The EU Packaging and Packaging Waste Regulation (PPWR) sets new rules for packaging on the EU market. The Regulation applies to all packaging, regardless of the material used, and to all packaging waste. The general application date is 12 August 2026. However, not all provisions apply on this date.
Main sustainability requirements of the EU PPWR
The EU PPWR sets requirements for:
- Substances in packaging and packaging components. The Regulation limits the presence of certain heavy metals and other substances of concern in its composition. Per- and polyfluoroalkyl substances (PFAS) in food-contact materials are restricted.
- Recyclable packaging for packaging and minimum recycled content in plastic packaging. All Packaging must be recyclable by 2030.
- Biobased feedstock in plastic packaging, including sustainability provisions, targets to increase the use of biobased feedstock, and recycled content targets.
- Compostable packaging, including definitions of “compostable packaging” and provisions for packaging formats mandatorily compostable.
- Packaging minimisation, namely packaging designed so that its weight, shape, and volume are minimal in relation to its function.
- Reusable packaging and criteria to define reusable packaging.
- Labelling provisions, including recycling symbols.
- Environmental claims.
Brand-owners of cosmetics that use packaging for their products must ensure compliance with the EU PPWR and draft a Declaration of Conformity (DoC).
Recycling symbols and harmonised recycling information
With the EU Packaging Waste Regulation, the EU is addressing the issue of fragmented rules across the Union market. According to Article 12.1 of the PPWR, packaging placed on the Union market shall be marked with a harmonised label containing information on its material composition in order to facilitate consumer sorting.
Currently, recycling symbols and recycling information are regulated by national laws. For instance, France requires the use of the Triman logo, the only EU country to impose specific symbols. Other countries such as Italy or Spain require packaging to displaying recycling information or information on its material, but do not impose the use of specific symbols.
How to prepare for the EU PPWR
Brand-owners will have to proceed as soon as possible to:
- ensure compliance of the packaging they are using.
- verify their producers are registered in the Member States.
- identify the different economic operators and responsibilities in the supply chain, including Extended Producer Responsibly (EPR).
- stay up-to-date about any possible regulatory updates, changes, and postponements.
Contact us here or at coslaw@obelis.net for any questions on cosmetics, packaging, and regulatory compliance.
References:
European Commission (2025). Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904, and repealing Directive 94/62/EC. Retrieved on 30/03/2026.
European Commission (2025). Packaging Waste Regulation. Boosting business and protecting the planet. Retrieved on 30/03/2026.
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