The European Union’s microplastics restriction, introduced under Commission Regulation (EU) 2023/2055, is reshaping how cosmetic chemists develop exfoliants, encapsulates, and decorative products. The rule entered into force in October 2023 and will roll out through multiple transition periods ending in 2035. Because the restriction targets intentionally added synthetic polymer particles that resist degradation, many once-standard ingredients — including polymer microbeads, glitter, and encapsulation systems — now fall under regulatory scrutiny. As a result, formulators must reassess raw materials, verify polymer classifications, and adopt fully biodegradable alternatives. This blended overview explains the regulation, its definitions, the categories most affected, and the technologies chemists are adopting to stay compliant.
Scientific Background and Regulatory Scope
The EU defines microplastics as “synthetic polymer particles smaller than five millimetres that are organic, insoluble, and resistant to degradation.” This language captures many functional solids used in modern cosmetic systems. These include exfoliating beads, decorative glitters, solid texturizers, sensory powders, and encapsulated actives built on polymer shells. The rule does not ban all polymers. It applies specifically to solid, non-biodegradable particles intentionally added to perform a function. Soluble polymers are generally excluded if the supplier demonstrates proper solubility. Natural polymers are also excluded when they remain unmodified or meet biodegradation criteria. The burden of proof, however, sits with suppliers and brands, who must present OECD test results and technical documentation during compliance checks.
Transition Periods and Category Timelines
The regulation uses staggered implementation deadlines to help industries phase out microplastics without disrupting supply chains. Rinse-off products receive the earliest deadline because they contribute directly to environmental release. Leave-on items gain more time due to lower emission potential. Decorative cosmetics receive the longest timeline because they rely heavily on polymeric structures and effect pigments.
The key transition points include:
- 2023: Entry into force; immediate restrictions on microbeads used for exfoliation or polishing in rinse-off cosmetics.
- 2027: Ban on microplastics in all rinse-off cosmetic products, including scrubs, cleansers, and exfoliating gels.
- 2029: Restrictions on encapsulated fragrance systems and several leave-on cosmetic formats.
- 2035: Final deadline for makeup, lip, and nail products containing non-biodegradable synthetic polymer microparticles.
These timelines may appear generous, but suppliers need years to redesign polymers, validate biodegradability, and build safety dossiers. Early planning remains essential for uninterrupted market access.
Industry Confusion and Material Classification Challenges
The regulation created initial uncertainty across R&D teams. Many chemists were unsure whether their microspheres, polymer powders, or encapsulated systems were in scope. Some solid polymers behave as film formers, while others act as fillers, blurring the boundary between particulate and dissolved forms. To navigate this, brands must classify every solid polymer using four questions:
- Is the polymer synthetic?
- Is it solid under normal conditions?
- Is any particle smaller than 5 mm?
- Can it be proven biodegradable under OECD protocols?
If the answer to the last question is “no,” the ingredient likely qualifies as a microplastic. Clear documentation — including biodegradability tests, characterization data, and supplier confirmations — is essential for regulatory accuracy and for updating each product’s PIF (Product Information File).
Encapsulation Technologies Under Scrutiny
Encapsulation systems are among the most impacted categories. Historically, many fragrance capsules and active carriers used cross-linked acrylates or polyethylene-based shells. These materials resist degradation and fit the microplastic definition. As a result, polymeric capsules must be replaced by biodegradable systems. Fortunately, next-generation alternatives already exist. Lipid-based carriers such as Solid Lipid Nanoparticles (SLN) and Nanostructured Lipid Carriers (NLC) offer strong stability, controlled release, and excellent skin compatibility. Polycaprolactone (PCL) microspheres degrade through hydrolysis and mimic traditional polymer beads. Additionally, encapsulation systems made from starch, cellulose, or naturally derived polyesters can match the performance of older materials without persistence in the environment. Encapsulation remains viable, but its chemistry must evolve.
Replacing Microbeads and Sensory Powders
The ban on polyethylene microbeads accelerated interest in natural exfoliants and biodegradable particles. Today’s scrubs often rely on bamboo powder, walnut shell, perlite, jojoba esters, and mineral silica. Starch-based particles dissolve during rinsing and leave no residue. These materials provide controlled abrasion and sensory refinement while remaining fully compliant. Sensory powders face similar scrutiny. Many blur powders and soft-focus agents use cross-linked acrylates or polymethyl methacrylate (PMMA). Chemists now turn to cellulose microfibers, starch esters, and mineral blends to deliver mattifying and texturizing effects. These alternatives offer comparable performance without generating persistent particles.
Impact on Decorative Cosmetics and Glitters
Makeup presents some of the most complex reformulation challenges. Decorative products rely heavily on polymeric structures to create long-wear effects, suspension stability, and luminous finishes. Traditional glitters made from PET or PMMA fall directly under the definition of microplastics and must be replaced. Biodegradable glitter technologies using regenerated cellulose or mica-based substrates now offer similar sparkle with better environmental profiles. Film-forming systems also require attention. Suppliers now offer biodegradable film formers that maintain wear time without relying on insoluble synthetic particles. Because decorative cosmetics have long transition periods, development can proceed strategically, but suppliers should not delay experimentation.
Formulator’s Guide: How to Audit and Replace Restricted Materials
Chemists should review each formula component carefully, especially when the ingredient list identifies beads, powders, or solid polymers. Common red flags include polyethylene, nylon-12, PMMA, polyacrylate crosspolymers, and solid acrylate beads. If a material is insoluble, solid, and synthetic, it requires further classification. Suppliers should provide:
- OECD biodegradability reports;
- Particle size distribution data;
- Solubility and dissolution profiles;
- Statements of compliance with Regulation (EU) 2023/2055.
Once classified, the formulation team can evaluate replacements. Biodegradable alternatives include lipid carriers for encapsulation, cellulose or starch powders for texturizing, and natural mineral scrubs for rinse-off applications. These categories continue to expand as suppliers innovate to meet the demand for compliant performance systems.
Testing, Certification, and Documentation
To qualify for exemption, polymers must demonstrate biodegradability in standardized tests such as OECD 301. These protocols require at least 60% degradation within 28 days. Suppliers must supply complete test reports, and formulators must store them in the PIF. Because the EU Cosmetics Regulation (EC) No. 1223/2009 already mandates robust documentation, integrating microplastic compliance into the existing dossier structure creates a seamless regulatory pathway. Thorough documentation prevents enforcement issues during inspections and strengthens a brand’s scientific credibility.
Claim Language: What Brands Can and Cannot Say
Marketing claims must remain accurate and verifiable. Acceptable language includes “formulated without intentionally added microplastics,” “contains biodegradable encapsulation system,” or “complies with EU Regulation 2023/2055.” Broad environmental terms such as “plastic-free,” “ocean-safe,” or “eco-friendly” must be substantiated or avoided. Claims must match supplier documentation. For example, a biodegradable encapsulation system must pass OECD biodegradation tests; otherwise, the claim is misleading. Aligning marketing teams with regulatory teams prevents inconsistencies between packaging and PIF documentation.
Recordkeeping and PIF Integration
The microplastics restriction integrates tightly with EU Cosmetics Regulation 1223/2009. Brands must update their product information files with polymer classification data, biodegradability evidence, particle size characterizations, and supplier declarations. Because authorities may request documentation at any time, complete records protect both the brand and the responsible person.
Key Takeaways for Cosmetic Chemists
The EU microplastics ban is not simply a ban on beads. It reshapes how solid polymer systems are used in cosmetics. To stay compliant, chemists should:
- Audit all polymer ingredients for microplastic classification.
- Request biodegradability proof or supplier declarations.
- Replace solid synthetic particles with lipid, cellulose, or starch-based alternatives.
- Update the PIF with complete analytical and regulatory documentation.
- Use accurate, verifiable claim language supported by supplier data.
Ultimately, the restriction pushes the industry toward more sustainable and transparent innovation. Chemists who adopt biodegradable encapsulation and microbead-free exfoliation technologies early will gain a regulatory and commercial advantage.
