Microplastics – reporting to ECHA by 31 May 2026

by: Chemicals Consulting In REACH

Ultimo aggiornamento 1 Aprile 2026

Microplastics – reporting to ECHA by 31 May 2026: who must report

The first ECHA microplastics reporting deadline is approaching. The first report must be submitted by 31 May 2026 and covers estimated emissions for the 2025 calendar year.

This reporting obligation comes from Regulation (EU) 2023/2055, which added entry 78 to Annex XVII of REACH for synthetic polymer microparticles (SPM).

This article is not about the general microplastics restriction as a whole.
Its purpose is more specific: to clarify who must submit the ECHA microplastics report by 31 May 2026.

Who must submit the ECHA microplastics report by 31 May 2026

The first reporting obligation, with deadline 31 May 2026, applies to:

  • manufacturers of SPM;
  • industrial downstream users of SPM;
  • where the SPM are in the form of pellets, flakes or powders;
  • and are used as feedstock in plastic manufacturing at industrial sites.

In other words, the obligation does not apply to all companies dealing with microplastics in a broad sense. It applies to a specific group of operators and uses. The first step is therefore to understand whether the company actually falls within this scope.

For this first reporting obligation, plastic manufacturing may include industrial activities such as:

  • compounding;
  • production of articles through processes such as moulding, extrusion, thermoforming, and 3D printing.

This means the obligation may also affect companies that do not immediately associate their activity with the word “microplastics”, but that use polymers in pellet, flake or powder form in industrial processes.

The correct assessment should therefore start from the actual manufacturing process and the physical form of the material, not only from the commercial description of the product.

When a polymer is considered SPM

The reporting obligation concerns synthetic polymer microparticles (SPM) as defined by the restriction.

In practical terms, a polymer or combination of polymers is considered SPM only if it meets the conditions set out in the legal definition. These conditions relate to:

  • the polymeric nature of the material;
  • the particle size distribution;
  • the size and concentration criteria laid down by the restriction.

If one or more of these conditions are not met, the material is not considered SPM and does not fall within the scope of the restriction.

For reporting purposes, this is a key point. Before discussing IUCLID, data collection or release estimates, the company must first confirm whether the material actually qualifies as SPM.

What must be reported to ECHA

The information must be submitted to ECHA through an IUCLID dossier, which is then transmitted via REACH-IT.

The dossier includes, at least:

  • details of the reporter;
  • information on the relevant site or sites;
  • general information on the identity of the polymer or polymers used;
  • the identified uses;
  • an estimate of the quantity of SPM released to the environment during the previous calendar year, including releases occurring during transport.

From an operational point of view, this is the core of the obligation: gathering the right information and building a defensible estimate of the releases.

How to estimate microplastics emissions

One of the most difficult parts of microplastics reporting is the emissions estimate.

ECHA provides the submission route, but companies still need to determine how to estimate releases based on their own operations and available information. This is where many businesses face uncertainty: what internal data should be used, how should it be interpreted, and how should it be translated into a reasonable estimate for the dossier?

In practice, companies need to work on:

  • the actual processes carried out at the site;
  • the type and form of the polymer used;
  • the data available from production, handling and transport;
  • the method chosen to estimate releases.

Support for ECHA microplastics reporting

At Chemicals Consulting, we can support your company in:

  • verifying whether the ECHA microplastics reporting obligation applies to your business;
  • assessing whether the materials used qualify as SPM;
  • collecting and organising the relevant data;
  • setting up the emissions estimate;
  • preparing and submitting the IUCLID dossier to ECHA.

If you want to understand whether your company must report by 31 May 2026, contact us for an initial assessment.