Microplastics Restriction: First Reporting Obligations from 31 May 2026

With the REACH restriction on intentionally added synthetic polymer microparticles (SPM), a new regulatory instrument has been in force since October 2023 that extends far beyond a mere prohibition on placing on the market. Regulation (EU) 2023/2055 establishes comprehensive information and reporting obligations that are now taking effect in stages and will accompany undertakings on a permanent basis. With the first reporting deadline on 31 May 2026, practical implementation is moving to the immediate forefront.

Background: Restriction of Microplastics under REACH

The legal basis for the restriction is Regulation (EU) 2023/2055, which introduced Entry No. 78 into Annex XVII of the REACH Regulation. Its objective is to reduce the release of microplastics into the environment by regulating intentionally added, solid, non-degradable polymer particles below certain size thresholds. Synthetic polymer microparticles are defined as all solid, synthetic, organic, insoluble, and poorly degradable polymer microparticles with a diameter of no more than 5 mm, or plastic fibres with a length of no more than 15 mm.

Unintentionally generated microplastics — for example through abrasion from textiles or tyres — are not covered. Rather, the restriction focuses on polymer particles that are deliberately used to impart specific properties to a product, such as granules, microcapsules, additives, or effect particles. The restriction applies to SPM as substances or in mixtures; finished articles do not fall directly within its scope. However, upstream processing steps — such as coating or formulation — may nonetheless trigger reporting obligations.

The central element of the restriction is not a general ban on use, but a prohibition on placing on the market, flanked by extensive reporting obligations for exempted uses. A number of applications are exempt from the prohibition — for instance, use in industrial installations, in medicinal and veterinary medicinal products, for in vitro diagnostics, or for SPM bound in solid matrices. These exemptions are, however, conditional upon compliance with information and reporting obligations.

Staged Model of Information and Reporting Obligations

The microplastics restriction provides for a staged system in which information and reporting obligations take effect at staggered intervals.

Information obligations from October 2025: Since 17 October 2025, suppliers of products containing synthetic polymer microparticles that fall under certain exemptions have been required to provide their customers with information on safe handling, disposal, and the avoidance of releases. This may be done through safety data sheets, technical data sheets, or equivalent accompanying information. In practice, even this step poses considerable requirements: both safety data sheets and labels must be updated, and the application of updated labels alone may take several months.

Reporting obligations to ECHA from May 2026: The first reporting obligations to ECHA commence in 2026. The transitional period for the reporting obligations is 24 months after entry into force and initially concerns manufacturers and downstream industrial users of SPM in pellets, flakes, and powders used as feedstock for plastics manufacturing in industrial installations. The first report must be submitted by 31 May 2026 for the preceding calendar year — that is, it must cover estimated emissions arising between January and December 2025.

Extension of reporting obligations from 2027: For further categories of actors — such as other downstream industrial users (excluding pellets, flakes, and powders) and all suppliers of products containing SPM — the reporting obligation commences with a transitional period of 36 months, i.e. from 2027. In these cases, too, reports are to be submitted annually by 31 May.

Content of the Reports

The reports must include, among other things, the following information: a description of the uses of synthetic polymer microparticles in the preceding calendar year; general information on the identity of the polymers used (e.g. CAS number, where available); an estimate of the quantity of SPM released into the environment in the preceding calendar year — including emissions during transport; and an indication of the exemption relied upon in each case.

Reports are submitted annually on an aggregated basis for the relevant calendar year. The information collected by ECHA is made available to Member States and the European Commission so that uses may be identified where further risk management is required or where releases prove to be low over time. Undertakings should therefore already be putting in place appropriate data collection and documentation processes.

Technical Implementation of Reporting

Reports must be prepared using IUCLID and submitted via the ECHA portal REACH-IT. ECHA provides guidance documents, templates, and training materials, which are available on the relevant ECHA webpage on microplastics reporting. In addition, the European Commission has published a comprehensive guidance document on the restriction of synthetic polymer microparticles, which, through a descriptive section, a questions-and-answers section, and annexes containing workflows and examples, is intended to facilitate implementation.

Practical Challenges

In practice, the reporting deadlines pose considerable challenges for many undertakings. Industry associations — including the European Chemical Industry Council (Cefic) and the Downstream Users of Chemicals Co-ordination Group (DUCC) — noted at the CARACAL meeting in July 2025 that the deadlines were scarcely achievable.

A key point of criticism concerns the late publication of the ECHA guidance, which was not issued until April 2025. As this guidance contains essential information — for example on the calculation of SPM content — software providers were unable to begin technical implementation until after its release, significantly reducing the remaining preparation time for undertakings. Furthermore, all actors in the supply chain are subject to the same deadlines. Downstream users are at a structural disadvantage in this regard, as they depend on information from their suppliers — and such information was in many cases provided late or was not yet available at all.

Significance for Undertakings

The microplastics restriction illustrates, by way of example, that REACH restrictions are increasingly establishing not only prohibitions but also permanent compliance obligations. The reporting obligations are expressly intended to monitor the effectiveness of the restriction and are accordingly not designed as a transitional phenomenon, but as a permanent element of the regulatory framework.

It is therefore advisable for undertakings to clarify the following questions at an early stage: Do the substances or products used fall within the definition of synthetic polymer microparticles? Which exemptions, if any, are applicable? What data must be collected and communicated along the supply chain? And how will annual reporting be implemented in organisational and technical terms? In this regard, it should be borne in mind that upstream processing — such as the coating of articles — may trigger reporting obligations, even where the final product, as an article, does not fall directly within the scope of the restriction.

Outlook

With the commencement of the first reporting obligations in 2026, the microplastics restriction enters a new phase of practical application. At the same time, it is foreseeable that ECHA will increasingly use the reported data in the future for evaluations, the enforcement of existing rules, and potential adjustments to the restriction.

For affected undertakings, microplastics under REACH will therefore not remain a one-off project, but will establish itself as a permanent compliance task. Those who put in place robust data collection processes at an early stage and structure their supply chain communications accordingly will be better positioned for the recurring reporting obligations.