets instead.

P11 L4 Given the wide-ranging audience of the journal, I wonder whether introducing another conceptual term “ontological politics” in the conclusion is needed or might it just add more confusion. The paragraph works fine without it. E.G., “they enact the object in particular ways [and] such enactments are never merely technical”.

P12 L4 Capitalise “Adaptation”.

Recommendation: Navigating regulatory complexities: Challenges and shifting problem framings in turning microplastics into a European policy object — R1/PR9

Comments

Some minor comments

Decision: Navigating regulatory complexities: Challenges and shifting problem framings in turning microplastics into a European policy object — R1/PR10

Comments

No accompanying comment.