Does the EU packaging regulation (PPWR) cover cosmetics, pharmaceutical and medical-device packaging?

Questions › Category: PPWR › Does the EU packaging regulation (PPWR) cover cosmetics, pharmaceutical and medical-device packaging?
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Team GreenSutra Staff answered on
PPWR for cosmetics, pharma and medical packs: small cosmetic jars and folding cartons on a packing line

Yes. The EU packaging regulation (PPWR) covers packaging for cosmetics, medicines and medical devices, because it applies to all packaging in every sector. What differs is a short list of exemptions: the immediate packaging of medicines, the contact-sensitive packaging of medical devices and some outer medicine packs are spared the recyclability and recycled-content rules. Cosmetics packaging gets no sector exemption.

Which rules do medicine and device packs escape?

Two design rules carve out the same groups:

  • the immediate packaging of human and veterinary medicines;
  • the contact-sensitive packaging of medical devices and in vitro diagnostics;
  • the outer packaging of medicines where it keeps the product’s quality.

These packs are outside the recyclability rules and the plastic recycled-content targets. The labelling relief is narrower. It applies only where there is no space left after other required labels, or where the label could put the safe use of a medicine at risk.

The other main rules still apply to them: the heavy-metal cap for all packaging, the minimisation rules, the empty-space cap and the reuse targets. The Commission’s guidance adds that IV bags and syringes are not packaging at all, even when sold pre-filled.

Why do cosmetics get no exemption?

The regulation defines contact-sensitive packaging by the product inside, and the Cosmetics Regulation is on that list. So cosmetic plastics are not exempt; they simply take the lower contact-sensitive recycled-content rates. Hotel miniatures of shampoo and lotion are a separate matter. Single-use toiletry packaging for one booking is banned in hotels and other accommodation from 1 January 2030, whatever the material (see single-use formats from 2030).

All three are in scope. Only medicine and device packs get exemptions.
All three are in scope. Only medicine and device packs get exemptions.
Point Status on 26 October 2026
Whether a device’s outer pack that never touches the device is contact-sensitive Open, no official answer yet
Recyclability criteria that cosmetics packs must meet Open, due by 1 January 2028

Example: a face cream jar

Example. A cosmetics brand sells face cream in a plastic jar that is not PET. From 2030, or three years after the Commission’s calculation rules if those come later, the jar must contain at least 10% recycled plastic. The same jar holding a product that is not contact-sensitive would need 35%, so the cosmetic jar’s target is 25 points lower. From 2040 the cosmetic rate rises to 25%.

Where this comes from: Regulation (EU) 2025/40, Articles 2(1), 3(1)(49), 5(4), 6(11), 7(1), 7(2), 7(4), 12(11) and Annex V point 5; Commission guidance, OJ C/2026/3084, section 1.

More on this: EU PPWR guide · EU PPWR compliance

Reviewed by Team GreenSutra on 26 October 2026.