“Unique hurdle for cosmetics”: How to prepare for the PPWR

The Packaging and Packaging Waste Regulation (PPWR), which applies to every company placing packaged goods on the EU market, is expected to fundamentally change how products — including cosmetics and beauty products — can be imported and sold in the EU.

A major game-changer is that by 2027, cosmetic brands must adopt refillable packaging systems and embrace a “circular asset” model. This move signals a fundamental shift, forcing companies to rethink their approach entirely. However, it won’t stop there — by 2035, brands will need to prove that their packaging is not just recyclable but actively being collected, sorted, and recycled across the EU.

For 24Hour AR, a compliance and legal consultancy based in the UK and EU, the PPWR is an operational and financial deadline starting in August 2026 that will require immense preparation. 

This looming deadline is set to raise challenges for brands — especially for packaging materials deemed “contact-sensitive,” such as those used in cosmetics. For these companies, quality control and sourcing high-quality recycled content will be significant hurdles. 24Hour AR says that companies that don’t act now could find themselves facing product delistings, penalties, or even market banishment.

“Companies that fail to adapt risk losing market access, product delistings, and significant penalties,” Ferry Vermeulen, CEO and co-founder of 24Hour AR, tells Personal Care Insights. 

How will the PPWR’s labeling requirements change the way cosmetics brands present packaging to consumers?

Vermeulen: Starting in August 2026, cosmetics brands will have to start treating packaging as a formally certified product itself. The most immediate change consumers will notice is a push for total transparency and traceability. Every bottle, tube, or box must bear a type, batch, or serial number, along with the manufacturer’s contact details, to ensure it can be tracked throughout the supply chain.

Ferry Vermeulen, CEO and co-founder of 24hour-AR, tells us more about the changes coming into force. Because cosmetic containers are often small, the regulation allows brands to move much of this mandatory information to digital data carriers, such as QR codes. This keeps the physical design clean while giving consumers instant digital access to information about the packaging’s material composition and proper disposal.

While the unified EU-wide recycling pictograms have a slightly longer transition period, the groundwork for this transparent, digital-ready presentation must be finalized by August 12, 2026.

What are the biggest compliance challenges cosmetics companies are likely to face?

Vermeulen: Cosmetic brands face a unique hurdle because their packaging is classified as ‘contact-sensitive’ under the new rules. Because these materials come into contact with products people apply to their bodies, they are subject to stricter rules regarding the quality and safety of any recycled content used. This classification triggers mandatory recycled content targets for 2030: 30% for PET plastics and 10% for other plastic materials.

The primary challenge is sourcing high-quality material that is both safe for consumer use and meets the strict EU standards for ‘high-quality recycling.’ Because suitable recycling technologies for plastic materials other than PET are still being scaled, the commission will reassess their actual market availability by 2028 to determine if these targets are technically feasible to meet.

Furthermore, brands sourcing recycled plastic from outside Europe are subject to the ‘mirror clause.’ This requires them to provide third-party-audited proof that their international suppliers meet EU-equivalent standards for environmental emissions and for separate waste collection. 

Finally, companies must now track and verify these percentages as averages for each manufacturing plant and year, ensuring that every claim is supported by formal technical documentation and a signed EU Declaration of Conformity.

What immediate steps should cosmetics companies take to ensure they meet the key deadlines in 2026?

Vermeulen: With the August 12, 2026, general application date fast approaching, cosmetics brands must first prioritize building a robust administrative infrastructure to manage the mandatory technical documentation and a signed EU Declaration of Conformity for each packaging type. 

Simultaneously, brands need to audit their physical designs to ensure every packaging unit bears a type, batch, or serial number to satisfy new traceability requirements. Because this identification often requires physical changes to engravings or print plates, these adjustments must be finalized now to account for production lead times. 

Finally, it is critical for companies to secure national Extended Producer Responsibility (EPR) registrations across all member states where they intend to sell, to maintain legal access to those markets. For brands selling directly to consumers through e-commerce, the immediate appointment of an authorized representative is mandatory to handle these financial and organizational obligations and avoid the risk of import blocks or delistings. Any company not fully registered in these national systems by the August 2026 cutoff will see their legal permission to distribute products severed.

How should cosmetic brands plan for the upcoming shift to “recycled-at-scale proof” requirements by 2035?

Vermeulen: By January 1, 2035, it will no longer be enough to show that a cosmetic bottle can be recycled — brands must prove it is actually being collected, sorted, and recycled in the real world across the EU.

Packaging must belong to a category that meets a minimum recycling threshold 55% for most materials on the EU level. Brands should audit their portfolios now to phase out niche materials or formats that are frequently rejected by sorting high-speed lines, such as very small or complex multi-material containers.

Brands must ensure their technical documentation includes verified data from downstream waste operators proving that their packaging type is effectively reaching recycling facilities.

Cosmetic brands should actively engage with EPR schemes and Producer Responsibility Organizations to ensure that small-format cosmetics packaging is being captured by established collection and sorting infrastructures.

Any packaging that fails the ‘recycled-at-scale’ assessment by 2035 will be considered technically non-recyclable and legally barred from the market. Planning must begin now because the commission will finalize the specific assessment methodology by 2030, leaving a narrow window for final structural changes.

When the new hospitality refill mandates start in 2027, how do you see this influencing cosmetic brand packaging design and strategies in hospitality?

Vermeulen: The upcoming mandates signal a fundamental shift from a ‘supply and discard’ model to a ‘circular asset’ model for cosmetic brands operating in the hospitality sector. While the FebruaryFor 24Hour AR, the most effective preparation is to treat 2030 as a temporary starting point rather than a final goal, and use the next decade to aggressively phase out any format that cannot survive the mandatory transition. 2027 refill obligations specifically target takeaway food and beverages, they are establishing the infrastructure and consumer habits that will define the market before the mandatory ban on single-use hotel miniatures takes effect in 2030.

For cosmetic brands, this means moving away from thin-walled disposables toward high-quality dispensers that withstand dozens of professional cleaning and sterilization cycles without compromising functionality or safety. 

Because cosmetics are classified as contact-sensitive packaging, strategies must now include rigorous hygiene protocols to ensure that refilled containers meet strict European safety standards. This shift also introduces a mandatory digital layer, as reusable packaging will need to bear QR codes or digital data carriers to track the number of trips and rotations each unit completes. This essentially turns the package into a data tool for sustainability reporting and inventory management.

Ultimately, cosmetic brands must transition from being ‘product sellers’ to ‘service providers’ by developing the logistics to collect, clean, and refill these dispensers. 

Brands that wait until the 2030 ban to build these reuse systems will likely find themselves locked out of a market that will have already operationalized these circular models by 2027.

How can cosmetics manufacturers prepare for the upcoming 2038 measures to meet the stricter sustainability targets?

Vermeulen: The jump in 2038 represents a significant regulatory hurdle because the union will essentially ban ‘borderline’ recyclable packaging that many brands currently rely on. While the initial 2030 rules allow Grade C packaging to remain on the market, by January 2038, every unit must reach at least Grade B, which requires a recyclability score of 80% or higher by weight.

For cosmetics manufacturers, this shift requires moving away from complex, multi-layered designs that barely meet minimum standards today and transitioning toward high-purity mono-materials that can reach the 95% recyclability threshold required for Grade A. 

Brands must also look toward the 2040 horizon, where the recycled content mandate for non-PET contact-sensitive plastic will more than double from the 10% required in 2030 to 25%.

Because sourcing high-quality, safely recycled plastic remains a major challenge, manufacturers should secure their international supply chains and validate alternative materials well before the commission performs its scheduled review of these targets in 2032. 

Ultimately, the most effective preparation is to treat 2030 as a temporary starting point rather than a final goal, and to use the next decade to aggressively phase out any format that cannot withstand the mandatory transition to high-performance recyclability.