EU microplastics restriction: what it means for PTFE lubricants

This analysis covers the EU microplastics restriction, REACH Annex XVII entry 78, as it applies to PTFE micropowder in lubricants. It does not cover the separate proposed EU restriction of PFAS, articles such as PTFE-coated parts, or rules outside the EU. It is not legal advice for a specific product.

What is changing for PTFE micropowder under Regulation (EU) 2023/2055, and when?

PTFE micropowder under Regulation (EU) 2023/2055 has moved from an unrestricted additive to a regulated synthetic polymer microparticle, with a sales ban for uses without a derogation since 17 October 2023 and duties that phase in until 2028. Status as of 14 October 2026: the restriction is in force as entry 78 of REACH Annex XVII, and Commission Regulation (EU) 2026/1168, published on 2 June 2026, has amended it (Regulation 2026/1168, 2026). Regulation (EU) 2023/2055 was adopted on 25 September 2023, published in the Official Journal on 27 September 2023 and entered into force on the twentieth day after publication (Regulation 2023/2055, 2023). The Commission states that the restriction "began applying on 17 October 2023" (European Commission, 2025).

The timeline below lists the dates that decide what a PTFE micropowder maker, lubricant formulator or industrial user must do.

The row that matters most for lubricant formulators is 31 May 2027, the first deadline that needs numbers: an estimate of the microparticles released in calendar year 2026 (ECHA, 2025).

Does Regulation (EU) 2023/2055 cover PTFE micropowder in lubricants?

Regulation (EU) 2023/2055 covers PTFE micropowder in lubricants, because PTFE micropowder meets each part of the entry 78 definition of a synthetic polymer microparticle and none of the exclusions fits it. Entry 78 defines synthetic polymer microparticles as "polymers that are solid" which make up at least 1% by weight of particles, where at least 1% by weight of those particles have all dimensions of 5 mm or less (Regulation 2023/2055, 2023). PTFE micropowder sold for lubricants is far below that size: one maker's grade for oils, fats and coatings has a mean particle diameter of 8 µm by ISO 13320 and a melting point of 325 °C (3M Dyneon, 2014), so it stays a solid particle in normal service.

Entry 78 excludes natural polymers that are not chemically modified, polymers proved degradable under Appendix 15, polymers with a solubility greater than 2 g/L under Appendix 16, and "polymers that do not contain carbon atoms in their chemical structure" (Regulation 2023/2055, 2023). PTFE is a synthetic, insoluble fluorocarbon polymer with a carbon backbone, so in our reading none of the four exclusions applies.

The ban on mixtures applies where the microparticles are present "to confer a sought-after characteristic" at 0.01% by weight or more (Regulation 2023/2055, 2023). PTFE is added to lubricants to reduce friction and wear, and the same data sheet gives typical additions between below 1% and 20% depending on the matrix (3M Dyneon, 2014), far above the 0.01% limit.

Which PTFE lubricant products are affected, and under which clause of entry 78?

PTFE lubricant products are affected according to where they are used and what happens to the PTFE: products for use at industrial sites stay on sale under paragraph 4(a), while products for use outside industrial sites need a paragraph 5 derogation. The Commission's explanatory guide lists "lubricants" among the products containing microparticles that "were not granted a transitional period" (European Commission, 2025), unlike waxes and polishes, whose ban starts on 17 October 2028 (Regulation 2023/2055, paragraph 6). The table below maps common PTFE lubricant forms to the clause that applies; the assignment of each form is our reading of entry 78 and the guide, since neither names these products.

The row with the most commercial weight is the dry PTFE spray sold through trade and retail channels: in our reading no derogation fits it, so it cannot be placed on the market with PTFE at 0.01% by weight or more, except stock placed on the market before 17 October 2023 (Regulation 2023/2055, paragraph 16).

Which derogation applies to PTFE micropowder used at industrial sites?

The derogation that applies to PTFE micropowder used at industrial sites is paragraph 4(a) of entry 78, which lifts the sales ban for "synthetic polymer microparticles, as substances on their own or in mixtures, for use at industrial sites" (Regulation 2023/2055, 2023). The recitals give the reason: emissions from industrial sites are easier to control than emissions from consumer or professional uses (Regulation 2023/2055, recital 18). The Commission's guide describes this placing on the market as "permanently derogated under Paragraph 4(a)" (European Commission, 2025).

The limit is where the lubricant is used, not who buys it. The explanatory guide states: "It does not apply to SPM for professional uses outside industrial sites." (European Commission, 2025). The guide points to ECHA Guidance R.12 on use description, whose table R.12-6 gives a weight of evidence method to decide whether a use takes place at an industrial site (European Commission, 2025). For lubricants, a PTFE dry film applied on a production line by plant staff can fall under paragraph 4(a), while the same product sold to a field service technician or a bicycle shop does not; that example is our reading, not the guide's.

Paragraph 4(a) can also apply alongside paragraph 5, since the guide states that multiple derogations can apply to the same microparticles (European Commission, 2025). In a PTFE lubricant chain, the micropowder maker relies on 4(a), and the formulator needs a derogation for each downstream channel.

What instructions and reports must PTFE lubricant suppliers and industrial users provide, and by when?

PTFE lubricant suppliers and industrial users must provide instructions for use and disposal from 17 October 2025 and report to ECHA by 31 May each year. For supplies under paragraph 4(a), entry 78 requires four items from 17 October 2025: instructions for use and disposal, a fixed statement that the microparticles supplied are subject to the conditions of entry 78, the quantity or concentration of microparticles, and generic information on polymer identity (Regulation 2023/2055, paragraph 7). The safety data sheet (SDS) is an allowed place for paragraph 7 information, and instructions given as text must be in the official languages of the Member States of sale, unless those Member States provide otherwise (Regulation 2023/2055, paragraph 10). Suppliers of paragraph 5 products must give instructions for use and disposal to professional users and the public from 17 October 2025 (Regulation 2023/2055, paragraph 8).

Manufacturers and industrial downstream users of microparticles outside plastics feedstock report uses, polymer identity, estimated releases including transport, and the derogation, by 31 May 2027 for calendar year 2026 (ECHA, 2025). A PTFE micropowder maker that also supplies plastics feedstock at industrial sites must report that use a year earlier, first by 31 May 2026 for calendar year 2025 (Regulation 2023/2055, paragraph 11). First suppliers of paragraph 5 products to professionals or the public also report from 2027, including estimated releases until disposal as waste (ECHA, 2025). Reports are filed in IUCLID format through REACH-IT, which ECHA opened for them on 26 November 2025 (CIRS Group, 2025).

What are the technical consequences for PTFE lubricant formulators?

For PTFE lubricant formulators, products for use outside industrial sites must drop PTFE microparticles or show the PTFE is permanently changed or bound in end use. Paragraph 5(b) covers microparticles whose physical properties are permanently modified so that the polymer leaves the scope of the entry (Regulation 2023/2055, 2023); the guide's example is film-forming polymers that coalesce into a film (European Commission, 2025). PTFE micropowder melts at 325 °C (3M Dyneon, 2014), so in our reading only a coating sintered above it could argue 5(b); a film cured below it keeps the PTFE as particles.

Paragraph 5(c) covers microparticles permanently incorporated into a solid matrix, and the guide adds that the matrix "needs to stay in place indefinitely, without any predetermined end date" (European Commission, 2025). From 22 June 2028 the text reads "during an intended end use of a duration of one year or longer" (Regulation 2026/1168, 2026). In our reading, a bonded film lasting a fastener's life is the strongest 5(c) case, a run-in film worn away in months the weakest.

For substitution, the Commission states that materials that are inorganic, natural, biodegradable or soluble in water are not regarded as microplastics (European Commission, 2025). Molybdenum disulfide, graphite and hexagonal boron nitride are not synthetic polymers, so in our reading fall outside entry 78, but differ from PTFE in friction, color and conductivity. The guide notes: "There are no standard tests to demonstrate compliance with Paragraph 5(a), (b) or (c)." (European Commission, 2025).

What should formulators and distributors of PTFE lubricants do now?

Formulators and distributors of PTFE lubricants should sort each product by sales channel, confirm a derogation for each channel, and collect 2026 release data for the 31 May 2027 report. The table below assigns the work; the dates come from entry 78 and ECHA, and the split of tasks by role is our reading.

The row with the hardest deadline is the report: by the end of May 2027, other industrial downstream users using microparticles at industrial sites should report estimated emissions for calendar year 2026 (ECHA, 2025), so release records must cover all of 2026. Distributors carry no reporting duty, and the guide confirms that products placed on the market before 17 October 2023 "can continue being sold or otherwise placed on the market along the supply chain until stocks run out" (European Commission, 2025). Before disposing of withdrawn PTFE spray or solvent-based stock, follow the disposal section of the product's SDS and the waste law of the Member State concerned.

What is still open for PTFE micropowder under the EU microplastics restriction?

Four points are still open for PTFE micropowder under the EU microplastics restriction as of 14 October 2026: industrial-site uses, PTFE chain waxes, bonded PTFE films under amended paragraph 5(c), and the proposed PFAS restriction. The industrial-site line is decided case by case with the weight of evidence method in ECHA Guidance R.12 (European Commission, 2025), and we found no published answer for lubricants applied by contractors in a plant. Entry 78 and the guide do not define waxes, so in our reading a PTFE chain wax should not rely on the 17 October 2028 waxes date (Regulation 2023/2055, paragraph 6) without a documented classification.

No source we found settles whether PTFE in a cured film is permanently incorporated in a solid matrix. The guide accepts concrete and most paints as 5(c) examples (European Commission, 2025), but national enforcement authorities judge a supplier's evidence, and they "do not pre-approve products or product information" (European Commission, 2025).

The draft opinion of ECHA's Committee for Socio-Economic Analysis (SEAC) on the proposed EU PFAS restriction was open for comment until 25 May 2026, with a proposed limit of 50 ppm for PFAS, including polymeric PFAS, in mixtures (SGS, 2026). That restriction is not adopted, but it could still catch a PTFE lubricant that meets entry 78. Lubinpla, an applied AI company, works cases like this from a company's own documents, such as SDS and supplier certificates, and returns one cited document for review, with each step approved by the user.