4 PPWR Topics Cosmetic Importers Should Act On Now

Apr 27

4 min read

Updated: 2 hours ago

ai created picture of bottels and jars with a clip board to show PPWR

The EU’s new Packaging and Packaging Waste Regulation (PPWR) (EU) 2025/40, has applied since 12 August 2026. Many of its hardest design requirements arrive later, mostly from 2030, and some dates depend on Commission implementing acts. For anyone importing cosmetic packaging or filled cosmetic products into the EU, four topics deserve early attention.

1. Recycled Plastic Content Becomes a Legal Requirement

Recycled content moves from a voluntary sustainability claim to a legal requirement across most plastic packaging. Cosmetic packaging counts as "contact-sensitive" because it is used for products covered by the Cosmetics Regulation (EC) No 1223/2009, and this classification applies to primary packaging.

From 1 January 2030, the minimum post-consumer recycled (PCR) content is 35% for general plastic packaging, 30% for PET contact-sensitive packaging and 10% for non-PET contact-sensitive packaging, rising to 65%, 50% and 25% by 2040. In practice:

PET cosmetic bottles: 30%
PP caps, HDPE tubes and other non-PET primary packaging: 10%
Other plastic packaging, such as outer plastic wraps and polybags: 35%

Some details matter for your documentation:

Only post-consumer recyclate counts. Post-industrial recyclate does not satisfy the targets, even though many suppliers market it as "recycled content."
The percentage is calculated as an average per manufacturing plant per year, not per pack, and plastic parts under 5% of 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, this means writing PCR requirements into specifications and supplier contracts, securing PCR supply early, and collecting supplier certificates that clearly separate post-consumer from post-industrial content.

2. Recyclability Grades and Design-for-Recycling Rules

PPWR does not just say packaging should be recyclable. It sets design-for-recycling criteria and a grading system that packaging is measured against. Key points:

From 1 January 2030, packaging that falls into the lowest performance grade (E) is not considered recyclable.
All packaging must be "recyclable at scale" from 1 January 2035, or later if the relevant implementing act is adopted later.
Requirements tighten further through 2038 and 2040.
By 2030, EPR fees are meant to be modulated according to recyclability performance grades, though each country sets its own fees.

The design direction for cosmetics is clear:

Mono-material bottles, jars and caps that match existing EU recycling streams
Simple, easy-to-separate components instead of permanently combined materials
Fewer problematic colours, coatings and decorations that confuse sorting or degrade recyclate quality

Importers who keep buying multi-material, heavily decorated packs risk ending up with designs that score poorly, forcing costly redesigns and higher fees. Exact grade thresholds and dates depend on the delegated acts, so check the latest text.

3. Cosmetic Formats Under Pressure

Some cosmetic packaging formats are directly regulated, while others are simply more exposed.

Directly regulated

Single-use hotel amenities: Single-use packaging for cosmetics and hygiene products in the accommodation sector is among the formats that cannot be placed on the market from 1 January 2030. The restriction targets plastic packaging, so refill or dispenser-based alternatives will be needed.
Double walls and false bottoms: Packaging features aimed solely at increasing the perceived volume of a product, such as double walls, false bottoms or unnecessary layers, will be prohibited, with narrow exemptions for certain protected designs and trademarks. Guidance differs on whether this applies from August 2026 or January 2030, so confirm the start date before setting your redesign timeline.
Empty space in gift sets and shipping cartons: Article 24 caps grouped, transport and e-commerce packaging at a maximum 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.

Higher risk, but not banned

Complex bottles, heavy metallisation and opaque full-body sleeves are not named in PPWR. They do, however, carry a higher risk of scoring poorly on recyclability, because multi-material components, metallised layers and non-compatible sleeves can interfere with sorting and recycling. Review these early and decide whether to redesign or phase them out.

4. Testing, Technical Files and Proof of Compliance

Cosmetics businesses are used to detailed product safety files. The same mindset now applies to the pack. Compliance with the minimisation rules must be proven in technical documentation under Annex VII. The manufacturer is responsible for producing this documentation, and an EU-established importer must verify that the non-EU manufacturer has fulfilled its obligations. Importers should therefore obtain and keep the EU declaration of conformity and supporting documentation, and build a file for each packaging family. It should contain at least:

Material specifications for every component (bottle, cap, pump, insert, carton)
A recyclability assessment against the design-for-recycling criteria, ideally supported by external guidance or testing
PCR calculations and supplier certificates, especially for contact-sensitive plastics
Supplier declarations covering composition, recyclability and minimisation
The EU declaration of conformity and evidence that the manufacturer's conformity assessment was completed

This documentation also supports EPR reporting, customs checks and audits.

Key Dates at a Glance

12 August 2026: PPWR applies generally
1 January 2030 (or later, depending on implementing acts): recycled-content targets, hotel amenity restriction, 50% empty-space cap, first recyclability requirements
2035: "recyclable at scale" requirement (or later)
2038 and 2040: further tightening of recyclability and higher PCR targets

Final Thoughts

PPWR is not just another packaging tweak. It changes what "good" packaging looks like in terms of recyclability, PCR content and design simplicity. Importers who start now by rewriting specifications, upgrading suppliers and building technical files will be in a much stronger position as 2030 approaches.

The content on this blog is provided for general informational purposes only and does not constitute legal advice. Regulations such as the PPWR change frequently, so please consult a qualified legal or compliance professional before making decisions for your business.