CPSR for Facial Scrubs & Exfoliants (UK & EU)

Exfoliants from sugar and salt scrubs to acid exfoliating toners are popular, satisfying products, but they sit at the intersection of two tricky areas: the microplastics ban for physical scrubs and acid limits for chemical ones. A scrub or exfoliant is a cosmetic that needs a CPSR, and the assessment has some specific ground to cover. This guide explains what matters for both physical and chemical exfoliants.

For the basics, see our guide to what a CPSR is. Here we focus on exfoliants.

Physical versus chemical exfoliants

Exfoliants fall into two broad types. Physical (or mechanical) exfoliants use particles sugar, salt, ground seeds, jojoba beads to scrub away dead skin. Chemical exfoliants use acids such as AHAs (glycolic, lactic) or BHAs (salicylic) to dissolve the bonds between dead skin cells. The two work very differently and raise different safety issues, so the assessment approach depends on which you are making.

Some products combine both, and many exfoliating products also need preserving if they contain water. Identifying clearly what kind of exfoliation your product delivers and through which ingredients is the starting point for getting it assessed correctly.

The microplastics ban and physical scrubs

The most important point for physical scrubs is that plastic microbeads are banned and plastic microparticles are being phased out. Tiny plastic exfoliating beads once common in face and body scrubs were among the first cosmetic microplastics restricted, because they wash down the drain and pollute the environment. Using plastic microbeads in a scrub today is not an option.

The good news is that there are many compliant natural exfoliants: sugar, salt, ground apricot or other seeds, jojoba esters, oatmeal, and similar. These are not caught by the microplastics rules (provided they are natural, biodegradable, soluble or inorganic). Our microplastics guide explains the restriction; for scrubs, the practical rule is simply to use a compliant exfoliant, not plastic beads.

Particle harshness and facial skin

Even compliant natural exfoliants can be too harsh for delicate facial skin if the particles are large, sharp or jagged. Crushed nut shells and some seed powders, for instance, can have irregular edges that cause micro-tears in the skin. Facial skin is more delicate than body skin, so a scrub fine for elbows and feet may be too abrasive for the face.

The safety assessment considers the nature of the exfoliating particles their size, shape and hardness in the context of where and how the scrub is used. For a facial scrub, gentler, rounder particles are generally more appropriate. This is a genuine safety point, not just a comfort one, since aggressive physical exfoliation can damage the skin barrier.

Acid exfoliants: concentration and pH

Chemical exfoliants built on AHAs and BHAs are governed by their concentration and pH, which together determine how strongly they exfoliate and how much they can irritate. Alpha-hydroxy acids in particular are subject to conditions for cosmetic use, and exceeding safe levels or using too low a pH turns a cosmetic exfoliant into something potentially harmful.

The safety assessment scrutinises acid type, concentration and pH together, and identifies the mandatory warnings such products require commonly including advice about increased sun sensitivity and using sunscreen. This mirrors the considerations for acid serums; the same care applies wherever exfoliating acids are used. Our restricted ingredients and label warnings guides give context.

Sun sensitivity warnings

Exfoliating acids can make skin more sensitive to the sun, increasing the risk of sun damage. Because of this, products with significant acid exfoliation typically must carry warnings advising users to protect their skin from the sun and to use sunscreen, often for a period after use. This is a safety-critical piece of labelling, not an optional nicety.

The assessment identifies exactly which warnings your acid product needs based on its formulation, and those must then appear on the label accurately. Omitting a required sun-sensitivity warning on an acid exfoliant is both a compliance failure and a genuine risk to users who might otherwise over-expose freshly exfoliated skin.

Preservation of water-based scrubs

Whether a scrub needs preserving depends on its water content. An anhydrous sugar or salt scrub in an oil base generally needs no traditional preservative though salt and sugar themselves can have some preservative effect at high concentration, and an antioxidant protects the oils. A water-containing exfoliant, including most acid toners and gel scrubs, needs a preservative system and a challenge test.

A particular watch-point is scrubs used in the wet shower environment, and oil-and-sugar scrubs that may have water introduced. As always, the assessor judges preservation needs from the actual formula and use. Our preservatives and challenge test guides cover the principles.

Salt, sugar and rinse-off considerations

Most scrubs are rinse-off, used in the shower or at the basin and washed away, which means the slightly more lenient rinse-off thresholds apply to restricted ingredients and fragrance allergens. Acid exfoliating products that are left on the skin, however, are leave-on and face the stricter limits another reason the distinction between a rinse-off scrub and a leave-on acid treatment matters.

Salt scrubs also raise the practical point that salt can be drying and stinging on broken or freshly shaved skin, which the assessment and any warnings take into account. Matching the product and its cautions to how and where it is used is part of a sound assessment.

Body scrubs versus facial scrubs

Although they share a category, body scrubs and facial scrubs are not interchangeable. Body skin on elbows, knees, feet and limbs is thicker and more robust, and tolerates coarser, more abrasive exfoliants. Facial skin is thinner and more delicate, so a particle size and hardness perfectly comfortable on the body can be too aggressive for the face, risking micro-tears and barrier damage. A product sold for both uses needs to be gentle enough for the most delicate site it targets.

This matters for both formulation and labelling. A salt scrub built for rough heels should not simply be relabelled as a facial product, and a facial scrub's instructions should steer users away from over-vigorous scrubbing. The safety assessment considers the intended use site, so being clear about whether your scrub is for face, body or both shapes how it is evaluated and what particles and cautions are appropriate.

For makers building a range, it is often cleaner to design distinct face and body scrubs than to stretch one product across both, precisely because the appropriate harshness differs. Matching the exfoliant to the skin it will meet is part of designing a safe, well-received product.

Enzyme and gentler exfoliants

Beyond physical particles and strong acids, enzyme exfoliants using fruit-derived or other enzymes to gently break down dead skin are an increasingly popular middle path, often marketed as gentler than scrubs or acids. They still need assessing: the enzymes and the overall formula have their own considerations, the product usually contains water and so needs preserving, and any accompanying acids or actives face their normal limits.

“Gentle” is a positioning, not a regulatory category, so an enzyme exfoliant goes through the same CPSR process as any other. The assessment simply reflects its particular chemistry enzyme stability and activity, pH, preservation and any actives. The point for makers is that reaching for a gentler exfoliation method does not remove the need for a proper safety assessment; it just changes what that assessment focuses on.

Key safety points for exfoliants at a glance

Facial scrub & exfoliant checklist

• Use no plastic microbeads — choose compliant natural exfoliants.

• Keep particles gentle enough for facial skin.

• Control acid concentration and pH for chemical exfoliants.

• Include sun-sensitivity and other required warnings.

• Preserve and challenge-test water-containing exfoliants.

• Apply the correct rinse-off or leave-on thresholds.

• Have it all assessed in a CPSR.

Frequently asked questions

Do facial scrubs need a CPSR?

Yes. A scrub or exfoliant is a cosmetic needing a CPSR, PIF, Responsible Person, notification and compliant labelling. Physical and chemical exfoliants raise different safety points the assessment addresses.

Can I still use microbeads in a scrub?

No. Plastic microbeads are banned and plastic microparticles are being phased out. Use compliant natural exfoliants such as sugar, salt, ground seeds or jojoba esters instead.

Can natural exfoliants still be too harsh?

Yes. Large, sharp or jagged particles like some crushed shells can cause micro-tears, especially on delicate facial skin. Gentler, rounder particles are more appropriate for the face.

What limits apply to acid exfoliants?

AHAs and BHAs are governed by concentration and pH, with conditions for cosmetic use. Exceeding safe levels or using too low a pH is unsafe, and the products typically require mandatory warnings.

Do acid exfoliants need sun warnings?

Usually yes. Exfoliating acids can increase sun sensitivity, so significant acid products typically must carry warnings to protect the skin from the sun and use sunscreen. This is safety-critical labelling.

Does a sugar or salt scrub need a preservative?

An anhydrous oil-based sugar or salt scrub generally does not, though it may use an antioxidant. A water-containing exfoliant or acid toner needs a preservative system and a challenge test.

Are scrubs rinse-off or leave-on?

Most scrubs are rinse-off, so the more lenient thresholds apply. Acid products left on the skin are leave-on and face stricter limits, so the distinction matters for compliance.

References: Regulation (EC) No 1223/2009 (EUR-Lex); Regulation (EU) 2023/2055 (microplastics); Annex III restricted substances; SCCS opinions on AHAs; UK Cosmetics Regulation as retained. General information only, not legal advice.