FDA likely will need to issue guidance to clarify exactly what materials are covered by the ban on plastic microbead use in selected personal-care products – i.e., a definition of “plastic” – and what the consequences of a violation could be. The issue could be of particular relevance to companies exploring gray-area replacement materials such as biodegradable PHA.
Violators of the US ban on plastic microbead-containing cosmetics could face warning letters and other enforcement actions from FDA once phase-out deadlines kick in, but the biggest threat could be of a PR, rather than compliance, nature.
Those considering borderline replacement materials should weigh potential benefits and risks accordingly.