Exporting eye patches and eye cream to the EU: PPWR (EU) 2025/40 recycled content, recyclability grades and EPR registration

Packaging rules and producer responsibility

Three things can be decided before sampling. Cosmetics packaging is legally contact-sensitive packaging, so the Article 7 tier applies from 2030-01-01: 10% recycled content for contact-sensitive non-PET and 30% for PET, rising to 25% and 50% by 2040. Packaging graded below C may not be placed on the market from 2030-01-01, and from 2038-01-01 only grades A and B. Separately, every sale country needs its own producer registration, from German LUCID to Polish BDO.

The PPWR timeline and how it applies

Packaging compliance stops being optional on 12 August 2026, and every date that follows is set by the regulation rather than by your launch calendar.

Regulation (EU) 2025/40 entered into force on 11 February 2025, replacing Packaging and Packaging Waste Directive 94/62/EC, and applies generally from 12 August 2026. From that date, placing a packaging unit on the market requires a declaration of conformity, non-EU producers must appoint an EU authorised representative, and PFAS limits for food-contact packaging apply. The Commission must adopt implementing acts on recycled-content calculation and verification methodology by 31 December 2026 under Article 7(8); most trackers still list them as pending.

Later milestones follow in sequence. From 2028-08-12 the harmonised material label and digital product passport apply, carried on a QR code. From 2029-01-01 member states must operate deposit-return schemes for beverage containers. From 2030-01-01 the recycled-content thresholds apply, packaging graded below C may not be placed on the market, and grouped, transport and e-commerce packaging may contain no more than 50% empty space. From 2038-01-01 only grades A and B may be sold.

For eye care the decisive clause is Article 3(49). PPWR defines contact-sensitive packaging as packaging for products under regulations including (EC) No 1223/2009 on cosmetics, so a cream jar and an eye patch sachet are contact-sensitive in the same category as a coffee bag. That puts cosmetics on the lower tier of recycled content rather than the general plastic tier.

Recycled content: which tier eye care sits in

Cosmetics fall into the lower of two Article 7 tiers, and that single fact determines the number to budget from 2030.

Article 7 sets four thresholds for 2030 and four for 2040. For 2030 the contact-sensitive PET tier is 30%, contact-sensitive non-PET is 10%, single-use PET drinks bottles are 30% and other plastic is 35%; by 2040 those become 50%, 25%, 65% and 65%. An eye patch film that is not PET therefore faces 10% by 2030 and 25% by 2040, while the same polymer classified as other plastic faces 35% and 65%.

The start date is conditional: thresholds apply from the later of 1 January 2030 or three years after the relevant implementing act enters into force, and compliance is averaged per manufacturing plant per year rather than per batch. Plants with high internal recycle flow get some headroom, which also means a converter's claims must be documented before you rely on them.

Paper, glass and metal are exempt from the percentage obligation but not from the rest; they remain subject to recyclability, minimisation, labelling and EPR. Articles 7(4) to 7(5) also carry exemptions, including plastic parts under 5% of the total pack weight, which can matter for a closure or a pump component.

Recyclability grades and structural risk

The grade a pack receives decides whether it can legally still be sold from 2030, and for eye care the structure matters more than the resin.

Packaging is assessed and graded, with the thresholds stepping up over time. Packaging rated below grade C may not be placed on the market from 2030-01-01, and from 2038-01-01 only grade A and grade B packaging may be sold. Secondary thresholds have been signposted at 95% for grade A, 80% for grade B and 70% for grade C, but the delegated acts that make them binding are still outstanding, so treat them as directional.

Structure is where eye care carries the most risk. PPWR bans features that inflate volume, including double walls and false bottoms, and from 2030-01-01 grouped, transport and e-commerce packaging must not exceed 50% empty space. An over-sized outer carton or a void-filling sleeve in a direct-to-consumer parcel is a compliance item, not a presentation choice.

On formats, an aluminium and PE laminate sachet is the highest-risk item in a typical eye care range, because laminates that cannot be separated run poorly on European sorting lines unless the operator can prove otherwise. A round metal tin is easier, since metal sits outside Article 7 percentages. A PE film as the primary pack is classed as other plastic and must plan for 35% PCR by 2030 and 65% by 2040.

Substance limits and how labelling overlaps

Two chemical limits and one new label layer sit on top of the cosmetics label rules you already follow.

PPWR carries a substance limit for packaging: the combined content of lead, cadmium, mercury and chromium VI must not exceed 100 mg/kg in total. PFAS limits of 25 ppb, 250 ppb and 50 ppm are also set, but they apply only to food-contact packaging. For eye care the practical consequence is that pigment, colourant and coating suppliers need current conformity data, not a certificate issued years ago.

Labelling gains a second layer. Article 12 introduces a harmonised material identification label and a digital product passport from 2028-08-12, carried on a QR code. Paper, glass and metal are outside the recycled-content percentage but still inside the labelling obligation, so cartons and jars need both the existing material markers and the future harmonised label in the artwork.

The cosmetics side is unchanged and should not be confused with the packaging side. A CPNP notification under Article 13 of (EC) No 1223/2009 is a market entry record, not an approval, and the responsible person carries the full liability. Article 19 label content continues to apply, including responsible party, country of manufacture, net content, best-before date or period after opening, warnings, batch number and function. The UFI code is a poison-centre tool under Regulation (EU) 2017/2228, not a print requirement.

Producer responsibility by country

Every sale country needs its own registration and declaration. The fees differ by an order of magnitude, and so do the penalties.

Germany charges nothing for the register itself. LUCID registration is free and returns a German number with a 13-digit DE prefix, usually within minutes to hours, and a dual-system contract can be signed in one to three working days. The cost sits in the dual-system fee, charged per material: paper and board from EUR 0.02 to 0.15 per kg, PET and PE from EUR 0.30 to 0.80, glass from EUR 0.01 to 0.05, aluminium and metal from EUR 0.15 to 0.40. The annual minimum is around EUR 23.9 to 30 and a typical small and medium business total lands between roughly EUR 300 and 1,400 per year. The annual declaration is due on 15 May, marketplaces such as Amazon verify the LUCID number and can delist a listing without it, and fines reach EUR 200,000 plus publication in a blacklist. Non-EU sellers additionally need a German authorised representative from 2026-08-12.

France issues the identification number after the declaration is signed, not before. The process takes two to eight weeks, the French IDU follows the format FR plus six digits, an underscore and six characters, and the annual filing runs from January to late February. Citeo's 2026 minimum contribution is EUR 110 per year for 10,000 units or fewer, up 37.5% from EUR 80, and Léko charges EUR 95 capped at EUR 150 for up to 20,000 units, up 26.7% from EUR 75. Triman and Info-tri signage has been mandatory since 2023-03-09, and business-to-business packaging comes into scope from 2026.

Italy registers through CONAI, with fees varying by material and tier. Plastic has been quoted at EUR 24 to 655 per tonne from January 2025, with some sources citing EUR 40 to 790 per tonne from 2026-07-07; ordinary paper is EUR 65 per tonne, glass EUR 35 per tonne from June 2025 rising to EUR 40 per tonne from 2026-01-01, steel EUR 5 and aluminium EUR 12. Registration realistically runs three to six months, or eight to twelve weeks at peak, and the number uses the IT prefix plus 14 digits. Many plastic tiers increase again from 2026-10-01.

Spain registers producers with MITECO and contracts Ecoembes under Royal Decree 1055/2022. No single national annual fee has been published, so the amount has to be confirmed with the Individual Producer Agreement rather than assumed; the annual declaration is due on 31 March. Poland's BDO register is the single point of entry, foreign sellers may register using a PESEL number, annual minimum fees run from about EUR 25 to 50 for small volume up to EUR 500 or more at high volume, the declaration is also due on 31 March, there is no equivalent national recycling mark, and marketplaces such as Allegro apply BDO verification strictly.

What a non-EU eye care brand must finish before the first shipment

Four items must be closed before the first palette leaves. None of them can be repaired at the border.

First, appoint the packaging EU authorised representative in writing, covering the packaging obligations in their own right. Second, issue a declaration of conformity for each packaging unit on the Annex VIII template and keep the supporting technical documentation on file. These two are new for most non-EU sellers, and they are why a shipment can be stopped with no defect in the product itself.

Third, complete producer registration and the first declaration in every sale country: LUCID plus a dual-system contract in Germany, the French IDU filing, CONAI in Italy, Ecoembes in Spain, BDO in Poland. Fourth, build the data trail behind the pack, recording material build-up, recyclability grade and EPR data per SKU so a marketplace audit can be answered from one source.

On timing, re-specify the highest-risk item first. Replace the non-separable laminate sachet with a mono-material or easily separated structure, confirm PCR content from the converter's documentation rather than a marketing sheet, and budget the premium on films classed as other plastic. Where a threshold depends on an unadopted implementing act, plan against the conditional date rather than assuming a delay.

FAQs

Sources: European Commission, Directorate-General for Environment - packaging regulation pages； Regulation (EU) 2025/40 - Articles 3(49), 5, 7, 12, 24 and Annex VIII； CONAI - Italian packaging consortium, article-by-article reading of PPWR； Bureau Veritas - PPWR compliance pages and cosmetics packaging practice； PPWR Connect and ppwrobligations.com - Article 7 exemptions and recycled-content thresholds； ZSVR - German LUCID registration and dual-system rate tables； Citeo and Léko - French 2026 annual contribution and IDU filing rules； CONAI and Corepla - Italian contribution rates and registration times； MITECO and Ecoembes - Spanish producer register under Royal Decree 1055/2022； Poland - BDO register, annual declaration and marketplace verification practice