PPWR 2026 for Cosmetics | Private Label & White Label

PPWR 2026 for Cosmetics – EU Packaging Regulation for Private Label and White Label Brands

PPWR 2026 for Cosmetics – What White Label & Private Label Brands Need to Know

The new EU Packaging Regulation (PPWR) also affects cosmetic products. For brands, private label customers, importers and international companies, this means that not only the cosmetic product itself must comply with legal requirements – packaging is also subject to significantly clearer requirements regarding conformity, documentation, labelling and responsibilities.

At BioCosmetics Germany, our work therefore does not end with product development, manufacturing and filling.

We monitor regulatory developments at an early stage and inform our customers about changes that may be relevant to their products or packaging.

This can be particularly important for larger projects and for companies outside the EU, helping to avoid costly mistakes before production even begins.

What Is the PPWR?

PPWR stands for Packaging and Packaging Waste Regulation.

It refers to the new Regulation (EU) 2025/40 on packaging and packaging waste. It entered into force on 11 February 2025 and generally applies from 12 August 2026.

The PPWR establishes more harmonised requirements for packaging throughout the European Union and generally applies to packaging regardless of the material from which it is made.

For cosmetics, this can include:

  • bottles
  • jars
  • airless dispensers
  • tubes
  • pumps and closures
  • dropper packaging
  • folding cartons and boxes
  • secondary packaging
  • transport and shipping packaging

Why Does the PPWR Affect Cosmetics Brands?

Cosmetic packaging is no longer simply a container for a product.

Depending on the type of packaging and its intended use, various PPWR requirements may need to be considered, including:

  • material composition
  • minimisation of unnecessary packaging
  • recyclability
  • certain substance restrictions
  • recycled content in certain plastic packaging
  • labelling
  • traceability
  • technical documentation
  • conformity assessment

Not all of these requirements apply from the same date, and not every requirement applies to every type of packaging.

Packaging should therefore always be assessed in relation to the specific product, material, supplier and intended market.

Why Is This Particularly Important for White Label and Private Label?

Several companies are often involved in a private label project.

The customer may own the brand.

BioCosmetics Germany develops and manufactures the cosmetic product.

A packaging manufacturer produces bottles, jars, airless dispensers or closures.

Another supplier may produce folding cartons or labels.

This makes one question particularly important:

Who is responsible for which obligations under the PPWR?

The answer is not automatically the company that manufactures the cream or fills the product.

Who Is the Manufacturer in a Private Label Project?

The PPWR uses different terms and roles such as manufacturer, supplier, importer, distributor and producer. These roles should not be confused with one another.

As a general principle:

If a company has packaging or a packaged product designed or manufactured under its own name or trademark, that company may be considered the manufacturer under the PPWR.

A typical example:

A customer commissions BioCosmetics Germany to manufacture a face cream.

The finished product is sold under the customer’s brand.

In this situation, the brand owner or contracting customer may generally be considered the manufacturer within the meaning of the PPWR.

However, the PPWR contains specific provisions for micro-enterprises. The exact allocation of roles must therefore always be assessed for the individual project.

What Does This Mean for the EU Declaration of Conformity?

The PPWR provides for a conformity assessment procedure for packaging.

Once compliance with the applicable requirements has been demonstrated, the manufacturer must draw up an EU Declaration of Conformity.

This is not simply a matter of signing a form.

The declaration must be based on the appropriate technical documentation and assessment of the packaging.

Under Article 15 of the PPWR, the manufacturer is responsible for ensuring that only compliant packaging is placed on the market.

Who Signs in Our Private Label Projects?

This depends on who is considered the manufacturer under the PPWR in the specific project.

For a product developed and manufactured under our customer’s own brand, this may generally be our customer or the brand owner.

BioCosmetics Germany does not automatically sign a PPWR Declaration of Conformity on behalf of the brand owner.

Our role is to inform our customers about relevant requirements at an early stage, record relevant packaging information and – where this forms part of our project – provide the required supplier documentation in a structured manner.

Legal responsibility remains with the person or company to whom the respective obligation is assigned under the PPWR.

Why Technical Documentation Is Becoming Essential

Packaging must be documented in a traceable manner.

Depending on the packaging, relevant information may include:

  • manufacturer or supplier of the packaging
  • article and packaging identification
  • material type and material structure
  • weight of individual packaging components
  • technical specifications
  • information on recyclability
  • information on materials contained
  • test reports, where required
  • applicable standards or technical specifications
  • traceability information

The PPWR also requires packaging suppliers to provide the manufacturer with the information and documentation needed to demonstrate the conformity of the packaging and packaging materials.

What Do Our Customers Receive from BioCosmetics Germany?

Our approach is not simply to manufacture a product and hand it over to the customer.

We aim to identify regulatory risks before they become a problem.

For this reason, our White Label and Private Label projects take into account not only product development and production, but also regulatory requirements relevant to the individual project.

Depending on the project, we can support our customers with:

  • recording the packaging components used
  • documentation of packaging and suppliers
  • assignment of technical packaging documentation
  • traceability of packaging used
  • requesting relevant information from packaging suppliers
  • providing available PPWR-related documentation
  • identifying potentially problematic packaging solutions from a regulatory perspective
  • coordination between product, packaging and intended target market

This does not replace individual legal advice.

However, we consider it part of professional contract manufacturing to inform our customers about relevant regulatory developments in good time.

Particularly Important for Companies Outside the EU

International customers understandably may not always be familiar with European requirements in detail.

A company from the United Arab Emirates, Saudi Arabia, the United Kingdom, the USA or Asia may, for example, select packaging that can be used without difficulty in its domestic market.

However, this does not automatically mean that the same packaging solution is suitable for the European market without further assessment.

In addition to the PPWR, the following may also be relevant:

  • EU Cosmetics Regulation
  • Responsible Person
  • CPNP
  • PIF and safety assessment
  • PPWR
  • packaging labelling
  • import requirements
  • extended producer responsibility
  • national packaging registrations and waste management systems

For this reason, packaging for a new private label product should ideally not be ordered in large quantities before the fundamental regulatory requirements have been clarified.

Responsible Person and PPWR Manufacturer Are Not the Same

One distinction is particularly important:

The Responsible Person under the EU Cosmetics Regulation and the manufacturer under the PPWR are two different regulatory roles.

The Responsible Person is responsible for certain requirements relating to the cosmetic product under Regulation (EC) No 1223/2009.

The PPWR, on the other hand, regulates requirements for packaging and establishes its own responsibilities within the supply chain.

Both roles may be held by the same company.

However, this is not necessarily the case.

In a professional private label project, product compliance and packaging compliance should therefore be considered separately.

Our Understanding of Private Label

We do not see contract manufacturing as production alone.

A product can be perfectly formulated and filled to a high standard – and still cause problems later if packaging, documentation or regulatory requirements have not been considered.

That is why we look at a project as a whole:

Product development. Formulation. Raw materials. Packaging. Documentation. Production. Quality. Regulatory requirements.

Especially with larger production volumes, an unsuitable packaging choice can have significant financial consequences.

Our goal is therefore to identify potential problems as early as possible.

Frequently Asked Questions About PPWR for Cosmetics

What does PPWR mean?
PPWR stands for Packaging and Packaging Waste Regulation. It refers to Regulation (EU) 2025/40 on packaging and packaging waste.
When does the PPWR apply?
The PPWR entered into force on 11 February 2025 and generally applies from 12 August 2026. However, individual requirements are subject to different transitional periods and later application dates.
Does the PPWR also apply to cosmetics?
Yes. Cosmetic products are normally placed on the market in packaging. Bottles, jars, airless dispensers, tubes, droppers, closures, folding cartons and other packaging components may therefore be affected by the requirements.
Does the PPWR apply to White Label and Private Label?
Yes. Particularly in White Label and Private Label projects, it is important to determine which company within the supply chain has which role under the PPWR and who is considered the manufacturer.
Is the contract manufacturer automatically responsible?
No. Where a product is designed or manufactured under the name or trademark of the contracting customer, the brand owner or contracting customer may generally be considered the manufacturer. Specific provisions apply to certain micro-enterprises.
Who signs the PPWR Declaration of Conformity?
The EU Declaration of Conformity is issued under the responsibility of the manufacturer as determined under the PPWR. In a Private Label project, it must therefore first be established which company actually holds this role.
Is technical documentation required for packaging?
The PPWR provides for technical documentation as part of the conformity assessment. The specific information and evidence required depend on the packaging and the applicable requirements.
Does the packaging supplier have to provide documentation?
Yes. Under Article 16 of the PPWR, suppliers must provide the manufacturer with the information and documentation required to demonstrate the conformity of the packaging and packaging materials.
Is the Responsible Person automatically the PPWR manufacturer?
No. The Responsible Person under the EU Cosmetics Regulation and the manufacturer under the PPWR are different regulatory roles. They may be held by the same company, but this is not necessarily the case.
What happens if the customer supplies their own packaging?
Even in this case, the regulatory roles and conformity of the packaging must be clarified. Customers should therefore provide us with technical information and available documentation for the intended packaging before ordering larger quantities.
Does BioCosmetics Germany support customers with PPWR requirements?
Yes. We monitor regulatory developments and take relevant changes into account in our White Label and Private Label projects. Depending on the project, we support our customers with packaging documentation, supplier documentation, traceability and the structured provision of available PPWR-related information.

Learn more about our Private Label and cosmetics contract manufacturing services

 

Official information on the PPWR can be found from the European Commission and in the Official Journal of the European Union:

European Commission – Packaging and Packaging Waste Regulation

 

Regulation (EU) 2025/40 – PPWR on EUR-Lex

Plan Your Private Label Cosmetics Properly from the Beginning

Would you like to develop and manufacture a cosmetic product under your own brand?

At BioCosmetics Germany, we consider more than formulation, manufacturing and filling. We also take packaging, documentation and relevant regulatory requirements into account during project planning.

This is particularly important for larger production volumes and for companies outside the European Union that intend to place their products on the European market.

Tell us about your project, planned quantity, target market and – if already available – your preferred packaging.

Send Inquiry

Last updated: July 2026. The information on this page is intended to provide general information about regulatory requirements and does not constitute individual legal advice.