Microplastic Rules: What Cosmetic Brands Must Reformulate Around

Microplastic restriction arrived as a formulation problem rather than as a marketing problem, & that is why it keeps surprising brand teams. The obligation sits on the ingredient list: on whether a specific polymer in a specific product is solid, insoluble, below the size threshold & present above the concentration threshold. A brand can have perfectly honest on-pack wording & still hold a formula it can no longer place on the market in a given region.

The buyer's problem is the calendar. Reformulation is not a single laboratory round; it is a new ingredient, a stability re-run, a compatibility re-run, a re-notification in each market & a new golden sample, & all of that sits inside a launch window that was planned around the old formula. This article covers what sits inside the definition, which product categories are affected first, the staged dates in the European Union, the narrower microbead measures elsewhere, substitution routes for exfoliants, glitter, film formers & encapsulates, & the evidence a supplier file should carry. Ingredient compliance across markets is described in our ingredient safety guide, & the scrub format most directly affected is set out in our body scrub OEM guide.

Why the rules landed on formulators rather than on marketers

The first generation of measures targeted one visible thing: the plastic bead in a face scrub. The current generation does not work that way. The European restriction is written against a defined class of material, synthetic polymer microparticles, wherever they appear & whatever function they perform, so the obligation is discharged at ingredient level rather than at claim level.

That shift has a practical consequence for how projects are planned. A marketing change is quick; an ingredient change is slow. Once a polymer is identified as in scope, the work is to find a substitute that delivers the same sensory effect, survive preservation, hold stability, stay compatible with the pack & arrive with documentation a regulator can read. That is a development cycle, not a copy change.

It also means the risk is unevenly distributed across a portfolio. A wash with visible beads was obvious. A wash with a pearlescent polymer dispersion was not, & neither was a pressed powder, a styling film former or a fragrance encapsulate. The exposure sits in the formulas nobody thought of as plastic.

What counts as a synthetic polymer microparticle

The definition has four tests, & a material must fail all four to be in scope. The material must be a solid polymer; it must be particulate below the size threshold, or fibrous below the fibre threshold with the specified length to diameter ratio; it must not be a polymer that occurs in nature without chemical modification; & it must not meet the biodegradability or solubility criteria the restriction sets out.

The size threshold for particles is in the millimetre range rather than the micron range, which is the detail formulators most often get wrong. A particle that a chemist would describe as a coarse powder rather than as a microplastic can still be in scope if it is below the threshold & solid. Fibres are assessed separately with their own length & aspect ratio limits.

The concentration threshold is the other half of the test. Below the stated weight percentage, the restriction does not bite; at or above it, it does. The number is low enough that an ingredient included for a sensory effect at a typical use level will usually exceed it, & low enough that incidental carry-over from a raw material supply is a question worth asking rather than assuming away.

The scope map: rinse-off, leave-on, colour, fragrance

Practical screening starts by sorting the portfolio into use patterns. A rinse-off product goes down the drain in use; a leave-on product stays on the body or in the home; a colour cosmetic is applied & removed or worn off; a fragrance is volatilised. The European restriction uses product category rather than chemistry to set the dates, so the first question for any formula is which category it sits in.

The screening then walks the ingredient list. Every INCI name that describes a polymer is a candidate, & the candidates divide into three groups: polymers that dissolve at the use pH & are therefore not solid particles, polymers that are delivered as a dispersion of solid particles & are candidates for restriction, & polymers that carry a documented biodegradability result & may fall outside the definition. The division is a matter of evidence, not of appearance.

The third step is the supplier file. A formula cannot be screened reliably from INCI names alone, because the same name can describe materials with different particle morphology & different solubility from different makers. The brand needs the polymer identity, the particle form & the biodegradability evidence from the supplier of each candidate ingredient, kept against the formula version that was approved.

The European restriction: its staged dates

The European measure was adopted as an amendment to the restriction list that sits under the chemicals regulation, adding an entry for synthetic polymer microparticles. It entered into force in 2023 & applies in stages, & the stage a product falls into is decided by its category & by the function the particles perform.

The earliest date applies where particles are present to give an abrasive, polishing or cleansing function, which is the microbead case & the one most markets acted on first. The next dates apply to rinse-off products, then to leave-on products, & the longest runway is given to colour cosmetic formats including make-up, lip & nail products. Loose glitter placed on the market on its own sits at the early end of that sequence rather than at the late end.

These dates should be read against the current legal text & any national measures, because staged restrictions of this kind are amended & because a supplier's own obligations differ from a brand's. The planning point for a buyer is simpler than the legal detail: the colour & leave-on categories have the longest runway, & that runway is exactly the development time a reformulation needs, so a brand that starts in the last year of the runway will be late.

The narrower microbead bans in other markets

Several markets acted earlier & more narrowly. The United States prohibited plastic microbeads in rinse-off cosmetics under its microbead legislation, with the definition tied to a solid plastic particle below a size threshold that is added to exfoliate or cleanse. The United Kingdom legislated for rinse-off personal care products, & Canada acted on toiletries under its environmental protection law. Each is narrower in scope than the European entry because each is tied to a function rather than to the material class.

The practical difference matters for a portfolio. A polymer that is lawful outside the European Union because it does not exfoliate can still be restricted inside it because it is a solid polymer particle present above the threshold. A brand that sells into both should screen to the stricter definition rather than maintain two ingredient lists, because the cost of a second formulation exceeds the cost of one conservative one.

Other markets have adopted or proposed measures of their own, & the scope differs enough that a market-by-market check is required rather than an assumption that one region's position travels. The safe operating practice is to hold a restricted-substance list per destination market & to re-screen at every formula change & every supplier change.

Exfoliating particles: the first thing to strip out

The scrub is the easiest case & the most instructive. Polyethylene beads were specified because they were cheap, spherical, size-controlled, chemically inert & colour-stable. Every substitute gives up at least one of those properties, & the formulation work is about deciding which property matters to the product.

Mineral options, principally silica, give size control & inertness but are harder & more angular, so the abrasion feel changes & the safety assessment for the intended use area has to be revisited. Botanical options such as jojoba esters, cellulose, rice, oat or ground fruit kernel give a softer feel & a natural story but vary by harvest & supplier, which shows as colour drift & particle size spread between lots. Sugar & salt dissolve, which removes the particle from the waste stream entirely but only works in a low-water or anhydrous base, since a water-rich product dissolves its own exfoliant.

The second-order effects are the ones that cost time. A botanical particle carries a microbial load that a synthetic bead does not, so preservation has to be re-challenged. A denser mineral particle settles, so suspension & viscosity have to be re-engineered. A softer particle shears during filling, so the filling method & the pump or orifice have to be re-qualified. None of that appears in an ingredient datasheet.

Glitter, decorative effect pigments

Decorative glitter is usually a metallised plastic film cut to size, most commonly polyester, & it is squarely within the material class. It is used in gels, body products, colour cosmetics & seasonal formats, & because the visual effect is the reason the product exists, substitution is a design decision rather than a chemistry one.

The substitutes behave differently. Regenerated cellulose film gives a biodegradable route with a softer, less mirror-like sparkle. Mica-based pearlescent pigments give a pearl lustre rather than a glitter flash & are widely used in colour cosmetics. Borosilicate & mineral flakes give a high sparkle at a higher cost & with a density that affects suspension. Aluminium is a metal rather than a polymer, so it sits outside a polymer restriction, but it is not biodegradable & it raises its own questions about the waste stream.

There is a separate duty that brands overlook: the colourant rules for the use area. A glitter or pearl used around the eye is subject to its own permissions & to particle size & shape considerations that have nothing to do with microplastic restriction. A substitute that satisfies the polymer rule can still be the wrong choice for the eye area, so the two checks run in parallel rather than in sequence.

Film formers, texture polymers: the hidden exposure

Film formers are the category that surprises people. They are used to hold a style, to give a wash-off resistant film, to suspend a pigment, to give a wash a pearlised or opaque look, & to make a texture feel powdery. Many are supplied as aqueous dispersions of solid polymer particles, which is precisely the physical form the definition describes.

The screening question is whether the polymer is soluble at the use pH, because a polymer that dissolves is not a solid particle in the finished product. A neutralised acrylic that is insoluble in its supplied dispersion can dissolve once the formula is adjusted, which is a genuine route to compliance & also a genuine trap if the pH drifts in storage. Solubility has to be demonstrated at the pH the product will actually hold across its shelf life, not at the pH of the fresh batch.

Where the polymer stays solid, the routes are a biodegradable film former, a soluble one, or a reformulation that achieves the effect by other means, for example by increasing a wax phase or by changing the surfactant ratio to build the sensory effect in the base. Each costs development time & each changes the performance the brand is selling, so this is the category where an early decision matters most.

Encapsulates, beads, delivery systems

Encapsulation is used to protect an unstable active, to delay a fragrance release or to separate incompatible materials. The shell is often a crosslinked polymer, & because the particle is small & solid, it falls to be assessed like any other. The encapsulate is therefore in scope on the same tests, & the fact that it performs a delivery function rather than a textural one makes no difference to the analysis.

The options are to change the shell chemistry to a biodegradable or soluble polymer, to move the function into the base so the encapsulate can be dropped, or to reformat the product so the delivery is achieved differently. Each carries a performance cost: a biodegradable shell can be more permeable, so the protection it provides is weaker, & a shorter fragrance release is a change the consumer notices.

The documentation point is that the shell is a separate supply chain item from the core. A brand buying an encapsulate is buying a shell chemistry from one supplier & a payload from another, & the declaration must cover both. A declaration that covers the payload only is not enough to discharge the brand's screening duty.

Biodegradability, solubility: what evidence looks like

Biodegradability is not a marketing adjective in this context; it is a test result against a specified method. The recognised methods include the ready biodegradability series used for chemicals & the marine & soil methods used where the exposure route is different, & the restriction sets out which evidence is acceptable. A supplier statement that says biodegradable without naming the method & the result is not evidence.

Solubility is the same kind of question. A polymer that dissolves above the stated threshold is outside the definition, & the evidence is a measured solubility at a stated pH & temperature. The measurement has to be at conditions the product will experience, because a polymer that is soluble at room temperature can be insoluble in a cold warehouse or in cold rinse water.

Analytical proof completes the file. Where a brand needs to demonstrate the absence of in-scope particles rather than the presence of a compliant one, the methods used are microscopy to establish particle form & size, with spectroscopic identification of the polymer. The practical route for most brands is simpler: hold a supplier declaration per candidate ingredient, keep it against the approved formula version, & commission analysis only where a declaration is unavailable or a customer demands it.

Restrictions at a glance

The table below sets the main ingredient classes a brief should screen against the use they are put to, the status to check & the substitution route commonly explored. The rows are a screening aid drawn from common formulation practice, not a legal classification, & the status of any specific material should be confirmed against the current legal text & the supplier declaration for the grade in use.

These are screening directions, not determinations. The same INCI name can describe a compliant grade & a restricted one depending on particle form, solubility & biodegradability, so the declaration for the grade in use is what decides. Any claim a brand makes about the environmental profile of the finished product is a separate question from the restriction, & the substantiation expected for that wording is set out in our claims testing guide.

What to put in the brief

State the destination markets first, because scope & dates follow from them. Name the sensory function each polymer is there to perform, so a substitute can be assessed against the effect rather than against the ingredient. Ask for a supplier declaration per candidate ingredient, tied to the grade & the formula version, & set the expectation that a reformulation re-runs stability & compatibility rather than inheriting them.

• The destination markets, because scope, dates & definitions differ by region.
• The full INCI list of the starting formula, including any encapsulate shell chemistry.
• A supplier declaration per polymer ingredient, naming the grade & the test method.
• The sensory function each polymer performs, so a substitute is judged on effect.
• The particle content you can accept in the finished product, weight based.
• The stability & compatibility programme you expect a reformulation to repeat.
• The re-notification work needed per market, & who owns doing it.
• The review trigger: a supplier change, a grade change, or a legal text change.

Then confirm the golden sample for the reformulated product will be made on the production grade of the substitute, because a substitute approved on a laboratory sample is a different product. A screen run once at launch & never repeated is the failure mode here; the obligation tracks the formula, not the project.

Where our capability fits

We take a restriction project as a screening exercise before it is a formulation one. We walk the ingredient list against the destination markets, mark every polymer as soluble, solid or documented, request the declaration for each candidate, & agree with the brand which functions can be rebuilt in the base instead of substituted. Where a substitute is needed, we trial it against the sensory target rather than against the old ingredient, re-run the stability & compatibility work, & hold a new golden sample because the reformulated product is a new product.

We work with brands on private label (your brand on a proven base), OEM/ODM contract manufacturing & full custom formula development, & the ingredient screen is run before a base is committed so the two move together rather than in sequence. Our own lines include a deep pore cleansing oil softgel capsule & a black pearl purifying serum capsule, screened & documented with the same declaration discipline.

Tell us the markets you sell into & the formula you are worried about, & we will come back with the screen, the candidates & the re-test plan. Start at our inquiry page, email capsulebiotech@163.com, or message the right team on WhatsApp: Capsule Series (capsules only) +86 158-7655-5319, Cosmetics Series (serum, hair care, body care, fragrance) +86 158-7655-5319.

General manufacturing information, not regulatory or legal advice. Microplastic restriction is governed by legal texts that differ by market, are staged over time & are subject to amendment; the scope, the dates & the evidence required for any specific material should be confirmed with the competent authority & with the ingredient supplier before a product is placed on sale.