PPWR Series: Packaging Minimisation
What is packaging minimisation and what does it mean for cosmetic companies?
Both the existing Packaging and Packaging Waste Directive (94/62/EC, or PPWD) and the upcoming Packaging and Packaging Waste Regulation (EU 2025/40, or PPWR) require companies to reconsider how they package products. One key focus is packaging minimisation.
As part of our ongoing series exploring the new PPWR, this article dives into the concept of packaging minimisation, what it is, what’s changing, and how cosmetic brands can prepare. If you haven’t already, check out our other articles in the series for a full picture of what’s covered under the new Regulation.
What is packaging minimisation?
Packaging minimisation is all about eliminating unnecessary packaging, especially packaging that exaggerates the size of a product to boost appearance on shelf (e.g. by appearing larger than the competition).
In essence, packaging must be designed and manufactured so that its volume and weight are no more than what is needed to ensure product safety, hygiene, and consumer acceptance. That means no oversized or deceptive boxes, unnecessary inserts, or decorative components that don’t serve a functional purpose.
Packaging minimisation as the first step of waste hierarchy
The waste hierarchy is laid down in the EU waste framework directive (Directive 2008/98/EC) and ranks waste management options from most to least environmentally preferable: prevention is best, while landfill disposal is worst.
*defra guidance on applying the Waste Hierarchy (Waste hierarchy guidance)
Packaging minimisation is at the forefront of the prevention step focusing on measures, taken before a substance, material or product has become waste, that reduce:
the quantity of waste, including through the reuse of products or the extension of the life span of products;
the adverse impacts of the generated waste on the environment and human health; or
the content of harmful substances in materials and products.
The requirements under PPWR
While the PPWD remains in effect until the end of 2029, new requirements under the PPWR begin to phase in shortly after:
Packaging must be designed to minimise weight and volume.
False or misleading packaging characteristics like double walls or false bottoms will be banned.
Transport and e-commerce packaging must not exceed an empty space ratio of 50%.
From 2030, single-use plastic packaging for cosmetics, hygiene, and toiletry products used in the accommodation sector will be prohibited if it’s designed to be discarded before the next guest arrives.
Designing packaging for compliance
To meet these requirements, brands must assess their packaging in a holistic way and not look at individual components like a tube or a carton in isolation. These need to be evaluated as part of the complete packaging system, and in relation to the product they protect.
For example, the tube, cap, and outer carton of a mascara all play a role in protecting the formula, particularly if it contains volatile ingredients or needs tamper-evidence.
In practice, reducing packaging size without compromising safety or usability requires a balanced approach and one that takes account of environmental, social, and economic characteristics.
In this article we’ve focussed on the concept of minimisation with regards packaging design aspects such as weight and volume but it is also important to remember that the PPWR also requires the presence and concentration of substances of concern as constituents of the packaging material or of any of the packaging components to be minimised. You can read more about this in our article: https://www.bloomregulatory.com/articles/ppwr-series-substances-of-concern
Evidencing compliance
Many companies demonstrate compliance by creating a Packaging Minimisation Dossier: a document that records decisions, design rationale, and supporting evidence. This dossier is typically supported by a broader packaging strategy outlining how minimisation decisions are made and how environmental design principles are applied.
Dossier template
At Bloom, we’ve developed a practical, ready-to-use Packaging Minimisation Dossier template designed specifically for the EU and UK regulatory landscapes. The template includes:
Guiding questions to help you think through critical decisions
and when purchased is also inclusive of
Our expert review of an existing completed dossier, or feedback on your first one using our template
Training and strategy support
We also offer tailored training for teams and cross-functional groups looking to strengthen their understanding of packaging minimisation and build a design strategy to include goals and considerations around:
Resource optimisation
Sustainable sourcing
Environmentally sound usage
Design for recycling
Please get in touch if you would like to know more about these services.
Amanda Isom