" The EU’s new Packaging and Packaging Waste Regulation (PPWR) is reshaping how cosmetic brands design, certify, label, and document their packaging.
The regulation entered into force in February 2025, with mandatory application from
12 August 2026, and introduces strict recyclability, recycled‑content, reuse, and digital‑labelling requirements that directly affect cosmetic packaging"
Read more about how it affect the cosmetic industry and how you can prepare
PPWR Compliance Priorities for Cosmetic Brands - What we suggest that you should do: 1. Achieve Grade‑A Recyclability Cosmetic packaging is often multi‑material (glass + metal + plastic), which PPWR penalizes. Recommended actions: -Switch to mono‑material lids (PP or PE). -Use detachable pumps (twist‑lock or magnetic). -Remove metallization and foil stamping. -Use water‑soluble adhesives for labels. 2. Secure Certified Recycled Content Contact‑sensitive plastics must meet 30% PCR by 2030. Mass‑balance accounting may be required for advanced recycling. 3. Implement Reuse & Refill Systems Particularly relevant for premium skincare and e‑commerce. 4. Prepare Digital Product Passports (DPP). QR codes must show recyclability, disposal instructions, and material composition. Replaces vague sustainability claims. 5. Build a Complete Technical File By August 2026, every SKU must include: -Material composition -Recyclability assessment -Recycled‑content verification -Supplier declarations -EPR registration details *Disclaimer The content of this website is purely for informational purposes and does not replace legal advice .
Add a Title
EU Packaging Regulation 2025 Explained Clear definitions of producers, distributors, importers, and all economic operators.
Definition of Roles & Actors Under Regulation (EU) 2025/40, the term economic operator (Article 3(1)(12)) includes producers, suppliers, importers, distributors, authorised representatives, end distributors, and fulfilment service providers. Producer (Article 3(1)(13)(ab) of Regulation (EU) 2025/40) A producer is any natural or legal person who manufactures packaging or packaged products. This typically refers to the entity that designs or manufactures packaging or packaged goods under its own name or trademark, even if other trademarks also appear on the packaging or product. An exception applies to EU-defined micro‑enterprises: in such cases, the producer is considered to be the supplier of the packaging, provided that the supplier is established in the same Member State as the micro‑enterprise receiving the packaging. Manufacturer (Article 3(1)(15)(ae) of Regulation (EU) 2025/40) A manufacturer is any person—whether based in the EU or a third country—who places packaging or packaged products on the market for the first time in a given Member State. This applies to all types of packaging (e.g., transport, service, primary production), whether single‑use or reusable, and across all distribution channels, including distance selling. A person who unpacks packaged products without being the end consumer may also be considered a manufacturer, unless another party has already been designated as such. Supplier (Article 3(1)(16) of Regulation (EU) 2025/40) A supplier is any natural or legal person who provides packaging or packaging materials to a producer. Importer (Article 3(1)(17) of Regulation (EU) 2025/40) An importer is any natural or legal person established in the EU who places packaging originating from a third country on the EU market. Distributor (Article 3(1)(18) of Regulation (EU) 2025/40) A distributor is any natural or legal person in the supply chain who resells or transfers packaging within the EU, excluding the party that originally manufactured or imported the packaging. Authorised Representative (Article 3(1)(19) of Regulation (EU) 2025/40) An authorised representative is a natural or legal person established in the EU who has been formally appointed by a producer to perform specific tasks on the producer’s behalf to ensure compliance with this Regulation. End Distributor (Article 3(1)(21) of Regulation (EU) 2025/40) An end distributor is any natural or legal person in the supply chain who supplies packaged products—including reusable or refillable products—to the final customer. Source: The new European Packaging Regulation 2025 – The new Packaging Act 2025
