EU REACH: Reporting Obligations – Complying with the Microplastics Restriction
The European Union has adopted a restriction on intentionally added microplastics under the REACH Regulation. This landmark measure, adopted in September 2023, aims to reduce emissions of synthetic polymer microparticles into the environment by an estimated 500,000 tonnes over 20 years.
The restriction, which entered into force in October 2023, introduces phased bans and reporting obligations that affect a wide range of industries.
What Are “Intentionally Added Microplastics”?
Under REACH, “microplastics” are defined as synthetic polymer particles smaller than 5mm that are organic, insoluble, and non-degradable.
They are intentionally added to products for functions such as:
- Exfoliants in cosmetics
- Abrasives in detergents/cleaning products
- Encapsulation in agricultural products (fertilizers, pesticides)
- Controlled-release applications (paints, coatings, medical uses)
Reporting & Labelling Obligations
The regulation doesn’t just ban — it requires reporting and labelling obligations:
Downstream Users & Importers must:
- Provide information to professional users on how to use and dispose of products to minimize microplastic release.
- Apply new labelling requirements when microplastics remain in products (e.g., “contains microplastics” with safe use instructions).
Annual Reporting to ECHA:
- Manufacturers and importers of products containing microplastics must submit annual reports detailing:
- Type and quantity of microplastics placed on the EU market.
- Intended use/application.
- Justifications where exemptions apply (e.g., medical uses).
- The first report is due by 2027 for the previous calendar year.
Key Compliance Deadlines
The restriction has transition periods depending on sector:
- October 2027 → Ban on microbeads in rinse-off cosmetics (already in force).
- 2028–2031 → Gradual bans on microplastics in leave-on cosmetics, detergents, and fertilizing products.
- 2035 → Full ban for encapsulated fragrances.
- Reporting obligations apply to anyone placing microplastics on the market until a complete ban applies.
Who Is Affected?
- Cosmetics & Personal Care (exfoliants, glitter, encapsulated fragrances)
- Agrochemicals (seed coatings, controlled-release fertilizers, pesticides)
- Detergents & Cleaning Products (abrasives, encapsulates)
- Paints, Coatings, and Inks (microcapsules for controlled release)
- Medical Devices (some exemptions but still reporting required)
Business Implications
Non-compliance risks enforcement actions, fines, product recalls, and loss of EU market access. Equally important, consumer perception is shifting rapidly toward microplastic-free claims, making compliance not only regulatory but also commercial.
Next Steps for Compliance Managers
- Audit your product portfolio to identify microplastic-containing formulations.
- Engage suppliers to obtain full material disclosures.
- Update labels, SDS, and DoCs to reflect new requirements.
- Prepare internal systems to capture and report data to ECHA by the 2027 deadline.
- Monitor further ECHA guidance and FAQs as the reporting framework develops.
In summary: The EU’s microplastics restriction under REACH is more than a ban — it introduces a reporting regime that requires manufacturers, importers, and downstream users to actively monitor, disclose, and minimize emissions. Early preparation is the best way to avoid disruption and demonstrate leadership in sustainability.
