Microplastics under REACH: reporting from 2027, but initial obligations already apply

On 31 May 2027, a broad group of businesses will be required to report to the European Chemicals Agency for the first time on synthetic polymer microparticles used in 2026. This does not, however, mark the beginning of the new regulations. The first restrictions on microplastics took effect in October 2023, further information requirements entered into force in 2025, and the first ECHA reporting deadline passed on 31 May 2026. The next significant deadline is 17 October 2026.

The regulation may be relevant to a much wider range of businesses than plastics manufacturers alone. In practice, an assessment may be needed at facilities using, among other things, paints and coatings, adhesives, inks, abrasives, ceramic raw materials, processing additives or other mixtures containing synthetic polymer microparticles.

For many companies, the greatest challenge may therefore be not submitting the report itself in 2027, but first establishing whether the raw materials and mixtures they currently use fall within the scope of the regulation at all, and which obligations already apply to them.

Microplastics under REACH – the regulation has applied since 2023

The obligations are based on entry 78 of Annex XVII to the REACH Regulation, introduced by Commission Regulation (EU) 2023/2055.

The regulation entered into force on 17 October 2023, when its first provisions began to apply. ECHA cites, as examples, the ban on certain microbeads used as abrasives and certain types of loose glitter. Transition periods of several years have been provided for a number of other uses.

Microplastics should therefore not be viewed as a regulatory issue that will only “take effect in 2027”.

Above all, 2027 marks a significant extension of reporting obligations.

What has already happened, and which deadlines lie ahead for businesses?

The regulatory timetable has several stages.

This timetable means that a business which only assesses the regulation shortly before reporting in 2027 may discover that certain information requirements or restrictions should already have been applied earlier.

Obligations since 17 October 2025 – also important for industry

A particularly significant change took place on 17 October 2025.

Since that date, suppliers of synthetic polymer microparticles intended for use at industrial sites have been required to provide recipients with specific information.

This includes, in particular, instructions for use and disposal explaining how to prevent SPM releases to the environment; a statement that the microparticles supplied are subject to the conditions set out in entry 78 of Annex XVII to REACH; data on the quantity or concentration of SPM in the substance or mixture; and generic information enabling the polymers it contains to be identified.

This information is intended to enable industrial downstream users to fulfil their own obligations, including subsequent emissions reporting.

This has significant practical implications.

A manufacturing company preparing to report for 2026 should therefore review not only its own processes, but also the information it currently receives from suppliers of raw materials and mixtures.

Missing data in supplier documentation may indicate a need to establish whether a material actually contains SPM and whether the obligations under entry 78 have been correctly identified throughout the supply chain.

The first microplastics reports were already submitted in 2026

Reporting to ECHA does not begin only in 2027 either.

The first deadline for submitting data on microplastics emissions passed on 31 May 2026.

It applied to manufacturers and industrial downstream users of SPM in the form of pellets, flakes and powders used as feedstock in plastics manufacturing at industrial sites.

The report covered emissions occurring in 2025.

For this purpose, ECHA launched a dedicated reporting process through IUCLID and REACH-IT.

This means that the reporting system is already operational. In 2027, it will extend to a much broader group of businesses.

The next change arrives on 17 October 2026

It is also important to note that a further obligation will arise before the end of 2026.

From 17 October 2026, suppliers of products containing synthetic polymer microparticles covered by the derogation for certain in vitro diagnostic devices will be required to provide instructions for use and disposal explaining to professional users and consumers how to prevent SPM releases to the environment.

For some other product categories, an equivalent information requirement has already applied since 17 October 2025.

When assessing microplastics obligations, it is therefore useful to distinguish three issues:

A ban or restriction on placing a particular product on the market, requirements to provide information throughout the supply chain, and the obligation to report emissions to ECHA annually.

The deadlines for these obligations differ.

The most significant extension of reporting will take place on 31 May 2027

From 2027, reporting will extend to other SPM manufacturers and other industrial downstream users using synthetic polymer microparticles at industrial sites.

This group’s first report must be submitted to ECHA by 31 May 2027.

Crucially, the report will not concern a period starting in 2027.

It will cover 2026.

Identifying the obligation only in the spring of next year may therefore create difficulties. The business will need to reconstruct information about materials used throughout the previous year and estimate the associated releases to the environment.

Certain product suppliers will also have to report from 2027

Reporting from 2027 is not limited to industrial users.

The obligation will also cover suppliers of certain products containing SPM that are placed on the market for the first time for professional users or consumers.

This applies to products benefiting from specific derogations under entry 78, including medicinal products, food additives, certain in vitro diagnostic devices, and cases in which the microparticles are contained by technical means, change their properties during end use, or become permanently incorporated into a solid matrix.

These suppliers will also need to provide information on end uses, polymer identity and estimated releases to the environment.

Microplastics obligations are not limited to plastics manufacturers

This is probably the most important practical aspect of the new obligations.

A company does not need to manufacture pellets or plastic products to potentially fall within the scope of reporting.

The types of materials used in its industrial processes may be decisive.

Screening may therefore also be necessary for businesses operating in areas such as industrial paints and coatings, adhesive and sealant manufacturing, printing and printing inks, packaging manufacturing, technical ceramics, construction materials, abrasive blasting, 3D printing, household chemicals, cosmetics, agriculture, pharmaceuticals, medical diagnostics, oil and gas, automotive manufacturing, machinery and equipment manufacturing, electronics and textiles.

This does not, of course, mean that every company in these sectors will be subject to reporting.

The obligation relates to a specific substance or mixture and its use, rather than simply to the sector in which a business operates.

Paints, varnishes and coatings

Facilities using specialist paints, varnishes and coatings may require particular attention.

SPM may be present as specific ingredients responsible for a product’s performance properties.

The regulation may therefore be relevant both to manufacturers of such mixtures and to industrial facilities using them in painting, surface protection or coating processes.

Adhesives and sealants

A similar situation may arise with adhesives and sealants.

Polymer microparticles may act as additives, fillers or components that give a mixture specific properties.

In practice, this issue may therefore concern not only the chemical industry, but also manufacturers of vehicles and components, machinery, electronics, household appliances and construction materials.

Printing and packaging

Another relevant area is printing inks, varnishes, coatings and adhesives used in the manufacture of packaging and labels.

Potential obligations may arise from the process chemicals used in manufacturing and finishing, rather than from the packaging material itself.

Technical ceramics

Microplastics may also be relevant to processes that are much less readily associated with plastics.

One example is technical ceramics, where certain polymer additives may be used during production.

This is a good illustration of why screening based solely on industry sector may be insufficient.

Automotive manufacturing, machinery, household appliances and electronics

A manufacturer of vehicles, automotive components, machinery or electrical equipment does not become subject to reporting simply because its product contains plastic parts.

What may matter, however, are the adhesives, coatings, surface treatment products, process materials or other mixtures containing SPM used at the site.

An assessment of auxiliary materials, rather than only the main raw materials, may reveal an obligation.

3D printing and powder materials

Processes using materials in powder form constitute a separate group.

This includes certain additive manufacturing technologies.

In these processes, identifying potential losses during material handling, machine loading, equipment cleaning and the management of unused material is also particularly important.

Household chemicals, cosmetics and agricultural products

The regulation provides specific transition periods for many categories of consumer and professional products.

For example, certain restrictions will apply from 17 October 2027 to rinse-off cosmetic products, and from 17 October 2028 to detergents, waxes, polishes and air care products. Even later dates are provided for other categories.

However, a transition period for a ban should not be equated with a complete absence of other obligations under the regulation.

What exactly must be reported to ECHA?

An industrial user’s SPM report will contain information relating to the preceding calendar year.

The company should identify the uses of the microparticles, provide generic information on the identity of the polymers used, and indicate the applicable derogation.

The most important part of the report, however, is an estimate of the quantities of SPM released to the environment during the preceding year.

The provisions expressly require releases occurring during transport to be included as well.

The greatest challenge may be the data, rather than the report

For many businesses, completing the report itself may be the easier part of the process.

It will be more difficult to establish beforehand which products actually contain SPM and where microparticles may be released.

The assessment may cover raw material delivery and unloading, storage, internal transport, dosing, the production process itself, equipment and surface cleaning, wastewater, emissions to air, waste and transport outside the site.

As a result, the necessary information may be held across purchasing, production, EHS, environmental protection, logistics, quality and waste management departments.

Not every safety data sheet will provide the answer

Documentation received from suppliers may also pose a practical challenge.

Identifying the presence of a polymer is not sufficient, on its own, to classify a material as SPM.

The definition in entry 78 is technical and takes into account, among other things, physical state, particle size and specific polymer properties.

A safety data sheet will therefore not always contain all the information needed to classify a product conclusively.

At the same time, since 17 October 2025, the provisions have required information to be supplied for SPM delivered for industrial uses, including their quantity or concentration and the generic identity of the polymers.

This can provide a useful starting point for screening purchased materials.

The provisions were amended again in 2026

The microplastics regulation continues to be refined.

Commission Regulation (EU) 2026/1168 of 1 June 2026 amended entry 78 of Annex XVII to REACH.

One element of the amendment was the explicit introduction of a derogation for synthetic polymer microparticles used for PPORD – product and process orientated research and development – in quantities of up to one tonne per year, including where such activities take place outside an industrial site, for example in a hospital or at a university.

This shows that the rules governing the restriction continue to evolve in light of experience gained through its practical implementation.

What should businesses do in 2026?

The most practical approach is to screen the raw materials, substances and mixtures used at the site before the end of 2026.

The first priorities are to establish whether processes involve materials that may contain SPM, verify the information received from suppliers, determine the legal basis for their continued use, and identify processes in which microparticles may be released.

For businesses subject to reporting, the next step should be to develop a methodology for estimating releases and collect data covering the whole of 2026.

Microplastics reporting – 31 May 2027 is the deadline, not the start of the project

The reporting deadline may seem a long way off.

In reality, by early October 2026, most of the period covered by the report has already elapsed.

For businesses subject to the obligation, this means that data on SPM use and emissions is being generated right now.

If a company only discovers in spring 2027 that one of its raw materials contains synthetic polymer microparticles, it may have to reconstruct historical data from several sites, systems and departments within the organisation.

The most important step at this stage is therefore to establish the scope of the regulation.

FAQ – microplastics and REACH

Are the microplastics provisions already in force?

Yes. The first restrictions under entry 78 of Annex XVII to REACH began to apply on 17 October 2023.

Have companies already had information obligations?

Yes. Since 17 October 2025, specific requirements have applied, among other things, to information provided by suppliers of SPM intended for use at industrial sites.

Has anyone already reported microplastics to ECHA?

Yes. The first reporting deadline passed on 31 May 2026 and covered data for 2025 from manufacturers and industrial downstream users of pellets, flakes and powders used as feedstock in plastics manufacturing.

What will change on 17 October 2026?

Another group of suppliers of products containing SPM will become subject to the obligation to provide instructions for use and disposal intended to prevent microparticle releases to the environment. This applies in particular to certain in vitro diagnostic devices.

What will change on 31 May 2027?

By that date, other SPM manufacturers and industrial downstream users using SPM at industrial sites will have to submit their first report covering 2026.

Does the obligation apply only to the plastics industry?

No. It may also be relevant to manufacturers using, among other things, paints, coatings, adhesives, process materials, inks, powders and other mixtures containing SPM.

Does every polymer give rise to an obligation?

No. A detailed assessment is needed of the SPM definition, material properties, use, the company’s role in the supply chain and the applicable derogation.

Summary

Microplastics reporting in 2027 is not the first obligation arising from the new REACH provisions.

The regulation began to have legal effects on 17 October 2023. Further information requirements have applied since 17 October 2025. The first deadline for reporting emissions to ECHA passed on 31 May 2026. A further stage of information requirements will take effect on 17 October 2026.

It is against this background that 31 May 2027 should be viewed, when reporting will extend to other SPM manufacturers and industrial downstream users.

For businesses, however, the key point is that the report submitted in May 2027 will concern activities already taking place in 2026.

In practice, this means that screening materials, identifying SPM, checking supplier documentation and determining how to calculate potential releases should all be carried out before the end of the current year.

Contact

Krzysztof Wiński
Managing Partner, T&P Advisory
krzysztof.winski@thedy.pl
Tel. +48 519 506 434

Joanna Frąckiewicz
Senior Manager, Thedy & Partners
joanna.frackiewicz@thedy.pl

Tel. +48 791 500 858