EU REACH Annex XVII, Entry 78
SPM auditing & emission reporting
Microplastics reporting to ECHA is now mandatory, and the first deadlines are close. Tell us a little about your operations and book a free 30-minute diagnostic with our Head of Public Affairs to find out exactly what you need to submit, and when.
What changed
Microplastics are now a reporting obligation
Under REACH Annex XVII, Entry 78, introduced by Commission Regulation (EU) 2023/2055, synthetic polymer microparticles (SPM) are solid synthetic polymer particles smaller than 5 mm that are insoluble, non-degradable, and intentionally added to products where they can be released to the environment. The definition also covers synthetic fibres shorter than 15 mm with a length-to-diameter ratio greater than 3.
The annual reporting duty concerns estimated emissions of SPM to the environment from uses that benefit from a derogation rather than being subject to an immediate placing-on-the-market ban. For each derogated use, you must estimate and annually report those emissions. Submissions are made to ECHA using IUCLID through REACH-IT. Getting the scope, data, and dossier right is where most companies need help.
The deadlines
Two dates that matter
31 May 2026
Manufacturers & industrial users of pellets, flakes and powders
First reports covering 2025 emissions are due to ECHA.
31 May 2027
All other manufacturers, downstream users and suppliers
First reports covering 2026 emissions are due to ECHA.
Does this apply to you
Who needs to report to ECHA
Who must report
- Manufacturers and industrial downstream users applying SPM at industrial sites for derogated uses.
- Suppliers placing products containing derogated SPM on the EU market for professional users or consumers for the first time.
Derogated uses in scope
- Use of SPM at industrial sites.
- Human and veterinary medicinal products (Directive 2001/83/EC and Regulation (EU) 2019/6).
- Food additives (Regulation (EC) No 1333/2008).
- In vitro diagnostic medical devices (Regulation (EU) 2017/746).
- SPM contained by technical means during use, permanently modified during end use, or permanently incorporated into a solid matrix.
Not sure which category you fall into, or whether a derogation applies? That is exactly what the free diagnostic is for.
How we help
Our services
Auditing
Review of your portfolio against regulatory expectations under the microplastics restriction.
Obligation mapping
Identification of your duties under the restriction, tailored to how you operate.
Data support
Help structuring emission information into the required format and categories.
IUCLID dossier preparation
Compilation of your data in the required IUCLID format, ready for submission.
REACH-IT submission
Technical handling and submission of your dossier through REACH-IT.
Follow-up
Ongoing monitoring of changes and updates to your obligations.
Free diagnostic
Book time with Julien de Cruz
Head of Public Affairs, REACHLaw
Pick a time that works for you and share a few details about your operations. In 30 minutes, we will assess your likely obligations under Entry 78, flag which deadline applies, and outline the fastest path to a compliant ECHA submission.
No preparation needed. If we cannot help, we will tell you that too.
Open the calendarREACHLaw Ltd, Helsinki, Finland. Your partner in Chemical and Product Regulatory Compliance and Sustainability
Prefer email? sales@reachlaw.fi
+358 9 412 3055