The DPP for Cosmetics

Cosmetics sit in an unusual position. The sector is heavily regulated on safety and largely unregulated on circularity, and the obligations now arriving reach it sideways — through packaging and through advertising rules rather than through product ecodesign.

What already exists to build on

Regulation (EC) 1223/2009 requires a product information file for every cosmetic placed on the EU market, held by the responsible person and available to authorities.

That file already contains a great deal of what a passport would want: composition, safety assessment, manufacturing method and evidence for claimed effects. It is a considerably better starting point than most sectors have.

Packaging arrives first

Regulation (EU) 2025/40 on packaging and packaging waste applies to cosmetic packaging like any other, and for a sector where the pack is a large share of both cost and environmental impact, this is the more consequential instrument.

Dispensing systems are the recurring problem. A pump is a small assembly of several polymers and a metal spring, it is functionally necessary, and it makes an otherwise recyclable bottle difficult to process unless the consumer separates it.

Green claims are the enforcement risk

Cosmetics marketing makes more environmental and origin claims per product than almost any other consumer category, which puts the sector directly in the path of Directive (EU) 2024/825.

• Natural and naturally derived — meaningful only against a stated definition and a calculation method.
• Ingredient origin — a specific geographic claim requires chain of custody, not a supplier’s word.
• Refillable — requires refills to actually be available for the product’s market life.
• Recyclable — assessed against the collection reality of the market, not technical possibility.
• Carbon claims — the directive constrains offset-based neutrality claims specifically.

The second is the one that generates the most exposure. A named-origin botanical claim is precisely the kind of assertion that requires traceable evidence, and botanical supply chains typically run through consolidators who blend material from many growers.

Where EUDR touches the sector

Regulation (EU) 2023/1115 covers palm oil and its derivatives, which appear in cosmetics extensively — in surfactants, emulsifiers and emollients that carry chemical names bearing no resemblance to their origin.

This catches formulators who reasonably believed they had no palm exposure. A derivative several reaction steps downstream is still within scope, and establishing whether an ingredient qualifies requires asking the supplier a question most have not been asked before.

What a cosmetic passport should carry

The useful design separates what the consumer needs from what the recycler needs, since they are almost disjoint sets and only one of them is interested in the formulation.

For the consumer: ingredient function in plain language, substantiation behind any claim on the pack, refill availability, and what to do with the empty container in their specific market. For the recycler: pack material by component, separability, and the decoration that affects recyclate quality.

A sensible first step

Build the packaging specification as structured data before anything else. Most brands hold pack details across artwork files, supplier drawings and purchasing records, and none of those is queryable.

A component-level pack record — every part, its polymer, its weight, its decoration and whether it separates — answers packaging reporting, recyclability assessment, fee calculation and the consumer disposal question at once. It is the highest-return data work available to the sector.

Doing this work now also positions the sector for whatever ESPR eventually requires. Regulation (EU) 2024/1781 gives the Commission the power to bring product groups into scope through delegated acts, and cosmetics has not been prioritised in the first working plan.

That is a reason to prepare rather than to wait. The eighteen-month window between a delegated act and its application is short for a sector with thousands of stock keeping units and packaging specifications held largely in artwork files, and the packaging record is the part that transfers regardless of what the act eventually asks for.