How Does PPWR Affect Cosmetic Packaging?

How Will PPWR Change Cosmetic Packaging?

1. Cosmetic packs must be designed for recycling

Article 6 establishes the central rule: all packaging placed on the EU market must be recyclable.

From 2030—or later if the relevant delegated acts are delayed—packaging will need to satisfy EU design-for-recycling criteria and achieve recyclability grade A, B or C. From 2038, grade C will no longer be sufficient; packaging must reach grade A or B, unless a specific exemption applies.

By 2035 or a later act-dependent date, theoretical recyclability will not be enough. Packaging must also be capable of being collected, sorted and recycled at scale.

For cosmetics, design reviews should examine:

• Whether components can be separated during normal sorting
• Whether pumps or closures interfere with the main material stream
• Whether metal springs, magnets or metallised parts create problems
• Whether dark colours prevent optical sorting
• Whether coatings, inks, labels and adhesives affect recycled output
• Whether residue can be removed sufficiently for recycling
• Whether small components are lost during collection or sorting

This does not mean that every multi-material pack will automatically be banned. It means that brands will need evidence showing how the final packaging format performs against the criteria adopted for its category.

2. Plastic cosmetic packaging will need recycled content

Article 7 introduces mandatory post-consumer recycled-content levels for plastic parts. Because cosmetic packaging is classed as contact-sensitive, the relevant targets generally depend on its main plastic material.

By January 1, 2030—or three years after the relevant implementing act takes effect, whichever is later—the targets are:

• 30% for contact-sensitive packaging in which PET is the major component
• 10% for contact-sensitive packaging made from plastics other than PET
• 35% for other plastic packaging outside the specified contact-sensitive and beverage categories

By January 1, 2040, those levels rise to:

• 50% for contact-sensitive PET packaging
• 25% for contact-sensitive non-PET plastic packaging
• 65% for other plastic packaging

The calculation is made per plastic part, packaging type and format as an annual average for each manufacturing plant. It is not simply a claim applied to a company’s entire packaging portfolio.

Before switching to PCR plastic, cosmetic companies should test colour consistency, odour, dimensional stability, formula compatibility, barrier performance and pump function. Recycled content can change the way a component behaves, especially in precision dispensing systems.

3. Excess weight and perceived volume will be challenged

Under Article 10, manufacturers or importers must ensure by 2030 that packaging weight and volume are reduced to the minimum necessary for functionality.

The regulation specifically targets features used only to make a product appear larger, including:

• False bottoms
• Unnecessary layers
• Excessively thick double walls
• Oversized boxes
• Decorative structures with no functional justification

Premium appearance is not prohibited. Protection, dispensing performance, hygiene, accessibility, product presentation and legally protected designs can still be relevant. However, the company must be able to explain why further material reduction would compromise a recognised performance criterion.

Technical documentation may need to include specifications, test results, simulations or studies supporting the selected weight and volume. “Luxury feel” alone is unlikely to be a sufficient engineering justification.

PPWR also limits empty space in grouped, transport and e-commerce packaging. From 2030—or later depending on the implementing acts—the maximum empty-space ratio for these formats will generally be 50%. Beauty brands shipping small products in large boxes should review their fulfilment formats early.

4. New labels will change pack artwork

Article 12 introduces harmonised EU labels showing packaging material composition to help consumers sort waste correctly.

The obligation begins from August 12, 2028 or 24 months after the relevant implementing acts enter into force, whichever is later. The final pictograms and technical specifications depend on those acts.

For cosmetic brands, this creates several artwork considerations:

• Space must be reserved for the harmonised label.
• Small components may require special treatment.
• Online product listings must make required information available before purchase.
• Optional QR codes may provide sorting instructions for separate components.
• Voluntary recycled-content claims must follow the harmonised methodology and label specifications.

Brands should avoid finalising long-life artwork systems around speculative PPWR icons. The better approach is to create adaptable artwork zones and update them when the official specifications are confirmed.

5. Certain hotel cosmetic miniatures will be restricted

From January 1, 2030, Article 25 and Annex V restrict single-use packaging for cosmetics, hygiene and toiletry products supplied for an individual booking in the accommodation sector and intended to be discarded before the next guest arrives.

The regulation specifically gives examples such as:

• Mini shampoo bottles
• Individual hand or body lotion bottles
• Sachets around single-use soap bars

Hotels and amenity brands will need to consider dispensers, refill systems or other compliant delivery models. This restriction is narrow: it does not amount to a general EU ban on cosmetic samples or travel-size products sold through retail channels.

6. Producer responsibility will become more structured

PPWR requires producers to register in every Member State where they first make packaging or packaged products available. They must also meet extended producer responsibility, or EPR, obligations.

Depending on the supply chain, the responsible producer may be the brand owner, importer, distributor or another party defined by the regulation. Companies selling directly across borders through e-commerce should pay particular attention to the country-by-country registration rules.

EPR fees will increasingly reflect recyclability performance. In practical terms, hard-to-recycle cosmetic packaging may cost more even where it remains legally marketable. Better design can therefore reduce both regulatory risk and long-term waste-management costs.