Canada’s ban on microbeads in rinse-off cosmetics, formalized under Bill C-62 and effective from July 2018, marked a significant shift in how personal care product supply chains were expected to operate. While public focus at the time was largely on the consumer-facing impact—removing visible microplastics from scrubs, cleansers, and toothpaste—the practical implications for manufacturers and their suppliers ran far deeper. The legislation required not just reformulation of products, but the construction of new supply-chain transparency mechanisms capable of verifying that banned substances were being effectively excluded.
Personal care brands found themselves needing to map their raw material inputs with a precision that, in many cases, exceeded what their existing supplier records could support. The task began with a close reading of Health Canada’s Cosmetic Ingredients Hotlist, the reference point for banned or restricted substances. Identifying microplastic resins on this list was straightforward enough in regulatory terms. The greater challenge was in tracing these materials back through multiple tiers of suppliers, some of whom were not accustomed to disclosing detailed polymer sourcing information. Companies quickly discovered that assumptions about the absence of microbeads—based on prior supplier attestations or broad product specifications—were no longer sufficient in the eyes of regulators or consumers.
One practical route involved engaging with the Canadian Plastic Industries Association, which had begun making open API tools available to assist in mapping polymer supply chains. These tools allowed manufacturers to query databases of resin producers, identifying sources of specific granules by composition, origin, and processing site. Integrating these queries into procurement workflows wasn’t always seamless. Teams had to reconcile API data with internal supplier records that varied in format and completeness. Moreover, discrepancies between supplier declarations and API results sometimes surfaced, requiring follow-up that introduced delays or contractual tensions.
Brands that navigated this complexity most effectively tended to take a phased approach. First, they compiled inventories of all formulations that previously contained, or might contain, microbead-type resins. Next came supplier outreach, requesting detailed disclosures on polymer granule origins and processing histories. The API data was then used as a cross-check, flagging inconsistencies or gaps for further investigation. In parallel, manufacturers began developing quarterly plastic microbeads avoidance audits. These audits served not only as internal control mechanisms, but also as records of due diligence that could be shared with regulators, NGOs, or retail partners as needed.
The audit templates typically included fields for listing product SKUs, supplier names, resin types, source facilities, and verification methods employed. Some firms went further, incorporating risk ratings based on factors such as supplier transparency track record or geographic origin of materials. For larger manufacturers, automation became an attractive option, with procurement systems modified to automatically trigger API queries or audit entries upon the approval of new raw materials. In smaller firms, the process was often more manual but no less rigorous, with compliance teams taking on the task of collating and checking data prior to each quarterly review.
The move toward greater supply-chain traceability in personal care wasn’t without friction. Some upstream suppliers—particularly those further removed from the consumer product level—questioned the need for what they saw as duplicative or burdensome reporting. Others struggled to provide the granularity of information requested, citing confidentiality concerns or record-keeping limitations. Brands found themselves balancing the need for compliance with the practicalities of maintaining supplier relationships. In some cases, alternative suppliers were sourced specifically because they could offer clearer traceability documentation, even if this came at a premium.
Over time, the industry began to adapt to the new normal. Microbead bans in other jurisdictions reinforced the message that supply-chain transparency on microplastics was here to stay. The use of open data tools, once seen as optional or experimental, became a routine part of supplier vetting and material sourcing. For many personal care brands, Bill C-62 catalyzed a deeper reassessment of raw material procurement practices—not only in relation to microbeads but across a broader spectrum of sustainability and safety concerns.
The Canadian microbead ban thus served as both a regulatory mandate and an inflection point in the evolution of supply-chain practices in the personal care sector. It pushed firms to move beyond basic compliance and toward proactive supply-chain mapping and audit frameworks that could stand up to scrutiny in an era of growing environmental awareness and stakeholder activism. While challenges remained, the experience laid important groundwork for future efforts to enhance material traceability and align procurement practices with evolving regulatory and consumer expectations.