PLASTIC THE HIDDEN BEAUTY INGREDIENT - An analysis of the use of microplastics in personal care products and the upcoming legislation covering ...
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PLASTIC THE HIDDEN BEAUTY INGREDIENT An analysis of the use of microplastics in personal care products and the upcoming legislation covering intentionally added microplastics
About
THE PLASTIC SOUP
FOUNDATION
T
DISLAIMER he Plastic Soup Foundation was
The information in this report has been founded in February 2011. Our goal is
obtained in good faith from sources that are to make the general public and other
believed to be reliable. We accumulated the stakeholders familiar with the phenomenon of
product level data via the Beat the Microbead “plastic soup” and to stop it at its source. As
app users. We requested input on this data, long as the supply of plastic to our rivers, seas
the perspective and policy on microplastics and oceans is not stopped, it’s like trying to
from the brand owners involved. The text of empty the ocean with a thimble.
this report is composed with utmost care We are a single-issue organisation, focused
and reflects the interpretation and opinion entirely on plastics. With a committed and
of Plastic Soup Foundation on the date of passionate team of about thirty people, we do
publication of this report. However, Plastic our utmost to achieve our goal: no plastic in
Soup Foundation cannot exclude and cannot our water or our bodies!
be held liable whatsoever for any inaccuracies
or incompleteness of the data or this Designed by: Diewertje van Wering
report. Published in: April 2022
Supported by:
2
TABLE OF
contents
LIST OF FIGURES 04 3.2. Where do these brands stand? 20 5. RECOMMENDATIONS 38
LIST OF BOXES 04 3.2.1. L’Oréal: “Plan for the future” 21 5.1. Recommendations for decision-makers 38
LIST OF ABBREVIATIONS 04 L’Oréal Paris: “Because Our Planet is 5.2. Recommendations for the cosmetics
GLOSSARY 05 Worth It” 21 industry 38
Elvive/Elseve: take on sustainability 22 5.3. Recommendations for consumers 38
EXECUTIVE SUMMARY 06 Garnier: ideas on how to protect
KEY FINDINGS 07 the ocean 23 END NOTES 40
3.2.2. Beiersdorf: “Care beyond Skin” 24
1. CONTEXT: THE OMNIPRESENCE OF Nivea: plan to phase out microplastics 25 ANNEXES 44
MICROPLASTICS 09 3.2.3. Procter & Gamble: “It’s our home” 26 ANNEX I: Beat the Microbead campaign
1.1. The reasons for concern 09 Gillette: plan to become transparent 27 and app 44
1.2. Making the invisible visible 10 Oral-B: revolution without change 28 ANNEX II: Our methodology 46
1.3. Europe’s restriction on intentionally Head & Shoulders: packaging, packaging, ANNEX III: Letter to targeted brands 48
added microplastics 11 packaging! 29 ANNEX IV: The forgotten synthetic polymers and
1.4. Aims of this report 11 3.2.4. Unilever: “Small Actions can Make a their environmental and human health
Big Difference” 30 concerns 50
2. MICROPLASTICS THROUGH THE EYES Dove: reducing virgin plastic 31
OF POLITICS AND SCIENCE 12 Rexona: sustainability plans not found 32
2.1. It’s all in the definition of microplastics 12 Axe: masculinity above planet 33
2.2. Science-based red flags 14 3.3. Bird's-eye view: a need for more action 33
2.2.1. Water-Soluble Polymers , liquid
and semi-solid polymers 14 4. A FUTURE FILLED WITH INTENTIONALLY
2.2.2. Engineered nanoplastics 15 ADDED LOOPHOLES 36
2.2.3. Biodegradable Polymers 16 4.1. A wall to hide behind 36
2.3. No data, No Market 17 4.2. Greenwashing could become
uncontrollable 36
3. TEN BRANDS UNDER THE MICROSCOPE 19 4.3. A problem for the future 36
3.1. A deep dive into Europe's popular
consumer brands 20
3
TABLE OF
contents
LIST OF FIGURES LIST OF ABBREVIATIONS
Figure 2.1 Ingestion of nanoplastics & plastic ADHD: Attention Deficit Hyperactivity Disorder
in blood and organs 15 BTMB: Beat the Microbead
Figure 2.2 Dying immune cells 16 CMR: Carcinogenic, mutagenic or toxic
Figure 2.3 Mineralisation 16 for reproduction
Figure 3.1 Microplastics in L’Oréal Paris ECHA: European Chemicals Agency
products 21 EC: European Commission
Figure 3.2 Microplastics in Elvive/Elseve EU: European Union
products 22 H&S: Head & Shoulders
Figure 3.3 Microplastics in Garnier products 23 PBT: Persistence, Bioaccumulation, Toxicity
Figure 3.4 Microplastics in Nivea products 25 PET: Polyethylene Terephthalate
Figure 3.5 Microplastics in Gillette products 28 P&G: Procter & Gamble
Figure 3.6 Microplastics in Oral-B products 29 PMMA: Poly(methyl methacrylate)
Figure 3.7 Microplastics in Head & Shoulders PP: Polypropylene
products 30 RAC: Risk Assessment Committee
Figure 3.8 Microplastics in Dove products 32 REACH: Registration, Evaluation, Authorisation
Figure 3.9 Microplastics in Rexona products 33 and Restriction of Chemicals
Figure 3.10 Microplastics in Axe products 33 TAUW: Technisch Adviesbureau van de Unie
van Waterschapsbonden
LIST OF BOXES UNEP: United Nations Environmental Program
Box 1.1 Plastics may affect our health 10 WSPs: Water-Soluble Polymers
Box 2.1 Microplastic proposed definition 13
Box 3.1 Guide to microplastics 19
Box 3.2 Overview of European popular
cosmetic brands' sustainable plans 34
Box 4.1 Greenwashing 37
4
GLOSSARY
Bioavailability: The extent to which a substance Microplastics: The term ‘microplastic’ is not biodegradation. Persistency is a cause of concern
is absorbed by a living organism. Small plastic consistently defined but is typically considered and as environmental concentrations will inevitably
particles such as microplastics and nanoplastics not limited to refer to small solid particles made of increase with the continuous release of a persistent
can enter bodies via ingestion and inhalation. They a synthetic polymer. They are associated with long- substance. With increasing environmental
are so small that they can cross biological barriers term persistence in the environment if released, concentrations, the probability of adverse effects
in the gut and lungs, reaching the blood stream as they are very resistant to biodegradation. In will increase as well. Once adverse effects are
and consequently other organs. cosmetics, 'microplastic' refers to all types of observed, reversing contamination could take
plastic particles intentionally added to personal centuries, or even longer.
Chemical toxicity: The degree to which a care & cosmetic products. This definition continues
chemical substance can cause adverse health to evolve in accordance with ongoing relevant Planetary boundaries: Planetary boundaries
and environmental effects. Chemicals are added scientific research. are thresholds within which humanity can survive,
to plastics to give them certain characteristics, develop, and thrive for generations to come. It is a
for example flexibility, durability, or colour. Some Nanoplastics: The exact cut-off between concept highlighting human-caused disturbances
plastic additives have been associated with serious a microplastic and nanoplastic is a subject of Earth system processes. There are nine
health problems such as hormone-related cancers, of ongoing debate. In this report we define boundaries created for a safe operating limit for
infertility, and neurodevelopmental disorders such nanoplastics as 0.1 micrometre (which equals survival. They include climate change, biodiversity,
as ADHD and autism. 100 nanometres) or less in size. These particles and deforestation.
tend to be smaller than or close to the size of
Leave-on cosmetics: Leave-on products intended viruses. Engineered nanoplastics are deliberately Polymer: A polymer is a natural or synthetic
to stay in prolonged contact with the skin, hair, or manufactured plastics for use in various products. substance consisting of very large molecules,
mucous membranes. These include body creams, Secondary nanoplastics are generated as a result called macromolecules, composed of many
sunscreens, hair sprays, make-up, et cetera. of the fragmentation of larger plastics. repeating subunits (monomers). Plastic is an
example of a synthetic polymer. Polysaccharides
Microbeads: Microbeads are tiny plastic particles Particle toxicity: The degree to which a particle are an example of a natural polymer, imagine your
that are intentionally added to personal care can cause adverse health effects. A well-known pasta, cereals, or bread!
products. They are commonly used in exfoliating example of particle toxicity is the air pollutant black
products and toothpaste. The microbeads carbon. Black carbon can lead to various lung Rinse-off cosmetics: Rinse-off products are
that the industry refers to are mainly made of conditions including cancer. intended to be washed off after application on
Polyethylene (PE) and Polymethyl Methacrylate the skin and hair. These include shower gels, face
(PMMA). Microbeads are also considered to be Persistency: Persistent substances remain in the washes and shampoos.
microplastics. environment for a long time, as they are resistant to
5
EXECUTIVE
summary
E
ach year about 3800 tonnes of microplastics adverse environmental and human health impacts. brands to gain information on any future plans on
are released into the environment through removing plastics from inside their products.
the use of everyday cosmetics and care With so many synthetic polymers exempted, This report provides a comprehensive analysis of
products in Europe. This is an estimation the the aim of the proposed restriction legislation the proposed definition of microplastics and its
European Chemicals Agency (ECHA) made after would be undermined. We want to stress the shortcomings. In particular, we demonstrate that if
the European Commission (EC) requested them to need for adopting the precautionary principle for this definition is adopted as proposed by ECHA, it will
submit a proposal for restricting intentionally added all synthetic polymer groups when developing have regrettable consequences. From the respons-
microplastics in certain products. The European new regulatory measures. The unjustified delays es that we received from the 4 cosmetic producers,
Union (EU) wants to restrict intentionally added because of the transition periods granted to the we observed that they hide behind ECHA’s pro-
microplastics in products such as cosmetics that cosmetics industry could potentially allow pollution posed definition to keep using microplastics that are
pose a potential risk to the environment and to to continue for up to 8 years. What’s more, an derogated. Consequently, the measures that these
human health.This restriction is on the horizon and inadequate piece of legislation gives the cosmetics producers take to tackle the microplastics in their
is expected to be adopted the end of 2022. industry the opportunity to work around restrictions products do not go far enough, which will result in
and continue their reliance on synthetic polymers. continuous releases of synthetic polymers from their
A central focus of ECHA’s restriction proposal By overlooking these consequential drawbacks, the products. We believe not only that the cosmetics
for the EC is to establish a definition of European Commission might also be undermining industry could take advantage of this situation by
microplastics. Unfortunately, ECHA’s proposed its own goal to make businesses accountable for using deceiving green claims, but also that con-
definition of microplastics is limited and has their green claims. sumers would find it even harder to make conscious
various loopholes, corresponding with industry decisions in choosing microplastic-free products.
lobbying positions. The current proposed definition To highlight this strong dependency of the cos-
excludes nanoplastics, water-soluble, liquid, and metics industry on plastic ingredients, we looked With this report we aim to invite the EC and the EU
biodegradable polymers. Therefore, we believe into the 10 most popular consumer brands of the 4 member states to close the loopholes and take
that ECHA’s figures (of microplastics released into biggest cosmetic producers in Europe. The brands the opportunity to deal with all intentionally added
the environment every year through cosmetics) are L’Oréal Paris, Elvive/Elseve, Garnier, Nivea, Gillette, microplastics once and for all. We want to urge the
have been thoroughly underestimated. Moreover, Oral-B, Head & Shoulders, Dove, Rexona, and Axe. We cosmetics industry to look beyond the proposed
if a synthetic polymer has been exempted from examined their product level information via citizen definition by ECHA, to ensure the environmental and
the proposed restriction on microplastics, it doesn't science efforts from the Beat the Microbead app us- human health safety of the products they bring on
mean that it has been proven to be safe. We want ers. We also evaluated public commitments made the market. We want to encourage consumers to
to take this report as an opportunity to present by the brands and their producers, as well as their demand transparency from brands and account-
a science-based review explaining why these policies on tackling the microplastic menace. Fur- ability for the ingredients these brands put into our
exempted polymers could potentially also cause thermore, we reached out to the producers of these personal care and cosmetic products.
6KEY
findings
9 out of 10 products Why scientists are worried Only 1 out of 10 brands
contain microplastics about the exemptions mention microplastics*
From the 10 popular brands registered in our • Water-soluble polymers (WSPs), • Looking closer at sustainability plans
database whose products we analysed (7.704 in liquid & semi-solid polymers: and the public commitments of the popular
total), we found that 9 out of 10 products contain WSPs are presumed to be present in the environ- consumer brands, as well as their response
microplastics according to our traffic light system ment based on their production volumes and to our letter (see Annex III), it became evident
to categorise products (see chapter 3). More high potential for environmental discharge. that not enough is being done to address the
precisely, microplastics accounted for 87% of the Their distribution, concentrations, and impact microplastics pollution caused by the personal
products. Our personal care and cosmetic products are unfortunately still highly unclear. Moreover, care and cosmetic products of these brands.
are riddled with plastic ingredients. little is known about the degradation products of
many WSPs, and their persistency and toxicity. In • Only 1 (Nivea) out of 10 brands made a direct
The exemptions are addition, the use of liquid, semi-solid and water- mention of the term 'microplastics' in their
undermining the purpose soluble plastics in cosmetic products greatly public plans. At the parent company level,
The stakes are high for an EU-wide initiative exceeds that of solid plastics. A commonly used only Beiersdorf and Unilever (2 out of 4) have
to take essential measures that will control a liquid polymer in cosmetics (dimethicone) public plans on tackling microplastics. Their
large amount of unnecessary microplastics. has been identified as a potential risk to the understanding of microplastics is limited to solid,
The proposed definition of microplastics under environment. This illustrates that these polymers insoluble particles of plastic smaller than 5mm.*
ECHA’s restriction proposal contains a number of should not be presumed benign.
derogations. With their current restriction proposal, • There is a clear need for more sincere actions
ECHA aims to address the environmental and • Engineered nanoplastics: to fight microplastic pollution arising from the
human health risks posed by microplastics. By Nanoplastics can easily cross biological barriers content of these products. The cosmetics industry
exempting engineered nanoplastics, water- and exert toxic effects, even more so than is already defending their use of WSPs, liquid
soluble, liquid and biodegradable polymers in their microplastics. and biodegradable polymers with the current
proposal, we argue that ECHA undermines the restriction proposal by ECHA. They argue that
purpose of its own proposal. • Biodegradable polymers: the synthetic polymers in their products are not
Real-world conditions are poorly reflected in cur- microplastics according to the definition in ECHA’s
rent standardised tests to assess the biodegra- proposal and hence do not pose a threat to the
dation of biodegradable polymers. Consequently, environment.
biodegradable plastics can still persist in the
environment. Additionally, various concerns about
their toxicity exist.
7 *Redaction 05/2022: As a result of reassessment of the table on page 34, we came to a conclusion that only 1 out 10 brands (Nivea) mention
the word microplastics in their public sustainaility plans. For detailed explanation, please see page 58.KEY
findings
Plenty of opportunities The European consumer market is one of the
for greenwashing biggest in the world. European laws will influence
By adhering to ECHA’s current proposal, which markets around the world. A strict EU law that
excludes engineered nanoplastics and soluble, regulates all intentionally added microplastics will
liquid, and biodegradable polymers, the cosmetics have a far–reaching impact on the global fight
industry would still be able to use plastics in nano, against the microplastics menace.
soluble, liquid, semi-solid and biodegradable
form. However, the environmental safety of
these ingredients cannot be guaranteed, and
any green claims may therefore be false. If the
upcoming legislation adopts the definition and
derogations proposed by ECHA, it may enable the
cosmetics industry to make misleading claims and
advertisements, such as ‘microplastic-free’ and
‘biodegradable ingredients’. It will leave more room
for greenwashing to be rampant, which would leave
consumers even more confused.
A future-proof legislation is key
With so many unknowns and potential risks for
environmental and human health, we call upon the
European Commission to adopt the precautionary
principle and include engineered nanoplastics,
water-soluble, liquid, semi-solid and biodegradable
polymers in their restriction proposal. The coming
years will be crucial for creating a future-proof
restriction on microplastics that potentially pose a
risk to the environment and to human health.
81 Context:
THE OMNIPRESENCE
OF MICROPLASTICS
P
lastic pollution is ubiquitous and far- wide variety of products, for example cosmetics,
reaching. Plastics are found in the water we paint, pharmaceuticals and agricultural products
drink, the food we eat, and the air we breathe. such as fertilisers. In Europe, each year around
There’s no corner of our planet left untouched by 42,000 tonnes of this irreversible pollution end up in
microplastic pollution. Plastics have infiltrated our the environment when products containing mi-
food chain at all levels. This should not come as a croplastics are used.1
surprise considering we live in a highly plasticised
world. From everyday products such as food Microplastics have been found at the highest
packaging and textiles to building materials and point on Earth, in the Himalayas, and at the lowest
industrial machinery, every industry uses plastic as points of our planet, such as the Mariana Trench.
a common ingredient. Microplastics have been found in all kinds of water
bodies on our planet. Once they end up in the
Microplastics are an (un)intended product of our environment, microplastics are almost impossible
plastic world. The term ‘microplastic’ is not defined to remove. In this sense, we are causing irreversible
consistently but only loosely as a plastic particle pollution via our seemingly harmless everyday
smaller than 5 mm. These particles are associated products.
with long-term persistence in the environment,
as they are very resistant to biodegradation. The reasons for concern
Microplastics can be generated through the In some cases, plastic can constitute up to 90% of
fragmentation of bigger plastic waste that ended the ingredients added to a cosmetic product.2 Once
up in the oceans and other ecosystems. These used, these microplastics, hardly visible to the na-
small pieces of plastics are often also referred to ked eye, flow straight from the bathroom drain into
as secondary microplastics because they were not the sewer system. Wastewater treatment plants are
intended to end up as microplastics. They are the not capable of filtering them out completely; that
result of the disintegration of plastic products that is how microplastics from cosmetics contribute to
broke down into ever smaller plastic pieces. the ‘Plastic Soup’ in our oceans. The microplastics
removed in wastewater treatment plants are also
The other type of microplastics – the primary or trapped in the sludge3, which is then applied to our
engineered microplastics – are deliberately man- agricultural soil as fertiliser. Consequently, our soil is
ufactured plastic particles which are added to a also contaminated by microplastics.
9Context:
THE OMNIPRESENCE
OF MICROPLASTICS
PLASTICS MAY AFFECT
our health
After ending up in the environment, these for exfoliation purposes. Since then, the Beat the
microplastic ingredients attract and absorb Microbead (BTMB) campaign has successfully
• Once ingested or inhaled, microplastics contaminants as if they were little magnets and raised awareness about microbeads as well as
can enter our bodies. Recently, ground- sponges. The particles become polluted and are other plastic ingredients. We accomplished this
breaking research showed that plastic eaten by organisms; the ingested microplastics by accumulating information on these ingredients,
is present in human blood. Once in our
can then be passed along the food chain. Since and reaching out on a large scale to brands,
blood, these plastics can travel to other
humans are ultimately at the top of this chain, we governments, and people.
parts of our bodies. Our immune system
also ingest microplastics and the chemicals added
will react to these plastic trespassers,
to these plastics. One of the earliest accomplishments of the BTMB
yet it is not equipped to deal with non-
campaign was to get multinational company
biodegradable objects. The immune
system may continue attacking these Using a variety of cosmetics and care products is, Unilever to promise in December 2012 to phase
plastic particles, which may in turn lead amongst others, one of the prominent ways our out microbeads from their entire product range.
to inflammation. Chronic inflammation bodies are exposed to microplastics. Over recent In 2013, this commitment was also adopted by the
is associated with numerous health years the scientific community has expressed biggest personal care & cosmetics brands in the
conditions such as auto-immune concerns about the human health hazards of world such as L’Oréal, Colgate-Palmolive, Beiersdorf,
diseases and cancer. microplastics. Plastics may affect our health in Procter & Gamble, and Johnson & Johnson. This
different ways (See box 1.1). move resulted in the removal of microbeads from
• Plastic products contain chemical all rinse-off products under the European Union
additives, and these can leach into our Our dependence on plastics in its multiple shapes Ecolabel.
bodies. A number of these chemicals and forms is not only a threat to our environment
have been associated with serious health but it may also have an impact on our health.4 Since the beginning of our campaign, 15 coun-
problems such as hormone-related can-
Plastic pollution is not just an environmental crisis tries have taken steps to ban microbeads. Our
cers, infertility, and neurodevelopmental
but also a human health issue. continuous campaigning put this topic on the map
disorders such as ADHD and autism.
and made the issue of microplastics in cosmetics
• Plastics in the environment attract Making the invisible visible a global concern. We may have been victorious in
micro-organisms, such as harmful We started campaigning against microbeads the battle, but the war is yet to be won. Microbeads
bacteria (pathogens). If microplastics in 2012, highlighting the 5 kinds of microbeads in cosmetics were just the tip of the iceberg. Thanks
containing these pathogens enter our made of Polyethylene, PET, PMMA, PP & nylon. to studies that followed, we now know that there
body, they may increase the risk of These spherical shaped beads were used in are hundreds of other plastic ingredients widely
infection. rinse-off products such as toothpaste and scrubs used in cosmetics and personal care products.
Box 1.1
10Context:
THE OMNIPRESENCE
OF MICROPLASTICS
The European Commission shares these concerns Aims of this report Lastly, we want to push the industry to take greater
and has started looking into restricting these With this report we aim to explain the potential responsibility for the substances they bring to our
intentionally added microplastics inside our care shortcomings of the upcoming European legislation markets and our everyday products. We want
products. But restricting these plastic ingredients on 'intentionally added microplastics'. The purpose to plead with regulators to not miss this golden
won’t be an easy task. of this legislation is to protect environmental and opportunity to deal with all intentionally added
human health from microplastic pollution. Some microplastics once and for all and to come up with
Europe’s restriction on intentionally types of microplastics might be exempted and a future-proof policy that leads the way for the rest
added microplastics we will present a science based review explaining of the world to follow. We want to ask consumers
In 2018, the EU’s ‘plastics strategy’ was published. In why these exemptions could also have adverse to demand transparency from brands, choose
its strategy, the EU recognises the serious negative environmental and human health impacts. zero plastic in their care and cosmetic products
effects plastics can have on the environment and Exempting these microplastics would be underming and make their voices heard in demanding a truly
human health. Therefore, the EU is taking measures the purpose of the upcoming legislation. We will microplastic-free future.
to tackle plastic pollution and marine litter. A stress the need for including a broader definition
central focus in the plastics strategy is to restrict of microplastics that is not limited to solid particles
“intentionally added microplastics that pose a risk (see chapter 2). As the EU is already working with
to the environment and/or to human health”. The a 'no data, no market' approach when it comes to
EU aims to restrict the use of microplastics that are chemicals, the precautionary principle should work
intentionally added to products such as cosmetics, in our favour where there is not enough information
detergents, paint, and pesticides. available on these substances (see chapter 2).
Although this restriction would be the first of its kind With this report we also want to seize the oppor-
and will initiate similar conversations worldwide, tunity to warn about how an inadequate piece of
it might not be free of limitations. We are worried legislation will enable the cosmetics industry to use
that not all synthetic polymers will be included in green claims such as 'microplastic-free' or 'biode-
this upcoming restriction on 'intentionally added gradable ingredients' on their products. However,
microplastics'. Decisions at this stage are crucial the environmental safety of these ingredients can-
in determining whether Europe’s future will be not be guaranteed, and these claims may there-
truly microplastic-free or not. Such loopholes can fore be false. Hence, the upcoming legislation may
jeopardise the integrity of the effectiveness of this enable the cosmetics industry to make misleading
restriction. claims and advertisements.
112 Microplastics
THROUGH THE EYES OF
POLITICS AND SCIENCE
T
he EU decision-makers are at a crucial as cosmetics, detergents, and agricultural products
crossroad. The decisions made at this point such as cosmetics, detergents, and agricultural
will either ensure a future-proof policy on products5. ECHA presented their final opinion to the
intentionally added microplastics, or it will create a EC in February 20216, together with the opinions of
backlog of problems that will have to be addressed its scientific committees7.
in the future. It all started in 2018 when the EU’s
‘plastic strategy’ was published. In this strategy, the The scientific data gathered by ECHA is loud and
EU recognises the serious negative effects plastics clear: microplastics pose a serious risk to the
can have on the environment and human health. environment, a source that is undeniably out of
Therefore, the EU is taking measures to tackle control8. ECHA wants to prevent 500,000 tonnes
plastic pollution and marine litter. of microplastics that would be released to the
EU environment (and to our food and water) over
In 2019, the European Commission (EC or Com- a 20-year period9. The European Commission will
mission) published the European Green Deal. This come up with a proposal for legislation to achieve
is a set of policy initiatives with the aim of making this goal. It is for the Commission to determine MICROPLASTICS
the European Union climate neutral in 2050. It also the extent to which the final text will follow ECHA’s
introduces new legislation on the circular econo- proposal. Once they have presented their proposal,
my, building renovation, biodiversity, farming, and the EU Member States will vote on it after which the
innovation. The Green Deal follows up on the EU’s European Parliament and Council will have a three
2018 plastic strategy and proposes measures to months scrutiny period to review it, before eventual
encourage Europe to adopt a sustainable approach final adoption.
to plastics. This will lead to rules and targets for
different areas, including single-use plastics, plastic It’s all in the definition of microplastics
packaging, microplastics, and biobased, biode- The EU is truly leading the way by investigating
gradable, and compostable plastics. a legislation to restrict intentionally added
microplastics. This restriction will be the first of its
Already in 2017, the European Commission kind in the entire world. However, in line with industry
requested the European Chemicals Agency lobbying positions, ECHA’s proposed definition of
(ECHA) to formulate a proposal for a restriction on microplastics is limited with various loopholes.
‘intentionally added microplastics’ in products such This is evident in the discussions and decisions
12Microplastics
THROUGH THE EYES OF
POLITICS AND SCIENCE
made around the central topic of this upcoming There are multiple problems here: not all synthetic products and six years to remove them from
legislation: defining microplastics. polymers have been included in this proposed defi- ‘leave-on’ products.
nition. For instance, all solid plastics smaller than
Defining microplastics is the most important 0.1 µm are outside of the scope. That means these The current derogations and long transitional
aspect of such an undertaking as it could ensure plastics would still be allowed in our care products. periods in the proposal will considerably undermine
the reduction of microplastics leaking into our All water-soluble, semi-solid and liquid polymers the capacity of the restriction to achieve its
environment considerably. The current proposed are also excluded from this definition, focusing only objective. On top of this, microplastic pollution will
definition is a good start, but it is still far from on synthetic polymers in solid form. Additional- continue for almost another decade. Such long
complete. ECHA suggested to define microplastics ly, ‘biodegradable’ plastics escape this restriction transitional periods to adapt to the law would
as10 (See box 2.1): proposal as these have also been derogated from mean allowing tonnes of microplastics to enter the
the proposal. The Plastic Soup Foundation consid- environment. A number of other organisations in
MICROPLASTIC ers ECHA’s definition of microplastics too limited, Europe share our concerns. Together, we drafted a
proposed definition as environmental and human health concerns also position paper that outlines these points at length.11
exist for the derogated groups. We also argue that
an inadequate piece of legislation gives ample These long periods for adaptation are even more
room for the cosmetics industry to work around the worrying when the Commission itself is delaying
‘microplastic’ means particles restriction and continue their reliance on synthetic delivering a proposal. The Commission should have
containing solid polymer, polymers (see Chapter 4). delivered a proposal in May 2021 (in accordance
with the legal deadline set in REACH, Art. 133(4)).
to which additives or other The cosmetics industry uses 8,700 tonnes of Yet, no proposal has been put forward. Because
substances may have been microplastics every year, and according to of unclear reasons, the process is delayed. The
added, and where ≥ 1% w/w ECHA an estimated 3,800 tonnes find their way adoption of this restriction is now foreseen by the
of particles have (i) all into the environment annually. Considering that end of 2022.12
many synthetic polymers escape the scope of
dimensions 0.1 µm ≤ x ≤ 5 mm, the proposed restriction, we believe that these ClientEarth and the European Environmental Bureau
or (ii), a length of 0.3 µm ≤ x ≤ figures are much higher than ECHA estimates. (EEB) have calculated that a yearlong delay could
15 mm and length to diameter Additionally, long transitional periods are see levels of around 42,360 tonnes of additional
ratio of >3. introduced that will delay the entry of the ban microplastics emitted into the environment through
into force. The cosmetics industry would get four cosmetics, detergents, paints, and fertilisers. This is
Box 2.1
years to remove microplastics from ‘rinse-off’ equivalent to 1.6 billion plastic bottles. Since 2017,
13Microplastics
THROUGH THE EYES OF
POLITICS AND SCIENCE
when the Commission first asked ECHA to come principle underpins REACH. changes to natural ecological processes.16
up with a proposal for a restriction, 169,441 tonnes Some WSPs are very slowly degraded in the
of microplastics (or 6.4 billion plastic bottles) are Similar concerns exist for microplastics as those environment and can therefore persist for a long
estimated to have already been released into the of persistent, bioaccumulative and toxic (PBT) time. Other WSPs are more prone to degradation
environment.13 chemicals. Therefore, an EU-wide restriction and degrade into various transformation products,
on microplastics is justified. Unfortunately, by which can be persistent and toxic. Polyacrylamide
The longer it takes the EC to submit its proposal, the exempting so many synthetic polymers in the (PAM) is a prominent example of this as the
more microplastics will end up in the environment. restriction, many synthetic polymers with PBT monomer acrylamide is a known neurotoxin and
Therefore, the restriction process must no longer be concerns will continue to be used in cosmetic potential carcinogen. Moreover, transformation
delayed. products. In the following sections we will address products of WSPs have the potential to cross
these concerns for engineered nanoplastics (< 0.1 biological cell membranes. The extent to which
Science-based red flags µm), water-soluble, liquid, and semi-solid polymers WSPs and degradation products are present or
Synthetic polymers are the main constituent of and biodegradable polymers. accumulating in drinking water, surface water,
plastics, resins, coatings, and paints. They are also sediments or soil is not investigated due to lacking
used in cosmetics, personal care products and Water-soluble, liquid, analytical tools; therefore, despite the increasing
a variety of other products. We and our environ- and semi-solid polymers exposure to WSPs, the environmental and health
ment are widely exposed to these polymers on a Water-soluble polymers risks resulting from them remain highly uncertain.17 18
daily basis. Over the years scientific research has Synthetic water-soluble polymers (WSPs) are
pointed out the various environmental and human plastics that ‘dissolve, disperse or swell in water’. Liquid and semi-solid polymers
health hazards of plastics. Nevertheless, synthetic Useful properties in many applications, these Some synthetic polymers are used in a liquid, or
polymers have so far been exempted from reg- plastics are therefore used in paints, building semi-solid phase, when being applied in products.
istration under the European chemical regulation materials, personal care products and agricultural Depending on their molecular structure, these
REACH.14 Under the REACH regulation, the 'no data, products, among other things. Many of these uses polymers can be water soluble or form insoluble
no market' principle is at play. Meaning, the REACH however enable direct or indirect discharge into droplets. The phase of a polymer depends not only
regulation holds the industry accountable for man- the environment. Annual production volumes of on the monomers that make up the (co)polymer
aging the risks from chemicals and providing safety WSPs are estimated in the millions of tons range but also on properties like chain length, degree of
information on the substances.15 Producers and in Europe alone, and this combination results in crosslinking and molecular weight. In addition, the
importers are required to gather information on the a high potential for the presence of WSPs in the ratio of different monomers in copolymer material
properties of their chemical substances, which will environment. When present in sufficiently high can also determine the phase of the polymer19.
allow their safe handling. Thus, the precautionary concentrations, WSPs could cause long-lasting
14Microplastics
THROUGH THE EYES OF
POLITICS AND SCIENCE
German figures illustrate that the use of liquid Engineered nanoplastics
and semi-solid polymers in cosmetic products Though the exact cut-off between a microplastic
greatly exceeds the use of solid polymers. Every and nanoplastic is a subject of ongoing debate,
year 23,700 tonnes of soluble, semi-solid and liquid nanoplastics are often defined as 100 nanometres
polymers enter the wastewater system due to the or less in size. These particles tend to be smaller
use of cosmetic products, compared to 922 tonnes than or close to the size of viruses. Engineered
of solid synthetic polymers (Microplastics
THROUGH THE EYES OF
POLITICS AND SCIENCE
DYING MINERALIZATION
immune cell s
in the gut, lung, placenta and brain, even more
so than larger plastic particles. Consequently,
nanoplastics are able to reach the blood, reach
organs and even the foetus24 (See figure 2.1). To
what extent nanoplastics accumulate in bodies or
are excreted remains to be investigated.
Thirdly, once in our body, the particle can exert
toxic effects (particle toxicity – see glossary).
A more well-known example of particle toxicity
Polymer Colonization of polymer
is black carbon, where exposure to the particle
entering soil. surface by soil bacteria
has been linked to the development of lung
and fungi.
diseases including cancer. Particle toxicity has
also been demonstrated for plastics and includes
immunotoxic effects, inflammation, DNA damage
CO2 CO2
and cellular damage, among other things25 (See
figure 2.2). Many features of plastics such as size,
shape and chemical make-up ultimately determine
the extent of particle toxicity. Nanoplastics are
potentially more toxic than larger particles as it
has been suggested that toxicity increases with
decreasing particle size26 27.
Biodegradable Polymers
A relatively new group of polymers are Breakdown of polymers Utilization of polymer
biodegradable polymers, and they can be made by microorganisms degradation products
from renewable feedstocks (biobased) or fossil by microorganisms
fuels. Biodegradable plastics are designed for
conversion into CO2, methane, biomass and
mineral salts by microorganisms, a process called
mineralisation (See figure 2.3). The speed and
Figure 2.2 Figure 2.3
16Microplastics
THROUGH THE EYES OF
POLITICS AND SCIENCE
degree of biodegradation in the environment, tests have been developed for chemicals, and
however, is largely dependent on the prevailing not specifically to assess the biodegradation
conditions (e.g. temperature, humidity) and of plastics. For engineered microplastics used
fragments of the biodegradable polymer may in cosmetic products, most approved tests use
remain in certain environments over long time average temperatures of at least 20 °C and
scales. oxygen-rich conditions. While these experimental
conditions may be useful for determining the
Biodegradable plastics should not be confused maximum degree of biodegradability, they poorly
with biobased plastics or compostable plastics. reflect relevant environmental conditions such
Biobased plastics are derived from biological raw as colder climates and low oxygen availability. In
materials (for example starch) and can but do those conditions, microbial activity may be much
not necessarily have biodegradable properties. lower and hence, also biodegradation rates are
Compostable polymers require very specific lower28. Consequently, biodegradable plastics may
conditions present in industrial composting facilities still persist in the environment. It has therefore
for their degradation. Though developed as an been argued that current standardised tests are
'environmentally friendly' alternative to conventional not rigorous enough and that degradation under
plastics, various questions regarding the actual field conditions should be studied in order to
persistency and toxicity of biodegradable polymers calibrate the standards29. Concerns also exist with
remain. regards to the presence of hazardous chemicals,
as chemicals contained in biodegradable
Different standardized laboratory tests are used plastics can have similar toxicity as conventional
to assess the biodegradation of plastics, for plastics30. Chemicals and micro-sized particles of
example in water, aquatic sediments, or soil. biodegradable materials have also been shown to
Depending on the plastic application, different adversely affect marine and freshwater organisms,
tests have been approved by the European crop growth, as well as soil quality and bacteria
Chemicals Agency, making use of standards amongst others.
developed by the Organisation for Economic
Co-operation and Development (OECD) or the No Data, No Market
International Organisation for Standardization With their restriction proposal, ECHA aims to
(ISO). It is important to note that many of these address the environmental and human health
17Microplastics
THROUGH THE EYES OF
POLITICS AND SCIENCE
risks posed by microplastics. By including only risk. Not all polymers within these groups may be knowledge gaps presented here. Furthermore,
solid, non-biodegradable plastics between 5 mm harmful to environmental and human health, it would require manufacturers and producers to
and 0.1 µm, we believe that ECHA is undermining but some likely will be. Future research take responsibility for all ingredients used in their
the purpose of this restriction. As outlined above, and hazard assessments will hopefully provide products.
the presence of WSPs in the environment is to be new insights and identify sub-groups requiring
expected based on their production volumes and strong regulation. Until that time we call upon
high potential of environmental discharge. policy-makers to adopt the precautionary
principle for all synthetic polymers and consider
Their distribution, concentrations, and impact are their hazards when developing new regulatory
unfortunately still highly unclear. Moreover, little is measures. In the case of ECHA’s restriction
known about the transformation products of many proposal, exemption of the above-mentioned
WSPs, and their persistency and toxicity. Regarding groups is particularly unjustified for applications
liquid and semi-solid polymers, the example of for which ample non-synthetic polymer alternatives
dimethicone illustrated that these polymers can be already exist (for example personal care products).
of environmental concern. Engineered nanoplastics, Additionally, regulations can be introduced that
such as those applied in personal care products will require more short-term and long-term
can cross biological barriers and exert toxic effects. hazard toxicity testing before authorizing synthetic
ECHA justifies the lower limit of 0.1 µm by arguing polymers to be placed on the market at certain
that a lower size limit (of 1 nm) cannot be enforced. volumes. One avenue for this would be to include
However, an interdisciplinary group of scientists the registration of polymers under REACH. The first
recently argued that this claim is invalid and that steps towards registering polymers under REACH
“intentionally added plastic particles in the nano have been made by the European Commission.
range (< 0.1 µm) could be reintroduced into the The criteria to identify polymers requiring
restriction proposal31. With respect to biodegradable registration (PRR) have however been highly
polymers, real-world conditions are poorly reflected criticised by members of the scientific community
in current standardised biodegradation tests and as at this stage 94% of polymers would be
various concerns about their toxicity exist.32 exempted from registration33. If polymers would
require registration under REACH, the 'no data,
Clearly, there are still too many unknowns for these no market principle would apply to these
synthetic polymer groups in order to assess their substances, which would fill many relevant
183 TEN BRANDS UNDER
the microscope
H
undreds if not thousands of synthetic
polymers are used in our cosmetics and GUIDE TO MICROPLASTICS
care products. While the extent of these
ingredients is known, the environmental impact is
difficult to grasp. Research by UNEP34, TAUW35, and
the restriction proposal by ECHA36 does help a little Products in this colour category contain microplastics. Our list of
in placing some of these synthetic polymers on our microplastics is derived from the research conducted by UNEP, TAUW, and
map. This information can be quite daunting, which ECHA. We consider these reports to be the best-substantiated overview
is why we, as the Plastic Soup Foundation, created currently available on the different microplastics potentially present in
a traffic light system to categorize products: Red, cosmetics and personal care products. This list contains over 500 synthetic
Orange & Green (See box 3.1). RED polymers.
We collected product information through the
citizen science efforts from Beat the Microbead
app users (see Annex II for detailed methodology). Products in this colour category contain what we call 'sceptical'
By collecting data and categorising them with microplastics. By 'sceptical microplastic' ingredients we mean synthetic
this traffic light system, we were able to look at polymers without sufficient information concerning their risks. These include,
ingredient level information of all the products but are not limited to, Polyquaternium, Polysorbate, PEGs, and PPGs. We will
registered in our database. Since 2020, we keep adding suspicious substances to this list and remove the ones that
have been able to investigate different product ORANGE proved not to pose a risk to the environment and/or human health.
categories and have discovered how many
products under these product types contain
microplastics.
For instance, in 2020, because of the Covid-19 Products in this category do not contain any known microplastics or
pandemic, the use and sales of hand sanitisers 'sceptical' microplastics from the red and orange categories.
skyrocketed. Out of 138 registered sanitisers and
hand gels, 82 contained microplastic ingredients,
GREEN
5 had sceptical microplastics and 28 disinfectants
had both microplastics and sceptical microplastics.
Box 3.1
19TEN BRANDS UNDER
the microscope
That’s about 80% of hand sanitisers and gels with After determining the producers and brands to en- the impact their products have on the planet. The
plastic ingredients inside them. There’s hardly any gage with, we looked at how many of the registered question is how sincerely big businesses want to
popular consumer brand with an entire range of products from these companies in our database tackle this issue. The summaries of our findings are
products using plastic-free ingredients. had either red, orange or both ingredients from our laid out in the following sections.
traffic light system to categorize products in our
A deep dive into Europe's database. We also looked for the most common
TAKING THE ABOVE INTO ACCOUNT,
popular consumer brands microplastics ingredients in these products.
To get a more specific picture of the wide use WE ENDED UP FOCUSING ON THE
of microplastics, we have dived into the 10 most Despite the increasing popularity of the BTMB app
FOLLOWING COMPANIES AND BRANDS:
popular consumer brands of the 4 biggest we are still far from having a complete overview of
cosmetic producers in Europe. For this purpose, we the cosmetics and personal care industry. Inevitably
largely based our choice of targeted companies certain limitations apply to our dataset. Our meth-
and brands on the report: ‘Leading 20 health odology, data collection method and its limitations
and beauty brands ranked by consumer reach can be found in Annex II. Furthermore, we analysed • Nivea •
points in Europe in 2020’, by the Statista Research the information available on these 10 brands' web- • L’Oreal Paris •
Department37. Our focus in choosing these sites, public policies and sustainability plans. • Elvive/Elseve •
producers and brands is based on the fact that • Garnier •
they are the biggest players in the market with To get further clarifications, insights on their plans
popular brands. They are by no means the worst and to verify whether the product formulae have
performers in the market. In order to obtain the been changed, we sent a letter to the producers
product level information, we looked into the Beat of all the brands mentioned above (see Annex IV).
the Microbead app database. This data is collected We did that so we could update our dataset based
• Gillette • • Dove •
through the citizen science efforts of the app users. on their response and find out how committed they
are to tackling microplastic pollution. • Oral-B • • Rexona •
Since we are committed to holding ourselves to the • Head & Shoulders • • Axe •
same high standards of transparency we demand Where do these brands stand?
of others, our thought process on which cosmetics Considering the recent developments in the
companies and brands should be included in this conversation around (micro)plastic pollution,
report is explained in Annex II. businesses cannot avoid addressing this issue
anymore. Businesses must take responsibility for
20TEN BRANDS UNDER
the microscope
L'ORÉAL: L'ORÉAL PARIS:
Plan for the future 'Because Our Planet is Worth It'
L'ORÉAL PARIS
The L’Oréal Group does recognise the problem of L’Oréal Paris’ plan 'Because Our Planet is Worth It'
plastic pollution. In their sustainability plan L’Oréal closely follows its producer’s plan. By 2030 they will
For the Future, they go as far as calling it “one of use 20% less material to package the same number 77% of the 1.003 L’Oréal Paris
today’s most pressing environmental issues”.38 They of products. They also want to use 100% recycled products registered in BTMB contain
do recognise the need for bettering their packaging plastic and optimise the recyclability of packaging. red microplastics.
by claiming that “by 2030, 100% of their packaging For instance, in the future they will sell their
will be from recycled or biobased plastic, and shampoo and conditioner in aluminium packaging 90% of the 1.003 L’Oréal Paris
by 2025 all plastic packaging will be refillable, that consumers can send back for refilling. products registered in BTMB contain
reusable, recyclable or compostable”39. orange microplastics.
However, these plans make no mention of
Only 4% of the 1.003 L’Oréal Paris
However, there is no direct mention of microplastics microplastics or their view on the use of
products registered in BTMB are
in their sustainability plans. Instead, they say microplastic ingredients. They seem to be
green, according to our product
they will re-evaluate all their formulae by 2030 to focusing their efforts on plastic packaging and
categorisation.
guarantee respectfulness to all aquatic ecosystems carbon emissions, but they stop short of really
both continental and coastal, but nowhere in making their formulae sustainable or respectful MOST USED MICROPLASTICS
their booklet or on their website do they explain to the environment. When we asked them about
what they mean by “respectful”. Another goal is their plans to tackle microplastics, L’Oréal Group • The top 5 most used red ingredients in
to have 95% of their ingredients biobased by that responded: the L’Oréal Paris products registered in
same date. What this means in terms of their use BTMB are: Dimethicone (376), Carbomer
of plastic ingredients is not specified enough as “• We reformulated all our rinse-off products (191), Acrylates Copolymer (60), Nylon-12
biobased ingredients do not automatically mean that are directly eliminated in water, such as (60), and Polyquaternium-7 (51).
they are environmentally friendly and shouldn’t be shower gels or shampoos. Since 2020 they are • The top 5 most used orange ingredients in
confused with biodegradable ingredients. all microplastic-free. the L’Oréal Paris products registered
• L'Oréal started working on reformulating its in BTMB are: PEG-100 Stearate (148),
rinse-off products in 2014. All plastic microbeads Amodimethicone (120), Ammonium
were eliminated from exfoliating products as of Polyacryloydimethyl Taurate (87), Ceteth-2
January 2017. (87), and Trideceth-6 (86).
Figure 3.1
21TEN BRANDS UNDER
the microscope
• The gradual replacement of microplastics in ELVIVE/ELSEVE:
other products is underway. ELVIVE/ELSEVE
Take on sustainability
• At the European level, with the cosmetics industry
On the L’Oréal Paris’ website, Elvive is described
and within our trade association, we are in
as “flying the flag of L’Oréal Paris’ ambitions toward
dialogue with the authorities on the definition of 53% of the 374 Elvive/Elseve
sustainability,” claiming that Elvive is making great
microplastic, how restrictions are implemented products registered in BTMB contain
strides to minimise its footprint and thus proving
according to product categories and the timing”. red microplastics.
that “planet-friendly credentials and innovative
products are not mutually exclusive.”40
It seems they refer to the limited definition of 83% of the 374 Elvive/Elseve
microplastics proposed by ECHA. Based on this products registered in BTMB contain
On their website L’Oréal Group presents their no-
premise we find it worrying that they consider orange microplastics.
rinse hair products like the Elvive Dream Lengths
the rinse-off products as microplastic-free. As
line as part of their “green innovations”. However, in
we demonstrated in the previous chapter, there Only 7% of the 374 Elvive/Elseve
our database we see that many of these products
is still no guarantee if the synthetic polymers products registered in BTMB are
still contain plastic ingredients: of the 15 products
that fall outside of this definition are safe for the green, according to our product
11 are red & orange, 3 are orange and only one (the
environment. Our data shows that there are still categorisation.
dry shampoo) is green (See figure 3.2). The Dream
many questionable plastic ingredients in their
Lengths range is being presented as eco-friendly MOST USED MICROPLASTICS
cosmetics, including shower gels and shampoos.
while it is full of plastic ingredients. On the L’Oréal
Because we consider all synthetic polymers in order • The top 5 most used red ingredients in
website they mention the Elvive Full Resist Power
to assess whether a product is microplastic-free the Elvive/Elseve products registered in
Mask released in 2019 as over 97% biodegradable
or not, our data shows that many L’Oréal products BTMB are: Carbomer (146), Dimethicone
ingredients41. According to our database, this
contain plastic ingredients (See figure 3.1). (127), Polyquaternium-7 (29),
product is also microplastic-free.
Polyquaternium-6 (7), and Acrylates/C10-30
Elvive has two strategies which focus on packaging Alkyl Acrylate Crosspolymer (4).
OF THE SUB-CATEGORIES FACIAL CARE and formulae. As of 2020, 100% of the bottles are • The top 5 most used orange ingredients in
AND HAIR PRODUCTS OF L’ORÉAL PARIS, made of recycled plastic and they will be 100% the Elvive/Elseve products registered
3 OUT OF 4 PRODUCTS IN OUR DATABASE recyclable in the future – they claim. Regarding in BTMB are: Amodimethicone (187),
the formula: their sustainability plan makes the Trideceth-6 (118), PPG-5-Ceteth-20 (59),
CONTAIN RED INGREDIENTS. first indirect mention of microplastics in the L’Oréal Ceteth-2 (56), and Trideceth-10 (43).
Group42. The L’Oréal Paris USA website states:
Figure 3.2
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