Plastic beads in scrubs and glitter in make-up have become a symbol of avoidable pollution, and the EU has acted. If you formulate or sell cosmetics, the microplastics cosmetics ban in the EU will reach your range on a fixed timeline, with the first products already affected. This guide explains what is covered, what is not, and how to prepare in time.
Contents
- The short answer
- What counts as a microplastic?
- What is outside the scope?
- The timeline for cosmetics
- Where microplastics hide in formulas
- How to check your formulas
- Replacing microplastics without ruining the product
- What does this mean for your CPSR?
- Claims such as “microplastic-free”
- Common mistakes
- Frequently asked questions
- Key takeaways
The short answer
Commission Regulation (EU) 2023/2055 restricts synthetic polymer microparticles, known as microplastics, that are intentionally added to products. It began applying on 17 October 2023, with loose glitter among the first affected, and cosmetics follow in stages: rinse-off products from 17 October 2027, leave-on products from 17 October 2029 and make-up, lip and nail products from 17 October 2035, with a labelling requirement for the latter in the period before the ban. Natural, biodegradable and soluble materials are generally outside the definition, but you must be able to prove it for every ingredient.
What counts as a microplastic?
The regulation uses the term synthetic polymer microparticles. In broad terms, these are small solid particles made of synthetic polymers that are organic, insoluble and resistant to degradation, and that are below a size threshold (a few millimetres at most, with a separate criterion for fibres). The key idea is that the particle stays in the environment because it does not dissolve and does not break down. Polyethylene beads in an exfoliating scrub are a classic example.
The exact definition has technical conditions on size, solubility, degradation and the share of polymer in the particle, and they matter. Do not rely on a summary: read the definition in the regulation when you classify an ingredient.
Read also Nanomaterials Cosmetics Regulation: Rules and Notification
What is outside the scope?
Several material groups are not microplastics under the regulation:
- Natural polymers that have not been chemically modified, such as cellulose or starch in their natural form.
- Biodegradable polymers that meet the degradation criteria set out in the regulation.
- Water-soluble polymers that dissolve in water above a set level, such as many thickeners.
- Inorganic particles such as mica, silica, titanium dioxide or clay, which are not polymers. Mineral glitter alternatives built on mica are therefore not covered, although the coating must still be checked.
- Liquid and gel-like polymers that do not form solid particles of the defined kind.
Only non-biodegradable, insoluble plastic glitter is in scope, which explains why many brands are moving to biodegradable film or mineral effect pigments.
The timeline for cosmetics
- 17 October 2023: the restriction began to apply. Loose glitter and a number of other products were in the first group.
- 17 October 2027: end of the transition for rinse-off cosmetics, for example exfoliating shower gels, scrubs and shampoos that contain microplastics.
- 17 October 2029: end of the transition for leave-on cosmetics such as creams, lotions and sunscreens.
- 17 October 2035: end of the transition for make-up, lip products and nail products, which have the longest period. From 17 October 2031 until then, these products must carry a label stating that they contain microplastics.
Some uses, for example fragrance encapsulation, have their own conditions and timeline in the regulation. If you use microcapsules in a fragrance, check that specific provision, rather than assuming the cosmetic category dates apply.
Where microplastics hide in formulas
Few brands add plastic beads on purpose today, but synthetic polymers appear in many raw materials:
- Exfoliating scrubs: polyethylene or similar beads, now mostly replaced by sugar, salt, seed or shell powder.
- Powders and make-up: nylon, polymethyl methacrylate or other plastic powders used for texture and slip.
- Glitter and effect pigments: plastic film glitter, often cut into particles.
- Fragrance microcapsules: shells made of synthetic polymers that release scent on friction.
- Sunscreens and long-wear formulas: some film formers and encapsulated actives.
The ingredient list helps, but it will not tell you whether a polymer is insoluble and non-degradable. You need supplier data for each raw material.
Read also CMR Substances in Cosmetics Explained: What Is Banned
How to check your formulas
- List every polymer, copolymer and particulate ingredient in each formula, including those hidden in blends and fragrances.
- Ask suppliers for a written statement on whether the ingredient is a synthetic polymer microparticle under Regulation (EU) 2023/2055, with the data on size, solubility and biodegradability that supports it.
- Classify each ingredient: outside scope, in scope, or unclear.
- For those in scope, plan a replacement and note the date that applies to your product category.
- Record the outcome in the product file and in the safety assessment.
Replacing microplastics without ruining the product
A replacement changes how a product feels, performs and ages. Consider:
- Texture: mineral powders, silica or starch can replace the slip of plastic powders, but the sensory profile will differ.
- Stability: a new powder or film former may change viscosity, colour or separation. A stability test on the reformulated product, in its real packaging, reveals problems before customers do.
- Preservation: natural powders and plant particles can carry microorganisms and change water activity. Re-run a challenge test on water-based products after the change, and check quality with a microbiological specifications test.
- Skin feel and safety: abrasive particles in scrubs must be gentle. Rough shell powders can cause micro-damage, so the particle shape and size matter for the safety assessment.
What does this mean for your CPSR?
The CPSR needs an accurate formula. If you replace an ingredient, the assessor must review the new composition, the toxicological profile of the new material and exposure from the product, so the report has to be updated. An old CPSR does not cover a reformulated product. Raw material SDS documents and supplier statements about microplastics belong in the product information file, so that you can answer an authority quickly. Keep the dates of each supplier statement, since a declaration given in 2023 may not reflect a changed raw material.
Read also Margin of Safety (MoS) in Cosmetics: How It Is Calculated
Claims such as “microplastic-free”
A free-from claim must be true for the whole product, not only for the ingredients that come to mind. If you advertise “microplastic-free”, you should be able to show supplier declarations for polymers, fragrance capsules and glitter. After the bans take effect, the claim may also become meaningless for products that are legally required to be free of microplastics anyway, so consider it a short-term differentiator rather than a long-term one. Avoid suggesting that products without the claim are unsafe.
Common mistakes
- Assuming that only scrubs are affected, when polymer powders and capsules are in scope too.
- Waiting until 2027 or 2029 to ask suppliers, when reformulation and testing take months.
- Replacing an ingredient without a new stability or preservation test.
- Treating every “biodegradable” marketing term as proof, rather than checking the regulation criteria.
- Forgetting the rest of the range, including products sold only in some markets.
Frequently asked questions
When does the microplastics ban apply to my cosmetic?
It depends on the product category: rinse-off products from 17 October 2027, leave-on products from 17 October 2029 and make-up, lip and nail products from 17 October 2035, with some uses already restricted since 2023.
Is silicone a microplastic?
Liquid silicones, such as dimethicone oils, do not form solid particles of the defined kind, so they are generally outside the scope. Solid silicone particles may need a closer check against the definition.
Do natural exfoliants like sugar or walnut shell count?
No. They are natural and not synthetic polymers, so they are not microplastics, although they still need a safety assessment.
Key takeaways
- Regulation (EU) 2023/2055 restricts intentionally added synthetic polymer microparticles.
- Cosmetics have staged dates: rinse-off 2027, leave-on 2029, make-up, lip and nail 2035.
- Ask suppliers now for declarations, and map every polymer in your range.
- After replacing an ingredient, update stability, preservation and the CPSR.