On August 10, 2026, the South Korea Cosmetic Association (KCIA) published the "PPWR Document Preparation Guidelines for the Cosmetics Industry," aimed at helping Korean cosmetics companies respond to the EU Packaging and Packaging Waste Regulation (PPWR) and prepare their Technical Documentation (TD) and EU Declaration of Conformity (DoC).
The guidelines note that, under the PPWR, all packaging placed on the EU market must undergo a conformity assessment against the applicable requirements, and the results must be prepared and retained in the form of a Technical Documentation (TD) and a Declaration of Conformity (DoC). As the majority of the PPWR’s provisions will generally apply from August 12, 2026, the publication of these guidelines comes at a critical juncture for corporate compliance efforts.
Overview of the PPWR and Key Dates
The PPWR (Packaging and Packaging Waste Regulation, i.e., EU Regulation (EU) 2025/40) was formally adopted by the European Parliament and the Council on December 19, 2024, and published in the Official Journal of the European Union on January 22, 2025, replacing the former Packaging and Packaging Waste Directive (PPWD, Directive 94/62/EC). The Regulation entered into force on February 11, 2025, and most of its provisions generally apply from August 12, 2026.
Main Contents of the Guidelines
The guidelines are divided into five main parts:
- Part I: Overview and impact on the cosmetics industry;
- Part II: Core PPWR provisions and response actions for cosmetics companies (article-by-article review of Articles 5–12);
- Part III: Preparation methods for the Technical Documentation (TD) and Declaration of Conformity (DoC), using a skincare tube pack as an example;
- Part IV: References;
- Part V: Annex — worked examples of the Declaration of Conformity and Technical Documentation (skincare tube type) and document templates.
The guidelines mainly cover: the scope of the PPWR and how to define packaging units and components; the article-by-article applicability review and conformity assessment methods for Articles 5–12; item-specific compliance criteria such as recycled content (PCR), recyclability, and heavy metals; the structure of and preparation method for the Technical Documentation (TD); the preparation method and format for the Declaration of Conformity (DoC); and the accompanying TD/DoC document templates.
Core Compliance Points for Cosmetics Companies (Articles 5–12)
1. Article 5-Requirements for substances contained in packaging
Article 5’s obligation to "minimize substances of concern" and the limit requiring the combined concentration of the four heavy metals — lead (Pb), cadmium (Cd), mercury (Hg), and hexavalent chromium (Cr6+) — not to exceed 100 mg/kg apply to all packaging placed on the EU market (sales, grouped, transport, and e-commerce packaging are all included). The PFAS concentration limit under Article 5(5) applies only to packaging intended for food contact, so general cosmetics packaging is not subject to it. It should be noted that the "5% threshold" used to determine composite packaging is not an exemption threshold for substance management: pigments, inks, coatings, and adhesives, even when they account for less than 5%, must still be included in the review.
2. Article 6-Recyclable packaging
All packaging placed on the EU market must meet the "Design for Recycling" (DfR) requirements and obtain a Grade A–C rating, with the recyclability assessment conducted on a per-component basis. The key milestones are: from August 12, 2026, all packaging must be recyclable (until the DfR delegated act is adopted, this may be demonstrated in accordance with the EN 13430:2004 standard); from 2030, the specified grade must be achieved; from 2035, the "recyclable at scale" assessment must be met; and from 2038, only packaging of Grade B or above may be placed on the market. Cosmetics packaging, owing to its extensive use of composite materials, multi-component designs, and surface treatments such as metallic coatings, faces relatively high barriers to recyclability.
3. Article 7-Minimum recycled content for plastic packaging
Plastic packaging placed on the EU market must incorporate recycled content (PCR, Post-Consumer Recycled) at or above a specified ratio. Most cosmetics packaging falls under "contact-sensitive packaging made of plastics other than PET" within the contact-sensitive category, and must meet the corresponding minimum PCR content standard; where the plastic weight of a component accounts for less than 5% of the total weight of the packaging unit, it falls outside the scope of the obligation.
4. Articles 10 and 24-Packaging minimization and overpackaging
Article 10 requires reducing the volume and weight of packaging without compromising its functional safety; Article 24 provides that the empty-space ratio of grouped, transport, and e-commerce packaging shall not exceed a maximum of 50%, and makes clear that cosmetics packaging will also be brought within the scope of setting maximum packaging space-ratio standards over the longer term.
5. Article 11-Reusable packaging
Article 11 sets out the design and performance requirements that "reusable packaging" must meet, rather than mandating that all packaging become reusable. Its concept of "reuse" means that, after the contents are depleted, the same packaging unit is reprocessed and re-supplied for its original purpose and repeated over multiple circulation cycles; being merely "sturdy and durable" or "offering refills" does not, in itself, constitute reusable packaging. For example, in cushion compact refill products, although the outer case is used repeatedly, the absence of a recovery–reprocessing–re-supply circulation system means it does not qualify as reusable packaging within the meaning of this Article.
6. Article 12-Packaging marking
Article 12 requires information such as material composition to be marked on the packaging to help consumers separately collect packaging waste; implementing acts will subsequently introduce a harmonized marking, EPR digital marking, Deposit Return Scheme (DRS) information, and digital marking of substances of concern.
7. Economic operator roles and obligations
The PPWR defines a range of economic operator roles — Manufacturer, Producer (bearing EPR obligations), supplier, importer, distributor, and others. Responsibility for preparing the Declaration of Conformity and Technical Documentation rests with the Manufacturer; importers must collect, verify, and retain the relevant documents, while distributors need only confirm their existence. Under Article 21, an importer or distributor that places packaging on the market under its own name or trademark, or makes changes sufficient to affect conformity, will likewise be deemed to be the Manufacturer and must fulfil the corresponding obligations.
Preparation of the Technical Documentation (TD) and Declaration of Conformity (DoC)
The Technical Documentation (TD) is prepared in accordance with the requirements of PPWR Annex VII, recording the composition and specifications of the packaging, the applicable requirements, the assessment methods, the assessment results, and the supporting evidence, in order to demonstrate the packaging’s conformity. The Declaration of Conformity (DoC), in accordance with Annex VIII, is the Manufacturer’s declaration of conformity for packaging whose compliance with the applicable requirements has been demonstrated through the TD.
The preparation workflow is: define the packaging unit and its components → review the applicable requirements → carry out the conformity assessment → record the results and supporting evidence in the TD → prepare and sign the DoC on that basis → retain the TD and DoC after market placement → re-assess and revise the documents when packaging specifications or applicable standards change. Suppliers must provide information such as packaging materials, structure, weight, drawings, BOMs (bills of materials), test reports, and confirmation data, which the Manufacturer reviews for applicability to the actual packaging specifications; importers and distributors must, before the packaging is placed on the market, confirm that the required documents and markings are in place.
The guidelines particularly emphasize: the DoC is not a certificate issued by a third party, but a declaration of conformity prepared and signed by the Manufacturer itself; supplier test reports and confirmation documents are merely supporting materials for the conformity assessment, and responsibility for the final conformity determination rests with the Manufacturer.
Special Impact on the Cosmetics Industry
The guidelines’ analysis points out that the cosmetics industry faces structural challenges in responding to the PPWR that are more acute than those in other industries: cosmetics packaging has long since evolved beyond a mere content-protection function into a complex system that conveys brand identity, marketing differentiation, and a maximized user experience; numerous brand lines have led to a highly diversified range of packaging materials and forms, with extremely short product replacement cycles; and the luxury and premium beauty markets have habitually employed heterogeneous-material composite packaging, decorative accessories, and multiple layers of packaging to create a sense of luxury.
Consequently, cosmetics companies must simultaneously achieve the twin goals of "packaging minimization" and "recyclable design," which poses an unprecedented challenge to existing complex packaging design driven by sensory value.
CIRS Reminder
1. As the majority of the PPWR’s provisions generally apply from August 12, 2026, companies exporting cosmetics to the EU should promptly conduct a packaging conformity self-assessment and clarify their economic operator role(s) (Manufacturer/Producer/importer, etc.) and the corresponding obligations under the PPWR framework.
2. Companies are advised to establish a packaging specification inventory by SKU (materials, structure, color, post-processing such as printing/coating, suppliers, and supporting evidence), and to systematically identify and classify packaging units and their components, laying the groundwork for TD preparation.
3. Communicate in advance with packaging material suppliers and ODM/OEM manufacturers to establish an information-provision and change-notification mechanism for materials and technical data, ensuring that supply-chain information covers the specifications of the packaging actually placed on the EU market. Note: the DoC is a declaration of conformity signed by the Manufacturer itself rather than a third-party certification, and companies bear primary responsibility for the final conformity determination.
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