PPWR Series: What Next?
Navigating the priorities of the Packaging and Packaging Waste Regulation
Over the past few weeks, our PPWR series has explored the critical aspects of the new EU Packaging and Packaging Waste Regulation, which was officially published on 22 January 2025 and comes into effect on 12 August 2026:
Substances of concern
Recyclability
Recycled content
Packaging minimisation
Sorting labels
Technical dossier and Declaration of Conformity
Our PPWR series initiative was triggered to inform and alert cosmetics businesses on the current and future requirements regarding packaging and packaging waste to avoid infringements and reputational damages.
While some details are still being finalised, proactive planning and strategic action are essential for businesses to navigate these new requirements successfully and on time.
Priority Actions
It is important to remember that some of the provisions already exist under the current PPWD but that enforcement in many Member States may not have been high. We, therefore, recommend that priority should be given to the existing essential requirements, including:
Minimisation of noxious and hazardous substances, in particular the levels of lead, cadmium, mercury, and hexavalent chromium;
Minimisation of packaging and, in particular, replacing items such as false bottoms and deceptive thick walled packaging, and removing unnecessary layers.
Preparing a packaging minimisation dossier for each product.
Focusing on these aspects will ensure current compliance to the PPWD.
We have services available to assist with all of these aspects, including a packaging minimisation dossier template and consultation with one of our team to help you prepare your product packaging dossiers.
Getting Ready for Future Requirements
Dates like 2030 may seem a long way off for aspects such as recyclability and recycled content but, the large portfolios of packaging in use by cosmetic brands, it can take significant time to source suitable alternatives whilst also having to balance the other requirements of hazardous substances and minimisation, and then to exhaust existing stocks. Some aspects of the definitions await clarification and additional Implementing Decisions/Regulations to be published. However, we can help you to devise a strategy to take you through this period of uncertainty, identifying priority areas that are already guaranteed to require action and then to support you as additional clarity becomes available.
We hope that you have found our series of articles around the new Regulation useful. Please do not hesitate to contact us if you would like to engage us for any advice in this area or would like to understand more about our PPWR-related services.
Amanda Isom