Cosmetic chemists now face a simple reality: the EU’s microplastics restriction is changing how teams design exfoliants, encapsulation systems, decorative effects, and polymer-based sensorials. Because enforcement rolls forward in phases after the restriction entered into force on 17 October 2023, you need a workflow that is both technical and auditable, not just “remove beads.” This guide consolidates the decision tree, category switches, documentation rules, and an execution timeline into one lab-ready playbook.
Regulatory snapshot: what the EU actually restricted
Commission Regulation (EU) 2023/2055 added a restriction in REACH Annex XVII (Entry 78) that targets synthetic polymer microparticles—often referred to as “microplastics”—either on their own or intentionally added to mixtures. In cosmetics, the practical impact is that solid, persistent polymer particles used for function (feel, visual effect, delivery, performance) now require a documented classification and, when in-scope, a phase-out plan aligned to category timelines.
- Core idea: “Evidence or exclude.” If you cannot prove an exclusion (soluble, non-particle at use, biodegrades under accepted conditions, or a qualifying derogation), treat the ingredient as in-scope and manage it as a compliance risk.
- Important nuance: Not every polymer is a microplastic. The trigger is solid microparticles that are synthetic and persistent at the moment of use or release.
Operational definition: how to decide if a raw material is a “microplastics” risk
Use this operational definition to classify each ingredient the way an auditor will: does the ingredient introduce solid polymer particles into the finished product at the point of application or release (rinsing, wear, removal)? If yes, the next question becomes whether those particles are synthetic and non-biodegradable under recognized methods, and whether an exclusion or derogation is supported by data.
Likely in scope (high probability)
- Loose plastic glitter (e.g., PET/PMMA flakes) used for immediate decorative effect
- Solid polymer beads/spheres used for scrub feel, “blurring,” or sensory slip
- Polymer microcapsules (fragrance/actives) built on persistent crosslinked shells
- Solid polymer powders that remain particulate (mattifiers, tactile modifiers)
Often out of scope (only with proof)
- Systems that fully dissolve in use under defined, evidenced conditions
- Particles that demonstrably biodegrade per recognized OECD-type tests (with full reports)
- Materials permanently bound in a cured inert matrix where release is not expected (with a defensible fate narrative)
- Natural polymers meeting exemption criteria (with clear identity + modification status)
Practical rule: build a one-page evidence sheet per ingredient: identity, polymer nature, physical state at use, fate narrative, particle size statement, and biodegradation/solubility proof where relevant. That single page prevents weeks of back-and-forth later.
The decision tree (run this on every polymer-linked raw material)
- At-use state: During application/removal/rinse-off, does this ingredient create or introduce solid polymer particles in the product?
- Synthetic check: Is the polymer synthetic (or a synthetic derivative that qualifies as such under classification expectations)?
- Particle reality: Are there particles present (or formed) in sizes consistent with microplastic concepts (solid fragments/particles, not a fully dissolved polymer)?
- Persistence check: Do you have credible evidence the particles are biodegradable in relevant conditions, or that they dissolve fully in realistic use?
- Binding/fate: Are particles permanently bound in a matrix in a way that prevents release during intended use, removal, or disposal?
- Decision + dossier: If you cannot support an exclusion with data, classify as in-scope risk, trigger substitution, and record the decision with version control.
That flow is short on purpose. The difficulty is not the logic—it’s the documentation. Therefore, treat missing data as a project blocker and assign an owner.
Category playbook: real switches by product type
1) Scrubs and exfoliating cleansers
Microbeads are the obvious starting point. Yet the bigger risk is that older “legacy” bead suppliers still appear in BOMs, prototypes, or regional variants. Replace them decisively, then tune feel so the product stays on-brief.
- Switch options: cellulose spheres, silica, calcium carbonate, perlite, jojoba ester beads (non-plastic), bamboo or olive-derived abrasives
- Lab checks that matter: abrasion profile, particle hardness, suspension stability, rinse clarity, residue on wet skin, drain safety narrative
2) Glitter and decorative flakes
Conventional plastic glitter is a direct compliance risk, especially when “loose glitter” is in scope. Move to certified alternatives or mineral sparkle systems and test the optical outcome under multiple lighting conditions.
- Switch options: cellulose-based biodegradable glitter (with certification + reports), mica-based sparkle systems, mineral platelets, effect pigments that do not rely on persistent plastic cores
- Lab checks that matter: luster under daylight and LED, fallout, migration, binder compatibility, stability in anhydrous and emulsion systems
3) Encapsulation systems for fragrance and actives
Encapsulation is not “dead.” However, legacy crosslinked shells may be difficult to defend if they persist as particles. Instead, shift to carriers with a clearer fate narrative and stronger biodegradation or dissolution logic.
- Switch options: lipid-based carriers (e.g., SLN/NLC-style systems), polysaccharide shells (starch/cellulose/alginate architectures), hydrolysable polyester systems where relevant evidence supports biodegradation
- Lab checks that matter: release in shear and humidity, storage stability, clarity (for clear bases), headspace/odor release for fragrance, HPLC/assay for actives
4) Long-wear film and tactile performance (mascara, foundation, lip, brow)
Some “blurring” and tactile powders are polymeric particles that may be in scope. When you remove them, you often see drag, poorer payoff, or reduced transfer resistance. Rebuild the sensorial system rather than swapping one ingredient and hoping.
- Switch options: mineral soft-focus systems, cellulose/starch tactile modifiers, biodegradable film networks where evidence supports a defensible status, wax-ladder tuning to recover wear
- Lab checks that matter: rub-off, transfer, water resistance (where relevant), curl/hold (mascara), humidity challenge, pilling risk, removal behavior
Comparison matrix: restricted risk vs safer design paths
| Use case | Common risk drivers (examples) | Preferred replacement families | What to validate |
|---|---|---|---|
| Scrub feel | Polyethylene or other persistent polymer beads | Cellulose spheres, silica, calcium carbonate, jojoba ester beads | Abrasion, rinse clarity, residue, suspension stability |
| Glitter sparkle | PET/PMMA plastic glitter flakes | Certified biodegradable cellulose glitter, mica/mineral sparkle systems | Luster, fallout, migration, binder compatibility |
| Capsule delivery | Persistent crosslinked polymer shells | Lipid carriers (SLN/NLC-type), starch/cellulose/alginate shells, hydrolysable systems with proof | Release, stability, clarity, assay, sensory equivalence |
| Soft-focus blur | PMMA/crosspolymer tactile powders (particle form) | Mineral blends, starch/cellulose tactile modifiers | Slip, blur optics, drag, wear, removal |
Timeline and execution plan: turn compliance into a rolling program
The restriction entered into force on 17 October 2023, with different measures and transition periods by product/application. Therefore, treat conversion as a rolling program with defined gates instead of a single “deadline panic.” Use the program structure below to keep R&D, Regulatory, Packaging, and Supply Chain aligned.
| Window | What the lab does | What Regulatory logs |
|---|---|---|
| Now → Q1 2026 | Audit polymer-linked materials; run the decision tree; request supplier dossiers; flag high-risk categories (glitter, beads, capsules) | Create ingredient one-pagers; open change controls; capture evidence status and gaps |
| Q2 2026 → Q4 2026 | Prototype substitutions; build test ladders for sensorial and performance equivalence; run stability on alternates | Attach test reports; align claims language; update product files and internal specs |
| 2027+ | Sequence conversions by risk and volume; lock high-volume rinse-off and high-release categories first; refine long-wear conversions early | Freeze dossiers for affected SKUs; maintain version control; archive evidence for audits |
Sequencing principle: start with high-release rinse-off and loose decorative systems first, then move to complex long-wear systems that need longer iteration loops.
Supplier workflow: what to request, how to stop delays
Most teams lose time because supplier answers are vague. Instead, request structured information that maps directly onto the decision tree.
- Particle status statement: “Does this ingredient introduce solid synthetic polymer particles at use?” (yes/no, with explanation)
- Fate narrative: “Dissolves, binds, degrades, or persists”—with the conditions defined
- Biodegradation proof: full report, method name/number, conditions, pass criteria, and results
- Particle size data: PSD where relevant, plus whether particles remain intact during use
- Management of change: written commitment to notify you of changes that affect particle status or degradation behavior
To stay audit-ready, store supplier files by SKU and mirror the key evidence into a single “Master Microplastics” dossier folder with dated versions.
Testing and evidence: what auditors and reviewers actually respect
Compliance decisions need defensible data. Consequently, collect evidence that is replicable and tied to realistic use.
- Biodegradation screening: OECD-style biodegradation reports (store full PDFs, not just certificates)
- Dissolution proof: dissolution profiles under realistic use conditions (time, temperature, product matrix)
- Material characterization: identity confirmation, polymer type, and particle form statements (plus PSD when relevant)
- Performance equivalence: side-by-side wear, rinse, and sensorial comparisons with photos and instrumentation where available
When “biodegradable” is used, keep the claim tied to the method and conditions. Do not rely on generic sustainability language, because enforcement pressure is moving toward proof rather than marketing tone.
Records and claims: keep your wording defensible
Claims should reflect evidence, not aspiration. Prefer wording that maps cleanly to supplier declarations and your dossiers.
- Preferred: “Formulated without intentionally added microplastics.”
- Preferred: “Designed for compliance with EU microplastics restriction (REACH Annex XVII, Entry 78).”
- Use carefully: “Biodegradable” (only with method + conditions supported in your files)
- Avoid: “Plastic-free,” “ocean-safe,” “100% eco-friendly,” or absolute environmental claims without substantiation
Also, keep batch-level notes: formula version, packaging version, first compliant batch date, and change-control IDs. That log becomes your fastest defense during questions.
Portfolio risk register: make decisions visible to leadership
| SKU | Category | Risk driver | Status | Next gate | Owner |
|---|---|---|---|---|---|
| DL-421 | Rinse-off scrub | Legacy bead supplier | Alt validated | Pilot run | Formulation |
| MX-210 | Mascara | Tactile powder classification | In testing | Wear panel | Claims/QA |
| FX-118 | Glitter eye | Plastic flakes | Design lock | Press proof | Packaging |
| FR-302 | Body lotion | Fragrance capsule | Alt shortlisted | Stability T30 | Regulatory |
Review this weekly. When a supplier stalls, escalate early. When testing fails, pivot fast. The goal is not perfection—it’s a controlled, documented conversion that prevents a last-minute scramble.
Research References
- https://echa.europa.eu/hot-topics/microplastics
- https://single-market-economy.ec.europa.eu/sectors/chemicals/reach/restrictions/commission-regulation-eu-20232055-restriction-microplastics-intentionally-added-products_en
- https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX%3A32023R2055
- https://trade.ec.europa.eu/access-to-markets/en/news/restriction-microplastics-eu-17-october-2023
- https://www.ul.com/news/reach-restriction-synthetic-polymer-microparticles
