Navigating the EU PPWR: Cosmetic Packaging Compliance Guide

April 16, 2026

The EU PPWR (Packaging and Packaging Waste Regulation – Regulation (EU) 2025/40) will enter into force in August 2026. The EU PPWR will replace the existing Packaging Directive with an EU-wide regulation that applies directly across all Member States.

Packaging waste grew by 20% in the EU over the last few years, and now regulators are fighting and regulating from the design phase to avoid it. For cosmetic brands, the EU PPWR introduces new requirements for cosmetic packaging, impacting design, materials, and compliance obligations.

At Cosmeservice, as your regulatory partner, we have structured this article to help you understand the core pillars of the EU PPWR and what they mean for cosmetic brands operating in the EU market.

What is the EU PPWR and what does it mean for cosmetic packaging?

The EU PPWR (Packaging and Packaging Waste Regulation – Regulation (EU) 2025/40) entered into force on 11 February 2025, and its primary obligations will begin to apply from 12 August 2026.

The EU PPWR will require almost all packaging placed on the EU market after 2030 to be reusable or recyclable, with defined levels of recycled content and restrictions on oversized packaging.

This is not merely a “sustainability update.” It is a fundamental change in how products must be designed, labelled, and managed at their end-of-life cycle.

The landscape of cosmetic regulation is undergoing a great shift. While the industry has traditionally focused on Regulation (EC) No 1223/2009 and the safety of substances inside the product, the EU PPWR now places strong regulatory focus on cosmetic packaging itself.

The Shift: From Directive to Regulation

Historically, packaging waste was governed by a Directive, which allowed Member States significant leeway in implementation. This led to a fragmented European market with varying recycling logos and requirements. Every country in the EU has its own system, symbols, and obligations for companies placing their products in the different markets.

The EU PPWR changes this approach by being a Regulation. This means the EU PPWR is directly applicable across all EU Member States, presumably harmonising requirements and reducing the national variations – provided you comply with the new, stricter central standards.

The EU PPWR is a long-term regulatory roadmap, not a single deadline. It all starts in 2026, a major milestone, but not all technical details are fully defined.

Let’s take a closer look at the EU PPWR (Packaging and Packaging Waste Regulation) and check if this will happen and how.

Key Pillars of the EU PPWR for Cosmetic Packaging

The EU PPWR is built upon several critical requirements that directly impact the secondary and primary packaging of all cosmetic products, such as perfumes, skincare, and make-up…

All of them that have any packaging, a bottle, a box, a can, a jar, any of them. Let’s check the requirements:

Mandatory Recyclability (2030 Deadline)

By 1 January 2030, all packaging placed on the EU market must be designed for recycling. The regulation introduces “Design for Recycling” (DfR) criteria. Packaging will be graded from Grade A to E based on its recyclability.

The Impact: Packaging graded ‘E’ (less than 70% recyclable) will be considered non-compliant under the EU PPWR and effectively banned from the market by 2030.
Cosmetic Challenge: Multi-material components, such as airless pumps with metal springs or complex caps, will need significant R&D to meet these criteria.

Minimum Recycled Content in Plastic Packaging

The EU PPWR supports a circular economy by requiring minimum levels of post-consumer recycled (PCR) content in plastic packaging.

By 2030: Most plastic packaging must contain at least 35% recycled content.
By 2040: This target rises significantly.

Note: For brands, this means securing high-quality PCR material that does not compromise the aesthetic “prestige” of the packaging. This will be a significant hurdle for luxury skincare.

Packaging Minimisation and “Empty Space” Restrictions

The EU PPWR introduces a strict ban on “over-packaging.” Packaging must be reduced to the minimum necessary to ensure product safety and functionality.

The 50% Rule: For grouped or e-commerce packaging, the “empty-space ratio” must not exceed 50%.
Goodbye, excessive luxury: Double-walled jars or oversized boxes designed solely to create a “premium” feel will likely face scrutiny under the new “performance criteria.”

Technical documentation and Declaration of Conformity (DoC)

The EU PPWR requires all cosmetic companies to prepare complete technical documentation and an EU Declaration of Conformity (DoC) for each packaging unit placed on the EU market.

This document should contain the identification of the packaging and a detailed description, manufacturer details, conformity with the EU legislation, and the tests and standards that prove compliance. The packaging suppliers must provide the information, and brands that place packaging under their name are considered responsible for it.

NOTE: This is not a Supplier Declaration. It is a legal assumption that cannot be disclaimed. When signing the Declaration of Conformity (DoC), certain requirements should be checked, such as:

Heavy Metal Limits
PFAS Restrictions
Substantiated Reusable Claims

Labelling: the new language of waste under the EU PPWR

One of the most visible changes introduced by the EU PPWR for cosmetic packaging is the harmonisation of labelling requirements, which will simplify compliance for Regulatory Departments.

The European Commission is expected to adopt uniform symbols under the EU PPWR to help consumers sort waste. These labels will be mandatory across the EU, finally replacing the confusing array of national symbols like the French Triman or the Italian environmental codes.

Providing some of the information via QR codes is becoming a preferred method to reduce physical packaging size while maintaining transparency, but the mandatory information listed in Regulation (EC) No 1223/2009 will always be required on the packaging itself.

EU Commission guidance on the EU PPWR for the Industry

The European Commission has issued draft guidance on the EU PPWR (Regulation (EU) 2025/40), providing a clearer interpretation of key provisions ahead of its application in August 2026.

The EU PPWR guidance contains key clarifications about what qualifies as packaging (a function-based approach), a classification based on use, and a definition of multi-component packaging and its requirements, the definition of reusable vs single-use, the responsibility in the supply chain, and clarifications provided on the application of requirements.

Despite these clarifications, key gaps remain, as a recent parliamentary question highlighted that no clear methodology to determine PFAS in food-contact packaging has been settled yet, and uncertainty on conformity assessment procedures is still in the air.

The Commission’s position is that national labels like Triman (France) are not compatible with the EU PPWR and will not be allowed alongside the new EU harmonised labels. Soon, national requirements must be repealed or adapted by new labelling rules and pictograms.

In addition, not all use cases are covered now; some interpretations remain case-by-case, and further clarification will come through a living FAQ document by the European Commission.

EU PPWR Living FAQ by the European Commission

The European Commission has published a Living FAQ document to support the implementation of the EU PPWR, providing ongoing clarifications and reinforcing the importance of a harmonised EU Single Market to enable circularity at scale. This EU PPWR FAQ will be updated regularly as new interpretations and requirements are defined.

One of the most important clarifications published in the FAQ document is the distinction between a manufacturer and a producer, two concepts that serve entirely different legal functions under the EU PPWR. The manufacturer, typically the brand owner or the company that decides on packaging design, bears the responsibility for conformity with the sustainability and labelling requirements. On the other side, the producer, identified market by market, carries the EPR obligations in each Member State where packaging is first made available.

Regarding PFAS, the European Commission has introduced a three-step enforcement approach under the EU PPWR for food-contact packaging, effective from 12 August 2026, with no transitional period. For companies handling food-contact packaging in their supply chain, compliance documentation needs to be in order now!

Industry will require further clarity and certainty to effectively apply the Regulation in practice while delivering its circularity objectives. As acknowledged by the Commission, several implementing measures are foreseen over the next two to three years.

Critical Deadlines: The Road to 2030

Milestone	Date	Requirement
Entry into Force	2025	Regulation became law. PPWR Entry into force.
Date of Application	2026	Core obligations and labelling specifications begin.
Labelling Requirements	2028	Uniform labelling and waste symbols are expected to become mandatory across the EU.
Recyclability Target	2030	All packaging must be “Design for Recycling” compliant. Mandatory recyclability grades, minimum recycled plastic content, and reuse objectives will be mandatory

Strategic Advice: Compliance is Key

Preparation is not just about compliance; it is about competitive advantage. Even with the FAQ guidance published, significant implementation questions remain, around PFAS testing methodology, EPR reporting, and recyclability criteria. Delegated acts still to come to clarify how technical documentation must be prepared, which economic operator bears which obligation, and when conformity assessments are required.

It’s on our side to inform you about the Secondary Acts. The EU will release “Implementing Acts” throughout 2026 to define the exact format of labels and EPR registration. Stay tuned to the Cosmeservice Blog for these updates.

Here is our advice to prepare. The first step should be to conduct a packaging audit. Review your entire portfolio and identify “at-risk” products, specifically those with multi-material components or high “empty-space” ratios. The second step should be engaging with your suppliers now: Ensure your packaging manufacturers are aware of the DfR (Design for Recycling) criteria and can provide certified PCR content.

PPWR is no longer just a new regulation published; it’s becoming an operational challenge. Uncertainty now shifted from legal interpretation to data collection, traceability, and real implementation, compliance will no longer depend only on understanding the regulation, but on making it work.

Cosmeservice Key Takeaways on the EU PPWR

At Cosmeservice, we don’t just track the law – we translate the EU PPWR into actionable steps for your brand. Our team of experts is ready to assist you with regulatory analysis, labelling review, and global regulatory strategy, aligning your strategy with other global requirements.

Key changes introduced by the EU PPWR:

Packaging becomes a fully regulated component of the cosmetic product
Substances of Concern (SoC) must be minimised
PFAS restrictions apply from August 2026 for food-contact packaging

To comply with the EU PPWR, cosmetic companies must ensure traceability, documentation, and technical validation. New rules on packaging design, labelling, reuse, and waste reduction will apply, with all packaging required to be recyclable by 2030.

A key challenge is that the EU PPWR does not operate in isolation. It interacts with other regulatory frameworks, including:

REACH and chemicals regulation
Food contact legislation
Cosmetic sector-specific regulations

The transition to the EU PPWR is complex, but you don’t have to navigate it alone. For more information on how the PPWR affects your specific product range, contact our team.

The future of cosmetics is circular – let’s build it together!

FAQs

What is the EU PPWR?

The EU PPWR (Packaging and Packaging Waste Regulation) is a regulation governing packaging sustainability, recyclability, and compliance across the European Union. At Cosmeservice, we help cosmetic brands interpret EU PPWR requirements and translate them into practical compliance strategies.

When does the EU PPWR apply?

The EU PPWR will become mandatory from August 2026 for all packaging placed on the EU market. Cosmeservice supports companies in preparing ahead of this deadline to ensure a smooth transition and avoid compliance risks.

Does the EU PPWR affect cosmetic packaging?

Yes, the EU PPWR introduces specific requirements for cosmetic packaging, including recyclability, labelling, and technical documentation. Cosmeservice assists brands in adapting their packaging to meet EU PPWR standards while maintaining product quality and design.

What is a Declaration of Conformity under the EU PPWR?

A Declaration of Conformity (DoC) under the EU PPWR is a document that proves packaging complies with Regulation (EU) 2025/40 and must be available for each packaging type. Cosmeservice helps companies prepare and review DoC documentation to ensure full regulatory compliance.

References

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