Regulation (EU) 2025/40 and Your Cosmetics Range: What the PPWR Actually Requires — and When

Somewhere in your packaging specification sits a component that will be non-compliant by 2030. That’s not speculation — it’s built into Regulation (EU) 2025/40, the EU’s new Packaging and Packaging Waste Regulation (PPWR), published in the Official Journal on 22 January 2025 and in force since 11 February.

For most cosmetics brands, the conversation about PPWR hasn’t started in earnest yet. It should have started the day the regulation entered into force. Because unlike the Packaging and Packaging Waste Directive (94/62/EC) it replaces, the PPWR is a Regulation with a capital R. It doesn’t require national transposition. It doesn’t give member states room to soften deadlines. It applies directly, uniformly, across all 27 member states — which means the fragmented national packaging laws that brands have been navigating (France’s loi AGEC being the most demanding example) are now being replaced with a single, binding EU framework.

The question isn’t whether PPWR will affect your cosmetics range. It will. The question is how much redesign you’ll need — and whether you’re starting early enough to avoid a crisis in 2026 or 2027.

The Deadlines: Not All at Once, But Faster Than Most Brands Realise

The PPWR has a layered implementation schedule, and many brands make the mistake of anchoring on the farthest-out date — the 2040 recycled content targets — while underestimating the nearer obligations that are arriving faster.

August 2026 is the first major threshold. Article 26, which restricts what the regulation calls “unnecessary packaging formats,” applies just 18 months after entry into force. For cosmetics, this hits directly: grouped packaging — gift sets, multi-item bundles, counter-top display units — must not exceed a 40% void space ratio. The space inside the box that isn’t occupied by product cannot account for more than 40% of total packaging volume. Brands using oversized gift boxes padded with tissue paper or decorative fillers will need to redesign or demonstrate that the empty space is structurally necessary for product protection during transport.

Also restricted from August 2026: single-use packaging formats that serve no demonstrable protective function. For cosmetics, this targets certain unnecessary secondary cartons. If a pump bottle is structurally self-contained and the outer carton adds no protection against breakage, contamination, or tampering, the outer carton needs a genuine functional justification to remain.

February 2027 is when most of the PPWR’s broader provisions apply — 24 months after entry into force. This is when the main recyclability and labeling obligations become enforceable, and when Extended Producer Responsibility (EPR) fee structures across member states will be modulated to align with the new recyclability and recycled content criteria.

2030 brings the first wave of hard recyclability and recycled content targets. By 1 January 2030, all packaging placed on the EU market must meet the minimum recyclability performance grades that the European Commission is currently finalising in delegated acts. Simultaneously, recycled content mandates for plastic packaging activate. Targets are tiered by packaging type and contact sensitivity: contact-sensitive cosmetic packaging — primary containers that directly contact the product — carries a lower initial target (around 10% post-consumer recycled plastic content) than non-contact grouped or transport packaging, where targets can reach 30–35% by 2030. The differential reflects the Commission’s acknowledgement that contamination risk from post-consumer recycled plastics is a genuine safety concern for skin-contact formats. But that window narrows sharply at the 2040 checkpoint, when all categories step up substantially.

What “Recyclable by Design” Actually Means — and Why Cosmetics Packaging Has a Structural Problem

Here’s the part that isn’t discussed enough in industry briefings: cosmetics packaging is arguably the most technically complex category in the PPWR’s scope.

Glass bottles, aluminum tubes, and HDPE containers will generally perform well under the recyclability assessment criteria. The recyclability-by-design framework, once set out in delegated acts, is expected to classify mono-material formats in well-established recycling streams favorably. But the core of cosmetics packaging — pumps, airless dispensers, spray actuators, snap-fit composite closures, multi-layer laminated flexible tubes — is exactly where the industry has a structural compliance problem.

A standard pump mechanism combines at least three different materials: a polypropylene (PP) barrel, a stainless steel or carbon steel spring, and a polyethylene (PE) dip tube. Under recyclability-by-design principles, components that cannot be separated at end-of-life and that contaminate recycling streams count against a product’s recyclability grade. A glass bottle with a non-detachable pump head doesn’t become a glass bottle in the recycling system — it becomes a problem piece that triggers downgrading of the entire unit.

The PPWR doesn’t immediately prohibit these formats. But as EPR fees become modulated based on recyclability grade from 2027 onwards, non-recyclable or low-grade packaging carries a direct financial penalty through every EPR scheme in every member state where product is placed. Brands using low-grade packaging will pay more into EPR systems — and that cost compounds across a full product range, potentially adding tens of thousands of euros annually for a mid-sized cosmetics brand with a diverse portfolio.

We’re already seeing forward-thinking brands move toward:

• All-PP pump mechanisms designed for mono-material recyclability, eliminating metal springs
• Aluminum actuators and closures (which sort correctly in scrap metal streams)
• Refillable formats with durable primary containers rated for 10+ use cycles
• Elimination of decorative secondary cartons for structurally self-contained formats

None of these transitions happen overnight. Packaging development cycles typically run 12 to 24 months from brief to production-ready tooling. If your recyclability audit hasn’t started, the August 2026 and February 2027 deadlines are effectively already here.

Recycled Content, Labeling, and What Loi AGEC Already Taught Us

French cosmetics manufacturers and brands selling primarily into the French market have had an involuntary head start. France’s anti-waste law — loi n° 2020-105 du 10 février 2020, known as loi AGEC — imposed some of the EU’s most demanding domestic packaging requirements years ahead of PPWR: mandatory recycled content information on packaging, reformed EPR, and single-use plastic restrictions that went beyond EU minimums. Building that compliance capability hurt at the time. It’s an advantage now.

Brands that built recycled content tracking into their supplier qualification process for loi AGEC are already 70–80% of the way toward PPWR’s equivalent obligations. Those that haven’t — particularly brands operating primarily outside France — are starting from zero.

The PPWR requires a new standardised recyclability label on packaging from approximately 2028 (42 months after entry into force). The format will incorporate a QR code linking to material composition data and recycling instructions by packaging type. This means brands must maintain an up-to-date digital record of every packaging component’s material composition, and keep that record current as suppliers change production specifications.

That QR code requirement sounds deceptively simple. It isn’t. Brands with complex packaging assemblies sourced from multiple suppliers across several countries need a structured process for gathering, verifying, and publishing that data in a format that meets Article 12’s harmonised specifications. A custom leaf logo and the word “eco-friendly” won’t satisfy this. The standardised label replaces it.

For recycled content verification, supplier declarations of post-consumer recycled (PCR) plastic content require third-party chain-of-custody certification to be defensible under the regulation’s traceability requirements. ISO 14021 (environmental claims) and ISCC PLUS (recycled content chain of custody) are the certifications that hold up under scrutiny — and under EPR audits. A Chinese packaging supplier’s marketing claim of “30% PCR content” without certification documentation is not compliant with what PPWR requires.

The Intersection with Regulation (EC) No 1223/2009 That Most Brands Miss

There’s a specific compliance overlap that tends to fall between teams: the chemical safety implications of recycled plastic in primary cosmetic packaging.

Using post-consumer recycled plastic in a container that directly contacts a cosmetic product creates a chemical migration question that must be addressed in the Product Safety Report under Regulation (EC) No 1223/2009. Recycled plastics can carry trace contaminants from their previous use — particularly if the PCR stream includes packaging from non-cosmetic applications. The safety assessor responsible for your PIF must specifically evaluate the recycled content material and confirm that migration levels remain within safe limits for the intended product and consumer population.

This intersection is currently underaddressed in the industry. As recycled content mandates increase through 2030 and 2040, the volume of safety assessments that haven’t incorporated this analysis will create a compliance backlog. Building it into your PIF documentation process now — before it becomes a retrofitting problem — is the cleaner path.

The practical starting point is requesting a full material composition declaration from every packaging supplier for every component in your range: primary, secondary, and tertiary. Map those declarations against the Article 26 void space requirements and the recyclability performance criteria in PPWR’s forthcoming delegated acts. That inventory is the foundation of everything else. Without it, you’re estimating your compliance exposure. With it, you can prioritise which formats require redesign first, which suppliers need to be pushed for PCR certification data, and where your EPR fee exposure is most concentrated.

The brands treating PPWR as a product development and procurement project — not a regulatory form to file — are the ones that will make the 2030 targets without a crisis. The others will be paying both the redesign costs and the modulated EPR penalties simultaneously.

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Written by Nour Abochama, Quality & Regulatory Advisor, Care Europe | VP Operations, Qalitex. Learn more about our team

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• Packaging Material Testing and Recycled Content Verification at Qalitex — ISO 17025-accredited migration testing and ISCC PLUS chain-of-custody verification for recycled plastic in cosmetic packaging, for US market compliance
• Canadian Packaging and Labeling Requirements for Cosmetics and NHPs — How Health Canada’s cosmetic and natural health product packaging rules compare to the EU’s PPWR framework for European brands entering the Canadian market