The handling of plastic pellets is among the relevant sources of unintentional microplastic releases in Europe. If these particles enter soils, water bodies and seas due to losses along the value and logistics chain, this is associated with demonstrable ecological impacts that also pose risks to human and animal health. The decisive factor here is the unintentional release during the manufacturing, processing, storage and transport of plastic pellets regardless of their shape, form or size.
Legal framework: entry into force and applicability
On 16 December 2025, Regulation (EU) 2025/2365 on preventing the release of plastic pellets to reduce environmental pollution from microplastics entered into force. Most requirements apply from 17 December 2027. With the Regulation, the European Union establishes a directly applicable legal framework that sets binding organizational and technical requirements along the entire value and supply chain.
Integration into the existing EU legal framework
The Regulation fits into the EU legal framework already in place for plastic pellets. The REACH Regulation most recently regulated the placing on the market of intentionally added polymer micro‑particles. By contrast, Regulation (EU) 2025/2365 specifically addresses the unintentional release of plastic pellets and pursues a preventive approach directly at the source. There are also intersections in particular with waste law, occupational safety law and the Industrial Emissions Directive.
Practical implications for companies
In practice, this requires a fundamental change in thinking. The Regulation introduces EU‑wide uniform requirements for the handling of plastic pellets. Activities particularly affected include:
In this context, the Regulation sets out specific requirements for handling, organization and information sharing. These are complemented by certification and approval requirements, publication obligations, effective sanction mechanisms, as well as liability and compensation provisions.
Who is affected? Overview:
As a rule, the scope of the Regulation covers companies that handled at least five tonnes of plastic pellets in the Union in the previous calendar year. There are also simplified rules for installations with less than 1,500 tonnes per year and for micro‑enterprises.
Those primarily affected include:
Also covered are:
In addition, requirements apply to shippers as well as to agents and masters of seagoing vessels that carry plastic pellets in freight containers and call at or depart from a port of a Member State.
Through this horizontal addressing, the European Union establishes a comprehensive, gap‑free supply chain approach.
Core requirements of the Regulation
The aim of the Regulation is to prevent releases of plastic pellets along the entire supply chain and—if releases nevertheless occur—to take effective measures to contain or remove them.
The most important requirements at a glance:
Key requirements for installation operators:
Key requirements for EU and non‑EU carriers:
Key requirements for shippers:
From when do which requirements apply?
With the Regulation entering into force on 16 December 2025, basic organizational and preparatory requirements already have to be fulfilled. These include, in particular, requirements to prevent releases as well as documentation and training requirements. Most operational requirements for installation operators and carriers, however, will only apply from 17 December 2027. In view of the considerable depth of intervention, the remaining implementation period is comparatively short.
What affected companies should do now – a checklist:
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Conclusion
Regulation (EU) 2025/2365 for the first time establishes a uniform, directly applicable legal framework across the Union to prevent releases of plastic pellets along the entire value and logistics chain. It goes well beyond previous, fragmented regulatory approaches and codifies comprehensive organizational, technical and contractual requirements for manufacturers, installation operators, logistics actors and carriers. By introducing binding risk management, documentation, training, monitoring and certification requirements, as well as a standalone liability and sanctions regime, the Regulation marks a paradigm shift in European environmental and product responsibility law. In view of the staged start of application, the considerable depth of intervention and the complex interfaces between operations, transport and external services, affected companies have only a limited timeframe to align their processes in a compliant manner. Early, strategically guided compliance management is therefore imperative not only from a regulatory perspective, but also in terms of liability and risk law.