Category: Industry Guide

Packaging Minimization: What Changes for Prestige Design

Under Article 10 of the PPWR, strict packaging minimization obligations become legally binding on January 1, 2030, sitting on a separate implementation timeline from the regulation’s general application date. From 2030 onward, manufacturers and importers must ensure that packaging weight and volume are reduced to the minimum necessary to ensure product functionality. To enforce this, the European Commission is mandating European standardization organizations to develop harmonized methodologies, including maximum weight, volume, and empty space benchmarks for common packaging types.

Prestige cosmetics brands have historically relied on structural weight, secondary packaging volume, and multi-layer construction to convey luxury positioning. Under Article 10, that approach now sits inside a strict compliance framework. The regulation explicitly prohibits packaging characteristics designed solely to increase perceived volume, including double walls, false bottoms, and unnecessary layers. A traditional facial cream jar suspended inside an oversized secondary carton is exactly the type of design this rule targets.

“Marketing presentation” and consumer acceptance are no longer recognized as standalone criteria to legally justify extra packaging mass. Where heavier elements or multi-layered structures remain, manufacturers must prove a legitimate functional necessity, such as formula protection, safe handling, or transport integrity, and document it within their technical documentation. Narrow exemptions exist for packaging designs or trademarks protected prior to February 11, 2025 (the date the PPWR entered into force), but these apply only where a forced redesign would alter the design’s novelty or destroy the packaging’s core visual distinctiveness.

Recycled Content Targets for Cosmetics Packaging

Cosmetics packaging that contacts the product directly is classified as contact-sensitive packaging under PPWR, which brings it within the mandatory recycled content targets that take effect January 1, 2030.

The thresholds, set under Article 7:

• Rigid PET components (containers, jars, flasks where PET is the major structural material): minimum 30% recycled content from post-consumer plastic waste
• Other contact-sensitive plastics (PP pumps, PE squeeze tubes, multi-layer acrylic caps): minimum 10% recycled content

These targets are calculated as an annual average per individual manufacturing plant, not across a global portfolio. This means cosmetics brands need verified, per-plant chain-of-custody data from converters and material suppliers, not a blended company-wide figure.

One exemption is worth knowing early: under Article 7(5)(b), any plastic part representing less than 5% of a packaging unit’s total weight is completely exempt from these recycled content targets. Because Article 7 only regulates plastics, non-plastic elements like glass bodies or metal collars already sit outside these mandates. The real strategic value of this 5% rule is for multi-material designs: if you have a heavy glass fragrance bottle or skincare jar, and its plastic pump or cap makes up less than 5% of the unit’s total overall weight, that plastic component is entirely exempt from the recycled content mandate.

PCR Sourcing and Cosmetics Safety: A Compatibility Question Worth Raising Early

Incorporating post-consumer recycled (PCR) content satisfies PPWR’s targets, but it raises a separate question under the CPR: whether a packaging material change affects the safety profile of the product it contains. PCR materials can carry trace impurities from their previous lifecycle that virgin, cosmetic-grade polymers do not.

Introducing a new packaging material that contacts a formulation is the kind of change that typically warrants a fresh look at packaging compatibility and stability under existing CPR safety assessment processes, since impurities or degraded polymer structures could, in principle, migrate into the product. Any PCR sourcing decision is worth reviewing jointly by packaging engineering and your safety assessor before it reaches production, rather than treating it as a packaging-only decision. Build this coordination into your compliance schedule now, since safety re-assessment timelines can run longer than a packaging redesign cycle.

Empty Space and Structural Efficiency

Under Article 24, PPWR sets a maximum 50% empty space ratio for grouped, transport, and e-commerce packaging, taking effect January 1, 2030 (or three years after the Commission’s implementing act on calculation methodology, whichever is later). This hard cap does not currently extend to sales packaging, the format most cosmetics products use.

That said, sales packaging is not exempt from scrutiny. By February 12, 2028, economic operators filling sales packaging must ensure empty space is reduced to the minimum necessary to ensure packaging functionality. Furthermore, the Commission is required to review the rules by February 12, 2032, to examine whether a strict maximum ratio should extend to sales packaging as well. The regulation explicitly singles out cosmetics as a primary target for this review, alongside toys, DIY kits, and electronic products.

Filler materials, including paper cuttings, air cushions, bubble wrap, and foam inserts, count as empty space under the regulation’s calculation method. Structural choices made now for multi-year tooling or packaging line development are worth evaluating against this direction of travel, even ahead of the upcoming 2028, 2030, and 2032 deadlines.

Chemical Restrictions on Inks, Coatings, and Packaging Finishes

Cosmetics packaging often relies on metallic hot-stamping, UV-cured lacquers, protective inner coatings, and heavy pigments to achieve a premium finish while protecting light-sensitive formulations. From August 12, 2026, PPWR’s general substance restrictions apply. While the new PFAS ban is strictly limited to food-contact packaging (meaning cosmetics currently escape this specific PPWR rule), all packaging must meet the strict 100 mg/kg combined limit for heavy metals, specifically lead, cadmium, mercury, and hexavalent chromium.

A broader Substances of Concern (SoC) assessment is also underway. By December 31, 2026, the European Commission and ECHA (European Chemicals Agency) must publish a report evaluating how specific SoCs negatively impact recycling or chemical safety. This report will set the stage for future restrictions on specific inks, dyes, or laminates, either through new REACH actions or upcoming “design for recycling” bans. Until that report is published, the safest approach is to begin composition audits with raw material suppliers now, so your data is ready when the regulatory crosshairs narrow.

The Single-Use Hospitality Ban

From January 1, 2030, PPWR prohibits single-use packaging for cosmetics, hygiene, and toiletry products in the accommodation sector, under Article 25 and Annex V. This directly hits miniature shampoo, lotion, and soap packaging supplied for individual hotel bookings, specifically, any liquid product under 50 ml and any non-liquid product under 100 g.

Two details matter for brands supplying this channel. First, the date is 2030, not August 2026: this ban sits on a separate timeline from PPWR’s general application date, and the two are easy to conflate. Second, the final text of the regulation is material-neutral. While several other packaging bans in Annex V explicitly target “single-use plastic,” the hotel miniature ban applies to all “single-use packaging.” Brands supplying hospitality miniatures cannot bypass this obligation simply by switching from plastic to another single-use material like aluminium or paper.

The alternatives already emerging in the market: fixed refillable dispensers, and reusable packaging within a formal reuse system. (Note: Even if products are made available “on request” rather than pre-placed in rooms, if they are single-use formats under the size thresholds and intended to be discarded before the next guest arrives, they are still banned under the regulation.)

Digital Labelling: Where PPWR and the CPR Actually Meet

PPWR’s harmonised packaging labels, showing material composition through standardised pictograms, become mandatory from August 12, 2028, not from the 2026 general application date. Once in force, Article 12 permits a QR code or other standardised digital data carrier to convey some of this information, particularly where physical space on the packaging is limited.

The CPR takes a different position. Under Regulation (EC) No 1223/2009, certain mandatory information, including the Responsible Person’s identity and address, country of origin where applicable, nominal content, and the ingredient list, must appear physically on the container or packaging in indelible, legible lettering. The CPR does allow some information to move to an accompanying leaflet or tag where physical space is genuinely insufficient, but it does not currently permit full digital replacement of these core safety particulars.

Where the two regulations do align is a provision worth knowing: PPWR’s text states that where EU law already requires product information to be provided via a data carrier, a single data carrier should be used to provide the packaging information alongside it, with both clearly distinguishable. In practice, this means a QR code placed on cosmetics packaging today, to meet PPWR’s digital labelling requirements from 2028, can be built to carry both the packaging-level information PPWR requires and be ready to extend to product-level information if future CPR digitalisation permits it. That does not solve today’s physical labelling requirement under the CPR, but it does mean the digital architecture built for PPWR does not need to be rebuilt if CPR rules evolve.

Documentation and Conformity Assessment

PPWR uses a self-assessment pathway (Module A, internal production control) rather than third-party certification. Before a filled cosmetics unit ships, the responsible party needs technical documentation covering material specifications, supplier verification, and a non-conformity risk assessment, alongside the signed EU Declaration of Conformity. Each distinct packaging component, including the primary container, the pump or closure, and the label, needs its own composition and eventually recyclability data.

This technical documentation and the corresponding Declaration of Conformity must be kept available for national market surveillance authorities for 5 years for single-use packaging and 10 years for reusable formats, measured from the date the packaging was placed on the market. We cover the broader consequences of gaps in this documentation, across all supply chain roles, in more detail in our earlier post on PPWR non-compliance.

Frequently Asked Questions

Does PPWR apply to cosmetics packaging?
Yes. PPWR applies to all packaging placed on the EU market regardless of sector, and cosmetics packaging that contacts the product directly is additionally classified as contact-sensitive packaging, which brings recycled content obligations into scope from 2030.

Can cosmetics brands use a QR code instead of printed labels?
Not for the core information the CPR requires physically on the container, such as the Responsible Person’s address and the ingredient list. PPWR’s own harmonised labels become mandatory from August 12, 2028 (or 24 months after the required implementing acts are adopted, whichever is later). Once in force, PPWR does permit a digital data carrier (like a QR code) to replace physical packaging labels, but only under a strict hierarchy: if the physical label cannot fit on the primary container, it must first be moved to the grouped (secondary) packaging. Only if that is also impossible can a QR code act as a full replacement.

When does the hotel miniatures ban take effect?
January 1, 2030, under PPWR Article 25 and Annex V. This ban specifically targets single-use cosmetics and hygiene packaging for liquid products under 50 ml and non-liquid products under 100 g. This is a separate date from PPWR’s August 12, 2026 general application date.

How PAQR Can Help

Cosmetics packaging portfolios span more SKUs, component types, and supplier relationships than almost any other sector, making compliance with overlapping PPWR deadlines exceptionally difficult to manage in spreadsheets. PAQR solves this by providing a central workspace that organizes your packaging data down to the individual component level, giving primary jars, pumps, caps, and secondary cartons their own material composition and recyclability records while storing the technical weight-and-volume justifications required for Article 10 minimisation.

By streamlining supplier data collection for plant-level PCR chain-of-custody and automatically compiling audit-ready technical documentation and Declarations of Conformity, PAQR helps beauty brands de-risk their packaging supply chain seamlessly.

Learn more at paqr.com/ppwr-solution/.

Click “Try now for free” on paqr.com to start a free trial:

Obligation One: Packaging Must Carry an Identifier

Article 15 PPWR requires that packaging bears a type, batch, or serial number, or some other element that allows it to be clearly identified. The European Commission’s own FAQs make an important clarification here: manufacturers have freedom of choice. You don’t need to provide all three. Pick whichever element actually lets that specific packaging be identified, whether that’s a batch number tied to a production run, a serial number for an individual unit, or a type designation that distinguishes one packaging format from another.

A GTIN, the number behind a standard retail barcode, is a perfectly valid identifier under Article 15, as long as it can be referenced to a specific packaging. If your packaging already carries a GS1 barcode, you’ve likely satisfied this part of the obligation already.

The catch is that a large share of packaging never carries a GTIN at all. Think of transport and grouped packaging, B2B shipments, e-commerce mailer boxes, protective packaging components, or service packaging handed out at point of sale. None of these typically have a retail barcode, because they’re not individual consumer sales units scanned at a till. For all of this packaging, manufacturers need another way to assign and display an identifier, and if the packaging is too small or its shape doesn’t allow for printing, the information can instead be provided in a document accompanying the product.

Obligation Two: Name, Trade Name, and Postal Address Must Be Indicated

The second requirement under Article 15 is about who stands behind the packaging. Manufacturers and importers must indicate their name, registered trade name or trademark, a postal address, and, where available, an electronic means of communication. This information can sit directly on the packaging, be provided through a QR code or other digital data carrier, or, for importers specifically, be included in an accompanying document if it cannot be placed on the packaging itself.

Two details here deserve more attention than they usually get.

Importers Add Their Own Details, They Don’t Replace the Manufacturer’s

A common misreading is to assume that whoever places the product on the EU market lists their details and that’s the end of it. That’s not how Article 15 works. If a product is manufactured outside the EU and brought in by an importer, the importer’s name and postal address must appear in addition to the manufacturer’s, not instead of them. Both economic operators need to be identifiable on the same packaging. This matters for traceability and accountability across the supply chain, and it’s an easy point to overlook when packaging artwork is designed once and reused across markets.

What Actually Counts as a “Postal Address” in the EU

This sounds straightforward until you have to specify it for compliance purposes. A postal address isn’t just “a city” or “a well-known company name.” Across the EU, postal systems are harmonized around the European Standard EN 14142, which aligns with the global UPU S42 standard. For a piece of mail (or, in our context, a printed address) to be valid and deliverable, it needs to contain three distinct elements:

The element of identity: the actual recipient, meaning the registered legal entity or company name.

The element of location: the street name and house number, or a registered P.O. Box, plus any apartment, floor, or building reference where relevant.

The element of routing: the postal code and town or city, which automated sorting systems rely on to route mail correctly.

Leaving out the postal code, or relying on a famous brand name and city alone, doesn’t meet this bar. Some very large organizations are assigned a dedicated postcode (Germany’s Großempfänger scheme or France’s CEDEX system are examples) that lets them skip the street name, but this is a narrow exception reserved for major mail recipients with registered arrangements, not something an average manufacturer can rely on. For Article 15 purposes, manufacturers and importers should give the full, structurally valid address: legal entity name, street and number (or P.O. Box), postal code, and city. A single valid postal address is required; the electronic contact detail is only mandatory if one already exists for the organization.

How a PAQR QR Code Meets Both PPWR Obligations

Affixing a QR code on packaging is explicitly recognized under Article 15 as a valid way to provide both the identifier and the contact details, and it solves the practical problems each requirement creates on its own.

For identification, a PAQR QR code gives every packaging type, batch, or product line a stable, scannable reference. There’s no need to retrofit a GTIN onto packaging that was never designed to carry one, such as transport packaging, grouped packaging, or e-commerce shipping boxes. The code itself stays fixed on the packaging, while the underlying record, batch numbers, serials, specifications, can be updated electronically whenever production details change, without ever needing to reprint or redesign the packaging.

For contact details, the same code carries the manufacturer’s name, trade name, and postal address, and the importer’s details alongside them when applicable, all hosted electronically and kept current. If a company moves offices, updates its registered trade name, or adds an electronic contact channel, that information updates behind the QR code instantly. The physical packaging never needs to change, and there’s no risk of outdated or incomplete address information circulating on stock that’s already been printed and shipped.

This is the real advantage of moving from print to a digital data carrier: compliance information becomes something you maintain centrally rather than something frozen at the moment of printing.

A Code That Can Do Even More: GS1 Digital Link

For manufacturers who already use GTINs and standard retail barcodes, there’s an additional layer worth knowing about. A PAQR QR code can be structured according to the GS1 Digital Link standard, meaning it encodes the GTIN within a web-resolvable URL rather than a traditional linear barcode pattern.

Practically, this means the same QR code that satisfies your Article 15 identification and contact-details obligations can also function at the point of sale exactly as a conventional barcode does, because the GTIN is embedded directly in the code’s structure. Retailers’ scanning systems, particularly as the industry moves through GS1’s global “Sunrise” transition toward 2D barcode acceptance, can read the GS1 Digital Link QR code for checkout, while consumers scanning the same code with a phone land on rich product, sustainability, and recycling information.

Instead of printing a separate EAN barcode and a separate compliance QR code, businesses that adopt PAQR with GS1 Digital Link structuring can consolidate both functions into one code on the packaging: less clutter, one less thing to manage, and a packaging design that’s ready not only for PPWR but for where retail barcoding is heading more broadly.

The Takeaway

Identification and contact details might be the least talked-about parts of PPWR’s labelling regime, but they apply from 2026, well ahead of the harmonized material labels arriving in 2028, and they apply to far more packaging types than companies typically expect. A GTIN covers identification on retail units that already carry one; everything else, plus the separate obligation to list manufacturer and importer contact details, needs its own solution.

A PAQR QR code is built to carry exactly this information, kept accurate and electronically available, on packaging that may never have carried a barcode before, and can even be structured to double as your GS1 Digital Link if you want one code to do both jobs.
If you’re not yet sure whether your current packaging satisfies Article 15’s identification and contact-detail requirements, that’s exactly the kind of gap worth checking now, while there’s still runway before the deadline.

PPWR Transport Packaging: The Rigid vs Flexible Rule

Under the PPWR, the obligation to issue a Declaration of Conformity falls on the manufacturer, defined as the party that manufactures packaging under their name or trademark, or that effectively controls the manufacturing of such packaging.

For transport packaging, whether your business carries that manufacturer status comes down to one question: does the packaging exist as a finished item before it reaches you, or does it only become packaging when you apply it?

Rigid packaging (pallets, crates, rigid containers) holds its shape. It is already a discrete, finished item when it leaves the supplier. The supplier, the pallet manufacturer for example, is typically the manufacturer under PPWR and is responsible for issuing the Declaration of Conformity. Exceptions are made if a rigid packaging is branded (or in other ways made “non-standard”), which would make the brand owner the manufacturer.

Flexible packaging (stretch film, strapping, shrink wrap) has no fixed shape until someone applies it to an item, or a load. It is a packaging material until the moment you bring it into its final shape, e.g. by wrapping a pallet. The film manufacturer is only a supplier under the regulation, and your company, as the party that creates the finished transport packaging by applying it, becomes the manufacturer and carries the compliance obligation.

A useful way to think about this: discrete items (a pallet, a crate) exist as finished packaging before they reach you. Continuous materials (a roll of stretch film, a reel of strapping) only become packaging when you apply them, and whoever does that application is the manufacturer.

This changes where the Declaration of Conformity obligation sits, who builds the technical documentation, and who is responsible if something is wrong.

Where This Distinction Comes From

The distinction emerges from how the PPWR defines its key roles.

Article 3(1)(13) defines the manufacturer as the party that manufactures (or has someone manufacture) packaging under their name or trademark. The Commission Guidance Document C(2026) 2151 final, published on March 30, 2026, reinforces a principle already familiar from sales packaging: packaging only truly exists once it has been filled or applied. An unused roll of stretch film is not packaging yet. It becomes packaging when it is wrapped around another item to fulfill a packaging function (such as: protection).

That logic, combined with Article 3(1)(16)‘s definition of a supplier as a party that provides packaging materials to a manufacturer, places film and strapping producers firmly in the supplier column, and operators using those materials in the manufacturer column.

The Contested Point: FAQ XV-12

There is a catch. FAQ point XV-12 of the Commission’s official PPWR Frequently Asked Questions appears to suggest that a separate Declaration of Conformity is also required for films and strapping bands as standalone products. Legal and compliance professionals have noted that this reading contradicts the regulation’s own logic, since it would treat an unused roll of film as finished packaging. The Commission FAQ and the regulatory text are currently pulling in slightly different directions on this point.

The practical takeaway: do not assume your film supplier will carry this obligation. If you are the one wrapping the pallet, you likely hold it. Confirm that position in writing with your suppliers before August 2026.

What the Technical Documentation Must Cover

Once your role as manufacturer is established for flexible transport packaging, you need to build the technical documentation that supports your Declaration of Conformity.

At the August 12, 2026 application date, component-level data is sufficient for material composition. This means confirming the material makeup of each packaging component. Your documentation must also confirm conformity with the heavy metals limit: the combined concentration of lead, cadmium, mercury, and hexavalent chromium in packaging and its components must not exceed 100 mg/kg.

The Declaration of Conformity and the supporting technical documentation must be kept available for national market surveillance authorities for five years for single-use packaging.

Collecting this data from your film and strapping suppliers in a structured format from the outset, rather than requesting it under deadline pressure, makes building these files significantly more manageable.

What This Means for Your Operations

If your warehouse or outbound logistics team uses flexible packaging, here is what to act on now.

1. Identify which transport packaging you create versus source as finished items. Use the discrete/continuous distinction as your guide. Discrete items sourced from a supplier (a pallet, a crate): their Declaration of Conformity. Continuous materials you apply yourself (stretch film, strapping): your Declaration of Conformity.
2. Treat your flexible packaging material suppliers as material suppliers, not compliance providers. They need to supply material composition data and substance information to support your technical documentation. The declaration is yours to issue.
3. Align with your suppliers on who holds which obligation. Make clear what data you need from them and why. Put that understanding in writing before August 2026.
4. Do not rely on FAQ point XV-12 as a safe harbour. The Commission guidance and the regulation text do not fully align on this point. Build your compliance approach on the regulation itself.

The rigid vs flexible distinction is one of those details overlooked in high-level PPWR summaries but with real operational consequences. If your business ships goods on stretch-wrapped pallets, you are likely a packaging manufacturer under PPWR, whether or not you have thought of yourself that way.

Getting your role defined now is the first step to getting the rest right.

How PAQR Can Help

If you are the manufacturer for your flexible transport packaging, the Declaration of Conformity and its supporting technical files are your responsibility to produce and retain. PAQR’s PPWR compliance workspace gives you a central place to organise your packaging data by format, collect the material documentation you need from your film and strapping suppliers through the supplier request portal, and generate your Declaration of Conformity when your technical files are complete.

Click “Try now for free” on paqr.com to start a free trial: