EU REACH & MICROPLASTICS REGULATORY UPDATE
On November 26, 2025, the European Chemicals Agency (ECHA) announced that IUCLID and REACH-IT now support the annual reporting of emissions of Synthetic Polymer Microparticles (SPMs). Companies affected by the EU microplastics restriction should review whether they must submit their first report by May 31, 2026, covering estimated emissions for 2025.
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Key Takeaways for EU-Bound Chemical and Product Suppliers
The launch of the microplastic emission reporting system marks a practical implementation stage of the EU Microplastics (SPMs) Regulation. Companies should no longer focus only on whether a product is banned or exempted. They also need to determine whether annual reporting, information transfer, labeling, SDS updates, and internal emission data collection apply.
The reporting system is now available. ECHA's IUCLID and REACH-IT tools now support microplastic emission reporting for relevant companies.
The first deadline is May 31, 2026. The first group of affected companies must report estimated SPM emissions for the 2025 calendar year.
Reporting is linked to exempted uses. Even if a use is exempted from the placing-on-the-market prohibition, it may still trigger annual reporting or information duties.
Preparation requires cross-functional data. Regulatory, EHS, R&D, production, logistics, procurement, and EU importer teams may need to coordinate polymer identity, use, derogation, and environmental release data.
Background: EU Microplastics Restriction Enters the Reporting Stage
The EU microplastics restriction was introduced by Commission Regulation (EU) 2023/2055, which amends Annex XVII of the EU REACH Regulation as regards synthetic polymer microparticles. The restriction began applying on October 17, 2023 and targets microplastics intentionally added to substances or mixtures.
The restriction includes prohibitions, exclusions, derogations, transition periods, information requirements, and annual reporting obligations. Therefore, a product that is not immediately banned may still require compliance actions, such as instructions for use and disposal, product labeling, SDS updates, supply chain communication, or annual emission reporting to ECHA.
Compliance note: Companies should not assess EU microplastic compliance only by product category. The assessment should consider polymer identity, particle size, physical state, concentration, intended function, solubility, biodegradability, product use scenario, exemption basis, and the company's role in the EU supply chain.
Who Must Submit SPM Emission Reports?
The reporting obligation is role- and use-specific. Companies should first identify whether they are a manufacturer, importer, industrial downstream user, or supplier placing products containing SPMs on the EU market for the first time.
| Actor | Potential Reporting Trigger | Practical Action |
|---|---|---|
| Manufacturers of SPMs | Manufacturing SPMs in the EU, including pellets, flakes, powders, or other SPM forms used at industrial sites. | Map SPM uses, identify applicable derogations, and collect annual emission data. |
| Importers | Importing SPMs or products containing SPMs into the EU, depending on product type, use, and supply chain role. | Confirm importer responsibilities with suppliers and downstream users; integrate checks into EU market access planning. |
| Industrial downstream users | Using SPMs at industrial sites, including SPMs used as feedstock in plastic manufacturing. | Establish site-level data collection for use descriptions, polymer identity, and environmental release estimates. |
| Suppliers placing products on the market for the first time | Products containing SPMs for certain exempted or derogated uses placed on the EU market for professional users or the public. | Review end-use descriptions, product portfolio scope, derogation basis, and market placement records. |
SPM Reporting Timeline and Deadlines
The report must cover the previous calendar year. The first reporting wave applies in 2026, while additional companies and product suppliers will be covered from 2027.
| Deadline | Who May Be Affected | Data Year Covered |
|---|---|---|
| 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. | 2025 |
| May 31, 2027 | Other manufacturers and industrial downstream users using SPMs at industrial sites, as well as certain suppliers placing products containing SPMs on the EU market for the first time to professional users or the general public. | 2026 |
What Information Should Companies Prepare?
Companies should prepare data before the deadline rather than waiting until the REACH-IT submission stage. The reporting obligation generally requires information on uses or end uses, generic polymer identity, estimated environmental releases, and the applicable derogation reference.
| Data Category | What to Prepare | Why It Matters |
|---|---|---|
| Use or end-use description | Description of how SPMs were used or placed on the market in the previous calendar year. | Determines the reporting category and supports the applicable derogation or exemption logic. |
| Generic polymer identity | Generic information on the identity of polymers used or placed on the market. | Supports ECHA and Member State authorities in monitoring SPM emission sources. |
| Environmental release estimate | Estimated quantity of SPMs released to the environment in the previous calendar year, including releases during transportation. | A key compliance item that may require coordination across production, storage, transport, loading, unloading, repackaging, and waste handling activities. |
| Derogation reference | Reference to the relevant derogation or exemption under REACH Annex XVII, Entry 78. | Shows why the SPM use is reportable rather than simply prohibited, out of scope, or covered by another compliance pathway. |
Compliance Checklist Before the First Submission
Screen product portfolios: confirm whether EU-bound substances, mixtures, pellets, flakes, powders, formulations, or finished products contain intentionally added SPMs.
Verify SPM status: review polymer identity, particle size, physical state, concentration, solubility, biodegradability, and possible exclusions.
Map exemptions and derogations: determine whether the product is prohibited, out of scope, derogated, or subject to delayed implementation.
Identify the responsible actor: confirm whether reporting should be handled by the manufacturer, importer, industrial downstream user, supplier, or another EU supply chain entity.
Collect annual data: prepare use descriptions, polymer identity information, SPM quantity data, environmental release estimates, and transportation spill records.
Review SDS and labels: check whether instructions for use and disposal, regulatory statements, quantity or concentration information, and EU language requirements affect SDS and label documentation.
Prepare submission workflow: confirm REACH-IT access, IUCLID data structure, internal review responsibility, and submission timing before the May 31 deadline.
How REACH24H Can Support EU Microplastics Reporting
REACH24H supports global manufacturers, formulators, importers, distributors, downstream users, and EU market access teams in assessing SPM obligations and preparing practical reporting, labeling, SDS, and supply chain compliance actions under the EU microplastics restriction.
SPM applicability assessment: determine whether substances, mixtures, or products fall within the definition of synthetic polymer microparticles under EU Microplastics (SPMs) Regulations.
Exemption and transition period evaluation: assess whether a product is prohibited, out of scope, derogated, or subject to delayed implementation.
Annual reporting preparation: support data gap analysis, use description review, generic polymer identity preparation, emission estimate organization, and derogation reference mapping.
IUCLID and REACH-IT submission support: assist with dossier preparation and submission workflow planning for annual SPM emission reports.
SDS and label review: update product labels, package leaflets, safety data sheets, and instructions for use and disposal where SPM-related information requirements apply.
EU chemical compliance integration: align SPM obligations with EU REACH, EU CLP, SDS, importer communication, and broader supply chain compliance requirements.
FAQ
Recommended Reading
EU REACH Compliance: Mandatory Reporting for Synthetic Polymer Microparticles (SPM) Due by May 2026
EU Microplastics (SPMs) Restrictions Explained: Key Compliance Duties and Business Solutions
EU REACH Registration & Only Representative Services for Non-EU Suppliers
Related Services
Official Resources
EUR-Lex: Commission Regulation (EU) 2023/2055 on Synthetic Polymer Microparticles
European Commission: Restriction of Microplastics Intentionally Added to Products
Need to determine whether your products trigger EU SPM reporting?
REACH24H can help assess SPM applicability, confirm exemptions and reporting roles, prepare emission data, review SDS and labeling obligations, and support annual report preparation through IUCLID and REACH-IT.
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