Cosmetic products in the EU market are facing a new challenge of the incoming EU-wide Registration, Evaluation and Authorisation of Chemicals (REACH) Regulation’s microplastics restriction.
This proposal covers almost all products containing microplastics: cosmetics and fragrances, biocides and even medical products. A link to the latest text and annex is available at Comitology Register (europa.eu).
The Restriction proposal has now been confirmed by the EU REACH Committee and as soon as it will pass the European Council and Parliament the transition periods will begin. This is expected to occur in Q3 2023.
The scope of this restriction has the protection of our environment at its core. There are potential hazards posed by microplastic particles with (very) long persistence in the environment combined with a potential to bioaccumulate.
What is a microplastic?
According to the European Chemicals Agency (ECHA) the definition of microplastic for the REACH Restriction on microplastics is that of any solid, synthetic polymer:
"A material consisting of solid polymer-containing particles, to which additives or other substances may have been added, and where ≥ 1% w/w of particles have (i) all dimensions 0.1µm ≤ x ≤ 5mm, or (ii), for fibres, a length of 0.3µm ≤ x ≤ 15mm and length to diameter ratio of > 3".
It is a broader definition than "plastic microbeads" which were present in some rinse-off cosmetics for their exfoliating properties but have been voluntarily phased-out across Europe and banned in several countries, ahead of the wider REACH Restriction proposal.
The "microplastic" definition will include many substances, such as functional polymers. A substance can also be considered microplastic if at least 1% of the particles meet the microplastic definition. Even non-microplastic particles can become microplastics if they have a coating, of any thickness, which meets the microplastic definition.
Reformulations – identify, redesign, retest
Once the regulation will be published there will be transitional periods for the decisions to enter into force. Many manufacturers will have to change the composition of their products to develop suitable alternatives. For microplastics in washable cosmetic products, for example, a transitional period of 4 years is foreseen, for leave-on cosmetic products it should be 6 years. An extended transition period of 12 years for the ban on the placing on the market is proposed for make-up, lip and nail ‘leave-on’ cosmetic products, as the cost to develop suitable alternatives for these products are expected to be higher than for other ‘leave-on’ cosmetic products.
The reformulation process involves multiple steps, and it won’t be a straightforward task.
Solid synthetic polymers falling in the microplastic definition currently play a fundamental role in the architecture of many cosmetic products, from sun care to skin care, to deodorants and colour cosmetics. They provide a combination of benefits like stabilising agents, soft skin feel, smooth textures, enhanced spreadability.
They cannot be simply replaced and the whole product will need to be looked at to be redesigned. A glance at the INCI names won’t be sufficient. The same INCI name could be in scope within some products and out of scope in others. An ingredient could be a microplastic but excluded from ban if not remaining in solid form in the finished product. Microplastic identification criteria will need to look at several aspects (size, chemical composition (carbon content), solubility, biodegradability, origin).
Looking for solutions
Suitable alternatives to microplastics could be polymers that occur in nature that have not been chemically modified or polymers that are (bio)degradable.
Ingredients suppliers are developing alternative ingredients and some offerings are available to try.
For example, biodegradable, natural origin ingredients from sustainable sources, like some cellulose and silica powders can be an excellent alternative solution to nylon powder to achieve different benefits like good texture and flowability in colour cosmetics or sebum control and soft focus in skincare applications.
Biodegradable and biocompatible ingredients from renewable natural sources with gelling, thickening, and stabilising properties could be an alternative to those synthetic thickeners that will meet the microplastic definition. Key to allow the formulation of firm gels to smooth and creamy textures.
We at The Cosmetic Experts are always on the look for latest innovations and solutions, while keeping up to date with incoming regulations to anticipate compliance and cutting down on timings required for a reformulation. If you are looking for a solution to reformulate your products or you would like to develop new products that will help to contribute to our environment protection, contact us at info@thecosmeticexperts.co.uk.