Reporting Obligations: Complying with the Microplastics Restriction under REACH
Under Regulation (EU) 2023/2055, the European Union imposes a gradual ban on the placing on the market of intentionally added microplastics. However, certain uses benefit from temporary exemptions, provided strict annual reporting obligations are met with the ECHA (European Chemicals Agency).
Who is affected by the microplastics restriction under REACH?
The reporting obligations apply to the following economic operators:
- Manufacturers of synthetic polymer microparticles (SPM),
- Downstream industrial users (on-site uses),
- Suppliers placing a product containing microplastics on the market for the first time for professional or consumer use.
Distributors are not affected.
Exempted uses of microplastics subject to reporting
Reporting obligations apply in the following cases:
Exemptions for specific uses of SPM
- Placing on the market of SPM intended for use at industrial sites (e.g., plastics industry)
- Placing on the market of medicines (human or veterinary)
- Placing on the market of food additives
- Placing on the market of in vitro diagnostic medical devices
Exemptions based on reduced environmental risk
- Placing on the market of SPM confined by technical means to avoid environmental release
- Placing on the market of SPM whose physical properties are permanently altered during their intended use so that they are no longer considered SPM
- Placing on the market of SPM permanently incorporated into a solid matrix during their intended use
It is important to note that several exemptions can apply to the same product or use.
Key regulatory deadlines for the microplastics restriction under REACH
Reporting must be submitted according to the following timeline:
- By 31 May 2026: for manufacturers and downstream industrial users of SPM in the form of pellets, flakes, and powders used as raw materials in plastic production at industrial sites (reporting on 2025 data).
- By 31 May 2027: for other SPM microparticle manufacturers and other downstream industrial users using SPM on industrial sites (reporting on 2026 data).
Content of the report to be submitted to ECHA (via IUCLID/REACH-IT) regarding microplastics
Each legal entity must submit an annual dossier including the following for each relevant use:
- Description of the use: sectors of use, product categories, technical function + concerned industrial sites for manufacturers or use on industrial sites,
- Identification of polymers used (4-digit HS code or free name),
- Emission estimates: quantities placed on the market, release rate, estimated losses,
- Applicable exemption(s) for the product or use.
Confidential information (company identity, technical details) will not be published, but aggregated statistics will be shared by ECHA for transparency purposes.
Compliance with these obligations requires
- A precise mapping of exempted uses of microplastics,
- Traceability of quantities placed on the market,
- Rigorous emission estimates, including downstream.
Failure to report may result in non-compliance with the restriction, thereby posing a risk to the placing on the market of products containing exempted SPM uses.
How can EcoMundo support you with the reporting obligation related to the microplastics restriction?
Our team of regulatory experts supports you to ensure rigorous, timely, and compliant reporting in line with the expectations of the authorities:
- Identifying uses subject to reporting obligations,
- Collecting and structuring the data required by ECHA,
- Preparing and submitting technical dossiers via IUCLID and REACH-IT,
- Advising you on best practices for emission estimation.
Feel free to contact us to schedule a product audit or a dedicated information session.
Under Regulation (EU) 2023/2055, the European Union imposes a gradual ban on the placing on the market of intentionally added microplastics. However, certain uses benefit from temporary exemptions, provided strict annual reporting obligations are met with the ECHA (European Chemicals Agency).
Who is affected by the microplastics restriction under REACH?
The reporting obligations apply to the following economic operators:
- Manufacturers of synthetic polymer microparticles (SPM),
- Downstream industrial users (on-site uses),
- Suppliers placing a product containing microplastics on the market for the first time for professional or consumer use.
Distributors are not affected.
Exempted uses of microplastics subject to reporting
Reporting obligations apply in the following cases:
Exemptions for specific uses of SPM
- Placing on the market of SPM intended for use at industrial sites (e.g., plastics industry)
- Placing on the market of medicines (human or veterinary)
- Placing on the market of food additives
- Placing on the market of in vitro diagnostic medical devices
Exemptions based on reduced environmental risk
- Placing on the market of SPM confined by technical means to avoid environmental release
- Placing on the market of SPM whose physical properties are permanently altered during their intended use so that they are no longer considered SPM
- Placing on the market of SPM permanently incorporated into a solid matrix during their intended use
It is important to note that several exemptions can apply to the same product or use.
Key regulatory deadlines for the microplastics restriction under REACH
Reporting must be submitted according to the following timeline:
- By 31 May 2026: for manufacturers and downstream industrial users of SPM in the form of pellets, flakes, and powders used as raw materials in plastic production at industrial sites (reporting on 2025 data).
- By 31 May 2027: for other SPM microparticle manufacturers and other downstream industrial users using SPM on industrial sites (reporting on 2026 data).
Content of the report to be submitted to ECHA (via IUCLID/REACH-IT) regarding microplastics
Each legal entity must submit an annual dossier including the following for each relevant use:
- Description of the use: sectors of use, product categories, technical function + concerned industrial sites for manufacturers or use on industrial sites,
- Identification of polymers used (4-digit HS code or free name),
- Emission estimates: quantities placed on the market, release rate, estimated losses,
- Applicable exemption(s) for the product or use.
Confidential information (company identity, technical details) will not be published, but aggregated statistics will be shared by ECHA for transparency purposes.
Compliance with these obligations requires
- A precise mapping of exempted uses of microplastics,
- Traceability of quantities placed on the market,
- Rigorous emission estimates, including downstream.
Failure to report may result in non-compliance with the restriction, thereby posing a risk to the placing on the market of products containing exempted SPM uses.
How can EcoMundo support you with the reporting obligation related to the microplastics restriction?
Our team of regulatory experts supports you to ensure rigorous, timely, and compliant reporting in line with the expectations of the authorities:
- Identifying uses subject to reporting obligations,
- Collecting and structuring the data required by ECHA,
- Preparing and submitting technical dossiers via IUCLID and REACH-IT,
- Advising you on best practices for emission estimation.
Feel free to contact us to schedule a product audit or a dedicated information session.
