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Microplastics Entry 78: Reporting and labelling

Microplastics Entry 78: Reporting and labelling

05/11/2025 | By Ivan Milenković

From strategy to action

In the first part of the guide I explained the timeline for the microplastics ban and the 5 different deadlines by sector (2027-2035), as well as the list of exemptions – full and conditional.

Now you know WHAT is coming and WHEN. You know whether you are covered or exempt.

But the key question remains: What exactly should you do now?

This second part is an operational guide – concrete steps, reporting obligations and an action plan for preparation.

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.

📋 FROM 2027: Suppliers for professional/general use

WHO REPORTS: Suppliers of products containing SPM on the basis of the exemptions under:

  • Point 4 (b) – Medicinal and veterinary products
  • Point 4 (g) – Fertilisers
  • Point 4 (d) – In vitro diagnostics
  • Point 5 – Conditionally exempt products (release technically prevented, physical properties changed, incorporated into a matrix)

WHAT IS REPORTED (deadline: March 31 every year):

  1. Description of the end use of products containing SPM placed on the market in the previous calendar year
  2. Generic information on the identity of the polymers placed on the market in the previous calendar year (separately for each end use)
  3. Estimate of the quantities of SPM released into the environment in the previous calendar year
    • Includes quantities released during transport
    • Must be per end use
  4. Reference to the derogation – state the exact legal basis (e.g. “Point 5 (a) – release technically prevented”)

LABELLING OBLIGATION (from 17.10.2027):

Suppliers of SPM under point 4 (a) – for industrial use – must provide:

  • Instructions for use and disposal – guidance on preventing the release of SPM into the environment
  • A statement: “The synthetic polymer microparticles supplied are subject to the conditions laid down in the regulation governing restrictions and bans on the manufacture, placing on the market and use of chemicals, under Restriction and Ban Entry No. 78.”
  • Information on the quantity or concentration of SPM in the substance or mixture
  • General information on the identity of the polymer – sufficient to meet the reporting obligations

Where it is given: On the packaging label, in the product instructions, or in the safety data sheet (for chemicals).

📋 FROM 2028: Manufacturers and professional users of pellets/powders

WHO REPORTS: Manufacturers and professional downstream users of SPM in the form of:

  • Pellets
  • Flakes
  • Powders

For what: Raw materials in plastics production at industrial sites

WHAT IS REPORTED (deadline: March 31 every year):

  1. Description of the use of SPM in the previous calendar year
  2. General information on the identity of the polymers used (for each use)
  3. Estimate of the quantity of SPM released into the environment for the previous calendar year
    • Includes emissions during transport
    • Separately for each use
  4. Reference to the derogation under Point 4 (a)

📋 FROM 2029: Other manufacturers and professional users

WHO REPORTS: ALL other manufacturers and professional users of SPM not covered by the 2027 and 2028 reporting.

WHAT IS REPORTED: The same content as for 2028 (points 1-4 in the paragraph above)

Deadline: March 31 every year

📋 ADDITIONALLY: Reporting on request (from entry into force)

WHO HAS THE OBLIGATION: Manufacturers, importers and industrial downstream users of products containing SPM

WHAT ON REQUEST:

  1. Data on the identity of the polymers covered by the restriction that are present in the products
  2. The function of the polymer in the products
  3. Information sufficient for clear identification of the polymer and its properties

DEADLINES:

  • Downstream user: 7 days from the competent authority’s request – must request the data from the supplier
  • Supplier: 30 days from the request to provide the information
  • Notice of forwarding: WITHOUT DELAY

Important: Data submitted to the competent authority becomes an integral part of the national database.

Consequences: Failure to meet these obligations is subject to inspection supervision and sanctions.

Product labelling obligations

In addition to reporting, there are also obligations for additional product labelling.

For food additives (from 17.10.2028)

Suppliers of food additives containing SPM must provide professional downstream users with:

  • Instructions for use and disposal
  • Guidance on preventing the release of SPM into the environment

The same obligations apply to in vitro diagnostics from 17.10.2029.

For cosmetics – transition period (17.10.2031 – 17.10.2035)

Products covered:

  • Make-up products
  • Lip products
  • Nail products

Mandatory statement:

“This product contains microplastics”

Where: On the product packaging – visible, legible, indelible

Note: Products placed on the market BEFORE October 17, 2031 do not need to carry this statement until December 17, 2031 (a 2-month transition period).

From knowledge to action

You now have a complete overview of the reporting obligations for microplastics in Serbia.

Roadmap through the series:

But knowledge without action does not protect you from inspection.

In the next blog I will show a 12-step action plan: what exactly to do in Q4 2025, during 2026, and in the final preparation for 2027. A practical timeline with concrete tasks, responsible persons and checklists you can implement tomorrow.

Subscribe to the newsletter to be the first to get the final part when it comes out.

Useful links:

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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