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Article 10 September 2025

Ecodesign for sustainable products regulation

In the cosmetics industry, ecodesign is not limited to environmentally friendly packaging. It is a comprehensive approach that covers all stages of a product’s lifecycle, from design to end-of-life, incorporating essential aspects such as sustainability, efficiency and reduction of environmental impact. The cosmetics sector is facing new requirements with the entry into force of the ESPR Regulation on July 18, 2024. This regulatory framework requires a rethinking of practices to design products in line with European goals. Let’s explore the implications of this regulation and the opportunities it presents.

What is ecodesign ?

Much more than a trend, ecodesign is a systemic approach that integrates social, economic and environmental dimensions at every stage of a product’s life cycle. Its primary goal is to reduce environmental impact while maximizing long-term value. This approach aims to balance performance, technical feasibility, cost management and environmental responsibility to create products that are both innovative, sustainable and responsible. In a context where consumers are increasingly aware of the impact of their choices on the planet, ecodesign has become an essential response to market demands and environmental challenges.

What is the Ecodesign for Sustainable Products Regulation (ESPR) ?

The Ecodesign for Sustainable Products Regulation (ESPR) is a major step forward in the European Union’s environmental policy. Replacing the Ecodesign Directive 2009/125/EC, it extends its scope well beyond energy-related products to almost all physical products, with notable exceptions for food, feed and pharmaceuticals. More ambitious than its predecessor, it introduces strict requirements for sustainability, repairability, circularity and reduction of environmental and climate footprints. For example, it includes a ban on the destruction of unsold products to further improve sustainability across the European Union. Thus, the aim is to promote a circular economy in which products are designed to last, be repaired and recycled efficiently, while minimising their impact on natural resources. In line with the European Green Deal and the Circular Economy Action Plan 2020, the ESPR plays a key role in the EU’s efforts to achieve its environmental and economic goals by 2030.

The ESPR regulation : an opportunity for the cosmetics industry

For the cosmetics industry, the Ecodesign for Sustainable Products Regulation offers new opportunities to strengthen its commitment to sustainability while meeting growing consumer expectations and European regulatory requirements. This framework encourages brands to design products that are more durable, repairable and recyclable, while minimizing their environmental and climate footprint.

In practice, this means several major adjustments :

  • Rethinking formulations and packaging : Brands must prioritize recyclable, reusable or sustainably sourced materials. Innovation in refillable packaging or bottles made from recycled materials will be a key focus to meet the requirements of the regulation.
  • Manufacturing and circularity : Manufacturing processes will need to incorporate energy-efficient practices and reduce waste while ensuring product durability. The repairability of cosmetic tools, such as brushes or containers, could also become a key differentiator.
  • Increased transparency and traceability : Consumers now demand clear information about the sourcing of ingredients, the environmental impact of products and their recyclability. The ESPR encourages companies to adopt environmentally responsible communications to highlight these efforts and build customer trust.

Beyond the challenges, the ESPR represents a strategic opportunity, encouraging brands to position themselves as sustainability leaders, innovators and differentiators in a rapidly evolving marketplace.

Key dates of the ecodesign for sustainable products regulation

  • December 11, 2019 : Adoption of the European Green Deal, a roadmap to make the EU economy more sustainable.
  • March 11, 2020 : Adoption of the Circular Economy Action Plan, promoting a circular and sustainable economy in the EU.
  • March 30, 2022 : Presentation of the proposal for the ESPR under the Sustainable Products Initiative, introducing new ecodesign requirements.
  • June 13, 2024 : Official adoption of Regulation (EU) 2024/1781 on ecodesign, replacing Directive 2009/125/EC.
  • July 18, 2024 : Entry into force of ESPR, establishing specific ecodesign requirements for sustainable products.
  • November 2024 : Creation of the Ecodesign Forum, a collaborative space to develop future ecodesign measures with stakeholder input.
  • April 2025 – January 2030 : Adoption of the first specific ecodesign measures for product groups – under the PSES work plan – following a process of prioritization and in-depth consultation.

Impact for businesses : anticipate and collaborate

The ESPR imposes strict ecodesign and sustainability requirements on European companies. It is essential to keep abreast of regulatory changes and anticipate necessary adjustments, especially for identified priority products.

Companies also have the opportunity to play an active role in shaping these criteria by joining forums such as the European Ecodesign Forum and participating in public consultations. This allows them not only to influence the rules, but also to prepare for their implementation.

It is crucial to raise awareness throughout the supply and value chain within the company, starting today. A coordinated approach across teams is needed, from selecting sustainable materials to ensuring the recyclability of products.

To maximize their resilience, companies can start investing in internal audits and green innovation, turning these regulatory requirements into a driver of sustainable growth.

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