The EU PPWR is changing cosmetic packaging rules. The new framework will affect recyclability, recycled content and refill models – and make earlier cross-team alignment increasingly important.
A conversation with Vivien Charrey, Managing Director Beauty, Berlin Packaging EMEA
Beauty brands will need to balance visual appeal with much stricter PPWR requirements on recyclability, packaging minimisation and recycled content
Euro Cosmetics:
What specific impact will the PPWR (Packaging and Packaging Waste Regulation) have on cosmetic primary packaging, particularly on complex formats such as pumps, dispensers and airless systems?
Vivien Charrey:
PPWR will significantly impact beauty packaging, especially complex formats such as pumps, dispensers and airless systems, which often combine multiple materials and components that are difficult to separate. From 2030, all packaging placed on the EU market must meet recyclability requirements, which puts pressure on multi-material designs, metallisation, coatings and very small components that remain difficult to sort and recycle.
At the same time, PPWR introduces strict packaging minimisation and recycled-content requirements. Beauty brands will need to reduce unnecessary components and empty space while maintaining product safety, hygiene and functionality. For complex systems such as pumps and airless packaging, integrating PCR without affecting performance or compatibility will require substantial redesign.
Euro Cosmetics:
The PPWR strengthens requirements around recycled content and material transparency. How prepared is the cosmetics industry to provide accurate data on PCR levels, material combinations and supply-chain traceability?
Vivien Charrey:
The cosmetics industry is making progress, but full readiness is still a work in progress. The main challenge is that cosmetics packaging must meet strict quality, safety and compatibility standards, which limits the range of PCR materials that can be used. In addition, the supply of high-purity, cosmetically suitable PCR remains limited.
Traceability is also complex at component level, especially for formats such as pumps that combine plastics, metals and elastomers. This makes it harder to quantify PCR content accurately and provide full material breakdowns across the supply chain. As a result, many companies are still building the data systems, supplier documentation processes and internal capabilities needed to meet PPWR requirements reliably.
Euro Cosmetics:
Refill and reuse models are gaining relevance in the cosmetics sector. What technical and regulatory challenges do you foresee regarding product safety, shelf life and consumer expectations?
Vivien Charrey:
Refill and reuse models are gaining traction in cosmetics, but they come with significant technical and regulatory challenges, especially around product safety, shelf life and consumer acceptance.
From a product safety and shelflife perspective, reuse systems must guarantee that formulas remain safe and stable across multiple use and refill cycles. This requires robust packaging design (e.g., resistance to repeated opening and closing, protection from contamination), strict hygiene protocols, and a clear definition of the maximum number of reuses or refill cycles.
In this context, in 2025 at Berlin Packaging we introduced FUTURefill, an innovative recharge system designed to redefine sustainable beauty packaging for skincare and makeup emulsions. The system is engineered to prevent the standalone use of the refill, ensuring the continued use of its most technical and complex components, particularly the pump. By preserving the integrity of the dispensing system, FUTURefill helps extend product life, maintain safety and performance over time, and significantly reduce single-use waste, while fully addressing hygiene and shelf-life requirements.
Regarding consumer expectations, refill and reuse systems must be convenient, intuitive and aligned with the premium experience that many beauty consumers expect. Different reuse models (refill at home, refill in store, and return and refill systems) require different levels of consumer engagement: their success also depends on how consumers behave, with differences that vary significantly across countries, age groups and product categories (e.g., skincare and haircare show higher adoption potential, while makeup and fragrances face greater technical and behavioural barriers). As a result, not all consumers are ready to adopt these models at the same pace, and brands must tailor their strategies accordingly.
In summary, while the cosmetics industry is strongly investing in reuse and refill, scaling these models will require continued innovation in packaging design, safety protocols, data transparency and consumer engagement to meet both regulatory expectations and market demands.
Euro Cosmetics:
Mono-material solutions are a key element of the PPWR. How significantly will this influence the design of cosmetic packaging, especially closures, dispensing components and decorative elements?
Vivien Charrey:
Overall, the PPWR’s emphasis on monomateriality will push the cosmetics industry toward simpler, more modular and more recyclable packaging architectures. Moving toward monomaterial designs will require substantial redesign: eliminating metal springs, reducing the number of polymers used, and ensuring that all components can enter the same recycling stream. Simplifying material combinations is essential to improve recyclability performance.
In response to these challenges, we launched a new generation of metal-free dispensing engines at Paris Packaging Week. They are available in both airless and atmospheric systems. These solutions are specifically designed to support mono-material packaging concepts, simplifying material compatibility while maintaining a refined, precise beauty gesture and a gentle, consistent dosage for fluid skincare and makeup textures.
Euro Cosmetics:
Time-to-market is essential in the cosmetics industry. How will the PPWR reshape development processes, NPD cycles and collaboration between packaging, procurement, brand teams and suppliers?
Vivien Charrey:
PPWR will make cosmetics packaging development more collaborative, data-driven and compliance-led. Packaging decisions can no longer be made in isolation or late in the NPD process; sustainability, regulatory requirements and supply-chain feasibility must be considered from the start.
This will affect time-to-market, as components that were once standard may now require redesign, material validation, compatibility testing and additional documentation. Close collaboration between brand, packaging, procurement and suppliers will therefore be essential to avoid delays. Berlin Packaging is strengthening this cross-functional support by integrating design, technical, procurement and sustainability expertise to help brands manage PPWR-driven complexity from concept to compliance.
Euro Cosmetics: Thank you for the conversation.
Biography
Vivien Charrey joined Berlin Packaging in 2014 and has since held several roles within the company, including CFO and Senior Advisor on Operational Excellence. Appointed General Manager of Berlin Packaging | Premi Industries in 2020, he was named Managing Director Beauty, Berlin Packaging EMEA, in 2024.
