Does the PPWR also apply to the smallest cosmetic packaging such as sample sizes and travel sizes under 50 ml?

Yes, in principle the PPWR applies to all packaging placed on the EU single market — regardless of fill volume. For very small packaging (under 1.5 litres in volume), there are in some cases exceptions or differing deadlines for recycled content quotas, but not for the design requirements for recyclability. Sample packaging and promotional products are also covered. Please clarify any exemptions on a case-by-case basis with your local Chamber of Commerce.

My airless pump consists of several materials. How is it classified?

Airless dispensers and similar multi-component systems are classified according to the primary material of the container body; however, the additional components (metal springs, silicone seals, pump mechanism) must also be assessed separately. If these components significantly impair the recyclability of the overall system, the packaging may be classified as 'difficult to recycle' — with corresponding consequences for compliance from 12.08.2026. A product assessment by a certified packaging inspector is recommended in this case.

When do the minimum quotas for recycled content in plastic packaging come into force?

The first binding minimum quotas for post-consumer recyclate in plastic packaging do not come into force on 12.08.2026 itself, but in phased stages from 2030. The key date of 12.08.2026 primarily marks the entry into force of the design requirements (recyclability), labelling obligations and minimisation requirements. Nevertheless, you should initiate the transition of your raw material procurement at an early stage, as supply chains for PCR materials in the cosmetics industry still have limited capacity.

Do we need to replace our existing packaging designs immediately, or are there transitional periods?

The PPWR provides limited transitional arrangements for packaging already placed on the market and existing stock. Packaging lawfully manufactured and placed on the market before 12.08.2026 may as a rule continue to be sold until stocks are exhausted. However, packaging newly produced or imported from the key date onwards must meet the new requirements. You should discuss the precise demarcation for your production situation with your local Chamber of Commerce or a lawyer specialising in packaging law.

Branchenguide · PPWR

PPWR for Cosmetics & Personal Care: What Manufacturers and Retailers Must Know from 12.08.2026

Jars, spray bottles and tubes are at the heart of the new EU Packaging Regulation (EU) 2025/40 — known as the PPWR. For the cosmetics and personal care industry, this means concrete obligations from the key date of 12.08.2026 regarding material selection, recycled content and the recyclability of your packaging. Acting now avoids fines and secures EU-wide market access.

What the PPWR Means in Practice for Cosmetic Packaging

Regulation (EU) 2025/40 — the so-called Packaging and Packaging Waste Regulation (PPWR) — replaces the previous Directive 94/62/EC and applies directly in all EU Member States. For manufacturers and those placing cosmetic and personal care products on the market, three areas are particularly relevant: material classification, recycled content requirements and recyclability.

Material Classification: Which Packaging Types Apply to What?

The PPWR distinguishes packaging by contact material and function. Glass or plastic jars, aluminium tubes, PP or PE spray bottles and composite packaging (e.g. airless systems) fall into different material categories. The classification determines which minimum requirements apply in terms of recycled content and design criteria. Multi-layer composite materials — such as aluminium-plastic laminate tubes — require particular attention, as these may be classified as difficult to recycle and are therefore subject to stricter requirements.

Recycled Content Obligation: Phased Minimum Quotas from 2030

The PPWR establishes phased minimum proportions of recycled plastic. For cosmetic packaging made from plastic, the first binding quotas apply from 2030, rising further by 2040. Specifically, plastic packaging not in direct contact with food — which covers the majority of cosmetic packaging — must contain a defined minimum proportion of post-consumer recyclate (PCR). For spray bottles and jars made from PET, PP or HDPE, you should already be engaging with your suppliers now to transition the supply chain to recycled raw materials.

Recyclability: Minimum Requirements for Packaging Design

From 12.08.2026, all packaging newly placed on the market must meet the design requirements for recyclability. In concrete terms, this means avoiding or reducing disruptive elements such as labels made from incompatible materials, non-removable adhesives or colour coatings that impair recycling. For cosmetic tubes, this requires a critical review of closure systems and labelling methods. Pump systems on dispensers must be assessed separately, as metal springs or mixed components can reduce recyclability.

Refill Systems: New Requirements and Opportunities

The PPWR actively promotes refill systems (Reuse & Refill). For brick-and-mortar retailers, refill stations for certain product categories will become mandatory above specific floor area thresholds. As a manufacturer, you can position yourself early through refill-compatible packaging designs. Investment in reusable jars or refill pouches pays off both from a regulatory and a commercial perspective, as demand for sustainable packaging formats in the premium segment is growing significantly.

Practical Implementation Tips

Conduct an inventory now: Classify all your packaging units by material category and check recyclability against the current PPWR design guidelines.
Supplier discussions: Actively enquire about the PCR content of your plastic raw materials and request supporting documentation.
Technical documentation: Keep material data sheets, composition certificates and declarations of conformity readily available — market surveillance authorities may request these from the key date onwards.
Labelling obligations: Check whether your packaging meets the new labelling requirements (material identification, separation instructions).

For a legally sound assessment of your specific product situation, we recommend contacting your local Chamber of Commerce (IHK) — it offers free initial consultation on the PPWR and can refer you to certified legal experts if needed.

Häufige Fragen

Does the PPWR also apply to the smallest cosmetic packaging such as sample sizes and travel sizes under 50 ml?: Yes, in principle the PPWR applies to all packaging placed on the EU single market — regardless of fill volume. For very small packaging (under 1.5 litres in volume), there are in some cases exceptions or differing deadlines for recycled content quotas, but not for the design requirements for recyclability. Sample packaging and promotional products are also covered. Please clarify any exemptions on a case-by-case basis with your local Chamber of Commerce.
My airless pump consists of several materials. How is it classified?: Airless dispensers and similar multi-component systems are classified according to the primary material of the container body; however, the additional components (metal springs, silicone seals, pump mechanism) must also be assessed separately. If these components significantly impair the recyclability of the overall system, the packaging may be classified as 'difficult to recycle' — with corresponding consequences for compliance from 12.08.2026. A product assessment by a certified packaging inspector is recommended in this case.
When do the minimum quotas for recycled content in plastic packaging come into force?: The first binding minimum quotas for post-consumer recyclate in plastic packaging do not come into force on 12.08.2026 itself, but in phased stages from 2030. The key date of 12.08.2026 primarily marks the entry into force of the design requirements (recyclability), labelling obligations and minimisation requirements. Nevertheless, you should initiate the transition of your raw material procurement at an early stage, as supply chains for PCR materials in the cosmetics industry still have limited capacity.
Do we need to replace our existing packaging designs immediately, or are there transitional periods?: The PPWR provides limited transitional arrangements for packaging already placed on the market and existing stock. Packaging lawfully manufactured and placed on the market before 12.08.2026 may as a rule continue to be sold until stocks are exhausted. However, packaging newly produced or imported from the key date onwards must meet the new requirements. You should discuss the precise demarcation for your production situation with your local Chamber of Commerce or a lawyer specialising in packaging law.

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