A brand owner I work with in the Netherlands called me last month, a week after launching two new SKUs in Germany. Her question was not about the packaging. It was about a registration number she had been told she needed before she could legally sell at all. Nobody on her team had heard of it.
This post is for her, and for every brand outside Europe that sells — or plans to sell — into European markets. Extended Producer Responsibility, or EPR, is no longer a background topic for the legal department. It shapes which packaging materials cost you more, which labels must appear on your artwork, and in Germany's case, whether you can sell there at all.
One scope note first. Food-contact compliance — EU 10/2011, FDA 21 CFR, China's CSAR — is a separate field, and we covered it in our regulatory compliance overview. This post is strictly about EPR and plastic restrictions: who pays for packaging waste, how the fees are calculated, and what your packaging design has to look like to stay on the right side of the rules.
What EPR means in plain language
EPR rests on one idea: whoever puts packaging onto a market is responsible for that packaging at the end of its life. In practice, "responsible" means paying. Brands join a compliance scheme in each country, report the tonnage and material type of packaging they place on the market — glass, plastic, paper, aluminium — and pay a fee per tonne into the system that funds collection and recycling.
Two things make this a packaging design problem rather than just an accounting one. First, the fees are not flat: they are modulated by material and by how recyclable the packaging is, which I will come back to. Second, the rules increasingly dictate design. Between single-use plastic restrictions in various markets and the EU's new packaging regulation, the question is no longer only "is my packaging recyclable" but "can I prove it, and will it still be compliant in four years." A brand that designs for EPR compliance packaging today is simply designing for the market as it now exists.
PPWR: the clock is already running
The big one is the EU's Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40 — everyone calls it PPWR. It entered into force on 11 February 2025, and its main obligations started applying from 12 August 2026. That date matters: as I write this in autumn 2026, we are only weeks into the live application phase, which means enforcement authorities, national registers, and compliance schemes are all setting up their routines right now. If your understanding of EU packaging law predates this regulation, it is out of date.
Two pillars of PPWR matter most for a cosmetic brand's packaging decisions.
The first is recyclability. By 2030, all packaging placed on the EU market must be designed for recycling — graded against design-for-recycling criteria, with poorly recyclable packaging facing restrictions. For a typical skincare set of bottle, pump, and folding carton, that pushes you toward mono-material components and away from mixed-material constructions that cannot be separated at a recycling plant. A pump with a glass bottle and a plastic collar is fine; a plastic bottle laminated with a material the recyclers cannot process is not.
The second pillar is recycled content. Plastic packaging will be subject to minimum recycled-content targets that phase in from 2030 and step up further after that, with the thresholds varying by plastic type and application. Combined with the recyclability requirement, the direction is unambiguous: plastic packaging with recycled content, designed to be recycled again, is where the regulation points. We built our [PCR plastic cosmetic tube] line for exactly this trajectory, and the brands who moved early are the ones not redesigning under deadline now.
There is more in PPWR — harmonized labeling for sorting, restrictions on certain packaging formats — and the details keep arriving in secondary rules. The safe assumption is that any packaging decision you make today should look compliant not just in 2026 but in 2030.
France: AGEC and the Triman mark
France ran ahead of the EU regulation, and its rules are a useful preview of where everyone is heading. The AGEC law — the anti-waste law for a circular economy — dates from 2020 and carries a requirement that trips up many first-time importers: most consumer packaging sold in France must carry the Triman mark, the sorting symbol that tells the consumer the product is recyclable and that sorting rules apply. Alongside it sits the "info-tri" sorting notice, which tells the consumer which components go where.
The mark has to be on the packaging artwork itself. It is not a sticker decision you make after printing. If France is in your distribution plan, the Triman mark and its accompanying sorting information belong on your artwork checklist from the first dieline, sized and placed according to the official specifications. Missing marks are an enforcement risk, and French authorities have shown they will use it.
Germany: VerpackG, LUCID, and no-registration-no-sale
Germany is the case where compliance becomes binary. Under the German Packaging Act — VerpackG — anyone placing packaged goods on the German market, including brands outside Germany selling direct to German consumers, must register with the Zentrale Stelle Verpackungsregister, the central packaging register, under its LUCID system. Registration is free. It is also mandatory before the first unit ships.
And here is the part my Dutch client ran into: without a valid LUCID registration number, selling in Germany is not allowed. Full stop. Marketplaces check registrations and delist non-compliant sellers, and competitors can and do report unregistered brands. Beyond registration, the brand must also license the packaging volumes with a dual system — that is where the fees get paid — and report the quantities. The register and the licensing are separate steps, and brands trip over the gap between them.
The lesson generalizes across Europe: EPR registration is a pre-launch task, not a post-launch cleanup. Each country runs its own scheme, and the obligations attach to whoever first places the packaging on that market.
| Market | Law / system | What it requires of your packaging | Status |
|---|---|---|---|
| EU | PPWR — Regulation (EU) 2025/40 | Design for recycling; recycled-content targets for plastic | In force Feb 2025, main obligations applying from 12 Aug 2026, targets step up toward 2030 |
| France | AGEC law | Triman mark + info-tri sorting notice on the artwork itself | In force and enforced |
| Germany | VerpackG + LUCID register | Register before the first unit ships; license volumes with a dual system | In force — no registration, no sale |
Why eco-modulation should change your material choices
EPR fees are not uniform. Most schemes apply eco-modulation: the fee per tonne is adjusted, up or down, based on how the packaging scores on recyclability and recycled content. Packaging that is mono-material, designed for recycling, and contains recycled resin pays less. Packaging that is hard to recycle, or mixes materials that cannot be separated, pays more — and under PPWR the worst performers will face restrictions regardless of what they pay.
| Packaging design choice | Typical fee direction | Why |
|---|---|---|
| Mono-material components | Down | Enters a real recycling stream |
| Recycled (PCR) content | Down | Supports recycled-content targets |
| Recyclable paper without laminates | Down | Clean fiber stream |
| Mixed materials that cannot be separated | Up | Contaminates the recycling stream |
| Poorly recyclable formats | Up — and restricted under PPWR | Fails design-for-recycling criteria |
This is where EPR stops being a compliance chore and becomes a lever. If you are choosing between two tube constructions anyway, the eco-modulated fee difference is a real recurring cost on every tonne you ship. The same logic applies to paper: an [FSC folding carton] made from recyclable fiber generally sits in a favorable fee class compared with complex laminates, and it carries a material story retail buyers ask about.
The practical translation: your packaging bill of materials now has a second price tag. Ask your supplier — that includes us — to flag which options in your project score better under eco-modulation, and make that part of the comparison alongside unit price and freight.
Three moves for smaller brands
Large brands have compliance departments. If you do not, here is the sequence I would run.
First, register before you ship. Map your target countries, find each national scheme, and get registrations done — Germany's LUCID is the one where non-registration blocks sales outright. This is measured in weeks and modest fees, and doing it late costs far more than doing it first.
Second, design for 2030 now. Favor mono-material packaging, put recycled content into your plastic components where the formula allows, and get written recycled-content declarations from your suppliers. Those declarations feed your EPR reporting, and under PPWR they will feed your recycled-content obligations too.
Third, build compliance marks into your artwork workflow. Triman and info-tri for France, sorting labels for other markets, material codes where required — on the checklist before every print run, not discovered after. Artwork revisions late in a project are where schedules die.
Where to start
None of this requires a legal department to begin. Send us your target markets and a rough packaging bill of materials — bottle, closure, tube, carton — and we will flag the compliance-relevant choices in the design, suggest the mono-material and recycled-content options we offer, and send samples with a quote. The brands that treat EPR as a design input are finding it cheaper than the brands that treat it as paperwork. My Dutch client now has her registration number framed, in a manner of speaking, and her next launch shipped compliant from day one.
