PPWR: the burden of proof shifts to brands

From August 2026, the phased implementation of the EU Packaging and Packaging Waste Regulation (PPWR) will increase the documentation requirements placed on cosmetics companies. Packaging compliance will no longer simply need to be ensured: it will also have to be demonstrated, based on technical assessments, supplier data and traceability information covering each component.

Responsibility does not rest solely with packaging manufacturers. The regulation also places obligations on operators that select packaging and place products on the EU market. This becomes particularly complex when containers, closures, labels, cartons and transport packaging are sourced from different suppliers.

The conformity assessment and declaration of conformity will be among the key documents to compile. As preparing them can take several months, Cosmeservice, a Spanish regulatory consultancy specialising in the cosmetics industry, recommends starting packaging portfolio reviews and collecting supplier data well in advance.