EU Microplastics Restriction in Cosmetics: The October 2025 Deadline Has Passed — Are You Compliant?

The October 2025 deadline under Commission Regulation (EU) 2023/2055 came and went seven months ago. If you manufacture or supply rinse-off cosmetic products that relied on synthetic polymer particles for exfoliation or cleansing — polyethylene microbeads, polypropylene scrubbing particles, PMMA beads — those products should not have been on the EU market after 17 October 2025. Not re-labelled, not re-positioned. Off the shelves.

And yet our team continues to receive enquiries from European cosmetic brands that are either mid-reformulation or, in some cases, still unclear on whether their formulations actually fall within scope. The reach of the restriction (no pun intended) is wider than many brands expected when the regulation first appeared in the Official Journal nearly three years ago.

Here’s what you need to know — including the three deadlines still ahead of you.

What the Restriction Actually Covers (and What It Doesn’t)

Commission Regulation (EU) 2023/2055 amends REACH Annex XVII by adding Entry 78, which restricts the intentional addition of microplastics to substances, mixtures, and articles placed on the EU market. The working definition is precise: synthetic polymer particles smaller than 5 mm in at least one dimension, that are organic, water-insoluble, and resistant to degradation.

That last criterion — resistance to degradation — is doing a lot of heavy lifting. The regulation specifies that a polymer qualifies as non-degradable unless it meets strict abiotic and biotic degradation thresholds within defined test windows. The EU expects substantive mineralisation to CO₂ within a set timeframe; partial breakdown doesn’t count. Many suppliers have positioned their alternatives as “biodegradable” without meeting that specific test standard, which creates real REACH compliance risk for brands that rely on supplier declarations alone.

What’s excluded: natural polymers that haven’t been chemically modified, soluble polymers, and polymers classified as hazardous by EU GHS criteria (which face restrictions through other routes). Cellulose, starch, and chitosan-based particles sit outside scope, provided they’re genuinely unmodified. Silica-based exfoliants fall outside the definition entirely because they’re inorganic.

The practical upshot is that roughly 90% of the synthetic scrub beads used in conventional rinse-off cosmetics are in scope. If there’s doubt about a specific ingredient, ECHA published updated technical guidance in 2024 specifically to help formulators assess whether their materials meet the biodegradability exemption criteria. It is worth reading carefully — the test protocol requirements are more demanding than most raw material suppliers communicate upfront.

The Cosmetics-Specific Timeline: Four Deadlines, One Regulation

One reason brands underestimated this regulation is the structure of its transitional periods. There isn’t one deadline; there are four for cosmetic products alone, spread across 12 years.

17 October 2025 (passed): Prohibition on rinse-off cosmetics where the microplastic is added specifically for an exfoliating or cleansing function. Scrubs, bead-format face washes, body polishes. Any product manufactured after this date and placed on the EU market must not contain in-scope microplastics for that function.

17 October 2027: All other rinse-off personal care products. This covers rinse-off conditioners, cleansing milks, shower gels, and similar categories where microplastics serve functions other than exfoliation — film-forming agents, viscosity modifiers, opacifiers. Brands in this space have approximately 17 months to complete reformulation, secure new raw material approvals, and update their Cosmetic Product Safety Reports (CPSRs).

17 October 2029: Leave-on cosmetics, excluding lip products. Moisturisers, serums, foundations, sunscreens, and hair-care leave-on products fall here. The longer window reflects the greater technical challenge: microplastics in leave-on formats often serve structuring or sensory functions that are harder to replicate without affecting stability or consumer experience.

17 October 2035: Lip products. The 12-year transition recognises the particular difficulty of replicating texture, slip, and pigment-binding properties in lipsticks and glosses without affecting product safety or performance.

There is also a labelling obligation running parallel to these phase-outs. From 17 October 2027, any product still on-market under a transitional exemption must carry the statement “This product contains microplastics.” That labelling requirement may seem distant, but the documentation, label re-design, and supply-chain reassessment work needed to support it — or to reformulate past the need for it — takes considerably longer than most brands plan for.

Where REACH and Regulation 1223/2009 Overlap — and Why That Matters

European cosmetic brands operating under Regulation (EC) No 1223/2009 already have a framework for substance restrictions: Annex II (prohibited substances), Annex III (restricted substances with conditions of use), and the positive lists in Annexes IV through VI covering colorants, preservatives, and UV filters. Microplastics don’t sit neatly in any of those annexes — they’re handled via REACH — but the implications ripple directly into your 1223/2009 obligations.

Specifically, your Cosmetic Product Safety Report (CPSR) must document all substances in the formulation and address their safety profile. If your CPSR was written before 2023, it almost certainly doesn’t address the microplastics restriction or the compliance status of synthetic polymer excipients. Updating the CPSR to reflect reformulation is mandatory before you can continue marketing a reformulated product. That assessment must be signed off by a qualified Cosmetic Safety Assessor — and those assessors are currently facing a meaningful backlog across France, Germany, and the Benelux region.

The Responsible Person (RP) under Article 4 of Regulation 1223/2009 also bears the obligation to ensure the Product Information File (PIF) is current and reflects the compliant formulation. An RP who continues to carry a reformulated product without an updated PIF is exposed to enforcement action on two fronts simultaneously: REACH (via national market surveillance) and the Cosmetics Regulation (via CPSR and PIF compliance). This dual-framework exposure is something we see brands underestimate consistently. Fixing the formulation is necessary but not sufficient.

Enforcement in Practice: What Inspectors Are Actually Checking

France’s DGCCRF conducted targeted inspections of cosmetic and personal care products throughout 2024 and into early 2025, with microplastics compliance explicitly named in the agency’s published sector plan. Non-conforming products found during inspections were subject to withdrawal notices, and in several cases brands received formal mise en demeure letters requiring remediation within 30 days.

ECHA’s market surveillance coordination under the REACH enforcement project REF-10 — specifically focused on microplastics — found non-conformities in approximately 15% of sampled leave-on and rinse-off cosmetics during its 2024 pilot phase. That figure aligns with informal feedback from regulatory contacts across France and the Netherlands and suggests the compliance gap in the sector is real, not hypothetical.

The inspection checklist at this stage is fairly predictable. Inspectors look at: the formulation and INCI list against the restriction scope; supplier documentation confirming degradation-exemption claims where applicable; whether the CPSR and PIF have been updated post-reformulation; and, for products still within a transitional window, whether the labelling requirement is being correctly applied. That last point will attract sharper scrutiny as October 2027 approaches.

One thing worth knowing: enforcement is currently more active at the brand and retailer level than at the raw material supplier level. If your supplier is still providing a non-compliant ingredient, the brand — as the RP — bears first-line responsibility under both frameworks. Don’t wait for supplier non-compliance to surface during an inspection.

Reformulation Isn’t Enough — The Documentation Requirements Too Often Missed

Switching from polyethylene beads to walnut shell powder, jojoba wax beads, or pumice achieves the formulation goal. It doesn’t automatically close the compliance record. Three documentation steps that regularly get skipped:

First, obtain written confirmation from your ingredient supplier that the replacement substance is either out of scope of Entry 78 or meets the biodegradability criteria under the specific OECD test protocols referenced in the regulation. A generic “biodegradable” claim on a technical data sheet is not sufficient — ECHA’s guidance identifies the precise test methods required, and any supplier worth working with should be able to reference them specifically.

Second, commission an updated CPSR from a qualified safety assessor before placing the reformulated product on the market. Even when the new ingredient is demonstrably safer than the old one, you cannot assume the existing CPSR covers the reformulation. Safety assessors evaluate the complete formulation, including interactions, stability data, and challenge test results.

Third, update your CPNP (Cosmetic Products Notification Portal) notification. The CPNP entry must reflect the current formulation. An outdated CPNP notification sitting against a product already reformulated and on-market creates an administrative non-conformity that inspectors will flag independently of the REACH question — and it’s entirely avoidable.

None of these steps is technically demanding. But in the pressure of a reformulation project, they tend to be treated as post-launch tasks rather than pre-launch prerequisites. That sequencing mistake is exactly the kind of issue that produces a DGCCRF inspection notice three months after a product relaunches.

The brands navigating this well are the ones that treated documentation and reformulation as parallel workstreams starting in 2022. For everyone else, the practical question isn’t whether action is required — it is — but whether the 17 months before the October 2027 deadline is enough time to close the gap properly. In our experience, for brands with more than 5 to 10 SKUs in scope, it barely is.

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Written by Nour Abochama, Quality & Regulatory Advisor, Care Europe | VP Operations, Qalitex. Learn more about our team

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