With the new Regulation (EU) 2025/40, the sustainability of cosmetic packaging becomes a compliance issue: minimization, recyclability, recycled content, and labeling are now included in the scope of safety and technical documentation.
With the new Regulation (EU) 2025/40 — the Packaging and Packaging Waste Regulation (PPWR) — the European Union has redefined the regulatory framework for packaging, introducing binding targets on packaging minimization, recyclability, and the use of recycled materials. As of 12 August 2026, the first operational provisions of the PPWR begin to apply: from that date onward, packaging sustainability is no longer just a design objective, but becomes part of compliance management.
In the cosmetics sector, which is both highly attractive and highly material-dependent, the most relevant development is that packaging sustainability is becoming a compliance obligation: no longer merely a corporate value, but a technical and documentary requirement that must be demonstrated.
Regulatory Context
The PPWR introduces harmonized criteria for the design, labeling, and management of packaging in order to reduce waste and strengthen the circular economy.
For companies, this means a profound rethink of products and supply chains:
- Packaging minimization: the obligation to reduce weight and volume, while demonstrating the functional necessity of the packaging.
- Recyclability: packaging must meet technical criteria compatible with European recycling streams.
- Recycled content (PCR): minimum mandatory shares of recycled material, especially for plastics.
- Environmental labeling: transparency and consistency in collection instructions, including for small cosmetic formats.
- Technical packaging dossiers: these must include evidence of recyclability, composition, material safety, and compatibility with the cosmetic formula.
Impact on the Cosmetics Sector
The PPWR creates an integration between packaging regulation and cosmetic regulation: safety, compatibility, and environmental communication will be interdependent.
The impact of the PPWR is significant at several levels:
1. Redesign of primary and secondary packs
– Review of decorative components (coatings, metallization, plastic labels) to ensure real recyclability.
– Greater pressure toward mono-materials to facilitate recycling.
– Introduction of refill formats and reusable solutions with specific hygiene and safety requirements.
2. Verification of PCR material safety
– The Product Information File (PIF) will need to be updated with evidence of material safety and conditions of use.
– Post-consumer recycled materials must be assessed in terms of compatibility with the cosmetic formula, migration, and stability.
3. Documentary compliance
– All data on packaging composition and weight must be traceable and available for compliance audits.
– In addition to technical environmental documentation (for recyclability and recycled content), the PPWR requires verification procedures for packaging minimization.
4. Labeling and consumer information
– Standardized collection symbols and clear indication of the main material are required.
Cosmetics companies should begin a structured regulatory and technical transition. These activities are not merely formal adjustments: the use of PCR, the reduction of weight and volume, and the mono-material solutions required by the PPWR are not only environmental constraints, but critical factors that directly affect the assessment of cosmetic safety (CPSR). PCR introduces variability (contaminants, NIAS) that may alter interactions with the formula, compromising shelf life through accelerated migration or loss of barrier performance; minimization reduces thickness, increasing susceptibility to mechanical stress, microcracking, and permeation of O2/H2O; mono-materials limit barrier options, requiring specific tests on pH, oils, and active ingredients to maintain stability and inertness. These choices must be validated in the PIF through accelerated testing, ensuring that sustainability does not compromise consumer safety.
PPWR compliance is not just a sustainability issue — it is a regulatory necessity.
As of 12 August 2026, the first operational provisions of the PPWR begin to apply.
The technical-regulatory assessment of packaging (recyclability, PCR safety, minimization, environmental labeling) must be integrated into the PIF.
Have you already checked whether your cosmetics packaging complies with the new PPWR requirements? Contact us for a tailored technical and regulatory assessment.