The EU Packaging and Packaging Waste Regulation: A cosmetic industry perspective

Introduction

On 22 January 2025, the EU adopted the new Packaging and Packaging Waste Regulation (PPWR). This regulation will come into effect on 12 August 2026, marking a significant change in how packaging is designed, managed, and regulated across the EU.Since 1994, the EU and Great Britain have followed a packaging and packaging waste framework designed to:

• Reduce the amount of packaging used
• Cut down on packaging waste
• Limit hazardous substances in packaging

This framework, often referred to by its ‘essential requirements’, required businesses to minimise packaging, design it for recyclability, and eliminate heavy metals and other harmful substances.

The new PPWR builds on this foundation rather than replacing it. Key updates include:

• It is now a regulation rather than a directive, ensuring consistent application across the EU
• It introduces stricter rules for packaging design, recyclability, and reuse
• It sets out clearer obligations for producers, backed by stronger enforcement mechanisms

The PPWR is part of the EU’s broader Green Deal and circular economy goals, aiming to reduce waste, increase recycling, and make better use of resources.

In this article, we’ll look at some of the key concepts and obligations relevant to the cosmetics industry, including: substances of concern, recyclability, recycled content, packaging minimisation, waste sorting labels, and the technical dossier.

Substances of Concern in Packaging

Defined by the Ecodesign for Sustainable Products Regulation (ESPR), the concept of ‘Substances of Concern’ (SoC) will play an important role in many legislative frameworks published under the Green Deal. With regards PPWR:

• Packaging should be manufactured to minimise the presence and concentration of substances of concern (by Aug 2026).
• The sum of concentrations of lead, cadmium, mercury, and hexavalent chromium in packaging or components should not exceed 100 mg/kg

Within ESPR, SoC are defined as:

• substances of very high concern (SVHC) under EU REACH;
• substances falling under specific hazard categories of the CLP Regulation, such as carcinogenic, mutagenic or reprotoxic (CMR), persistent, bioaccumulative and toxic (PBT), very persistent and very bioaccumulative (vPvB), and specific target organ toxicity (STOT);
• persistent organic pollutants (POPs);
• and any substance that negatively impacts the reuse or recycling of packaging.

Whilst minimisation and substitution are the primary goal, it may not always be possible to completely eradicate all SoC from packaging. Packaging containing substances of concern will have to be marked using standardised, open, digital technologies in the future as part of the digital product passport and transparency principles.

Recyclable Packaging

One of the central pillars of the PPWR is the requirement for all packaging to be recyclable by 2030. This will introduce clear, enforceable obligations for businesses across the packaging supply chain as well as increase consumer expectation in this area.Within the PPWR, obligations will be introduced to ensure that packaging will not only be theoretically recyclable but that it can also be recycled on a practical basis. This will mean that packaging must be both designed for recycling and also be able to be part of an effective collection, sorting, and recycling system. Packaging that combines the two criteria means it is considered to be ‘recyclable’.

To make this requirement achievable for industry, each criterion will need to be supported by additional legislation to clarify what ‘Design for Recycling’ entails and what qualifies as ‘recycled at scale’.

The European Commission, Parliament, and Council acknowledge that such significant changes to packaging cannot happen overnight, and that the infrastructure needed to recycle all materials at scale is not yet fully in place. As a result, the final PPWR text includes phased deadlines and transitional measures to support progress toward its long-term goals.

The first key milestone comes in 2030, when only packaging rated A to C will be allowed on the market. By 2038, the requirements become stricter, permitting only packaging that meets at least a grade B standard.

Recycled Content

The PPWR introduces mandatory requirements for minimum levels of recycled plastic content in packaging, including for cosmetic products. These new rules aim to reduce reliance on virgin plastics and promote the use of post-consumer recycled (PCR) materials. However, while the intent is environmentally driven, the implementation raises complex challenges for industries where product safety, stability, and consumer protection are key.From Jan 2030 and Jan 2040, plastic packaging should contain a minimum percentage of recycled content recovered from post-consumer plastic waste, calculated as an average per manufacturing plant and year.

The new PPWR requirements represent a significant step toward more sustainable packaging practices in the cosmetics industry. However, meeting these recycled content targets poses technical and supply chain challenges. The limited availability of high-quality recyclates means the industry must look to adapt and adopt new risk assessment strategies. Initiatives like CosPaTox (1) offer valuable tools to bridge this gap, providing structured guidance on how to evaluate and safely integrate PCR materials. As regulatory timelines approach, proactive collaboration between stakeholders will be essential to ensure that both sustainability and product safety are maintained.

Packaging Minimisation

Both the existing Packaging and Packaging Waste Directive (94/62/EC, or PPWD) and the Packaging and Packaging Waste Regulation (EU 2025/40, or PPWR) require companies to reconsider how they package products. One key focus is packaging minimisation.Packaging minimisation is all about eliminating unnecessary packaging, especially packaging that exaggerates the size of a product to boost appearance on shelf. In essence, packaging must be designed and manufactured so that its volume and weight are no more than what is needed to ensure product safety, hygiene, and consumer acceptance. That means no oversized or deceptive boxes, unnecessary inserts, or decorative components that don’t serve a functional purpose.

Packaging minimisation plays a key role in the ‘waste hierarchy’ set out in the EU Waste Framework Directive (Directive 2008/98/EC). This hierarchy ranks waste management options from most to least environmentally friendly, starting with prevention and ending with disposal, e.g. landfill.

Minimising packaging is part of the most favoured prevention stage. It focuses on actions taken before a material or product becomes waste, so reducing:

• the amount of waste generated;
• the environmental and health impacts of waste; and
• the presence of harmful substances in materials and products.

Under PPWR, this means:

• Packaging must be designed to minimise weight and volume.
• False or misleading packaging characteristics like double walls or false bottoms will be banned.
• Transport and e-commerce packaging must not exceed an empty space ratio of 50%.
• Single-use plastic packaging for cosmetics, hygiene, and toiletry products used in the accommodation sector will be prohibited.

In practice, reducing packaging size, without compromising safety or usability, requires a balanced approach across all components of a product, along with efforts to minimise hazardous substances. Many companies demonstrate compliance by developing a Packaging Minimisation Dossier, which documents design choices, justifications, and supporting evidence. This is often supported by a broader packaging strategy that explains how minimisation decisions are made and how environmental design principles are applied.

Sorting Label

Several EU Member States, including France, Italy, Spain, and Portugal, already define sorting instructions that must be supplied to consumers but the requirements are diverse. The PPWR will introduce a new harmonised label that will standardise packaging disposal information across all Member States, whilst maintaining that packaging provides indication of the material(s) used and the disposal route (e.g. plastic recycling bin)Not part of the PPWR when published, the European Commission is tasked with developing the technical details of the labelling system through implementing acts, which will define how the label should appear, how it should be used, and when exactly businesses must begin applying it to packaging.

Earlier this year, the European Commission launched a targeted consultation to gather feedback from consumers, industry stakeholders, and local authorities on the design of the harmonised label. The draft guidelines shared as part of this consultation provided a proposed design for use on consumer packaging and the corresponding waste receptacles, featuring a packaging icon, such as plastic bottle, on coloured background and text description of the waste stream e.g. plastic. We will need to wait to see if this proposal moves forward or whether new formats will be proposed in the coming months.

Technical Dossier

Once all requirements of the PPWR detailed in Articles 5 to 12 are met, compliance must be demonstrated via a Declaration of Conformity (DoC) and supporting Technical Dossier. Just like the Product Information File for a cosmetic product, this is a structured collection of evidence that demonstrates that compliance has been achieved.Many of the details of ‘how’ to comply with requirements of the PPWR are yet to be decided and so the exact content of the technical dossier cannot be fully determined at this time (e.g. choice of assessments and methodologies). However, as deadlines approach and more detail becomes available over aspects such as determining recyclability, this dossier will need to be populated and updated to document and demonstrate design choices, materials used, recyclability assessment, and other relevant test results.

Conclusion

It is important to remember that some of the provisions of the PPWR already exist under the current PPWD and compliance is currently required in areas such as:

• Minimisation of noxious and hazardous substances, in particular the levels of lead, cadmium, mercury, and hexavalent chromium;
• Minimisation of packaging and, in particular, replacing items such as false bottoms and deceptive thick walled packaging, and removing unnecessary layers.
• Preparing packaging minimisation information for each product.

Although 2030 may seem far off, meeting requirements for recyclability and recycled content can take considerable time, especially when balancing other factors like safety from hazardous substances, packaging minimisation, and managing existing stock.

Some definitions still need clarification through additional Implementing Acts or Regulations. However, we believe companies should begin assessing their current packaging portfolio now to identify priority areas for change.