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On December 18, 2024, the European Chemicals Agency (ECHA) initiated a public consultation for the implementation of the reporting requirements of the microplastics restriction under REACH. The deadline for proving input is January 1, 2025.
Background
Entry 78 of Annex XVII of the REACH Regulation, introduced by Commission Regulation (EU)2023/2055 of 25 September 2023 (commonly known as “the microplastics restriction”), sets out restrictions for certain uses of synthetic polymer microparticles (SPMs) . The Regulation also specifies requirements of information reporting and annual report for certain derograted uses.
The reporting obligation shall apply as follows:
From October 17, 2025, information reporting for suppliers of SPMs for industrial uses and food additives;
From May 31, 2026, annual report for manufacturers and industrial downstream users of SPMs in the form of pellets, flakes, and powders used as feedstock in plastic manufacturing at industrial sites;
From October 17, 2026, information reporting for suppliers of products containing SPMs for vitro diagnostic devices;
From May 31, 2027, annual report for other manufacturers and industrial downstream users using SPMs at industrial sites; and suppliers of products containing SPMs for medicinal products, veterinary medicinal products, food additives, or vitro diagnostic devices that are placed on the market for the first time to professional users and the general public.
Despite having outlining the reporting timelines and general requirements, the details of what information that is to be reported as well as how to submit reporting data technically is not described in the Regulation.
Overview of Reporting Requirements
As per the proposal, the reporting will be done using IUCLID and be submitted via REACH-IT.
The description of use for microplastics is similiar to REACH registration as follows:
Brief description of the use in free text form
Sector(s) of use (SU)
Product Categor(ies) (PC)
Technical function(s) (TC)
For the manufacture and/or use at industrial sites, the identification of the industrial sites where the use takes place should be provided.
Focus on Detailed Reporting Information
The proposal does not include a definite reporting requirement for generic information of the polymers and calculation methods for the annual estimated emissions. Instead, it has offered two options currently being considered:
For reporting the generic identity of the polymers:
Entry 78 states in point (b) of paragraphs 11 and 12, that the reports for each use shall include generic information on the identity of the polymers used or placed on the market. The two options are as follows:
Option 1: The CAS number and CAS name of the polymer(s);
Option 2: A pre-selected list of entries (codes and descriptions) from the Harmonised System.
For annual estimated emissions:
As described in entry 78, the reporting entity reports information on annual estimated emissions
to the environment arising from the derogated use reported. The two options are as follows:
Option 1: Quantity of particles and concentration of SPM in the particles;
Option 2: Quantity of SPM.
The ECHA is planning to launch the annual reporting system by December 2025, and release guidance for microplastics restriction based on the consulation input.
The proposal can be accessed here.
