Synopsis
This Regulation will apply obligations on the handling of plastic pellets across the supply chain, with the aim of achieving zero pellet losses.
Amongst other obligations, risk management plans will be required for installations handling plastic pellets. Additional obligations will apply to the carriage, packaging, shipment and maritime transport of plastic pellets.
Summary
Regulation (EU) 2025/2365 on Preventing Plastic Pellet Losses to Reduce Microplastic Pollution will come into force on 17 December 2027.
This legislation applies across all EU Member States.
What will change?
Obligations are applied on the handling of plastic pellets across the entire supply chain, with the aim of achieving zero pellet losses.
A general obligation requires economic operators, EU carriers and non-EU carriers to avoid losses and taken immediate action to contain and clean up losses where they occur.
Scope
The Regulation will apply to:
Notifications
Organisations operating installations, EU carriers and authorised representative must notify authorities in the respective Member State of these activities. This notification must be made by 17 December 2027 or before they commence.
Risk management priorities
Economic operators, EU carriers and non-EU carriers must act in accordance with the following hierarchy in descending order:
Risk Management Plans
Operators of installations must prepare, implement and maintain a Risk Management Plan satisfying the requirements of Annex I.
The plan must include a site plan, estimated quantities of pellets handled and annual estimates of spills and losses, alongside high and low risk spill and loss locations and operations. Equipment and procedures must be put in place for prevention, containment and clean-up and a specific role must be put in place to record, investigate and report spills or losses.
Once in place, operators must notify the relevant competent authority for each Member State.
Medium and large enterprises handling 1,500 tonnes or greater per year must undertake annual internal compliance assessments. Operators handling less than 1,500 tonnes per year must update the plan and renew their self-declaration of conformity every five years.
EU Member States may apply equivalent measures to Risk Management Plans through conditions and requirements under environmental permits.
Training
Operators must ensure staff receive training appropriate to their roles, so that they understand environmental risks and can use relevant equipment.
Record keeping
Records must be kept of the total quantities of plastic pellets handled. Operators must also submit annual estimates of pellet losses.
Risk Management Plan Certification Requirements
Where 1,500 tonnes or greater of plastic pellets were handed in the previous calendar year, Risk Management Plans must be certified by the following schedules. Certification must be delivered by an accredited certifier.
|
Enterprise size |
First Certification Deadline |
Certification frequency |
|
Large |
17 December 2027 |
Three yearly |
|
Medium |
17 December 2028 |
Four yearly |
|
Small |
17 December 2030 |
Five yearly |
Smaller handlers and micro-enterprises may use a simplified self-declaration of conformity, which must be renewed every five years.
Incident and Accident Reporting
In the event of an incident or accident causing a loss affecting human health of the environment, operators, EU carriers and non-EU carriers shall inform the emergency services (as relevant) and take all possible measures to minimise consequences. Organisations must then provide a report within 30 days detailing quantities lost, causes of the loss and containment actions taken.
Action must be taken to prevent further incidents or accidents.
Alternative Routes to Compliance: Eco-Management and Audit Scheme (EMAS)
Operators registered with EMAS are exempt from Risk Management Plan and certification obligations, provided an accredited verifier confirms that the existing management system meets the requirements of the Regulation.
Carrier obligations
EU and non-EU carriers must implement preventive measures, containment and clean-up processes, and on-board equipment in Annex III.
Maritime transport rules
Shippers must ensure that plastic pallets are securely packed and required transport and cargo information (including a special stowage request) is provided.
From 17 December 2028, shippers must provide detailed information on the number and weight of containers carrying plastic pellets. Operators and masters must ensure they possess the list or manifest based on the cargo information received from the shipper.
Operators and masters of seagoing vessels must ensure containers are stowed in the most stable and sheltered areas of the vessel, typically below deck, to reduce the risk of pellet losses.
Manufacturer, Importer, Downstream User and Distributor Obligations
Statements and the label in Annex V must be provided for plastic pellets comprising synthetic polymer microparticles that are placed on the market. This information must be clearly included on the label, packaging, packaging leaflet or safety data sheet.
Greenspace subscribers receive full monthly updates summarising new and forthcoming legislation applicable to their organisation.
To receive these free updates by email, please subscribe to our mailing list. For a free trial and demonstration of Greenspace or a quotation, please contact us by email.
