Contents 6 sections
On 17 October 2023, the European Union banned microbeads. Many brands withdrew their scrubs and considered the matter closed. It is not: the same text covers, step by step, all synthetic polymer microparticles intentionally added to a product.
The next step concerns rinse-off products, on 17 October 2027. For a retailer or a brand, that is less than a year away, and a reformulation is not something to decide at the last minute.
What does the restriction actually cover?
Regulation (EU) 2023/2055, which created entry 78 of Annex XVII to REACH, does not speak of "microplastics" but of synthetic polymer microparticles. The distinction matters, because the definition goes far beyond what most people imagine.
A polymer is covered if it meets two conditions: it is solid, and it is present as particles. It can make up at least 1% of the weight of those particles, or form a continuous coating around them. In that second case, no minimum applies. An ingredient coated with a synthetic polymer therefore deserves a check, even if the ingredient itself is not a plastic.
- 0,01%
- threshold by weight in the finished product, for intentionally added particles
- 5mm
- all dimensions (or 15 mm long, if length is over 3 times the diameter)
- 2g/L
- minimum solubility to prove for a polymer to be excluded
Regulation (EU) 2023/2055, entry 78 of Annex XVII to REACH
Which polymers fall outside the restriction?
Five families are out of scope, provided this can be demonstrated:
- liquid polymers;
- natural polymers that are not chemically modified;
- degradable polymers, proven under Appendix 15;
- soluble polymers above 2 g/L, proven under Appendix 16;
- polymers with no carbon in their structure.
An INCI name is therefore not enough to decide. Two similar ingredients can be treated differently depending on their physical state, solubility or degradability, and it is up to the supplier to document this.
What is the timeline for your products?
The date depends on the type of product, not the size of the company. One exception applies in every case: a product containing microbeads has been banned since 2023, and a fragrance encapsulated in a synthetic polymer follows its own date.
The timeline, by product type
| Product | Ban on placing on the market | Note |
|---|---|---|
| Microbeads | 17 October 2023 | All products, no transition period |
| Rinse-off products | 17 October 2027 | Cleansing gels, shampoos, rinse-off masks |
| Encapsulated fragrances | 17 October 2029 | Also applies to rinse-off and make-up products |
| Leave-on products | 17 October 2029 | Creams, serums, sun care, excluding make-up |
| Make-up, lip and nail products | 17 October 2035 | "Contains microplastics" statement from 17 October 2031 |
Are leave-on products the real issue?
Rinse-off products come first, but a scientific review published in 2024 in the Journal of Hazardous Materials points out that leave-on products remain very little studied. Yet they are bought in larger volumes and often contain several ingredients of this type.
Two extra years are not two years of respite. It is better to audit creams and serums at the same time as rinse-off products, so you only reformulate once.
Does a derogation exempt you from everything?
No. Some film-forming polymers can fall under a derogation, because they stop being particles once applied: the Commission's guide mentions this case for cosmetic products. The restriction then does not apply, but other obligations take over: instructions for use and disposal, and annual reporting to ECHA before 31 May from 2027.
Conversely, incorporation into a solid matrix does not apply to cosmetics, as the guide notes they are meant to be removed and renewed.
Audit your range in five steps
- 01Classify each product
Rinse-off, leave-on, make-up: this classification sets your date.
- 02List the synthetic polymers
Go through each formula, including compound ingredients, coated pigments and encapsulated fragrances.
- 03Ask suppliers for proof
Physical state, particle form, solubility, degradability. A claim without proof is not enough.
- 04Calculate the threshold
For each polymer concerned, check its concentration in the finished product against the 0.01%.
- 05Prioritise reformulations
Start with rinse-off products. Allow for stability testing, packaging compatibility, the product file update and new labels.
Sources
- Commission Regulation (EU) 2023/2055, Official Journal of the European Union, 2023.
- Commission Explanatory Guide on entry 78, version 1.1, June 2025.
- Kukkola A., Chetwynd A.J., Krause S., Lynch I. Beyond microbeads: Examining the role of cosmetics in microplastic pollution and spotlighting unanswered questions. Journal of Hazardous Materials, 2024. DOI 10.1016/j.jhazmat.2024.135053
