ECHA microplastics reporting 2027 – who reports, IUCLID and transport losses
Practical guide to the 2027 ECHA SPM annual emissions report, roles, transport data, supplier exemptions and REACH-IT handoff.
Short answer: Businesses covered by REACH Annex XVII entry 78 paragraphs 11 or 12 must submit estimated environmental releases of synthetic polymer microparticles (SPM) for the previous calendar year, generally by 31 May each year. For many newly covered businesses the first deadline is 31 May 2027 for 2026 releases. Certain plastic-production pellet, flake and powder operators began in 2026. Not every company buying or selling plastic has this obligation.
Who must report microplastics emissions to ECHA?
Determine whether the substance meets the legally defined SPM criteria, whether an exemption from the placing-on-market restriction applies and what the company actually does. Distinguish SPM manufacturer, industrial downstream user and supplier of particular SPM-containing products. Paragraph 11 concerns specified industrial activity; paragraph 12 concerns first placing certain exempted products on the market for professional or public end uses. An ingredient label or general environmental policy does not settle reporting duties.
Why the first reporting year differs
The first 31 May 2026 reports covered emissions during 2025 for industrial manufacturers or downstream users of pellets, flakes and powders as feedstock for plastic production. The 31 May 2027 first reporting round covers other SPM manufacturers and industrial downstream users and certain suppliers under paragraph 12, with emissions in 2026. For the earlier pellet cohort, the 2027 submission is the next annual report, not its first.
Paragraphs 11 and 12: responsibility decision table
| Actor or scenario | Reporting assessment |
|---|---|
| Pellets, flakes and powders used as plastic feedstock at industrial sites | Paragraph 11. First due 31 May 2026 for 2025; next due 31 May 2027 for 2026. |
| Other manufacturers of SPM in scope | Paragraph 11 from 2027. Record uses, generic polymer identity, site, annual estimated emissions and paragraph 4(a) derogation. |
| Industrial downstream users of SPM | Paragraph 11 where applicable. Processing or purchased mass does not equal environmental release. |
| Supplier first placing certain exempted SPM-containing products on the EU market | Paragraph 12 from 2027 for specified derogations in 4(b), 4(d), 4(e) or 5(a–c), subject to actual end use and role. |
| Ordinary retailer without a relevant first placement or other regulated role | Not automatically subject to reporting solely by reselling; verify importation or any additional activity. |
| 8 tonnes transported, 2 kg estimated lost to the environment | 8 tonnes is shipping mass, not environmental release. Justify the 2 kg and prevent double counting. |
Emissions versus shipped polymer mass
For each covered use or end use, document a generic polymer identity, the derogation relied on, and a method-based estimate of releases to the environment over the reporting calendar year, including transport. Paragraph 11 industrial reporters also provide the relevant site information. Maintain sources, assumptions, uncertainty, measurement or calculation method, review and transport responsibility. No data is not zero emissions. ECHA's guidance does not prescribe one universally valid emission factor for every site.
Prepare the official report in IUCLID 6 and submit via REACH-IT. The microplastics report identifies Synthetic polymer microparticles, inventory number 750-000-6, in sections 1/1.1. Section 2 captures uses and applicable derogations, relevant site details, generic polymer identity and annual releases. A Word or Excel working paper is not a compliant IUCLID dossier or proof of submission. Keep the real ECHA receipt.
Six steps to an auditable IUCLID dossier
- Confirm SPM definition with actual polymer and particle evidence, or record why it does not apply.
- Identify paragraph 11 or 12, correct use or end use, applicable derogation and relevant industrial sites.
- Collect 2026 process records, measurements, mass-balance inputs and documented estimates for air, water and land releases.
- Request carriers' and warehouses' actual or estimated losses, capture collection measures and establish which actor reports each release to avoid duplication.
- Review estimates, methods, uncertainty and missing values. Require a qualified manual sign-off, not an automatic spreadsheet approval.
- Enter the verified details into current IUCLID, submit via REACH-IT by the applicable 31 May deadline and retain the official acknowledgement.
Three practical scenarios
Industrial adhesive: A company uses qualifying SPM in production in 2026. Evaluate paragraph 11 and develop a transparent annual process and transport release estimate.
Exempted product supplier: A supplier first markets an SPM-containing professional product under an express exception. Evaluate paragraph 12; permission to market does not itself remove reporting.
Logistics: Shipping records show 8 tonnes transported but estimated 2 kg lost during loading. Record who is responsible for this release and the estimation method, rather than reporting all shipped mass.
Frequently asked questions
Is 2027 the first reporting year for every manufacturer?
No. Relevant industrial pellet, flake and powder operations first reported in 2026 for 2025 emissions.
Must transport losses be included?
Yes, where reporting applies the estimate covers environmental releases during transport, not total shipped weight.
Does missing carrier data mean zero?
No. Record missing evidence and assess a suitable defensible estimate.
Can an Excel file submit to ECHA?
No. Create the required IUCLID report, upload through REACH-IT and retain the real submission evidence.
Official sources and boundaries
reach · echa · guidance · kemi · naturvardsverket · commission
Primary legal and agency source review 13 November 2026. This is documentation support, not a certified emissions inventory, an IUCLID dossier, a regulatory approval or individual legal advice.
Practical Word, PDF and Excel templates
For editable supporting documents, see Microplastics to ECHA 2027 – annual emissions report, IUCLID and transport | Word/PDF/Excel. Check the product page for the exact included files.
