What does the PPWR means for the Beauty Industry

It was expected at the end of 2024 and was actually published on the 22nd of January 2025. The European Union has officially adopted the Packaging and Packaging Waste Regulation (PPWR), pushing forward sustainable packaging legislation. The PPWR is set to enter into force on February 11, 2025, with its provisions becoming applicable from August 12, 2026.

The purpose of this regulation is to improve packaging design to promote reuse and recycling, prevent over-packaging, increase recycled content in new packaging and reduce packaging waste.

All rules have now been set, and delegated acts will be published between now and 2030 to define design rules, recycling rules, recycled content, and more. The objective is to set the same standards for all member states.

Key measures impacting beauty & cosmetics

Reducing packaging use

Ban of specific packaging formats on the market by the 1st of January 2030:

• Single-use plastic packaging used for multi-packs at points of sale and designed for convenience purposes to encourage consumption. Further guidelines will be defined.
• Miniature cosmetic and toiletry packaging in hotels.

The targets are to reduce packaging waste generated per inhabitant in Europe compared to 2018, of - 5% by 2030, - 10% by 2035 and - 15% by 2040.

The general objectives are to reduce packaging to a minimal amount wherever possible.

• Packaging items will be re-designed to reduce weight, volume, and quantity without jeopardizing their function.
• Empty space rate does not exceed 50% for multi-packs, transportation packaging or e-commerce packaging (sent to a distributor or end-user).

The methodology applied to calculate packaging reduction or empty space will be set out in a delegated act.

Recyclability

The definition of packaging recyclability is changing and being harmonised throughout the EU.

• All packaging must be recyclable by 2030, and packaging must be "recycled at scale (1)" throughout the Union by 2035.
• All packaging will need to comply with the recyclability design criteria (2) set out (Guidelines to be available from January 2028). Packaging that does not comply will be banned from the market. A recyclability performance class (from A to C) system will be implemented, with eco-modulation associated with these classes.

From 2030, only packaging ranked from A (over 95% recyclable) to C (over 70% recyclable) will be accepted on the market.

Labelling & Information

To prevent a proliferation of national markings (such as France triman for instance), the regulation will implement the following measures:

• Compulsory labelling
  • Sorting rule labels will be harmonised by 2028. A delegated act planned for 2026 will provide details on the procedures for this harmonised label. The label will need to include sorting rules, compostability, and substances of concern (substance names and concentrations will need to be provided in electronic format for each packaging component). A QR code will indicate the destination of each component.
• Implementation of on-pack and off-pack labels for reusable packaging, with a QR code on the packaging to provide information on collection points.
• Optional labelling
  • Roll-out of optional EPR (Extended Producer Responsibility) labelling in the form of a QR code. The symbol will need to be clear and understandable.
  • Harmonisation of on-pack and off-pack labels showing the percentage of recycled content and of bio-based plastic through a QR code.
  • Harmonisation of optional labelling for all packaging included in a deposit return scheme.

Compostability

As for now, compostability only refers to labels for fresh fruits and vegetables as well as tea and coffee. There are no indications for cosmetics packaging.

Recycled Content

The recycled content targets in place since the implementation of the SUP Directive (25% for PET bottles by 2025 and 30% for all plastic bottles by 2030) will be extended to cover all plastic packing.

New categories will be created, such as "contact sensitive" packaging(3), which includes cosmetics packaging, drinks bottles, and all other plastic packaging.

Recycling & reuse deposit schemes

By 2029, Member States will be obligated to set up recycling deposit return schemes for plastic and metal beverages packaging with a capacity of less than 3L (excluding wine, spirits and milk).

The Regulation defines the minimum requirements for implementing these schemes. An exemption is possible if the collection rate reaches 80% in 2026. Member States will also have the option of linking the recycling deposit return scheme with the reuse deposit return scheme.

Reusabilbity

The European Commission has defined reusable packaging and reuse system by:

• Reuse: any operation by which reusable packaging is used again several times for the same purpose for which it was conceived.
• Reuse scheme: an organisational, technical or financial set-up enabling closed-loop or open-loop reuse, offering reuse incentives, such as a deposit return schemes that guarantee packaging is collected with a view to be being reused.

The current target mainly concerns the food and drinks sector but will be extended to all sectors.

The Regulation will include exemptions for micro-companies, economic operators who place less than 1,000 kg of packaging on the market annually and operators with a sales area smaller than 100 m2.

Implications for the Beauty and Personal Care Industry

The beauty and personal care sector, known for its diverse packaging solutions, will experience notable impacts:

• Material Innovation: Brands will need to continue to invest in research to develop packaging that meets recyclability and recycled content standards, potentially shifting towards materials like glass, aluminum, or innovative bioplastics.
• Design Overhauls: Companies must continue to reassess packaging designs to reduce unnecessary components and ensure compliance with the empty space and recyclability criteria.
• Supply Chain Adjustments: The emphasis on reusable packaging may lead to the adoption of refillable systems, influencing product distribution and retail strategies.
• Regulatory Alignment: Businesses will need to stay abreast of the delegated acts and implementing measures that the European Commission is set to develop, ensuring timely compliance with evolving standards.

In summary, the PPWR represents a transformative shift towards a circular economy within the EU, compelling industries, including beauty and personal care, to adopt sustainable packaging practices. Proactive adaptation and innovation will be crucial for businesses aiming to align with these new regulatory landscapes.