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ECHA RAC and SEAC Opinion on an Annex XV dossier proposing restrictions on intentionally-added microplastics


1st March 2021 - The European Chemicals Agency (ECHA) Committees for Risk Assessment (RAC) and Socio-economic Analysis (SEAC) published today their compiled final opinion on an Annex XV dossier proposing restrictions on intentionally-added microplastics. It is an important step in the restriction process, whose outcome will have a significant impact on multiple industry sectors in Europe, and the cosmetics and personal care sector in particular. 

Cosmetics Europe shares concerns over the issue of plastic pollution and as such, considers it crucial that the proposed REACH restriction delivers a tangible and meaningful benefit to the environment.

Cosmetics and personal care products are essential in all stages of life, contributing to quality of life, health, hygiene as well as mental well-being and self-esteem. Cosmetics do matter to people. The societal value of cosmetics should not be underestimated. The cosmetics and personal care industry is consumer-driven. With its wide diversity of products, it serves the needs and expectations of the hundreds of millions of people who use cosmetics every day. Thanks to the meticulous selection of ingredients, and the complex design of formula architecture, our products deliver a high-level of effectiveness and performance, providing choice and quality for all consumers.

Cosmetics Europe welcomes the recognition of the SEAC that a derogation for make-up, lip and nail care leave-on cosmetic products, which are mainly disposed via solid waste, could be proportionate1. Such measure would indeed take into account the low contribution to overall emissions as well as the huge impact on industry of a ban on microplastics in these products. A derogation would require the products to provide information to consumers on use and disposal.

We are, however, deeply disappointed that the SEAC opinion does not recommend extended transition periods for other leave-on cosmetic products. Given the complexity of leave-on formulations, the lack of suitable alternatives and the complex, costly and lengthy reformulation process, the proposed 6-year transition period is not a realistic timeframe to allow for a simultaneous reformulation of thousands of formulations so that consumers are still able to enjoy the products they love and need.

Therefore, we urge the European Commission to support the derogation for make-up, lip and nail care leave-on cosmetic products as a proportionate measure to manage microplastic emissions from these uses as well as to extend the transition periods for other leave-on cosmetic products to reflect the reality of the reformulation challenge.

As a constructive stakeholder, Cosmetics Europe has appreciated the opportunity to engage in the ECHA Annex XV REACH restriction process and provide substantive evidence representative of our market. We stand ready to continue working towards solutions that will be good for consumers, the environment and industry.


1ECHA RAC and SEAC Opinion on an Annex XV dossier proposing restrictions on intentionally-added microplastics, p. 149 and 152.



Cosmetics Europe is the European trade association for the cosmetics and personal care industry. Our members include cosmetics and personal care manufacturers as well as associations representing our industry at national level, right across Europe.

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