A plastic exfoliant in a scrub

How it happens

A maker buys an exfoliant described as a bead or a jojoba-style sphere without establishing what it is made of, and formulates a rinse-off scrub around it. The prohibition turns on the material and the purpose, not on the product name.

The definition does not need a polymer name

Any solid plastic particle under five millimeters intended to exfoliate or cleanse. So there is no list to check and no new material that escapes by being new. The question is what the particle is.

Which makes the supplier specification the control

Ask what the particle is made of, in writing. A trade name is not an answer, and jojoba esters, which are a common and lawful alternative, are sometimes sold under names that sound synthetic.

There is no labeling cure

Unlike almost everything else in this library, this is a prohibited act rather than a requirement to disclose. A warning does not make it lawful and a disclosure does not either.

And it reaches manufacture, not only sale

The prohibited act is the manufacture or the introduction or delivery for introduction into interstate commerce. So making it is caught before anything ships.

The leave-on version is a different question

A plastic particle in a body butter is outside this paragraph. Whether it is a sensible ingredient, and what a customer would think of it, are separate judgments and increasingly commercial ones.

Plastic-free is the simpler position

It removes the classification question entirely and it is a claim this market rewards. Sugar, salt, ground shell, pumice, clay and coffee are all ordinary exfoliants and none of them is caught.

Ask what it is, not what it is called

Exfoliant trade names are deliberately evocative and tell you nothing about composition. One written question to the supplier closes the whole issue, and a reluctance to answer it is itself the answer.

References