PPWR for the Cosmetics Industry

Executive summary

The PPWR (EU Packaging & Packaging Waste Regulation) applies to all cosmetic packaging, from primary containers and pumps to cartons, sleeves, and shipping packs. Cosmetics does not get a sector exemption. It does get one named restriction, on single-use hotel miniatures. The bigger impact comes from the design and recyclability rules, since the finishes and formats common in beauty (metallised, opaque, multi-material, very small) are the hardest to recycle. The core documentation duties have applied since 12 August 2026, and the redesign pressure peaks around 2030.

Implications

1. Now applicable (from 12 August 2026)

• Declarations of conformity and technical documentation are required for each packaging type, held by the "manufacturer" (usually the party whose brand appears on the packaging)
• A general limit of 100 mg/kg applies to lead, cadmium, mercury and hexavalent chromium in packaging, including cosmetics
• The PFAS limits apply to food-contact packaging, so ordinary cosmetic packaging is not covered. Check the classification of any borderline products, such as edible lip products
• Non-EU brands generally need an authorised representative or EU-established importer, including for online sales

2. Highest-risk packaging formats

• Multi-material designs, dark or opaque pigments, and metallised finishes can score poorly on recyclability, potentially landing in grade D or E and becoming unsaleable in the EU from 2030
• Bonded sleeves, hot stamping, multilayer lacquers, multi-material pumps and airless systems all need review
• Sachets and sample-size products are often too small to be captured by sorting machinery
• Heavy "luxury" packs and unnecessary layers also fall under minimisation and empty-space rules (from 2030)

3. Named cosmetics restriction

• From 1 January 2030, single-use packaging for cosmetics, hygiene and toiletry products for use in accommodation is prohibited. This covers hotel miniatures under 50 ml or 100 g and is not limited to plastic
• The exact scope is still pending Commission guidelines due by 12 February 2027
• Brands with hospitality lines should plan a shift to refillable dispensers or another supply model

4. Later obligations (2028 to 2030)

• Harmonised labelling with standardised pictograms for material composition and sorting applies from 2028
• Minimum recycled content applies to plastic packaging from 2030. Product classification affects the targets for plastic cosmetic packaging
• From 1 January 2030, recyclability must meet a minimum performance grade under Design for Recycling criteria being developed by the Commission
• EPR fees may vary with recyclability, so poor design becomes a direct cost

5. Overlaps and uncertainties

• The PPWR sits alongside the Cosmetics Regulation. Packaging claims and labelling should be checked against both
• Implementing measures are still expected over the next two to three years, covering label formats and conformity assessment procedures

6. Suggested actions

1. Group SKUs by packaging construction and identify your legal role (manufacturer, importer, distributor)
2. Build declarations of conformity and technical files, and collect supplier evidence on heavy metals
3. Run a recyclability audit on pumps, sleeves, decoration, and small formats
4. Plan the exit from single-use hotel miniatures before 2030
5. Budget for EPR cost changes and recycled-content sourcing
6. Track implementing acts and national producer registers