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Sustainability and regulatory compliance have become two of the greatest challenges facing the European cosmetics industry. Against this backdrop, the new PPWR Regulation (Packaging and Packaging Waste Regulation) marks a major turning point for all companies manufacturing, importing or placing cosmetic products on the European Union market.
These new packaging and waste regulations introduce stricter requirements for packaging design, composition, recyclability and labelling, with the aim of reducing packaging waste, promoting a circular economy and harmonising requirements across all EU Member States.
Although many of the provisions will start to apply from August 2026, cosmetics businesses should already be assessing the impact that the EU PPWR will have on their packaging and internal processes.
To help brands navigate these new requirements with confidence and efficiency, Cosmeservice has developed a dedicated consultancy service to support compliance with the EU PPWR, from the initial assessment through to the implementation of the measures required to achieve full regulatory compliance.
What is the PPWR Regulation?
The PPWR Regulation is the new European legislation governing packaging and packaging waste. Its objective is to transform packaging management across Europe by promoting more sustainable packaging practices, reducing waste generation and encouraging the reuse and recycling of materials.
The main objectives of the PPWR Regulation include:
- Ensuring that all packaging placed on the EU market is recyclable by 2030.
- Reducing packaging waste.
- Increasing recycled content in specific packaging categories.
- Restricting the use of substances of concern.
- Improving the information provided to consumers.
- Harmonising packaging labelling requirements throughout Europe.
This regulation applies directly in every Member State, resulting in more consistent implementation and stricter obligations for economic operators.
How does the EU PPWR affect the cosmetics industry?
The cosmetics sector is among the industries most affected by these new packaging and waste regulations, owing to the complexity of cosmetic packaging formats and the wide variety of materials used.
Bottles, tubes, jars, pumps, aerosols, secondary cartons, promotional samples and multi-material packaging will all need to be assessed against the new criteria introduced by the PPWR Regulation.
New packaging requirements for manufacturers and brands
One of the most significant aspects of the PPWR Regulation is the introduction of packaging design requirements focused on recyclability.
This means packaging must be designed taking into account factors such as:
- Material compatibility.
- Ease of component separation.
- Elimination of unnecessary elements.
- Optimisation of packaging weight and volume.
- Progressive incorporation of recycled materials.
Businesses will need to demonstrate that their packaging complies with the technical criteria established under the legislation, as well as future European recyclability classification systems.
PFAS in packaging: an increasingly important issue
One of the areas receiving growing attention from regulatory authorities is the presence of PFAS in packaging.
PFAS (per- and polyfluoroalkyl substances) are chemical compounds widely used because of their resistance to water, grease and harsh environmental conditions.
The EU PPWR introduces specific restrictions for certain applications and strengthens controls on these substances due to their persistence in the environment.
Although many cosmetics companies do not intentionally use PFAS, it is advisable to review packaging materials, coatings, inks, adhesives and third-party supplied components to identify potential regulatory risks.
Recyclable Packaging and Recyclability: A core principle of the PPWR Regulation
Recyclability is one of the key concepts underpinning the new regulatory framework.
Businesses will no longer be able to simply claim that packaging is recyclable. They will need to demonstrate that it can be effectively collected, sorted and recycled within existing waste management systems.
This is particularly relevant for:
- Multi-material packaging.
- Metallised components.
- Pumps and dispensers.
- Labels that are difficult to remove.
- Complex closure systems.
Companies that begin assessing the recyclability of their packaging now will be better prepared for future requirements and avoid costly last-minute redesigns.
Labelling requirements for recyclable packaging
The PPWR Regulation also introduces significant changes to the labelling of recyclable packaging.
Its objective is to establish harmonised requirements across the European Union, making it easier for consumers and waste operators to correctly identify how packaging should be disposed of and recycled.
- Businesses should therefore prepare to update:
- Packaging labels, graphic design and on-pack information.
- Material identification systems.
- Recycling instructions.
- Associated technical documentation.
For cosmetics brands operating across multiple European markets, this harmonisation offers an opportunity to simplify compliance processes and reduce the costs associated with different national labelling systems.
Is your packaging ready to comply with the PPWR Regulation?
This is probably the most important question currently facing packaging, quality and regulatory affairs professionals.
Complying with the PPWR Regulation goes far beyond changing materials or updating labels. It requires a comprehensive review of a company’s entire packaging strategy.
Key questions include:
- Does our packaging meet future recyclability requirements?
- Do we have sufficient information about the materials used?
- Are our suppliers prepared to meet the new regulatory requirements?
- Are there any risks associated with PFAS or other restricted substances?
- Will our recycling labelling need to be updated?
- What investment will be required to ensure compliance?
Conducting this assessment early enables businesses to minimise risk, optimise resources and plan the transition more effectively.
Why is it important to act before the regulation applies?
Although many obligations will only become applicable from 2026 onwards, packaging compliance projects often require several months – or even years – of preparation.
Delaying implementation may lead to:
- Limited availability of alternative materials.
- Supply chain bottlenecks.
- Increased costs.
- Product launch delays.
- Regulatory non-compliance risks.
Companies that act early can turn regulatory obligations into an opportunity to improve sustainability and strengthen their competitive position with consumers, retailers and investors.
PPWR compliance services for cosmetics companies
To support businesses throughout this transition, Cosmeservice offers a comprehensive consultancy service dedicated to the PPWR Regulation, covering every stage of compliance – from the initial packaging assessment to ongoing regulatory support.
1. Packaging assessment
The first step is to review the company’s packaging portfolio in order to identify the applicable obligations and establish an effective compliance strategy under the EU PPWR.
Our specialists:
- Identify the applicable PPWR requirements for each packaging type.
- Assess the technical characteristics of packaging and its components.
- Evaluate recyclability and packaging design.
- Group similar packaging formats to streamline the assessment process.
- Develop a tailored compliance roadmap.
- Prepare a detailed project quotation.
2. PPWR compliance pack
Following the initial assessment, Cosmeservice provides comprehensive regulatory and technical documentation support to facilitate conformity assessment under the PPWR Regulation.
Our services include:
- Reviewing technical and regulatory documentation.
- Verifying completeness, consistency and traceability.
- Identifying documentation gaps.
- Assessing evidence supporting recyclability and sustainability requirements.
- Organising technical documentation.
- Preparing the technical compliance file.
- Drafting the EU Declaration of Conformity.
Where required, we also advise companies on gathering information relating to materials, components and substances potentially affected by future restrictions, including PFAS.
Please note that signing the EU Declaration of Conformity remains the sole responsibility of the manufacturer, as established under European legislation.
3. Ongoing PPWR compliance monitoring and authorised representative services
Packaging legislation will continue to evolve through implementing acts, technical guidance and additional obligations introduced under the PPWR Regulation.
For this reason, Cosmeservice also offers an annual monitoring service that helps businesses remain compliant with evolving packaging and waste regulations, including requirements relating to recyclable packaging, recyclability, sustainability and other regulatory obligations.
This service includes:
- Monitoring regulatory developments.
- Tracking new technical guidance.
- Keeping clients informed of upcoming obligations.
- Monitoring changes relating to substances and materials, including PFAS, where applicable.
- Acting as an authorised representative where required.
With ongoing expert support, businesses can anticipate regulatory changes, reduce compliance risks and ensure continued alignment with the PPWR Regulation.
To understand how the PPWR Regulation may affect your products and how to assess compliance across the EU market, complete our contact form or contact us at info@cosmeservice.com.
FAQs
When does the PPWR Regulation apply?
The PPWR Regulation entered into force in February 2025, with most of its provisions becoming applicable from August 2026.
Does it apply to all cosmetic packaging?
Yes. The PPWR Regulation applies to all packaging placed on the EU market, regardless of the material used.
Will businesses need to demonstrate recyclability?
Yes. Recyclability is one of the fundamental requirements introduced under the new regulatory framework.
How will PFAS affect packaging?
Restrictions on PFAS will gradually increase, making it essential to assess their presence in packaging materials and components.
Can Cosmeservice help my company comply with the PPWR Regulation?
Yes. Cosmeservice supports cosmetics businesses throughout every stage of compliance with the PPWR Regulation, from the initial gap analysis through to the implementation of the measures required to achieve full regulatory compliance.
