Cosmetics Europe welcomes the European Parliament’s formal adoption of the provisional agreement on PPWR

The European cosmetics industry fully supports the objectives of the revision of the PPWR to harmonise the Single Market rules on packaging and move towards more sustainable packaging.

Cosmetics Europe welcomes many of the new provisions of the PPWR including the packaging minimisation measures adopted which require manufacturers to reduce the amount of packaging material used in products. We appreciate that these measures allow flexibility in design and shape of packaging and make it possible for the packaging to fulfil its key functions including protecting the product, facilitating its application and differentiating products from each other.

Moreover, Cosmetics Europe welcomes that information about the packaging of products, (e.g. on composition of packaging material, packaging reusability, or minimum recycled plastic content) can be accessed digitally instead of on-pack for small products’ packaging. This measure is important for small cosmetic products and will help to minimise packaging and contribute to the waste reduction objectives.

However, Cosmetics Europe remains concerned about a number of elements included in the agreements. While Cosmetics Europe welcomes the improvements to harmonise the Single Market rules on packaging to ensure its free movement across the European Union, these rules do not provide full harmonisation across all Member States. In fact, Member States are still allowed to maintain or adopt specific national measures, and this can limit the free circulation of packaging in the Single Market.

Cosmetics Europe appreciates that according to the adopted measures, EU standardisation bodies will need to develop a harmonised methodology to measure the compliance of packaging minimisation requirements. However, we are greatly disappointed that these rules also allow EU standardisation bodies to set up new packaging obligations (standardised maximum weight and volume limits) for ‘‘most common packaging types and formats’’. These obligations would reduce companies’ creative freedom when designing their packaging and ultimately their ability to differentiate their product’s packaging from their competitors.

Cosmetics Europe is also disappointed that the final text of the PPWR bans all single use hotel cosmetic product packaging regardless of their volume. This type of packaging is mostly used in hotels for hygiene reasons to ensure products are not shared among multiple guests. These new measures might stop guests from using certain cosmetics, for example toothpaste. If toothpaste is provided in reusable/refillable packaging and shared among multiple guests, it may be that for hygiene reasons, guests will refrain from using the product completely.

Lastly, Cosmetics Europe is concerned about the feasibility of the implementation of rules on minimum post-consumer recycled (PCR) plastic content in the packaging of products. The amount of PCR content to be used will be calculated “by manufacturing plant’’. However, many small manufacturing plants focus on producing certain types of plastic packaging in which for hygiene, safety and functional reasons, the minimum PCR content required cannot be incorporated. Therefore, these manufacturers may not be able to comply with the rules. This is the case for manufacturers that make the pumps of fragrance bottles.

We look forward to the Council of the EU’s approval of the provisional agreement in autumn and continuing our dialogue on the implementation of the PPWR with EU legislators.

We also look forward to receiving guidance from the European Commission on aspects of the text which need further clarification to ensure a smooth implementation of the regulation.

Read more:

Cosmetics Europe reacts to the Council’s General Approach on PPWR

Packaging and Packaging Waste Regulation: Cosmetics Europe’s recommendations for the Council’s General Approach

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Cosmetics Europe is the European trade association for the cosmetics and personal care industry. Our members include cosmetics and personal care manufacturers as well as associations representing our industry at national level, right across Europe.

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