Polymer Comply Europe
The only training course covering both the REACH Restriction EU 2023/2055 and the new Pellet Loss Regulation EU 2025/2365 — with practical, operational guidance for every company handling plastic pellets, flakes, or powders.
REACH labelling is already live — your first annual emissions report to ECHA is due May 2026, covering 2025 losses.
What's At Stake
Under Article 20 of Regulation 2025/2365, the maximum administrative penalty must be at least 3% of annual EU turnover in the preceding year — set by each Member State to be effective, proportionate, and dissuasive.
Additionally, competent authorities can suspend operations or immobilise vehicles where an infringement poses an immediate risk to human health or the environment.
Course Curriculum
Full overview of EU 2025/2365: scope, definition of plastic pellets, and covered operators. Key obligations include the RMP, certification thresholds, and record keeping.
Scope and provisions of EU 2023/2055. Understand the industrial site derogation, as well as the new labelling and reporting obligations.
Practical implementation of Annex I measures of the Pellet Loss Regulation. Covering the three layers of protection to stop pellets from escaping.
How you can meet the REACH reporting requirements. Covers the ECHA account, IUCLID templates, and how to submit an emissions estimate via REACH-IT.
Inside the EuPC Bow-Tie model: how to structure your site setup and score your barriers. Learn how to estimate losses safely without dedicated spill campaigns.
A complete, practical guide to quantifying your pellet losses using a sample injection moulding converter. Concludes with a step-by-step ECHA reporting walkthrough.
Who Is This For
Responsible for implementing Risk Management Plans, practical measures and day-to-day pellet loss prevention on site.
Ensuring REACH labelling is correct, ECHA reporting is submitted on time, and certification deadlines are met for your company size.
Carriers and logistics managers responsible for transport obligations, SQAS compliance, incident reporting, and Incoterms responsibilities.
Understanding the full exposure — penalties up to 3% of EU turnover, certification timelines, and the strategic compliance roadmap.
Access
Questions
My company handles less than 1,500 t/yr. Do I still need to comply?
Yes. The scope threshold under EU 2025/2365 is just 5 t/yr. Below 1,500 t/yr you are exempt from third-party certification, but you still need a Risk Management Plan and a self-declaration to competent authorities — both covered in Module 2.
What is the difference between EU 2023/2055 and EU 2025/2365?
EU 2023/2055 drives labelling and ECHA reporting obligations. EU 2025/2365 covers operational prevention, Risk Management Plans, certification, and transport. Most plastics companies are subject to both — Modules 1 and 2 cover each regulation in full.
I haven't measured my losses yet. Can I still report by May 2026?
Yes. You can extrapolate from a 15–30 day measurement window to estimate annual losses. Module 4 explains the methodology and Module 6 walks through a complete worked example — including how to document your approach for ECHA.
What is the Bow-Tie model and do I need it?
The Bow-Tie model is the industry-recommended approach for estimating your annual pellet losses for ECHA reporting. Module 5 explains how it works and how to score your barriers. Module 6 applies it to a complete worked example using the downloadable Excel file included with the course.