Previously, the European Chemicals Agency (ECHA) published the Guidance on the Reporting Requirements for the Restriction on Synthetic Polymer Microparticles (Microplastics) under REACH, providing detailed operational instructions for enterprises to fulfil their annual microplastics emission reporting obligations. With the first reporting deadline (31 May 2026) fast approaching, enterprises involved in plastics manufacturing, pharmaceuticals, food additives, and in vitro diagnostic devices should promptly begin data collection and filing preparations.
I. Definition of SPM (Synthetic Polymer Microparticles)
Solid polymers that simultaneously meet both of the following conditions:
(a) Present in particles and satisfying any of the following:
- Constituting at least 1% by mass of that particle; or
- Forming a continuous surface coating on that particle;
(b) At least 1% by mass of the particles meeting condition (a) above satisfy any of the following:
- (i) All dimensions of the particle are ≤ 5 mm; or
- (ii) The length of the particle is ≤ 15 mm and the length-to-diameter ratio is greater than 3.
The following polymers are excluded from this definition:
- (a) Polymers that occur in nature through a polymerisation process (regardless of extraction method) and have not been chemically modified;
- (b) Polymers proven to be degradable in accordance with Appendix 15;
- (c) Polymers proven to have a solubility greater than 2 g/L in accordance with Appendix 16;
- (d) Polymers whose chemical structure contains no carbon atoms.
II. Reporting Obligations
Reporting obligations are implemented in phases according to entity type.
|
Entity Type |
First Reporting Date |
Reporting Content |
|
SPM manufacturers and industrial downstream users (pellets/flakes/powders for plastics manufacturing) |
By 31 May 2026 |
Emissions from own manufacturing/use processes |
|
Other SPM manufacturers and industrial downstream users |
By 31 May 2027 |
Emissions from own manufacturing/use processes |
|
Suppliers of products containing SPM (first placing on the market for professional users/general public) |
By 31 May 2027 |
Downstream emissions (from placing on the market to end-of-life) + own emissions (if applicable) |
Note: Distributors have no direct reporting obligation (unless involved in importation, reformulation, repackaging, or relabelling).
III. Reporting Elements (Per Legal Entity, Per Use, Per Year)
|
Information Category |
Description |
|
Use |
Selected from a predefined list (e.g., industrial manufacturing, pharmaceutical products, food additives, in vitro diagnostic devices) |
|
Derogations |
Specific derogation basis applied |
|
Use Name |
Free-text description in English |
|
Product Category (PC) |
Applicable to "other industrial uses" and "other consumer/professional uses" |
|
Sector of Use (SU) |
Applicable to industrial uses only |
|
Technical Function (TF) |
Function of the SPM in the product |
|
Site |
Specific site to be indicated for industrial uses |
|
Polymer Generic Identity |
Selected from a predefined HS code list (e.g., polyethylene 3901, polypropylene 3902, etc.) |
|
Environmental Emission Estimate |
Total annual emissions (combined air, water, and soil, including transport emissions, excluding waste stage) |
IV. Emission Estimation Methods
- Option A: Report the total weight of particles containing SPM (tonnes or kg/year), with optional provision of SPM concentration range (0.1–100%).
- Option B: Report only the weight of the SPM itself (excluding additives/fillers).
Note: Emissions below 1 tonne/year should be reported in kilograms; emissions exceeding 1 tonne should be reported in tonnes. There is no minimum reporting threshold—even very low or near-zero emissions must be reported.
V. Reporting Process
- Format: IUCLID format
- Submission Platform: REACH-IT
- Submission Deadline: Data for the previous calendar year must be reported by 31 May each year
- Reference Substance: "Synthetic polymer microparticles" (EC Number: 750-000-6)
- Update Mechanism: A dossier update function will be launched in Q2 2026
VI. Confidentiality and Dissemination
- Confidential Information: Legal entity information, site information, and attachments requested by competent authorities
- Public Information: Emission data will be published in aggregated form on the ECHA website to avoid disclosure of commercial secrets
VII. Further Information Requests by Competent Authorities
Pursuant to paragraph 14 of the restriction, competent authorities may request:
- Specific identity information of the polymer (at least including the information required under REACH Annex VI, points 2.1–2.2.3 and 2.3.5–2.3.7)
- Function of the polymer in the product
Such information will be treated confidentially and will not be included in public dissemination.
Key Reminders
- A single legal entity may be involved in multiple uses and multiple derogations, which must be reported separately within one IUCLID dossier.
- Transport emissions shall be estimated by the party holding ownership of the product as contractually agreed.
- Emission estimates do not require precise data; default release factors, industry experience, or measured data may be used.
- ECHA recommends using tools such as OECD Emission Scenario Documents, ECHA Guidance R.16 (ERCs), and industry-specific environmental release categories (SPERCs) to assist in estimation.
