(SA) Include Microplastics as a Water Pollutant

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Author: Jacinda Dixon-Rielly & Emmaby Barton Grace  | Publish date: 19/6/2026

• P: In SA, microplastics are not explicitly listed as a water pollutant.

• S: The SA Minister for Climate, Environment and Water should amend the Environment Protection (Water Quality) Policy 2015 (SA) to include microplastics as an indicator of water quality under Schedule 2 - Class 1 Pollutants. 

• E: Tangaroa Blue Foundation (TBF): ‘South Australia should formally recognise microplastics as a water pollutant within its regulatory framework.’

Problem Identification: 

Schedule 2 of the Environment Protection (Water Quality) Policy 2015 (SA) under the Environment Protection Act 1993 (SA) sets out ‘Class 1 Pollutants’ such as ‘agricultural waste’, ‘human waste’ and ‘rubbish and litter’. Division 2(10) states that industries must not discharge these pollutants to ‘any waters or onto land in a place from which it is reasonably likely to enter any waters’. However, microplastics are not included. 

According to TBF, a charity working to prevent marine debris, and others, the current approach is ‘failing to prevent risks of harm to the environment’, as well as to human health. They further emphasised that ‘serial offenders continue to pollute … waterways with little consequence’, while these consequences are instead borne by non-polluters.

Context: 

Microplastics refer to ‘plastic particles less than 5mm in size’. Microplastics can be intentionally produced (e.g. pharmaceuticals, textiles) or generated due to the break-up of plastic debris (e.g. packaging, bottles). Sutkar et al. (2023) noted that ‘[microplastics] may survive in the environment for decades or even hundreds of years without degrading’. 

A report co-authored by TBF, Environmental Justice Australia (EJA), and the Port Phillip EcoCentre (PPEC) highlighted that not only do microplastics harm ‘marine animals who can become sick or die’ but they also ‘[enter] the food chain and [impact] human health.’ Houssain et al. (2025) explained that these effects can include cancers, pulmonary diseases, organ damage, lower growth rates, and foodweb disruption. Xia et al. (2023) emphasised that these impacts are likely to be exacerbated, given that ‘plastic pollution could be tripled by the year 2040’.

According to Eriksen et al. (2014), microplastics make up 92.4% of plastic particles found on ocean surfaces. The Australian Microplastic Assessment Project reported that the ‘worst microplastic pollution in Australia is in Adelaide’, with ‘over 796,000 pieces per square metre [in the waterways], which are long-lasting and accumulating’.  

Australian studies have found that ‘industrial precincts [are] responsible for a large majority of microplastics’. According to Legal Services Commission SA, failure to comply with mandatory provisions under the Environment Protection Act 1993 (SA) obligations may result in a fine of up to $2 million for a body corporate, depending on severity and intent. Any officer of the body corporate may also be fined up to $500,000 if they ‘did not take all reasonable and practical prevention measures’. The SA Environmental Protection Authority noted that fines can send a ‘strong message … to deter the defendants and others from offending in this way.’

Arguments:

A report from the Senate Environment and Communications References Committee (2016) highlighted that ‘the economic costs of marine plastic pollution are immense and are being borne by all levels of government through clean-up and infrastructure costs.’ According to Beaumont et al. (2019), ‘the economic costs of marine plastic … are conservatively [estimated] at between $3,300 and $33,000 per tonne of marine plastic per year’ globally.

Amberg & Mitrano (2025) noted that ‘[microplastics] are deeply integrated into many different production value chains for a variety of purposes … highlight[ing] the complexity of their substitution challenges.’ However, they also emphasised that ‘there are instances in which suitable alternatives for [microplastics] exist [or are being developed] and in which the future environmental cost of [microplastics] pollution clearly outweighs the short-term economic benefits of inaction.’ For example, Zhang et al. (2024) developed a degradable microparticle for cleansing products and food fortification. Moreover, as Amberg & Mitrano highlighted, models can be developed that allow for the ‘[gradual] phasing out [of] other less essential applications’ and thus ‘help[ing] lower risk for companies’. 

Advice/Solution Identification:

TBF has called for microplastics to be explicitly included as a water pollutant. They, along with the EJA and PPEC, argued that ‘it is critically important to use existing environmental protection laws to prevent plastics entering the marine environment’ in order to increase microplastics pollution regulation. TBF and Operation Clean Sweep further emphasised that ‘preventing microplastic pollution represents low-hanging fruit for environmental protection. It is directly tied to industrial housekeeping and site management and therefore can – and should – be stopped at the source before it enters our waterways.’

Precedent:

If SA were to enact this reform, it would be nation-leading to the best of the authors’ knowledge.

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Public Support: 

1. Tangaroa Blue Foundation (see acknowledgements)

Broad Support:

2. Xin Yang, Yi Shou, Yincheng Li, and Siming Wang - Called for ‘marine microplastics as a kind of pollutant [to] be clearly defined in the relevant treaties’. However, they did not call for microplastics to be defined as a water pollutant in South Australia. 

The following groups called for actions to address microplastic pollution, including to ‘incorporate plastics (including microplastics) within the frameworks of indicators and objectives of water quality’ and to ‘regulate plastic feedstock pollution from plastic industry operators’. However, they did not call for microplastics to be defined as a water pollutant in South Australia.

3. Environmental Justice Australia 

4. Port Phillip EcoCentre              

This list reflects publicly stated positions and should not necessarily be taken as endorsement of this specific brief.

News Coverage:

• ABC News - “Our homes are full of hidden microplastics that could be harming our health”. This article discussed the negative impacts of microplastics on human and animal health, including reproductive effects, tissue damage, and premature aging. By: Norman Swan | 22 October 2025 - Read the article here. 

• Australian Microplastic Assessment Project - “Worst Microplastic Pollution in Australia is in Adelaide”. This article reported on the microplastic pollution found in Adelaide, noting it was the worst in Australia. It explained the potential harms of this pollution on humans and wildlife and noted the lack of effective strategies being implemented. No author | 9 August 2024 - Read the full article here.

Where to go to learn more: 

1. (2025) Microplastics Around Australia - AUSMAP Results | Australian Microplastic Assessment Project - This study reported on microplastics found when sampling over 350 shorelines across Australia. Notably, it found that ‘[SA] is home to two microplastic hotspots with the highest loads found in Australia’. Read the full findings summary here.

2. (2025) Microplastics pollution in Australia: Sources, impacts, and mitigation strategies | Rumana Hossain, Anirban Ghose, and Veena Sahajwalla - This article provided a review of microplastics in Australia including: where they are found; where they come from; their effects on humans, animals, and ecosystems; and existing and recommended policies and strategies. Read the full article here. 

3. (2021) From Pollution to Solution: A Global Assessment of Marine Litter and Plastic Pollution | United Nations Environment Programme - This report discussed the growing problem of marine litter, including microplastics. It included an overview of impacts and sources of marine litter, monitoring methods and challenges and other responses to marine litter and plastic pollution. Read the full report here. 

4. (2024) International Law and Regulation of Marine Microplastics: Current Situation, Problems, and Development | Xin Yang, Yi Shou, Yincheng Li, and Siming Wang - This article provided an overview of current international and regional responses to microplastic pollution. They highlighted that addressing microplastic pollution aligns with current international and regional treaties/conventions, and signalled the need to bolster legal frameworks to strengthen sustainable development. Read the full article here.

5. Microplastic pollution in Melbourne’s waterways: Existing legal solutions | Tangaroa Blue, Port Phillip Eco Centre, and Environmental Justice Australia - This report provided an overview of the microplastic pollution problem in Melbourne’s waterways, the potential harms of this pollution, and various legal tools that could be used to address it. Read the full report here. 

6. Environment Protection (Water Quality) Policy 2015 (SA) - Read the full Policy here.

7. Environment Protection Act 1993 (SA) - Read the full Act here.

Human Perspective: 

Harper loves to go fishing with her father every weekend at the Barket Inlet Wetlands where they spend the morning catching seafood they’ll take home to eat for dinner. Harper’s father always talks about how lucky he feels to live near the water and be able to catch fresh seafood for the family. Recently, however, they have been catching less healthy fish, which has worried them. After their school does a presentation about the adverse ecological effects of microplastics, Harper does some research and realises the water quality regulations do not consider microplastics to be a pollutant. Harper is worried that her family and other families who use the bay have been consuming contaminated seafood that might cause them to get sick. Harper also becomes concerned about the other animals living in the oceans and how the pollution will make them sick as well. She learns and shares with her father that the fish they catch have been weaker and smaller due to microplastics impacting their growth rate and causing organ damage. Harper’s father now wonders why microplastics are not as tightly controlled as the other pollutants. 

To protect the anonymity of those involved, this is a fictionalised account drawn from an amalgamation of real-life stories, experiences and testimonials gathered during the research process for this brief. Any resemblance to actual individuals is purely coincidental.

Conflict of interest/acknowledgment statement: 

Heidi Tait (CEO and Director of Tangaroa Blue Foundation) confirmed their support for this recommendation in a meeting with FORE Good held on 16 Dec 2025.

Support 

If your organisation would like to add your support to this paper or suggest amendments, please email Info@foreaustralia.com. 

Disclaimers

Please review all FORE disclaimers here.

Reference list: 

Alva, P. P. & Thomas, T. A. (2025). Microplastics: a global threat to life and living. Environmental Monitoring and Assessment, 197(725). https://doi.org/10.1007/s10661-025-14160-w 

Amberg, S., & Mitrano, D. M. (2025). Exploring the Essential Use Concept for Primary Microplastics Regulation in the EU. Environmental Science & Technology, 59(16), 7799–7809. https://doi.org/10.1021/acs.est.4c10830 

Australian Microplastic Assessment Project (AUSMAP). (2024). Worst Microplastic Pollution in Australia is in Adelaide. AUSMAP. https://www.ausmap.org/post/worst-microplastic-pollution-australia-adelaide  

Beaumont, N. J., Aanesen, A., Austen, M. C., Börger, T., Clark, J. R., Cole, M., Hooper, T., Lindeque, P. K., Pascoe, C., & Wyles, K. J. (2019). Global ecological, social and economic impacts of marine plastic. Marine Pollution Bulletin, 142, 189-195. https://doi.org/10.1016/j.marpolbul.2019.03.022. 

Commission Regulation (EU) 2023/2055 of 25 September 2023 amending Annex XVII to Regulation (EC) No 1907/2006 of the European Parliament and of the Council concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) as regards synthetic polymer microparticles (EU). https://eur-lex.europa.eu/eli/reg/2023/2055/oj/eng

Environmental Justice Australia. (2025). Microplastic pollution in Melbourne’s waterways: Existing legal solutions. Tangaroa Blue, Port Phillip Eco Centre, and Environmental Justice Australia. https://tangaroablue.org/wp-content/uploads/2025/03/Microplastic-pollution-solutions-2025Report.pdf 

Environment Protection (Water Quality) Policy 2015 (SA). https://www.legislation.sa.gov.au/_legislation-documents/lz/c/pol/environment-protection-water-quality-policy-2015/current/2015.-.un.pdf 

Environmental Protection Authority SA. (2025). Penalty for serious environmental harm in Adelaide Hills. Environmental Protection Authority SA. https://www.epa.sa.gov.au/blog/2025/04/04/penalty_for_serious_environmental_harm_in_adelaide_hills 

Eriksen, M., Lebreton, L. C. M., Carson, H. S., Thiel, M., Moore, C. J., Borerro, J. C., Galgani, F., Ryan, P. G., & Reisser, J. (2014) Plastic Pollution in the World's Oceans: More than 5 Trillion Plastic Pieces Weighing over 250,000 Tons Afloat at Sea. PLOS ONE, 9(12). https://doi.org/10.1371/journal.pone.0111913 

Hossain, R., Ghose, A., & Sahajwalla, V. (2025). Microplastics pollution in Australia: Sources, impacts, and mitigation strategies. Case Studies in Chemical and Environmental Engineering, 11(101036). https://doi.org/10.1016/j.cscee.2024.101036. 

Legal Services Commission South Australia. (2013). Pollution Offences. Legal Services Commission South Australia. https://www.lawhandbook.sa.gov.au/ch19s03s09.php 

Senate Environment and Communications References Committee. (2026). Toxic Tide: The Threat of Marine Plastic Pollution in Australia. https://www.aph.gov.au/parliamentary_business/committees/senate/environment_and_communications/marine_plastics/~/media/Committees/ec_ctte/Marine_plastics/Report/c08.pdf 

SMaRT@UNSW (Sustainable Materials Research & Technology). Study reveals extent of microplastics pollution in Australia. SMaRT@UNSW. https://www.smart.unsw.edu.au/news-events/news/study-reveals-extent-microplastics-pollution-australia 

Sutkar, P. R., Gadewar, R. D., & Dhulap, V. P. (2023). Recent trends in degradation of microplastics in the environment: A state-of-the-art review. Journal of Hazardous Materials Advances, 11(100343). https://doi.org/10.1016/j.hazadv.2023.100343. 

Xia, C., Cai, L., Lam, S. S., & Sonne, C. (2023). Microplastics pollution: Economic loss and actions needed. Eco-Environment & Health, 2(2), 41-42. https://pmc.ncbi.nlm.nih.gov/articles/PMC10702888/ 

Zhang, L., Xiao, R., Jin, T., Pan, X., Fransen, K. A., Alsaiari, S. K., Lau, A., He, R., Han, J., Pedretti, B. J., Yeo, J. Y., Yang, X., Olsen, B. D., Alexander-Katz, A., Smith, Z. P., Langer, R., & Jaklenec, A. (2025). Degradable poly(β-amino ester) microparticles for cleansing products and food fortification. Natural Chemical Engineering, 2, 77–89. https://doi.org/10.1038/s44286-024-00151-0