The microplastics restriction is part of the EU REACH Regulation (Regulation (EC) No 1907/2006) and has been added as a new entry in Annex XVII.

It is based on a restriction dossier prepared by the European Chemicals Agency (ECHA) assessing the environmental risks of intentionally added synthetic polymer microparticles. Following scientific evaluation by the Risk Assessment Committee (RAC) and the Socio-Economic Analysis Committee (SEAC), the European Commission formally adopted the restriction.

As a regulation, REACH applies directly in all EU Member States.
No national transposition is required.

For companies, this means the requirements are legally binding and fully integrated into the existing REACH compliance framework.

The microplastics restriction is an extension of the EU REACH Regulation. Its aim is to reduce the release of synthetic polymer micro-particles (SPMs) into the environment.

The regulation addresses two key points:

• the phased ban on the placing on the market of certain products containing intentionally added microplastics
• the introduction of labeling and annual reporting requirements

It is important to note that even products that may continue to be sold may be subject to reporting requirements. The restriction therefore affects not only individual sectors but also numerous industrial and commercial applications.

SPM refers to solid polymers in particle form or as a coating, in which at least 1% by weight of the particles:

• are ≤ 5 mm in size or
• have a length of ≤ 15 mm with a length-to-diameter ratio of > 3.

The definition does not apply, for example, to naturally occurring polymers, biodegradable polymers, polymers with high solubility (> 2 g/L), or polymers without carbon.

In practice, it is often not self-evident whether a substance falls under the definition and requires technical testing.

Even companies without their own production facilities can therefore be held regulatory responsible.

The specific obligation depends not only on the role, but also on:

• the type of product
• the concentration and type of polymer particles
• the intended use
• the respective transition period

An individual assessment is therefore necessary in almost all cases.

Possible obligations:

• Compliance with marketing bans and transition periods
• Implementation of labeling and information requirements
• Sharing of information along the supply chain
• Annual reports to the ECHA (if applicable)

The reporting requirements will be phased in as follows:

Starting in 2026: For pellets, flakes, and powders used as feedstock in plastics manufacturing (reporting of emissions from 2025).
Starting in 2027: For other industrial uses as well as products for professional or private users (reporting of emissions from 2026).

The report must be submitted annually by May 31 via IUCLID/REACH-IT.

This is a recurring reporting obligation—not a one-time registration.

Companies that place products containing synthetic polymer microbeads (SPM) on the market must—depending on the type of product—ensure that their customers are adequately informed. This includes, in particular:

• Instructions for proper use and disposal to minimize releases into the environment
• Information regarding the presence of SPMs in the product, where required
• Where applicable, supplementary information in safety data sheets or technical product documentation
• These obligations apply not only to manufacturers but also to importers, formulators, and, in certain circumstances, distributors.

Important: The obligation to provide information applies regardless of whether the product may continue to be marketed. Even for permitted uses, labeling or communication requirements may apply.

For companies, this means:

• Product labels and packaging must be reviewed
• Safety data sheets must be updated as necessary
• Sales and marketing materials must not contain misleading information

Early review of communication documents is therefore an essential part of the compliance strategy.

Yes. Certain applications are exempt from the marketing ban but remain subject to reporting requirements. These include, for example:

• industrial uses at specific sites
• human and veterinary pharmaceuticals
• food additives
• in vitro diagnostic medical devices

SPMs that are technically encapsulated, permanently physically altered, or incorporated into solid matrices may also be subject to reporting requirements.

This distinction is a major source of uncertainty for many companies.

The following information, among other things, must be reported:

• Type of polymer used
• Quantity data
• Intended use
• Information on potential emissions

The data must be consistently documented and submitted in a structured format via IUCLID.

In practice, this often requires close coordination with suppliers to obtain reliable information on polymers and quantities.

Late or inaccurate reports can:

• lead to inquiries or actions by regulatory authorities
• create sales risks
• tie up significant internal resources on short notice
• undermine the trust of business partners

This can be particularly burdensome for small and medium-sized businesses that do not have their own compliance department.