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PPWR Regulation: EU Compliance for Cosmetic Packaging
The PPWR regulation – the EU Packaging and Packaging Waste Regulation (EU) 2025/40 – replaces Directive 94/62/EC with directly binding rules on packaging substances, documentation, recyclability, labelling and recycled content. Cosmereg helps cosmetic brands, importers and distributors map their obligations, build the technical file and sign a defensible EU Declaration of Conformity for every packaging item.
Request a PPWR gap assessment See the deadlinesCan you prove your packaging complies today?
Under the old Packaging Directive, most cosmetic companies relied on supplier statements and national rules. The PPWR changes that. It is a Regulation, so it applies identically in every Member State, and it introduces a formal conformity procedure: each packaging item placed on the EU market needs technical documentation and an EU Declaration of Conformity before it is sold.
For cosmetics, this sits on top of your obligations under Regulation (EC) No 1223/2009. Jars, tubes, droppers, pumps, cartons, shipper boxes and e-commerce mailers are all in scope, whether your products are made in the EU, the US, Korea or anywhere else.
Cosmereg already manages PIFs, CPSRs and Responsible Person services for brands entering the EU. We extend that same dossier discipline to packaging, so your product file and your packaging file tell the same story.
Talk to a packaging specialistTypical gaps we find in cosmetic portfolios
- No signed EU Declaration of Conformity per packaging item or family
- Heavy-metal declarations missing for inks, pigments and metallised parts
- Multi-material components (pumps, mirrors, magnets) with no recyclability assessment
- Unclear who is the PPWR "manufacturer" for private-label and contract-filled products
- Oversized secondary cartons and e-commerce boxes with excess empty space
- National sorting logos that will need replacing with harmonised EU labels
What the PPWR regulation requires for cosmetic packaging
Obligations are phased. Some already apply; others depend on implementing acts the Commission is still adopting. We track both.
Substance restrictions
The combined concentration of lead, cadmium, mercury and hexavalent chromium must not exceed 100 mg/kg in packaging or its components, and substances of concern must be minimised. The PFAS ban applies to food-contact packaging, not cosmetic packaging, but PFAS remain on the regulatory radar.
Technical file & Declaration of Conformity
The packaging manufacturer runs a conformity assessment, compiles technical documentation and signs an EU Declaration of Conformity for each packaging item or family, kept available for authorities on request.
Recyclability
Packaging must be designed for recycling. From 1 January 2030 packaging below recyclability Grade C cannot be placed on the market, with the threshold rising to Grade B from 2038.
Minimisation & empty space
Weight and volume must be reduced to what the product's function and safety require. Grouped, transport and e-commerce packaging face a maximum 50% empty-space ratio from 2030.
Recycled content in plastics
Plastic packaging must contain minimum percentages of post-consumer recycled material from 2030, increasing in 2040. The applicable target depends on the polymer and the packaging category.
Harmonised labelling
Pictogram-based EU labels showing material composition for consumer sorting replace national logos. Your cosmetic label artwork will need to integrate them alongside Article 19 mandatory information.
* 12 August 2028 or 24 months after the relevant implementing act, whichever is later. Producer (EPR) registration continues to be handled through each Member State's national scheme.
PPWR regulation timeline: key dates for cosmetic companies
Rule of thumb: documentation and substances first, labels next, design and recycled content after.
Published in the Official Journal
Regulation (EU) 2025/40 adopted, entering into force on 11 February 2025.
General date of application
Heavy-metal limits, conformity assessment, technical documentation and EU Declaration of Conformity required for packaging placed on the market. Directive 94/62/EC repealed.
Empty space in sales packaging
Operators filling sales packaging must reduce empty space to the minimum needed for functionality.
Harmonised EU labelling
Material-composition sorting labels become mandatory; parallel national sorting labels are phased out.
Recyclability Grade C & recycled content
Non-recyclable packaging below Grade C prohibited; first minimum recycled-content targets for plastic packaging; 50% empty-space cap for grouped, transport and e-commerce packaging.
Stricter thresholds
Minimum recyclability rises to Grade B (2038) and recycled-content targets increase (2040).
Brand, importer or distributor? Your PPWR role decides your obligations
The PPWR defines its own operator roles. They do not map one-to-one onto the Cosmetics Regulation, so each product and market needs its own role analysis.
| Role | Who it usually is in cosmetics | Core obligations |
|---|---|---|
| Manufacturer | The company that manufactures packaging, or has it designed or manufactured, and places it on the market under its own name or trademark — typically the brand owner. | Conformity assessment, technical documentation, EU Declaration of Conformity, labelling, traceability, corrective action. |
| Importer | The EU entity placing packaging from a non-EU manufacturer on the EU market. | Verify the manufacturer has done the conformity assessment and documentation; keep a copy of the DoC; identify itself on the packaging or accompanying documents. |
| Distributor | Retailers, wholesalers and marketplaces making packaged products available in the EU. | Due care: check required labelling and information is present; do not supply packaging they believe is non-compliant. |
| Producer (EPR) | The operator first making packaging available in each Member State, including non-EU sellers shipping directly to consumers. | Register with national extended producer responsibility schemes, report volumes, pay fees; appoint an authorised representative where required. |
| Supplier | Packaging component and material suppliers, converters, ink and pigment makers. | Provide the manufacturer with the information and documentation needed to demonstrate compliance. |
Important for non-EU brands: your EU Responsible Person under Regulation 1223/2009 is not automatically your PPWR manufacturer, importer or EPR representative. We map these roles explicitly so nothing falls between the gaps.
One dossier mindset: where PPWR meets your PIF
Your CPSR already has to address packaging material, impurities and potential migration. The same supplier data supports your PPWR technical file. We build both together instead of chasing suppliers twice.
Single supplier request
One questionnaire covers material specs, heavy metals, substances of concern and migration data for both the CPSR and the PPWR file.
Consistent records
Component references, materials and weights stay aligned across your PIF, artwork and Declaration of Conformity.
Audit-ready on request
When an authority or retailer asks, you can produce the product safety file and the packaging file from the same structured archive.
PPWR compliance services for cosmetic brands
Take the full programme or only the module you need.
PPWR gap assessment
Portfolio review by SKU and component, role mapping, risk ranking and a prioritised action plan with owners and dates.
Technical file & DoC
Preparation of technical documentation and EU Declarations of Conformity per packaging item or family, using harmonised standards or recognised guidance where available.
Supplier data management
Questionnaires, follow-up and review of supplier declarations, test reports and specifications, with gaps flagged and escalated.
Heavy-metal & substance testing
Testing plans and coordination with accredited laboratories where supplier data is missing or unreliable. Cosmetic product testing →
Packaging label review
Artwork review to integrate harmonised EU sorting labels with your Article 19 cosmetic labelling and translated labels.
Ongoing regulatory monitoring
Updates on implementing acts, recyclability methodology, recycled-content rules and national EPR changes, applied to your portfolio.
Scope
Share your SKU list, packaging specs and markets. We confirm roles and scope.
Assess
We review components against current and upcoming PPWR requirements.
Document
We build the technical file and Declarations of Conformity with your suppliers.
Maintain
We keep files current as packaging, suppliers and rules change.
PPWR questions from cosmetic brands
When did the PPWR start to apply?
Does the PPWR apply to cosmetic packaging?
Does the PPWR PFAS ban apply to cosmetics packaging?
Who signs the EU Declaration of Conformity?
We are a US or Korean brand. Does the PPWR affect us?
Is our EU Responsible Person also responsible for PPWR?
Can we keep selling while the documentation is being prepared?
Does company size change the requirements?
Will our packaging supplier take care of PPWR for us?
Where should we start?
Get a clear PPWR plan for your packaging portfolio
Send us your SKU list and the markets you sell in. We will confirm your role, scope the work and quote a fixed-fee gap assessment.
Request your PPWR assessmentRelated EU cosmetic compliance services
This page summarises Regulation (EU) 2025/40 for general information as of October 2026. Several obligations depend on implementing and delegated acts still being adopted. Contact Cosmereg for advice on your specific products.