Adopted on April 24, 2024, the EU Packaging Directive, formally known as the "Directive on Packaging and Packaging Waste"sets a new standard for a greener cosmetics industry. This directive emphasizes the need for sustainability and is a catalyst for significant changes that will drive our industry towards a more circular economy globally. The fact that the EU is driving the green transition also emphasizes the lack of willingness to change and important expertise locally.
In short, this is what affects our industry
Requirements for increased content of recycled materials in packaging.
Specific target percentages of recycled content to be reached within specific deadlines.
Packaging must be designed so that it is easier to recycle.
Reduction of complex material combinations that are difficult to recycle.
Clear labeling on packaging that informs about correct disposal and recyclability.
Inclusion of information on the proportion of recycled materials used in production.
Implementation of systems to track the origin and lifecycle of packaging materials,
Requirements for reporting the use of recycled materials.
Packages, especially those under 50 ml, must be designed to be refillable.
Encouragement to establish refill stations and offer refill packages.
Encouraging the adoption of practices that reduce environmental impact beyond just packaging, such as reducing the carbon footprint of manufacturing processes.
Increased Use of Recycled Materials
From 2025, all cosmetics packaging must contain a minimum proportion of recycled materials. This proportion will gradually increase, with the first target set at 30% recycled content in plastic packaging in 2025and further increases are planned for the future (see table below).
Design for Recycling
The directive obliges manufacturers to design for recycling, which requires innovation and creative thinking. By simplifying the use of materials in our packaging, we ensure that it can be easily disassembled and recycled, reducing waste and increasing recycling.
Marking for Recycling
To ensure that consumers are informed and can contribute to circularity, the directive also involves clear and informative labeling of packaging. There is currently no harmonized system for symbols, in Norway we rely on Sortere.no and countries such as France and Italy have other symbols. This causes greater problems in international trade, but harmonization within the Union is expected. By including recycling symbols and information about recycled content, we make it easier for the consumer to take part in the recycling process.
The goal is to close the circle so that new packaging comes from recycled material and used packaging ends up back in source sorting. It is hoped that this circle will be as good as closed by 2030, and given that cosmetics products have a shelf life of 3-4 years, it is only a matter of time.
Traceability and Transparency
Implementation of traceability systems is necessary to document the use of recycled materials and the life cycle of the packaging. It is expected that a producer responsibility for the packaging will be established. For producers in Norway who import goods from outside Europe, it is particularly important to be aware that they are responsible for ensuring that these rules are followed, which requires increased transparency and cooperation across national borders. Today, producer responsibility is handled through Grønt Punkt Norge.
Refill solutions
Finally, from 2026, all cosmetic products under 50 ml must be designed to be refillable, a rule that encourages repeated use of the durable containers and further reduces waste. We are encouraged to provide in-store refill stations and sell refill packs, which is a convenient and hygienic solution for consumers. It will be incredibly exciting to see the next few years and how this change unfolds in stores. It will probably be particularly challenging for the ampoule market and disposable products.
Origin of the product
Furthermore, I believe that the industry should change to consider the origin of the whole product and not just the formulation. Many follow the ISO 16128 standard on natural origin, but it's important that the whole product and not just the formulation is included in this assessment to provide a more holistic view.