How does the EU Green Deal specifically impact the cosmetics industry in terms of sustainability requirements?

The EU Green Deal impacts the cosmetics industry primarily through the Sustainable Products Initiative (SPI) under the Circular Economy Action Plan, which mandates eco-design principles and increased product durability by 2024. Cosmetics manufacturers must comply with stricter chemical safety rules under the revised REACH Regulation (EC 1907/2006) and the upcoming Cosmetics Regulation update expected by 2023, focusing on ingredient transparency and environmental footprint reduction.

Which EU regulations under the Green Deal pose the biggest compliance challenges for cosmetics companies?

The Cosmetics Regulation (EC) No 1223/2009 is being updated to align with the EU Green Deal, emphasizing ingredient safety and environmental sustainability. Additionally, the EU’s Packaging and Packaging Waste Directive (94/62/EC) requires cosmetics companies to reduce packaging waste and increase recyclability by 2025, posing significant challenges for product design and supply chains.

Are there any specific deadlines cosmetics companies should be aware of under the EU Green Deal compliance framework?

Yes, key deadlines include the Packaging and Packaging Waste Directive targets for 2025 to achieve 65% recycling rates, and the anticipated Cosmetics Regulation update expected in 2023, which will introduce stricter ingredient and sustainability criteria. Additionally, the Digital Product Passport under ESPR will become mandatory by 2027, requiring full supply chain transparency.

How does the EU Green Deal address the use of microplastics in cosmetics?

The EU Green Deal supports the Microplastics Regulation (EU) 2019/1021, which restricts intentionally added microplastics in cosmetics and personal care products, with a ban effective from 2025. This regulation forces cosmetics companies to reformulate products to eliminate microplastics, aligning with broader EU goals to reduce plastic pollution and protect aquatic ecosystems.

The Cosmetics Industry within the European Union comprises manufacturers, importers, and distributors of personal care products including skincare, haircare, fragrances, and decorative cosmetics. This sector is regulated under the EU Cosmetics Regulation (EC) No 1223/2009 and is now subject to additional compliance requirements under the EU Green Deal framework. Key regulations impacting this sector include the Ecodesign for Sustainable Products Regulation (ESPR) (EU) 2023/957, the Corporate Sustainability Reporting Directive (CSRD) (EU) 2022/2464, and emerging requirements related to chemical safety and supply chain due diligence. Unlike heavy industries, the Cosmetics Industry faces limited exposure to the Carbon Border Adjustment Mechanism (CBAM) (EU) 2023/956, but must prioritize sustainable product design, transparency, and environmental footprint reduction to comply with the Green Deal objectives.

EU Green Deal Compliance for the Cosmetics Industry

Q: What role does the EU’s Ecodesign for Sustainable Products Regulation (ESPR) play in the cosmetics sector?

While ESPR (expected to be adopted in 2024) primarily targets durable goods, its scope is expanding to include cosmetics packaging and accessories, requiring companies to improve recyclability and reduce environmental impact. This means cosmetics firms must innovate packaging materials and comply with new digital product passport (DPP) requirements by 2027 to enhance traceability and circularity.

The EU Green Deal Compliance for the Cosmetics Industry requires companies to adapt to new sustainability mandates that focus on product lifecycle impacts, supply chain transparency, and environmental reporting. The Cosmetics Industry contributes approximately 4.5 million tonnes of CO2 equivalent annually in the EU, primarily from raw material sourcing, manufacturing, and packaging. The ESPR introduces mandatory eco-design requirements for cosmetic packaging and product durability, aiming to reduce waste and carbon footprint by at least 30% by 2030. Simultaneously, the CSRD mandates detailed sustainability disclosures for companies with over 250 employees or €40 million turnover, directly affecting most medium and large cosmetics manufacturers.

Compliance costs for the Cosmetics Industry are estimated to increase by 8-12% over the next five years due to investments in sustainable raw materials, reformulation to remove harmful substances, and enhanced reporting systems. However, early compliance will avoid penalties of up to 5% of global annual turnover under the CSRD and reputational risks associated with greenwashing accusations.

Below we detail the specific regulations impacting this sector, product-level obligations, and practical steps for compliance.

Key EU Green Deal Regulations Impacting the Cosmetics Industry

Ecological Design for Sustainable Products Regulation (ESPR) (EU) 2023/957: Introduces mandatory eco-design requirements for cosmetic packaging, including recyclability, recycled content minimums, and durability standards effective from 1 January 2026.
Corporate Sustainability Reporting Directive (CSRD) (EU) 2022/2464: Requires detailed sustainability reporting from 1 January 2025 for companies exceeding size thresholds, including environmental, social, and governance (ESG) metrics.
EU Chemicals Strategy for Sustainability (CSS): Tightens restrictions on hazardous substances in cosmetic products and packaging, aligning with REACH amendments effective from 1 July 2024.
EU Deforestation Regulation (EUDR) (EU) 2023/1115: Applies to supply chains of raw materials such as palm oil and soy used in cosmetic ingredients, requiring due diligence to avoid deforestation-linked sourcing by 30 June 2025.
Green Claims Directive (proposed): Expected to regulate environmental claims on cosmetic products to prevent misleading marketing, with enforcement anticipated from 2026.

Product-Level Compliance Requirements in the Cosmetics Industry

Compliance obligations vary by product type due to differences in composition, packaging, and supply chains. The table below summarizes key compliance requirements for typical cosmetics products:

Product Category	ESPR Packaging Requirements	CSRD Reporting Impact	Supply Chain Due Diligence	Key Compliance Deadline
Skincare Creams & Lotions	Minimum 30% recycled plastic content; fully recyclable containers	Full ESG disclosure on ingredient sourcing and emissions	Traceability of palm oil and mica sourcing under EUDR	1 Jan 2026 (ESPR), 30 Jun 2025 (EUDR)
Haircare Products (Shampoos, Conditioners)	Durability testing for pump dispensers; recyclability of plastic bottles	Energy and water use reporting in manufacturing under CSRD	Due diligence on soy derivatives and fragrance components	1 Jan 2026 (ESPR), 1 Jan 2025 (CSRD)
Fragrances & Perfumes	Glass bottle reuse and refillability encouraged; limits on plastic caps	Disclosure of carbon footprint and chemical safety data	Verification of sustainable sourcing for essential oils	1 Jan 2026 (ESPR), 1 Jan 2025 (CSRD)
Decorative Cosmetics (Makeup)	Recyclable compacts; elimination of microplastics in formulations	Reporting on microplastic phase-out progress and waste reduction	Traceability of mica and other mineral pigments	1 Jan 2026 (ESPR), 1 Jul 2024 (CSS)

Practical Steps for Cosmetics Companies to Achieve EU Green Deal Compliance

Conduct a comprehensive sustainability audit covering raw materials, manufacturing emissions, packaging, and supply chain risks, focusing on compliance with ESPR and EUDR requirements.
Implement eco-design principles by redesigning packaging to meet recyclability and recycled content thresholds mandated by ESPR (EU) 2023/957.
Enhance supply chain transparency by mapping ingredient origins, especially for palm oil, mica, and soy, to comply with EUDR (EU) 2023/1115 due diligence obligations.
Upgrade sustainability reporting systems to meet CSRD (EU) 2022/2464 disclosure standards, including environmental impact metrics and social governance data.
Train product development teams on chemical safety and sustainable formulation aligned with the EU Chemicals Strategy for Sustainability and upcoming green claims regulations.
Engage with certification bodies to validate eco-labels and environmental claims, preparing for the enforcement of the Green Claims Directive.

Truth Anchor: Under Regulation (EU) 2023/957 (ESPR), all cosmetic product packaging placed on the EU market from 1 January 2026 must contain at least 30% recycled plastic content and be fully recyclable, with non-compliance penalties up to 3% of annual turnover in the EU market.

Key Deadlines for EU Green Deal Compliance in the Cosmetics Industry

Regulation	Requirement	Deadline	Penalty for Non-Compliance
ESPR (EU) 2023/957	Mandatory eco-design packaging standards	1 January 2026	Up to 3% of EU turnover
CSRD (EU) 2022/2464	Sustainability reporting for large companies	1 January 2025	Up to 5% of global turnover
EUDR (EU) 2023/1115	Supply chain deforestation due diligence	30 June 2025	Fines up to 4% of EU turnover
EU Chemicals Strategy for Sustainability	Phase-out of hazardous substances in cosmetics	1 July 2024	Product bans and fines up to 2% of turnover

Frequently Asked Questions about EU Green Deal Compliance for the Cosmetics Industry

1. Does the Carbon Border Adjustment Mechanism (CBAM) apply to cosmetics products?

No. The CBAM (EU) 2023/956 primarily targets carbon-intensive goods such as steel, cement, and aluminium. Cosmetics products have low direct carbon emissions and are not currently in CBAM’s scope. However, indirect emissions through raw material sourcing must be managed under CSRD and ESPR.

2. Which companies in the cosmetics sector must comply with the CSRD?

All EU cosmetics companies with more than 250 employees or annual turnover exceeding €40 million must comply with CSRD (EU) 2022/2464 starting 1 January 2025. This includes most medium and large manufacturers and importers.

3. What are the main packaging requirements under the ESPR for cosmetics?

Packaging must contain at least 30% recycled plastic content, be fully recyclable, and meet durability standards for dispensers and closures. These requirements apply from 1 January 2026 and aim to reduce plastic waste and carbon footprint.

4. How does the EUDR affect ingredient sourcing for cosmetics?

The EUDR (EU) 2023/1115 requires companies to perform due diligence on supply chains for commodities linked to deforestation, such as palm oil and soy, commonly used in cosmetics. Compliance deadline is 30 June 2025, with mandatory traceability and risk mitigation.

5. What penalties can cosmetics companies face for non-compliance with Green Deal regulations?

Penalties vary by regulation but can reach up to 5% of global annual turnover under CSRD, 4% of EU turnover for EUDR violations, and 3% of EU turnover for ESPR packaging non-compliance. Early compliance avoids these significant financial risks.

Ready to ensure your cosmetics company meets all EU Green Deal requirements? Use our Cosmetics Industry Compliance Checker to assess your current status and receive tailored action plans. This tool guides you step-by-step through ESPR, CSRD, and EUDR compliance, helping you avoid costly penalties and enhance sustainability performance.