A document outlining the execution of reporting requirements for the REACH restriction on microplastics was published by the European Chemicals Agency (ECHA) on April 16, 2025. 

Background of the Reporting Requirements

Commission Regulation (EU)2023/20552 of September 25, 2023, also referred to as “the microplastics restriction,” established Entry 78 of Annex XVII of the REACH Regulation, which lays forth limitations for specific applications of synthetic polymer microparticles (SPMs). Additionally, the Regulation creates yearly report and information reporting requirements for specific derogated purposes. 

According to Commission Regulation (EU)2023/2055, the reporting timeline are as follows: 

• From October 17, 2025: Suppliers of SPMs for industrial applications and food additives must begin information reporting.

• From May 31, 2026; Manufacturers and industrial downstream users of SPMs in the form of pellets, flakes, and powders used as feedstock in plastic manufacturing at industrial sites must submit the annual report.

• From October 17, 2026: Suppliers of products containing SPMs for in vitro diagnostic devices must begin information reporting.

• From May 31, 2027: Other manufacturers and industrial downstream users utilizing SPMs at industrial sites must submit the annual report. This deadline also applies to suppliers of products containing SPMs for medicinal products, veterinary medicinal products, food additives, or vitro diagnostic devices that are placed on the market for the first time to professional users and the general public. 

The rule does not specify the precise information to be reported or the technical submission procedure, even if it does describe reporting dates and general standards. These aspects are intended to be clarified in the revised ECHA publication.

Overview of Detailed Reporting Requirements

The document issued on April 16, 2025, clarifies the following aspects of the reporting obligations:

Who Needs to Report?

The maker, industrial downstream user, or supplier of a product containing SPM that is put on the market for professional or consumer use are examples of reporting entities.

What Information Needs to Be Reported?

The estimated SPM emissions per usage must be reported by suppliers, manufacturers, and industrial downstream users. The following choices will be available on a pick-list from which the use will be chosen: 

• Manufacture or use of pellets, flakes and powders for plastic manufacturing at industrial sites

• Other manufacture or use at industrial sites

• Consumer and/or professional use in medicinal and veterinary medicinal products

• Consumer and/or professional use in food additives

• Consumer and/or professional use in in vitro diagnostic devices

• Other consumer and/or professional use

For each use applicable to the reporting entity, the following elements will be provided:

• Description of use

• Generic identity of the polymer(s)

• Estimation of emissions

• Applicable derogation(s)

Details for the above elements are described in the document. For example, the description of the use will consist of the following:

• Use name in free text form

• Sector(s) of use (SU) (pick-list)

• Product Categor(ies) (PC) (pick-list)

• Technical function(s) (TC) (pick-list)

Where to report?

The reporting will be done using IUCLID and the submission of the dossiers will be coordinated via REACH-IT.

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