Microplastics

Microplastics are persistent contaminants of global concern and are increasingly regulated under EU chemicals legislation. Regulatory focus has moved beyond secondary microplastics formed through degradation to also address intentionally added microplastics, referred to in EU legislation as Synthetic Polymer Microparticles (SPM). These include solid polymer-containing particles smaller than 5 mm (e.g. powders, pellets, flakes and beads) that are intentionally used to fulfil a specific function.

ARCHE Consulting supports companies and sector organisations in understanding and complying with the evolving EU regulatory framework on microplastics, with a strong focus on practical compliance, emission quantification, and regulatory reporting.

The EU has adopted a restriction on Synthetic Polymer Microparticles (SPM) under REACH (“microplastics restriction”). While certain uses are prohibited, others remain allowed under specific derogations, subject to defined reporting and information obligations. For derogated uses, companies are required to annually estimate and report releases of SPM to the environment. 

In addition, the Pellet Loss Regulation (Regulation (EU) 2025/2365) introduces binding requirements to prevent unintentional plastic pellet losses across the entire supply chain (production, processing, transport, storage, packaging, and cleaning). Most provisions apply from 16 December 2027.  

Unlike traditional chemical compliance frameworks, these measures are not centred on full environmental risk assessment. Instead, the regulatory objective is exposure reduction. 

Depending on their role in the supply chain, obligations may apply to manufacturers, importers, industrial downstream users and suppliers of products containing SPM. For companies using pellets, flakes or powders as plastic feedstock, the first reporting deadline is 31 May 2026, covering releases for calendar year 2025, and continues on an annual basis thereafter.

Organisations making use of derogated SPM are expected to: