As the 2020s dawn, personal care packaging faces the prospect of legislated Extended Producer Responsibility (EPR) regimes. These are based on a “producer pays” principle, while seeking to reward innovation away from less sustainable formats.

The current status and future course of this important development are tracked and analyzed in depth in The Impact of EPR Legislation on the Packaging Industry to 2032 – a new expert study from Smithers.

The campaign is led by the EU, with multiple jurisdictions around the world monitoring and evaluating the suitability of its policies for their national markets. Smithers analysts identify the following as directly applicable to personal care and beauty brand owners:

Product bans are the most straightforward option for lawmakers, but the only packaging material currently targeted in Europe is expanded polystyrene (EPS). And plastic cotton swabs have been banned in Europe since July 2021, via the Single-Use Plastics Directive. The same legislation imposes package labeling, consumer education and disposal requirements on sellers of personal care and cosmetic wipes.

Plastic taxes and surcharges seek to push brands to substitute for harder-to-recycle polymeric materials, where the scope for personal care is limited. One option to maximize recyclability is to ensure that caps and closures are from the same family of plastics as the base unit, to allow them to be recycled together. The EU will require all beverage caps to be attached to their container from 2024, a step that could be extended to other products in the future.

There are several mandates to include post-consumer recycled (PCR) content in packaging. The first cycles of these polyethylene terephthalate (PET) beverage bottles target, but will again be extended to other types of containers over time. Several personal care lines already use PCR, up to 100% by weight, but the challenge will be to find adequate supplies of polyolefins (HDPE/PP).

For aesthetic and organoleptic reasons, beauty products generally require higher quality PCR resins – authorized for food contact. Currently, only around 10% of PCR resins are approved for food contact, and volumes of PP and HDPE are particularly low (~3%), which means there will be competition for these premium materials and price premiums.

Some beauty brands were the first to use bioplastics, like polylactic acid (PLA). However, these are falling out of favor as EPRs prioritize high-volume recycling, where PLA can contaminate recovered stocks of more common polymers and adversely affect the material performance of all PCR resins.

The Impact of EPR Legislation on the Packaging Industry to 2032 is available from Smithers.


Summary of the main EU financial and fiscal initiatives that affect packaging. Source: Smithers

John Nelson is an award-winning editor and journalist working in Smithers’ market reporting and consulting businesses. Here he covers market and technology developments in multiple technical and business segments; including paper, packaging, durability, printing, nonwovens, rubber and tires.

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