Cosmetics and EPR: Packaging Compliance for Beauty Brands Selling in the EU

A standard cosmetics product involves more discrete packaging components than almost any other consumer category. Consider a face serum: a glass dropper bottle, an aluminium collar, a glass pipette, a PP pump cap, a paper label, an outer cardboard carton with a spot UV coating, and a tissue paper wrap inside that carton. That is six or seven separate packaging components, potentially across four different material categories, each carrying a different EPR fee rate.

Multiply that across a catalog of 30 SKUs selling to 8 EU countries, and the scope of the compliance exercise becomes clear. Beauty brands that have not built structured packaging Bills of Materials are almost certainly mis-declaring their EPR obligations — either under-reporting by ignoring secondary components, or misclassifying composite materials.

This guide is specifically for cosmetics and personal care brands. It covers how to classify beauty packaging, which materials attract the highest fees, and how to structure your EPR declarations accurately under the PPWR.

The typical cosmetics packaging stack

Before getting into fee rates and classifications, it helps to be precise about what "cosmetics packaging" typically means at each level.

Primary packaging

Primary packaging directly contains the cosmetic product. For beauty brands, this is enormously varied: glass bottles and jars, aluminium tubes, HDPE and PET bottles, PP or ABS rigid containers, PP or PE pump dispensers, flexible PE or PET laminated tubes, tin compacts, acrylic jars. Each of these is a separate material category for EPR purposes.

Critically, functional components that are integral to the primary packaging must also be declared. The pump mechanism on a lotion dispenser is part of the primary packaging. The dip tube inside a spray bottle is part of the primary packaging. If these are different materials from the main container, they need separate material entries in your BOM.

Secondary packaging

Most cosmetics products ship in an outer carton — the printed cardboard box that surrounds the primary container. This is secondary packaging. Paper labels, tissue paper inserts, paper instruction leaflets, and the cardboard shipping mailer that your D2C orders ship in are also secondary packaging.

The outer carton complication

There is a nuance specific to beauty brands that sell both D2C and through retail channels. When you sell through a retailer, the outer carton may be removed at the store. In that case, the retailer takes on the secondary packaging obligation for units sold through their channel. When you sell D2C, the outer carton reaches the consumer and remains your obligation. Brands selling through both channels must split their declaration quantities accordingly.

Material classification for cosmetics packaging

The following table shows how common cosmetics packaging materials map to EPR material categories and approximate fee rates across the major EU markets. These are indicative 2026 rates — actual rates depend on PRO contract terms, polymer sub-classification, and eco-modulation adjustments.

The data shows why glass is a relatively low-cost primary packaging material for EPR purposes despite its weight. A 100g glass jar costs roughly €0.002–0.003 in EPR fees per unit in most markets. A comparable HDPE jar at 25g would cost €0.027–0.028 in Germany — almost ten times more per unit in absolute fee terms for less physical weight, because the per-kilogram plastic rate is so much higher.

Worked example: a moisturiser in a glass jar

A 50ml face moisturiser sold D2C with the following packaging:

• Glass jar (50ml): 65g glass
• Aluminium lid: 8g aluminium
• Paper label (self-adhesive): 2g paper
• Cardboard outer carton (printed, 4-colour): 25g cardboard
• Paper leaflet inside carton: 5g paper
• Corrugated mailer box (e-commerce shipper): 180g cardboard
• Tissue paper wrap: 12g paper

BOM totals per unit: 65g glass, 8g aluminium, 224g paper/cardboard.

Annual sales to France: 5,000 units.

France CITEO fees: (325 kg glass × €0.022) + (40 kg aluminium × €0.052) + (1,120 kg paper × €0.057) = €7.15 + €2.08 + €63.84 = approximately €73 per year for France at this volume.

The same product at 50,000 units per year costs approximately €730 for France alone — still modest in absolute terms, but the data infrastructure required to produce accurate declarations is the same regardless of volume.

Pump dispensers: the most commonly mis-declared component

Pump dispensers are a source of systematic error in cosmetics EPR declarations. The pump assembly on a 200ml lotion bottle might weigh 15–25g and contain three or four different materials: a PP pump head, a PE dip tube, a metal spring, and sometimes a small stainless steel ball. Most brands declare the entire bottle including the pump as a single plastic component. This is inaccurate.

The practical approach is to treat the entire pump assembly as the dominant material (PP or the overall plastic fraction) unless the metal spring is significant enough to warrant separate declaration. For most pumps, the metal spring weighs under 1g and can be classified under the "other metals" category or treated as a negligible fraction. The PP pump head and PE dip tube should be included in your plastic weight total for the unit.

For disassembled pump bottles — where the pump and bottle can be separated — some PROs treat the components more favorably under eco-modulation because the packaging is designed for material separation at end of life. Check your PRO's eco-modulation rules for disassembly credit.

Eco-modulation and beauty packaging

Cosmetics packaging tends to score poorly on eco-modulation assessments because the category has historically prioritized aesthetics over recyclability. Opaque black plastic, multi-layer metallized tubes, mixed glass-plastic assemblies, and spot UV coatings on cartons all attract eco-modulation penalties at most major PROs.

The most common penalties in beauty packaging:

• Opaque or black plastic: Non-detectable by NIR sorting equipment. Germany's dual systems and France's CITEO apply surcharges of 20–50% on opaque and black plastic. Switching to natural HDPE or clear PET eliminates this penalty.
• Metallized flexible tubes: Aluminium-barrier laminates in cosmetic tubes are typically classified as non-recyclable composite material. The eco-modulation penalty reflects this. ABL (aluminium barrier laminates) tubes carry higher fees than equivalent mono-material PE or PP tubes.
• Spot UV and holographic coatings on cartons: Some PROs assess penalties for heavy coatings on cardboard if they contaminate the paper recycling stream. Check your PRO's specific guidance for coated paperboard.
• Multi-material assemblies that cannot be disassembled: A glass bottle permanently bonded to a plastic sleeve is harder to recycle than a pure glass bottle. PROs may classify the assembly as composite rather than glass, increasing the effective fee rate.

For a detailed guide on how to use eco-modulation to reduce fees through packaging redesign, see our eco-modulation optimization guide.

Glass-specific PRO registrations

Beauty brands using glass packaging — bottles, jars, vials — need to be aware that two major EU markets route glass declarations through a separate PRO:

• Spain: Glass packaging is reported to ECOVIDRIO, not ECOEMBES. You need two separate registrations if your products use both glass and non-glass packaging.
• Italy: Glass is handled by CO.RE.VE, one of the CONAI material-specific consortia. You must register with CO.RE.VE separately from your general CONAI registration.

Germany, France, the Netherlands, and most other EU countries route glass through the general household packaging PRO — no separate registration required. But Spain and Italy will catch brands that assume a single PRO registration covers everything.

Building your cosmetics packaging BOM

For a practical walkthrough of constructing a packaging Bill of Materials, see our packaging BOM guide. For cosmetics specifically, the additional steps beyond a standard BOM are:

• Weigh each sub-component of multi-piece assemblies (bottle body, pump, cap, collar) separately.
• Identify and record the specific polymer type for every plastic component — PP, PE, PET, HDPE — as Germany in particular has polymer-level subcategories.
• Classify whether your outer carton is coated or uncoated — this affects eco-modulation.
• Distinguish between D2C and wholesale/retail channel for each SKU, as secondary packaging attribution differs.
• If any glass packaging is included, note it separately and ensure you have glass-PRO registrations in Spain and Italy.

Tools like Pack Declare store your BOM data per SKU and automatically apply it to your order data when calculating country-level declarations, eliminating the need to manually multiply component weights by order volumes for each reporting period.

Frequently asked questions

Does a plastic pump dispenser count as separate packaging for EPR purposes?

Yes. A pump dispenser attached to a bottle is an integral component of the primary packaging and must be declared separately if it is made from a different material than the bottle. A HDPE bottle with a PP pump and a metal spring inside the pump mechanism should have each material fraction declared. In practice, the metal spring weight is negligible (under 1g), but the PP pump head can weigh 8–15g and should be declared as plastic.

How do I classify a glass jar with a metal lid for EPR?

The glass jar and the metal lid are declared as separate material components. The glass jar is declared under glass (routed to the glass-specific PRO in Spain and Italy). The metal lid — typically tinplate steel or aluminium — is declared under the relevant metals category. In France, both are declared to CITEO. In Germany, each material is declared to your contracted dual system. Weigh each component separately.

Are cosmetic samples and sachets subject to EPR?

Yes. Samples, sachets, and miniatures are packaging that reaches end consumers and must be declared. The fact that they are promotional or given away free does not create an EPR exemption. The obligation is triggered by placing packaging on the market, not by selling it. Sachets are typically multi-layer flexible plastic and attract the plastic rate with eco-modulation penalties for low recyclability.

Do outer cartons count for EPR if they are removed at retail?

If outer cartons are removed at a retail location before reaching the consumer, the retailer takes on the secondary packaging obligation for units sold through their channel. However, if you sell D2C and the carton reaches the consumer's home, it is your obligation. For brands selling through both channels, split your declaration quantities accordingly.

What is the EPR impact of switching from a glass bottle to an aluminium bottle?

Switching from glass to aluminium typically increases your per-unit EPR fee rate in most EU markets, because aluminium carries a higher per-kilogram rate than glass. However, aluminium bottles weigh significantly less than equivalent glass bottles, so the total weight declared per unit drops substantially. A 100ml glass bottle might weigh 90g, while an equivalent aluminium bottle weighs 15–20g. Despite the higher per-kg rate, the lower weight often results in a lower total fee per unit. Read the full analysis in our EPR fees explained guide. For how material choices affect recyclability scores — which directly influence eco-modulation rates — see recyclability grades under PPWR.