Microplastics in EU Cosmetics: The REACH Restriction Timeline Most Brands Are Already Behind On

The October 2025 deadline for rinse-off cosmetics came and went quietly. For brands that reformulated early, it was just another milestone crossed off the compliance calendar. For those that didn’t — and we’ve seen more than a few in this position — it’s the moment Commission Regulation (EU) 2023/2055 stopped being a future concern and became a present liability.

Published in the Official Journal on 25 September 2023, this regulation amends Annex XVII of REACH with a new Entry 78: a phased restriction on intentionally added microplastics across virtually every product category that uses them. Cosmetics are among the most affected. The ECHA estimates personal care products account for approximately 35% of intentionally added microplastic releases to the EU environment — around 12,600 tonnes annually — making the sector one of the primary regulatory targets. Over a 20-year horizon, the restriction is projected to prevent approximately 500,000 tonnes of microplastic from reaching the environment.

If you formulate, manufacture, or import cosmetics for the EU market, this restriction demands your full attention. Not because all deadlines are still future events, but because the reformulation timelines in this sector are long, the definition contains subtleties that trip up even experienced formulators, and the labelling obligations during transition periods are already active and often overlooked.

What Commission Regulation (EU) 2023/2055 Actually Restricts

The restriction is deliberately broad. It applies to “microplastics” defined as synthetic polymer particles that meet four cumulative criteria: they are less than 5 mm in any dimension; they are solid; they are insoluble or only slowly soluble in water; and they are resistant to (bio)degradation. This definition is technology-neutral. It covers polyethylene and polypropylene microbeads, polylactic acid particles that don’t meet the degradation threshold, polyacrylate microspheres used as sensory enhancers, and metallic decorative glitter made from synthetic polymer films — all within scope.

Crucially, this is a REACH restriction, not a product-specific cosmetics rule. It applies to any substance, mixture, or article placed on the EU market that intentionally contains these particles. Cosmetics fall under this scope not as a carve-out, but as a mainstream application alongside detergents, agrochemicals, and construction materials. The distinction matters because it means the enforcement pathway runs through national REACH competent authorities — in France, that’s the ECHA liaison network coordinated through the DGPR — not exclusively through the DGCCRF’s cosmetics inspection unit.

The Phase-Out Timeline: Where Your Products Stand Right Now

Brands need to be precise here. The regulation establishes distinct phase-out dates by application type, and they do not move.

17 October 2023 (immediate): Restriction on loose powder glitter products and microbeads used for exfoliation in rinse-off products entered into force the day the regulation took effect. These uses were banned on day one. If any SKU in your portfolio still carries exfoliating polyethylene microbeads, it should not be on the EU market.

17 October 2025 (two years): All remaining rinse-off cosmetics — body washes, facial cleansers, shampoos, conditioners, toothpastes — containing intentionally added, non-exempt synthetic polymer particles became restricted. This deadline has passed. Products placed on the EU market after this date that still contain non-compliant microplastics are in violation of REACH Annex XVII, and liability rests with the entity placing the product on the market.

17 October 2027 (four years): Leave-on cosmetics. Moisturisers, serums, foundations, primers, lip products, BB creams — any cosmetic not intended to be washed off. Brands with microplastic-containing leave-on SKUs have approximately 16 months from the date of this post. That sounds like breathing room. It isn’t, given that a typical reformulation cycle in colour cosmetics — including formula development, stability testing at accelerated and real-time conditions, sensory panel evaluation, packaging compatibility, and PIF documentation — runs 12 to 24 months.

17 October 2029 (six years): Nail products and products relying on encapsulated fragrances where the capsule wall is a synthetic polymer. Fragrance microencapsulation is worth calling out specifically here. Many fine fragrance and functional fragrance technologies use polymer-walled microcapsules for longevity effects. These are explicitly within scope. Suppliers have been aware of this since 2023, but brands that license fragrance compounds should be verifying directly with their fragrance house that the encapsulation technology used in their specific formulas is either compliant, substituted, or carries a valid exemption dossier.

17 October 2035 (twelve years): The longest transition applies to a narrow set of applications where no technically feasible alternative is currently available, subject to ECHA review before 2031. Most cosmetic categories do not qualify for this extension.

The Definition Trap: What Counts — and What Doesn’t

The most common compliance error we encounter in practice is the assumption that if a material is “natural,” “bio-based,” or “plant-derived,” it is automatically outside the restriction. It is not. The exemptions are defined by functional and degradation characteristics, not by origin.

Three exemption pathways exist, and each requires substantiation.

Water solubility. If a synthetic polymer particle fully dissolves in water at concentrations relevant to use, it falls outside the definition of a solid particle. This covers many polyethylene glycols (PEGs), certain cellulose derivatives, and some carboxymethyl celluloses. But “water-soluble” under this regulation requires demonstrating dissolution at ≥2 g/L per the OECD 105 test method. If your technical dossier from the supplier doesn’t reference this specific threshold, don’t assume the exemption holds.

Degradability. Polymer particles that degrade by 90% or more to CO₂, water, and biomass within two years under relevant environmental conditions — freshwater, marine water, or soil, as appropriate to likely exposure routes — are exempt. Most bio-based plastics, including many commercial grades of polylactic acid (PLA) and polyhydroxyalkanoates (PHA), do not meet this standard without specific certification. A supplier claim that a material is “biodegradable” is not a regulatory exemption. The burden of proof under REACH falls on the party asserting the exemption, and that requires third-party test data.

Natural origin, unmodified. Polymers derived from natural sources and not chemically modified to alter their intrinsic properties are outside scope. Microcrystalline cellulose spheres, rice starch particles, and tapioca starch microspheres can qualify here — provided they are mechanically processed rather than chemically derivatised. Esterification, etherification, or crosslinking that changes the polymer’s properties can negate this exemption even if the starting material was natural.

For every ingredient in your formulation that contains or could contain polymer particles meeting the microplastic definition, you need a compliance dossier: the CAS number, the applicable exemption pathway, supporting test data referenced to the correct OECD method, and a written rationale. “We believe it dissolves in water” is not a dossier. In an inspection scenario, it wouldn’t withstand ten minutes of scrutiny.

The Labelling Obligation That Often Gets Overlooked

During each product category’s transition period, products that still contain restricted microplastics and are permitted to remain on the market carry an explicit labelling obligation. They must bear the statement: “This product contains microplastics.”

This requirement is quietly generating non-compliance across the industry, for two reasons. First, brands that reformulated before the deadline often don’t realise that existing stock placed on the market during the transition window needed relabelling even if the formula hadn’t yet changed. Second, distributors holding old stock of leave-on products placed before the October 2027 deadline will face the same obligation on that inventory.

The labelling must appear in all languages in which the product is marketed, consistent with the standard cosmetics labelling framework under Regulation (EC) No 1223/2009. This is not a voluntary sustainability declaration — it is a mandatory REACH compliance label, and its absence on applicable products constitutes a separate infringement from the microplastic presence itself.

What Your Reformulation Strategy Should Look Like

For leave-on cosmetics — the most commercially significant category for most brands, with a 2027 deadline — three substitution approaches are currently proving viable at scale.

Inorganic silica microspheres. Spherical silica particles replicate the skin-feel of polyethylene microspheres in soft-focus and blurring applications. They are inorganic and clearly outside the synthetic polymer scope. The trade-offs are density (they tend to settle more readily) and a slightly different tactile profile that requires texture adjustment. But several INCI-listed silica grades are performing well in stability and sensory trials across foundation and primer categories.

Natural starch and cellulose microspheres. Spherical particles from tapioca starch, rice starch, or microcrystalline cellulose have improved substantially in sensory profile over the last several years. If you pursue this route, confirm your supplier can provide the unmodified natural polymer documentation required for the Article 2 exemption — not just a “natural” claim on the TDS. The exemption dossier is your responsibility, not the supplier’s.

Reformulating around the functional effect. In soft-focus foundations and blurring primers, the microplastic particle was delivering a light-diffusion effect. Modern mica grades, boron nitride, and certain silicone elastomers can achieve comparable optical results without falling under the restriction. This is not a one-for-one ingredient substitution; it requires optical characterisation, comparative texture evaluation, and usually consumer testing to confirm parity. But for brands with 18-month lead times, this approach produces the most defensible long-term formula — one that isn’t contingent on supplier exemption claims.

One practical note that affects every reformulation: when you substitute any ingredient in an EU cosmetic product, the change must be reflected in an updated Product Information File (PIF). If the substituted ingredient affects the safety profile — and any change in particle type, particle size, or surface chemistry in a leave-on product warrants assessment — an updated Cosmetic Product Safety Report (CPSR) from your Responsible Person is required before the reformulated product is placed on the market. Don’t let the reformulation race ahead of the paperwork.

If you’re uncertain which SKUs in your portfolio are within scope of Entry 78, or need support mapping exemption claims against the regulatory definition, our team can work through a preliminary compliance screening with you.

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

Talk to our team about EU market entry and microplastics compliance screening. Contact us

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