It is important to distinguish between two key dates:
- The regulation entered into force in 2025, shortly after its publication in the Official Journal of the European Union
- It will apply from 12 August 2026, when most of its provisions become applicable
From that point onwards, companies placing products on the EU market will need to comply with new requirements related to packaging design, recyclability, labeling, and producer responsibility.
For the cosmetic industry, where packaging plays both a functional and branding role, this creates a new reality: packaging is no longer just a design choice, but a regulated and technically documented component of the product.
A Regulation Focused on Circularity
The PPWR aims to reduce packaging waste and support the transition to a circular economy. It applies to all packaging types—primary, secondary, and tertiary—and addresses the entire lifecycle, from design to end-of-life.
One of its central directions is that, by 2030, packaging placed on the market should meet recyclability criteria defined by the regulation, ensuring it can be effectively collected, sorted, and recycled.
This requires companies to integrate sustainability and compliance considerations from the earliest stages of product development.
Key Requirements You Need to Know
– Packaging Design and Minimisation
The regulation requires packaging to be designed so that its weight and volume are reduced to the minimum necessary to ensure functionality.
It also introduces restrictions on unnecessary packaging and excessive empty space, meaning companies should review formats and eliminate avoidable components where possible.
– Recyclability Requirements
Packaging must comply with design-for-recycling criteria defined at EU level.
The regulation introduces a performance-based recyclability assessment, which will classify packaging according to how effectively it can be recycled. These criteria will apply progressively, with key milestones from 2030 onwards and stricter thresholds over time.
In practice, this means companies need to:
- Identify the materials used (plastic, glass, metal, paper, multilayer)
- Ensure compatibility with recycling systems
- Consider how different components affect recyclability
– Recycled Content in Plastic Packaging
The PPWR establishes minimum recycled content targets for certain types of plastic packaging.
To comply, companies must:
- Verify the proportion of recycled material used
- Ensure traceability of that content
- Maintain supporting technical documentation
– Harmonised Labelling
The regulation introduces a harmonised EU system for packaging labelling, aimed at improving waste sorting and consumer information.
These requirements will be further specified through implementing measures and introduced progressively. Companies will need to ensure that labels are clear, legible, and consistent with EU rules.
– Extended Producer Responsibility (EPR)
The PPWR reinforces Extended Producer Responsibility, meaning that companies placing packaging on the market are responsible for its end-of-life management.
This includes registering as a producer or importer, reporting packaging data and financing waste management systems
These obligations coexist with national legislation, such as Royal Decree 1055/2022 in Spain.
– Technical Documentation and Compliance
A key element of the regulation is the requirement to demonstrate compliance through technical documentation.
Companies must be able to provide evidence that their packaging meets applicable requirements, including material composition, recyclability performance and recycled content (where applicable)
In the cosmetics sector, this information is typically integrated into the Product Information File (PIF) in line with sector-specific legislation.
From Regulation to Practice: What Companies Should Do
While the PPWR sets the legal framework, companies need to translate it into practical actions. A structured approach may include:
- Reviewing packaging portfolios to identify materials and formats used
- Collecting technical information from suppliers to support compliance
- Assessing packaging design against recyclability and minimisation criteria
- Tracking recycled content where required
- Preparing for new labelling requirements
- Ensuring alignment with EPR obligations
- Maintaining up-to-date documentation
Regular reviews will be essential, as requirements evolve and additional implementing measures are adopted.
Looking Ahead: Reuse and Future Developments
The regulation also introduces measures to promote reuse and refill systems in specific sectors and applications.
In addition, recyclability requirements will become stricter over time. For example:
- Detailed recyclability performance criteria will apply from 2030
- Lower-performing packaging categories are expected to be progressively restricted in the longer term
This reflects a broader transition towards higher-quality, more circular packaging solutions.
Why This Matters
The PPWR represents more than a regulatory update—it is a structural change in how packaging is approached in the EU.
For cosmetic manufacturers, it means:
- Greater emphasis on technical validation and traceability
- Stronger collaboration across the supply chain
- Integration of regulatory requirements into product development
At the same time, it offers an opportunity to simplify packaging, improve efficiency, and align with growing expectations around sustainability.
