EU REACH Compliance | Synthetic Polymer Microparticles
On September 25, 2023, the European Union adopted Commission Regulation (EU) 2023/2055, amending Annex XVII of the REACH Regulation to restrict intentionally added synthetic polymer microparticles (SPMs), commonly known as microplastics.
The first key information deadline, October 17, 2025, has now applied. Companies using SPMs in industrial applications, food additives, and certain risk-controlled situations should verify whether instructions for use and disposal, regulatory statements, polymer identity information, labels and Safety Data Sheets (SDS) have been updated.
Overview | Restricted SPMs | Exemptions | Obligations | Sector Roadmap | Compliance Strategy | How REACH24H Can Help
Overview
The EU microplastics restriction is a complex, phased-in regulation rather than a complete one-time ban. It is part of the EU's broader Zero Pollution Action Plan, which aims to reduce microplastic emissions and address persistent environmental pollution.
For chemical companies exporting to the EU, compliance requires more than reassessing formulations. Depending on the product type and use scenario, companies may need to determine whether the product contains regulated SPMs, whether exemptions or transitional periods apply, whether sales restrictions are triggered, and whether information transfer or annual reporting obligations are required.
Implementation update: The first information transfer deadline on October 17, 2025 has already applied, and the first ECHA annual reporting deadline on May 31, 2026 has also passed for certain SPMs used as plastic manufacturing feedstock. Companies should review whether they have completed all applicable obligations and prepare for future annual reporting cycles.
What Are the “Restricted Microplastics” under Commission Regulation (EU) 2023/2055?
The microplastics restricted by Regulation (EU) 2023/2055 are officially defined as Synthetic Polymer Microparticles (SPMs). This definition is technical and refers to solid, synthetic polymer particles that meet specific size, solubility and biodegradability conditions.
In general, a regulated SPM must meet one of the following particle size criteria:
All dimensions of the particle are equal to or less than 5 mm.
For fibre-like particles, the length is equal to or less than 15 mm, with a length-to-diameter ratio greater than 3.
The restriction also applies to mixtures containing SPMs at a concentration equal to or greater than 0.01% by weight, where the SPMs are intentionally present to confer a sought-after characteristic. Companies should also verify whether the polymer is natural, biodegradable, soluble or otherwise outside the scope.
| Assessment Item | Key Question | Why It Matters |
|---|---|---|
| Polymer identity | Is the particle a synthetic polymer? | Natural, non-chemically modified polymers may fall outside the SPM definition. |
| Particle size | Does the particle meet the 5 mm or fibre-like 15 mm criteria? | Particle size determines whether the substance may fall within the restriction. |
| Solubility | Is the polymer soluble above 2 g/L? | Water-soluble polymers may be excluded from the SPM designation. |
| Biodegradability | Can the polymer meet the relevant biodegradability criteria? | Biodegradable polymers may be excluded if supported by valid evidence. |
| Concentration | Is the SPM present at 0.01% w/w or above? | Mixtures above this threshold may trigger restrictions or obligations. |
What Are the Exemptions?
Even if a product contains SPMs, certain exemptions or derogations may apply. However, exemption from the placing-on-the-market prohibition does not necessarily mean exemption from all compliance duties. Many exempted or derogated uses still trigger information transfer, instructions for use and disposal, SDS and labeling updates, or annual reporting.
Industrial use: SPMs used exclusively at industrial sites may be exempt from the sales ban, but information and reporting obligations may apply.
Specific regulated products: products regulated by other EU laws, such as medicinal products, food additives and certain EU fertilizing products, may be exempt to avoid double regulation.
Risk-controlled situations: derogations may apply where SPMs are contained by technical means, lose their microplastic nature during use, or are permanently incorporated into a solid matrix.
Products with transitional periods: certain cosmetics, detergents, plant protection products, biocidal products, medical devices and synthetic turf infill may benefit from phased deadlines.
Regulatory update: Companies should also monitor subsequent amendments and clarifications, including Regulation (EU) 2026/1168 updates to the REACH microplastics restriction, which introduced clarifications relevant to medicinal products, PPORD and the solid matrix derogation.
Overview of Microplastic Compliance Obligations
For products that are not immediately banned but are either exempt or subject to a transitional period, the regulation generally imposes two major compliance obligations: information transfer and annual reporting.
Information Transfer Obligation
Suppliers must provide clear and precise information to prevent SPM release to the environment. This may include instructions for use and disposal, compliance statements, quantity or concentration information, and generic polymer identity information.
| Deadline | Affected Products / Uses | Required Action |
|---|---|---|
| October 17, 2025 | Industrial-use SPMs, food additives, and products covered by certain risk-controlled derogations. | Provide instructions for use and disposal, compliance statement, and polymer quantity or identity information through labels, packaging, package leaflets or SDSs. |
| October 17, 2026 | In vitro diagnostic devices containing SPMs and meeting relevant exemption conditions. | Provide use and disposal information to prevent environmental release. |
Annual Reporting Obligation
Manufacturers, industrial downstream users and certain suppliers must submit annual reports to the European Chemicals Agency (ECHA). Reports may cover information such as use descriptions, polymer identity, estimated quantities of SPMs released to the environment and applicable derogation references.
| Reporting Deadline | Who May Be Affected | Compliance Focus |
|---|---|---|
| May 31, 2026 | Manufacturers and industrial downstream users of SPMs in the form of pellets, flakes and powders used as plastic manufacturing feedstock at industrial sites. | Verify whether 2025 data were submitted and retain evidence for emission estimates and submission records. |
| May 31, 2027 | Other manufacturers, industrial downstream users and certain suppliers of exempted or transitional-period products. | Build an annual data collection mechanism and prepare 2026 use, release and polymer identity data. |
Companies preparing annual reports should also review REACH24H’s update on the EU microplastic emission reporting system and first submission deadline.
Sector-Specific Compliance Roadmap and Obligations
Products with an Immediate Ban
Starting from October 17, 2023, certain microplastic-containing products without a transitional period were immediately banned from being placed on the EU market. This primarily targets non-essential products prone to environmental release, such as loose plastic glitter for arts and crafts or toys, unless the product is out of scope or benefits from a derogation.
Industrial Use: Exempt from Ban, but with Obligations
Industrial-use SPMs may be exempt from the sales ban. In exchange, companies must meet strict information transfer and annual reporting obligations. Suppliers should update SDSs, labels, package information, use and disposal instructions, compliance statements and polymer identity information where required.
| Sector / Product Type | Key Date | Main Compliance Action |
|---|---|---|
| Rinse-off cosmetics | October 17, 2027 | Review formulation, substitution plan and inventory transition for affected products. |
| Detergents, waxes, polishes and air care products | October 17, 2028 | Assess product scope, SPM function, substitution feasibility and relevant information obligations. |
| Leave-on cosmetics and encapsulated fragrances | October 17, 2029 | Prepare formulation review, substitution strategy and market transition plan. |
| Medical devices | October 17, 2029 | Review device-specific scope, exemptions and information duties. |
| Plant protection products, seeds and biocidal products | October 17, 2031 | Coordinate sectoral product authorization with SPM restriction requirements. |
| Synthetic turf infill | October 17, 2031 | Plan material transition and procurement strategy before the end of the transition period. |
| Make-up, lip and nail products | October 17, 2035; labeling requirement from October 17, 2031 | From October 17, 2031, affected products must bear the statement “This product contains microplastics” to continue being sold during the transitional period. |
REACH24H tip: Even for products with a transitional period, if their use also meets conditions for a specific exemption or derogation, information transfer and annual reporting obligations may arise earlier than the final sales restriction date.
Building a Proactive Compliance Strategy
Given the complexity of the regulation, companies should move from a “wait and see” approach to proactive compliance. Failure to comply may lead to blocked market access, product recalls, supply chain disruption, reputational damage and enforcement risks under national implementation mechanisms.
Screen product portfolios: identify products containing intentionally added SPMs and prioritize products placed on the EU market.
Assess SPM scope: review polymer identity, particle size, solubility, biodegradability, concentration and intended function.
Determine legal route: confirm whether the product is banned, exempt, derogated or covered by a transitional period.
Update documentation: prepare labels, packaging information, package leaflets, SDSs and downstream communication documents.
Prepare annual reporting: build a data collection mechanism covering use descriptions, polymer identity and emission estimates.
Plan reformulation: evaluate substitution, inventory control and product launch strategy before relevant transition deadlines.
Monitor EU updates: track ECHA guidance, European Commission clarifications and further amendments to the microplastics restriction.
Need to confirm whether your products are affected by the EU microplastics restriction?
REACH24H can help you assess SPM scope, identify exemptions, update SDSs and labels, prepare ECHA reporting, and build a practical EU compliance roadmap.
Contact Our Regulatory SpecialistsHow REACH24H Can Help
The EU microplastics restriction requires companies to combine technical product assessment with practical compliance implementation. REACH24H provides support for companies placing substances, mixtures and finished products on the EU market under EU Microplastics (SPMs) Regulations, EU REACH, EU CLP and Global GHS/SDS/MSDS/Label Compliance.
| Support Area | REACH24H Services |
|---|---|
| Microplastics Compliance and Exemption Assessment | Assess whether products contain regulated SPMs and identify applicable exclusions, exemptions, derogations or transitional periods. |
| Testing and Technical Evidence Review | Support evidence review for solubility, biodegradability, particle size, polymer identity and solid matrix or other derogation claims. |
| SDS and Labeling Updates | Update SDSs, labels, package information and instructions for use and disposal to meet information transfer requirements. |
| ECHA Reporting Preparation | Prepare annual reporting data, including use descriptions, generic polymer identity information, estimated releases and derogation references. |
| EU Market Access Strategy | Develop product-specific compliance roadmaps covering reformulation, substitution, inventory control, customer communication and transition deadlines. |
| Integrated EU Chemical Compliance | Provide integrated support for EU REACH, EU CLP, SDS/label compliance, microplastics restrictions and broader EU market access obligations. |
Conclusion
The EU microplastics restriction is entering a more operational stage. The key question for companies is no longer only whether certain products are banned, but also whether information transfer, labeling, SDS updates, reporting and technical evidence obligations have been properly implemented.
Companies should review the impact of the October 17, 2025 information deadline, confirm whether the May 31, 2026 reporting obligation applied, and prepare for upcoming product-specific transition deadlines. Early product screening and documentation control remain essential to maintaining uninterrupted access to the EU market.
浙公网安备 33011002014301号