Microplastics Under REACH: Material Declaration and Supplier Due Diligence Checklist

Reviewed By: Regulatory Compliance Specialist | REACH, RoHS & Environmental Compliance Expert

To comply with the REACH microplastics restriction, companies must determine whether their products contain intentionally added microplastics, assess applicable exemptions, collect detailed information from suppliers, and maintain material declarations and due diligence records. These requirements affect far more than cosmetics and glitter, extending to industries such as electronics, medical devices, construction materials, paints and coatings, agriculture, industrial chemicals, consumer products, and textiles.

For businesses placing products on the EU market, compliance now depends on understanding product composition, ensuring supply chain transparency, and maintaining robust documentation.

This guide covers material declarations, supplier questionnaires, reporting obligations, exemptions, and a practical checklist for REACH microplastics compliance.

Table of Contents

• What Are Microplastics Under REACH?
• The Legal Basis of the Restriction
• Why Did the EU Restrict Microplastics?
• Products Within Scope
• Exemptions Under REACH
• REACH Microplastics Compliance Timeline
• Reporting and Labeling Requirements
• Material Declaration Requirements
• Information to Request From Suppliers
• Supplier Due Diligence Framework
• REACH Microplastics Compliance Decision Tree
• Supplier Due Diligence Checklist
• Testing Methods for Identifying Microplastics
• Industry Examples
• Responding to Customer Declaration Requests
• Documentation and Record Retention
• Common Compliance Mistakes
• Future Regulatory Trends
• Partner with AMREP Supplier Management Services for an Audit-Ready REACH Compliance
• Frequently Asked Questions

Under REACH, microplastics generally refer to:

Solid polymer-containing particles smaller than 5 mm that are organic, insoluble, and resistant to degradation.

The restriction primarily targets intentionally added microplastics, meaning particles deliberately included in products to perform a specific function.

Examples include:

• Exfoliating beads
• Synthetic glitter
• Polymer powders
• Controlled-release fertilizers
• Encapsulated fragrances
• Specialty fillers
• Industrial abrasives

The restriction does not automatically apply to all plastics or to microplastics generated unintentionally during product use.

The Legal Basis of the Restriction

The microplastics restriction is established under:

• Regulation (EC) No. 1907/2006 (REACH)
• Annex XVII Entry 78
• Commission Regulation (EU) 2023/2055

The legislation restricts the placing on the market of synthetic polymer microparticles that are likely to be released into the environment.

The regulation also introduces:

• Information requirements
• Reporting obligations
• Labeling obligations
• Transition periods
• Exemptions for specific uses

Why Did the EU Restrict Microplastics?

Microplastics persist in the environment for decades and can:

• Accumulate in oceans and soil
• Enter food chains
• Affect ecosystems
• Become nearly impossible to remove once released

The European Chemicals Agency (ECHA) estimates that the restriction could prevent hundreds of thousands of tonnes of microplastics from entering the environment over the coming decades.

Products Within Scope

Products potentially affected include:

Cosmetics and Personal Care Products

• Facial scrubs
• Glitter products
• Makeup products

Agriculture Products

• Fertilizers
• Seed coatings
• Plant protection products

Paints and Coatings

• Decorative coatings
• Specialty additives

Medical Products

• Drug delivery systems
• Encapsulation technologies

Industrial Products

• Polymer powders
• Abrasives
• Fillers

Construction Products

• Artificial turf infill
• Additives and sealants

Electronics

• Encapsulated chemicals
• Specialty polymer components

Exemptions Under REACH

One of the most misunderstood areas of the regulation is the exemption framework.

Biodegradable Polymers

Certain polymers meeting strict biodegradability criteria may be exempt.

Natural Polymers

Naturally occurring polymers that have not been chemically modified may be outside the scope of the restriction.

Soluble Polymers

Specific soluble polymers may not be subject to the restriction.

Permanently Incorporated Particles

Microplastics permanently incorporated into a solid matrix and not expected to be released may qualify for exemptions.

Contained Industrial Uses

Some industrial applications are exempt but may still be subject to reporting requirements.

How to Document Exemptions

Companies should maintain:

• Technical justifications
• Supplier declarations
• Laboratory evidence
• Risk assessments
• Internal approval records

Assuming an exemption applies without evidence is one of the most common causes of non-compliance.

REACH Microplastics Compliance Timeline

Different product categories have different implementation dates and transition periods.

Businesses should monitor official guidance because reporting obligations and implementation requirements may evolve.

Reporting and Labeling Requirements

Depending on the product and exemption claimed, companies may need to:

• Submit information to authorities
• Provide instructions for use and disposal
• Label products appropriately
• Maintain annual records
• Provide information throughout the value chain

These obligations are frequently overlooked.

What Information Must Be Reported to Authorities?

Companies subject to reporting requirements may need to provide information such as:

Businesses should establish internal systems for collecting and maintaining this information.

Material Declaration Requirements

A compliant material declaration should include:

Product Information

• Product name
• Product code
• Manufacturer information
• Revision number

Composition Information

• Polymer identity
• CAS number
• Concentration range
• Particle size

Regulatory Information

• Contains intentionally added microplastics
• Exempt from restriction
• Outside scope
• Under investigation

Supporting Documentation

• Safety Data Sheets
• Technical Data Sheets
• Test reports
• Certificates of compliance

Example Material Declaration Template

Information to Request From Suppliers

A simple "compliant/non-compliant" statement is no longer sufficient.

Companies should request:

• Polymer identity
• CAS number
• Particle size
• Concentration
• Product function
• Environmental release potential
• Testing methods
• Supporting evidence
• Exemption justification

Supplier Due Diligence Framework

Step 1: Map the Supply Chain

Identify:

• Raw material suppliers
• Chemical suppliers
• Component suppliers
• Contract manufacturers

Step 2: Categorize Supplier Risk

High Risk

• Polymer suppliers
• Chemical manufacturers
• Coating suppliers

Medium Risk

• Component manufacturers
• Compounders

Low Risk

• Packaging suppliers
• Metal suppliers

Supplier Risk Matrix

Step 3: Send Supplier Questionnaires

Questions should include:

• Does the material contain intentionally added microplastics?
• What polymers are present?
• What is the particle size?
• Does an exemption apply?
• Has testing been performed?
• Can supporting evidence be provided?

Step 4: Verify Supplier Information

Verification methods include:

• Technical reviews
• Documentation assessments
• Independent testing
• Supplier audits
• Third-party laboratory analysis

Learn how to conduct a supplier performance evaluation to identify risks and improve supply chain compliance.

REACH Microplastics Compliance Decision Tree

• Does your product contain polymer particles?
• ↓
• YES
• ↓
• Are the particles intentionally added?
• ↓
• YES
• ↓
• Do exemptions apply?
• ↓
• NO
• ↓
• Restriction applies
• ↓
• Assess reporting obligations
• ↓
• Collect supplier information
• ↓
• Prepare material declaration
• ↓
• Maintain records

Supplier Due Diligence Checklist

Supplier Identification

• ☐ Supplier name
• ☐ Manufacturing location
• ☐ Contact person
• ☐ Product information
• ☐ Assessment date

Material Information

• ☐ Polymer identity confirmed
• ☐ CAS number obtained
• ☐ Particle size information available
• ☐ Concentration information obtained

Compliance Assessment

• ☐ Restriction status determined
• ☐ Exemptions assessed
• ☐ Reporting obligations reviewed
• ☐ Supporting documentation collected

Verification Activities

• ☐ Technical review completed
• ☐ Supplier responses verified
• ☐ Testing considered
• ☐ Information approved internally

Ongoing Monitoring

• ☐ Annual review process established
• ☐ Regulatory updates monitored
• ☐ Documentation retention procedures implemented

Testing Methods for Identifying Microplastics

Laboratory testing may be necessary when supplier information is incomplete.

1. FTIR Spectroscopy

Used to identify polymer composition.

Advantages:

• Widely accepted
• Good for polymer identification

Limitations:

• Limited sensitivity for very small particles.

2. Raman Spectroscopy

Useful for analyzing extremely small particles.

Advantages:

• High sensitivity.

Limitations:

• More expensive.

3. Microscopy

Used for particle characterization and sizing.

Advantages:

• Relatively inexpensive.

Limitations:

• Limited chemical identification.

4. Pyrolysis-GC/MS

Provides detailed polymer analysis.

Advantages:

• Highly accurate.

Limitations:

• Higher cost and specialized expertise.

Industry Examples

Cosmetic Manufacturer Example

A cosmetic company sourcing glitter should obtain:

• Supplier declarations
• Particle size data
• Exemption assessments
• Supporting test reports

Electronics Manufacturer Example

An electronics company purchasing specialty coatings should:

• Review chemical composition
• Assess polymer additives
• Maintain supplier questionnaires

Paint and Coating Manufacturer Example

A coatings manufacturer should:

• Evaluate additives and fillers
• Assess release potential
• Document exemption claims

Responding to Customer Declaration Requests

Customers increasingly request:

• Material declarations
• Compliance certificates
• Supplier statements
• Test reports
• Regulatory assessments

Organizations with standardized templates can respond significantly faster and reduce audit risks.

Documentation and Record Retention

Companies should maintain:

• Supplier questionnaires
• Material declarations
• Risk assessments
• Test reports
• Internal approvals
• Technical justifications
• Regulatory assessments

Good documentation demonstrates reasonable due diligence and significantly reduces compliance risk.

Common Compliance Mistakes

1. Assuming Suppliers Understand the Regulation

Many suppliers remain unfamiliar with the restriction.

2. Accepting Generic Compliance Statements

Declarations without evidence create significant risks.

3. Failing to Document Exemptions

Unsupported exemption claims are common audit findings.

4. Poor Recordkeeping

Insufficient documentation is one of the leading causes of compliance failures.

Future Regulatory Trends

Companies should prepare for:

• Digital product passports
• Increased supply chain transparency requirements
• Expanded substance reporting obligations
• More customer due diligence requests
• Enhanced environmental disclosure requirements

Organizations investing in compliance programs today will be better positioned for future regulations.

In addition to reviewing supplier compliance, businesses should understand various inspection methods for manufacturing to verify product quality and support supplier due diligence efforts.

Partner with AMREP Supplier Management Services for an Audit-Ready REACH Compliance

The REACH microplastics restriction represents a significant shift toward greater environmental accountability and supply chain transparency. Companies that establish robust material declaration procedures, implement risk-based supplier due diligence, and maintain comprehensive documentation will be best positioned to achieve compliance, satisfy customer requirements, and prepare for future environmental regulations.

At AMREP, we help businesses strengthen their due diligence processes through supplier quality management services that provide greater visibility into supplier capabilities and documentation practices.

Contact AMREP Inspect today to assess your supply chain, validate supplier information, and build an audit-ready REACH compliance program with confidence.

Frequently Asked Questions

Are all plastics covered under the restriction?

No. The regulation focuses primarily on intentionally added microplastics.

Can companies rely solely on supplier declarations?

No. Risk-based verification is considered a best practice.

Is testing always required?

Not necessarily. However, testing may be appropriate when supplier information is incomplete.

Are imported products affected?

Yes. Importers placing products on the EU market may have obligations under REACH.

Why is supplier due diligence important?

Because regulators increasingly expect companies to understand the substances present in their products and demonstrate reasonable efforts to verify compliance information throughout the supply chain.