What falls under the ban?

The proposed restriction applies to intentionally added ingredients that meet the definition of microplastics, when present at concentrations higher than 0.01% (w/w) in the finished consumer product. This includes cosmetics and personal care, as well as other categories such as household and cleaning products.

Microplastics are defined as solid, insoluble, non-degradable and persistent polymer particles with a maximum size of 5 mm (spherical) or 15 mm (rod-shaped). Importantly, not every polymer qualifies as a microplastic. Ingredients such as proteins or sugars are polymers but are excluded from the ban because they are soluble or biodegradable. The focus is strictly on solid polymer particles that meet the criteria of being both persistent and microscopic in size.

Which cosmetic ingredients remain allowed?

Polymers that are soluble (>2 g/L), degradable, or naturally derived and unmodified (for example, alginates or pectins) do not fall under the ban.

However, borderline cases require careful evaluation. All microplastics are polymers, but not all polymers are microplastics. Some polymers may either be exempt or restricted depending on their form in the finished product. For instance, the same INCI name could represent a soluble variant in one formula and a non-soluble particle in another. Assessments that rely only on the INCI name without considering the actual physico-chemical properties of the ingredient risk reaching the wrong conclusion. Since the same INCI name may cover both situations (e.g., acrylates copolymer or acrylates crosspolymer), compliance assessments based only on INCI names are unreliable.

In such cases, it becomes necessary to verify the exact physico-chemical properties of the ingredient in the final formulation, as used by the consumer. This may involve reviewing supplier technical data and collaborating with raw material providers when additional information is required.

For cosmetic products, the following categories remain allowed under the current proposal:

• Soluble polymers (solubility > 2 g/L), such as certain polyacrylic emulsifiers or gelling agents.

• (Bio)degradable polymers that break down naturally.

• Natural polymers not chemically modified, such as alginates, pectins, guar, and similar substances.

Why this creates challenges for cosmetic R&D

For R&D teams, the difficulty lies in determining whether a given raw material should be flagged as a microplastic in the context of the final product. This demands ingredient-level data and collaboration with suppliers. Misclassification could lead to unnecessary reformulation or, worse, non-compliance.

How PRIMS supports your preparation

This is where PRIMS comes in. The platform automatically flags raw materials, formulas, and products that may fall under the microplastics definition. By linking substances to technical data and regulatory parameters, PRIMS helps you:

• Identify non-compliant formulations early

• Distinguish between polymers that are safe to use and those that are restricted

• Run compliance analysis across your portfolio, including future regulation scenarios

• See exactly which products would require reformulation through the Where Used function

Because PRIMS tracks ingredient usage across all product levels, manufacturers can avoid oversights and prepare phase-out strategies with full visibility.

Expected timelines for cosmetics

Based on the proposal, the foreseen transition deadlines are:

• Immediate from Entry into Force (EiF) for cosmetics with microbeads used as abrasives, such as scrubs and toothpastes

• EiF + 4 years for rinse-off cosmetics containing microplastics

• EiF + 6 years for leave-on cosmetics

In addition to removal from the market, reporting duties and labeling requirements may apply.

Getting ready, with PRIMS

Regulatory uncertainty is always challenging, but systems like PRIMS give you a structured way to act now. Start by analyzing your formulations against the proposed definition, flagging potential risks, and mapping the impact on your product range.

With built-in compliance dashboards and future regulation alerts, PRIMS provides cosmetic brands and manufacturers with the insight needed to prioritize reformulations, manage timelines, and ensure uninterrupted market access.