REACH microplastics 2027 – shampoo, shower gel, polymer certificate & batch block | Word/PDF/Excel

Do your shampoo, shower gel or cleansing cosmetic contain synthetic polymer microparticles – and can you confirm that the formulation can be placed on the EU market after 16 October 2027? This compact document package for Swedish cosmetic companies, brand owners, contract manufacturers and importers helps you check actual polymer status, request technical evidence from suppliers, reformulate formulations and manage inventory batches ahead of the REACH restriction on intentionally added microplastics.

Regulatory status: Regulation (EU) 2023/2055 introduced REACH Annex XVII, Entry 78, on 17 October 2023. Microbeads used for exfoliating, polishing or cleansing have been covered since this date. For other rinse-off cosmetic products, a special transition period applies until 16 October 2027; the restriction applies from 17 October 2027. Intentionally added, defined microparticles of synthetic polymers in mixtures are covered when they are present to provide the desired property and reach at least 0.01 weight percent, with specific definitions, exemptions and evidence requirements. Not all polymers or INCI names are automatically covered.

Five practical working templates

1. Product classification ahead of 2027: identify SKU and formulation revision. Check whether the product is rinse-off, leave-on or another special cosmetic category, whether abrasive microbeads are present, whether the particle falls under the SPM definition and which transition period applies.
2. Supplier certificates and polymer evidence: request polymer identity, particle size and shape, intended function, concentration, testing method and evidence of any exemption. Claimed solubility or biodegradability must be assessed against the applicable testing requirements in Entry 78, Annex 15–16.
3. Reformulation and change control: plan alternative raw material, pilot batch protocol, stability and safety. Reminds especially that the product's cosmetic safety report (CPSR), product information file (PIF), ingredient labelling and CPNP notification under the cosmetics regulation may require separate updating.
4. Inventory, market release and block: record actual lot numbers, production date, documented first EU market release, recipient and internal block. Distinguishes between manufactured goods and goods that have actually been released on the market.
5. Final check and signing: separate decisions for REACH, cosmetic safety and commercial release. Excel or a supplier email can never automatically approve a product.

Excel tool with nine Swedish tabs

The tabs are Overview, Products, Ingredients, Supplier Certificates, Reformulation, Inventory Batches, Release, Actions and Sources. The formulas sum up filled-in cases and provide administrative indicators for, for example, MICROBEADS – TEST NOW, TEST 2027-10-17 and MISSING SUPPORTING EVIDENCE. A product with documented concentration below 0.01 weight percent is not automatically approved – it retains status for manual assessment. Empty rows do not count as registered products.

Example: A shampoo with documented 0.02 weight percent intentionally added SPM and complete supplier evidence is flagged for 2027 assessment. A scrub with abrasive microbeads is flagged for immediate testing. An unclear supplier certificate is flagged as missing supporting evidence. These are risk and workflow indicators and not an automated chemical analysis or authority certification.

Particularly important regarding law, exemptions and inventory

Who is covered? A product must be tested against the legal definition of synthetic polymer microparticles, relevant content and function. Also, for example, small solid particles, solubility or degradability evidence and any exemptions must be checked, not just the name in the ingredient list.

Can older inventory always be sold after 17 October 2027? No. The general legal rule about products placed on the market before 17 October 2023 does not expressly automatically exempt product categories that have special transition periods in Entry 78, point 6. The EU Commission specifies 16 October 2027 as the last day for the special rinse-off transition. Individual older batches and evidence of market placement must be assessed concretely.

Are Swedish rules changing in 2027? The government's memorandum on 3 November 2026 proposes that the older Swedish ban on cosmetics containing microplastics be removed, with a proposed start on 1 April 2027, because the EU's REACH regulation governs the area. This is yet another proposal – not an adopted Swedish law change. The EU's directly applicable REACH restriction applies regardless.

Who benefits from the package?

Small and medium-sized cosmetic brands, private-label companies, shampoo and shower gel manufacturers, hygiene product developers, importers and responsible persons under the cosmetics regulation who need to document raw material assessment and release decisions. For loose plastic glitter, plastic pellets or regular cleaning products outside the cosmetics regulation, a separate regulatory review is required.

Frequently asked questions

Are all synthetic polymers in shampoo banned from October 2027?

No. REACH Entry 78 applies a special definition of microparticles of synthetic polymers and certain concentration, function, transition and exemption conditions. A polymer name on the INCI list does not prove that the product is banned.

Is 17 October 2027 also the end date for scrub particles?

No. Microbeads used for exfoliation, polishing or cleansing have been covered since 17 October 2023. They must be tested immediately, also against current Swedish national rules.

Can I use the supplier's certificate of "biodegradable" without more information?

Not without assessing whether the supplier actually supports the legal exclusion with relevant test methods and criteria according to REACH Entry 78 and Annex 15 or 16.

Can old packaging and batches be sold after 17 October 2027?

It is not possible to answer generally yes. Document when a product was actually placed on the EU market and apply the correct transition rule. The product contains a special batch and inventory check but no automatic legality stamp.

Do I get a finished PIF, safety report or EU notification?

No. The documents help with change control and evidence but do not replace the cosmetic safety report, PIF, CPNP, necessary testing or other legal and technical review.

Are all documents in English?

Five main templates and Excel are in Swedish. Swedish guide and separate English User Guide are included. The PDF files are searchable and printable, but not digitally fillable forms.

Sources and transparency

Regulation (EU) 2023/2055 – REACH Annex XVII Entry 78; Swedish Chemicals Agency – cosmetic regulations; EU Commission guidance; government memorandum 3 November 2026 and cosmetics regulation (EC) 1223/2009.

Version 1.0, 9 November 2026. AI-assisted internal legal source check has been carried out, but no independent external legal review, chemical testing, product certification or approval by a cosmetic safety assessor has been carried out. The document package is an internal working aid and no guarantee that a certain ingredient or product is permitted. Digital customer files are delivered as a ZIP only when the store owner activates the product and connects the download separately.