At the European level, intentionally added microplastics in cosmetics and other products are subject to a wide-ranging European restriction proposal put forward by the European Chemical Agency (ECHA), which has been working on the issue since 2017. The restriction is currently in its final stages prior to adoption by the EU regulator and aims to address potential human health and/or environmental concerns caused by microplastics intentionally added to consumer or professional use products of any kind.
The Plastic Soup Foundation’s report1 predominantly focuses on the definition of microplastics recommended by ECHA as part of the intentionally added microplastics restriction process.
ECHA’s proposed restriction includes the most extensive investigation of the definition of microplastics ever undertaken by a regulatory authority anywhere in the world. ECHA itself describes the proposal as “the most comprehensive restriction initiative in the world for reducing emissions from intentional uses of microplastics”2.
The restriction process, on which work has been ongoing for five years, has included a call for evidence, a stakeholder workshop, and two extensive public consultations, which provided the opportunity for any concerned stakeholders to submit evidence on the definition. Plastic Soup Foundation and other organizations sharing their concerns on intentionally added microplastics pollution were free to present evidence and express their view throughout the process.
The definition of microplastics recommended by ECHA was subject to thorough scrutiny by both the experts on the ECHA’s Committee for Risk Assessment (RAC) and Socio-Economic Analysis Committee (SEAC). Taking into account all evidence submitted, ECHA firmly takes the view that any potential environmental concerns relate to small, solid and persistent plastic particles. Therefore ECHA does not consider liquid, water-soluble or biodegradable polymers as microplastics.
In its report, Plastic Soup Foundation refers to biodegradable polymers. From a scientific point of view, the biodegradability thresholds for polymers proposed by ECHA are considered very stringent and the polymer biodegradability assessment ECHA recommends uses internationally ratified test methods (such as OECD test guidelines 301 B, C, D, F).
In its report, Plastic Soup Foundation also refers to nanoplastics. It is important to point out that all nanomaterials used in cosmetic products, including plastics fulfilling the criteria of a nanomaterial definition, are already regulated under the EU Cosmetic Products Regulation (EC) No 1223/2009. For example, nanomaterials need to be notified to the European Commission via the Cosmetic Product Notification Portal (CPNP). All such materials notified up till now to the CPNP have been subject to the safety review by the European Commission’s Scientific Committee on Consumer Safety (SCCS).
The Plastic Soup Foundation’s traffic light system is based on a microplastic definition rejected after expert scrutiny in the light of the evidence, and therefore highly misleading to consumers. It is not possible to assume an ingredient is a microplastic by simply referring to the ingredients INCI list - this point is also emphasized by ECHA3. Plastic Soup Foundation is more interested in unduly alarming consumers than providing them with meaningful information.
It is crucial to underline that intentionally added microplastics from cosmetic and personal care products represent an extremely small contribution to overall microplastics emissions. Based on figures included in the ECHA proposed restriction, intentionally added microplastics from leave-on cosmetics are estimated to contribute to only 0.28% of all microplastic releases in the EU4. Cosmetics Europe supports the proposed restriction on the use of intentionally added microplastics in rinse-off products and we recommended the phase-out of plastic microbeads in 2015. Therefore, we call on the Plastic Soup Foundation to address the real challenge of microplastics pollution.
Cosmetics Europe would like to emphasize that cosmetic products are safe for consumers. All cosmetic and personal care products available in the EU have to comply with very strict EU legislation requiring thorough safety assessments. The EU Cosmetic Products Regulation governing cosmetic products is one of the most stringent and respected regulatory frameworks in the world.
 Plastic Soup Foundation, “Plastic. The Hidden Beauty Ingredient” Report
 ECHA RAC and SEAC Annex to Background Document to the Opinion on the Annex XV report proposing restrictions on intentionally-added microplastics, Annex H, Question 2.18
 ECHA RAC and SEAC Background Document to the Opinion on the Annex XV report proposing restrictions on Intentionally-added microplastics, p. 6, 76-77; ECHA RAC and SEAC Opinion on an Annex XV dossier proposing restrictions on intentionally-added microplastics, Table 8
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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