PPWR Is Already in Force. What Changes for a Bottle Buyer This Year?
By Joe Joo · 8PCK · Shantou
Regulation (EU) 2025/40 has applied since 12 August 2026. The deadlines that matter for cosmetic packaging are not the ones in the news — they are the design and labelling dates just behind them.
What Changed
Regulation (EU) 2025/40 on packaging and packaging waste — PPWR — has applied since 12 August 2026. It replaced the old directive, which means it applies directly in every member state rather than waiting for national transposition. For a brand selling into the EU, the practical effect is that packaging is now a compliance item on the same list as the formula.
The dates that matter are staggered. Minimum recyclability and design-for-recycling requirements come in later this decade, and the Commission is still working through the delegated acts that define how they are measured — including, as reported this month, rules for bioplastics. Harmonised labelling on the pack follows on its own timeline.
What It Means for Buyers
What that means for a bottle order placed now: the pack you design in 2026 is likely to be on shelf when the design rules bite. A mono-material PET or HDPE bottle with a compatible closure is the low-risk shape. A bottle with a metallised sleeve, a black carbon pigment or a glued-on base is the one that will need rework.
Three questions worth asking a supplier before the next order. Is the body mono-material, and is the closure separable? Is the decoration compatible with the recycling stream the pack will enter — wash-off label, or direct print? And can they give you the material and additive declaration in writing, because your customer will ask for it.
What to Ask a Supplier
None of this requires a new mould today. It requires knowing which of your packs would fail a design review, and replacing those on the next tooling cycle rather than the one after.
For an importer, the useful next step is a one-page audit per SKU: material, closure, decoration, and whether the pack can be separated by a consumer in five seconds. That is the level the rules operate at — not the chemistry of the resin, but whether the pack comes apart.
We are asking the same three questions of our own range this quarter, and will publish which stock bottles pass and which need a change before the next run.