EU Microplastics Restriction in Cosmetics (Regulation 2023/2055): Deadlines, Definitions and Which Ingredients Apply

• Regulation (EU) 2023/2055 bans intentionally added microplastics in cosmetics via REACH (Annex XVII, entry 78) — not the Cosmetics Regulation 1223/2009. That distinction changes who enforces compliance and how it must be documented.
• The ban is phased: microbeads fell on 17 October 2023; other rinse-off cosmetics follow in 2027; leave-on in 2029; make-up, lip and nail products in 2035, with mandatory labelling from 2031.
• Not every polymer INCI is a banned microplastic: the restriction activates four simultaneous criteria (solid, synthetic, within size thresholds, insoluble + non-biodegradable). Knowing the precise definition is the difference between a false positive and a real violation.
• The polymers most commonly affected in cosmetic formulation: Polyethylene, Nylon-12, Acrylates Copolymer, PMMA (Polymethyl Methacrylate) — each with important nuances.

1. What are microplastics in a cosmetic context?

Under Regulation (EU) 2023/2055, the technical category is called synthetic polymer microparticles (SPM). The definition is precise: it does not cover "small plastics" in general but particles that simultaneously satisfy four structural, size, concentration and environmental conditions.

First criterion — solid form: the polymer must be present as a solid particle, either constituting at least 1% by weight of the particle or forming a continuous surface coating on the particle. This criterion immediately excludes polymers that are fully dissolved in the formulation.

Second criterion — size: at least 1% by weight of the particle distribution must meet one of two size conditions: (a) all dimensions ≤ 5 mm, or (b) length ≤ 15 mm with a length-to-diameter ratio above 3. The lower enforcement bound is 0.1 µm (100 nm) for the 5 mm class, or 0.3 µm length for the 15 mm fibre class.

Third criterion — concentration: the restriction activates only when SPM are present at a concentration equal to or greater than 0.01% by weight of the product and their presence confers a sought-after characteristic — meaning they perform a technical function in the formula.

Fourth criterion — environmental behaviour: the polymer must be insoluble (solubility below 2 g/L, per Appendix 16 of the regulation) and non-biodegradable (per Appendix 15). Polymers that pass the biodegradability or solubility tests are exempt — details in the exemptions section below.

The technical definition exists to avoid banning polymers that formulation already handles safely. The regulatory objective is aquatic ecosystem contamination: microplastics that pass through wastewater treatment systems without degrading are the ones accumulating in rivers, soils and living organisms. That is why biodegradability and solubility criteria are central, not ancillary.

In cosmetic formulation, intentionally-added microplastics with real technical function fall into four main types: abrasive microbeads (mechanical exfoliation), texture and shine-control particles (sebum-regulating or matifying effect), film-forming particles (coverage effect), and light-diffusing particles. Each type has a different ban date, corresponding to its risk of release to the aquatic environment.

2. What does Regulation (EU) 2023/2055 restrict?

Regulation (EU) 2023/2055 was published in the Official Journal of the European Union (Series L, No 238) on 27 September 2023 and entered into force on 17 October 2023. Its text amends the REACH Regulation (EC) No 1907/2006 by adding a new restriction — entry 78 — to Annex XVII of that regulation. It is therefore a REACH restriction, not an amendment to the Cosmetics Regulation (EC) No 1223/2009.

This distinction has three practical regulatory consequences:

1. The enforcement authority is different. Compliance with the Cosmetics Regulation is supervised by each Member State's cosmetics competent authority. Compliance with REACH is supervised by the REACH competent authority — a separate body in most Member States. The same product can have two different regulatory interlocutors for the same substance, depending on which rule applies.

2. The supporting documentation is different. For the Cosmetics Regulation, safety evidence goes into the Product Information File (PIF/CPNP). For REACH, compliance justification may require an updated Safety Data Sheet (SDS) and, in some cases, documentation of the applicable exemption appendix.

3. The scope of application is broader. The REACH restriction does not apply only to cosmetics: it covers any substance, mixture or article containing SPM under the described conditions — detergents, lubricants, paints, agricultural products, medical devices. Ingredient suppliers who serve multiple sectors need a single compliance evaluation against one regulation.

The prohibition itself is: no substance, mixture or article that contains SPM under Annex XVII entry 78 conditions may be placed on the market (made available, including import) unless an exemption applies.

3. Application timeline

The regulation sets different transition periods by cosmetic product category, because the risk of release into the aquatic environment varies: a rinse-off product releases directly into the wastewater system; a leave-on cosmetic has a different and less direct exposure route.

One drafting detail worth knowing: the REACH text phrases the deadlines as "may continue to be placed on the market until 16 October YYYY inclusive", which is equivalent to saying the ban applies from 17 October of the same year. Both formulations carry identical legal effect.

The "make-up, lip and nail" category has the longest transition precisely because it includes products with high loadings of functional polymers that are technically difficult to substitute in the short term — lipsticks, foundation, mascaras, nail polishes, highlighters, compact eyeshadow. The legislator acknowledged that reformulation requires more time when equivalent technical solutions are not yet readily available.

4. Exemptions

Regulation 2023/2055 establishes structural exemptions for polymer categories that, by their nature or behaviour, do not generate the environmental risk the restriction was designed to address:

Natural polymers. Polymers that originate in nature and have not been chemically modified are exempt. A polymer is "naturally occurring and not chemically modified" if its manufacturing process involved only physical, biological or microbiological steps. Examples: micronised cellulose of plant origin, unmodified starch, naturally-derived chitin.

Biodegradable polymers. Polymers that pass the biodegradability criteria in Appendix 15 of the regulation are exempt. These criteria are demanding: they assess mineralisation (conversion to CO₂, water and biomass) under aquatic and sedimentary conditions — not merely physical disintegration. A polymer that fragments into smaller pieces without mineralising does not meet the criterion.

Soluble polymers. Polymers with a water solubility above 2 g/L, assessed per Appendix 16, are exempt. This covers polymers that dissolve under conditions of product use or wastewater treatment, eliminating environmental persistence.

Polymers with no carbon atoms. Inorganic polymers — silicates, inorganic silicones, certain polyphosphates — fall outside the definition because the restriction applies only to organic polymers (carbon-backbone chain).

Inorganic materials. Glass, metal, minerals: out of scope.

An important technical point: the biodegradability or solubility exemption requires supporting documentation. A supplier declaration that a polymer is biodegradable is not sufficient — the evaluation must follow the Appendix protocol and must be available to the competent authority.

Regarding glitter: glitter made from non-biodegradable, insoluble plastic polymer (typically PET or PVC) is not inherently exempt. However, the regulation distinguishes by use:

• Loose plastic glitter for non-cosmetic uses (crafts, toys, decoration) was banned from October 2023 under the general REACH restrictions.
• Plastic glitter used as a cosmetic ingredient or present in a cosmetic follows cosmetic transition deadlines (rinse-off: 2027; leave-on: 2029; make-up/lip/nail: 2035).
• Glitter permanently embedded in a solid matrix (paints, objects, decorative articles) falls outside the restriction's scope.
• Biodegradable, soluble or naturally-derived glitter is exempt in any use.

5. How to check whether an ingredient is a microplastic

A polymer INCI is not automatically a microplastic under Regulation 2023/2055. Verification requires evaluating four criteria in sequence:

Step 1 — Is it solid under formulation conditions? If the polymer is fully dissolved in the formulation (no separate solid phase), it is not a particle — the restriction does not apply. This is relevant for film-forming polymers that are applied as a solution and form a film only on drying.

Step 2 — Does it meet the size criterion? At least 1% by weight of the particle size distribution must fall within the range of 0.1 µm to 5 mm (or 0.3 µm to 15 mm for fibres). Most functional cosmetic polymers are in the micrometre range, which is the most relevant range.

Step 3 — Is it insoluble? Solubility < 2 g/L in water. Water-soluble polymers — such as certain PVP derivatives, low-chain PEG or carrageenans — are outside scope.

Step 4 — Is it non-biodegradable? A polymer that passes Appendix 15 testing is exempt even if it satisfies the three criteria above.

If a polymer passes all four filters (solid + size in range + insoluble + non-biodegradable) and is present at ≥ 0.01% with a technical function, the restriction applies and the polymer must be phased out according to its product category deadline.

INCI polymers that most frequently require this analysis in cosmetic formulation:

• Polyethylene (CAS 9002-88-4): historically the most common microplastic in scrubs. In the form of solid microspheres, it is the paradigmatic microbead — banned since October 2023.
• Nylon-12 (CAS 24937-16-4): nylon powder used in foundation and compact powders for texture and shine control. Solid, insoluble, non-biodegradable — subject to evaluation; the make-up deadline is 2035.
• Acrylates Copolymer: INCI name covering several acrylic copolymers. May present as solid particles or as an emulsion. Requires evaluating whether the phase is dispersed as solid particles or dissolved.
• Polymethyl Methacrylate (PMMA) (CAS 9011-14-7): acrylic powder with an optical blurring effect. Solid, insoluble, used frequently in foundations, concealers and powders — make-up/nail/lip deadline: 2035.
• Styrene/Acrylates Copolymer, Polyethylene Terephthalate (PET), Polyurethane, Polypropylene: all potentially affected; a case-specific evaluation — physical form, solubility, biodegradability — determines whether the restriction applies.

For practical verification, the microplastics section of the BD-API CosIng database lists the polymers identified in our database that fall within the scope of Regulation 2023/2055, with their ban dates by product category. The Regulatory Watch monitors EUR-Lex for any subsequent modification to the REACH Regulation affecting entry 78 or its technical appendices.

For the broader CosIng framework and ingredient search, the guide What is CosIng and how to use it explains the Annex structure and the ingredient search tool.

6. How BD-API handles this

The BD-API microplastics database lists the polymers identified in our CosIng data that fit the definition under Regulation 2023/2055, with their CAS numbers where available and the corresponding ban dates by product category. The database is updated whenever the regulator publishes modifications to REACH Annex XVII or to the technical appendices of entry 78.

The Regulatory Watch monitors EUR-Lex for published acts that amend REACH — including potential updates to Appendices 14 through 19, which define the exemption criteria for microplastics. When a change is detected, the analysis pipeline classifies it, extracts the deadlines and affected substances, and delivers it by webhook and email with an estimated impact level.

This is particularly relevant for microplastics because the Commission is expected to review the exemption criteria within 5 years of entry into force (i.e. before 2029), and it is possible that the lists of polymers exempt by biodegradability will evolve as standardised test methods mature. Tracking those updates without having to manually monitor the Official Journal is exactly the use case for Regulatory Watch.

7. Frequently asked questions

Does Regulation (EU) 2023/2055 amend the Cosmetics Regulation 1223/2009? No. It amends the REACH Regulation (EC) 1907/2006, specifically its Annex XVII (restriction list). The Cosmetics Regulation is unchanged — but formulators must comply with both. The supervisory authorities are different.

When were microbeads banned in EU cosmetics? From 17 October 2023, with no transition period. Abrasive or cleansing microbeads in rinse-off products were the first category to be banned.

What concentration threshold triggers the restriction? The restriction applies when synthetic polymer particles are present at a concentration of 0.01% or more by weight and confer a sought-after characteristic.

Does every polymer INCI automatically become a banned microplastic? No. A polymer qualifies as a synthetic polymer microparticle only if it meets four simultaneous criteria: solid, synthetic, within size thresholds, and insoluble plus non-biodegradable. Presence in an INCI does not imply automatic prohibition.

When are leave-on cosmetics banned? From 17 October 2029. Creams, serums, balms, stick deodorants and similar products have until that date.

Is cosmetic glitter already banned? Loose plastic glitter for non-cosmetic uses (crafts, toys) was banned in October 2023. Plastic glitter as a cosmetic ingredient follows cosmetic transition dates: rinse-off 2027, leave-on 2029, make-up/lip/nail 2035. Biodegradable or soluble glitter is exempt.

Where can I read the full legal text? On EUR-Lex: CELEX:32023R2055 — the primary reference for any technical or legal interpretation.