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Microplastics Entry 78: Action plan, what to do right away

Microplastics Entry 78: Action plan, what to do right away

09/11/2025 | By Ivan Milenković

Now that you know WHAT and WHEN the ban is coming, and WHOM and WHEN you have to report to, here are concrete steps you can take today.

🔍 PHASE 1: URGENT ASSESSMENT (Q4 2025)

Completion deadline: December 31, 2025.

Reporting obligations: who, what, when

One of the most complex parts of implementation is the reporting obligations. Reporting does not apply only to manufacturers; it also covers other participants in the supply chain.

Step 1: Product inventory

  • Make a list of all products you manufacture, import or distribute
  • For each product, check whether it contains polymers
  • Identify whether those polymers are in the form of particles (<5mm or fibres <15mm)
  • Document quantities/concentrations

Practical tool: An Excel table with the columns:

  • Product name
  • Contains polymers (YES/NO)
  • Polymer type (synthetic/natural/degradable)
  • Form (particles/fibres/coating)
  • Dimensions
  • Concentration (% w/w)
  • Ban deadline
  • Status (covered/exempt)

Step 2: Identifying the deadline

  • Based on the timeline from the first part, determine which deadline applies to your products
  • Pay attention to products that may fall under several categories
  • Identify “risky” products that require quick action
  • Make a priority list by urgency

Prioritization:

  1. 🔴 HIGH PRIORITY: Products with a 2027-2028 deadline
  2. 🟡 MEDIUM PRIORITY: Products with a 2029-2031 deadline
  3. 🟢 LOW PRIORITY: Products with a 2035 deadline

Step 3: Checking suppliers

  • Contact ALL suppliers of raw materials that may contain polymers
  • Request:
    • Confirmations of the nature of the polymers (synthetic/natural)
    • Test results for degradability/solubility
    • Statements on SPM-free alternatives
    • Plans for phasing in alternatives

Email template for suppliers:

Subject: Inquiry - Synthetic polymer microparticles in [product name]

Dear Sir or Madam,

In accordance with the Rulebook on restrictions and bans on the production, placing on the market and use of chemicals (Official Gazette of RS 90/2025), 
we need to determine the status of the polymers in your products.

Please provide us with:
1. Confirmation of whether the polymers in [product name] qualify as SPM
2. Test results for degradability or solubility (if available)
3. Information on available SPM-free alternatives
4. A timeline for switching to alternatives

Deadline: [date - 2 weeks]

Thank you,
[Your name]

Step 4: Analysis of alternatives

  • Research the availability of SPM-free alternatives on the market
  • Evaluate:
    • Technical performance of the alternatives
    • Switching costs
    • Availability in Serbia/the region
    • Time needed for the switch
    • The need for testing/validation

Criteria for selecting alternatives:

✅ Technical equivalence (performance)

✅ Regulatory compliance (REACH, CLP, local regulations)

✅ Economic sustainability (cost vs. product price)

✅ Availability (at least 2 suppliers)

✅ Delivery time (max 4-6 weeks)

📝 PHASE 2: PREPARATION (2026)

Completion deadline: December 31, 2026.

Step 5: Updating safety data sheets (SDS)

  • Update Section 15 (regulatory information) in all SDSs
  • Add notes on SPM where relevant
  • State the exact legal basis (Entry No. 78, Point X)
  • Distribute the new versions through the supply chain

What to add to the SDS (Section 15):

15.1. SAFETY, HEALTH AND ENVIRONMENTAL REGULATIONS/
LEGISLATION SPECIFIC FOR THE SUBSTANCE OR MIXTURE

Restrictions in accordance with Annex 1 of the Rulebook on restrictions:
- Entry No. 78: Synthetic polymer microparticles (SPM)
- Product status: [Covered/Exempt - state the basis]
- Applicable ban deadline: [October 17 XXXX]
- Additional information: [Instructions for preventing emissions, if relevant]

Step 6: Product reformulation

  • Start developing new formulations for products that fall under the ban
  • Test the performance of SPM-free alternatives
  • Keep documentation of the development process
  • Prepare a plan for phasing in the new formulations

Timeframe for development and testing:

  • Q1 2026: Laboratory testing of alternatives (3-4 different options)
  • Q2 2026: Pilot production and stability tests
  • Q3 2026: Validation of performance and shelf life
  • Q4 2026: Finalizing the formulation and preparing for production

Documentation:

  • List of tested alternatives
  • Test results (performance, stability, shelf life)
  • Comparative analysis (old vs. new formulation)
  • Cost analysis
  • Scale-up plan

Step 7: Preparing for reporting

  • Set up a system for tracking SPM quantities in products
  • Organize the data by category (end use, polymer identity, emissions)
  • Designate the persons responsible for annual reports
  • Prepare reporting templates (March 31 of each year)

Reporting system, minimum:

  • Excel or a database with the following data:
    • Product with SPM
    • End use
    • Polymer type (identity)
    • Quantity produced/sold (kg/year)
    • Estimated emissions to the environment
    • Legal basis for an exemption (if any)

Responsible persons:

  • Primary: [name, position], data collection
  • Secondary: [name, position], validation and submission of reports
  • Backup: [name, position], in case of absence

Step 8: Employee training

  • Organize training for quality, production and procurement
  • Educate employees about the new requirements
  • Establish procedures for compliance checks
  • Create internal guidelines/instructions

Training by team:

QA/QC team:

  • Identifying SPM in raw materials
  • Checking supplier SDSs
  • Updating internal SDSs
  • Documentation for ensuring compliance

Production:

  • Procedure for preventing emissions (if the product is exempt)
  • Use and handling of SPM products
  • Cleaning and maintenance

Procurement:

  • Communication with suppliers
  • Procurement of SPM-free alternatives
  • Verification of documentation

Sales/Marketing:

  • Communicating changes to customers
  • Marketing “SPM-free” products
  • B2B compliance questions

✅ PHASE 3: IMPLEMENTATION (2027+)

Ongoing, according to your deadlines

Step 9: Monitoring critical deadlines

  • Set up alarms for your specific deadlines
  • Track stock levels of products with SPM
  • Organize the gradual sell-off of “old” formulations
  • Plan the launch of “new” products

Alarm system:

  • 12 months before the deadline: Finalizing the new formulation
  • 9 months before the deadline: Start of production scale-up
  • 6 months before the deadline: Launch of new products, end of orders for old ones
  • 3 months before the deadline: Selling off stocks of old products
  • 1 month before the deadline: Final check, nothing old may remain

Step 10: Gradual introduction of new products

  • Organize a phased transition
  • Communicate the changes to customers
  • Maintain parallel production if necessary
  • Launch new products at least 6 months before the deadline

Launch plan:

  1. Pre-launch (6-9 months before): Testing with key customers
  2. Phased launch (3-6 months before): Parallel availability of the old and new version
  3. Launch (3 months before): Only the new version on sale
  4. Phased end of supply (until the deadline): Selling off old stocks

Step 11: Annual reports

DEADLINE: MARCH 31 OF EACH YEAR

For 2027/2028/2029 (depending on your category): Submit a report to the competent authority with:

  • A description of the use
  • The identity of the polymer
  • Estimated emissions
  • A reference for the exemption

Where to send it:

  • Ministry of Environmental Protection
  • [Specific address/email, check on the MZŽS website]

Format:

  • [The MZŽS is expected to provide an official template]
  • Until then, use a structured Excel file with all the data from the reporting obligations

Step 12: Readiness to report at the request of a state authority

  • Keep data available for inspection
  • Prepare quick responses (7-30 days)
  • Maintain contact with suppliers for data
  • Update documentation with every formulation change

Inspection “go bag”:

  • List of all products with SPM
  • Polymer identity (technical data sheet)
  • Function of the polymer in the products
  • Supplier statements
  • Test results (degradability/solubility)
  • Annual reports (previous years)
  • Internal procedure for SPM compliance

Conclusion: compliance is a competitive advantage

The microplastics ban is no longer “something coming in the future”.

It is HERE. NOW. With clear deadlines. With reporting obligations. With inspection oversight.

And this is only the beginning. PFAS (Entry 79) will be next. DMAC and NEP (Entries 80-81) follow after it.

Two approaches:

APPROACH 1: Reactive:

  • Wait for the inspection
  • Panic when the deadline expires
  • Lose market share because products are not compliant
  • Pay fines

APPROACH 2: Proactive:

  • Prepare 18+ months in advance
  • Test alternatives while there is still time
  • Use compliance as a marketing advantage (“SPM-free!”)
  • Be ready when the competition panics

Do not wait for the deadline. Start today.

Downloadable resources:

📄 Compliance Checklist: print and use

📊 Timeline infographic

📧 Email Template for Suppliers

This blog post is for informational purposes only and does not constitute legal advice. For specific situations, consult a licensed chemical adviser or a lawyer specialising in chemical regulation.

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