5 Key Changes the PPWR Will Bring to Cosmetic Packaging

The Packaging and Packaging Waste Regulation (PPWR – Regulation (EU) 2025/40) entered into force on 11 February 2025 and will generally apply from 12 August 2026. The regulation covers all packaging placed on the EU market, regardless of material or country of origin. For the cosmetics industry, it represents a fundamental shift in how packaging is designed, manufactured and marketed.

1. Cosmetic Packaging Must Be Designed for Recycling

One of the most significant changes introduced by the PPWR is the mandatory implementation of Design for Recycling (DfR) principles. From 2030, packaging will be assessed according to recyclability performance classes (A, B or C). Packaging with a recyclability rate below 70% (below Class C) will no longer be allowed on the EU market. From 2038 onwards, only Class A and Class B packaging will be permitted.

For cosmetic packaging, this means that every component matters—from the primary material and colour to labels, sleeves, adhesives, pumps, droppers, metallisation and the ease of separating individual parts. Attractive packaging alone will no longer be sufficient; it must also be technically recyclable.

2. Minimum Recycled Plastic Content Will Become Mandatory

The PPWR introduces mandatory minimum levels of post-consumer recycled (PCR) plastic content for plastic packaging. From 2030, the required minimum recycled content will include:
30% for contact-sensitive PET packaging;
10% for contact-sensitive packaging made from plastics other than PET;
35% for all other plastic packaging.
These targets will increase further in 2040 to 50%, 25% and 65%, respectively.

For cosmetic manufacturers, this will affect PET bottles, plastic jars, airless packaging, tubes and numerous plastic components. The challenge will be maintaining premium aesthetics, colour consistency and product compatibility while incorporating higher levels of recycled material.

3. Excess Packaging Will No Longer Be Acceptable

The PPWR requires packaging to be reduced to the minimum size and weight necessary to fulfil its protective, logistical and informational functions.
For the beauty industry, this means reducing oversized cartons, unnecessary inserts, decorative secondary packaging and excessive empty space designed purely to enhance perceived value.

Premium packaging is not prohibited, but every packaging element must have a justified functional purpose rather than serving only decorative or marketing objectives.

4. Packaging Labelling Will Become More Standardised

The regulation introduces harmonised labelling requirements to improve packaging sorting and recycling across the European Union.
Packaging will be required to clearly identify its material composition and provide consistent disposal information for consumers. Digital solutions, including QR codes, will play an increasingly important role, particularly for small cosmetic products such as serums, eye creams, travel sizes and hotel amenities where label space is limited.

Environmental claims such as “recyclable”, “contains PCR”, “eco-friendly” or “sustainable” will need to be supported by verifiable evidence and comply with harmonised EU requirements.

5. Refill and Reuse Systems Will Become Increasingly Important

The PPWR aims to reduce packaging waste by limiting certain single-use packaging formats. Among the affected products are single-use cosmetic packaging used in the hospitality sector, including hotel miniature toiletries.
As a result, cosmetic brands are expected to accelerate the development of refill solutions, refill pouches, replaceable cartridges, reusable packaging systems and larger-volume formats designed for repeated use.

Companies investing in refillable packaging today will be better positioned to meet future regulatory requirements while responding to growing consumer demand for more sustainable products.

Conclusion

The PPWR is far more than a waste management regulation—it represents a fundamental transformation in cosmetic packaging design.
Packaging suppliers and cosmetic brands will need to integrate recyclability, recycled content, packaging optimisation and circular economy principles into product development from the earliest design stage.
The companies that begin adapting now will not only ensure regulatory compliance but also strengthen their competitiveness in an increasingly sustainability-driven European cosmetics market.