When must cosmetics stop containing microplastics in the EU?

Entry 78 restricts “synthetic polymer microparticles” (SPM). These are solid polymers that make up at least 1 % by weight of particles, or coat particles continuously.

At least 1 % by weight of those particles must measure 5 mm or less in every dimension. Fibre-like particles count up to 15 mm long if their length-to-diameter ratio exceeds 3.

There is no lower size limit. If analysis or documentation cannot determine the concentration, only particles of at least 0.1 µm (0.3 µm long for fibres) are counted (paragraph 3).

The ban applies when SPM confer a sought-after characteristic (the Explanatory Guide cites texture, colour or bulk) at 0.01 % by weight or more (paragraph 1).

The 0.01 % is solid polymer weight divided by total product weight, as placed on the market: 0.1 g per kg.

Only solid polymers count. Liquid polymers, and polymers dissolved in the product rather than held in particles, are not SPM.

Four kinds of polymer are excluded from the definition:

Entry 78 entered into force on 17 October 2023. Paragraph 6 defers the ban for cosmetics, using the product categories of Regulation (EC) No 1223/2009.

“Placing on the market” means any supply, including by distributors and retailers (REACH Article 3(12)). Non-compliant stock must be sold before each date; there is no sell-off period.

The exemption for products already on the market on 17 October 2023 (paragraph 16) does not apply to these deferred categories.

Where a rinse-off or make-up product contains SPM that encapsulate fragrance, the Commission’s guide applies the 17 October 2029 date (paragraph 6(a)).

Paragraph 5 permanently exempts SPM that, during intended end use, are contained by technical means so that releases are prevented, permanently stop being SPM, or are permanently incorporated into a solid matrix. Exempted products carry instruction and reporting duties instead.

Film-forming polymers in nail polish, nail gels and dipping powders fall under paragraph 5(b). They coalesce into a film and permanently stop being particles (Explanatory Guide, Q&A 7.4 and 15.1).

Glitter and other SPM that remain particles on the nail are not exempt. They follow the 17 October 2035 date for nail products (Q&A 15.5).

The guide states that paragraph 5(c), permanent incorporation into a solid matrix, does not cover cosmetics. From 22 June 2028, Regulation (EU) 2026/1168 restricts 5(c) to end uses lasting one year or more.

Paragraph 4(a) exempts SPM supplied for use at industrial sites, such as raw materials delivered to a formulating plant. It does not cover finished cosmetics sold to consumers.

Since 17 October 2025, suppliers of SPM under paragraph 4(a) must provide instructions for use and disposal, the entry 78 statement, the SPM quantity or concentration, and generic polymer identity information that lets downstream users and other suppliers meet the paragraph 11 and 12 reporting duties (paragraph 7). It may be given on the safety data sheet (paragraph 10).

Paragraph 4(g), added by Regulation (EU) 2026/1168 and applicable retroactively from 17 October 2023, also exempts SPM supplied for product and process orientated research and development, in quantities of 1 tonne per year or less. It covers R&D outside industrial sites too, such as in universities (recital 3).

Make-up, lip and nail products that still contain SPM must carry a specific statement (paragraph 9). From 17 October 2031 until 16 October 2035, it reads: “This product contains microplastics.”

Paragraph 10 requires text given under paragraphs 7, 8 and 9, including this statement, to be in the official languages of the Member States where the product is placed on the market, unless they provide otherwise. Each language version of entry 78 gives its own wording, e.g. French: “Ce produit contient des microplastiques.”

Products placed on the market before 17 October 2031 need not bear the statement until 17 December 2031. After that, unlabelled products must be withdrawn (Explanatory Guide, Part I, Section 7).

The statement must be clearly visible, legible and indelible text on the label, packaging or package leaflet (paragraph 10). A pictogram cannot replace it.

Since 17 October 2025, cosmetics containing exempted SPM, such as nail polish with film-forming polymers, must carry instructions for use and disposal (paragraph 8). This applies even during transition periods (Q&A 9.11).

These instructions may be text or pictograms on the label, packaging or leaflet; a QR code can only supplement them. National authorities judge their adequacy case by case.

The guide cites “Do not pour product down the drain” and “Do not rinse packaging before disposal” as possible wording (Q&A 9.4).

Where given as text, these instructions are subject to the same language rule (paragraph 10).

Reports are due to ECHA by 31 May each year and cover the previous calendar year. For cosmetic formulation and products, the first deadline is 31 May 2027, covering 2026.

Industrial downstream users of SPM at industrial sites, such as formulating plants, report their uses, generic polymer identity and estimated releases (paragraph 11). Releases during transport are included.

Sites using plastic pellets, flakes or powders as feedstock to make plastics have reported since 31 May 2026 (paragraph 11).

The first supplier to place products with exempted SPM on the market for consumers or professionals reports their end uses and releases (paragraph 12).

Distributors and retailers do not report. Reports are prepared in IUCLID and submitted to ECHA through REACH-IT, which has accepted them since 26 November 2025 (ECHA reporting guidelines).

On request, manufacturers, importers and industrial downstream users must give authorities the exact identity and function of the polymers in their products (paragraph 14).

Those claiming a polymer is degradable or soluble must provide the Appendix 15 or 16 test evidence without delay when asked (paragraph 15).

Entry 78 is a REACH restriction. It applies to cosmetics alongside Regulation (EC) No 1223/2009, which has no microplastics ban of its own.

Its categories reuse Cosmetics Regulation definitions: rinse-off, leave-on, lip and nail products (preamble to Annexes II to VI, point 1).

“Make-up product” is defined in paragraph 2(e) of entry 78. It means a product applied to the epidermis, eyebrows or eyelashes mainly to change their appearance. Classification is case by case (Q&A 4.3).

The transition periods only cover products within the Cosmetics Regulation. Cosmetics for dolls, for example, get no transition (Q&A 15.6).

The microplastics statement is a REACH duty on top of Article 19 labelling under the Cosmetics Regulation. “Microplastic-free” claims remain subject to its Article 20 on product claims.