A turning point for sustainable by design: the EU Packaging and Packaging Waste Regulation

The EU Packaging and Packaging Waste Regulation (PPWR) marks a shift in the regulatory landscape for the cosmetics industry, transforming packaging from a marketing-driven element into a core component of compliance and sustainability strategy. By introducing stricter requirements on recyclability, recycled content, labelling, and extended producer responsibility, the Regulation challenges long-established packaging practices – particularly in a sector characterised by complex, multi-material formats. At the same time, it accelerates the transition towards circular models, including reuse and refill systems, while increasing the need for robust data, traceability, and cross-value chain collaboration. As implementation will be phased and further defined through secondary legislation, companies must navigate evolving requirements while anticipating future developments. Ultimately, the PPWR not only raises compliance expectations but also creates opportunities for innovation, differentiation, and improved environmental performance within the European Single Market.

Driven by a combination of consumer, investor and regulatory demands the cosmetics industry is undergoing a profound transformation, as sustainability moves from a ‘nice-to-have’ marketing concept to a mandatory regulatory requirement. In recent years, the highest policy momentum has been linked to the European Union, particularly through its Green Deal – a strategy adopted in 2020 by the European Commission aiming to transform Europe’s economy, energy, transport, and industrial systems to a more sustainable model, with the overarching goal of making the EU climate-neutral by 2050

A centrepiece legislative reform has been the replacement of the Packaging and Packaging Waste Directive (PPWD)[1], which first entered into force in the mid-1990s. The PPWD had three key objectives: to reduce packaging, to reduce waste from packaging, and to reduce hazardous substances. Together, these formed the ‘essential requirements’ of the legislation.

A core part of the reform was the introduction of a harmonised regulatory approach resulting in the Packaging and Packaging Waste Regulation (PPWR)[2]. The shift to a Regulation from a Directive ensures directly applicable rules across all Member States, helping to avoid a fragmented regulatory landscape within the European Single Market, while also setting a clearer framework to improve the environmental performance of packaging.

For the cosmetics sector, this change brings greater clarity from a single rulebook, but also new challenges, as sustainability requirements and standards become more stringent and comprehensive than before. Given cosmetics is a sector where packaging is commonly linked to brand identity, the implications of this revision are particularly significant.

Regulatory priority, new responsibilities

Packaging plays a central role in cosmetics. Beyond its functional purposes – protecting formulations, ensuring safety, and enabling precise application – it is also a key part of the frontline to consumer awareness and appeal. The choice of materials, designs, and multi-layered packaging have traditionally been used to signal quality and differentiate brands.

The PPWR officially entered into force on 11 February 2025, challenging the traditional model by introducing requirements that directly target excess and redundant packaging. These introductions widen the scope from the PPWD by not only reducing (over)packaging and packaging waste, but also with measures to promote packaging reuse, improve recycling, and increasing the uptake of recycled content in packaging.

The PPWR scope is horizontal and wider than covering simply what is received by a consumer. Indeed, it covers packaging at every stage: from raw materials to processed goods, through storage and distribution. As such, primary (e.g., sold to end consumer), secondary (e.g., grouped products), and tertiary (e.g., transport) packaging can fall under the requirements.

Key obligations include:

• Packaging minimisation: limits on weight, volume, double walls, and maximum empty space in e-commerce packaging
• Substances: reduction of ‘substances of concern’; the combined total of lead, cadmium, mercury, and hexavalent chromium (sum of) should not exceed 100 mg/kg; food-contact packaging containing PFAS above specific concentrations is restricted
• Labelling: clear information on packaging composition to facilitate consumer sorting (by 2028)
• Recycled content: from 2030, a minimum amount of post-consumer recycled (PCR) content must be incorporated into plastic packaging (e.g., 30% for PET)
• Recyclability: all packaging should be recyclable via material recycling by January 2030 and ‘at scale’ by January 2035; recyclability will be graded A, B and C. Also, from January 2038, only grades A and B may be used.
• Reusability: targets for reusable packaging
• Prohibition of packaging types: e.g., single-use plastic packaging for foods and beverages filled and consumed on site.
• Extended Producer Responsibility: not new, but the Regulation is likely to strengthen the focus on Extended Producer Responsibility (EPR), with fees modulated based on recyclability

The introduction of recyclability requirements for all packaging, including design for recycling criteria from January 2030, and the recyclability at scale obligation from January 2035, are key milestones.

From 12 August 2026, the legislation will apply EU-wide, setting requirements on packaging for any operator placing a product on the Union market. Furthermore, application of the PPWR will also lead to secondary legislation, including delegated and implementing acts. Implementation resources[3] and a FAQ guide[4] have already been published by the European Commission, as well as from representatives of the packaging industry value chain, who have published a guidebook to the PPWR[5] to help stakeholders navigate the new requirements.

Design for recycling: A technical challenge

One of the most consequential aspects of the PPWR is the requirement that all packaging placed on the EU market must be recyclable by 2030. While this objective is straightforward in principle, its implementation is complex – especially for cosmetics.

Cosmetic packaging is often inherently multi-material. Airless pumps, droppers, and dispensing systems combine plastics, metals, and sometimes glass to ensure product integrity and user convenience. Innovative new packaging is therefore required to bridge any gaps, ensuring that materials can be effectively separated and processed within existing recycling systems, which are not always designed to handle complex, multi-material formats.

Indeed, compliance with the legislative landscape will require integrating an eco-design strategy into any project. To this end, packaging would need to be designed for optimised resource use, sustainable sourcing, reduced waste and environmental impact, and improved recycling. Given the focus on a circular economy approach, the need for recyclates that are not only high quality, but for which the traceability of that quality can be monitored throughout the chain of custody, become essential elements. This is particularly important to ensure that recycled materials incorporated into the packaging for finished cosmetic products can be properly assessed and safely used, without triggering non-compliance to cosmetic legislation or posing any risk to consumer’s health.

The push towards simplified component solutions seems a logical step, as does the use of mono-material solutions. However, these changes are not without trade-offs. Packaging must still protect sensitive formulations from contamination, oxidation, and degradation. Achieving recyclability without compromising product safety or performance is therefore one of the central technical challenges, alongside ensuring that products remain practical to transport and appealing and convenient for consumers to use.

A fundamental question for recycling is whether there is a sufficient grade of recycled packaging materials on the market for cosmetic manufacturers, at a price that is affordable and with a quality that is permissible by law for safety. Furthermore, there is the question of how to calculate and verify recycled content in a consistent and reliable way. To answer this, by January 2029, the Commission will adopt delegated acts and establish a methodology by assessing the available recycling technologies.

The role of guidance

Although the PPWR sets out the overarching framework, many of its most critical elements will be further defined through guidance and secondary legislation developed by the European Commission. This evolving regulatory layer is especially important for the cosmetics sector, where compliance often hinges on technical detail.

One key area is packaging labelling. The PPWR foresees the introduction of harmonised EU-wide waste sorting labels, replacing the current patchwork of national systems. These labels are expected to focus on material composition, enabling consumers to sort packaging correctly regardless of where they are in the EU. Recently, a technical proposal on waste sorting labels was published by the European Commission’s Joint Research Centre[6].

For cosmetics, this presents a particular challenge. Packaging frequently consists of multiple components – such as bottles, caps, pumps, and applicators – each of which may consist of different materials. Understandably, the PPWR infers the need for close coordination between packaging designers, regulatory specialists, and supply chain partners to ensure overall compliance for operators placing products the market.

Recognising the constraints of small packaging formats, the Commission has also signalled support for digital labelling solutions. These may allow companies to provide detailed information – such as material composition and recycling instructions – through QR codes or similar technologies, complementing physical labels where space is limited

Defining compliance

The PPWR is highly reliant on implementing and delegated acts to establish the technical rules that underpin compliance. While the Regulation sets the direction, these secondary measures will ultimately determine how its provisions are applied in practice and interpreted across Member States.

Among the most forthcoming measures are design-for-recycling criteria, recyclability performance grades, and methodologies for assessing “recycled at scale”. These elements are particularly important, as they will translate broad regulatory objectives into concrete, measurable requirements.

For cosmetics companies, these measures are critical. They will influence material choices, packaging formats, and even product architecture. At the same time, their phased adoption creates a moving regulatory target, requiring companies not only to respond to current requirements, but also to anticipate future developments and adapt their strategies accordingly.

Reuse, refill, and new business models

Beyond recyclability, the PPWR promotes a general shift toward all methods to support circularity by encouraging reuse and refill systems. While the Regulation does not impose uniform reuse targets across all cosmetic categories, it clearly signals a policy preference for reducing single-use packaging and moving towards more circular models.

Refillable packaging is therefore gaining traction across the industry. From reusable fragrance bottles to refillable skincare containers, brands are experimenting with new formats that extend the lifecycle of packaging. However, scaling these models presents practical challenges, including safety considerations, reverse logistics (i.e., the collection, cleaning, and redistribution of packaging), and consumer acceptance of return-and-reuse formats.

Equally, the PPRW can impact segments of the cosmetics industry that rely on high-volume, low-size packaging, such as the hospitality industry, which has traditionally depended on single-use formats, including small hotel toiletries.

A new compliance landscape

The PPWR fundamentally changes the compliance landscape for cosmetics companies. Packaging can no longer be treated as a secondary consideration or a purely marketing-driven element. Instead, it becomes a central pillar of regulatory strategy.

The PPWR see a significant expansion of extended producer responsibility (EPR), with mandatory digital reporting systems for all EPR schemes, harmonised methods for calculating fees across the EU, new eco-modulation criteria based on packaging recyclability, an extended scope to cover all packaging types and formats, and increased transparency requirements for cost calculations.

Compliance now requires a detailed understanding of material composition, recyclability, and supply chain dynamics. Companies must invest in data collection, testing, and documentation to demonstrate that their packaging meets evolving EU standards. Collaboration across the value chain is key.

Following its application across all 27 EU Member States in August 2026, sequential implementation will take place, with rolling and improving targets from 2030 through to 2040. Key milestones in 2035 and 2038 will further restrict the use of low-grade recyclable materials and contribute to the reduction of packaging waste.

Conclusion: redefining cosmetic packaging

The PPRW represents a turning point, given it challenges established practices and compels companies to rethink their approach. Yet it also creates an opportunity as sustainability considerations remain a feature of the European Single Market, offering companies a path to differentiate themselves through innovation, transparency, and environmental performance.

In this new context, packaging is no longer just a container for the product, but rather an additional reflection to a brand’s sustainability commitments. The key action points for operators now remain to understand the new requirements and navigate legal uncertainties, conduct an audit on the current and future compliance, establish a compliance strategy with supplier involvement, implement the strategy alongside appropriate  due diligence systems for data recording and storing of information, and final ensure monitoring and adaptation as new requirements are phased in.

Lastly, to work as intended, its ambitious policy goals must be supported by the timely adoption of secondary legislation. The main risk lies in regulatory uncertainty for businesses: even if there is strong support for regulatory enforcement, the need to secure and sustain investment in innovation is paramount to drive greater efficiency, ensure compliance, and enable the transition to more sustainable packaging systems.

 

Article written by Dr Mark Smith, NATRUE Director General, and originally published on China CNCRDJ (available here.)

References:

[1] https://eur-lex.europa.eu/eli/dir/1994/62/oj/eng

[2] https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ:L_202500040&pk_campaign=todays_OJ&pk_source=EUR-Lex&pk_medium=X&pk_content=Environment&pk_keyword=Regulation

[3] https://green-forum.ec.europa.eu/packaging-and-packaging-waste-regulation-implementation_en

[4] https://ec.europa.eu/commission/presscorner/detail/en/ip_26_664

[5] https://www.ppwr-guidebook.eu/

[6] https://publications.jrc.ec.europa.eu/repository/handle/JRC141706