European Commission Issues Guideline for Microplastics Restriction under REACH

SafeGuardSAutomotive, Cosmetics & Personal Care, Electrical & Electronics, Hardgoods, Personal and Protective Equipment, Softlines, Toys and Juvenile ProductsApril 15, 2025

SG 057/25

The European Commission (EC) has recently issued an explanatory guide for the restriction of microplastics under REACH.

In 2023, the European Union (EU) published Regulation (EU) 2023/2055 to restrict synthetic polymer microparticles (SPM), also known as microplastics, under new entry 78 to Annex XVII of Regulation (EC) No. 1907/2006 ‘Registration, Evaluation, Authorization and Restriction of Chemicals (Annex XVII of REACH, current consolidated version to December 2024).

In 2024, the EC’s technical services announced the latest thinking on certain points associated with the application of the SPM restrictions, including plastic glitter on its own and in products (SafeGuardS 37/24 and references therein).

In March 2025, the EC issued a three-part explanatory guide (the Guide) to assist stakeholders and EU countries with implementation of the microplastics restriction:

Part I ‘A Narrative Part’
Part II ‘A Set of ‘Questions and Answers (Q and A)’’
Part III ‘Annexes’

The Guide has been endorsed by Member States by consensus, except for the view that articles with glitter affixed on their surface do not fall within the scope of restriction (See a) Part I, Section 5, b) Part II, Q & A Sections 2.25, 17.2, 17.6-17.8, 19.1 and 19.3 and c) Part III, Annex III, Section A3.3), where Austria (AT), Belgium (BE), Germany (DE) and the Netherlands (NL) expressed the position that the restriction applies to glitter not permanently affixed on the surface of articles.

Highlights of the Guide are summarized in Table 1.

Guide	Highlights
Part I ‘A Narrative part’	Describes using plain language the provisions and intended implementation of the restriction of SPM listed in entry 78 to Annex XVII of REACH (Commission Regulation (EU) 2023/2055) Details the recommended verification steps to be followed to determine whether a product (a substance, a mixture or a combination of substance/mixture and an article) is within the scope of entry 78 Indicates that SPM in articles or that are an integral part of an article are excluded from the scope of this entry Emphasizes that polymers must fulfil two conditions to be considered as SPM: First condition (all must be met): Solid Either synthetic polymers or natural polymers that have been chemically modified Organic (i.e. contains carbon atoms anywhere in their structure) Not degradable (when tested in accordance with Annex 15 of Annex XVII of REACH) Insoluble (≤ 2g/L solubility when tested in accordance with Annex 16 of Annex XVII of REACH) Second condition (either must be met): Contained in articles in a concentration ≥ 1% (i.e. the weight of the polymer(s) is 1-100% of the total weight of the particle containing the polymer(s) Built as a continuous coating around particles (including particles with a liquid core, such as vesicles) – no concentration limit applies and the coating needs to be ‘continuous’ Provides an overview of the following methods in Appendix 15 for natural and/or synthetic polymers or copolymers and their 'Pass level': EN ISO 14851 EN ISO 14852 EN ISO 17556 EN ISO 19679 and 18830 EN ISO 22404 Provides examples of SPM on their own (e.g. uncompounded polyethylene terephthalate (PET) or uncompounded polyvinyl chloride (PVC) and uncolored polystyrene (PS) Provides several examples of Case 1 mixtures with explanations: Rubber granulates used as infill material for sports surfaces (it is a mixture of styrene butadiene co-polymer (the SPM) and other substances) A piece of glitter where PET (the SPM) is mixed with aluminum and other substances Indicates Case 2 mixtures with explanations, including cosmetic formulations where polymer powder or flakes (the SPM) have been added Details Case 3 mixtures (Case 1 or 2 mixtures mixed with additional substances in the final product), including infill material for synthetic sports surfaces made of rubber granulate mixed with sand Details examples of calculations for mixtures in Cases 1-3 above Emphasizes that certain products containing SPM and uses of SPM were not granted a transitional period. These include but are not limited to: Granular infill for uses other than on synthetic sports surfaces Loose glitter Lubricants Products for arts and crafts Toys Details the information requirements, including instructions for use and disposal (IFUD)
Part II ‘A Set of Q and A’	Addresses the submitted questions from stakeholders into 19 sections covering specific provisions in the restriction or products: Section 1 ‘General Section 2 ‘Definition of ‘SPM’ and scope of restriction’ Section 3 ‘Paragraph 1 – ‘Prohibition of placing on the market’ Section 4 ‘Paragraph 2 – ‘Definitions’ Section 5 ‘Paragraph 3 – Temporary lower size limit’ Section 6 ‘Paragraph 4 – Derogations for certain uses and products’ Section 7 ‘Paragraph 5 – Derogations for SPM in certain intended uses’ Section 8 ‘Paragraph 6 – Transitional periods’ Section 9 ‘Paragraphs 7 to 10 – Information requirements, including IFUD’ Section 10 ‘Paragraphs 11 to 13 – Reporting of estimated SPM emissions’ Section 11 ‘Paragraphs 14 and 15 – Information to national competent authorities’ Section 12 ‘Paragraph 16 – Derogation for products on the market at entry into force’ Section 13 ‘Appendix 15 – Degradability’ Section 14 ‘Appendix 16 – Solubility’ Section 15 ‘Cosmetics – Specific questions’ Section 16 ‘Infill material for synthetic sports surfaces – Specific questions’ Section 17 ‘Glitter’ – Specific questions’ Section 18 ‘Toys – Specific questions’ Section 19 ‘Textiles – Specific questions’
Part III ‘Annexes’	Contains three Annexes to further assist stakeholders with SPM identification, obligations and borderline cases: Annex 1 ‘Decision trees for SPM identification’ Annex 2 ‘Obligations arising from entry 78 at different levels of the supply chain Annex 3 ‘Borderline cases’ with 28 illustrative examples of specific products, indicating whether the product is in or out of scope of the restriction or whether any derogations may apply

Table 1

The Guide will be revised regularly to meet the needs of additional clarification arising from the practical implementation of the restrictions.

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