Sustainability in the cosmetics industry now extends beyond packaging to the ingredients used and the way formulations are designed. As environmental impact becomes an increasingly important consideration in ingredient selection, the European Union’s microplastics restriction is one of the regulatory changes to watch in cosmetic product development.
In 2023, the EU amended the REACH Regulation and began restricting the placing on the market of certain synthetic polymer microparticles intentionally added to products. Cosmetic products are also within the scope of the restriction, with different transition periods applying depending on the product type.
This change involves more than simply removing a particular ingredient. In some cases, an alternative ingredient must perform the same function as the original while maintaining the product’s sensory feel and quality.
How, then, will the EU microplastics restriction affect ingredient selection and formulation development in cosmetics?
1. What Has Changed Under the EU Microplastics Restriction?
The term “microplastics” generally refers to small plastic particles. Some microplastics do not readily break down after being released into the environment and may persist for long periods, making them an environmental concern.
In cosmetics, plastic microbeads formerly used in scrubs and cleansing products are a typical example. Other synthetic polymer particles may also be used to modify a product’s texture or appearance.
To reduce the release of these particles into the environment, the EU began applying its microplastics restriction under the REACH Regulation on 17 October 2023.
An important point is that not all synthetic polymers fall within the scope of the restriction.
Under the EU regulation, several factors are considered together, including whether particles contain a synthetic polymer in solid form and whether the particle size and polymer content meet the specified thresholds. Whether the polymer is degradable, soluble, or of natural origin is also assessed against the specific criteria set out in the regulation.
An ingredient therefore cannot be assumed to fall within the restriction simply because its name contains the word “polymer.” The ingredient’s actual properties and conditions of use must be reviewed.
2. Different Application Dates for Different Types of Cosmetics
The EU microplastics restriction does not apply to all cosmetic products at the same time.
Transition periods were established by product type to give brands and manufacturers time to review existing ingredients and develop alternative materials where necessary.
| Product Type | Main Application Date |
|---|---|
| Plastic microbeads used for exfoliation or cleansing | 17 October 2023 |
| Rinse-off cosmetic products | 17 October 2027 |
| General leave-on cosmetic products | 17 October 2029 |
| Makeup, lip, and nail products subject to an extended transition period | 17 October 2035 |
These dates apply to synthetic polymer microparticles that fall within the scope of the EU restriction. Derogations or separate obligations may apply depending on the product and its conditions of use.
Makeup, lip, and nail products require particular attention even before the final restriction date.
Products containing the relevant microplastics will be subject to labeling requirements from 17 October 2031 through 16 October 2035. The applicable labeling requirements should therefore be considered alongside the final restriction date.
Regardless of product type, derogations from the restriction on placing products on the market may apply under certain conditions of use. Even in such cases, separate obligations—such as instructions for use and disposal or reporting requirements—may still apply.
After the applicable date, restrictions may apply to the placing on the EU market of products containing restricted substances. The rules governing the continued distribution of products lawfully placed on the EU market before the applicable date must be reviewed separately.
Responding to the restriction therefore requires reviewing not only the applicable dates but also labeling obligations, conditions for derogations, and distribution rules for products already placed on the market.
3. How the Microplastics Restriction Affects Cosmetic Formulation Development
Each cosmetic ingredient performs a particular function, and a single ingredient may influence several product characteristics.
Some particulate polymer materials can affect a product’s spreadability, the finish it leaves on the skin, and its appearance. If an ingredient subject to the restriction must be replaced, the overall user experience of the product may need to be reassessed.
Sensory Feel and Texture
Sensory feel is one of the key factors consumers use to evaluate a product.
For example, particulate materials may be used to adjust the feel of primers designed to spread smoothly or skincare products characterized by a lightweight finish.
Changing these ingredients may affect the product’s spreadability, smoothness, and after-feel on the skin.
When introducing an alternative ingredient, it is therefore important to evaluate whether it can reproduce the intended sensory feel of the product.
Product Appearance and Finish
Some particulate materials can affect light scattering or surface texture, influencing the product’s visual characteristics.
In base makeup products, where the appearance of the skin is particularly important, changing an ingredient may alter the blurring effect or finish.
If an alternative material does not provide the same properties as the original ingredient, the blend of other ingredients or the formulation design may need to be adjusted to suit the product concept.
Formulation Stability
Changing an ingredient may also affect how it interacts with other components of the formulation.
Depending on the properties of the product and the material, viscosity, particle dispersion, and physical stability during storage may change. Stability may therefore need to be reevaluated.
Not every ingredient substitution will necessarily cause stability problems. However, it is important to confirm that the new material functions appropriately within the existing formulation.
Product Development Example: Replacing an Ingredient in Base Makeup
Consider the development of a base makeup product designed to glide smoothly over the skin and create a blurring effect.
If a particular particulate ingredient is responsible for the product’s sensory feel and visual effect and falls within the scope of the EU restriction, an alternative material may need to be considered.
In this situation, selecting an alternative material that complies with the regulation is not enough. Developers must determine whether the alternative can provide spreadability, finish, and appearance similar to those of the original product. They must also evaluate how the new material affects the formulation as a whole.
Although this is a hypothetical development example, it illustrates the type of review process that regulatory compliance may require in actual product development.
An ingredient change resulting from the microplastics restriction may therefore involve more than a simple substitution. It can lead to a formulation review aimed at maintaining the product’s function and user experience.
4. Factors to Consider When Selecting Alternative Ingredients
When replacing an ingredient subject to the restriction, the first step is to determine what role the existing material performs in the product. Materials capable of delivering the same function can then be evaluated.
Brands and manufacturers should first confirm whether each candidate material falls within the scope of the restriction. Naturally derived materials or mineral ingredients may also be considered depending on the product’s intended purpose. However, their practical suitability must be determined by evaluating the material’s properties and its performance in the finished formulation.
Terms such as “naturally derived” or “biodegradable” should not, on their own, be taken to mean that a material complies with the EU regulation. The material’s actual properties and the specific criteria set out in the regulation must be confirmed.
The following factors should be reviewed when considering alternative ingredients:
- Function: Can the alternative perform the role of the existing ingredient?
- Sensory feel: Can the product’s spreadability and finish be maintained?
- Stability: Can the formulation maintain appropriate quality when the alternative is combined with other ingredients?
- Regulatory compliance: Does the alternative meet the relevant requirements of the target market?
- Manufacturing compatibility: Is the alternative feasible in terms of the production process and cost?
The key is not simply to remove an ingredient subject to the restriction, but to find an appropriate alternative while considering both product quality and regulatory requirements.
5. How Cosmetic Brands and Manufacturers Should Prepare
The microplastics restriction highlights the need to assess the regulatory compliance of ingredients from the early stages of product development.
In particular, brands planning products for global markets should consider the following points.
First, determine whether each ingredient falls within the scope of the restriction.
The ingredient name alone should not be used as the basis for this assessment. Technical documentation and relevant information from the raw material supplier should be reviewed. Where necessary, additional information about the ingredient’s particle characteristics or the criteria for exclusion from the scope of the regulation may also need to be confirmed.
Second, review the entire formulation when an ingredient change is required.
The function of the existing ingredient within the product should be identified, and the alternative material should be evaluated to determine whether it can perform that function appropriately.
Third, consider testing to confirm product quality.
If an ingredient change could affect sensory feel or physical stability, testing and evaluation appropriate to the product’s characteristics may be required.
Fourth, review the regulatory timeline and obligations in the target market.
The EU regulation includes not only transition periods for different product types but also labeling obligations for certain products and derogations for specific conditions of use. The product launch schedule and relevant requirements should therefore be reviewed together.
These processes can help manage not only regulatory compliance but also overall product quality and market suitability.
Conclusion: The Challenges Regulatory Change Poses for Formulation Development
The EU microplastics restriction demonstrates that cosmetic product development must consider the function of each ingredient alongside regulatory compliance and environmental considerations.
For brands and manufacturers, the ability to develop formulations that meet evolving standards while maintaining the sensory feel and quality consumers expect is becoming increasingly important.
What is needed, therefore, is not simply ingredient substitution, but a development approach that considers both regulatory requirements and the overall quality of the finished product.
Recognizing the need for this approach, Neo Mirae stays attuned to the evolving beauty market and product development landscape and seeks to work alongside brands as they explore new product possibilities.
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