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2026-09-24
The European Union is introducing a major change to the way packaging is designed, manufactured, placed on the market and managed after use.
The Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40, establishes a harmonized framework covering the entire packaging life cycle, including packaging design, recyclability, recycled content, packaging waste prevention, reuse, labeling and Extended Producer Responsibility (EPR).
The regulation entered into force on 11 February 2025 and began to apply across the EU on 12 August 2026. It replaces the previous Packaging and Packaging Waste Directive 94/62/EC, although certain provisions of the previous framework have transitional effects.
For cosmetic packaging manufacturers, beauty brands, importers and B2B purchasing teams, PPWR is particularly relevant because many cosmetic products rely heavily on plastic bottles, jars, pumps, caps and other packaging components.
So what does PPWR mean for cosmetic packaging?
And what should buyers start asking their packaging suppliers?
This guide explains the key PPWR requirements and provides a practical procurement checklist for cosmetic packaging buyers in 2026.
PPWR stands for:
Packaging and Packaging Waste Regulation
Officially:
Regulation (EU) 2025/40 on packaging and packaging waste
The regulation applies to packaging placed on the EU market and packaging waste generated in the EU, regardless of the material or origin of the packaging. It covers the entire packaging life cycle.
Compared with the previous Directive 94/62/EC, PPWR introduces a more detailed and harmonized framework covering areas such as:
For international cosmetic packaging suppliers, this means that EU packaging compliance is becoming increasingly connected to the design and purchasing stage.
One of the most important dates for packaging businesses is:
PPWR began to apply across the European Union on this date.
The regulation therefore should no longer be treated simply as a future regulatory development.
For companies supplying packaging to the EU market, 2026 is the point at which compliance planning becomes an active procurement and product-development issue.
However, not every requirement has the same implementation deadline.
Some obligations apply from the general application date, while other technical requirements, targets and delegated or implementing acts are phased in later.
The previous EU packaging framework was based on:
Directive 94/62/EC on packaging and packaging waste
PPWR replaces this Directive with a directly applicable EU Regulation.
This is important for international packaging suppliers because a Regulation is directly applicable across EU Member States, helping establish more harmonized requirements across the single market.
The European Commission states that the previous Packaging and Packaging Waste Directive was generally repealed on 12 August 2026, while certain existing provisions may continue to apply under transitional arrangements.
Cosmetic packaging frequently includes:
Many of these products are plastic-based.
The PPWR therefore creates several areas that cosmetic packaging buyers should monitor closely:
Packaging must be designed with recyclability requirements in mind.
Certain plastic packaging formats must meet minimum recycled-content targets from 2030, subject to the specific category and applicable exemptions.
Unnecessary packaging and excessive material use are increasingly regulated.
Specific packaging formats and sectors face reuse-related requirements.
Certain substances, including PFAS in food-contact packaging, are restricted.
Producers have obligations relating to the collection and management of packaging waste.
One of the most important objectives of PPWR is to make packaging more recyclable.
The European Commission states that the regulation aims to make all packaging placed on the EU market recyclable in an economically viable way by 2030.
However, buyers should understand that this is not simply a statement that every package suddenly becomes “recyclable" on January 1, 2030.
PPWR establishes a progressive framework for assessing packaging recyclability.
From 2030, packaging recyclability is assessed using design-for-recycling criteria and performance grades. From 2035, additional requirements relating to recycling at scale become relevant.
This creates an important implication for cosmetic packaging design:
Recyclability should be considered during product development rather than after the packaging has already been manufactured.
For cosmetic packaging suppliers, recyclability can involve much more than selecting a recyclable resin.
The entire packaging structure may matter.
For example:
Bottle + Pump + Cap + Decoration + Label + Other Components
should be evaluated as a packaging system.
Potential design considerations include:
A packaging design that uses one easily identifiable material may be easier to manage in recycling systems than a highly complex multi-material structure.
Therefore, cosmetic packaging buyers should increasingly ask:
“How does the complete packaging system perform from a recycling perspective?"
rather than simply:
“Is the bottle made from recyclable plastic?"
Another major PPWR requirement concerns recycled plastic content.
Under Article 7, minimum recycled-content requirements begin from 1 January 2030, or three years after the relevant implementing act enters into force, whichever is later, subject to the detailed provisions and exemptions in the Regulation.
The 2030 targets vary according to the packaging category.
For example, the regulation provides:
| Plastic Packaging Category | Minimum Recycled Content by 2030 |
|---|---|
| Contact-sensitive PET packaging | 30% |
| Contact-sensitive plastic packaging other than PET | 10% |
| Single-use plastic beverage bottles | 30% |
| Other plastic packaging | 35% |
These percentages are subject to the detailed definitions, exemptions and calculation rules in Article 7.
The targets increase further for 2040.
This is particularly important for cosmetic packaging suppliers because different packaging formats can fall into different regulatory categories.
Therefore, buyers should not assume that one recycled-content percentage applies to every cosmetic bottle or jar.
PET is already widely used in cosmetic packaging.
Common applications include:
For EU-focused packaging projects, buyers may increasingly ask suppliers about:
PCR PET
or other recycled-content solutions.
However, recycled content can influence:
For example, a brand requiring crystal-clear packaging may need to balance recycled content with its visual requirements.
This means the supplier should discuss the relationship between:
PCR Content + Appearance + Performance + Cost
rather than simply offering a recycled material option.
PP is commonly used for:
PPWR's recycled-content requirements also cover plastic packaging made from plastics other than PET, subject to the specific category and applicable exemptions.
For B2B buyers, this creates a potential need to evaluate:
This is especially important for cosmetic jars where the visual appearance and surface finish are important parts of the product design.
PETG, AS, acrylic and other materials may be selected for premium cosmetic packaging because of their appearance and structural properties.
However, buyers should not assume that a material is automatically “PPWR compliant" simply because it is technically recyclable.
Compliance depends on the complete packaging design and the applicable PPWR requirements.
For example, a premium packaging system may include:
PETG Bottle + Pump + Metalized Decoration + Label
The recyclability assessment should consider the complete packaging system and the applicable technical criteria.
Therefore, premium packaging development should increasingly involve recyclability considerations from the beginning.
PPWR also introduces packaging waste prevention targets.
Each EU Member State must reduce packaging waste generated per capita compared with the 2018 baseline by at least:
These are Member State-level packaging waste prevention targets, not a simple requirement that every individual cosmetic brand must cut its own packaging volume by exactly 5%, 10% or 15%.
Nevertheless, the targets are expected to influence national measures and packaging practices.
For cosmetic packaging companies, this means that:
Packaging minimization is becoming an increasingly important design consideration.
PPWR promotes reducing unnecessary packaging and excessive material use.
The regulation's approach includes reducing packaging volume and weight and avoiding unnecessary packaging.
For cosmetic packaging, this may encourage brands and suppliers to reconsider:
However, lightweighting should not compromise:
The objective should be:
Material Efficiency + Product Protection
rather than simply making packaging thinner.
PPWR also introduces measures supporting reuse and refill.
However, this is an area where cosmetic packaging buyers need to be careful.
It would be inaccurate to say that all cosmetic packaging must become reusable from 2030.
The regulation establishes different reuse targets and restrictions for specific packaging formats and sectors.
For example, certain transport packaging has a 2030 reuse target, with further targets for 2040.
PPWR also restricts certain single-use packaging formats, including some small single-use cosmetic and toiletry products used in hotels.
For the beauty industry, refillable packaging is therefore worth considering as a product-development direction, particularly for:
For premium skincare brands, refillable airless packaging can combine:
Premium Design + Controlled Dispensing + Refill Concept
A typical structure could be:
Reusable Outer Bottle
Replaceable Inner Cartridge
Instead of replacing the complete packaging system every time, consumers may replace only the inner component.
However, brands should evaluate the complete environmental and technical performance of the system.
Important considerations include:
Refillable packaging should therefore be treated as a complete system rather than simply a marketing label.
PFAS are often discussed in connection with PPWR.
However, cosmetic packaging suppliers should be precise about the scope.
The PPWR introduces restrictions on PFAS in food-contact packaging above specified thresholds. The European Commission's 2026 guidance specifically addresses the enforcement of these PFAS restrictions.
Therefore, it would be misleading to state that:
“PPWR bans PFAS in all cosmetic packaging."
The direct PPWR PFAS restriction is specifically focused on food-contact packaging.
Nevertheless, brands should continue to assess substances of concern and applicable chemical regulations relevant to their specific products and markets.
Another important PPWR concept is:
Extended Producer Responsibility — EPR
Under EPR systems, producers can have financial and organizational responsibility for packaging at the end of its life.
PPWR establishes requirements relating to producer registration and EPR schemes. Producers may need to register in Member States where they make packaging or packaged products available for the first time, subject to the applicable rules.
For international cosmetic brands, this means packaging compliance is not limited to the physical bottle or jar.
It can also involve:
Because implementation can involve Member State-level systems, companies selling cosmetics in multiple EU countries should review the specific EPR obligations applicable to each market.
For EU-focused cosmetic packaging projects, buyers should add PPWR-related questions to their supplier evaluation process.
Ask:
Ask:
Ask:
Buyers should consider requesting relevant documentation such as:
The exact documentation required will depend on the role of the company in the supply chain and the applicable PPWR requirements.
The regulation creates several design trends that B2B packaging buyers should watch.
Brands may increasingly request:
Brands may look for:
Packaging with fewer unnecessary materials may become more attractive.
For example:
Single-Material or More Easily Separable Structures
may offer advantages compared with unnecessarily complex multi-material systems, depending on the packaging format and recycling pathway.
Potential applications include:
As regulations become more detailed, buyers may increasingly require suppliers to provide:
Material + Composition + Recycled Content + Technical Documentation
This makes documentation capability an increasingly important part of supplier selection.
| Packaging Strategy | PPWR-Relevant Considerations |
|---|---|
| Virgin PET Bottle | Recyclability + future recycled-content requirements |
| PCR PET Bottle | Recycled-content documentation + quality consistency |
| PP Cream Jar | Recyclability + recycled-content options |
| Acrylic Jar | Material structure + recyclability assessment |
| PETG Bottle | Recyclability + complete packaging structure |
| Airless Bottle | Multiple components + recyclability + refill options |
| Refillable Airless | Reuse/refill system + component compatibility |
| Heavy Glass Jar | Material recyclability + packaging weight/minimization |
| Multi-Material Packaging | Separation and recycling considerations |
| Oversized Secondary Packaging | Packaging minimization |
Instead of waiting until a regulatory deadline approaches, brands can take a five-step approach.
Create a list of:
Record:
Ask:
Can we reduce material without reducing performance?
Can we simplify the structure?
Can components be separated more easily?
Ask suppliers about:
For each packaging SKU, maintain relevant:
This can make future compliance management more efficient.
Before placing an EU-focused packaging order, buyers can use this checklist:
Material clearly identified
Material composition documented
PCR option evaluated
Recycled content confirmed where applicable
Packaging weight optimized
Unnecessary components removed
Multi-material structure reviewed
Components assessed for recycling compatibility
Formula compatibility tested
Leakage tested
Pump performance tested
Transportation performance evaluated
Technical documentation available
Recycled-content documentation available
Stable production capacity
Consistent repeat-order quality
Recyclability requirements reviewed
Applicable labeling requirements reviewed
EPR obligations identified
Member State requirements checked
PPWR is not only a compliance challenge.
It can also create new opportunities for packaging manufacturers.
Suppliers that can provide:
may be better positioned to support brands adapting their packaging portfolios.
For manufacturers, sustainability should therefore become part of product development rather than simply a marketing message.
One of the biggest lessons for cosmetic packaging buyers is that compliance should not be considered only after production.
It should start at:
Material Selection
↓
Packaging Design
↓
Prototype
↓
Formula Compatibility Testing
↓
Recyclability Assessment
↓
Production
↓
Documentation
This approach can reduce the risk of having to redesign packaging after a product has already entered the market.
The EU Packaging and Packaging Waste Regulation represents a major change in the European packaging landscape.
For cosmetic packaging buyers, the most important areas to monitor are:
Recyclability
Recycled Content
Packaging Minimization
Reuse and Refill
Substances of Concern
Extended Producer Responsibility
PPWR began applying on 12 August 2026, and several requirements are being phased in through 2030 and beyond.
For plastic cosmetic packaging, the 2030 recycled-content requirements are particularly important. Depending on the packaging category, the regulation sets different minimum percentages, including 30% for certain contact-sensitive PET packaging, 10% for certain contact-sensitive non-PET plastic packaging, and 35% for other plastic packaging.
At the same time, the EU is moving toward more recyclable packaging design, lower packaging waste, greater use of recycled materials and more reuse/refill systems.
For cosmetic brands and B2B buyers, the practical response is to begin evaluating packaging from a complete life-cycle perspective:
Material → Design → Function → Recyclability → Recycled Content → Documentation → End-of-Life
The most important question is no longer simply:
“Is this cosmetic packaging attractive and affordable?"
It is increasingly:
“Can this packaging deliver the required product performance while meeting the evolving requirements of the EU market?"
By working with packaging suppliers that understand materials such as PET, PP, PETG, PCR and refillable packaging systems, cosmetic brands can develop packaging solutions that are better prepared for the changing European regulatory environment.
PPWR stands for the Packaging and Packaging Waste Regulation, formally Regulation (EU) 2025/40. It establishes EU-wide requirements covering packaging design, recyclability, recycled content, waste prevention, reuse, labeling and Extended Producer Responsibility.
PPWR began to apply across the EU on 12 August 2026. It replaces the previous Packaging and Packaging Waste Directive 94/62/EC, subject to applicable transitional provisions.
The EU's policy objective is for all packaging on the EU market to be recyclable in an economically viable way by 2030. The detailed recyclability requirements are phased, with design-for-recycling criteria and performance grading applying from 2030 and additional recycling-at-scale requirements from 2035, subject to the detailed rules.
EU Member States must reduce packaging waste generated per capita compared with 2018 levels by at least 5% by 2030, 10% by 2035 and 15% by 2040.
PPWR introduces minimum recycled-content requirements for plastic packaging from 2030, with different percentages depending on the packaging category. The exact requirement must be determined according to the relevant PPWR category and any applicable exemptions.
The PPWR's specific PFAS restriction concerns food-contact packaging. It should not be described as a blanket PPWR ban on PFAS in all cosmetic packaging.
No. PPWR introduces reuse and refill requirements for specific packaging formats and sectors rather than requiring every type of cosmetic packaging to be reusable. Certain single-use packaging formats are also restricted.
Buyers should ask about:
The exact compliance responsibilities depend on the company's role in the supply chain and the EU market in which the packaging or packaged product is placed.
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