EU microplastics ban forces bath bomb makers into reformulation and mandatory reporting

Bath bomb makers across Europe must now juggle two urgent tasks: reformulate products to remove persistent synthetic polymer microparticles (SPMs) and prepare annual emissions reports to the European Chemicals Agency (ECHA). Commission Regulation (EU) 2023/2055 - entry 78 of Annex XVII to the REACH Regulation - creates a phased ban on placing on the market polymers that meet the SPM definition unless a use is explicitly exempted.

The reformulation clock is staggered by product type. Rinse-off cosmetics must be reformulated by October 2027, leave-on cosmetics and fragrance encapsulates by October 2029, and makeup, lip, and nail leave-on products by October 2035. Microbeads were already restricted across all applications in October 2023, so any bath bomb formulas that relied on solid plastic glitter or scrub beads must already have been removed from shelves.

Reporting obligations are the immediate operational burden for many small producers. ECHA sets a two-tier reporting timetable: manufacturers and industrial downstream users handling SPM in the form of pellets, flakes, and powders used as feedstock must report 2025 emissions by May 31, 2026, while other manufacturers, downstream users, and suppliers with temporary derogations must report 2026 emissions by May 31, 2027. ECHA states, “Manufacturers, industrial downstream users and suppliers placing on the market polymers that meet the definition of synthetic polymer microparticle (SPM) must report their estimated annual emissions to ECHA.”

Submit reports through ECHA’s systems after preparing the dossier in IUCLID 6. ECHA guidance says, “Before submission, you must create your report using IUCLID 6. You can use: The standalone IUCLID software installed on your computer, or The ECHA Cloud services (free of charge) which ensures you are using the latest IUCLID version.” For the IUCLID substance identity, use IUPAC name Synthetic polymer microparticles and inventory number 750-000-6. In IUCLID section 2 include the use and relevant derogation, site details for manufacturers and industrial downstream users, generic polymer identity, and estimated annual emissions; reporting must explicitly include releases during transportation.

Supplier documentation rules kick in from October 17, 2025. Suppliers must provide use and disposal instructions, a compliance statement, quantity/concentration information, and general polymer identity information in Safety Data Sheets and other product documents. Cosmetics suppliers should also note a labeling window flagged by a regulatory consultancy: a declared “This product contains microplastics” statement is expected during October 17, 2031 - October 16, 2035 for affected products, with transitional rules for stock placed on the market before October 17, 2031.

Practical next moves for bath bomb makers: map every polymer ingredient against the SPM definition, collect site and process emission data now, prepare IUCLID 6 dossiers, and update SDS language and on-pack information to meet the October 17, 2025 documentation start. Consider switching to biodegradable or water-soluble alternatives to avoid later reformulation rushes; industry analysis frames reformulation as an opportunity to modernize product lines and win consumer trust.

If you need regulatory help, consultancy contacts listed by industry advisers include CIRS: email service@cirs-group.com and phone +353 1 477 3710 (EU), +44 20 3239 9430 (UK), +1 703 520 1420 (USA), +86 571 8720 6574 (CN), +82 2 6347 8816 (KR), +81 070-9365-8022 (JP).

For makers of fizzy tubs and scented spheres, the takeaway is clear: reporting comes first, reformulation follows, and planning now will avoid compliance-driven panic later. Expect further guidance from ECHA as suppliers file IUCLID dossiers and regulators refine practical enforcement.