Regulation (EU) 2025/40, known as the PPWR for its English name (Packaging and Packaging Waste Regulation), establishes a new harmonised framework for packaging and packaging waste in the European Union. Its objective is to reduce the environmental and health impact of packaging throughout its entire life cycle, while also strengthening the internal market with common rules for all operators. It replaces the former Directive 94/62/EC, entered into force on 11 February 2025, and, in general terms, will start to apply on 12 August 2026.
Although the PPWR is not a regulation aimed exclusively at the cosmetics sector, its impact in this field is especially significant. Cosmetics rely heavily on packaging not only to protect the product, but also to communicate brand identity, positioning, user experience and perceived quality. The problem is that, from now on, packaging will no longer be just a design or marketing decision. It will become much more strongly shaped by regulatory requirements on recyclability, minimisation, labelling, reuse and recycled content.
What is the PPWR and why does it change the landscape so much
The PPWR covers all packaging placed on the EU market, whether empty or filled, regardless of the material used and whether it has been produced inside or outside the Union. It also covers all packaging waste generated in the EU. Its approach is no longer limited to managing waste at the end of the process, but instead directly addresses design, composition, reuse, recyclability, labelling and the prevention of excessive packaging.
The logic of the Regulation is quite clear: if packaging continues to be generated in large volumes, with low levels of reuse and recycling, the system will remain inefficient. That is why the Commission is promoting a more uniform and more demanding regulation, aimed at reducing waste, cutting the use of virgin raw materials and pushing the market towards a circular economy.
Why the cosmetics sector should pay special attention
In cosmetics, packaging is rarely just a simple container. It may include multiple materials, decorative elements, dispensers, valves, pumps, metallised components, sachets, single-dose formats, outer cartons and secondary packaging. That complexity means that compliance with the PPWR cannot be solved simply by switching one plastic for another and hoping everything will work out.
In addition, many cosmetic brands use packaging as a core element of their commercial differentiation. This is exactly where the friction appears: what works visually or in terms of perceived luxury does not always fit well with criteria such as recyclability, structural simplification or reduction of empty space. And the Regulation moves precisely in the opposite direction to everything superfluous, which is a fairly elegant way of saying that part of cosmetic packaging will have to be rethought.
Recyclability requirements under the PPWR: the major structural change
One of the pillars of the PPWR is that all packaging will have to be recyclable in an economically viable way by 2030. The Commission presents this as one of the central objectives of the Regulation. This directly affects the cosmetics sector, where multi-material packaging, hard-to-separate components and finishes that hinder actual recycling are all common.
For a cosmetics company, this means reviewing very specific questions:
- whether the packaging is made up of compatible materials;
- whether its different elements can be properly separated or sorted;
- whether decoration, metallisation or colour prevent efficient recycling;
- and whether the final format follows a circular logic or only an aesthetic one.
The uncomfortable part is that it will no longer be enough for a material to be “theoretically recyclable”. The PPWR goes beyond the nice-sounding catalogue language.
Recycled content in plastic packaging
Another important axis of the Regulation is the push for the use of recycled content in plastic packaging, with increasing targets for 2030 and 2040. The Commission presents this as one of the key tools for reducing the use of virgin materials and accelerating the sector’s transition.
For cosmetics, this can be especially delicate in primary packaging, where issues of compatibility, stability, interaction with the formula, consumer perception and visual consistency come into play. Not all recycled materials fit equally well in all products, and in some cases it will be necessary to balance safety, functionality and environmental compliance. In other words, the solution is not simply to “add PCR and that’s it”, because things rarely allow themselves to be tamed that easily.
Packaging minimisation and the removal of unnecessary elements
The PPWR also pushes towards lighter, smaller packaging with less empty space, and the Commission summarises this quite clearly by referring to more sensible and less wasteful packaging.
For cosmetics, this translates very directly into the need to:
- review secondary packaging that adds little functional value;
- reduce purely promotional over-packaging;
- rethink sizes, empty spaces and double structures;
- and justify each component of the packaging system more clearly.
Here, many brands will have to face a rather unromantic truth: part of the packaging currently sold as a premium experience may begin to be seen, from a regulatory point of view, as excess.
Labelling and communication to the consumer
The Commission has also indicated that the new framework aims for clearer and less confusing labelling, so that consumers better understand what the packaging is made of, where it should be disposed of and how reuse or return systems work where applicable.
In cosmetics, this may require reviewing not only the graphic design of the packaging, but also the coordination between the product’s legal labelling and the environmental information provided for the packaging. And since space is already limited in many formats, any additional obligation quickly turns into a regulatory fitting exercise that is much less glamorous than the original branding briefing.
Reuse, refill and new packaging models under the PPWR
The PPWR also promotes reuse, refill systems and, more generally, models that reduce the generation of packaging waste. The Commission stresses that the Regulation encourages reuse and refill options wherever possible.
In cosmetics, this can open up opportunities, but it also requires caution. A refillable format is of little use if the system is not technically robust, hygienic, user-friendly and consistent with the formula and its preservation requirements. Refill looks very good in a sustainability presentation, but then it actually has to work in real life.
Key dates of the PPWR that should be kept in mind
From a practical point of view, the most important dates to watch are the following:
- 22 January 2025: publication of Regulation (EU) 2025/40 in the Official Journal of the European Union.
- 11 February 2025: entry into force of the PPWR.
- 12 August 2026: general date of application of its provisions, except for those linked to 2030 or to the development of secondary legislation.
- 30 March 2026: publication by the European Commission of a guidance document and FAQs to support the uniform application of the Regulation.
This last point is important because it confirms that the Regulation has already entered the stage of practical implementation, not that comfortable limbo where everyone says “we’ll see later”.
What cosmetic brands should already be reviewing
Although many of the obligations will fully unfold later, for a cosmetic brand it makes a lot of sense to begin an internal packaging review now. At a minimum, it is worth analysing:
- the material structure of primary, secondary and tertiary packaging;
- the actual recyclability of each format;
- the presence of problematic decorative or functional elements;
- the possibility of reducing weight, volume or unnecessary components;
- the integration of recycled content in plastics;
- the feasibility of refill or reusable models;
- and the technical documentation needed to support compliance.
Not everything will require immediate packaging reformulation, but a roadmap will. Waiting until 2026 to “start looking into it” is one of those decisions that tends to end up accompanied by urgency, tense suppliers and far less friendly budgets.
How SHAPYPRO can help
In this context, SHAPYPRO can help manufacturers and brands review the impact of Regulation (EU) 2025/40 (PPWR) on their cosmetic packaging, identifying critical points related to recyclability, minimisation, composition, labelling and the technical suitability of the packaging. This makes it possible to anticipate changes, prioritise actions and prepare a more realistic adaptation strategy before regulatory pressure goes from theoretical to rather tangible.
Conclusion
The PPWR is not a minor update to the European packaging framework. It introduces a much more structural regulation on how packaging must be designed, used and managed in the EU, and this directly affects the cosmetics sector. Packaging stops being an almost exclusively commercial decision and becomes a regulated element with technical, environmental and documentary implications.
For cosmetic brands, the key is not to read the Regulation as an abstract threat, but to translate it into concrete decisions on design, materials, suppliers and product strategy. Because the PPWR already exists. The optional part, as always, was having started earlier.