Cosmetic brands and their packaging supply partners across Europe are facing what may be the most complex regulatory landscape the industry has ever encountered. While the Packaging and Packaging Waste Regulation (PPWR) will come into effect on August 12, 2026, the UK’s Extended Producer Responsibility (EPR) initiative has entered its next phase, with the Recyclability Assessment Methodology (RAM) set to modulate EPR fees.
Through the green, amber, and red rating system, complex multilayer plastic packaging and nonrecyclable formats, which automatically receive a red rating under the EPR legislation, could result in businesses paying up to double the base rate by 2028. Packaging now directly influences commercial market access, and this impact will be further intensified by the EU PPWR recyclability grades A to C, which will restrict market access. What is particularly concerning is that these developments are often regarded solely as compliance challenges, although they also have significant implications for internal communication, customer communication, consumer messaging, and on-pack communication.
Frustrations abound
As a specialist marketing and communications partner to the global print, packaging, and life sciences industries, it has been consistently reported by companies across the beauty, household, and personal care sectors that the pace of regulatory change has exceeded their internal ability to communicate these developments effectively to customers, procurement teams, suppliers, trade media, and consumers.
This is partly due to packaging and operations teams having to comply with two major legislative frameworks simultaneously, and partly because not all PPWR definitions have yet been finalized.
Frustration is not limited to packaging designers; it is also affecting major global brand owners. Several have signed a petition to the European Commission requesting an adjustment to the enforcement date unless full legal certainty of the framework can be guaranteed. The issue remains highly contentious and has divided the industry. For some, an extended transition period is necessary to establish officially recognized methods for demonstrating compliance. For others, postponing enforcement creates additional uncertainty and ultimately undermines the objective of PPWR: improving packaging sustainability.
Stock management also presents a challenge. With restricted market access, noncompliant inventory could generate additional waste in the short term. However, if sustainability outcomes are to improve, a clear transition point must eventually be established. The way cosmetic companies and beauty brands communicate their position and collaborate with packaging suppliers on this issue has become increasingly important. The gap between actual progress and perceived progress continues to widen, creating measurable commercial consequences.
Communication readiness
The implications are substantial. The RAM green, amber, and red classification now directly affects the fees businesses will pay under UK EPR legislation. Under PPWR, recyclability claims that fail to comply with the legal definitions represent a significant compliance risk. Since several regulatory requirements have not yet been fully defined, uncertainty remains. Incorrect claims could result in penalties of up to 10% of annual business turnover under the EU Green Claims Directive.
These developments should be communicated internally by technical and operational leadership, with clear direction provided throughout the organization. Marketing and communications teams should work closely with compliance departments to ensure the right questions are being addressed. These include how claims on products currently in the value chain can be substantiated, what information can be shared regarding compliance status, how compliance can be communicated consistently through sales teams, websites, and media relations, and what actions are required over the next 30, 60, and 90 days to prepare for compliance.
With the introduction of new legislation, sustainability communication has become one of the most legally-sensitive aspects of corporate marketing, particularly within the cosmetics industry, where biobased chemicals and organic materials are involved. For many senior leadership teams, this represents one of the industry’s highest priorities. Communications strategies should therefore be managed with the same level of rigor applied to operational compliance and technical expertise. Marketing teams should be involved at an early stage, fully informed about upcoming legislation, aware of market access restrictions, and prepared to communicate potential impacts on customers.
Building stronger brand narratives
Companies that have already adopted this approach have successfully integrated sustainability communication into their overall brand narrative. For consumers, this may be reflected in the transition from flexible multilayer plastic packaging inside virgin fiberboard cartons to fully recyclable monomaterial pumps or tubes combined with biobased carton packaging. Instead of disposing of multilayer plastic packaging as household waste, consumers can simply rinse the rPET packaging and place it in the recycling bin together with the carton. One advantage of this transition is that recycling behavior is already well understood, while clear on-pack recycling instructions provide additional guidance when needed.
Companies that collaborate closely with their packaging suppliers and communicate with clarity, confidence, and precision will distinguish themselves from competitors. Organizations whose sales and account management teams engage customers early regarding packaging SKU changes are likely to benefit from stronger regulatory preparedness and more effective collaborative material innovation.
At Think B2B Marketing, companies are supported as an extension of their internal teams. Extensive expertise in the print and packaging industries provides a strong understanding of both the purpose of this legislation and the most effective ways of communicating its implications to stakeholders, brand owners, and consumers. The key recommendation is straightforward: communications strategies should be fully aligned with compliance strategies.
Joanna Stephenson
Managing Director, Think B2B Marketing, Wakefield, UK, www.thinkb2bmarketing.com