The EU microplastics in cosmetics restriction is binding law — Commission Regulation (EU) 2023/2055, REACH Annex XVII Entry 78, in force since 17 October 2023.
Leave-on products, including tattoo aftercare balms, foams, and serums, must comply by 17 October 2029.
The ban targets solid synthetic polymer particles under 5 mm (fibres up to 15 mm) that are water-insoluble, non-biodegradable, and added to perform a function, at 0.01% by weight or more.
Film formers, texture powders, and fragrance microcapsules are the sources most brands miss.
Compliance is a paperwork job: ask your supplier for a declaration that names Entry 78 — a generic "REACH compliant" certificate does not name the restriction.
Most tattoo aftercare lines pass every normal EU check and then hit one wall in 2029: the microplastics in cosmetics restriction. The rule does not target dirt or plastic waste. It targets solid synthetic polymer particles added on purpose, and film formers, texture powders, and scent capsules can all fall inside it. The dates are fixed, the exemptions are real, and the brands that start early keep their launch on schedule.
What the Ban Covers and When
The rule behind the headlines is Commission Regulation (EU) 2023/2055 — see the European Commission's official restriction page for the full legal text and guidance. It is not a proposal waiting in committee. It is binding law, written into REACH Annex XVII as Entry 78, and it has applied since 17 October 2023. (A June 2026 amendment adjusted derogations for medicinal products and R&D uses; the cosmetic deadlines below are unchanged.)
The Short Version
Entry 78 restricts solid synthetic polymer microparticles smaller than 5 mm that:
do not dissolve in water (solubility at or below 2 g/L), and
do not break down fast enough to count as biodegradable under the legal test methods.
The ban bites where those particles are present to confer a sought-after characteristic — in plain terms, added to do a job in the formula — and reach 0.01% or more by weight of the mixture. Fibres count too: a polymer fibre up to 15 mm long, with a length-to-diameter ratio above 3, falls inside the same definition.
What Counts as a Microplastic
The target is particles added on purpose to perform a function. Trace plastic that rubs off production equipment, with no function in the finished product, is not what the law aims at, and naturally occurring, unmodified polymers sit outside the scope.
The trap is that most restricted particles do not look like plastic on a spec sheet. They arrive hidden inside thickeners, powders, and coatings. That is why the INCI check later in this article matters more than a quick glance at a label.
The Dates That Decide Your Plan
Cosmetics are split by how the product behaves on skin. These dates decide a launch plan.
| Product type | Compliance deadline |
|---|---|
| Rinse-off (washes, shampoos) | 17 October 2027 |
| Leave-on (balms, lotions, serums) | 17 October 2029 |
| Lip, nail, and make-up | 17 October 2035 |
| Make-up labelling requirement | From 17 October 2031 |
Tattoo aftercare sits in the leave-on row. If the line also includes a cleansing wash, that wash follows the 2027 date and needs attention sooner.
Why a Balm Counts as Leave-On
The deadline is not random. It follows how long the product touches the skin, and for microplastics in cosmetics that single fact decides the date.
Minutes in the Sink or Hours on Skin
A rinse-off product is made to be washed away within minutes. A leave-on product stays on the skin for hours. Tattoo balm, foam, and serum sit on healing skin all day and all night, which is the textbook leave-on case — a , applied after washing and left to absorb, is the classic example. The EU treats leave-on products as the higher-exposure group, so their deadline lands in 2029 rather than 2027.
The Legal Test: Added to Do a Job
Open the INCI list and, for every synthetic polymer, ask one question: is it there to confer a sought-after characteristic?
Film formers that leave a protective layer on skin? Added to do a job — in scope.
Powders that give slip or a soft-focus feel? Added to do a job — in scope.
Trace polymer from equipment wear with no function in the formula? Outside scope — but read this narrowly. If the residue performs any function at all, it counts as added on purpose.
This test is why a supplier certificate that only says "compliant with REACH" leaves the question open — look for one that names Entry 78 and the specific particles. The leave-on rules also tie into the wider a private label brand must track at the same time.
Where Microplastics Hide in a Formula
The obvious offenders are easy to catch. The expensive surprises hide inside finished raw materials. When microplastics in cosmetics turn up late in a project, they sit in one of three places.
Film Formers and Texture Powders
Acrylates copolymer, nylon-12, and PMMA work as film formers, mattifiers, and slip agents in leave-on products. On a spec sheet they look like ordinary feel ingredients. Under Entry 78 they are exactly the particles the law targets. A balm that depends on an acrylates film for spread will most likely need a new formula, not a one-line swap. (One narrow exception exists for film formers that permanently lose their particle nature when the film forms during use — but never self-certify this; it needs written confirmation from the raw material supplier.)
Glitter and Exfoliating Beads
Polyethylene, polypropylene, and PET glitter are the visible offenders. Microbeads used as abrasives have been banned since 17 October 2023 with no transition period, so any scrub still using them is already breaking the rule. The remaining risk is an old formula or a contract manufacturer still drawing from an outdated raw material library.
Scent Capsules Most Brands Miss
This one slips past most teams. Fragrance is often packed inside tiny polymer shells that break open on the skin to release scent. Those shells are synthetic polymer microparticles by definition. A formula can read clean from top to bottom and still fail because of them. The only reliable check is to ask the fragrance house directly whether the delivery system uses polymer microcapsules.
Materials That Sit Outside the Ban
Not every polymer is caught, and the exemptions are real. The catch is that a claim is not proof. Each route below needs documents, not adjectives.
Natural Polymers
Cellulose, starch, chitosan, and carnauba wax are natural polymers and sit outside the restriction. They can fill some texture and film roles. A modified natural polymer can fall back inside the definition, though, if it has been altered into a synthetic state. Confirm the exact material and its status in writing.
Plastics With Proof They Break Down
A synthetic polymer can leave the scope if it passes the legal biodegradation tests. The reference test series are OECD 301, 302D, and 310. A supplier saying "biodegradable" without a study proves nothing. Where a biodegradable option truly performs, it is the cleanest route, because it removes the particle instead of documenting it.
Minerals Such as Silica
Silica and other inorganic minerals are not polymers, so Entry 78 never applies to them. Some roles filled by nylon-12 can move to mineral alternatives, though the skin feel is rarely identical. Treat minerals as one tool in the replacement set, and test them on the real formula.
Papers to Ask Your Supplier For
Proving microplastics in cosmetics compliance is a paperwork job as much as a chemistry job. The right documents clear customs and retailer audits. The wrong ones stall a launch.
A Declaration That Names Entry 78
Ask for a declaration that names synthetic polymer microparticles and cites Entry 78 of REACH Annex XVII. A generic certificate that only mentions REACH 1907/2006 does not name the restriction and leaves the Entry 78 question open. The paper should state which particles are present or absent, at what level, and whether any exemption applies.
Files That Agree With Each Other
The safety data sheet, the product information file, and the cosmetic product safety report should all match the microplastics position. If the safety data sheet still lists a polymer the formula claims to have dropped, that mismatch is a red flag for regulators and retailers alike.
Proof Behind Any Formula Change
If a formula was already changed to remove restricted particles, ask for the evidence: the updated INCI, the stability data, and the safety reassessment. The proof has to belong to the version you will actually ship, not to an old prototype.
The microplastics rule is one of several EU chemical rules reshaping cosmetics at once. The parallel touch many of the same product lines, and planning both together avoids a second reformulation later.
Your Move Before 2029
The date looks distant until you count the work. Finding a replacement ingredient, testing it for stability, and repeating the safety assessment are all slow steps, and they run in order. The sequence below keeps a private label line on schedule.
Map Every Ingredient
Pull the full INCI for every leave-on SKU and flag each synthetic polymer. Record particle size, water solubility, and biodegradation status for each one. Anything you cannot confirm in writing stays treated as in scope until proven otherwise.
Get Every Answer in Writing
Send the audit to every supplier and require declarations that name Entry 78. Collect the studies behind any biodegradable claim and file everything against the product. A folder of verbal assurances will not survive an audit.
Test the Replacement Early
For each caught particle, qualify a replacement that keeps the same skin feel, then run stability and safety testing on the revised formula. Starting early leaves room to complete that testing and documentation well before the deadline. If your current manufacturer cannot document an Entry 78 position, talk to a before the 2029 queue builds.
FAQ
What Is the EU Microplastics Ban?
It is Commission Regulation (EU) 2023/2055, which added Entry 78 to REACH Annex XVII. The rule restricts solid synthetic polymer particles under 5 mm that do not dissolve and do not biodegrade, where they are added to perform a function at 0.01% by weight or more. It has applied since October 2023.
When Does the Ban Apply to Cosmetics?
Microbeads were banned from October 2023 with no transition. Rinse-off cosmetics must comply by 17 October 2027, leave-on by 17 October 2029, and lip, nail, and make-up by 17 October 2035. The date depends on whether the product stays on the skin.
Are Microplastics Banned in Leave-On Cosmetics?
Not yet, but the deadline is set. Leave-on products such as balms, creams, and lotions must be free of restricted particles by 17 October 2029, or rely on documented exemptions. Since reformulation and safety re-testing take time, start the ingredient audit now.
Does the Ban Affect Tattoo Aftercare?
Yes. Tattoo aftercare balms, foams, and serums are leave-on cosmetics because they stay on healing skin. EU brands and importers must make sure those formulas hold no restricted synthetic polymer microparticles by October 2029. It is a formulation and documentation task, not a label tweak.
How Do I Know My Formula Has Microplastics?
Check every INCI list and flag each synthetic polymer, then ask each supplier for a written declaration that names Entry 78. A generic REACH certificate is not enough. Natural polymers, silica, and tested biodegradable materials are usually outside the ban, but confirm in writing.
Which Ingredients Count as Microplastics in Cosmetics?
Any solid synthetic polymer particle under 5 mm (or fibre up to 15 mm) that is water-insoluble, non-biodegradable, and added to perform a function at 0.01% by weight or more. Common examples in leave-on products include acrylates copolymers, nylon-12, PMMA, polyethylene and PET glitter, and fragrance microcapsules. Natural polymers, silica, and lab-proven biodegradable polymers sit outside the ban.
Talk to Your Manufacturer First
Planning an EU launch or reviewing a live line? Reformulation and re-testing take time, so the ingredient audit is worth starting well ahead of the 2029 leave-on deadline. Treat microplastics in cosmetics as a documentation job and open the file now.
Ask your manufacturer for a written SPM declaration, and if the file comes back thin, with your INCI list in hand.
