Under the reporting obligation stems from Annex XVII Entry 78 of the EU’s REACH Regulation (often referred to as microplastic restriction) companies must start submitting annual SPM (Synthetic Polymer Microparticles or more commonly known as microplastic) emission to ECHA. The first reporting covering 2025 is due the 31st of May 2026.
On 26th November 2025, ECHA published it first Guidance document on the reporting requirement set by the microplastic restriction for certain uses derogated from the prohibition of placing on the market. The information shall be prepared in IUCLID 6 file and submitted by (or on behalf of) each legal entity (LE) that is subject to the reporting requirements via REACH-IT.
The specific information to be reported shall depend on which derogation applies to the use in question. But the report will cover SPM uses/end use, use category and sector, identity of the polymers, concentrations of the SPM, technical function and estimated emission quantity.
Manufacturers of SPM and industrial downstream users (DUs) using SPM (pellets, flakes, and powders) at an industrial site shall benefit from the derogation in paragraph 4(a) and report estimated emissions of SPM from their own manufacture or use, including during transportation, according to paragraph 11. They will report estimated emissions per LE, indicating the site(s) where the emissions take place.
Suppliers of products containing SPM benefitting from a derogation in paragraphs 4(b), 4(d) or 4(e), or 5(a), 5(b) or 5(c), that place those products on the market for the first time to professional users and the general public, shall report the estimated downstream SPM emissions occurring until the product is disposed of as waste (e.g. the estimated downstream emissions from distributors, including retailers, and end users), including from transportation, according to paragraph 12. In addition, the suppliers shall report their own estimated emissions according to paragraph 11 if applicable.
When to submit reporting information to ECHA?
The report shall be submitted to ECHA by 31st of May each year and shall contain information for the previous calendar year (for example emissions to the environment in 2025 must be reported to ECHA by 31 May 2026).
Who is responsible for reporting?
The obligation of reporting falls on the Legal entity (LE) that first places the SPM-containing product on the EU/EEA market. Therefore, manufacturers and importers, as well as industrial downstream users of SPM (pellets, flakes, and powders) used as feedstock in plastic manufacturing at industrial sites must submit a report by the 31st of May 2026.
Suppliers of products containing SPM with derogations as specified in paragraphs 4, points (b), (d), (e), and paragraph 5 of the restriction will be required to report by the 31st of May 2027. This included SPM containing products that are placed on the market for the first time as well as professional users and the public.
What information must be disclosed in the report?
The guidance also gives examples of how uses are to be reported. For example, if a company is a supplier of in vitro medical devices for both consumer and professional uses, they are only obliged to provide one reporting covering both uses. But if they produce medicinal products as well as in vitro medical devices for both consumer and professional uses, they must provide two reports, one for the medicinal product and another for the medical device.
Reporting environmental emissions:
The estimation shall comprise an aggregated numerical sum considering all environmental compartments (such as air, water and soil) as well as any emissions that occur during the use, including during transportation, until disposal or exit from the EEA. The estimation shall include emissions from intentional uses and operational losses within a use after all mitigation measures, losses during e.g. storage as well as from incidents such as accidents or spills. The waste stage is not included as this does not constitute a part of the use.
The estimated transportation emissions will be reported together with the emissions from the use/end use as one aggregated estimate under the relevant pre-defined use.
The guidance provides two options for report:
- Quantity of particles containing SPM estimated as a total quantity of particles in tonnes or kg per year (this includes SPM + non-SPM components) with option to include concentration range of SPM in particle. Otherwise, a default assumption of 100% concentration range will be assumed if no range is provided.
- Quantity of SPM only estimated as the total quantity of SPM in tonnes or kg per year excluding any additives, fillers and other non-SPM components.
Suppliers of products containing SPM shall report, in addition to their own emissions, the downstream emissions from the moment the product is placed on the market to the moment it is disposed of after end use but not including the waste stage.
Emissions during disposal should be estimated up to the point where the product becomes waste. This means that any spills that are retrieved and disposed of as waste are out of the scope. What needs to be estimated is the spilled amount of SPM that is not put back into production or disposed of as waste.
Tools for Estimating Emissions
ECHA did not provide specific tool for estimating emission but recommend that the industry can use their own preferred methods/tools. Nonetheless, they have indicated that the following resources may be used.
OECD Emission Scenario Documents which provide information on sources, use patterns and potential releases pathways.
Environmental Release Categories (ERCs): this model provides default worse case release factor as a percentage for different ERCs. This may therefore lead to an overestimation of environmental emissions.
Sector-specific environmental release categories (SPERCs) this is based on industries specific use maps. These models tend to be more accurate but can only be used in limited use cases.
Navigating the submission process
Companies must prepare the dossier using IUCLID 6. One dossier is required per legal entity and can contains multiple uses.
The completed dossier is then submitted via ECHA’s REACH-IT portal.
The report must be repeated annually and resubmitted using REACH IT.
Key Challenges with the reporting
Estimation of environmental emission remains a challenge as ECHA does not state which specific tools can be used. There are suggestions of developing SPERCs for separate industries but currently this is limited and will take some years to develop.
Furthermore, supply chain communication is complex, and downstream users must rely on the information provided by their supplier. Communicating this can be a problem especially as estimation of emissions is difficult due to the gaps in estimation models.
If you require any help with Microplastics Reporting, our team of compliance experts are well placed to assist you.
Published February 3rd, 2026
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