Will the Microplastic Restriction affect my cosmetics?
Upcoming EU and UK Regulatory Changes for Ingredients: The EU Microplastic Restriction
What is the Microplastic Restriction?
Annex XVII of the REACH Regulation introduces restrictions on Synthetic Polymer Microparticles (SPM), commonly known as microplastics. The Regulation impacts a wide range of cosmetic products, including but not limited to exfoliants, cleansers, and certain types of makeup.
The REACH restriction officially entered into force on 17 October 2023, which is the date where the transition periods also started. With various deadlines under this transition period in the coming years for different product types, it is important to plan ahead and be aware of any ingredients in your formulas that may impact your future compliance, and the timelines involved.
The regulation defines SPM as:
Polymers that are solid and which fulfil both of the following conditions:
(a) are contained in particles and constitute at least 1 % by weight of those particles; or build a continuous surface coating on particles;
(b) at least 1 % by weight of the particles referred to in point (a) fulfil either of the following conditions:
(i) all dimensions of the particles are equal to or less than 5 mm;
(ii) the length of the particles is equal to or less than 15 mm and their length to diameter ratio is greater than 3.
How do I know if my product contains microplastics?
There isn’t a definitive list of ingredients that qualify as microplastics. Each ingredient on its own and as part of the finished product must be assessed for its properties to decide whether it meets the definition of a SPM and is in or out of scope of the restriction. Cosmetics Europe (CE) and European Federation for Cosmetic Ingredients (EFfCI) have developed a joint guidance and assessment template which contains a step-by-step approach to help determine whether an ingredient is an SPM.
What are the timelines?
Transition Periods and Off-Shelf Dates:
17 October 2027: Rinse-off cosmetic products.
17 October 2029: Encapsulation of fragrance and leave-on cosmetic products.
17 October 2035: Lip products, nail products, and makeup.
Labelling Requirements:
17 October 2025: Include instructions for use and disposal to minimise microplastic release into the environment.
17 October 2031 - 16 October 2035: Products like lipsticks, nail products, and makeup containing microplastics must be labelled:
“This product contains microplastics.”
What steps should you take now?
Identify microplastics in your portfolio: review your product formulations to determine if they contain microplastics.
Plan for deadlines: identify products affected by labelling or off-shelf requirements.
Strategic adjustments: prepare for formula revisions, derogations, and compliance strategies.
How we can help
We are here to support you in strategic decisions regarding your formula, derogations, labelling and reporting obligations to help you in achieving compliance with this new regulation.
Contact us today to learn how we can support your transition to compliance with the EU REACH microplastics restriction.
Stay tuned as we delve deeper into upcoming cosmetic ingredient regulatory changes in the EU and UK. Our next alert focuses on ingredient changes to EU Cosmetic Regulation and their upcoming deadlines.
Laila Manshi