Regulation (EU) 2025/40 generally begun to apply on August 12, 2026. Under the Windsor Framework, much of the regulation applies in Northern Ireland, while Great Britain remains outside the EU PPWR framework. This creates an important distinction for companies selling cosmetics and other packaged products across the UK.
For businesses operating across England, Scotland, Wales and Northern Ireland, the key question is therefore not simply whether the PPWR applies in the UK, but which PPWR requirements apply in Northern Ireland and how they interact with the separate rules applicable in Great Britain.
Why does the PPWR apply in Northern Ireland?
Following Brexit, Northern Ireland continues to align with certain EU rules for goods under the Windsor Framework. The UK Government’s assessment of the PPWR confirms that the regulation will apply in Northern Ireland to the extent that it falls within the Windsor Framework’s scope.
This is important because the PPWR is broader than a traditional waste-management measure. It introduces requirements covering packaging design, recyclability, recycled content, substances and other aspects of packaging placed on the market. Northern Ireland’s Department of Agriculture, Environment and Rural Affairs (DAERA) confirms that much of the PPWR will apply in Northern Ireland from August 12, 2026.
However, the entire PPWR does not apply. Several provisions concerning waste-management policy fall outside the Windsor Framework. These include, subject to specific exceptions, certain reuse targets, extended producer responsibility requirements, return and collection systems, deposit-return systems, recycling targets and some reporting obligations.
What does this mean for cosmetic companies?
For cosmetics manufacturers and brands, the most relevant requirements are likely to be those affecting packaging design, recyclability, composition and market access.
The PPWR introduces a more detailed EU framework for packaging sustainability, including requirements intended to improve recyclability and reduce the environmental impact of packaging. Companies supplying Northern Ireland may therefore need to review packaging specifications, materials and supporting technical documentation.
This can be particularly relevant for cosmetic packaging that combines several materials, such as pumps, multilayer tubes, jars with separate components and refill systems.
UK-wide packaging strategies may become more attractive
The regulatory situation creates a potential split between Great Britain and Northern Ireland.
Companies selling the same cosmetic products throughout the UK may face different regulatory requirements depending on where the product is placed on the market. As a result, some businesses may choose to develop packaging that meets the more demanding or relevant requirements across their entire UK supply chain, rather than maintaining separate packaging systems.
This approach could simplify manufacturing and logistics, but it may also increase costs associated with packaging redesign, testing, supplier changes and documentation.
What should companies do now?
Businesses supplying cosmetics to Northern Ireland should first determine which PPWR provisions actually apply to their products and packaging, rather than assuming that the entire regulation applies.
They should then review packaging materials and designs, identify any requirements that may affect existing formats, and assess how their Northern Ireland supply chain differs from their Great Britain operations.
The PPWR therefore adds another layer to the UK’s post-Brexit packaging landscape. For cosmetic companies, understanding the distinction between Great Britain rules and the PPWR requirements applicable in Northern Ireland will be essential when designing packaging, planning product launches and managing UK-wide supply chains.
