Is this for you at all
Updated
On this page8
What this covers
Body butter, body lotion, body oil, body scrub, foot cream, hand cream, massage oil, stretch mark balm and cuticle balm. Nine leaves across two archetypes, which means somebody researched this group rather than stamping one default across it.
The prohibition
It is a prohibited act to manufacture, or to introduce or deliver for introduction into interstate commerce, a rinse-off cosmetic that contains intentionally-added plastic microbeads. Not a labeling requirement, a prohibition.
Defined by size and purpose
A plastic microbead means any solid plastic particle that is less than five millimeters in size and is intended to be used to exfoliate or cleanse the human body or any part thereof. No list of polymers to check against.
And rinse-off is the trigger
A body scrub is rinsed off. A body butter is not. So the identical particle is prohibited in one of your products and outside this paragraph in the next one along the shelf, and the customer’s use is what decides.
Which makes one of the nine leaves the whole question
Body scrub. The other eight are leave-on and this paragraph does not reach them. Whether a plastic particle belongs in a leave-on product is a separate judgment and not a prohibited act.
Toothpaste is named in the statute
The term rinse-off cosmetic includes toothpaste, expressly. So a maker with both a body range and an oral care product has the paragraph reaching both, which is easy to miss.
And the cuticle balm archetype names a tin we do not stock
It sits on the small tin archetype, whose shelf is 47 containers of which 30 are polypropylene and 17 glass, with no metal at all. The catalog does hold 29 tins, and the formats section says so.