The EU Packaging and Packaging Waste Regulation (PPWR) changes how brands need to think about cosmetic packaging.
For airless bottles, the key question is no longer simply whether a package is made from PP, contains PCR, or is refillable.
Brands need to consider the complete packaging system:
Material → Structure → Components → Product Protection → Use → Collection → Sorting → Recycling → Documentation
The PPWR entered into force on February 11, 2025 and began applying across the European Union on August 12, 2026. The regulation establishes requirements covering packaging recyclability, recycled content, packaging minimisation and other aspects of the packaging lifecycle. [1]
For cosmetic brands developing new airless packaging, this means sustainability decisions should be made during packaging development—not after the bottle has already been designed.
Why Is PPWR Important for Cosmetic Packaging?
Packaging is a significant waste stream in Europe.
According to Eurostat, the EU generated 79.7 million tonnes of packaging waste in 2023, equivalent to 177.8 kg per inhabitant. Plastic packaging accounted for 19.8% of packaging waste, while an average of 35.3 kg of plastic packaging waste was generated per person. Of that plastic packaging waste, 14.8 kg per person was recycled. [2]
These figures help explain why packaging design is increasingly becoming a regulatory and commercial issue.
For beauty brands, packaging has traditionally been evaluated around:
- Product protection
- Shelf appearance
- Consumer experience
- Manufacturing cost
- Filling compatibility
- Brand differentiation
The PPWR adds another layer:
- Recyclability
- Recycled content
- Material efficiency
- Packaging waste prevention
- Reuse and refill considerations
- Evidence and documentation
The result is a shift from “eco-friendly material selection” toward packaging system design.
What Does the PPWR Say About Packaging Recyclability?
Article 6 of the PPWR establishes that packaging placed on the EU market must be recyclable.
The regulation introduces recyclability performance grades and a phased approach to design-for-recycling and recycled-at-scale requirements.
From 2030, recyclability performance is connected to design-for-recycling criteria, while later requirements incorporate recycled-at-scale considerations. [3]
This is important for airless packaging because an airless bottle is rarely just a bottle.
A typical airless package can contain:
- Bottle
- Piston
- Pump
- Spring
- Actuator
- Cap
- Gasket
- Decoration
- Label
- Other functional components
Therefore, evaluating only the bottle resin does not necessarily tell you how the complete package will perform in a recycling system.
Does a Mono-Material Airless Bottle Automatically Mean It Is Recyclable?
No.
Mono-material design can simplify material composition, but it does not automatically prove that the complete package is recyclable in every market.
ISO 18604 provides requirements for packaging that is considered recoverable through material recycling, while ISO 18601 establishes the general framework for applying the packaging-and-environment ISO standards. [4]
In practical terms, brands should evaluate more than the primary resin.
Questions should include:
1. What materials are used?
Is the bottle PP, PE, PET or another polymer?
2. What materials are used in the pump?
Does the pump introduce different polymers or metal components?
3. What happens to the decoration?
Are inks, coatings, labels or metallisation compatible with the relevant recycling stream?
4. Can components be separated?
If different materials are required for functionality, can they be separated appropriately?
5. What recycling infrastructure exists in the target market?
A theoretically recyclable package may not have the same practical pathway in every market.
This is why the term “mono-material” should describe a verified packaging structure rather than function as a blanket sustainability claim.
What About PCR Airless Bottles?
Post-consumer recycled (PCR) material is another important part of the PPWR discussion.
Under Article 7, the regulation introduces minimum recycled-content requirements for plastic packaging, with targets that vary according to packaging type and material.
For example, the regulation sets a 10% minimum recycled content by 2030 for contact-sensitive packaging made from plastics other than PET, subject to the regulation's detailed conditions and calculation framework. For other plastic packaging categories, a 35% target is specified. [5]
This is one reason cosmetic brands should not simply ask:
“Can you make this bottle with PCR?”
A more useful supplier discussion is:
“Which component contains PCR, at what percentage, under which calculation category, and how will the material affect performance, appearance and documentation?”
PCR can influence:
- Color
- Transparency
- Odor
- Mechanical properties
- Surface appearance
- Decoration
- Material consistency
Therefore, PCR selection should happen alongside product and packaging testing.
Is Refillable Airless Packaging a Better Choice?
Refillable packaging can reduce repeated use of a durable outer component, but refillability does not automatically make a package environmentally preferable.
The actual result depends on:
- Number of refill cycles
- Weight of the outer package
- Weight of each refill
- Refill material
- Transportation
- Secondary packaging
- Consumer adoption
- Availability of refill products
This is why brands should avoid treating refillable, recyclable, PCR and mono-material as interchangeable terms.
They solve different problems.
A refillable system focuses on keeping part of the package in use.
A mono-material system focuses on material simplification.
PCR focuses on incorporating recycled feedstock.
Recyclability concerns whether packaging can enter an appropriate recovery pathway.
Airless Packaging Still Needs to Protect the Formula
Sustainability cannot be separated from packaging functionality.
Airless systems are used in beauty packaging partly because their dispensing architecture can protect formulas from air exposure and provide controlled dispensing.
Aptar's current airless packaging information describes benefits including formula protection, controlled dosing and high product evacuation, with some systems supporting more than 90% product evacuation. Its published range also covers different viscosities and formats. [6]
However, performance varies by system.
A package designed for a thin serum should not automatically be treated as suitable for a high-viscosity cream.
The packaging development process should therefore evaluate:
Formula → Viscosity → Pump Output → Container Structure → Filling Method → Compatibility → Product Evacuation
This is where packaging engineering becomes more important than simply selecting a “green” material.
How Should Beauty Brands Prepare Their Airless Packaging?
A practical development process can be divided into five steps.
Step 1 — Define the Formula
Understand:
- Viscosity
- Active ingredients
- Sensitivity to oxygen
- Required dosage
- Filling temperature
- Filling method
Step 2 — Define the Market
Identify the target markets and their packaging requirements.
For European launches, the PPWR should be considered during packaging development rather than after commercialization.
Step 3 — Evaluate the Complete Package
Review:
- Bottle
- Pump
- Piston
- Closure
- Decoration
- Label
- Secondary packaging
Step 4 — Compare Sustainability Strategies
Depending on the application, consider:
- Mono-material
- PCR
- Refillable
- Lightweighting
- Reduced components
- Metal-free structures
Step 5 — Build Evidence
Keep documentation covering:
- Material composition
- PCR content
- Testing
- Packaging specifications
- Supplier information
- Relevant recyclability assessments
The goal is not to find one universal “greenest” package.
The goal is to build a packaging system that can balance performance, material efficiency, regulatory requirements and end-of-life considerations.
How TOPFEELPACK Approaches Sustainable Airless Packaging
At TOPFEELPACK, sustainable packaging development includes multiple approaches rather than one single material strategy.
Our airless packaging portfolio includes solutions such as:
- Mono-PP airless bottles
- PCR airless packaging
- Refillable airless bottles
- Metal-free airless structures
- Dual-chamber airless packaging
For example, TOPFEELPACK's PA186 is a mono-PP airless packaging solution available in 30ml, 50ml and 100ml configurations. [7]
TOPFEELPACK also offers refillable and PCR airless options such as PA77 and PA103, allowing brands to evaluate different packaging strategies according to product requirements. [8][9]
The important point is that packaging sustainability should be considered at the complete-package level.
A product should not be described as “PPWR compliant” simply because it uses PP, PCR or a refillable structure. Final compliance depends on the applicable regulation, packaging configuration, market and supporting assessment.
A Better Question for Cosmetic Packaging Development
Instead of asking:
“What is the most sustainable airless bottle?”
Brands should ask:
“Which airless packaging system provides the right balance of formula protection, dispensing performance, material efficiency, recyclability, consumer experience and regulatory readiness for our target market?”
That question creates a much more practical packaging development process.
Conclusion
The PPWR marks a shift in the way packaging is designed for the European market.
For cosmetic brands, sustainability is moving from a marketing feature toward a technical and regulatory consideration.
For airless packaging, the most important areas to evaluate are:
1. Complete packaging composition
2. Design for recycling
3. Recycled content
4. Packaging minimisation
5. Refillability where commercially appropriate
6. Formula protection and dispensing performance
7. Market-specific recycling infrastructure
8. Technical documentation
Mono-material, PCR and refillable packaging can all be useful strategies—but none should be treated as a universal answer.
The strongest packaging solution is the one that works as a complete system.
Explore TOPFEELPACK Airless Packaging
Looking for an airless bottle supplier for your next cosmetic project?
Explore our:
Airless Packaging Collection
Mono-PP Airless Bottles
Refillable Airless Packaging
PCR Cosmetic Packaging
Or contact TOPFEELPACK for OEM/ODM airless packaging development.
Sources
[1] European Commission / EUR-Lex — Regulation (EU) 2025/40
[2] Eurostat — Packaging waste statistics
[3] European Union — PPWR Article 6
[4] ISO 18601 / ISO 18604
[5] European Union — PPWR Article 7
[6] Aptar Beauty — Airless Packaging Technology
[7] TOPFEELPACK — PA186 Mono-PP Airless Packaging
[8] TOPFEELPACK — PA77 Refillable Airless Bottle
[9] TOPFEELPACK — PA103 PCR Refillable Airless Bottle
Post time: Sep-22-2026
