Packaging regulation in the cosmetics sector: what changes

Why cosmetics packaging is contact-sensitive packaging

Article 3 defines contact-sensitive packaging by reference to the Union acts governing the products it contains, and the list includes Regulation (EC) No 1223/2009, the rules on cosmetic products.

The consequence is set out in Article 7: from 1 January 2030, or three years after the entry into force of the relevant implementing act if later, the plastic parts of packaging must contain at least 30% post-consumer recycled content if the main component is PET, and at least 10% if made of plastics other than PET. For plastic packaging that is not contact-sensitive, the threshold is instead 35%.

The percentage is calculated as an average per production plant and per year.

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What applies from 12 August 2026

The heavy metals limit: sum of lead, cadmium, mercury and hexavalent chromium not exceeding 100 mg/kg in the packaging or in one of its components. Caps, pumps, dispensers, labels and inks each fall within scope as separate components.

Technical documentation and the EU declaration of conformity, for each type of packaging, under Annexes VII and VIII.

The suppliers' information obligation, which Article 16 places on whoever supplies packaging and materials: this is the route to obtaining composition, values and test reports for cartons, bottles and closures.

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The ban concerning the hospitality sector

Annex V, point 5, bans, from 1 January 2030, single-use packaging for cosmetics and toiletries "for use in the hospitality sector, as described in NACE Rev. 2, intended solely for an individual booking and to be disposed of before the arrival of the next guest".

The illustrative examples given in the text are shampoo bottles, hand and body lotion bottles, and soap bags.

The ban concerns the placing on the market of those formats for that use: it therefore concerns both hospitality establishments and the undertakings that produce or supply the amenity lines.

Article 25(4) allows Member States to permit microenterprises to place on the market the formats listed in point 3 of Annex V, subject to demonstrated conditions: that option does not cover point 5.

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The other requirements affecting the sector

Minimisation (Art. 10): weight and volume reduced to the minimum necessary, with demonstration in the technical documentation, which must contain the technical specifications used for the assessment, the design requirements that prevent further reduction, and the results of tests, studies or simulations. This is the provision that concerns cartons and secondary packaging.

Excessive packaging (Art. 24): from 1 January 2030, or three years after the implementing act if later, the proportion of empty space in grouped, transport and e-commerce packaging does not exceed 50%.

Recyclability (Art. 6): from 1 January 2030, or 24 months after the delegated acts if later, packaging that is not recyclable to performance grade A, B or C cannot be placed on the market; from 1 January 2038 the threshold rises to grades A or B.

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References

Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on packaging and packaging waste, in OJ L of 22 January 2025.

• Art. 3 · Definition of contact-sensitive packaging
• Art. 5(4) · Heavy metals
• Art. 6 · Recyclable packaging and performance grades
• Art. 7 · Minimum recycled content
• Art. 10 · Minimisation
• Art. 24 · Excessive packaging
• Art. 25 and Annex V, point 5 · Single-use cosmetics and toiletries packaging in the hospitality sector
• Annexes VII and VIII · Technical documentation and EU declaration of conformity

Official text: http://data.europa.eu/eli/reg/2025/40/oj