On 31 March 2025, the European Commission Technical Services published guidance documents on the application of EU REACH Regulation (EC) No 1907/2006 Annex XVII Entry 78 on synthetic polymer microparticles (SPM, microplastics).

The highlights are as follows:

1. The microplastic restriction in Entry 78 aims to address the risk of the intentional use of SPM. If the presence of SPM is unintentional (e.g., from the breakdown of plastic packaging, or larger plastic/polymeric objects), Entry 78 does not apply.
2. Particles continuously coated with solid polymer are considered SPM, even the solid polymer represents less than 1% of the weight of that particle.
3. The microplastic restriction includes a temporary 0.1 µm lower size limit for enforcement purposes (0.3 µm for fibre-like particles) due to the technical restraint. However, a lower size limit may apply in the future after technical development.
4. Emphasize the condition of “permanently” in Derogations 5(b) and 5(c). To apply the derogation(s), the change to the condition of the polymer shall be permanent until the product is disposed of.
5. Emphasize the condition of “instructions for use and disposal (IFUD)” in Derogation 5(a). The IFUD should be feasible and within the capacity for the target users to achieve in practice - particularly when targeted to consumers and professional users. If SPM emissions can only be prevented by means of instructions so complex/stringent that a target user would be unable to implement them in practice, then the derogation may not apply.
6. Articles with glitter affixed on their surface fall outside the scope of the restriction, irrespective of whether glitter detaches during normal use due to wear and tear.
7. Where a test material containing polymer particles meets the degradation pass criteria, it can be assumed that a test material containing smaller polymer particles of the same chemical composition (i.e., particles with higher surface-to-volume ratios) would also meet the pass criteria, so such test material would not need to be tested separately.

The guidance emphasizes that the EU Member States national enforcement authorities are the ones responsible for assessing the applicability of restriction on specific products and effectiveness of IFUD. There are certain borderline products being assessed, and their conclusions will be published by the European Chemicals Agency (ECHA) in the future, and only the Court of Justice of the European Union can give authoritative interpretations.

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