Public perception and condemnation of plastic waste in oceans, rivers and nature has heightened dramatically in recent years. The origin of plastic wastes in nature is highly diverse, and not primarily attributable to cosmetics. Nevertheless, cosmetics are also under heavy scrutiny. 

At first, pressure was focused mainly on synthetic abrasives in scrub and shower formulations; and now certain water-soluble polymers (“liquid plastic”) are also being challenged. Raw material suppliers, cosmetics producers and consumer organizations do not always see eye-to-eye on what the term plastic or microplastic refers to, and whether or not cosmetics necessarily have to contain such raw materials. The cosmetics industry has recently expressed its position on this, but there is still no standard definition at the EU regulatory level. ECHA (the European Chemicals Agency) is now addressing this very issue. 
 

Cosmetics Europe – the perspective of “industry”

As far back as 2015, Cosmetics Europe, the European trade association for the cosmetics and personal care industry, recommended that its members discontinue the use of synthetic scrub particles (microbeads) in rinse-off cosmetics by 2020. So, how does Cosmetics Europe define microplastics or microbeads?

(1)

The terms as used by Cosmetics Europe coincide with existing efforts and definitions of individual EU countries and the USA («The Microbead-Free Waters Act»). 
 

ECHA seeks a holistic solution for the EU

The lack of European legislation has already compelled a number of EU countries to regulate microbeads in “rinse-off” cosmetics at the national level. For the pan-European level, ECHA is currently investigating whether there is a need to ban microplastic particles that are in use. Cosmetic plastic beads might also fall under this category of particles. As a first step, ECHA has formulated a definition for the term microplastic. The working definition of a microplastic is:

“any polymer, or polymer-containing, solid or semi-solid particle having a size of 5 mm or less in at least one external dimension” (2)

A particle has to fulfil all of the given criteria to fall under this definition. Specifically, the definition breaks down into 4 criteria:

1. Substance: The term “polymer” is used because it is defined in the REACH regulation while the term “plastic”, for example, is not. The definition does not make the distinction between natural and synthetic polymers, yet the former are excluded from the definition per se.
2. State (solid, semi-solid)
3. Morphology (“particle shape”)
4. Particle size

In practice, this means we can characterize the following raw material groups, for example:

(3)

Going by the above criteria, substances may or may not fall under the definition of microplastics. Establishing a definition remains the basis for further discussion. After that, even more important will be identifying follow-up measures that will be suitable for microplastic substances. The fact is, not all microplastics are alike. And the question is which microplastic substances require the most caution? To answer this question, ECHA has formulated the following test questions:

• Is the substance a microplastic at the time of its use?
• Is the microplastic emitted into the environment when it is used?
• Is the microplastic poorly degradable in nature (is it “persistent”)?

Substances that meet all three of these criteria are of particular concern, and are therefore the primary object of further clarification (and potentially restrictions). ECHA intends to conclude its investigation for the identification and potential restriction of microplastics by January 2019.

 

Literature:

1. www.cosmeticseurope.eu/how-we-take-action/leading-voluntary-actions/all-about-plastic-microbeads/
2. htps://echa.europa.eu/documents/10162/13641/note_on_substance_identification_potential_scope_en.pdf/6f26697e-70b5-9ebe-6b59-2e11085de791 page 3
3. echa.europa.eu/documents/10162/13641/note_on_substance_identification_potential_scope_en.pdf/6f26697e-70b5-9ebe-6b59-2e11085de791 page 13