Under REACH Annex XVII Entry 78, the EU has banned the placing on the market of synthetic polymer microparticles (SPMs) unless a specific derogation applies. Derogations exist for essential uses such as:
• Industrial feedstock (where microplastics remain contained within industrial sites)
• Medicinal products and veterinary medicines
• Food additives (within EU food laws)
• In vitro diagnostic devices
• Uses where microplastics are permanently embedded or contained in a solid matrix (e.g., certain construction materials)
Even if your use falls under a derogation, you are not automatically exempt from reporting. For derogated uses, the regulation requires an annual report to ECHA. This report must include the type of use, the specific derogation claimed, the generic identity of the polymer (using Harmoniz ed System codes), and an estimate of annual emissions – both during transport and at end‑use.
Key Deadlines to Keep in Mind
| Deadline | Who it applies to | Emissions period covered |
|---|---|---|
| 31.05.26 | Manufacturers and industrial users of pellets, flakes, and powders used as a feedstock in plastic manufacturing at industrial sites | Calendar year 2025 |
| 31.05.27 | Other manufacturers and downstream users using SPM at industrial sites | Calendar year 2026 |
| 31.05.27 | Products in Paragraphs 4b, 4d, 4e and Paragraphs 5a–5c | Calendar year 2026 |
The restriction is designed to reduce intentionally added microplastics released into the environment. It does not cover unintentional microplastics (e.g., from tyre wear or textile washing), nor does it apply to polymers that are biodegradable, water‑soluble, or have no particles below 5 mm (about 0.2 in).
However, proving that your product falls outside the scope often requires analytical data or technical justification.
Reference:
https://gpcregulatory.com/microplastics-restriction-reporting-services/
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