Plastics in cosmetics and other products are subject to a wide-ranging European restriction proposal currently entering its final stages prior to adoption by the EU regulator.
The restriction aims to address environmental concerns caused by microplastics.
The Greenpeace report refers to liquid and soluble plastics. The proposed restriction does not include liquid and soluble polymers in its extensive definition of microplastics. Environmental concerns relate to solid particles. Greenpeace, as all stakeholders, has had the opportunity to submit its views to the European Chemicals Agency (ECHA) during the consultation stage. In its report, Greenpeace does not present evidence that the approach of ECHA, supported by the ECHA Risk Assessment Committee, is incorrect or unfounded.
It is also crucial to underline that microplastics (small solid polymer particles) from cosmetic and personal care products represent a very small potential contribution to the overall aquatic plastic litter. According to the ECHA Annex XV REACH Restriction Proposal on microplastics intentionally added to products, leave-on cosmetics are estimated to contribute to only 2% of the overall emissions of intentionally added microplastics to products.
It is also important to stress that leave-on products are designed to stay on the skin for a relatively long period of time, not to go directly to the drain. Such products as for instance make-up, lip and nail care cosmetic products are mainly disposed via solid waste, which has also been acknowledged by ECHA, and therefore do not end up in wastewater.
The alternative ingredients suggested by Greenpeace have of course been tested by the industry. However, they do not meet the product performance requirements that consumer value and expect.
Last but not least, Cosmetics Europe would like to emphasize that all cosmetic products, including those containing microplastics, are safe for consumers. All cosmetic and personal care products available in the EU have to comply with very strict EU legislation and every product is covered by robust safety laws that require them to be assessed for safety. The EU Cosmetic Products Regulation governing cosmetic products is one of the most stringent and respected regulatory frameworks, which is highly protective of consumers’ safety.
 The concept of polymers as used in the ECHA restriction proposal is wider than the concept of plastics as all plastics are polymers, but not all polymers are plastics. Also see the definition of polymer in Article 3(5) of Regulation (EC) No 1907/2006 (REACH).
 ECHA RAC and SEAC Opinion on an Annex XV dossier proposing restrictions on intentionally-added microplastics, p. 18.
 Annex XV REACH Restriction Proposal – Microplastics, p. 128.
 ECHA RAC and SEAC Opinion on an Annex XV dossier proposing restrictions on intentionally-added microplastics, p. 149.