Short answer: EU packaging rules started applying on 12 August 2026 and green-claim rules apply from 27 September 2026 — together they turn a packaging choice into a compliance file with a declaration of conformity, a retained technical dossier and evidence behind every sustainability word on the pack.
For twenty years, cosmetic packaging lived under a directive each member state translated its own way. That is over. A directly applicable packaging regulation now sits across all member states, and it arrived in the same quarter as a consumer-law instrument that restricts what a pack may claim about the environment. The two are separate, and they meet in the same place: your specification sheet.
This is not a sustainability-marketing update. Under the new framework, a pack that cannot be documented is a pack you cannot place on the market — and a claim you cannot evidence is a claim you must remove.
Two rulebooks that land on one decision
The packaging regulation sets design, substance and documentation duties for all packaging placed on the EU market, including primary containers, cartons, e-commerce boxes and transport packaging. The consumer-law instrument sits alongside it and governs communication: what may be said about environmental performance, and what evidence has to exist before it is said.
For a cosmetics brand the practical consequence is that packaging can no longer be specified by the design function alone. It has to be specified with a documented material composition, a declared substance position, a conformity file and a claims review. Four workstreams, one bill of materials.
What is already in force, and what is still ahead
| Date | What applies | What it changes in a cosmetic pack |
|---|---|---|
| 11 February 2025 | The packaging regulation entered into force | Replaces the national implementations of the old packaging directive |
| 12 August 2026 | Regulation applies: recyclability requirements, substance limits, conformity assessment and the EU declaration of conformity | A written declaration per packaging type, plus technical documentation held for 5 years (single-use) or 10 years (reusable) |
| 27 September 2026 | Green-claim rules apply | Generic environmental wording and self-styled labels come off cartons, labels and product names unless substantiated |
| 12 August 2028 | Harmonised material labelling on packaging becomes mandatory | Material composition and sorting guidance converge on one EU format instead of national symbols |
| 1 January 2030 | Design-for-recycling grades, minimum recycled content, empty-space cap, certain single-use formats banned | Multi-material dispensers, full-body sleeves and oversized gift cartons become the redesign queue |
| 1 January 2038 | Only the highest recyclability grades may be placed on the market | Decoration that defeats sorting becomes the constraint on premium finishing |
Two of these are live now, and they are the two most brands have under-read.
The conformity duty is the one with the least marketing visibility and the most legal weight: for each packaging type there is an assessment, a written declaration and a technical file describing the packaging, its components and the standards applied. The documentation retention period is five years for single-use packaging and ten for reusable packaging. Your packaging supplier has to supply the information that file depends on, which changes the supplier relationship from a price negotiation into a documentation partnership.
The substance limits already in force are a separate and older thread: combined lead, cadmium, mercury and hexavalent chromium in packaging or its components are capped at 100 mg/kg, and fluorinated substances are restricted in packaging under the chemicals framework as well as in the cosmetic product itself. A carton is not exempt from either.
The green-claim list that has to come off your cartons
The consumer-law instrument is where most beauty brands will feel this first, because it touches language rather than materials. From 27 September 2026 it restricts, across consumer products including cosmetics:
- Generic environmental claims — "eco-friendly", "green", "sustainable", "planet-friendly" — unless the brand can demonstrate recognised excellent environmental performance rather than simply assert it.
- Claims that attribute a whole-product benefit to one component. Recycled board in the outer carton does not make the product sustainable, and the rules now say so explicitly.
- Carbon-offsetting neutrality claims. Saying a product is climate neutral because credits were purchased is not permissible where it suggests the product itself has a neutral impact.
- Self-styled sustainability labels. A label has to rest on a recognised certification scheme or a public authority's assessment, not on a mark the brand designed.
- Legal requirements presented as selling points. Complying with a legal obligation is not, by itself, a distinguishing benefit.
- Forward-looking commitments — climate neutrality by a future date — unless backed by a plan, measurable targets and independent verification.
Two of these are habits rather than campaigns. "Recyclable" printed on a pack, for example, now has to withstand both the consumer-law test and the packaging regulation's own definition of recyclability, which has two limbs: designed for material recycling, and collectable, sortable and recyclable at scale. The second limb is the harder one and tightens further into the 2030s, so a claim about recyclability is a claim about infrastructure as well as design.
Where the cosmetic pack is hardest
Three components carry most of the difficulty:
Dispensing systems. Pumps, sprayers and droppers combine several polymers with a metal spring, which makes them the least recyclable part of a typical cosmetic pack. Mono-material and spring-free designs exist and continue to improve; the useful decision is to evaluate them on new launches instead of retrofitting a whole range at once.
Sleeves and decoration. A full-body shrink sleeve can make an otherwise sortable bottle unsortable, because optical sorting equipment reads the sleeve rather than the container. Perforated sleeves, floatable materials and direct printing are the usual answers, and each is a design decision with a compliance consequence.
Gift sets and shipping cartons. Empty-space limits apply to grouped, transport and e-commerce packaging, which is precisely the shape most beauty gift sets take. A set built around presentation volume is a set that has to be re-engineered.
Across all three, one number is regularly misread: the 70% packaging-waste recycling rate for 2030 is an obligation on member states, not a target a brand has to hit. Brands are measured through the design-for-recycling grades, the recycled-content minimums and their extended-producer-responsibility registration — separate duties that are easier to plan once the difference is clear.
The counter-intuitive part: refills are not automatically the answer
Refill and reuse are encouraged by the direction of the regulation, and a refill system is often the right answer for a high-repurchase liquid. But a refill is a compliance object in its own right, with its own declaration, its own material composition and its own conformity file — and, commercially, a second component to order against a minimum quantity. A refill that replaces a mono-material bottle with a pouch plus a heavier reusable outer can be the cleaner choice, or a lateral move, depending on the assumptions. The comparison of refillable systems and the rules that shape them sets out where each format fits, and it is worth reading alongside the format trade-offs in our packaging formats guide.
The same caution applies to recycled content. Minimum recycled-content percentages for plastic packaging attach to specific categories and start in 2030, and they are met as an average per manufacturing plant and year rather than per unit. That is planning information for your resin strategy, not a line to print on a carton.
What to change in your next packaging specification
- Add a documentation line to every component. For each pack type, record the material composition, the substance position and who holds the technical file.
- Ask your packaging supplier what they will declare. A supplier who cannot provide component-level material information cannot support the conformity file you now have to keep.
- Audit the words on every pack, carton and label against the claims list above, including product names and any mark the brand designed itself.
- Read every pack against the 2030 grades and the recycled-content categories before tooling is committed, because a mould change is a far longer project than an artwork change.
- Sequence the redesign. Refill systems, mono-material dispensers and decoration changes share a tooling calendar; bundling them into the natural artwork cycle costs less than retrofitting the range.
- Keep the file current. Retention periods of five and ten years mean today's specification is tomorrow's audit evidence.
None of this is optional for the EU market, and it applies to brands based outside the EU as much as to those inside it — a non-EU brand placing packaged cosmetics on the market carries the duties and, where required, appoints an authorised representative. Our Europe & UK market entry pages list the registration and documentation route per market, and packaging questions sit well alongside how to import cosmetics from China when the packaging and the fill are being planned together.
FAQ
Q: Does the EU packaging regulation apply to my cosmetic packaging if I am not based in the EU? A: Yes. It applies to packaging placed on the EU market, whoever places it there, and it covers primary containers, cartons, e-commerce boxes and transport packaging. A brand based outside the EU also appoints an authorised representative where the rules require one.
Q: What documentation does the packaging regulation require right now? A: A conformity assessment per packaging type, a written EU declaration of conformity, and technical documentation describing the packaging, its components, the standards applied and any test reports. Retain it for five years for single-use packaging and ten years for reusable packaging. There is no third-party certification scheme for the regulation itself — it works on internal production control.
Q: Can I still print "eco-friendly" or "recyclable" on a cosmetic carton? A: Generic wording such as "eco-friendly" or "green" is no longer permissible without demonstrating recognised excellent environmental performance, and a label has to rest on a recognised certification scheme or a public authority's assessment. "Recyclable" also has to satisfy the packaging regulation's own definition, which includes collection, sorting and recycling at scale.
Q: Is a refill pack automatically compliant with the new rules? A: No. A refill is a separate packaging type with its own conformity assessment, declaration and technical file, and it is a second component to order against a minimum quantity. Refills are favoured by the direction of the rules and often reduce material use, but each design still has to be documented and assessed on its own terms.