AsCo Europe | EU packaging compliance
Understand the requirements. Organise the evidence. Plan the changes to your packaging.
Practical assessment and implementation support for brands, manufacturers, importers and distributors, including cosmetic and personal-care businesses.
Separate legislation. Separately scoped support. PPWR (EU) 2025/40 is not part of the EU Cosmetic Products Regulation (EC) 1223/2009. A CPSR, PIF, CPNP notification or cosmetic Responsible Person appointment does not establish PPWR compliance. Our PPWR services are separately scoped and quoted; they are not automatically included in cosmetics compliance work.
Cosmetic Products Regulation (EC) 1223/2009: governs cosmetic product safety and compliance, including the CPSR, PIF, ingredient and label requirements, EU CPNP notification and Responsible Person duties.
PPWR (EU) 2025/40: governs packaging and packaging waste across sectors. It creates a separate set of applicable packaging requirements, conformity documentation and manufacturer, importer, distributor and producer responsibilities.
Both frameworks can apply to the same packaged cosmetic. A CPSR may consider packaging characteristics and product compatibility, but that is not a PPWR conformity assessment. A PIF, CPNP or UK SCPN notification is not a PPWR declaration, and appointing a cosmetic Responsible Person does not automatically appoint a PPWR authorised representative or fulfil national EPR obligations.
Relevant supplier evidence may support both reviews, but the legal assessments, responsibilities and deliverables remain distinct. PPWR support is a separate service with its own agreed scope, quotation and deliverables.
Sources: European Commission: cosmetics legislation and Regulation (EU) 2025/40 on packaging and packaging waste.
The Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, is the EU framework for packaging and packaging waste. It covers packaging of all materials, whether made in the EU or imported: the container around a product, its outer box and the packaging used to deliver it.
For cosmetic businesses, that means looking beyond the formula to bottles, jars, tubes, pumps, caps, labels, cartons and shipping materials. The applicable duties depend on the packaging, the company's role and the markets supplied. PPWR is EU legislation; Great Britain has its own packaging rules.
Use fewer resources and generate less waste, keep materials in circulation, improve packaging recyclability and increase reuse and recycled plastic content. More consistent rules and clearer sorting information also aim to make the EU market easier to navigate. These objectives do not mean every new requirement starts on the same day.
PPWR entered into force on 11 February 2025 and generally applies from 12 August 2026. The main milestones below are a planning framework, not a single deadline for every pack.
Dates and obligations must be checked against the packaging category, applicable exceptions, transitional provisions and adopted secondary legislation. National EPR registration, reporting and fees also require country-by-country review; an EU-wide framework does not create a single registration for every market.
Timeline basis: PPWR, especially Articles 5-7, 10-12, 15, 44-45 and 71, and the European Commission's implementation guidance.
A commercial product range is not automatically one packaging family. For this review, a packaging family is a practical way of organising sufficiently similar packs and their evidence. The legal reference is the packaging type in Annex VII, not simply a broad material category such as "plastic" or "glass".
The Commission's August 2026 FAQ explains that different bottle sizes containing the same product may share one declaration only where the size difference affects none of the applicable requirements in Articles 5-12. Different packaged products must not simply be swept into one blanket declaration. The grouping rationale and the variants covered need to be documented.
These are example assessment groups, not a legally prescribed list or a finding about any actual product.
A bottle, closure and label can form one packaging unit. The Commission confirms that one assessment and declaration can cover that unit, while including the relevant information on all its components. This does not mean a separate declaration is automatically needed for every attached label or cap.
When to reopen the review: a different product, bottle material or design, colourant, coating, label or adhesive, closure or pump, supplier specification, recycled-content specification, or size/weight change that could affect conformity. These changes trigger a documented check; they do not all automatically demand a new family.
AsCo Europe can build a family register linking each assessed packaging type to its product references, component list, dimensions and weights, supplier evidence, document revision and declaration. The aim is to reuse evidence where justified without overlooking materially different packs.
Legal basis: Article 15(4), Annex VII and Annex VIII. Grouping and component guidance: Commission PPWR FAQ, August 2026, Section XV, questions 2, 5, 10 and 11 (printed pages 52-54). The F1-F6 register is our practical illustration of those principles, not wording from the Regulation.
We turn packaging questions into a defined review, a usable evidence file and a prioritised action plan. Support can be a targeted assessment or a coordinated implementation project, with scope, deliverables, timing and fees agreed before work starts.
Map your packaging portfolio, justified packaging families, supply-chain roles and destination markets. Separate duties that apply now from later requirements and identify the evidence or decisions still missing.
Deliverable: a family register, applicability matrix and prioritised gap report.
Organise component specifications, material and weight data, supplier declarations and available test evidence. Identify what needs clarification before a packaging claim or conformity conclusion can be supported.
Deliverable: an evidence inventory and supplier information request.
Support the preparation or review of the packaging technical file and EU declaration of conformity against applicable requirements. Keep the packaging identification, evidence and document versions aligned.
Deliverable: a structured file, draft documentation and outstanding-action list.
Review packaging choices, recyclability evidence, recycled-content information and artwork readiness. For cosmetics, keep packaging changes aligned with product protection, compatibility and the cosmetic dossier.
Deliverable: documented findings and recommended supplier or artwork changes.
Map country-specific registration and reporting needs, organise packaging data and coordinate follow-up with the relevant schemes or local specialists. Representation, registrations and third-party fees are scoped separately.
Deliverable: a market-by-market responsibility and action tracker.
Translate the findings into owners, deadlines and supplier actions. Review updated evidence and help teams track relevant regulatory developments as agreed within the project.
Deliverable: a phased implementation roadmap and review checkpoints.
Share a product and packaging list, the countries you sell into, your role in the supply chain, pack photographs or artwork, component materials and weights, supplier specifications and any existing EPR arrangements. An initial inventory is enough to discuss the scope; confidential files can follow through an agreed channel.
PPWR support does not replace a cosmetic CPSR, PIF, notification or Responsible Person appointment. A consultant's review is not regulatory approval and does not transfer the manufacturer's or producer's legal duties. Any authorised-representative mandate, laboratory testing or national EPR service must be agreed separately.
Reviewed 10 September 2026. General regulatory information; each packaging system and market requires its own assessment.
