ESPR, Digital Product Passports and PPWR for Cosmetics
Core Thesis
For cosmetics companies, ESPR, Digital Product Passports and PPWR will not replace the established Cosmetics Regulation. They will add a new sustainability, circularity, data and packaging layer to an already demanding product-safety framework. The strategic challenge is to connect formulation safety, responsible-person obligations, sustainability metrics, packaging evidence and digital product information into one governed operating model.
Executive Summary
The EU cosmetics sector already operates under a mature product-safety framework. Regulation (EC) No 1223/2009 harmonises the rules for cosmetic products in the Union, aims to ensure a high level of human-health protection and includes obligations relating to responsible persons, safety assessment, product information files, notification, labelling and ingredient restrictions. [4]
The next regulatory wave adds a broader sustainability and transparency dimension. Regulation (EU) 2024/1781, the Ecodesign for Sustainable Products Regulation, establishes a framework for setting ecodesign requirements for sustainable products and provides the legal basis for future Digital Product Passports. The European Commission describes the Digital Product Passport as a digital identity card for products, components and materials that supports sustainability, circularity and legal compliance. [1][2]
In parallel, Regulation (EU) 2025/40 on packaging and packaging waste applies to packaging placed on the EU market and introduces lifecycle requirements for packaging design, waste prevention, recyclability, reuse, recycled content, labelling and technical documentation. For cosmetics companies, this affects primary, secondary, e-commerce, refill and transport packaging. [3]
Executive insight
The cosmetics industry will need to manage two compliance systems at once: a safety-led cosmetic product framework and a sustainability-led product and packaging transparency framework. The most resilient companies will integrate both across formulation, claims, packaging, supplier governance and digital data systems.