PPWR in the Cosmetics Industry – Are Your Packaging Stocks Safe? Key Information Before 12 August 2026
The Packaging and Packaging Waste Regulation (PPWR) is currently one of the most important legislative changes affecting manufacturers, importers and owners of cosmetic brands across the European Union. As 12 August 2026 approaches, many companies are asking whether their existing packaging stocks can still be used and what documentation will be required.
The good news is that PPWR does not apply retroactively, meaning that businesses do not need to worry about packaging that has already been purchased or placed on the EU market before the new requirements take effect.
Why is 12 August 2026 such an important date?
From 12 August 2026, the first key obligations under the PPWR will begin to apply. For packaging manufacturers and companies placing packaging on the EU market, this will primarily mean the requirement to prepare documentation demonstrating compliance with the Regulation.
It is also important to note that many of the environmental requirements introduced by PPWR will be implemented gradually over the coming years. Therefore, not all obligations will apply from August 2026.
Are existing packaging stocks safe?
Yes.
The most important message for cosmetic brand owners is that PPWR does not apply retroactively.
This means that packaging placed on the EU market before 12 August 2026 may continue to be used and sold until existing stocks are exhausted. PPWR documentation is not required for such packaging.
What documentation will be required?
For packaging subject to the new rules, the following documents will play a key role:
- EU Declaration of Conformity (DoC),
- Technical Documentation,
- Conformity Assessment Procedure,
- Documentation demonstrating compliance with PPWR requirements,
- Documentation enabling the identification and traceability of the packaging.
The exact scope of the required documentation will depend on the type of packaging and the company’s role within the supply chain. In most cases, preparing the technical documentation will remain the responsibility of the packaging manufacturer.
How can you protect your existing stock?
Although packaging placed on the EU market before 12 August 2026 does not require PPWR documentation, businesses should retain documents confirming when the packaging was placed on the market.
We recommend keeping:
- purchase and sales invoices,
- warehouse records,
- waybills,
- transport documents.
These documents may serve as evidence that the packaging was placed on the EU market before the new obligations became applicable.
What about imports from outside the European Union?
For packaging imported from non-EU countries, the key factor is the moment it physically enters the European Union.
If the packaging is placed on the EU market after 12 August 2026, it will be subject to the PPWR requirements, including the obligation to provide the necessary compliance documentation.
How does Glass&Co support its customers?
At Glass&Co, we continuously monitor developments related to the PPWR and work closely with packaging manufacturers to ensure compliance with the upcoming requirements.
Our goal is not only to supply high-quality cosmetic packaging but also to support our customers in adapting to the new regulations. As additional guidelines and implementing acts become available, we will continue to publish practical information and updates to help our customers prepare for the changes.
If you have any questions regarding PPWR documentation or your future packaging projects, our team will be happy to assist you.
