EU Ban on Microplastics in Cosmetics: 2027-2035 Deadlines and What Ukrainian Manufacturers Should Do

# EU Ban on Microplastics in Cosmetics: 2027-2035 Deadlines and What Ukrainian Manufacturers Should Do

October 2027 - less than a year for the majority of shampoos and shower gels. If your brand sells rinse-off products on the EU market or plans to enter it in the coming years, the deadline is already running: formulations need to be reviewed, alternative ingredients tested, new CPSRs signed off. This article gives the full picture of the regulatory ban, a practical audit algorithm and the real cost of transition.

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> Quick answer > > Microplastics (officially - synthetic polymer microparticles, SPM) are man-made polymeric particles smaller than 5 mm intentionally added to cosmetic formulations as exfoliants, thickeners, carriers of active substances or glitter. From 17 October 2023 they are banned in a series of EU product categories under [Commission Regulation (EU) 2023/2055](https://single-market-economy.ec.europa.eu/sectors/chemicals/reach/restrictions/commission-regulation-eu-20232055-restriction-microplastics-intentionally-added-products_en), which amends REACH Annex XVII, Entry 78. For rinse-off cosmetics (shampoos, shower gels, face washes) the key date is 17 October 2027.

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What Microplastics Are and Why the EU Is Banning Them in Cosmetics

Synthetic polymer microparticles (SPM) have been used in cosmetics for decades because of their low cost and technical convenience: polyethylene microbeads cleansed the skin without abrasiveness, nylon particles gave creams a silky texture, polymeric capsules released fragrances gradually. The problem became evident when studies showed that, once rinsed off, these particles pass through wastewater treatment systems and accumulate in marine organisms, soils and drinking water.

According to estimates by [ECHA](https://single-market-economy.ec.europa.eu/sectors/chemicals/reach/restrictions/commission-regulation-eu-20232055-restriction-microplastics-intentionally-added-products_en), around 145,000 tonnes of intentionally added microplastics enter the EU environment every year - cosmetics account for a significant share of this volume. That is precisely why Regulation (EU) 2023/2055, adopted on 27 September 2023 as part of the EU Green Deal strategy, introduced the world's strictest restrictions on the use of SPM in products sold within the EU.

Importantly, the ban applies not only to manufacturers within the EU. Any product placed on the EU market, regardless of where it is manufactured, must comply with the requirements. For Ukrainian manufacturers exporting to Poland, Germany or Lithuania, or planning to enter these markets, the clock is already ticking.

The threshold value distinguishing "traces of contamination" from "intentional addition": products with an SPM concentration of up to 800-1,300 ppm are treated by the regulator as containing only technological traces rather than intentionally introduced particles. However, this is not an automatic exemption from the ban - documented evidence is required to show that the SPM is not a functional ingredient.

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Timeline of the Ban: 2023, 2027, 2029, 2031, 2035 Deadlines

Regulation (EU) 2023/2055 introduced a staged system of bans depending on the product category. The full table for cosmetics is set out below.

| Product category | Date of ban | Status | |---|---|---| | Loose plastic glitter, microbeads for exfoliation | 17 October 2023 | Already banned | | Rinse-off cosmetics (shampoos, shower gels, facial cleansers, toothpaste) | 17 October 2027 | Active deadline | | Leave-on cosmetics (day and night creams, body lotions, serums) | 17 October 2029 | 3 years | | Encapsulated fragrances | 17 October 2029 | 3 years | | Decorative cosmetics: eyeshadows, foundations, powders | 17 October 2035 | 9 years | | Lipstick, lip gloss, lip liners | 17 October 2035 | 9 years | | Nail polishes and gels | 17 October 2035 | 9 years | | Decorative, lip and nail cosmetics: mandatory "contains microplastics" labelling | 17 October 2031 | Preliminary step before 2035 |

*Sources: [Commission Regulation (EU) 2023/2055](https://single-market-economy.ec.europa.eu/sectors/chemicals/reach/restrictions/commission-regulation-eu-20232055-restriction-microplastics-intentionally-added-products_en), [research-regulatory-trends.md - section 3.1]*

### October 2023 - Glitter and Microbeads (Already Banned)

From 17 October 2023 plastic loose glitter and microbeads for exfoliation have been withdrawn from the EU market without a transitional period. If your brand is still selling any beauty product containing conventional PET glitter in EU countries, this is an ongoing infringement. Replacements (biodegradable cellulose-based glitter, mica) are available in the portfolios of most raw material suppliers.

### October 2027 - Rinse-Off (Shampoos, Shower Gels, Face Washes)

This is the most critical deadline for the majority of Ukrainian manufacturers. The rinse-off category covers everything that is washed off with water: shampoos, conditioners, shower gels, bath foams, scrubs, facial cleansers, toothpastes. From 17 October 2027, products in this category containing SPM may no longer be placed on the EU market. The sale of stock already released after this date is also prohibited - unlike with some other regulatory changes, there is no separate sell-through window after the placing-on-the-market deadline.

### October 2029 - Leave-On (Creams, Lotions, Serums)

Leave-on products remain on the skin after application. The category includes day and night creams, serums, body lotions, oils, hair styling products, sunscreens and deodorants. By the same date, encapsulated fragrances are also banned - a technology widely used in scented lotions and laundry conditioners.

### 2031 - Labelling for Decorative Cosmetics and Lip Products

From 17 October 2031, manufacturers of decorative cosmetics and lip and nail products are required to indicate on the packaging "This product contains microplastics". This is a precautionary step before the full ban in 2035, allowing the consumer to make an informed choice.

### 2035 - Decorative Cosmetics, Lip and Nail Products

The longest transitional period applies to segments where technological alternatives are the most difficult: lipstick (where polyisobutene functions as a binder), nail polishes (where nitrocellulose and polymeric film-formers are critical for wear), powders and eyeshadows (where coated micas or encapsulated pigments contain synthetic shells).

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Which Substances Fall Under the Ban: List of INCI Names

The ban covers synthetic polymer microparticles - solid or liquid/wax-like, insoluble in water, smaller than 5 mm. The most common INCI names worth checking in every formulation are listed below.

Exfoliating microbeads and particles: Polyethylene (PE), Polypropylene (PP), Polystyrene, Nylon-6, Nylon-12, Polyethylene Terephthalate (PET), Polymethyl Methacrylate (PMMA).

Thickeners, texture modifiers and film-formers: Acrylates/C10-30 Alkyl Acrylate Crosspolymer, Carbomer (certain versions), Polyacrylate Crosspolymer, Acrylates Copolymer (in certain forms), Styrene/Acrylates Copolymer, Polyurethane-35.

Encapsulated ingredients: any INCI marked "(and) Urea Formaldehyde Resin" or "Polyurea Microcapsules" in the composition of encapsulated fragrances or active substances.

Decorative effects: Synthetic Fluorphlogopite (where the shell is synthetic), Polyethylene Terephthalate coatings on micas.

An important detail: natural polymers (cellulose, chitosan, starch, alginates), as well as polymers that are water-soluble or fully biodegradable in accordance with EN 13432, are not covered by the ban. For this reason, when auditing a formulation it is necessary to distinguish synthetic carbomer (subject to review) from xanthan gum (not subject to review).

The full technical description of the SPM definition is set out in [Annex 15 to REACH](https://single-market-economy.ec.europa.eu/sectors/chemicals/reach/restrictions/commission-regulation-eu-20232055-restriction-microplastics-intentionally-added-products_en), which provides the precise criteria for chemical composition, particle size, solubility and biodegradability.

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Why This Is Particularly Relevant for Ukrainian Manufacturers

Haircare and rinse-off products are the backbone of Ukrainian cosmetic exports. According to [APCU Industry Analysis 2024](https://apcu.ua/wp-content/uploads/2024/11/), the haircare category (UKTZED 3305) accounts for 29% of total UA cosmetic exports by value - USD 14.70 million out of USD 51.03 million in 2023. Together with the bath/shower category (17%), this segment makes up almost half of all Ukrainian cosmetic exports.

The key exporting brands - Dr. Sante, O'Herbal, Green Pharmacy by ElfaGroup - account for a significant share of this volume. ElfaGroup exports 50% of its production abroad to 68 countries, including Poland, Germany, Lithuania and other EU markets ([Retailers.ua](https://www.retailers.ua/news/mneniya/14002-eksport-ukrayinskoyi-kosmetiki-dosvid-elfagroup-na-cosmoprof-bologna-2024)). Dr. Sante and O'Herbal shampoos and conditioners fall directly within the rinse-off category with an October 2027 deadline.

Geography matters: the three principal destinations of UA cosmetic exports - Poland (18%), Germany (9%) and Lithuania (7%) - are EU markets where, from 17 October 2027, compliance of formulations with Regulation (EU) 2023/2055 will be checked at customs clearance and through market surveillance. Any consignment of rinse-off products containing SPM after this date may be detained or destroyed.

An additional factor: Ukraine has held EU candidate status since June 2022, and harmonisation of regulatory requirements is part of its obligations under the Association Agreement. This means that, even for the domestic market, Ukraine will inevitably adopt analogous restrictions in future updates of the Technical Regulation.

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Natural Alternatives: 8 Practical Replacements

Reformulation is not simply about removing SPM - it is about selecting an ingredient with an equivalent functional profile. The table below sets out proven replacements, taking into account raw material availability and regulatory status.

| Function | Synthetic SPM | Natural alternative | INCI name | Notes | |---|---|---|---|---| | Exfoliation (face) | Polyethylene (PE) | Sugar scrub | Sucrose | Dissolves easily, suitable for sensitive skin | | Exfoliation (body) | Polyethylene (PE) | Sea salt | Maris Sal | More aggressive - not for the face | | Exfoliation (moderate) | Nylon-12 | Walnut shell powder | Juglans Regia Shell Powder | Moderate abrasiveness, widely available | | Exfoliation (delicate) | PMMA | Wax-like jojoba beads | Jojoba Esters | Melt on the skin at body temperature, zero environmental impact | | Exfoliation in rinse-off | Polypropylene | Cellulose microspheres | Cellulose | Fully biodegradable, compliant with EN 13432 | | Shine/pearlescence | PET-coated micas | Natural phlogopite mica | Phlogopite | Natural mineral without synthetic shells | | Texturiser/thickener | Carbomer (synthetic) | Xanthan gum | Xanthan Gum | Natural biopolymer with broad application | | Encapsulated fragrance | Polyurea Microcapsules | Starch-based microcapsules | Starch Microcapsules | Actively being developed by suppliers, higher cost |

Practical tip: when switching from PE microbeads to alternatives in shower scrubs, the most important thing is to calibrate the particle size and test the stability of the formulation. Natural exfoliants, as a rule, deliver a less uniform particle size, which may require adjustment of overall viscosity and the system's pH. This process takes between 4 and 12 weeks depending on the complexity of the formulation.

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How to Check Your Formulation: An Audit Algorithm

Auditing a formulation for compliance with Regulation (EU) 2023/2055 consists of four sequential steps.

Step 1. Product portfolio inventory. Divide all products sold or planned for sale in the EU into three groups: rinse-off (2027 deadline), leave-on (2029 deadline), decorative/lip/nail (2031/2035 deadline). This sets the order of priority for the work.

Step 2. Review of INCI lists. For each product in the rinse-off group, go through the full INCI list and flag all synthetic polymeric names from the list above. If any of them are present, request from the raw material supplier a technical data sheet (TDS) and Safety Data Sheet (SDS) specifying particle size, solubility and degree of biodegradability.

Step 3. Applying the mass balance approach. For formulations in which the same base component (for example, a polyacrylate thickener) is used in several products, apply a mass balance approach: calculate the total amount of SPM introduced via each ingredient and assess its share in the finished product against the 800-1,300 ppm threshold. This is particularly relevant when using concentrated premixes or fragrance bases, where microcapsules may be a hidden component.

Step 4. Documentation and updating the PIF. If the audit confirms the absence of SPM or that its concentration is below the threshold with a documented justification, add a corresponding note to the Product Information File (PIF). If reformulation is required, record all changes in CPSR Part A and update the CPNP notification. For more detail on updating the CPSR following reformulation, see our article ["CPSR 2026: The Full Manufacturer's Guide"](/news/cpsr-2026-povnyi-haid-vyrobnyka).

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Reformulation Cost and Timeframes: approx. USD 5,000-50,000 per Product Line

The cost of reformulation varies significantly depending on the complexity of the formulation, the need for additional testing and the volume of documentation.

Minimum scenario (a direct replacement of a single exfoliant in a simple formulation, without changes to the pH profile): approx. USD 5,000-10,000 per product line. This includes the cost of the alternative raw material, stability testing (temperature, freeze/thaw, photostability), microbiological testing and the CPSR update.

Medium scenario (several SPM ingredients, the need to reselect the thickener or fragrance system): approx. USD 15,000-30,000 per line. This covers iterative rounds of formulation studies (typically 3-6 months), comparative consumer testing, updates to the technical documentation and to the CPNP.

Complex scenario (systemic reformulation involving encapsulated fragrances, redesign of packaging, new claims): approx. USD 30,000-50,000 and above. This applies to flagship products or to simultaneous work across several markets (EU + UK + US), where requirements differ somewhat.

Timeframes: from the start of the audit to the first batch of the reformulated product takes between 6 and 18 months depending on complexity. This means that for rinse-off products, where the deadline is October 2027, the decision-making window is practically closed: if an audit is not started now, the risk of missing the deadline becomes real.

Recommendation from [BeautyMatter / EcoMundo](https://beautymatter.com/articles/eu-microplastics-regulation-the-global-beauty-impact): "Do not wait for the deadline - rushed R&D in the final months carries the risk of hasty substitutions and reputational damage." Rushed reformulation often results in unstable formulations that are sent back for rework after launch.

For more on labelling of reformulated products and parallel changes to the INCI Glossary, see our article ["Cosmetics Labelling: EU vs UK vs US vs Ukraine - 2026 Table"](/news/markuvannya-kosmetyky-eu-uk-us-ukraina-2026).

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What Happens If You Do Not Comply in Time: Real Consequences After October 2027

Regulation (EU) 2023/2055 is not a recommendation but an amendment to REACH Annex XVII, meaning a legally binding directly applicable rule across all 27 EU Member States. The consequences of non-compliance are specific.

Detention at customs. EU customs authorities have the right to block consignments that, on the available evidence, do not comply with Annex XVII. After October 2027, rinse-off products containing SPM are prime candidates for inspection - especially where the INCI list contains names from the list above.

Withdrawal from the market. Market surveillance authorities (in Poland - UOKiK, in Germany - Bezirksregierungen, in Lithuania - VMVT) are empowered to initiate the withdrawal of products from retail networks. Withdrawals are recorded in the RAPEX / Safety Gate - the EU database of dangerous products, which is public and immediately damages the brand's reputation across all markets.

Financial penalties. Penalties are set at the level of each EU Member State. In Poland - up to 2% of the company's annual turnover for breaches of product composition requirements. In Germany - up to EUR 50,000 per single infringement under the Chemicals Act (ChemG).

Liability of the EU RP. All consequences are borne by the EU Responsible Person - the legal entity that placed the product on the EU market. If this is your Polish or Lithuanian distributor, they will have grounds to terminate the contract and recover damages from the UA manufacturer. For more on regulatory requirements in Ukraine, see our article ["Cosmetics Technical Regulation of Ukraine 2026"](/news/tekhnichnyy-rehulament-kosmetyky-ukraina-2026).

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Reporting Obligations: ECHA IUCLID from 31 May 2026

In addition to the product ban itself, Regulation (EU) 2023/2055 introduces mandatory annual reporting for certain categories of market participants. According to [Intertek / ECHA](https://www.intertek.com/blog/2026/04-22-microplastics-reporting-in-the-european-union/):

Manufacturers and importers of synthetic polymer microparticles used as raw materials for plastics production are required to submit their first annual report via the ECHA IUCLID platform by 31 May 2026 (covering 2025 data). From 31 May 2027 the reporting scope expands: it will include manufacturers and downstream users operating under derogations or transitional periods.

For most Ukrainian cosmetics manufacturers, this reporting requirement does not apply directly - it is addressed to SPM raw material producers. However, if your company manufactures or imports SPM for its own use (for example, synthesising polyethylene microbeads in-house), the reporting obligation is relevant.

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Frequently Asked Questions (FAQ)

Does the microplastics ban apply to products sold only on the Ukrainian market?

No - Regulation (EU) 2023/2055 applies only to products placed on the EU market. On Ukraine's domestic market, the Technical Regulation on Cosmetic Products (CMU Resolution No. 65) remains in force, which currently contains no analogous restrictions. However, as part of its European integration commitments, Ukraine will gradually align its regulatory framework with the EU acquis - so corresponding regulation will appear on the domestic market too, most likely within the 2027-2030 horizon.

Are mineral powders containing mica particles caught by the ban?

Natural mica (Mica, Phlogopite) is not a synthetic polymer and is not covered by the ban. The issue arises with coated mica - where the shell of the particles is made from a synthetic polymer (for example, a PET coating). In such cases it is worth requesting confirmation of the shell material from the supplier.

Is the CPNP updated automatically following reformulation?

No. A change of formulation - even if driven by a regulatory requirement - requires the CPSR (Part A) to be updated, after which the responsible person (EU RP) must update the CPNP notification manually via the portal. The timelines are not automated: the update must take place before a new batch of the product is placed on the EU market.

Can a plant-based polymer (for example, xanthan gum) be regarded as SPM?

No. Natural polymers - polysaccharides (xanthan, guar, alginates), cellulose and its derivatives of natural origin - do not fall within the definition of synthetic polymer microparticles, provided that they have not undergone chemical modification giving them the properties of a synthetic polymer. Check the supplier's TDS and the CAS number.

What should I do if a supplier claims that their carbomer is "biodegradable"?

This is a tricky point: standard Carbomer (polyacrylic acid) is not biodegradable in an aqueous environment under EN 13432. Some newer versions ("biodegradable crosspolymers") may meet the exemption criteria, but this requires written confirmation from the supplier referencing the results of testing under a standardised method. Without such confirmation, it is advisable to replace the ingredient or to obtain a legal analysis against the criteria of REACH Annex 15.

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Conclusion: October 2027 Deadline - Less Than 18 Months to Act

For Ukrainian manufacturers of shampoos and shower gels targeting EU markets, the window for comfortable reformulation is closing. The standard R&D cycle from decision to a validated new batch takes 6-18 months - which already puts you up against October 2027.

First-priority actions: carry out an INCI audit of the rinse-off portfolio, identify which ingredients fall under the ban and start working with suppliers of alternative raw materials. In parallel, check whether your scented conditioner or shower gel contains encapsulated fragrances: if so, this is also a rinse-off product with a 2027 deadline, not a leave-on with a 2029 deadline.

VRC supports reformulation audit + transition planning for Ukrainian brands: from INCI analysis and selection of alternative ingredients through to updating the CPSR and the CPNP notification. Get in touch with us for an initial consultation.

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*Article prepared on the basis of: [Commission Regulation (EU) 2023/2055](https://single-market-economy.ec.europa.eu/sectors/chemicals/reach/restrictions/commission-regulation-eu-20232055-restriction-microplastics-intentionally-added-products_en) | [ECHA REACH Annex XVII Entry 78](https://single-market-economy.ec.europa.eu/sectors/chemicals/reach/restrictions/commission-regulation-eu-20232055-restriction-microplastics-intentionally-added-products_en) | [Intertek/ECHA Microplastics Reporting 2026](https://www.intertek.com/blog/2026/04-22-microplastics-reporting-in-the-european-union/) | [BeautyMatter - EU Microplastics Regulation](https://beautymatter.com/articles/eu-microplastics-regulation-the-global-beauty-impact) | [APCU Industry Analysis 2024](https://apcu.ua/wp-content/uploads/2024/11/) | [Retailers.ua - ElfaGroup Cosmoprof 2024](https://www.retailers.ua/news/mneniya/14002-eksport-ukrayinskoyi-kosmetiki-dosvid-elfagroup-na-cosmoprof-bologna-2024) | [Critical Catalyst - EU Microplastics](https://criticalcatalyst.eu/european-union-restricts-microplastics-in-cosmetic-products/) | [Freshfields - EU Microplastics](https://www.freshfields.com/en/our-thinking/blogs/sustainability/eu-regulations-on-microplastics-big-steps-against-small-particles-102l6lb)*