Date: 18 September 2026
Prepared for: Importers, Manufacturers, Suppliers and Buyers of Cosmetic Products for the EU Market
EU Packaging and Packaging Waste Regulation (PPWR) Now in Force – Traceability and Importer Obligations Apply Immediately
On 12 August 2026, Regulation (EU) 2025/40 on packaging and packaging waste (PPWR) became generally applicable across all EU Member States, replacing the Packaging and Packaging Waste Directive (94/62/EC).
The PPWR applies to all packaging placed on the EU market regardless of material, product category, or whether it is produced within the EU or imported from third countries. This includes primary cosmetic packaging (bottles, jars, tubes, pumps, droppers, compacts), secondary packaging (cartons, shrink wrap), and transport packaging such as outer cartons.
For cosmetic businesses exporting to the EU, the PPWR introduces a fundamentally different compliance framework. It is no longer sufficient to ensure that the product formulation meets the Cosmetics Regulation — the packaging itself is now subject to its own set of mandatory requirements, and several of these obligations are already in force.
Background:
The PPWR was published in the Official Journal on 22 January 2025 and entered into force on 11 February 2025. It became generally applicable from 12 August 2026, with certain provisions phasing in over time.
The Regulation aims to reduce packaging waste per capita by at least 5% by 2030, 10% by 2035, and 15% by 2040 (compared to 2018 levels). It also introduces harmonised requirements for recyclability, recycled content, packaging minimisation, labelling, and extended producer responsibility (EPR).
Unlike the previous Directive, which required transposition into national law, the PPWR is directly applicable in all Member States. There is therefore less flexibility at national level to soften or adapt the obligations, and the requirements are consistent across the EU.
Timeline:
The PPWR requirements are being introduced in phases. The table below summarises the milestones most relevant to cosmetic packaging.
Requirement | What It Means for Cosmetic Packaging | Effective date |
Substance restrictions (Article 5) | 1. Heavy metals (Pb + Cd + Hg + Cr VI) ≤ 100 mg/kg in packaging or components, assessed per homogeneous material; 2. PFAS limits apply to food-contact packaging and PFAS must not be intentionally added | 12 August 2026 |
Traceability and identification (Article 15) | Packaging must carry a packaging identification element (batch or item number), and the manufacturer's or importer's EU contact details | 12 August 2026 |
Declaration of Conformity (Article 39) and EPR | Manufacturers of packaging or packaged products must draw up a DoC; producer registration and EPR obligations apply | 12 August 2026 |
REACH restriction measures and recycled content implementing act | Prepare report on substances of concern in packaging; implementing act on minimum recycled content in plastic packaging | 31 December 2026 |
Packaging minimisation standards and reusable packaging authorisation act | Commission to request harmonised standards on packaging minimisation; delegated act on minimum rotation numbers for reusable packaging | 12 February 2027 |
Recyclability design and performance grading requirements | Requirements for recyclable packaging design and performance grades established | 1 January 2028 |
Bio-based plastic sustainability requirements and compostable packaging design | Commission to propose legislation on bio-based feedstock sustainability and use ratios; compostable packaging design requirements | 12 February 2028 |
Harmonised packaging labelling and digital labelling | All packaging must carry harmonised sorting labels; digital labelling introduced. Applies from 12 August 2028 or 24 months after the relevant implementing act enters into force. | 12 August 2028 |
Calculation and verification of minimum recycled content | Compliance with recycled content calculation methodology applies | 1 January 2029 |
Reusable packaging labelling requirements | Reusable packaging must carry specific labelling | 12 February 2029 |
Recyclability (Article 6) | All packaging must achieve at least Grade C recyclability (≥70% recyclable). Packaging below Grade C will be prohibited from the EU market. Applies from 1 January 2030 or 24 months after the relevant delegated act enters into force. | 1 January 2030 |
Minimum recycled content for plastic packaging (Article 7) | Plastic components must contain minimum post-consumer recycled (PCR) content — 30% for PET contact-sensitive packaging; 10% for other contact-sensitive plastic packaging; 35% for other plastic packaging. Applies from 1 January 2030 or 3 years after the relevant implementing act enters into force | 1 January 2030 |
Packaging minimisation (Article 10) | Packaging weight and volume must be reduced to the functional minimum. Empty space in grouped, transport, and e-commerce packaging must not exceed 50%. Applies from 1 January 2030 or 3 years after the relevant implementing act enters into force. | 1 January 2030 |
Stricter recyclability | Only Grade A or B packaging (≥80% recyclable) may be placed on the EU market | 1 January 2038 |
Recycled content increase | PET contact-sensitive: 50%; non-PET contact-sensitive: 25%; other plastic: 65% | 1 January 2040 |
Why Cosmetic Packaging Is Particularly Challenging
Cosmetic packaging presents specific difficulties that make PPWR compliance more complex than for many other product categories.
l Complex multi-material design: Cosmetic packaging frequently combines plastics, metals, glass, elastomers, inks, adhesives, and coatings within a single packaging unit. A pump dispenser, for example, may contain a PP body, a metal spring, an elastomer seal, and a metallised coating. Each component must be assessed separately for heavy metal compliance, and the complete packaging unit must be assessed for recyclability.
l Small formats with limited labelling space: Lipsticks, mascara tubes, ampoules, and sample sachets have very limited surface area for the packaging identification and manufacturer/importer details required from 2026 and even less for the harmonised sorting labels required from 2028.
l PCR compatibility: Introducing post-consumer recycled content into cosmetic packaging can affect colour, odour, mechanical strength, barrier properties, and critically compatibility with the cosmetic formulation. PCR sources must be certified, and stability and compatibility testing is required. Recycled content is calculated as an average across production facilities, on an annual basis, and by packaging type and format not per individual bottle.
l Recyclability of complete packaging units: PPWR assesses whether the complete packaging unit can be effectively collected, sorted, and recycled not whether individual materials are theoretically recyclable. A recyclable PP bottle paired with a non-recyclable pump head or a full-body shrink sleeve may fail the overall assessment.
l Single-use hotel amenity packaging. From 1 January 2030, single-use cosmetic and personal care packaging intended for hotel stays where the product is discarded before the next guest arrives will be prohibited. This includes shampoo bottles, lotion bottles, and soap wrappers. This restriction is not limited to plastic, and should not be generalised as a ban on all retail sample sizes. Hotel suppliers should evaluate refillable, fixed dispenser, or reusable alternatives.
What this means for you
The PPWR brings several obligations that apply regardless of whether you are a packaging manufacturer, a brand owner, or a buyer. The following actions are relevant to your compliance planning.
l Confirm importer information is on the packaging. If you import from outside the EU, your EU importer's name, address and contact details must appear on the packaging, including outer cartons. This is already in force.
l Prepare the DoC and technical documentation. From 12 August 2026, a DoC is required, clarify who bears the DoC and EPR obligations. If you manufacture complete empty packaging or the packaged product, you are likely the "manufacturer" under PPWR and must prepare the technical documentation and DoC yourself.
l Align test report batch numbers with your DoC and packaging ID. The DoC must contain a unique packaging identification, and the packaging ID on the label must match the DoC. All test reports must be traceable to that identification at batch level. A packaging ID can be batch or serial number, or an equivalent identifier for traceability. Technical documentation and DoC must be retained for 5 years for single-use packaging, and 10 years for reusable packaging.
l Map your packaging BOM and plan your testing programme. Record every component, material, weight and supplier for each packaging format.
l Arrange the necessary testing and conformity evidence. Depending on your packaging type, this may include:
ü Heavy metal testing — Pb, Cd, Hg, Cr(VI); total ≤ 100 mg/kg;
ü PFAS screening — total fluorine (TOF) and targeted PFAS where applicable
ü REACH Annex XVII and SVHC screening where applicable
ü Recyclability assessment — against EN 13430 or an equivalent recognised protocol
ü Recycled content verification — GRS, RCS, ISCC or ISO 14021 certification for PCR claims
ü Packaging minimisation assessment — against EN 13428
ü Reusable packaging assessment — against EN 13429, where applicable
l Review packaging against 2030 requirements, including recyclability grading and PCR content. Identify formats unlikely to achieve Grade C recyclability or where PCR content may be difficult to source. For plastic packaging, check which recycled content category applies: PET contact-sensitive (30%), non-PET contact-sensitive (10%), or other plastic (35%).
l Evaluate hotel amenity packaging. If you supply single-use cosmetic or personal care products for hotel use, assess refillable or reusable alternatives ahead of the 1 January 2030 prohibition. Verify durability, cleaning, sealing, and contamination control.
l Coordinate EPR registration in each EU member state. Producer registration and EPR obligations apply from 12 August 2026. If you place packaging on the market in multiple member states, registration is required in each one.
How We Can Support You
We assist brands, buyers, and packaging suppliers with the practical steps required under PPWR:
l Substances in Packaging: Heavy metal testing — Pb, Cd, Hg, Cr(VI); total ≤ 100 mg/kg; PFAS screening, REACH SVHC and POPs testing if applicable
l Technical documentation — packaging BOM, material declarations, and supplier evidence
l DoC support — preparation and review for brand owners and manufacturers
l EPR registration — EPR registration guidance etc.
Reference: Regulation (EU) 2025/40 on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904, and repealing Directive 94/62/EC
© 2026 EASYHARMONY TECHNOLOGY CO., LIMITED (EHC). All rights reserved.