Microplastics Reporting: time to take action
ECHA released guidance explaining how companies must meet the annual REACH reporting requirements for synthetic polymer microparticles, including how to submit data using IUCLID and REACH-IT.
On November 26, 2025, the European Chemicals Agency (ECHA) officially launched reporting channels for annual microplastics emissions. With the update of the IUCLID software and the REACH-IT portal, companies can now proceed with the preparation and submission of data required by EU regulations.
Context: derogations and obligations (Reg. 2023/2055)
The reporting obligation is established by Regulation (EU) 2023/2055, which introduced specific restrictions on the intentional use of synthetic polymer microparticles (SPM) by adding entry 78 to Annex XVII of REACH. The regulation does not only impose bans but also establishes specific derogations (listed in paragraphs 4 and 5) for sectors where use remains permitted.
As established in paragraph 11 of the regulation, benefiting from such exemptions entails the duty to monitor and declare annually the quantities of synthetic polymer microparticles (SPM) placed on the market and their resulting emissions. In other words, transparency regarding environmental releases is the essential condition to market products that fall under these exempt categories.
Who must submit the report?
The obligation applies to:
- Manufacturers and industrial downstream users of SPM (pellets, flakes, powders) used as feedstock in plastic manufacturing at industrial sites.
- Other manufacturers of SPM and other industrial downstream users using SPMs.
- Suppliers of products containing SPM, benefitting from a derogation in paragraphs 4 letters b) (medicinal products and veterinary medicinal products), d) (food additives), or e) (in vitro medical diagnostic devices), and under paragraph 5(a), 5 (b) or 5 (c) that place those product on the market for the first time to professional users and the general public.
Deadlines and dossier content
Reports must reflect emissions from the previous calendar year. Consequently, the reporting scheduled for 2026 must be based on data collected throughout the entire year of 2025. Key deadlines are:
- May 31, 2026: for manufacturers and industrial downstream users of SPMs in the form of pellets, flakes, or powders used as raw materials in plastic production at industrial sites.
- May 31, 2027: for all other manufacturers and industrial downstream users of SPMs at industrial sites, and Suppliers of products containing SPM who benefit from the exemptions under paragraph 4, letters b), d), e) and under paragraph 5, placed on the market for the first time for professional users and the general public.
The IUCLID dossier must include the identity of the polymer, its use, the industrial site, the applicable exemption, and the estimated releases (comprehensive of accidental and related to normal use).
What to do now
To ensure compliance and avoid potential sanctions, companies should adopt a proactive approach:
- Verify whether they fall within the scope of obligated entities.
- Initiate a structured collection of all relevant information – including polymer types, quantities, production processes, sites, and applications – and establish an internal system for systematic monitoring and traceability of releases, while preparing the necessary data in advance of the reporting deadline.
It should be emphasized that this new reporting obligation does not apply to products already subject to a total ban. Instead, it is specifically aimed at companies benefiting from exemptions or derogations, allowing them to continue marketing their products in exchange for enhanced transparency.
>>>Complife’s dedicated microplastics task force is committed to supporting companies at every step – from laboratory analysis of microplastics to expert guidance on accurate IUCLID reporting – helping you stay fully compliant with regulatory requirements.
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