Navigating New EU Packaging Rules: A Guide for Beauty and Cosmetic Brands

JULY 2024

Updated 31 October 2026 to reflect the final PPWR and current implementation guidance.

ECO-RESPONSIBLE TIPS

 

When I look at a beauty product, I see more than its bottle and label. I think about the cap, the carton, the parcel it travels in, and what someone will do with each piece when the product is finished. Those details belong in the design conversation from the beginning.

The EU packaging rules: what has changed?

I first wrote this guide in 2024, while the rules were taking shape. The final Packaging and Packaging Waste Regulation, or PPWR, entered into force on 11 February 2025 and generally began applying on 12 August 2026. Specific requirements have their own timelines. The European Commission’s application update explains this phased approach.

Start with the whole pack, including the parts your customer barely notices.

The waste-reduction targets of 5% by 2030, 10% by 2035 and 15% by 2040 are Member State targets for packaging waste per person, compared with 2018. They are not an identical reduction quota for every beauty business. See Article 43 of the PPWR.

My starting point for a brand is a component list: bottle, closure, label, adhesive, decoration and outer box. Before choosing a finish, I want to understand the complete pack.

Texture and embossed detail in MISEICO’s packaging.

Recyclability is already part of the brief. Reuse depends on the packaging and its use.

Article 6’s general requirement for recyclable packaging already applies. The detailed design-for-recycling grades start on 1 January 2030 or 24 months after the relevant delegated acts enter into force, whichever is later. The Commission’s PPWR guidance explains this distinction.

From 1 January 2030, Article 10 requires packaging weight and volume to be reduced to the minimum necessary for functionality, subject to its criteria and exceptions. Reuse obligations concern particular formats and uses; there is no universal requirement to make every cosmetic pack refillable. See Articles 10 and 29 of the PPWR.

I would ask what each layer contributes. Does the insert protect something fragile? Is the carton proportionate to its contents? A smaller pack still needs to do its job.

LIV Botanics: consider the product packaging and its journey to the customer together.

Leave space for useful information

The PPWR’s harmonised sorting labels are due from 12 August 2028 or 24 months after the relevant implementing acts enter into force, whichever is later. Article 12 includes scope exceptions. The Commission is still developing these measures. Check its PPWR implementation page before approving artwork.

France: Triman and Info-tri

Triman indicates that an item needs sorting; Info-tri explains the appropriate destination. It is not a blanket certification that a pack is recyclable. Check the French ministry’s Info-tri guidance for the requirements that apply to your packaging.

Italy: environmental labelling

For Italy, I would check the applicable material identification and disposal information with the supplier, using CONAI’s environmental labelling guidance. The details depend on the packaging and its intended use.

This information deserves space in the design from the first layout. Adding it at the final artwork stage can make even a carefully designed carton feel crowded.

Information printed on LIV Botanics packaging. Disposal instructions need checking against the intended markets.

 

Clarify producer responsibilities

A beautiful pack still needs a clear paper trail.

Extended producer responsibility, or EPR, needs its own check. Ask who is responsible for registration, reporting and fees in each market. Do not assume that buying packaging from a supplier settles your brand’s obligations. The Commission’s implementation resources include national EPR information.

I would put those questions beside the design brief, with a named person responsible for each answer.

 

Explain what you can support

Specific information is more useful than a broad green promise.

I would be careful with “100% recyclable” based only on a glass jar or paper carton. What about the closure, decoration and other components? What evidence supports the statement for the finished packaging?

The same applies to certifications. Name the actual certification and make its scope clear. A claim about the paper should not accidentally read as a claim about everything in the box.

The container and carton in the OKOKO packaging project.

A material name is the beginning

Glass, aluminium, paper and plastic each raise different questions. I want to know the product’s needs, the component specification and the intended disposal route. A material’s appearance cannot answer those questions.

A closer look at the packaging finish for LILIXIR.

Before the next order, I would gather three things:

  • The complete specification: materials, weights, components, adhesives and finishes.

  • The commercial context: where the product will be sold, how it travels and how customers use it.

  • The supporting information: supplier documentation, relevant assessments and the evidence behind any environmental claims.

Then we can discuss what to simplify, what needs testing and what information is still missing.

 

Keep the brand’s character

Careful packaging decisions can still leave room for personality. In RUA Nordic Beauty’s identity, the colours and textures help tell the brand’s story. I see that as a useful design question: which details carry the identity, and which add complexity without helping the product?

A portfolio photograph can show design decisions. It cannot establish regulatory compliance or demonstrate a measured reduction in environmental impact. Those conclusions need evidence about the actual packaging system.

Explore more branding and packaging projects for visual inspiration.

Photo courtesy of Beauty Kitchen.

Make the next order a useful checkpoint

For a practical starting point, read my PPWR guide for beauty brands preparing their next packaging order.

You need a clear brief and the right information before committing to production. If you are reviewing your packaging, tell me what you are working on. We can start with the product you have and the decisions ahead.

 
 

Share this guide with the person preparing your next packaging brief.

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