Microplastics: Explanatory Guide

Disclaimer: This document provides guidance and is not a legally binding interpretation and shall therefore not be relied upon as legal advice.

Microplastics Restriction – What you need to know now

The restriction on intentionally added microplastics under Regulation (EU) 2023/2055 entered into force on 17 October 2023. Different provisions apply at different times. The next key restriction takes effect on 17 October 2025 – just months away! With the European Commission’s recently published Explanatory Guide, it’s time to clarify what applies to your products.

Mixture versus Article – Know the difference

The Explanatory Guide provides clarification:

  • The restriction applies to synthetic polymer particles intentionally added to mixtures, not to articles.
  • Loose plastic glitter is classified as a mixture — and has been banned since October 2023 unless proven biodegradable.
  • Glitter embedded in cured matrices such as paint or glue is generally allowed, provided it is not released under normal use conditions.
  • Products with surface-applied glitter may fall outside the scope, but only if no microplastics are released during use – you’ll need evidence.

Examples in the Explanatory Guide

  • Already restricted (since Oct 2023): Loose plastic glitter used for arts & crafts.
  • Still permitted: Glitter fully encapsulated in a solid matrix (e.g. cured coatings, inks).
  • Subject to justification: Surface-applied glitter that may detach is not automatically banned but requires evidence that no microplastics are released during normal use.

Deadlines

17 October 2025 – Ban on products containing non-releasing microplastics

Applies to products where microplastics are present but not intended to be released during use, including:

  • Leave-on cosmetics (e.g. creams, lotions, sunscreens, styling gels)
  • Encapsulated fragrances in detergents and other mixtures
  • Paints and coatings
  • Printing inks
  • Adhesives, sealants
  • Construction materials

These products must not be placed on the market if they contain intentionally added microplastics, unless a derogation applies or specific labeling and reporting obligations are met.

17 October 2027 – Ban on products that release microplastics during use.

Affects mixtures where microplastics are released during normal use. Examples include:

  • Rinse-off cosmetics (e.g. shampoo, scrubs, cleansers)
  • Detergents and cleaning agents
  • Waxes and polishes (e.g. car wax)
  • Air care products (e.g. room sprays)
  • Paints, coatings, adhesives that release particles during use (e.g. sanding or washing)

Exemptions (derogations) may apply for specific uses, with reporting obligations.

17 October 2028 – Start of reporting obligations for derogated uses

Companies making use of derogations must submit annual reports on:

  1. Type and quantity of microplastics used
  2. Purpose and function
  3. Measures taken to prevent release

Examples include:

  • Controlled-release fertilisers
  • Certain industrial coatings and sealants
  • Medicinal or veterinary applications

17 October 2029 – 2035

Progressive Ban on Microplastics in Remaining Leave-On Cosmetics

Phased restriction for categories such as:

  • Makeup (e.g. foundation, eye shadow, highlighter)
  • Lip products (lipsticks, glosses)
  • Nail products (e.g. polish, gel nails)

Specific dates depend on product type and availability of reformulated alternatives.

17 October 2031

Ban on Microplastics as Granular Infill in Artificial Sports Pitches

One of the largest sources of microplastic pollution – full market ban begins.

Do not postpone

  1. Assess your products – Identify any intentionally added microplastics.
  2. Check classification – Is your product a mixture or an article?
  3. Gather documentation – Evidence of biodegradability or non-release is key.
  4. Start reformulating where needed — Transition periods are limited.

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