Key Takeaways:
Two years on from the European Union's move to restrict intentionally added microplastics in cosmetics, global beauty brands, cosmetic chemists, formulators, and raw material suppliers are investing in compliance. And as reporting and phase-out deadlines approach, pressure is on to adhere to an array of restrictions.
EU Microplastics Restriction Deadlines
In September 2023, the European Commission adopted Regulation (EU) 2023/2055, restricting intentionally added synthetic polymer microparticles, or microplastics. One month later, the regulation came into force with a series of phase-out deadlines to give industry time to adapt accordingly.
The industry has until October 2027 to reformulate rinse-off cosmetic products; until October 2029 to reformulate leave-on cosmetic products and fragrance encapsulates; and until October 2035 to reformulate makeup, lip, and nail leave-on cosmetic products. Microbeads across all applications were immediately restricted in October 2023.
The earliest deadline in the EU regulation is around reporting. Industry must report the use and disposal of synthetic polymer microparticles at industrial sites, providing estimates on how much is released into the environment during processing and end product use. Data submissions for 2026 must be filed by May 31, 2027.
So, are viable and scalable alternatives available today to enable successful reformulation? Does the industry have a grasp on this sweeping restriction? And what sort of waves is this EU regulation creating worldwide in beauty?
“Extremely Complicated” Regulatory Obligations
“The restriction is extremely complicated and extremely broad,” John Chave, Director General of European trade association Cosmetics Europe, told BeautyMatter. The regulation is linked to a “whole series of different deadlines for different kinds of obligations,” Chave explained—some to remove microplastics entirely, some to label presence, and some to report use and disposal.
As phase-out deadlines approach, he said the biggest challenge for the industry worldwide remains deciphering the complexity of these obligations within the directive, including permitted derogations.
In April 2025, the European Commission published an Explanatory Guide on its restriction of microplastics under the European Chemical Agency’s (ECHA) Registration, Evaluation, Authorization, and Restriction of Chemicals (REACH) regulation in 22 EU official languages to help stakeholders and Member States implement necessary changes. Prior to this, Cosmetics Europe (CE) and the European Federation for Cosmetics Ingredients (EFfCI) published an independent guidance document to address key elements, frequently asked questions, and areas for further work.
The existence of both documents underlines the complexity of this restriction.
“The regulation is already very radical and very, very broad based and, even in the best-case scenario, is placing significant costs on the industry,” Chave said. “But then you have additional bells and whistles—the reporting obligation—and there is widespread concern about the reporting obligation not only in cosmetics but the broader range of industries being asked to comply with it.”
The Director General said that, broadly, it remains unclear why exactly this reporting is needed—there is also no methodology for gathering data and the software interface is complex for users. “While we can all understand the need to address the microplastics issue, the reporting obligation is an example of where the EU really goes further than it has to.”
The Global Beauty Impact
Typically, the EU is considered a golden reference point for cosmetic regulation, with countries often moving to align with EU laws. However, fewer countries are falling in line with the EU's microplastics restriction.
“I don't see much evidence of a rush to sign up to the EU restriction in this case. Why is that? Is it because the EU went too far? Is the EU losing its regulatory superpower state? I think it's an interesting question to ask,” said Chave.
So, as global markets keep watch on how things evolve in Europe—considering their own positioning on the use of intentionally added microplastics in cosmetics—it will be critical for industry and scientists to stay actively involved in regulatory discussions, according to Kelly Dobos, US-based Independent Consultant Cosmetic Chemist and Adjunct Professor in the Cosmetic Science Program at the University of Cincinnati.
“Regulations shape the products we create and the technologies we invest in, so having a seat at the table allows us to share real-world insights, feasibility considerations, and scientific evidence,” Dobos said. “Without that collaboration, regulations risk being disconnected from practical implementation, which can lead to unintended consequences like supply chain disruptions or reduced innovation.”
Currently, the US has no federal restriction on microplastics in cosmetics. There is a ban on plastic microbeads in rinse-off cosmetic products under the Microbead-Free Waters Act of 2015, but no comprehensive federal restriction for leave-on or decorative cosmetic categories. However, like many other global markets, the country is looking closely at how the EU regulation evolves and, of course, US companies placing products on the EU market must adhere to restrictions.
Innovate, Don't Procrastinate
Marc-André Vernhet, Cosmetics Department Director at global regulatory compliance agency EcoMundo, warned against waiting for deadlines to approach—whether working in the EU or elsewhere—noting that last-minute reformulation R&D risks “rushed substitutions, compromised performance, and reputational damage.”
“Extended transition periods should be used for innovation, not procrastination—those who invest early gain a competitive advantage,” Vernhet said.
On a global scale, he said the picture is clear: non-degradable synthetic polymer microparticles will be phased out of cosmetics entirely. “This is not just a compliance issue—it's a strategic pivot for the industry. Brands that act early and embrace biodegradable or water-soluble systems will not only reduce regulatory risk but also position themselves as leaders in sustainability and innovation. Reformulation should be viewed as an opportunity to modernize product portfolios, strengthen consumer trust, and differentiate in a market increasingly driven by environmental responsibility.”
Reformulating to remove microplastics, however, is far from without its challenges.
Caroline Rainsford, Director of Science at UK trade association The Cosmetic Toiletry and Perfumery Association (CTPA), said synthetic polymers play an essential functional role in a huge number of formulations across beauty and personal care, making this category “extremely challenging to replace as a whole.”
Industry Must "Completely Redesign" Product Architecture
In many cases, formulations rely on microplastics as key functional ingredients: binding together ingredients in toothpaste; boosting effectiveness of certain UV filters in sunscreens; or giving long-wear and waterproof function to color cosmetics, to give just a few examples.
Globally, the cosmetics industry is working hard to develop replacement ingredients and alternative formulations, but Rainsford said there is an incredible amount of innovation required. According to Cosmetics Europe’s socioeconomic analysis 2019 survey, filed as submission no. 2361 to the public consultation on ECHA’s Annex XV dossier, A European cosmetics industry survey in 2018 showed that in 85% of cases, no alternative ingredients were available. Today, advances have been made, but “there will never be 'drop-in' replacements because microplastics perform such diverse roles in many different product types,” she said.
Given one-to-one substitution is not feasible, formulators need to “completely redesign the product architecture,” she explained—all the while maintaining performance, stability, and microbiological and toxicological safety. Overall, it is an expensive, multistep process that typically takes two to five years to complete.
Rainsford urged brands and manufacturers to start reformulation efforts as early as possible, investing heavily in R&D and working collaboratively with raw material suppliers to identify viable options. It is critical now for the industry to consider sustainability and regulatory compliance as “core design principles.”
Currently, the EU restriction on microplastics does not apply to products in Great Britain—England, Scotland, and Wales—but the UK government and relevant authorities are reviewing outcomes from an Evidence Project investigation assessing whether risk management measures are needed for intentionally added microplastics. UK companies placing products on the EU market are, however, required to follow the EU regulation.
The Impact of Bans “At Scale”
Dr. Mark Smith, Director General of The International Natural and Organic Cosmetics Association NATRUE, said natural and organic brands have long demonstrated that substitution of microplastics is possible, with numerous effective and high-performance products already on the market across all categories, including rinse-off, leave-on, and color cosmetics.
However, Smith said it is important to acknowledge the impacts of implementing bans at scale. “What the natural and organic cosmetics sector has shown is that ingredient selection, collaboration across the supply chain, and innovation—which the cosmetics industry is renowned for—all play a role. To this end, early action, access to alternatives at scale, transparent consumer communication, and collective problem-solving consistently lead to better outcomes.”
Chave agreed: “It's not just a point of finding functional alternatives, it's about finding ones the industry can easily formulate with and that are widely available.”
Daniela Rechenberger, Corporate Media Relations Manager at German chemicals multinational BASF, said cosmetic ingredient suppliers are working hard to provide the industry with the necessary tools to adhere to restrictions. BASF, for example, is taking a three-pronged approach: keeping permitted synthetics where they deliver best performance and cost; developing biopolymer alternatives; and focusing on hybrid blends. “The approach is a combination of leveraging existing safe synthetics, innovating with biopolymers, and smart formulation strategies to meet regulatory and environmental goals.”
But Rechenberger said any new ingredients or blends must meet compatibility, performance, and regulatory compliance requirements in tandem. “Key learnings from silicone replacement can be applied to the microplastics challenge. Anticipate and lead: don't wait for regulations—develop and launch alternatives early. Match performance: ensure new ingredients like biopolymers and natural abrasives deliver the same or better results in texture, stability, and sensory experience. And validate thoroughly: conduct comprehensive testing to confirm performance and consumer acceptance.”
Phase-Out Deadlines: Leave-On, Rinse-Off, Makeup, Lip, and Nail
Expert consensus is that leave-on products, particularly decorative makeup, lip, and nail products, are the toughest to reformulate free from microplastics.
The reason lies in the heavy dependence on synthetic polymer film formers for performance attributes like long-wear, water resistance, flexibility, and transfer resistance in decorative cosmetics and textural, stability, and efficacy attributes in leave-on products. This has been acknowledged in the longer transition periods for these two categories versus rinse-off, where lots of advances have already been made.
Dr. Barbara Brockway, Scientific Advisor in Cosmetics and Personal Care and owner of Barbara Brockway Consulting, said that as the industry continues to innovate to remove microplastics, it is important not to shy away from complete reformulation versus individual material replacement.
Brockway said drop-in materials can cause instabilities and, in some cases, longer-term issues, such as a negative lifecycle analysis impact, so it remains important to “look at the whole picture.”
“I always think of that wobbly table where you start shortening one leg, then another, until eventually the table is too low, still wobbles, and you end up buying a new table. It's the same with formulations. A drop-in replacement may cause instabilities that another drop-in material does not resolve, so eventually you go back to the start and reformulate.”
The expert advised the industry to avoid any “regrettable substitutions,” and pushed an open-minded approach—revisiting existing cosmetic materials, for example, that could perhaps be coaxed into providing new functions.
“Focusing resources on reformulation often means less time for new product development; however, from my perspective, developing more earth-friendly cosmetics materials to help formulators remove banned microplastics from their products is a challenge worth embracing for the sake of environmental health, human well-being, and the welfare of all life.”
Vernhet agreed: “The companies that invest now in robust R&D, supplier partnerships, and transparent communication will set the benchmark for the next generation of beauty products.”