EU Microplastics Restriction: What Rinse-Off Beauty Brands Must Review Before October 2027

For brands planning to sell shampoos, face cleansers, body washes and other rinse-off cosmetics in the European Union, formulation review should include more than performance, cost and stability. It should also include a documented check of synthetic polymer microparticles (SPMs) that may be intentionally present in the formula.

Under Commission Regulation (EU) 2023/2055, the transition period for relevant SPMs in rinse-off products runs through 16 October 2027; the restriction applies from 17 October 2027. Specific uses have different timelines or provisions, so this is not a blanket instruction to remove every ingredient with “polymer” in its name.

As of 25 October 2026, fewer than 12 months remain before that date. Product-development and regulatory teams should begin the ingredient-level evidence review now, while there is time to evaluate alternatives and confirm performance.

What the EU microplastics restriction covers

Commission Regulation (EU) 2023/2055 amended Annex XVII of the REACH Regulation to restrict synthetic polymer microparticles intentionally added to products. The scope depends on the legal definition and material properties—not on whether an ingredient simply sounds synthetic.

The definition focuses on solid polymer particles that meet specified criteria relating to properties such as synthetic or chemically modified origin, organic composition, insolubility and resistance to degradation. The regulation also sets out exclusions, derogations, information duties and product-specific transition periods.

A polymer name in an INCI list does not, by itself, prove that the ingredient is an SPM within the restriction. Equally, a supplier’s brief statement that a grade is “compliant” may not explain the technical basis for that conclusion.

Official references:

• European Commission overview: https://single-market-economy.ec.europa.eu/sectors/chemicals/reach/restrictions/commission-regulation-eu-20232055-restriction-microplastics-intentionally-added-products_en
• Legal text, Commission Regulation (EU) 2023/2055: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32023R2055

Dates that should not be confused

Transition dates differ by intended use. Verify the provision that applies to each ingredient and product rather than treating all cosmetics as one category.

• 17 October 2023: Certain uses were restricted immediately, without a transition period. This includes relevant SPMs used as abrasives to exfoliate, polish or clean—commonly called microbeads—subject to the regulation’s exact scope and provisions.
• 17 October 2027: The transition period ends for relevant SPMs in rinse-off products, subject to exclusions, derogations and specific provisions.
• 17 October 2029: Separate transition periods apply to leave-on products and certain fragrance-encapsulation uses.
• 17 October 2035: A later transition applies to specified make-up, lip and nail products, with a separate labelling phase before the final date.

The European Commission notes that its overview is not legally binding. Use the legal text and qualified regulatory advice for final scope and market decisions.

Why rinse-off product teams should start now

A rinse-off formula is a system: surfactants, rheology, sensory profile, fragrance, botanical or active additions, packaging and target cost all interact. A polymer may contribute to suspension, texture, film formation, opacity, conditioning or another performance attribute. If a material is in scope, simply deleting it can change the finished product.

Changing a rheology modifier may affect viscosity and dispensing. Replacing a particulate ingredient may alter appearance or suspension. Changing a fragrance delivery system can raise a different scope question from changing a thickener. These examples do not mean each ingredient is restricted; they show why the function and physical form must be understood before substitution.

A planned review gives teams time to assess alternatives, test performance and stability, and update documents before a commercial formula is locked.

A six-step ingredient review

1. Build a product-by-product inventory

List each EU-bound rinse-off SKU: shampoo, face wash, shower gel, rinse-off conditioner, scrub and other products intended to be removed after application to the skin, hair or mucous membranes. Record the formula version, target market, launch date, manufacturer and regulatory owner.

Do not rely on the product name alone. Confirm intended use, especially for products with unusual directions or delivery systems.

2. Screen raw materials at ingredient level

Review the quantitative formula and raw-material specifications with the formulator and suppliers. Flag materials described as polymers, particles, encapsulates or beads for further assessment—but do not automatically classify every flagged ingredient as prohibited.

For each candidate, record its identity, function, physical form, particle characteristics where relevant, solubility and degradation evidence, plus the supplier’s regulatory rationale. If information is missing, mark the material as unresolved rather than assuming it is in or out of scope.

3. Separate function from identity

Ask what the material physically is and how it works in the finished product. Is it a dissolved polymer, a solid particulate material, a capsule, or something else? Is its purpose abrasion, rheology control, suspension, film formation, fragrance delivery or another function?

Pay particular attention to abrasive microbeads, because their timeline differs from the transition period for other relevant SPM uses in rinse-off products. Fragrance encapsulation also has a separate provision. Where a material has multiple functions, record the intended use and seek a scope assessment instead of relying on a generic label.

4. Request a usable supplier evidence pack

Ask suppliers for documents that let your technical or regulatory team understand the grade and the basis for its compliance statement. Depending on the material, useful records may include:

• Chemical or polymer identity and a current technical data sheet.
• Physical form and particle-size or morphology information, where relevant.
• Evidence supporting solubility or biodegradation claims, including methods and conditions.
• Intended function and any use restrictions.
• A dated statement addressing Regulation (EU) 2023/2055 and explaining the rationale, exclusion or derogation relied upon.
• Document revision date and change-notification commitments.

A safety data sheet alone may not answer every scope question. Keep the evidence with the raw-material record and link it to the formula versions where the grade is used.

5. Evaluate alternatives against the product brief

If a material is in scope or cannot be supported with adequate evidence, select alternatives based on the function that must be preserved. Do not assume a grade described as natural, biodegradable or water-soluble is automatically suitable or out of scope; request evidence and assess the exact material.

Set acceptance criteria before trials. Depending on the product, these may include viscosity, suspension, foam, cleansing, rinse feel, deposition, appearance, fragrance, microbial quality, preservative performance, stability and cost. The test plan should reflect the intended formula, pack, use conditions and shelf-life expectations.

A replacement must work in the actual formulation—not only in a supplier brochure or a bench sample.

6. Lock evidence into change control

Update the master formula, raw-material specifications, manufacturing instructions, finished-product specification, stability plan and relevant product documents when a formula changes. Record the reason for change, versions tested, results accepted and approval owner.

For contract-manufactured products, agree who obtains supplier declarations, who assesses scope, who approves substitutions and who maintains the dossier. Put these responsibilities into the development brief and change-control process.

Do not confuse product restrictions with ECHA reporting

The EU also has reporting duties for certain uses of SPMs subject to derogations. ECHA explains that reporting can apply to specified manufacturers, industrial downstream users and suppliers, depending on their role and activity. EU reporting guidance published in 2026 supports those obligations.

This is not a blanket annual filing requirement for every cosmetic brand, and an emission-reporting deadline is not the same as a product restriction date. Assess any reporting duty separately from the formula scope review.

Official reporting resources:

• ECHA microplastics reporting: https://echa.europa.eu/fi/support/dossier-submission-tools/reach-it/microplastics-reporting
• 2026 reporting guidance: https://op.europa.eu/en/publication-detail/-/publication/507886bf-7685-11f1-bf5e-01aa75ed71a1/language-en

How a contract manufacturer can support the review

A manufacturing partner can help translate a regulatory concern into a controlled development plan: map raw materials to formulas, gather supplier documents, flag unresolved questions, coordinate trials and compare revised formulas with approved specifications.

For teams developing haircare products, face-care products or body-care products, start with a complete brief: product type and intended use, destination market, current INCI and quantitative formula, function of any flagged polymer, performance targets, pack format and launch timing.

GMP or ISO 22716 systems support disciplined production and documentation, but certification alone does not determine whether an ingredient falls within the EU microplastics restriction. That requires ingredient-specific evidence and a market-specific assessment.

Frequently asked questions

Does every cosmetic polymer need to be removed?

No. The restriction concerns SPMs that meet the legal definition and are not covered by relevant exclusions or derogations. An INCI polymer name alone does not determine scope.

Are exfoliating microbeads treated like other SPMs in rinse-off products?

No. The restriction for relevant SPMs used as abrasives to exfoliate, polish or clean began applying from 17 October 2023. Other relevant SPM uses in rinse-off products have a transition period ending on 16 October 2027, subject to the detailed provisions.

Is a supplier’s “microplastic-free” declaration sufficient?

It can be useful, but confirm which grade and use it covers, its date and version, and the technical rationale. Escalate ambiguous or unsupported statements to the supplier and regulatory adviser.

Should every rinse-off product be reformulated immediately?

Not automatically. Screen the portfolio, resolve ingredient scope and prioritise confirmed or unresolved candidates. Plan substitutions and performance testing early enough to complete stability, compatibility, cost and document reviews.

Does every cosmetic company need to submit an annual microplastics report to ECHA?

No. Reporting applies to specified roles and uses, including certain derogated uses. Confirm applicability to the actual activity instead of assuming it applies to every brand or SKU.

Make the review part of the next formula handover

Before an EU-bound rinse-off formula is locked, create a SKU-level list of candidate materials, supplier evidence, open scope questions, proposed alternatives, test requirements and decision owners. Start with ingredient facts—not a blanket “polymer-free” claim.

CTA: Share the product type, destination market, current INCI list and performance priorities with Vaishnavi Gramodyog to scope a technical formulation discussion. Confirm regulatory interpretation and final market clearance with a qualified EU regulatory professional.

This article is educational information, not legal advice. Use the legal text and competent regulatory advice for final scope and market decisions.