Cosmetics & packaging
The pack is the regulated object
PPWR sets recyclability grades and recycled-content thresholds for the container, not the formulation. Substantiating either means knowing what every pack component is made of — and being able to show who said so.
- Instrument
- PPWR (EU) 2025/40
- Applies
- Phased
- Object
- The packaging
GS1 Digital Link
id.circuleid.com/01/09506000134352
- Product
- Merino Crew Knit
- GTIN
- 09506000134352
- Material composition
- 82% RWS merino · 18% recycled PA
- Carbon footprint
- 14.2 kg CO₂e · ISO 14067
- Recycled content
- 18.4% by mass
- End-of-life route
- Take-back · fibre-to-fibre
Illustrative passport record. Field coverage follows the ESPR delegated act for the product group.
Definition
What does a cosmetics Digital Product Passport cover?
A cosmetics passport records the packaging composition, recyclability grade and recycled content required by the Packaging and Packaging Waste Regulation, alongside ingredient and allergen information, sourcing certifications, and refill or return eligibility. It resolves from a QR code on a pack too small to carry the information as printed text.
The ESPR provides the passport framework; PPWR (EU) 2025/40 supplies most of the substantive requirements for this category. The practical consequence is that your converter, not your formulator, holds the data that decides compliance.
Pack components
A pack is four regulated objects in a trench coat
| Component | What decides its grade | Who holds the evidence |
|---|---|---|
| Primary container | Polymer or glass type, colourant, barrier layers | The converter |
| Closure and pump | Material mix, metal springs, separability from the container | The component supplier |
| Label and adhesive | Substrate, ink and whether the adhesive releases in washing | The label printer |
| Decoration | Metallisation, sleeves and coatings that defeat sorting | The decorator |
| Secondary packaging | Fibre source, recycled content, recyclability | The carton supplier |
Capabilities
What the platform handles
Component-level packaging data
Container, closure, label and carton each carry their own composition and recycled-content evidence.
Recyclability grading
Assess the assembled pack against design-for-recycling criteria and see which component pulls the grade down.
Signed supplier claims
Converters and resin suppliers assert recycled content themselves, so a claim carries its author.
Ingredient transparency
INCI listings, allergens and sourcing certifications at full length, resolved from a pack with no room to print them.
Refill and return
Item-level container identity with a recorded cycle count, so refill works outside your own stores.
Formulation links
Batch identity ties a pack to its filled formulation for recall and traceability, without publishing the formula.
Implementation
Start at the converter, not the brand
- 01
Decompose the pack
Model container, closure, label, decoration and carton as separate components. Recyclability is assessed on the assembly, evidenced per part.
- 02
Onboard converters
Component suppliers submit and sign composition and recycled-content figures, which is what makes the claim defensible.
- 03
Grade and fix
The pack is scored against design-for-recycling criteria and the failing component is named, before tooling is committed.
- 04
Publish to the shelf
A QR on the pack resolves to ingredients, sourcing and recycling guidance in the reader’s language, with no app.
Answers
Frequently asked questions
Does a cosmetic product itself need a passport?
Usually the packaging is the regulated object rather than the formulation. The Packaging and Packaging Waste Regulation (EU) 2025/40 sets recyclability and recycled-content requirements for the pack, while cosmetic formulations are governed separately by Regulation (EC) 1223/2009. A passport is most valuable where those two meet — at the item a consumer holds.
What does PPWR require of a beauty pack?
Packaging must be designed for recycling against defined performance grades, and must contain minimum recycled content by material type, with both phased over time. Empty space is limited, and certain single-use formats are restricted. Substantiating any of it requires knowing what each pack component is made of, which is exactly what most brands cannot currently evidence.
How does this support refill and return schemes?
A refill scheme needs to know a container is genuine, refillable, and how many cycles it has completed. Item-level identity on the container gives you all three, recorded as events rather than inferred. Without it, refill programmes rely on trust at the counter, which limits them to owned retail.
Can a passport carry ingredient information?
Yes, and it removes the constraint that the pack is too small for the label. INCI listings, allergen information, sourcing claims and certifications resolve from a QR code at whatever length they need, in whatever language the reader’s device asks for, without shrinking the type on a 30 millilitre bottle.
Who verifies a recycled-content claim?
The converter or resin supplier that knows it. In CirculeID that party issues the claim as a Verifiable Credential signed with its own key, so the brand can show a market surveillance authority who asserted the figure and when. A brand-level self-declaration with no upstream evidence is what these regimes are designed to catch.
Next step
Grade one pack
Send us the component specification for a single SKU. We will show you its recyclability grade, its recycled-content evidence, and what is missing.