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EU GPSR, PPWR packaging rules and EPR for skincare sellers

Reviewed by our formulation chemist team. Updated October 2026.

What the General Product Safety Regulation, the Packaging and Packaging Waste Regulation and national packaging registrations mean for a skincare brand selling online into the EU, with the dates as of October 2026.

Not legal adviceThis guide summarizes EU and national texts to help you plan. Packaging and EPR rules differ by country and change with national laws; confirm your duties with your EU Responsible Person, a compliance provider or the national register before you sell.

Short answer

Cosmetics have their own EU safety law, so the General Product Safety Regulation (GPSR, Regulation (EU) 2023/988) applies to them only where the Cosmetics Regulation is silent: in practice, the information every online listing must show (manufacturer, EU contact, product identification, warnings), accident reporting, recall notices and the duties of online marketplaces, all since 13 December 2024. The Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40) has applied since 12 August 2026, with the big design rules in 2028 to 2030: harmonized sorting labels, recyclability grades, 10% recycled content for most plastic cosmetic packaging, less empty space. Separately, every country where you sell packaged products to consumers expects you to register for extended producer responsibility (EPR) and pay for packaging recycling, and marketplaces such as Amazon ask for those registration numbers.

Three sets of rules, one product

A 30 mL serum sold from Korea to a consumer in France touches three separate legal layers. Mixing them up is the most common source of confusion.

Layer	Law	What it governs	Who acts
The product	Cosmetics Regulation (EC) No 1223/2009	Safety, ingredients, the cosmetic label, the Responsible Person, CPNP	Your EU Responsible Person
Selling it, especially online	GPSR, Regulation (EU) 2023/988	Listing information, accidents, recalls, marketplace duties	You as the seller, and the marketplace
The packaging	PPWR, Regulation (EU) 2025/40, plus national EPR laws	Packaging design, packaging labels, registration and recycling fees in each country	The "producer" of the packaging in each country, often you

Our EU cosmetics regulation guide covers the first layer and the EU ingredient rule tracker lists the dated ingredient changes. This page covers the other two.

GPSR: how it applies to cosmetics

The GPSR replaced the old General Product Safety Directive and has applied since 13 December 2024. It is a safety net: Article 2 says that where a product is covered by specific EU harmonization legislation, such as the Cosmetics Regulation, the GPSR applies only to aspects and risks that law does not cover, and several chapters do not apply at all.

GPSR part	Applies to cosmetics?	What it means for you
General safety requirement (Chapter II)	Not for risks the Cosmetics Regulation covers	The CPSR and the Cosmetics Regulation decide whether the product is safe
Manufacturer, importer, distributor duties and the GPSR "responsible person" (Chapter III, Section 1, Articles 9 to 18)	No	Your Responsible Person under the Cosmetics Regulation plays this role
Distance sales information (Article 19)	Yes	Online offers must show set information (next section)
Accidents (Article 20)	Yes, for aspects the Cosmetics Regulation does not cover	Accidents linked to a product are reported through the Safety Business Gateway; serious undesirable effects still go to the authority under the Cosmetics Regulation
Online marketplaces (Chapter IV, Article 22)	Yes	Marketplaces must collect and display your information and act on authority orders
Safety Gate, recall notices and remedies (Chapters VI and VIII)	Yes	Recalls follow GPSR rules on the notice to consumers and the remedy offered

A product offered online counts as made available in the EU when the offer is targeted at EU consumers, for example a site in a member state language, delivery to EU addresses or prices in euro (Article 4). Selling from Korea does not take you out of scope.

What every online listing must show

Article 19 requires every online or other distance-sale offer to show, clearly and visibly:

The manufacturer
Name, registered trade name or trademark, and a postal and electronic address. For a private label product, that is usually your brand company as named on the label.
The EU contact when the manufacturer is outside the EU
The name, postal and electronic address of the EU person responsible. For cosmetics, give your Responsible Person under the Cosmetics Regulation, the same one printed on the label.
Product identification
A picture of the product, its type and any other product identifier (for example the GTIN barcode and the product name and size).
Warnings and safety information
Any warning that must be on the product or packaging, in a language consumers in that country understand. For skincare: the cosmetic label warnings, such as the vitamin A warning, "avoid contact with eyes", or the precautions for acids.

ExampleA Shopify store in English and German ships a retinol cream from a warehouse in the Netherlands. Each product page shows the brand company and its email and postal address, the EU Responsible Person's name and address, product photos with the 50 mL size and GTIN, and the label warnings in German and English. The same data goes into each marketplace listing.

Online marketplace duties

Article 22 puts duties on providers of online marketplaces (Amazon, eBay, TikTok Shop and similar). The ones that affect sellers:

Collect your information: the marketplace's interface must let you enter the Article 19 data for each product and display it with the offer.
Act on authority orders: when a market surveillance authority orders the removal of a dangerous product offer, the marketplace must act within 2 working days.
Handle notices: product safety notices about an offer must be processed within 3 working days.
Use Safety Gate: marketplaces register on the Safety Gate Portal and check the alerts published there.

In practice, a listing without the manufacturer and EU contact fields filled in can be suppressed, and a product named in a Safety Gate alert can be removed. Keep the EU Responsible Person's details identical on the label, in the CPNP notification and in every listing.

PPWR: the packaging regulation and its dates

The Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, replaces the old Packaging Directive with directly applicable rules. It has applied since 12 August 2026, but most design requirements start later and some depend on implementing acts that the Commission still has to adopt. Where the text says "date X or N months after the implementing act, whichever is later", the later date wins.

Date (as of October 2026)	Requirement	Article
12 August 2026	The regulation applies: substance limits (lead, cadmium, mercury and hexavalent chromium together under 100 mg/kg in packaging), PFAS limits for food-contact packaging, producer and EPR rules, conformity documentation	Art. 5, 44 to 47, 71
12 February 2028	Sales packaging empty space reduced to the minimum necessary	Art. 24(4)
12 August 2028 or 24 months after the implementing act	Harmonized label with material composition on packaging (pictograms, possibly a QR code); Italy says its current national label may be used until 11 August 2028	Art. 12
1 January 2030	Packaging minimization: weight and volume reduced to the minimum; no double walls, false bottoms or unnecessary layers meant only to look bigger	Art. 10
1 January 2030 or 24 months after the delegated acts	Recyclable packaging only: recyclability performance grade A, B or C	Art. 6
1 January 2030 or 3 years after the implementing act	Minimum recycled content in plastic packaging; empty space ratio of at most 50% in e-commerce, grouped and transport packaging	Art. 7, Art. 24(1)
1 January 2030	Ban on single-use cosmetic, hygiene and toiletry packaging for individual hotel bookings (for example mini shampoo and lotion bottles)	Art. 25, Annex V
1 January 2035	Packaging must also be "recycled at scale"	Art. 6
1 January 2038	Only grades A or B allowed	Art. 6
1 January 2040	Higher recycled content targets	Art. 7

PPWR design rules for cosmetic packaging

Recycled content: cosmetics count as contact-sensitive

The PPWR defines "contact-sensitive packaging" to include packaging for products under the Cosmetics Regulation. That gives cosmetic plastic packaging the lower targets:

Plastic packaging type	From 2030 (or 3 years after the implementing act)	From 2040
Contact-sensitive, PET as the main material (for example a PET toner bottle)	30% post-consumer recycled content	50%
Contact-sensitive, other plastics (PP jars, PE tubes, airless bottles)	10%	25%
Other plastic packaging (for example shipping film, outer wraps)	35%	65%

Targets are calculated as an average per manufacturing plant and year, and a plastic part under 5% of the total weight of the packaging unit is outside them. Compostable plastic packaging is also excluded. The manufacturer or importer of the packaging shows compliance in the technical documentation.

Recyclability, minimization and labels

Recyclability: from 2030 packaging must reach grade A, B or C under design-for-recycling criteria the Commission will set by product category. Mixed-material pumps, metallized films and dark pigments that sorting machines cannot read are typical risks for cosmetics.
Minimization: packaging that only adds perceived volume (double walls, false bottoms, thick outer boxes around small bottles) is banned from 2030, with a narrow exception for designs or shapes protected by design rights or trademarks before 11 February 2025.
E-commerce boxes: from 2030 (or later, see the table) the empty space in shipping boxes may be at most 50%, counting air pillows and paper fill as empty space.
Labels: the harmonized material label will replace national sorting marks once its implementing act applies. Until then national marks such as France's Triman and Info-tri and Italy's environmental label still apply.

For packaging choices (PCR plastic, refills, glass vs plastic), see our skincare packaging guide and the packaging options we offer.

EPR: registering in each country

Extended producer responsibility (EPR) means the company that first makes packaged products available in a country pays for collecting and recycling that packaging. EPR registration is national: one registration does not cover the EU.

Find out if you are the producer
Under PPWR Article 3 and national laws, the producer is usually whoever first makes the packaged product available in that country. If an EU importer or distributor buys your goods and sells them on, it is often the producer. If you sell directly to consumers from Korea or from your own EU warehouse, you usually are.
Register in the national register
PPWR Article 44 requires producers to register in each member state where they first make packaging available, before they sell. Registration details include the brand names and the packaging types.
Join a compliance scheme
Most countries require you to join a producer responsibility organization (PRO) or a dual system and pay fees by weight and material.
Appoint an authorized representative where required
PPWR Article 45(3) requires a producer selling directly into a member state where it is not established to appoint an authorized representative for EPR there, and member states may require one for producers from outside the EU. In December 2025 the Commission proposed suspending these authorized representative rules (COM(2025) 982); it was still a proposal when we checked in October 2026, so follow the national law in force.
Report every year
Producers report the packaging they placed on the market by weight and material, by 1 June for the previous calendar year under the PPWR register rules, or on the national schedule.

France, Germany, Spain, Italy and others

Country	Packaging EPR in practice (as of October 2026)	Labels on pack
Germany	The Packaging Law Implementation Act (VerpackDG) implements the PPWR and replaces the earlier Packaging Act (VerpackG). Producers register with the Central Agency Packaging Register (ZSVR) in the LUCID register before first making packaging available, and take part in a dual system for packaging that ends up with private consumers. A producer without an establishment in Germany must appoint a German EPR authorized representative by written mandate in German before first sale (VerpackDG sections 5 to 7)	No national sorting logo required; material identification under the act
France	Producers join an approved packaging PRO (for household packaging, for example Citeo) and receive a unique identifier (identifiant unique) from ADEME's register; marketplaces must check that sellers are registered or pay on their behalf (reported; check with your PRO)	Triman logo and Info-tri sorting instructions on household packaging, until the EU harmonized label applies
Spain	Royal Decree 1055/2022 on packaging: producers register in the producer register (packaging section) and meet EPR individually or through a collective scheme. Where a foreign seller has no authorized representative, an e-commerce platform selling its products acts as the producer in the alternative	Optional and conditional marks on recyclability and recycled content, with rules on claims
Italy	CONAI, the national packaging consortium, runs EPR; producers and users of packaging join and pay the environmental contribution	Mandatory environmental label (material code and disposal information); CONAI says the current format may be used until 11 August 2028, then the EU harmonized label
Netherlands	Verpact (formerly Afvalfonds Verpakkingen) runs the packaging EPR scheme with fees by material, including discounts for easily recyclable plastic; check thresholds and registration with Verpact	No national sorting logo required
Other member states	Austria, Belgium, Poland, Sweden and others run their own registers and schemes, and several require an authorized representative for foreign distance sellers	Check national rules

Many brands use an EPR compliance provider that registers and reports in several countries for a fee. Ask your EU Responsible Person whether it offers this or works with one.

What Amazon and other marketplaces ask for

EPR numbers: Amazon's EU stores ask sellers for their EPR registration numbers for packaging in countries such as Germany and France and can block listings without them. Enter the numbers in the EPR section of Seller Central. Under PPWR Article 45(4), large online platforms will have to collect each producer's registration number for the consumer's country and a self-certification before letting it sell.
GPSR data: the manufacturer, the EU contact and safety information for each product, as required by Article 19.
Cosmetic documents: the EU Responsible Person, label images and, in some reviews, the CPNP notification or safety documents. See our Amazon and TikTok Shop guide and the export documents guide.
Fulfillment services: PPWR Article 45(7) requires producers to give fulfillment service providers (for example a 3PL or FBA) their registration information when they sign up.

Step by step for a brand selling into the EU

Map your sales
Which countries, which channels (own store, Amazon, retailers, distributors), and who first makes the packaged product available in each country.
Appoint the Responsible Person and notify
Cosmetics Regulation first: RP, CPSR, PIF, CPNP. The RP's name and address go on the label and in every listing.
Build the GPSR listing data
One table per SKU: manufacturer details, EU contact, product photo, GTIN, size, warnings per language.
Register for EPR per country
Germany (LUCID plus a dual system), France (PRO and unique identifier), Spain, Italy and any other country where you are the producer, with an authorized representative where the national law requires it.
Add national packaging marks
Triman and Info-tri for France, the environmental label for Italy, and plan the harmonized EU label for 2028 or later.
Review packaging for 2030
Ask your packaging supplier for material data, recycled content options and recyclability. Cut empty space in boxes and shipping cartons.
Report and pay
Annual or periodic declarations by weight and material in each country.
Keep it current
New SKU, new country or new packaging: update the listing data and the EPR declarations.

Common mistakes

Assuming the GPSR does not apply to cosmetics at all; its listing, accident, recall and marketplace rules do.
Listing a different EU contact online than the Responsible Person on the label.
Thinking one EU registration covers packaging EPR everywhere; it is country by country.
Selling into Germany from abroad without a LUCID registration, a dual system contract and the required German authorized representative.
Shipping French orders without Triman and Info-tri marks on household packaging.
Designing a premium box with a false bottom or a thick insert around a small bottle, which the PPWR bans from 2030.
Ignoring the 5% weight rule and recycled content when choosing a new plastic bottle for a 2029 launch.
Waiting for Amazon to block listings before registering for EPR.

Checklist

Countries and channels mapped, with the producer identified for each
EU Responsible Person appointed, CPNP done, RP details identical everywhere
GPSR listing data per SKU: manufacturer, EU contact, photo, identifier, warnings by language
Accident and recall contacts set up; Safety Gate alerts monitored
Germany: LUCID registration, dual system contract, German authorized representative if required
France: PRO membership, unique identifier, Triman and Info-tri on pack
Spain, Italy, the Netherlands and other countries checked and registered
EPR numbers entered in Amazon Seller Central and given to your 3PL
Packaging material data and recycled content options requested from suppliers
Boxes and cartons reviewed for empty space and false bottoms
Plan for the harmonized EU packaging label from 2028
Annual EPR declarations scheduled

How KoreanOEM helps

KoreanOEM is a Korean skincare OEM and private label manufacturer: we develop your formula and produce it in Korea, and we plan the packaging and label with you from the first sample.

Packaging data: a stock container and a one-color printed label are included in the unit price. For PCR plastic, refills or other formats, custom container sourcing is USD 199 covering up to 2 products, with up to 3 options matched to your reference and a fit and leak check with the formula; box sourcing is USD 149 for up to 2 products. See custom packaging sourcing.
Label files: we provide the dieline, print specs and a file check; your designer adds the Triman, Info-tri or Italian environmental marks. We do not design artwork.
Label proof check: free on orders where we print the labels, against EU cosmetic label rules including the Responsible Person details. See the label proof check.
EU cosmetic compliance through our partner: CPSR and PIF USD 1,250 per formula, CPNP notification USD 420 per product, Responsible Person USD 335 per product per year for the UK and EU. Packaging EPR registration is done by you or your compliance provider in each country.
Shipping: FOB Incheon by default, or DDP to your EU warehouse, quoted per shipment.

Best price, best cost and the lowest minimum order you cannot find anywhere else. We believe in our customers' vision rather than our own profit, so even if we lose money at the beginning, we still support you.

Get a free quote See packaging options

Frequently asked questions

Does the EU GPSR apply to cosmetics sold online?

Partly. The Cosmetics Regulation covers safety and the Responsible Person, but since 13 December 2024 the GPSR's distance sales rules (Article 19), accident reporting, recall notices and online marketplace duties also apply to cosmetics, so every listing must show the manufacturer, the EU contact, product identification and warnings.

Do I need a GPSR responsible person for my skincare products?

No separate one: the GPSR's Article 16 responsible person rules do not apply to cosmetics, because the Cosmetics Regulation already requires an EU Responsible Person. Use that Responsible Person's name and address as the EU contact in your online listings.

Which packaging and EPR rules apply per EU country?

Each country runs its own packaging EPR register and scheme: Germany's LUCID register and dual systems under the VerpackDG, France's PROs such as Citeo with a unique identifier and the Triman logo, Spain's producer register under Royal Decree 1055/2022 and Italy's CONAI consortium and environmental label. Register in every country where you first make packaged products available to consumers.

What do the EU PPWR and EPR rules mean for my packaging?

The PPWR has applied since 12 August 2026; from 2028 to 2030 cosmetic packaging needs a harmonized material label, a recyclability grade of A to C, at least 10% recycled content in most plastic parts (30% for PET), minimal empty space and no false bottoms or double walls. EPR means you register and pay recycling fees in each country you sell to.

Do I need recycling marks such as France's Triman?

Yes, household packaging sold in France must carry the Triman logo with Info-tri sorting instructions, and Italy requires an environmental label with material codes and disposal information. These national marks will give way to the EU harmonized label once its implementing act applies, from 12 August 2028 at the earliest.

What does Amazon EU need from a non-EU skincare brand?

An EU Responsible Person on the label and in the listing, the GPSR information for each product, EPR registration numbers for packaging in countries such as Germany and France, and the cosmetic label and documents Amazon asks for in a category or listing review.

Is recycled plastic required for cosmetic bottles in the EU?

From 1 January 2030, or 3 years after the Commission's implementing act if later, plastic packaging for cosmetics must contain at least 10% post-consumer recycled plastic, or 30% if it is mainly PET, averaged per manufacturing plant and year. Plastic parts under 5% of the packaging unit's weight are exempt.

Are hotel mini toiletries banned in the EU?

From 1 January 2030 the PPWR bans single-use packaging for cosmetic, hygiene and toiletry products intended for one hotel booking and thrown away before the next guest, such as mini shampoo and lotion bottles. Refillable dispensers remain allowed.

Sources

Checked against these sources in October 2026. Rules and fees change; check with the authority or your importer before you sell.