
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 our article about how PPWR affects the cosmetic industry and how to prepare
EU Regulation and PPWR Compliance
What Is PPWR and Why It Matters for Cosmetic Packaging
The PPWR (Regulation (EU) 2025/40) replaces the old Packaging Directive and creates one unified rulebook for all packaging sold in the EU. For cosmetics, this is especially impactful because the sector relies heavily on multi‑material, decorative, and small‑format packaging, which is now under strict recyclability and documentation scrutiny.
PPWR applies to any economic operator that places packaging or packaged goods on the EU market. This includes manufacturers, importers, distributors, and producers (and representative) each with different responsibilities. Understanding which role applies to your company is the first step in compliance.
Key implications for cosmetic brands
As of 12 August 2026, the first obligations under the EU's Packaging and Packaging Waste Regulation (PPWR) are in force, including Article 5, which restricts substances of concern in packaging. Since that date, producers placing packaging on the EU market must hold a Declaration of Conformity and technical documentation demonstrating compliance. Packaging that does not meet these requirements may no longer be placed on the market.
We're obligated to provide our customers with the information needed to meet these requirements. That includes:
Design and material requirements
-
Packaging must be designed to be recyclable
-
Compliance with substance restrictions covering substances of concern, heavy metals, and PFAS (varying by application)
Technical documentation
-
Material specifications
-
Technical data sheets
Declaration of Conformity (DoC)
-
Issued per packaging type
-
Prepared by the packaging producer
Upcomming changes; 31/12:
Publication of the following elements under Article 7
-
Calculation, verification and reporting of PCR content
-
Assessing the sustainability of recycling processes
Extended Producer Responsibility (EPR) - What You Must Do as the Brand / Importer. Under EU law, the company placing packaging on the EU market is responsible for EPR. If you import packaging, sell packaged goods, or sell into the EU from outside the EU, you are the “producer” under EPR, even if you did not manufacture the packaging. Norse Packaging supplies compliant packaging — but you, as the brand or importer, must fulfill EPR obligations. 1. Register for EPR in Each EU Country Where You Sell You must register in the national EPR register of every Member State where your products are placed on the market. This applies to: - EU brands - Importers - Non‑EU brands selling into the EU - E‑commerce sellers Without registration, your products cannot legally be sold. 2. Report Your Packaging Data Annually You must submit detailed data for every packaging type you place on the market, including: - Material type - Weight per component - Recyclability - Recycled content - Annual volumes per Member State PPWR increases the level of detail required — reporting becomes SKU‑level. 3. Pay Eco‑Modulated EPR Fees Your fees depend on the environmental performance of your packaging: - Highly recyclable materials → lower fees - Difficult‑to‑recycle materials → higher fees This makes packaging design a cost driver. 4. Maintain Documentation for Authorities You must keep documentation proving: - Material composition - Recyclability - Recycled content - Supplier declarations - Alignment with your EU Declaration of Conformity (required under PPWR) Authorities can request this at any time. 5. Ensure Packaging Is Compliant Before Placing It on the Market From 12 August 2026, you must ensure that every SKU meets: - Verified recyclability - Digital labelling requirements - PFAS and heavy‑metal limits - Correct documentation and declarations If you import packaging, you are legally responsible for verifying compliance, not the supplier. 6. Consequences of Non‑Compliance From August 2026, failing to meet EPR obligations can result in: - Product bans - Customs blocks - Marketplace delisting - Fines - Inability to sell in key EU markets What Norse Packaging Does (and Does Not) Cover We provide: - Verified material data - Recyclability information - Supplier declarations - Packaging designed for EU compliance You must handle: - EPR registration - EPR reporting - EPR fee payments - Maintaining your own compliance documentation *Disclaimer The content of this website is purely for informational purposes and does not replace legal advice .
EPR Responsibilities for Buyers of Packaging Delivered to the EU and the role of Norse Packaging. To ensure full compliance with EU packaging legislation, please note the following: 1. You Are the Importer of Record When you purchase packaging from Norse Packaging for delivery to an EU member state, you are considered the Importer of Record. This is defined by EU law and applies even when the packaging is empty. 2. You Hold All EPR Obligations As the Importer of Record, you are responsible for: - Registering with the national EPR scheme (PRO) in your country - Reporting the amount and type of packaging you place on the market - Paying the required recycling and waste‑management fees - Ensuring compliance with national packaging regulations 3. What Norse Packaging Provides To support your compliance, we can supply: - Material specifications - Packaging weights - Recyclability information - Documentation required for your EPR reporting 4. What Norse Packaging Does Not Do Norse Packaging does not: - Register for EPR in EU countries - Report packaging volumes on your behalf - Pay EPR fees for packaging delivered to the EU - Act as Importer of Record 5. Why This Matters EU authorities enforce EPR through: - National registers - Customs checks - Marketplace controls - Audits and reporting systems Being properly registered ensures your products can be legally sold in the EU. *Disclaimer The content of this website is purely for informational purposes and does not replace legal advice .

Important dates for the Cosmetic Industry to be aware of starting now and goes until 2030



