The topic is short and compact
The PPWR applies as of August 2026. From 2030, packaging with less than 70 percent recyclability will no longer be marketable.
From 2030, plastic packaging must contain at least 35 percent post-consumer recyclate, which has mechanical and olfactory consequences.
formulations in refill systems require a challenge test over 28 days according to ISO 11930, because the container is opened repeatedly.
So läuft die Entwicklung bei Labtree
1
Konzeptionierung
2
Bemusterung – Standardmuster in 24 h
3
Individualisierung
4
Prototyping
5
Produktion
White Label 2–3 Monate · Private Label 3–6 Monate · Produktion ab 1.000 Stück
With Regulation (EU) 2025/40, the European Packaging Regulation PPWR, the EU is replacing the previous directive framework with directly applicable law. It entered into force on February 11, 2025, and generally applies from August 12, 2026. This means that the same design requirements apply in all member states, without national implementation.
The decisive date is January 1, 2030. From then on, every packaging placed on the market in the EU must be designed to be recyclable. The assessment is carried out in performance classes from A to E. Packaging with less than 70 percent recyclability falls into class E and may no longer be placed on the market from 2030. From 2038, the threshold will be raised to at least class B.
Applicability since August 12, 2026, directly in all member states.
From January 1, 2030: recyclability mandatory, class E no longer marketable.
From 2038: at least class B, i.e. around 80 percent recyclability.
Maximum 50 percent empty volume for grouped, transport, and e-commerce packaging.
The deadline sounds far off, but it is not: Anyone qualifying packaging materials today commits themselves for several years. How such decisions fit into the schedule is shown in Shorten time-to-market.
The PPWR and its deadlines
With Regulation (EU) 2025/40, the European Packaging Regulation PPWR, the EU is replacing the previous directive framework with directly applicable law. It entered into force on February 11, 2025, and generally applies from August 12, 2026. This means that the same design requirements apply in all member states, without national implementation.
The decisive date is January 1, 2030. From then on, every packaging placed on the market in the EU must be designed to be recyclable. The assessment is carried out in performance classes from A to E. Packaging with less than 70 percent recyclability falls into class E and may no longer be placed on the market from 2030. From 2038, the threshold will be raised to at least class B.
Applicability since August 12, 2026, directly in all member states.
From January 1, 2030: recyclability mandatory, class E no longer marketable.
From 2038: at least class B, i.e. around 80 percent recyclability.
Maximum 50 percent empty volume for grouped, transport, and e-commerce packaging.
The deadline sounds far off, but it is not: Anyone qualifying packaging materials today commits themselves for several years. How such decisions fit into the schedule is shown in Shorten time-to-market.
Post-consumer recyclate: mechanical and optical hurdles
A core element of the PPWR is the minimum quota for post-consumer recycled content. For standard plastic packaging, this will be 35 percent from 2030. However, recyclate behaves differently from virgin material, in a way that is directly relevant to cosmetics.
Polyolefins from household collections have undergone several processing cycles. The polymer chains are shortened, the melt flow index fluctuates, and foreign residues remain. Recycled polyethylene achieves up to 30 percent lower notched impact strength than virgin material, and the resistance to environmental stress cracking drops significantly. In combination with surfactant-containing cleaning products or polar emollient esters, this increases the risk of micro-cracks and leaks.
Lower notched impact strength and poorer environmental stress cracking resistance than virgin material.
Increased risk of micro-cracks with surfactant- and ester-containing formulations.
Gray, yellow, or green cast, which limits light color designs.
Inherent odor that can transfer to sensitive fragrance compositions.
Mono-material: Replacing multi-component dispensers
Classic cosmetics packaging is a mixture of materials. A common lotion pump combines up to six materials: polypropylene housing, polyoxymethylene piston, elastomer seals and a stainless steel spring. In automatic sorting systems, such components are sorted out by near-infrared detection and go into incineration. According to PPWR criteria, they automatically end up in Class E.
The solution lies in mono-material designs. The metal spring is replaced by a leaf spring or a bellows made from the same polymer family, so that the entire unit can run through the mechanical recycling stream without disassembly. Polypropylene offers high chemical resistance and a density of less than 1.0, which allows separation in the sink-float process.
Springless dispensers made from a single polymer family instead of metal-plastic combinations.
Polypropylene with a density of around 0.90 to 0.92, ensuring reliable separation in the washing process.
No manual disassembly required, resulting in a higher recycling class.
Design refilling systems constructively
Refill systems separate the packaging into two functional units: a durable outer housing and a lightweight, recyclable refill cartridge. From a life cycle assessment perspective, the effect is significant, provided the outer housing is actually used over many cycles. The benefit of reuse clearly exceeds the effect of pure material savings.
Technically, the mechanics are decisive. Bayonet locks, magnetic holders, and click systems must maintain their fit over hundreds of changes without widening. Living hinges on tins and pallets are subject to cyclic fatigue. These components must therefore be designed for fatigue strength and not just tested for initial function.
Outer housing designed for multi-year use, inner pod designed for recyclability.
Docking mechanism with a defined fit over hundreds of change cycles.
Test living hinges and snap closures for cyclic fatigue.
What refilling systems mean for the formulation
What is ecologically convincing exacerbates the microbiological situation. A container that is repeatedly opened and refilled by hand is exposed to atmospheric humidity, oxygen, and germs from the application. Even with cartridge systems, product residues at the docking opening can oxidize or contaminate.
Water-based formulations therefore require a preservation system that can cope with repeated introduction. Proof is provided by the challenge test according to ISO 11930: The formulation is specifically inoculated with defined bacterial, yeast, and mold strains, and the germ count is measured after 7, 14, and 28 days. In parallel, the antioxidant system must be strengthened because repeated contact with oxygen quickly depletes individual antioxidants.
Challenge test according to ISO 11930 over 28 days, measured at several points in time.
Design preservation for repeated introduction, not for one-time filling.
Combined fat- and water-soluble antioxidants against repeated contact with oxygen.
Check skin compatibility and stability in the laboratory
Recyclate, mono-material and refill pods bring materials into play whose interaction with the formulation is unknown. Testing is therefore always carried out on the filled final container, not on the bulk and not on a substitute sample.
Accelerated storage runs for twelve weeks at elevated temperatures, usually 37, 40 and 45 degrees Celsius, accompanied by controls at room temperature and at 4 degrees Celsius. This allows a shelf life of about two to three years to be estimated. In addition, freeze-thaw cycles show whether hinges become brittle and seals retain their function. An odor test against a glass control reveals whether the recyclate transfers odor to the product.
Accelerated storage for twelve weeks at 37 to 45 degrees Celsius in the final container.
Freeze-thaw cycles to test hinges, seals and emulsion stability.
Odor test against a glass control to detect transfer from the recyclate.
Checking for bottle collapse, wall softening and weight loss.
The full scope of testing is described in Stability and Safety Testing.
Packaging material that is convincing in a hand-assembled sample can fail on the line. Recycled material has wider dimensional tolerances, different surface friction, and varying shrinkage. Mono-material tubes with thinner walls react differently to ultrasonic and heat sealing tools.
These discrepancies only become apparent at line speed. If the ovality of the bottle neck fluctuates, the capping spindles tilt and tightness is no longer guaranteed. Sustainable plastics also creep more under load, which is why the screw-on torque must be readjusted. These parameters belong in the pilot batch, not in the first series production.
Check neck dimensions and ovality on the actual line before starting series production.
Recalibrate the screw-on torque for recycled materials, as they creep more.
Adjust sealing and welding parameters for thin-walled mono-materials.
How this step can be structured and secured is shown in Scaling via the pilot batch.
More useful links
FAQ
As of when does the PPWR apply to cosmetic packaging?
The European Packaging Regulation PPWR, Regulation (EU) 2025/40, entered into force on 11 February 2025 and generally applies from 12 August 2026. By 1 January 2030, all cosmetic packaging placed on the EU market must be designed to be recyclable and meet the minimum quotas for recycled content.
What do the recycling classes A to E mean?
Packaging is classified into performance classes from A to E based on design-for-recycling criteria. Class E means less than 70 percent recyclability; such packaging may no longer be placed on the market from 2030 onwards. From 2038, at least Class B is required. Mono-material constructions are the most important lever for achieving a higher class.
How much recyclate is prescribed?
For standard plastic packaging, a minimum quota of 35 percent post-consumer recyclate will apply from 2030. Recyclate behaves differently mechanically and optically than virgin material, which is why skin compatibility with the formulation must be proven separately.
Why is the skin compatibility test for recyclate so important?
Recycled polyethylene achieves up to 30 percent lower notched impact strength than virgin material and is more susceptible to stress cracking. In the case of surfactant-containing or ester-rich formulations, this can lead to microcracks and leaks. Additionally, the color cast and inherent odor of the recyclate can affect the product.
What is changing in the formulation for refill systems?
The container is repeatedly opened and filled by hand, which introduces humidity, oxygen, and germs. The preservation system must withstand this repeated introduction, which is verified by a preservation efficacy test according to ISO 11930 over 28 days. In addition, the antioxidant system must be strengthened.
How does the stability testing process work for sustainable packaging?
The filled final packaging is stored for twelve weeks at an elevated temperature, typically at 37, 40, and 45 degrees Celsius, with controls at room temperature and at 4 degrees Celsius. The test is supplemented by freeze-thaw cycles and an odor test compared against a glass control.
