Microplastics in Serbia: 5 deadlines you need to know

From announcement to law: Microplastics are now regulated in Serbia

At the beginning of August 2025, I wrote about what is coming to Serbia from REACH Annex XVII. Entry 78 – microplastics – was only a matter of time back then. Many people were asking: “Will it really come here? And how fast?”

Today it is a reality.

The Rulebook on restrictions and bans on the production, placing on the market and use of chemicals (“Official Gazette of RS”, No. 90/2025) has implemented a complete system of bans and restrictions for synthetic polymer microparticles (SPM) – more widely known as microplastics.

But – and this is the key point most people still do not understand – this is NOT a simple ban. It is a phased implementation with FIVE different deadlines for different sectors, complex exemptions and precisely defined reporting obligations.

If you think this does not concern you because you are a “small company” or “we only work for the domestic market” – you are probably wrong. Here is what it means in practice for your company.

What are synthetic polymer microparticles (SPM)?

Before we get to the deadlines and obligations, let us clarify the basic terms. The rulebook gives a precise technical definition:

Technical definition

Synthetic polymer microparticles are solid polymers that meet the following conditions:

They are contained in particles and make up at least 1% by weight of those particles, OR they form a continuous surface coating on the particles
At least 1% by weight of the particles meets any of the following conditions:
- The particle dimension is not greater than 5 mm
- The particle (fibre) length is not greater than 15 mm, and the length-to-diameter ratio is greater than 3

In practice, this means:

✅ COVERED by the regulation:

Microbeads in scrub creams and shower gels
Glitter and sequins in cosmetics
Polymer granules for synthetic sports pitches
Additives in detergents and cleaning products
Fragrance encapsulation in personal care products
Polymer fibres in textile products that are washed
Coatings and finishes that can release particles

❌ NOT COVERED (exempt by nature):

Polymers resulting from natural polymerization (e.g. cellulose, starch)
Degradable polymers (according to the prescribed test methods)
Soluble polymers (>2 g/L)
Polymers without carbon atoms in their chemical structure

The critical timeline: When EXACTLY it concerns you

This is the most important part of the guide. There is NO single deadline for everyone – there are five different deadlines depending on the product type and intended use.

⏱️ MICROPLASTICS IN SERBIA

Entry 78: Implementation timeline for restrictions and bans
Rulebook on restrictions and bans, Official Gazette of RS No. 90/2025

17 OCT 2027: 🚿 FIRST WAVE OF BANS. Cosmetics (rinse-off), Shampoos, Shower gels, Scrub products, Toothpastes, Soaps. EXEMPTION: Products with SPM for fragrance encapsulation have until 2029.
17 OCT 2028: 🧼 SECOND WAVE OF BANS. Detergents, Cleaning products, Waxes, Polishes, Air fresheners; Fertilising products, Agriculture, Horticulture. EXEMPTION: Plant protection products (pesticides) and biocides have until 2031.
17 OCT 2029: 💄 THIRD WAVE OF BANS. Fragrance encapsulation, Microcapsules; Leave-on cosmetics, Creams, Lotions, Deodorants, Sun protection, Make-up; Medicines, Medical devices. EXEMPTION: Lip and nail products have until 2035.
17 OCT 2031: 🌾 FOURTH WAVE OF BANS. Pesticides, Insecticides, Fungicides, Herbicides, Biocidal products, Treated seed; ⚽ Sports pitches, Artificial turf - infill, Athletics tracks. NOTE: Sports pitches - an often forgotten sector with a large environmental impact!
2031-2035: 🏷️ MANDATORY LABELLING. Lip products, Nail products, Make-up. Mandatory statement on the packaging: “This product contains microplastics”
17 OCT 2035: 💅 FINAL DEADLINE. Lip make-up (lipstick, gloss), Nail polish, Nail gel, Nail strengtheners. WHY THE LONGEST DEADLINE? Technologically, it is hardest to find alternatives that maintain performance and safety.

📅 OCTOBER 17, 2027. – First wave of bans

COSMETIC PRODUCTS RINSED OFF THE BODY (rinse-off)

Covers:

Shampoos and conditioners
Shower gels and soaps
Bath foam
Scrub products and exfoliants
Toothpastes
Rinse-off shaving products

EXEMPTION: Products containing SPM for fragrance encapsulation have until 2029.

Note: Products with “microbeads” (abrasive particles for scrubbing/polishing) are specifically singled out and must be the first to be removed.

📅 OCTOBER 17, 2028. - Second wave

DETERGENTS, WAXES, POLISHES AND AIR FRESHENERS

Covers:

Laundry and dishwashing products
All-purpose cleaners
Floor and furniture waxes
Wood and metal polishes
Air fresheners in spray form or diffusers
Degreasers

FERTILISING PRODUCTS

Covers:

Foliar fertilisers with polymers
Horticultural protection products
Polymer nutrient carriers

AGRICULTURAL AND HORTICULTURAL PRODUCTS

Covers:

Mulching products
Polymer seed coatings (that are not biocides)
Additives in growing media

EXEMPTION: Plant protection products and biocidal products have until 2031.

📅 OCTOBER 17, 2029. - Third wave

FRAGRANCE ENCAPSULATION

Covers:

Fragrance microcapsules in all products
Perfumes with encapsulated components
Textiles treated with microcapsules

LEAVE-ON PRODUCTS

Covers:

Face and body creams
Lotions and body milk
Balms and ointments
Deodorants (except sprays)
Sun protection products
Make-up foundation and contouring

EXEMPTION: Lip and nail products have until 2035.

MEDICINES AND MEDICAL DEVICES

Covers:

Pharmaceutical dosage forms with polymers
Topical treatments
Dermatological preparations

EXEMPTION: Products with “microbeads” must already be removed in 2027/2028.

📅 OCTOBER 17, 2031. - Fourth wave

PLANT PROTECTION PRODUCTS AND BIOCIDAL PRODUCTS

Covers:

Pesticides with polymer carriers
Insecticides, fungicides, herbicides
Biocidal products (all types)
Seed treated with these products

GRANULAR INFILL FOR SYNTHETIC SPORTS SURFACES

Covers:

Infill for artificial turf pitches
Shock-absorbing infill for athletics tracks
Rubber granulate from recycled tyres

Note: This is one of the most frequently forgotten sectors, but one with a large environmental impact.

📅 OCTOBER 17, 2035. - Final deadline

LIP AND NAIL PRODUCTS

Covers:

Lip make-up (lipstick, gloss)
Nail polish
Nail gel
Nail strengthening preparations

Why the longest deadline? Technologically, it is hardest to find alternatives that maintain performance and safety.

Exemptions: Who is NOT covered by the ban

The rulebook defines several categories of products that are fully or conditionally exempt from the ban.

FULLY EXEMPT PRODUCTS (Point 4)

The ban does not apply to:

SPM for use at industrial sites
- Strict conditions for preventing emissions must be met
- Reporting and additional labelling are mandatory
Medicinal products and veterinary medicinal products
- Governed by separate regulations
- Covered by pharmaceutical legislation
Fertilisers
- Governed by plant nutrition regulations
- NPK fertilisers and compound fertilisers
Food additives
- Governed by food regulations
- E-numbers and technological additives
In vitro diagnostic medical devices
- Laboratory equipment and consumables
Food
- Directly governed by food safety regulations

CONDITIONALLY EXEMPT PRODUCTS (Point 5)

The use of SPM is permitted if:

a) Release into the environment is technically prevented

The product must have a mechanism for containing SPM
The instructions must clearly explain how to prevent emissions
Example: Filter systems, closed processes

b) The physical properties change permanently during use

The polymer changes chemically or physically during use
After use, it no longer meets the SPM definition
Example: Polymers that crosslink or polymerize in situ

c) Permanently incorporated into a solid matrix

The SPM is fully incorporated into the solid material
There is no possibility of release during use
Example: Polymers in composite materials, crosslinking coatings

CONDITIONALLY EXEMPT PRODUCTS (Point 5)

The use of SPM is permitted if:

a) Release into the environment is technically prevented

The product must have a mechanism for containing SPM
The instructions must clearly explain how to prevent emissions
Example: Filter systems, closed processes

b) The physical properties change permanently during use

The polymer changes chemically or physically during use
After use, it no longer meets the SPM definition
Example: Polymers that crosslink or polymerize in situ

c) Permanently incorporated into a solid matrix

The SPM is fully incorporated into the solid material
There is no possibility of release during use
Example: Polymers in composite materials, crosslinking coatings

Conclusion

Now you know: Are you covered, and when?

If you have made it this far, you have a clear picture:

5 different deadlines (2027-2035) depending on your sector
Fully exempt products that are not subject to the ban
Conditionally exempt products where you can use SPM under certain conditions

This is the fundamental part – understanding WHAT is coming and WHEN.

But critical questions remain:

Who has to report and what exactly do they report?
When do the reporting obligations start (2027? 2028? 2029?)?
What steps should you take NOW to be ready?
What mistakes do people make most often and how can you avoid them?

In the second part: Reporting and notification on the use of microplastics

The complete reporting system (who, what, when – March 31 every year)

In the third part I explain concrete operational steps:

Product labelling obligations

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.