PPWR Series: Recycled Content
How will the increasing pressures around recycled content impact the cosmetic industry?
As part of the European Union’s broader push toward a circular economy, the upcoming Packaging and Packaging Waste Regulation (PPWR) introduces mandatory requirements for minimum levels of recycled plastic content in packaging, including for cosmetic products. These new rules aim to reduce reliance on virgin plastics and promote the use of post-consumer recycled (PCR) materials. However, while the intent is environmentally driven, the implementation raises complex challenges for industries where product safety, stability, and consumer protection are key. In this article we’ll outline the relevant regulatory targets and the implications for the cosmetic sector.
Upcoming regulatory requirements
From Jan 2030, any plastic part of the packaging should contain a minimum percentage of recycled content recovered from post-consumer plastic waste, calculated as an average per manufacturing plant and year. The minimum percentage varies depending on the contact sensitivity of the packaging: for cosmetics the minimum level will be 30% for PET, 10% for other plastics.
From Jan 2040, increased targets for minimum recycled content will apply (50% for PET, 25% for other plastics)
The recycled content should be sourced from post-consumer plastic waste collected and recycled within the EU or collected in a third country with equivalent standards.
Challenges for the cosmetic industry
Such requirements as those above, in tandem with the desire for brands to be more sustainable, will mean that there will be a much greater demand for recycled plastic packaging: This could be as much as five times that required today.* This increase in demand does not come without challenges, in particular, a scarcity in acceptable quality recyclates. Currently, industry favours using food contact grade materials as this already ensures a quality and safety equivalent to virgin plastic. But the increased demand (also in the food sector) is likely to lead to shortages for the cosmetic industry.
Consumers today are becoming more aware of the importance of their waste disposal habits in order to protect planetary resources and so there is a great deal of waste plastic that is ready to be sent to post-consumer recyclate waste streams, however, these plastics do not generally meet food contact requirements and so the standard principles for assessing the use of food contact recyclate or virgin plastic as cosmetic packaging are not appropriate. As a result, it is challenging for cosmetic companies to be able to utilise these PCR materials to package their cosmetics.
At the recent Cosmetics Europe Annual Conference (CEAC), I attended the session that highlighted these challenges and which presented the CosPaTox** guideline and four-step methodology for evaluating the risk of using a recycled plastic material:
Testing approach: Identification of impurities via non-targeted or targeted tests in order to evaluate their risk (hazard AND exposure) in the later steps.
Toxicological characterisation of the identified substances.
Exposure characterisation, including the assumption that ALL substances will migrate (maximum exposure scenario).
Risk characterisation via established safety assessment principles such as product types, amount of product applied, retention factor (leave-on/rinse-off) and absorption factor.
The guidance also goes on to establish recommended acceptable quality levels for leave-on products and rinse-off products to take account of the different exposure scenarios.
Balancing sustainability with safety
The new PPWR requirements represent a significant step toward more sustainable packaging practices in the cosmetics industry. However, meeting these recycled content targets poses technical and supply chain challenges. The limited availability of high-quality recyclates means the industry must look to adapt and adopt new risk assessment strategies. Initiatives like CosPaTox offer valuable tools to bridge this gap, providing structured guidance on how to evaluate and safely integrate PCR materials. As regulatory timelines approach, proactive collaboration between stakeholders will be essential to ensure that both sustainability and product safety are maintained.
Bloom Regulatory supports cosmetic businesses to monitor those new requirements and provide training on the new PPWR requirements. If you are interested in organising an in-house or online training for your regulatory, packaging and procurement teams please contact us.
* Data from CosPaTox Consortium
** The CosPaTox Consortium, which concentrates on the link between Cosmetics, Packaging, and Toxicology, aims to develop clear safety assessment guidelines tailored for high-quality post-consumer recycled plastics (PCRs) intended for use in cosmetic and detergent packaging. In addition, the consortium is working to establish appropriate testing methods to support these evaluations. The full guideline is available from the CosPaTox website: https://cospatox.com/publication/.
Amanda Isom