Microplastics – compliance checklist

Entry 78: a practical preparation guide

Microplastics – checklist for implementing the ban

Rulebook on restrictions and bans, Official Gazette of RS No. 90/2025

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1.1 Product inventory Deadline: by 31 Dec 2025 Make a complete list of every product you manufacture, import or distribute. For each one, record whether it contains polymers and in what form (particles, coatings, fibres).
1.2 Identifying SPM in your products Deadline: by 31 Dec 2025 For every product containing polymers, check: (a) whether the particles are smaller than 5 mm or the fibres shorter than 15 mm, (b) whether polymers make up ≥ 1% w/w, (c) whether they are synthetic (not natural), (d) whether they are non-degradable and insoluble.
1.3 Setting deadlines per product Deadline: by 31 Dec 2025 Based on the timeline, determine exactly which deadline applies to each of your products (2027, 2028, 2029, 2031 or 2035). Rank your products by urgency.
1.4 Talking to suppliers Deadline: by 31 Jan 2026 Contact ALL suppliers of raw materials that may contain polymers. Ask for: (a) confirmation of the nature of the polymers, (b) test results for degradability/solubility, (c) statements on SPM-free alternatives.
1.5 Researching alternatives Deadline: by 31 Jan 2026 Identify SPM-free alternatives available on the market. Assess: (a) technical performance, (b) cost, (c) availability in Serbia, (d) the time needed to switch.

2.1 Updating safety data sheets (SDS) Deadline: by 30 Jun 2026 Update Section 15 in all your safety data sheets: (a) add a reference to entry 78, (b) state the product’s status (covered/exempt), (c) include the deadline for your sector.
2.2 Developing new formulations Deadline: by 31 Aug 2026 Start developing SPM-free formulations for the products the ban covers: (a) laboratory testing of alternatives, (b) stability and shelf life, (c) performance compared with the old formulation.
2.3 Setting up a reporting system Deadline: by 31 Oct 2026 Build a system to track: (a) the quantity of SPM per product, (b) the end use of each product, (c) the identity of the polymers, (d) estimated emissions to the environment. Appoint the people responsible for the annual reports.
2.4 Preparing reporting templates Deadline: by 31 Oct 2026 Set up a spreadsheet or system for: (a) annual reports (due 31 March), (b) reports requested by the authorities (within 7–30 days), (c) keeping data for the national database.
2.5 Staff training Deadline: by 31 Dec 2026 Organise training for: (a) quality control / the QA team, (b) production, (c) procurement, (d) sales. Cover the new requirements, deadlines and internal procedures.

3.1 Monitoring critical deadlines Set reminders for your specific deadlines. Check every month: (a) stock levels of “old” products, (b) readiness of the “new” formulations, (c) the deadlines for your sector.
3.2 Phasing in new products Plan a gradual switchover: (a) run down old stock, (b) parallel production (if needed), (c) launch new products 6+ months before the deadline.
3.3 Annual reports Deadline: 31 March every year For 2027/2028/2029 (depending on your category), submit a report to the competent authority with: (a) a description of the use, (b) the identity of the polymers, (c) estimated emissions, (d) a reference to the derogation.
3.4 Ready to report when the authorities ask Keep the data available for inspection: (a) the identity of the polymers, (b) their function in the products, (c) supplier contacts. Replies are due within 7–30 days.
3.5 Product labelling (where relevant) During the transition period (2031–2035), lip and nail products must carry the statement “This product contains microplastics” – visible, legible and indelible.
3.6 Documentation for inspections Keep up to date: (a) supplier statements, (b) polymer test results, (c) annual reports, (d) the internal procedure, (e) training records.

4.1 Checking exemptions Could your products count as exempt? (a) Point 4a – industrial use? (b) Point 5a – release technically prevented? (c) Point 5b – physical properties changed? (d) Point 5v – permanently bound in a matrix?
4.2 Degradability/solubility testing If you claim your polymers are degradable or soluble, prepare test results using the standard methods in Annex 1, Part 2a of the rulebook. Keep the documentation for inspections.
4.3 Marketing and communication Turn compliance into an advantage: (a) “SPM-free” marketing, (b) “compliant before the ban takes effect” messaging, (c) B2B communication with customers about compliance.

Additional notes and action plans

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This checklist is for educational purposes. For specific cases, consult a licensed chemicals adviser.