EU Microplastics Restriction Under REACH: What Cosmetic Brands Must Do Before the 2027 Deadline

Most cosmetic brands got rid of polyethylene microbeads years ago — largely ahead of the wave of national bans that swept across Europe from 2017 onwards. France, the Netherlands, Sweden, and others each moved independently before an EU-wide measure existed. So when Commission Regulation (EU) 2023/2055 entered into force on 17 October 2023, amending REACH to restrict intentionally added microplastics, some manufacturers assumed the job was already done.

It wasn’t. Not even close.

The 2023 REACH restriction covers intentionally added microplastics far more broadly than those cosmetic scrub beads. It catches PET glitter particles in eyeshadow palettes and body shimmer products. It captures certain encapsulated fragrance systems used in leave-on products. It applies to synthetic polymer powders used as skin feel or mattifying agents in foundations and pressed powders. For most formulation teams, a serious compliance audit still needs to happen — and the 2027 deadline for rinse-off cosmetics is closer than it looks when you account for what reformulation actually takes.

ECHA estimates the restriction will prevent approximately 500,000 tonnes of microplastics from entering the environment over 20 years. Around 7,000 tonnes of that comes specifically from cosmetics and personal care. It’s a significant share — and the enforcement apparatus for REACH regulation compliance is not forgiving.

What Commission Regulation (EU) 2023/2055 Actually Restricts

REACH Annex XVII, Entry 78 (as inserted by Regulation (EU) 2023/2055) restricts the placing on the market of synthetic polymer microparticles — both as substances and in mixtures — where those particles meet two conditions: at least one dimension is ≤5mm (or for fibrous particles, length ≤15mm with an aspect ratio >3:1), and the polymer is not biodegradable within a reasonable timeframe under real-world environmental conditions.

That biodegradability criterion is important. The restriction targets synthetic persistence, not particle size alone. Cellulose microbeads derived from wood pulp are exempt; nylon-12 powder used as a skin feel agent is not. The distinction is scientifically grounded and practically significant for anyone building a reformulation roadmap.

A few explicit carve-outs are worth noting:

Natural polymers — cellulose, starch, chitosan, natural rubber — are excluded from the restriction’s scope. This was a deliberate choice reflecting their environmental behaviour and provides clear options for reformulation teams.

Polymers in solution (genuinely dissolved, forming no particulate fraction) fall outside scope. Dissolved polyacrylate thickeners, for example, are different from polyacrylate microspheres. But this distinction requires verification; some systems contain both dissolved and particulate fractions.

Demonstrably biodegradable synthetic polymers may qualify for exemption, but the burden of demonstration sits with the manufacturer or importer. Biodegradability must be assessed against OECD test methods — this is not a self-declaration exercise.

The regulation also creates an immediate labelling obligation. Products containing microplastics that remain on the market under the applicable transition periods must carry labelling stating the product “contains microplastics.” That obligation applied from 17 October 2023. It’s not a future deadline — it’s current, and non-compliance with it is enforceable today.

The Phase-Out Timelines That Belong in Your Compliance Calendar Right Now

The transition periods under Regulation (EU) 2023/2055 are staggered by product category. For cosmetics and personal care, the key dates are:

• Rinse-off cosmetics and personal care (shampoos, body washes, face scrubs, toothpaste, cleansing products): 4-year transition — compliance required from 17 October 2027.
• Leave-on cosmetics (moisturisers, serums, SPF creams, foundations): 4-year transition — also 17 October 2027.
• Lip and nail products: 6-year transition, meaning compliance from 17 October 2029.
• Make-up products other than lip and nail (pressed powders, blushers, eyeshadows): 6 years — 17 October 2029.
• Products where microplastics are used to encapsulate fragrances that release during use: 12-year transition, extending to October 2035 — though the labelling obligation still applies immediately.

Those deadlines can feel comfortable. They shouldn’t. A realistic reformulation cycle for a mid-complexity cosmetic product runs 12–24 months from concept to market-ready batch: ingredient qualification, formulation development, stability testing under ICH Q1A climatic conditions, challenge testing, sensory evaluation, regulatory documentation update, and for brands selling across markets, parallel safety assessments. Factor in supply chain lead times for new ingredients — particularly biodegradable alternatives that are still scaling — and 18 months is an optimistic minimum.

Brands treating October 2027 as the starting gun are already behind. Brands treating it as a finish line they have plenty of time to reach need to recalculate.

Identifying Microplastics in Your Formulations — It’s Not Just the Obvious Ones

The INCI naming system was not designed to signal regulatory status, and the scope of the microplastics restriction creates real audit challenges for formulation teams.

Glitter and reflective particles. PET (polyethylene terephthalate) glitter is ubiquitous in cosmetics — highlighters, lip glosses, body lotions, eye products. A product that removed PE scrub beads in 2019 and filed its safety assessment accordingly may still contain PET glitter subject to the 2023 restriction. These are different polymers, both in scope.

Microsphere and microcapsule delivery systems. Encapsulated actives — retinol, vitamin C, AHA complexes, perfumes — are frequently delivered in nylon, polyacrylate, or polymethylmethacrylate (PMMA) shells. The shell itself qualifies as a microplastic under Entry 78. The active payload typically doesn’t, but the delivery system does. Formulators who switched to encapsulated systems as a performance upgrade in recent years may have introduced a REACH compliance issue without realising it.

Film formers and powdered polymer processing aids. Some pressed-powder cosmetics use fine synthetic polymer particles as binders or bulking agents. Certain long-wear liquid lipstick formulas rely on film-forming polymer dispersions that contain particulate fractions. These require ingredient-level review.

A thorough audit means going beyond INCI lists to raw material supplier documentation. For each synthetic polymer ingredient in your formulation, you need explicit written confirmation from the supplier covering: whether the ingredient is supplied in particulate or dissolved form; the particle size distribution where applicable; and the supplier’s specific REACH compliance position with respect to Annex XVII Entry 78.

A REACH Certificate of Conformance (REACH CoC) from a supplier covers many REACH obligations but may not explicitly address Entry 78. Ask directly. If the supplier can’t or won’t answer clearly, that’s a supply chain risk that needs addressing now, not in 2026.

Reformulation Options: What’s Working in Practice

The alternative ingredient market has matured considerably since the first-generation microbead bans. For formulators working on compliant reformulations:

Physical exfoliants: Walnut shell powder, bamboo powder, rice bran, apricot kernel powder, sugar, and salt all perform well in rinse-off applications. Cellulose microbeads (wood pulp-derived) are biodegradable, comply with OECD test criteria, and have published in-vitro efficacy data comparable to PE microbeads at equivalent particle sizes. Jojoba wax beads are a higher-cost premium option with strong skin feel data and a well-established regulatory history.

Glitter and shimmer: Cellulose-based biodegradable glitters — most visibly the Bioglitter range, which holds independently verified biodegradability data under OECD 301B and 308 — are the most commercially proven PET alternative for high-sparkle applications. Cost differential runs approximately 3–5× per gram at scale compared to PET glitter, but mainstream retail buyers are increasingly specifying biodegradable alternatives. Natural mica serves many shimmer needs but doesn’t replicate the optical character of fine glitter particles.

Film formers: This remains the hardest category. Several ingredient suppliers are developing bio-based or biodegradable polymer alternatives to conventional PVP, acrylates copolymers, and polyurethane dispersions. Long-wear performance validation continues to be the sticking point — the durability characteristics that make synthetic film formers valuable are also a function of their non-biodegradability. Expect this area to require multiple formulation iterations and longer development timelines than exfoliant replacements.

For brands managing large portfolios, a tiered approach is practical: prioritise rinse-off products first (shortest deadline, often simplest reformulations), run stability and performance testing in parallel across the shortlisted alternatives, and maintain an 18-month buffer before October 2027 to absorb reformulation failures without a compliance gap.

What a Robust REACH Regulation Compliance Programme Looks Like in 2026

REACH regulation compliance for cosmetics manufacturers has expanded significantly in scope over the past three years. The microplastics restriction under Entry 78 sits alongside ongoing SVHC candidate list obligations, substance authorisation requirements, and restrictions under other Annex XVII entries — all of which interact with the cosmetic safety assessment under Regulation 1223/2009.

A programme that addresses microplastics specifically should cover five things:

1. Supplier-level documentation review for all synthetic polymer ingredients — explicit written confirmation covering Entry 78 scope, not just a general REACH CoC.
2. Formulation-level mapping of every synthetic polymer component, distinguishing particulate from dissolved forms and flagging encapsulated systems for case-by-case assessment.
3. Updated Product Information Files under Regulation 1223/2009, documenting the Entry 78 assessment for each SKU alongside the existing safety assessment content.
4. Immediate labelling compliance for any products still containing permitted microplastics under transition derogations — this applies today, not in 2027.
5. A reformulation roadmap with hard testing milestones, aligned to the applicable phase-out deadline for each product category, with buffer time built in.

If your products also export to North America, a parallel check adds value. Health Canada’s Cosmetic Ingredient Hotlist already restricts microplastics in rinse-off cosmetics, covering polyethylene, polypropylene, polyethylene terephthalate, polymethyl methacrylate, and nylon-6 and nylon-12, among others. The scope differs from the REACH restriction in specifics — a EU-facing audit doesn’t automatically cover the Canadian market position, and vice versa. For brands entering both markets simultaneously, testing and compliance documentation need to address both frameworks in parallel.

Our team works with European cosmetics manufacturers at exactly this intersection — coordinating formulation audits, reviewing supplier documentation against REACH Annex XVII requirements, and where brands are pursuing simultaneous US or Canadian market entry, connecting with our ISO 17025-accredited partner labs in North America for the analytical testing that underpins those filings. The brands that navigate this most efficiently are the ones that treat reformulation and regulatory compliance as a single workstream — not sequential tasks.

The 2027 deadline is real. So is the 2029 deadline, and the labelling obligation that already applies. The question isn’t whether to act — it’s how far ahead you’re willing to start.

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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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Related from our network

• Cosmetic raw material and finished product testing under ISO 17025 — Qalitex Laboratories provides US-based analytical testing for European cosmetics brands, including polymer identification and ingredient verification for REACH compliance documentation.
• Health Canada Cosmetic Ingredient Hotlist compliance testing for the Canadian market — Androxa offers Health Canada-aligned testing services to verify reformulated products meet Canadian microplastics restrictions alongside EU REACH requirements.