EU PPWR for cosmetics: obligations of manufacturers, special features of cosmetics packaging, and recycling symbols

Cosmetic brands that place products on the market under their own name or trademark are generally considered the legal manufacturer of the packaging associated with those products. As a result, from 12 August 2026, they must ensure that such packaging complies with the requirements of the EU Packaging and Packaging Waste Regulation (EU PPWR).

Obligations of manufacturers under the EU PPWR

In addition to the provisions of the EU Cosmetics Regulation, manufacturers shall place packaging of cosmetics on the market only when compliant with EU PPWR. Conformity with the EU PPWR includes the following key provisions:

• Requirements for substances in packaging. The Regulation sets provisions on restricted heavy metals as well as substances that adversely affect human health or the recyclability of materials.
• Recyclable packaging. Simply claiming and proofing that the packaging is recyclable is not sufficient. The Regulation sets strict requirements on what can be claimed “recyclable” and related recycling grades.
• Minimum recycled content in plastic packaging. Post-consumer plastic must be part of the plastic packaging.
• Packaging minimisation. Packaging on the market should be designed so that its weight and volume is reduced to the minimum necessary.
• Reusable packaging. For packaging presented as reusable, the conditions have to meet the requirements of the Regulation.
• Labelling of packaging. Manufacturers must pay strong attention to traceability, claims, QR code and information on the packaging features displayed on their products.
• Biobased feedstock in plastic packaging and compostable packaging.

The new Regulation applies from 12 August 2026. While most provisions have later application dates, manufacturers shall already draw up a Declaration of Conformity under the EU PPWR for each packaging, including packaging of cosmetics, placed on the market from 12 August 2026.

Special features of cosmetic products’ packaging

Cosmetics’ packaging often has specific characteristics, such as being reusable or refillable, intended for the accommodation sector, or designed to group multiple products. All these special features have to be checked against the provisions of the EU PPWR. Environmental claims, either concerning the packaging or the product itself, have also be subject to strict conditions. Compliance with these requirements accompanied by scientific and methodological substantiation must be shown in the technical documentation.

How about recycling symbols?

While currently the EU has no harmonised symbols to affix on labels, this is changing soon thanks to the new EU Packaging Waste Regulation. By August 2028 (or later, depending on when the implementing act is published), packaging placed on the EU market shall be marked with a harmonised label on sorting information by indicating its material composition. Meanwhile, every EU country has their own rules about recycling symbols. Some countries such as Italy, France, and Spain impose the use of recycling information or symbols.

More tools to understand the EU PPWR

European Parliament to vote on EPR rules’ suspension

What is the extended producer responsibility in the EU?

EU PPWR: new EU Packaging Regulation from August 2026

EU PPWR applies from today 12 August 2026

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For any questions on the EU PPWR, EPR, producers, and labelling, contact us here or at coslaw@obelis.net.

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