Microplastics: When Your Product Suddenly Falls Under the REACH Restriction
Microplastics are no longer just a cosmetics issue. With Regulation (EU) 2023/2055, the EU amended Annex XVII of the REACH Regulation. As a result, it now restricts the sale of intentionally added microplastics, as well as products that release them during use. The regulation has been in force since 17 October 2023.
Far more industries are affected than the first impression suggests. Cosmetics and detergents are included, of course, but so are plasticizers, fertilizers, plant protection products, infill granulate for artificial turf, glitter, toys, and medical devices. If you manufacture, place on the market, or industrially use products containing synthetic polymer microparticles, you should check whether one of the exemptions applies. One example: products used at industrial sites that do not release microplastics. However, that exemption comes with an obligation attached. Manufacturers must provide instructions for use and disposal to prevent release.
The transition periods are staggered and run until 2035. Still, some obligations are already relevant now. Suppliers of the relevant substances and mixtures have had to meet information requirements since October 2025/2026. In addition, a reporting deadline for affected actors ends on 31 May 2026.
Here, too, it's worth looking at ISO 14001:
Our new posts on the EmpCo Directive and the PPWR cover related substance and labelling obligations. If you're keeping your legal register current, our post on the new EU AI Act is another timely example.
Five Microplastics Regulation Takeaways From Our Advisory Practice
Legal Compliance
A product-related restriction like this needs to appear in your legal register. It is not just an environmental topic – it is a compliance obligation with deadlines.
Risk Management
Do your own products, processes, or supply chain contain microplastics within the meaning of the regulation? The standard's new life-cycle perspective applies directly here.
Document Management
Keep evidence for any exemptions claimed, instructions on use and disposal, and proof of reporting obligations to authorities.
Supplier Management
Control formulations, raw material specifications, and supplier declarations so that no products with non-compliant microplastic content reach the market.
Objectives Management
Substituting microplastic-containing raw materials makes for a concrete, measurable environmental objective. It is not just a reaction to the regulation – it is an active step in developing your product portfolio.
Staggered deadlines, but partly active already: The transition periods run until 2035. However, suppliers of the relevant substances and mixtures have had to meet information requirements since October 2025/2026, and a reporting deadline for affected actors ends on 31 May 2026.
Whether action is needed depends on whether your products or processes contain or release synthetic polymer microparticles. Sennefer Consulting is happy to help you assess this and document it properly.
This article was created with AI assistance.