PWR, EMPCO, UWTD: Why are these regulations a game-changer?

Data, the cornerstone of the new environmental regulations for the cosmetics industry

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While recent months have brought a wave of regulatory adjustments on sustainability topics, they do not reflect what is really at stake for the cosmetics industry. EMPCO, PPWR, UWTD, DPP: four texts moving forward, some already in force, sharing an unprecedented logic. For the first time, beyond toxicity, regulation requires measuring, documenting and demonstrating the real environmental impact of products, with direct financial consequences. What does each of these texts concretely mean, and why does their convergence change the game?

PPWR (Packaging and Packaging Waste Regulation): cosmetic packaging in the era of circularity

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The cosmetics industry did not wait for PPWR to tackle its packaging. In France, the AGEC law paved the way as early as 2020 and major groups have already fully committed to transformation plans to comply with its requirements. The FEBEA (Fédération des entreprises de la beauté) is spearheading the Plastic Act to reduce packaging impact. Regulation (EU) 2025/40 -PPWR for Packaging and Packaging Waste Regulation - builds on this momentum and extends it to all Member States. It will apply directly to everyone, without national transposition, from 12 August 2026, with differentiated deadlines depending on the obligation.

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This new regulation aims to reduce packaging waste, improve its environmental performance and harmonise the internal market. While it applies to all consumer goods, the implications are particularly significant for the cosmetics industry. The sophistication of packaging is often a positioning signature, especially for luxury houses. These aesthetic and functional choices become criteria for regulatory compliance, from the design phase onwards.

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The obligations of Regulation (EU) 2025/40 for cosmetic packaging are built around six pillars:

• Recyclability: by 2030, all packaging must be technically recyclable, compatible with existing treatment channels and free of disruptive elements. Recyclability will be assessed according to a classification defined by delegated acts by 2028. Only packaging reaching a minimum level will be authorised on the market.
• Reduction: brands will need to adopt a source-minimisation approach: reducing volume and weight, eliminating unnecessary over-packaging, minimising at the design stage.
• Reuse: the regulation introduces reuse objectives. The cosmetics sector is not directly subject to generalised obligations. However, refill models are fully in line with the regulatory trajectory and represent an anticipation lever.
• Recycled content: brands will need to progressively incorporate recycled materials into plastics, with increasing thresholds up to 2040.
• Extended Producer Responsibility (EPR): producers register in each Member State where they market packaged products and pay eco-contributions modulated according to the environmental performance of their packaging. Poorly recyclable packaging will generate a higher contribution than packaging that meets the regulation’s criteria.
• Labelling: labelling systems will be harmonised at European level for sorting and reuse by 2028.

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EMPCO: the end of environmental claims without data

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The cosmetics industry is one of the most exposed to the issue of environmental claims. “Natural”, “eco-responsible”, “environmentally friendly”: these qualifiers have long occupied marketing narratives. In France, the AGEC law established a first framework as early as 2021, prohibiting claims suggesting zero or positive impact without established proof. This provision forced marketing teams to revise their messaging, without fundamentally changing underlying practices.

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A new step will soon be taken with the EMPCO directive (Empowering Consumers for the Green Transition) adopted in 2024 and applicable from September 2026.

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As early as 2020, the Commission identified that more than half of environmental claims on consumer products were vague, misleading or unfounded (1). The directive responds to this finding by strengthening the requirements for commercial practices.

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The EMPCO directive covers 6 key areas:

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• Prohibition of unsubstantiated generic claims: terms such as “green”, “ecological”, “sustainable” or “nature-friendly” used without precise documentation on product characteristics, methodology or scope will be considered unfair commercial practices. This logic extends and tightens what AGEC initiated in France, giving it harmonised reach across the Twenty-Seven.
• Regulation of comparative claims: comparisons must be based on objective, relevant and verifiable elements, and must not mislead the consumer.
• Regulation of claims based on carbon offsetting The directive prohibits presenting a product as “carbon neutral” or “climate positive” when this assertion relies on offsetting mechanisms external to the value chain. A distinction must be made between effective impact reduction and offsetting.
• Regulation of claims about future performance Environmental promises relating to future objectives must be credible, verifiable and must not mislead the consumer. General unsubstantiated or insufficiently precise statements may be considered misleading.
• Strengthening justification requirements: companies must be able to demonstrate the veracity of their claims on the basis of reliable and documented data. Regulation of environmental labels: Labels must be based on transparent and credible certification systems. Self-declared labels or those not based on verifiable criteria will be restricted. The directive brings environmental communication into a logic of justification and traceability.

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The directive brings communication into the era of proof. Compliance with EMPCO is not a matter of lexical reformulation but of data. For a cosmetics brand, this means that any claim about a formula, packaging or the environmental trajectory of a product must be based on solid, documented and defensible data.

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Urban Wastewater Treatment Directive: for the first time, the formula at the heart of water regulation

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While PPWR and EMPCO dominate the agendas of packaging and marketing teams, the revised Urban Wastewater Treatment Directive  addresses R&D. Published in the Official Journal on 12 December 2024 and entering into force in January 2025, it is currently being transposed into national law within Member States. For the first time, it raises the question of the end-of-life of formulas and their impact on wastewater as a regulatory issue in its own right.

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The UWTD's obligations for the cosmetics industry fall under three fronts:

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• Quaternary treatment of micropollutants: the directive introduces the obligation of quaternary treatment in large wastewater treatment plants — in other words, an additional level of treatment designed to eliminate a wide range of micropollutants that current processes do not capture. This treatment will progressively apply to plants serving more than 150,000 population equivalents by 2045, with intermediate milestones from 2033. It may be extended to medium-sized plants whose discharges occur in sensitive areas: bathing water, drinking water catchments, aquaculture zones.
• Extended Producer Responsibility: the polluter-pays principle applied to the formula. The pharmaceutical and cosmetics industries are designated as responsible for financing 80% of the costs induced by this quaternary treatment (investment and operation). The directive remains vague on the definition of a micropollutant, does not distinguish between types of products, and does not prescribe an eco-modulation mechanism at this stage. It establishes primarily a framework of financial responsibility. It is precisely this strict and undifferentiated character that is currently mobilising professional federations, with Cosmetics Europe leading the way.
• A still unclear text, with decisive work underway. National transposition is underway. It is within this framework that the essential trade-offs for the industry will play out: definition of the micropollutants concerned, establishment of a reference list, conditions for a possible eco-modulation of the EPR according to the environmental profile of products. This work could create a mechanism that genuinely incentivises eco-design of formulas.

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Beyond these trade-offs, UWTD points to new regulatory challenges. The nature of the substances present in a formula, their persistence, and their fate in aquatic environments are becoming parameters to measure and manage. UWTD places formula eco-design at the heart of tomorrow’s challenges and opens up a field that the cosmetics industry has until now addressed only marginally, without a global measurement of aquatic impact.

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DPP (Digital Product Passport): towards mandatory environmental data per product

Unlike the preceding texts which regulate practices, packaging, marketing and formulation, the Digital Product Passport introduces a requirement of a different nature: structuring, documenting and transmitting the product’s own environmental data. Introduced by the Ecodesign for Sustainable Products Regulation (ESPR, EU 2024/1781), which entered into force in July 2024, it represents one of the most significant regulatory developments in the medium term.

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The DPP rests on three dimensions:

• A phased rollout by product category: the DPP will not apply to all products simultaneously. Each category will be subject to a delegated act defining mandatory data, standardised formats and access modalities. The 2025-2030 work plan, adopted by the European Commission in April 2025, lists priority categories. Textiles, batteries, electronics and steel will be the first concerned. The timeline for cosmetics has not yet been set.
• A shift in the nature of data: the DPP does not merely create a transparency obligation. It imposes an interoperable and verifiable data architecture. The requirement will be to provide reliable, traceable and up-to-date environmental data, structured according to European standards. This data must be accessible to stakeholders: consumers, authorities, value chain partners.
• A point of convergence for the other texts: the DPP acts as a transversal layer across the entire regulatory sequence: packaging data documented for PPWR, claim justifications required by EMPCO, substance impact for DERU. Everything converges towards the same need: having coherent, consolidated and usable product data at portfolio scale. The product passport becomes the centralisation vehicle.

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From compliance to proof

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EMPCO, PPWR, UWTD, DPP.  All these new texts share the same logic: moving from compliance to proof. Regulation no longer simply requires rules to be followed or substances to be excluded. It now requires measuring, documenting and demonstrating, with financial stakes attached. This is not a simple regulatory tightening but a change in nature, with the management of the environmental performance of consumer goods as its culmination.

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For cosmetics players, this implies moving from a logic of one-off assessment to a capacity for continuous measurement, structured and usable at portfolio scale. LCA is the most robust method to meet this challenge.  It is the only one that covers all the environmental dimensions of a product, from packaging to formula, from raw material to end of life, within a standardised and auditable framework.

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n this context, tools capable of producing reliable, multi-criteria and industrialisable environmental data are no longer a technical subject. They are becoming a condition for competitiveness.

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(1) European Commission, “Environmental claims in the EU” (2021)

53% of environmental claims are vague, misleading or unfounded

40% are not supported by evidence

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