PPWR for Cosmetic Packaging: What Beauty Brands Need to Know

The PPWR separates two roles.

The manufacturer (Article 15). In most cases, this is the brand that fills the box and places the product on the EU market. The manufacturer must make sure the packaging conforms to the regulation, carry out the conformity assessment, draw up the technical documentation and sign an EU declaration of conformity. Documentation must be kept for 5 years for single-use packaging.

The supplier (Article 16). This is the company that produces the packaging or packaging materials, such as your box maker. Suppliers must give the manufacturer all the information and documentation needed to prove conformity.

In practice, your declaration is only as strong as the data you get from your box supplier. If they cannot provide it, the gap becomes your problem.

Some 2030 and later dates can move back if the related delegated or implementing acts are adopted late. The direction, however, is fixed.

Paperboard folding cartons start from a strong position. They are mostly one material, widely collected and recycled across Europe. Recyclability will be graded A to E, and a mono-material carton is the easiest route to a good grade.

Design choices that can lower recyclability:

• Full-surface plastic lamination. Some soft-touch and gloss effects are made with a thin plastic film. Varnishes and coatings can often give a similar look while keeping the box closer to pure paperboard.
• Plastic windows glued into the carton.
• Mixed-material inserts, such as plastic trays or foam inside a paperboard box. Paperboard inserts are the simpler option.
• Large metallised areas. Small hot foil details are generally less of a concern than full-surface effects, but the final grading criteria will come with the delegated acts.

If you are designing a new box now, design it for 2030. A carton developed today will often still be on the shelf when the recyclability rules take effect.

Article 10 requires that, by 1 January 2030, packaging weight and volume are reduced to the minimum needed for the packaging to do its job.

It also names features that only increase the perceived volume of the product, including double walls, false bottoms and unnecessary layers. These are common in cosmetics and gift sets, so it is worth reviewing them early.

There are narrow exceptions, for example packaging designs protected by a registered design or trademark before 11 February 2025, where changing the design would affect its protection. Most brands should not rely on them.

Practical steps:

• Size the carton to the bottle or jar, not to the shelf.
• Use inserts only where they protect the product.
• Question every extra layer, such as a sleeve over a carton over a pouch.

Functional reasons such as product protection, hygiene and safety still count. Marketing preference alone does not.

Packaging must be made so that substances of concern are minimised. The combined level of lead, cadmium, mercury and hexavalent chromium in packaging or its components must not exceed 100 mg/kg.

For cartons, this mainly concerns inks, coatings, adhesives and the paperboard itself. Ask your supplier what declarations they can provide.

From 12 August 2028 at the earliest, packaging must carry a harmonised label with pictograms showing its material composition, to help consumers sort it correctly. Packaging must also be identifiable, for example by a type or batch number, and carry the manufacturer's name and contact details. A QR code can be used for some of this information.

If you redesign your artwork in the next two years, leave space for the label.

Use this checklist when you request a quote:

1. Can you provide the material composition and weight of each component of the box?
2. Which paperboard grade do you use, and is it FSC certified?
3. Which inks, coatings and adhesives do you use, and can you provide declarations for them?
4. Can you confirm heavy metal levels in packaging components?
5. Can you suggest a mono-material alternative to laminates, plastic windows or plastic inserts?
6. Can you help reduce empty space and unnecessary layers?
7. Will you provide this information in a format you can attach to your technical documentation?

If a supplier hesitates on these questions, factor that into your decision.

We produce folding cartons for skincare, fragrance and candle brands in Istanbul, where we have manufactured packaging since 1983.

• Packaging data for your technical documentation: on request, we share the material composition, component weights, board grade and finishing details of your box.
• FSC-certified paperboard: FSC Chain of Custody certificate FSC-C183770.
• Design for 2030: we suggest varnish instead of laminate, paperboard instead of plastic inserts, and carton sizes that fit your product.

Planning a new launch or redesigning an existing box? Send us your product dimensions and current packaging, and we will suggest a PPWR-ready alternative with a quote.