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Microplastics in cosmetics – new reporting obligation to ECHA

July 14, 2025

Microplastics Under the Legal Lens of REACH

Since October 2023, new REACH provisions (Regulation 2023/2055¹) have been in force, introducing a restriction on the use of synthetic polymer microparticles (SPM) – commonly known as microplastics – in various products, including cosmetics.

The aim is to limit the emission of persistent, insoluble particles into the environment.
The Commission estimates that over 42,000 tonnes of microplastics from various sectors, intentionally added, end up in the environment each year.

From the beginning, one of the main challenges in the development of this regulation has been how to identify substances subject to the ban and the specific derogations that allow certain product categories to continue their use.There is no clear catalogue of chemical/INCI names of substances that fall under the ban. Whether a substance is covered depends not only on its chemical structure, but also on its physicochemical properties and intended use. Therefore, determining whether a substance should be removed from a product to comply with the new obligation is difficult in practice.

However, for companies in the cosmetics industry, equally important as the ban itself is the new reporting obligation to ECHA via the IUCLID and REACH-IT systems (described in the Reporting Requirements ECHA of 16 April, 2025²).

Who is affected by the new law?

The obligations apply to all entities placing on the market products or mixtures containing SPM – including in the cosmetics sector.

According to Annex 78¹to Annex XVII of Regulation (EC) 1907/2006, microplastics (SPM) are:

Polymers that are solid substances and meet both of the following criteria:

a) are contained in particles and constitute at least 1% w/w of those particles or form a continuous coating on the particles;
b) at least 1% w/w of the particles referred to in (a) meet any of the following conditions:

(i) all dimensions of the particles are ≤ 5 mm;
(ii) the length of the particles is ≤ 15 mm and the length-to-diameter ratio is > 3

It does not apply to natural polymers (which have not been chemically modified), polymers that do not contain carbon atoms in their structure, biodegradable polymers (in accordance with Annex 15¹), and water-soluble polymers (>2g/l, in accordance with Annex 16¹) – provided they meet the REACH criteria.

When do restrictions on the use of microplastics in cosmetics start to apply?

Cosmetic product	Placing on market ban	Transition period
Rinse-off (e.g. scrubs, gels)	from 17 October 2023	none
Leave-on (e.g. creams, lotions)	from 17 October 2029	6 years
Colour cosmetics (lips, nails, makeup)	from 17 October 2035	12 years *
Leave-on with fragrance microcapsules	from 2031	6 years

New reporting obligation – who, when, how?

For products covered by derogation, companies must report annually to ECHA.
The reporting obligation is independent of tonnage and free of charge.

Who must report?

Manufacturers
Importers
Industrial users
Final suppliers*

(*A supplier may be a manufacturer, importer, or industrial downstream user placing the product on the market for the first time for professional or consumer use.
Distributors are not required to report).

When?

By 31 May 2026 (for 2025): for Derogation 4a (industrial uses)
By 31 May 2027 (for 2026): for Derogation 5 (e.g. leave-on cosmetics, colour cosmetics)

How? – IUCLID and REACH-IT

IUCLID

IUCLID is ECHA’s IT system for submitting chemical dossiers. In May 2024, a dedicated template for microplastic submissions was made available.

Data entry methods:

IUCLID web portal (online version^3,4)
Desktop application (for more complex submissions)

Fig. 1. Fragment view of IUCLID portal (refs.^3,4)

REACH-IT

Portal for submitting IUCLID files to ECHA. Once the IUCLID file is completed, it is exported as .i6z and uploaded to REACH-IT as a “Submission”.

What data must be submitted?


Substance name (INCI / IUPAC)	Full name of the substance reported as SPM
CAS / EC number	Chemical identifiers as per REACH
Physical form (e.g. granules, flakes)	Select from available options
Is it in solid particle form (< 5 mm)?	Evaluate per Annex 78¹ criteria
SPM concentration in mixture (%)	Mass percentage in the final product
Is presence of SPM intentional?	Was SPM intentionally added?
Use description (e.g. leave-on cream)	Purpose and use of the product
CN/TARIC use code	Including HS code per Annex II.2
Estimated annual environmental emission	Select range (e.g. 0.1–10%; 10–30%)
End user type	Consumer / Professional / Industrial
Applied derogation	State derogation number (e.g. 4a, 5b)
Company name	Full name of reporting entity
REACH-IT number (UUID)	UUID of REACH-IT account
Responsible person	Full name of submitter
Report submission date	Date of .i6z file upload to ECHA

What about derogations?

Allowed in cases of:

industrial use (4a)
permanent change of form (5b)
particle encapsulation in a matrix (5c)
fragrance microcapsules (with transition period)

IFUD Labelling (Instructions for Use and Disposal) applies to cosmetics containing synthetic polymer microparticles (SPM) that are still allowed under derogation.
Described in detail in Part I of the European Commission Guidance.⁵

Manufacturers must:

inform consumers about the presence of microplastics
include appropriate labelling on packaging, leaflet or website

Examples of IFUD label:

“This product contains microplastic”

„Do not rinse packaging before disposal”

Labelling is intended to raise environmental awareness and ensure compliance with the applicable REACH regulations. The detailed format and method of providing the IFUD (Instructions for Use and Disposal) should be tailored to the type of product and the available means of communication.

Labelling is mandatory under derogation 5b if the form of the SPM (synthetic polymer microparticles) changes during the consumer use phase — for example, acrylic powder with glitter used for nail hardening. Such a product must carry a label (pictogram) or information advising consumers not to rinse the packaging and any remaining product down the drain.

The detailed format and method of providing the IFUD should be adapted to the type of product and the available information tools.

Below is the IFUD pictogram proposed by the cosmetics industry:

An exemption may be applied to products with tightly sealed packaging, such as aerosols or airless dispensers. In such cases, the existing pictograms informing how to dispose of the packaging may be sufficient.

At the same time, the guidance does not provide approved, official tests to confirm whether a cosmetic product fully qualifies under a given derogation (e.g. whether microbeads used in the product have completely transformed, reacted 100%, and no longer exist in the final formulation). This raises many concerns and questions regarding the proper use of derogations.

Nevertheless, any form of testing data collected about the product will certainly be useful in the event of an inspection (e.g. analysis of solid particles <5 mm using light microscopy, Raman spectroscopy, FTIR, XRD, or membrane filtration after appropriate sample preparation).

What should we do now?

Identify SPM in your product portfolio – check INCI, supplier declarations, run tests
Collect data on quantity, physical form, application – basis for reporting
Create accounts in IUCLID and REACH-IT – test system functionality
Consult suppliers – request biodegradability data (OECD 301/310 per Annex 15¹) and water solubility info (>2 g/l, per Annex 16¹)

New microplastic reporting duties represent a real commitment for the cosmetics sector – even if the company does not directly produce microplastics.
IUCLID will become a key tool not only for chemists, but also for regulatory and sustainability professionals.

Failure to report will be treated as a REACH violation, so it’s worth preparing data and teams ahead of deadlines.