EU Packaging Rules in 2026: A Practical Guide for Cosmetic Packaging Importers
Updated: Sep 21
Importers of cosmetic packaging must now align their operations with both existing rules and the new Packaging and Packaging Waste Regulation (PPWR). This covers bottles, jars, pumps, droppers and outer cartons used for beauty and personal care products. It means reviewing pack designs, coordinating closely with Asian suppliers and managing EPR duties, so that cosmetic packs stay legally marketable and cost-effective in the EU.
From PPWD to PPWR: What Changes for Cosmetics
The EU has replaced the Packaging and Packaging Waste Directive (PPWD 94/62/EC) with the PPWR, Regulation (EU) 2025/40. It entered into force on 11 February 2025 and has applied directly in all EU member states since 12 August 2026. Several of its most demanding requirements phase in later, mostly from 2030, and some dates depend on Commission implementing and delegated acts that have not yet been adopted.
Because PPWR is a regulation, its technical rules on recyclability, recycled content and minimisation are harmonised across the EU. This reduces national differences in design requirements. Extended producer responsibility (EPR) remains national, however, so registers, fee levels and reporting mechanics still differ by country.
Objectives of the PPWR for Cosmetics
For cosmetics, the EU's objectives include:
Less packaging and waste: Optimised volume and weight, limits on unused space, and a ban on features that only make a pack look bigger. A cosmetics-specific empty-space ratio could be set in the future.
Higher recyclability: Formal design-for-recycling criteria and recyclability grades that packaging must meet from 2030 onward.
Mandatory recycled plastic content: This applies to the plastic parts of packaging, with cosmetic packaging falling into the stricter "contact-sensitive" category.
Clearer labelling: Harmonised labels showing material composition and, where applicable, reusability, with an optional label for PCR content.
Almost all cosmetic-related packaging is in scope. This includes primary packs (bottles, jars, compacts, tubes), secondary gift boxes and sets, and tertiary e-commerce and transport packaging used for beauty shipments.
Key PPWR Requirements for Cosmetic Importers
Extended Producer Responsibility (EPR)
Importers of cosmetic products or packaging are "producers" in each EU country where they first make that packaging available, whether it is empty or filled. They must register with the national producer register (and typically a producer responsibility organisation, or PRO) in each country, report packaging by material and weight, and pay national fees, which are moving toward recyclability-based modulation.
Non-EU sellers shipping directly to EU customers must appoint an EPR authorised representative in each country from 12 August 2026. Separately, importers must confirm that packaging meets PPWR product requirements and keep the declaration of conformity and supporting documentation.
Recyclability and Recycled Content
Recyclability. From 1 January 2030, or 24 months after the design-for-recycling delegated acts enter into force if that is later, packaging must reach at least recyclability grade C, meaning it is at least 70% recyclable by weight. From 1 January 2038 only grades A and B will be allowed. The delegated acts are due by 1 January 2028, so the exact criteria are not yet published. The regulation also requires packaging to be "recyclable at scale" from 2035, or later depending on the relevant implementing act.
Recycled content. Cosmetic packaging counts as "contact-sensitive" because it is used for products covered by the Cosmetics Regulation (EC) No 1223/2009, and this applies to primary packaging. From 1 January 2030, the minimum post-consumer recycled (PCR) content in the plastic parts of packaging is:
30% for contact-sensitive PET packaging, such as serum and toner bottles
10% for other contact-sensitive plastic packaging, such as PP caps, HDPE tubes and PS compacts
35% for other plastic packaging, such as shrink wrap and some transport plastics
These rise to 50%, 25% and 65% respectively by 2040. Several details matter for your documentation:
Only post-consumer recyclate counts. Post-industrial recyclate does not satisfy the targets, even if a supplier markets it as "recycled content."
The percentage is calculated as an average per manufacturing plant per year, not per pack.
Plastic parts making up less than 5% of the total packaging weight are exempt.
The 2030 date is a floor. The targets apply from 1 January 2030 or three years after the calculation implementing act, whichever is later.
For importers, PCR moves from a "nice-to-have story" to a compliance requirement. You will need suppliers who can provide traceable, safe recycled content suitable for contact-sensitive use, and supporting certificates that clearly distinguish post-consumer from post-industrial material.
Minimisation, Empty Space, and Banned Formats
Minimisation, Empty Space and Restricted Formats
PPWR requires that packaging weight and volume be minimised while still protecting and presenting the product. For cosmetics, this includes:
Limiting empty space in outer packaging. Grouped, transport and e-commerce packaging is capped at a 50% empty space ratio from 1 January 2030, or three years after the calculation method act if that is later. This cap applies to outer and shipping packaging, not to an individual jar or bottle. A tighter ratio specifically for cosmetics packaging could be introduced later.
Removing features that only inflate perceived volume. Double walls, false bottoms and unnecessary layers are prohibited, with narrow exemptions for certain protected designs and trademarks. Oversized gift boxes and purely decorative inserts with no functional purpose carry a risk of being challenged under the minimisation rules. Guidance differs on exactly when the prohibition starts to apply, so confirm the timing against the regulation text.
Ending single-use hotel cosmetics. From 1 January 2030, single-use plastic packaging for cosmetics and toiletries in the accommodation sector is restricted. This targets small formats of up to 50 ml or 100 g, so refill, dispenser or bulk solutions will be needed.
Labelling and Information
PPWR introduces harmonised packaging labels. These must show material composition and, where applicable, reusability. A label showing PCR content is optional. Key timing points:
The harmonised material-composition label applies from 12 August 2028, or 24 months after the labelling implementing acts enter into force, whichever is later. Those acts were due in August 2026 and had not been adopted at the time of writing, so 2028 should be treated as a floor.
Reusable packaging must additionally carry a reusability marking with a QR code from 12 February 2029, on the same conditional basis.
The material-composition label is meant to be physical. A QR code is optional for it and does not replace it, although digital tools can help carry extra information on small formats.
Until the harmonised label applies, national labelling schemes still apply, such as France's Triman logo.
Packaging made or imported before the labelling deadline may still be placed on the market for a period afterwards, so print runs don't become worthless overnight.
Because the final pictograms are not yet published, final artwork is not possible yet. You can, however, reserve space on new artwork.
How Cosmetic Importers and Manufacturers Will Be Affected
Cosmetics is among the more exposed sectors because it often uses multi-component, highly decorated packaging and single-use formats for gifting, minis and travel. The main impacts include:
Redesigning bottles, jars, airless packs and compacts to meet recyclability and PCR thresholds, which often means simplifying materials and decorations.
Rethinking gift sets, subscription boxes and luxury presentations to reduce empty space and non-functional components.
Replacing single-use hotel minis with refill, dispenser or bulk solutions.
Complex bottles, heavy metallisation and opaque full-body sleeves are not named in PPWR, but they carry a higher risk of scoring poorly on recyclability, so review them early.
Supply chains will need to:
Switch to mono-material, recyclable designs and PCR-capable resin suppliers.
Implement internal checks so that new packaging projects meet PPWR design, recyclability and recycled-content requirements before launch.
Costs will initially rise due to:
Higher prices for cosmetics-suitable PCR materials and validated components.
Testing to verify recyclability and material performance under new criteria.
Systems for tracking EPR fees and reporting obligations across multiple EU countries.
EU-wide technical standards do mean that one compliant pack design can generally be used across all EU markets, reducing the need for country-specific variants. EPR registration, fees and (for now) national labels will still differ by country.
How Cosmetic Brand Owners Can Prepare Now
1. Review All Cosmetic Packaging
Audit all packs you place on the EU market (bottles, jars, tubes, airless systems, droppers, compacts, outer cartons), regardless of which agent sourced them.
Ask your sourcing agent for full specs and samples. Flag multi-material, heavily decorated or low-recyclability items for redesign.
2. Work Closely With Your Sourcing Agent and Their Suppliers
Make sure your agent understands that your packaging is contact-sensitive and must meet PPWR recyclability and PCR requirements. Instruct them to collect material specs, PCR certificates (separating post-consumer from post-industrial content) and recyclability data from each factory as standard.
Update your contracts with the agent. Make PPWR compliance (design, PCR content and data provision) a non-negotiable part of the sourcing brief.
3. Organise EPR Compliance for Your Cosmetic Lines
Map where each cosmetic SKU is sold. Confirm that you, not the agent, are registered for packaging EPR in each relevant country. If you are a non-EU seller shipping directly to EU customers, you also need an authorised representative in each country.
Set up internal processes to capture packaging weights and materials from your agent's data. This lets you report accurately and use eco-modulated fees as a design signal, since more recyclable, PCR-rich packs should reduce long-term EPR costs.
4. Update Labels and Technical Documentation
Work out your role. If you place packaging on the market under your own name, or you fill it, you may be the PPWR "manufacturer" and must draw up the EU Declaration of Conformity and technical file. If you import packaging made by others, verify the manufacturer's documentation and keep copies. Either way, keep the master documentation in-house and use test reports and data provided via your agent.
Keep a file per packaging family with material specs for each component, PCR calculations and certificates, supplier declarations, and recyclability data. The full recyclability conformity assessment is not yet required until the delegated acts enter into force, but collecting the evidence now will make it much easier later.
Plan artwork for the harmonised EU labelling system, and reserve space for pictograms and, where relevant, a QR code. Make sure your agent's suppliers can print what you need once the formats are published.
5. Monitor Regulatory and Supplier Performance
Track updates on recyclability criteria, cosmetic-specific empty-space ratios, PCR calculation methods and labelling implementing acts. Translate these into updated sourcing instructions for your agent.
Regularly review both the agent's performance and the underlying factories, focusing on packaging updates, documentation quality and audit readiness, especially as 2030 approaches and recycled-content deadlines tighten.
Conclusion
The transition to the PPWR framework presents challenges and opportunities for cosmetic importers and manufacturers. By preparing now, with better specs, stronger supplier data and simpler pack designs, you can stay compliant and contribute to a more sustainable future.
© Norse Packaging – info@norsepackaging.com
This blog is for informational purposes only and is not legal advice, so please consult a qualified professional about your specific situation
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