However, introducing a refill model is not simply a packaging redesign. In the European Union, cosmetic products must continue to comply with the requirements of Regulation (EC) No 1223/2009, while the Packaging and Packaging Waste Regulation (EU) 2025/40 (PPWR) is creating a broader framework for reusable and refillable packaging. The challenge for the industry is therefore to reconcile consumer demand for less packaging with product safety, hygiene, traceability and regulatory compliance.
What EU Cosmetics Regulation Says About Refillable Products
Regulation 1223/2009 does not establish a specific regulatory category for “refillable cosmetics.” Instead, the same fundamental requirements apply to the cosmetic product regardless of whether it is sold in a conventional container or through a refill concept.
The product must be safe under normal or reasonably foreseeable conditions of use, and the responsible person remains responsible for ensuring compliance with the Regulation. This includes the product’s safety assessment, Product Information File and good manufacturing practice requirements.
Packaging and presentation are also relevant to safety. Regulation 1223/2009 requires mandatory information to be provided on the container and packaging, including the responsible person’s details, nominal content, durability information, precautions for use and ingredients, subject to the specific rules and exemptions in Article 19.
For refillable systems, this means manufacturers need to consider not only the formulation itself but also how the product is transferred, stored, identified and used after refilling.
The PPWR Adds a New Layer of Requirements
The regulatory landscape changed significantly with Regulation (EU) 2025/40. The PPWR entered into force on 11 February 2025 and generally applies from 12 August 2026. It introduces EU-wide requirements aimed at reducing packaging waste and increasing packaging circularity.
Importantly for cosmetics, the PPWR establishes specific requirements for packaging described as reusable. Packaging placed on the market from 11 February 2025 is considered reusable only when it meets a defined set of conditions. It must be designed for multiple rotations, protect consumer health and safety, allow emptying and refilling without compromising the product, permit appropriate labelling and information, and ultimately be recyclable.
This is significant because simply designing a container to be physically refillable does not necessarily make it a compliant “reusable packaging” solution under the PPWR.
Refill Systems Must Also Be Properly Managed
The PPWR goes beyond the physical container. Where economic operators offer products through refill, they must provide consumers with clear information about the types of containers that can be used, hygiene requirements and the consumer’s responsibilities concerning health and safety. Refill stations must also comply with specific requirements, including information provisions and mechanisms for dispensing a specified quantity of product.
This creates an important distinction between a refillable product and a refill system. A cosmetic brand might sell a durable container with replacement cartridges, for example, without operating a consumer refill station. Another brand may allow consumers to bring containers to a retail location and have them refilled. These models can raise different packaging, hygiene, operational and compliance considerations.
Consumer Demand Is Driving Innovation
Regulation is only one part of the story. Refill systems respond to growing consumer interest in reducing packaging waste and purchasing products in more circular formats. For manufacturers, they can also create opportunities to reduce the amount of packaging associated with repeat purchases and build longer-term relationships with consumers.
But sustainability claims should not overshadow practical considerations. A refill system must maintain the quality and safety of the cosmetic throughout its intended use. Container compatibility, contamination risks, preservation, dispensing mechanisms, cleaning procedures and product stability may all need to be evaluated.
The PPWR itself recognises these challenges. Its requirements for reusable packaging include maintaining the quality and safety of the packaged product during emptying, refilling and reuse.
What Cosmetic Manufacturers Should Consider
For brands developing refillable cosmetics, regulatory planning should begin at the design stage rather than after the packaging has been developed.
The first step is to determine exactly how the refill model will work: whether consumers will replace an inner cartridge, transfer product into a reusable container, or use a retail refill station. The formulation, primary packaging and refill process should then be assessed together.
Manufacturers should also review the mandatory information required under Regulation 1223/2009 and determine how it will remain accessible when the original container is reused. Batch identification, durability information, precautions and ingredient information must remain appropriately linked to the cosmetic product.
At the same time, the packaging should be assessed against the PPWR’s requirements for reusable packaging, refill systems, recyclability and packaging minimisation.
