Regulation (EU) 2025/40, known as the PPWR (Packaging and Packaging Waste Regulation), is the new European framework for packaging and packaging waste. It covers jars, bottles, pumps, caps, cartons and transport packaging, regardless of material or sector.
One clarification we often see misunderstood: the regulation entered into force in February 2025, but applies from 12 August 2026. These are two different things. From that date, the PPWR is directly applicable across the Union, but it does not work like an on-off switch: many of the most visible measures have their own deadlines between 2028 and 2038 and still require technical implementing acts.
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Why Europe changed the rules
The figures explain the choice better than any introduction. According to Eurostat, in 2023 the European Union generated 79.7 million tonnes of packaging waste, equal to 177.8 kilograms per inhabitant. In the same year, each European citizen generated an average of 35.3 kilograms of plastic packaging waste, of which 14.8 kilograms was recycled: 42.1%.
The issue concerns not only the amount of material used. How the packaging is designed also matters: how many different materials it contains, how easily they can be separated, whether collection and recycling systems exist for it at a real-world scale, and how much empty space it transports.
The PPWR therefore intervenes upstream, requiring packaging to be rethought before it reaches the market. European targets provide for a reduction in per-capita packaging waste compared with 2018 of 5% by 2030, 10% by 2035 and 15% by 2040.
The timeline: what changes and when
| Date | What takes effect |
|---|---|
| 12 August 2026 | General application of the regulation. The phase begins in which producers, importers and distributors adapt their design, documentation and processes. |
| 12 February 2028 | The weight and volume of sales packaging reduced to the minimum necessary for functionality. Harmonised labelling on material composition is forthcoming. |
| 1 January 2030 | Packaging designed for recycling and classified according to European criteria. Minimum percentages of post-consumer recycled plastic. Ban on single-use items in accommodation facilities and HoReCa. 50% empty-space limit for grouped, transport and e-commerce packaging. |
| 2038 | Only packaging in the highest performance classes provided for by the regulation will remain on the market. |
The dates linked to the implementing acts may be delayed if the technical acts require more time. This is why it is currently correct to speak of a defined path, not a completed transformation.
Weight and volume: the most relevant aspect for cosmetics
From February 12, 2028, the weight and volume of retail packaging will have to be reduced to the minimum necessary to ensure its functionality, also taking shape and material into account.
This is the point that most directly affects our sector. In cosmetics, the perception of luxury has often been created through thick walls, double bottoms, and cartons larger than their contents. The regulation targets precisely those features designed solely to make the product appear more voluminous.
However, elements with a real function are not being called into question: protecting the formula from light and oxygen, ensuring hygiene and stability, guaranteeing proper dispensing, and withstanding transport. This is a distinction worth explaining at the counter: an airless bottle is not unnecessary packaging; it is what allows an unstable active ingredient to reach the end of the jar intact.
Empty space: be careful not to generalize
The maximum limit of 50% empty space applies to grouped, transport, and e-commerce packaging from 2030 or the subsequent applicable technical date.
There is currently no identical specific percentage limit for retail cosmetic packaging: the Commission will have to review the issue by 2032. This is an important distinction, because "reducing empty space" does not mean immediately applying the same formula to every carton.
Design for recyclability and recycled plastic from 2030
From 2030, packaging will have to be designed for recycling and classified according to European recyclability criteria, defined through delegated acts that will take into account the actual capacity to collect, sort, and recycle the materials.
Also from 2030, minimum percentages of post-consumer recycled plastic for plastic parts will come into play, with different values depending on the type and with specific exceptions. Claiming that every cosmetic bottle will have to contain the same proportion of recycled material would therefore be inaccurate: format, material, function, and technical acts still to be completed all matter.
Environmental claims will have to become more precise
The regulation pays particular attention to environmental claims about packaging. When a claim concerns a property governed by the PPWR, it will have to be supported by technical documentation, clearly indicate whether it refers to the entire package, a part, or a single unit and, where applicable, describe performance that exceeds the minimum legal requirements.
For counter advice, this translates into a simple criterion. Writing "sustainable packaging" does not say which characteristic has been improved. More useful are specific, verifiable statements: the percentage of recycled material, the component to which it refers, the actual possibility of separating the parts, and the relevant collection stream.
A clarification is also needed regarding the term recyclable, which does not mean "will definitely be recycled". Design is a necessary condition, but the result depends on local collection, sorting, available facilities and the behavior of the person disposing of the waste.
PFAS: a necessary clarification
In the days following its entry into application, several news reports linked the PPWR to limits on PFAS, per- and polyfluoroalkyl substances.
The distinction is essential: the thresholds set by the PPWR from 12 August 2026 concern packaging intended to come into contact with food. They do not constitute an automatic and general ban on every cosmetic jar or bottle. The debate on PFAS in cosmetics remains open, but follows other regulatory pathways: we wrote about it in our dedicated analysis of the French ban on PFAS in cosmetics.
End of single-dose bottles in accommodation establishments
Article 25, together with Annex V, establishes a ban, from 1 January 2030, on single-use packaging for cosmetic products provided for a single reservation in accommodation establishments:
- shampoo, conditioner and shower gel in mini bottles;
- body cream and other personal hygiene products in single-dose bottles.
The following are excluded from the ban:
- travel products sold at retail;
- commercial samples;
- healthcare and hospital facilities.
Many operators are already moving towards sealable refillable dispensers, solid cosmetics and certified refill systems. The challenge is to balance sustainability, practicality and compliance with hygiene and health regulations.
The ban on single portions in the food sector
From 1 January 2030, single-use sachets of sauces, oil, vinegar, sugar, jam and butter offered for on-site consumption will also be banned. They will remain permitted for takeaway and delivery, in retail sales and healthcare settings.
What it means for pharmacies
The PPWR does not impose direct obligations on points of sale, but it changes three concrete aspects of daily work.
- Customer questions will become more technical. No longer just "is it recyclable?", but "can the parts be separated?", "how much recycled material does it contain?", "why is this packaging like this?". These are legitimate questions and deserve precise answers.
- Packaging will no longer be an indicator of product range. A heavy jar will no longer automatically mean a superior product, and this changes how to present a premium product on the shelf.
- Environmental claims on products in the range will be more verifiable. Those who use them vaguely will face greater exposure; those who document them will have an advantage.
The approach we recommend at the counter is the same one we follow in the company: always distinguish between unnecessary material and functional material, and do not confuse aesthetic simplicity with genuine sustainability. Lightening a container is not an advantage if it compromises the formula’s stability and generates more product waste.
Frequently asked questions about EU Regulation 2025/40
When does the PPWR apply?
From August 12, 2026. The regulation entered into force in February 2025, but general application begins in August 2026. The operational bans on single-use items will instead take effect on January 1, 2030.
Will cosmetics on the market become non-compliant on August 12, 2026?
No. The regulation provides for a transition period, and many substantive provisions have their own dates. Packaging already on the market does not automatically become non-compliant.
Will every bottle have to contain recycled plastic?
From 2030, minimum percentages of post-consumer recycled plastic will be required for plastic parts, but the values will vary by type and there will be exceptions. There is no single quota that applies to all formats.
Does the 50% empty-space limit apply to cosmetic boxes?
Not in the way it is often reported. The limit concerns grouped, transport and e-commerce packaging. For sales packaging, the Commission will have to review the issue by 2032.
Does the PPWR ban PFAS in cosmetics?
No. The PPWR thresholds in force from August 12, 2026 concern food-contact packaging. The issue of PFAS in cosmetics follows separate regulatory pathways.
When will single-use bottles in hotels be banned?
From January 1, 2030, for cosmetics supplied for a single booking in accommodation establishments. Travel sizes sold at retail will remain permitted.
Will there be penalties?
Yes, but the implementing procedures will depend on the national authorities: each Member State will define its own system of sanctions.
Sources for this article
- Regulation (EU) 2025/40 of the European Parliament and of the Council on packaging and packaging waste, published in the Official Journal of the European Union on January 22, 2025; in particular Article 25 and Annex V.
- Eurostat, packaging waste statistics, data for 2023 published on October 22, 2025.
- European Commission, information framework on packaging waste and PPWR implementation.
- Regulation (EC) No 1223/2009 on cosmetic products.
On the website: PFAS in cosmetics · Cosmetics expiry date and PAO
Article updated in August 2026, on the occasion of the regulation’s general application.
