Recycled Packaging in Cosmetics: An Insight into Trends and Environmental Impact

The cosmetics industry is undergoing a green revolution, with recycled packaging emerging as a key initiative to reduce its environmental impact. This article explores the growing interest in recycled packaging in cosmetics, examines industry trends, discusses environmental benefits and associated challenges, and delves into current and future innovations in this evolving field.

Industry Trends In Recycled Packaging

In recent years, consumers have shown increasing concern about the environmental impact of the products they purchase, including cosmetics. This heightened awareness has prompted cosmetic companies to reevaluate their packaging practices and adopt more sustainable solutions. Recycling has become a central focus, with many companies committing to the use of recycled materials in their packaging.

Industry trends reveal a significant rise in the use of recycled materials in cosmetics, including glass, plastics, cardboard, and aluminum. Additionally, companies are exploring alternative options, such as bioplastics and compostable packaging, to further reduce the environmental impact of their products.

Environmental Benefits of Recycled Packaging

The use of recycled packaging in cosmetics provides several important environmental benefits. First, it reduces reliance on virgin natural resources, such as oil, which are needed to produce new packaging materials. By using recycled materials, companies contribute to the conservation of natural resources and minimize waste generation.

Additionally, adopting recycled packaging helps to lower pollution caused by plastic waste. Plastic pollution poses a significant threat to marine and terrestrial ecosystems, with vast amounts of plastic entering seas and oceans annually. By using recycled materials, companies decrease the production of virgin plastic and help address this pressing environmental issue.

Challenges And Obstacles In Adopting Recycled Packaging

While the use of recycled packaging in cosmetics offers numerous benefits, it also comes with challenges. One significant obstacle is the availability and quality of recycled materials. As the demand for recycled materials rises, supply shortages and price increases may occur. Furthermore, the quality of recycled materials may not always meet the stringent standards required for cosmetic packaging, potentially impacting the appearance and functionality of the final product.

Another challenge lies in educating consumers about the importance of recycling and choosing products with recycled packaging. Many consumers are unaware of the environmental impact of their cosmetics consumption and may hesitate to change their purchasing habits. To address this, companies must invest in awareness and education campaigns to encourage the adoption of products with recycled packaging.

Future Innovations In Recycled Packaging Materials For Cosmetics

Despite the challenges, there are many interesting innovations in the field of recycled packaging in cosmetics. Companies are investing in new technologies and processes to improve the quality and availability of recycled materials. For example, there are new recycling methods that make it possible to obtain high-quality recycled materials from sources such as post-consumer plastics and industrial waste.

In addition, there are growing efforts to develop biodegradable and compostable materials for cosmetic packaging. These materials offer an eco-friendly alternative to traditional plastics and can help to further reduce the environmental impact of cosmetics.

Ensuring The Safety Of Recycled Packaging In Cosmetics

Assessing the safety of recycled packaging in cosmetics is a crucial process to guarantee that products remain safe for consumer use. Below are some key steps involved in evaluating the safety of recycled packaging.

1. Analysis of Recycled Materials

Before using recycled materials for cosmetic packaging, it is essential to conduct a thorough analysis of the materials themselves. This may include:

• Source Identification: Knowing the origin of recycled materials is important to ensure that they are not contaminated with harmful substances or pollutants.
• Contamination Testing: Conduct tests to detect the presence of contaminants such as heavy metals, solvents, plasticizer residues, or other harmful chemicals.
• Purity Analysis: Check the purity of recycled materials to ensure they are suitable for use in cosmetic packaging.

2. Regulatory Compliance

Ensure that the recycled packaging meets all regulatory and safety requirements set by the relevant authorities. These requirements may vary depending on the country and region. It is therefore important to be aware of local and international regulations.

Below are the main regulatory references related to packaging:

2.1 Regulation (EC) No 1935/2004 provides for a harmonised EU regulatory framework. It sets out the general principles of safety and inertia for all packaging materials.

The principles laid down in Regulation (EC) No 1935/2004 require that materials shall not:

● release their components into food in quantities that endanger human health;

● result in an unacceptable change in the composition, taste and odour of food.

In addition, the regulatory framework provides:

● special rules for active and intelligent materials (they are not designed to be inert);

● Possibility to take additional EU measures for specific materials (e.g. plastics);

● the procedure for carrying out safety assessments of substances used in the manufacture of packs, involving the European Food Safety Authority;

● Documentation to demonstrate compliance and traceability

2.2 Regulation (EC) No 2023/2006 ensures that it always complies with the requirements for the manufacture of the pack in accordance with the so-called GMP, through:

● Fit-for-purpose locations and staff who are aware of the critical stages of production;

● Documented quality assurance and quality control systems at all times;

● Selection of suitable starting materials for the manufacturing process, taking into account the safety and inertia of the finished articles.

Good manufacturing practices apply to all stages of the entire process, even if the production of the starting materials is covered by other legislation.

2.3 In addition to general legislation, certain packaging – ceramic materials, regenerated cellulose film, plastics (including recycled plastics), as well as active and smart materials – are covered by specific EU measures. There are also other specific rules on certain starting substances used to produce packs.

The most comprehensive measure is the EU regulation on plastic materials and articles, Regulation (EU) No 10/2011, which describes the rules on the composition of such plastic packs, including the establishment of a Union list of substances authorised in the manufacture of plastic packs. The regulation assigns a unique identification number for each substance.

Regulation 10/2011 lays down rules for verifying the conformity of plastic materials and specifications as well as restrictions on the use of these substances, including migration limits, which specify the maximum permitted amount of migration of substances into food. The total migration of substances from a plastic to a food may not exceed 60 mg/kg of food.

3. Evaluation of the Recycling Process

Examine the recycling process used to obtain the recycled materials. An effective and controlled recycling process is essential to ensure the safety of recycled materials used in cosmetic packaging.

• Traceability: Ensure that the recycling process is traceable and well-documented to identify any risks of contamination or errors in the process.
• Supplier Validation: Work with reliable and certified suppliers to ensure the quality and safety of recycled materials.

4. Safety Testing

Conduct specific safety tests to assess the suitability of recycled materials for use in cosmetic packaging. These tests may include:

• Migration Testing: Check whether the chemicals present in the recycled materials can migrate to the cosmetic product and pose a risk to the user’s health.
• Stability Testing: Evaluate the stability of recycled materials over time and under different environmental conditions to ensure that the packaging maintains its integrity and safety throughout the entire life cycle of the cosmetic product.
• Compatibility Testing: Check the compatibility of recycled materials with the ingredients of the cosmetic product to avoid unwanted chemical reactions or alterations in the quality of the product.

5. Continuous Monitoring

Once recycled packaging is introduced, it is important to continuously monitor its safety and compliance with regulations. Carry out regular checks on the quality of recycled materials and manufacturing processes to ensure that cosmetic products remain safe for consumer use.

The Safety Requirements Of Cosmetics

The safety assessment, as specified in Article 10 of the Cosmetics Regulation 1223/2009, must be carried out before the product is placed on the market and must contain information on cosmetic products, such as the quantitative and qualitative composition of the products, the physical and chemical characteristics, the stability, the microbiological quality, as well as impurities, traces, and other useful information about the packaging material.

Have a look at our comprehensive article on Cosmetic Product Safety Report for more details. 

Given that undesirable substances could transfer from the packaging to the product formulation, the so-called “relevant characteristics of the packaging material” must be considered.

Information on the relevant characteristics of the packaging material in direct contact with the product is intended to make an assessment of the potential risks. Therefore, such characteristics could include, for example, these factors:

• Composition of the packaging material, including technical substances such as additives;
• Impurities (unintentional presence in raw materials) that are technically unavoidable;
• Possible transfer of these substances from the pack to the product.

How Important Is Transparency In The Use Of Packaging Materials?

Transparency in the use of packaging materials is crucial. Traces or residues can originate from various sources, including impurities or unintentional presences in raw materials, manufacturing processes, and potential chemical interactions or migrations of substances in the cosmetic product during storage or through contact with packaging materials.

If banned substances are present, evidence of their technical inevitability would necessarily have to be provided. All this is reported in Decision 674/2013, which specifies the guidelines in Annex I of Regulation 1223/2009, in point 3.4.

Recycled Plastic And Cosmetics: Possible Interactions Between Packaging And Product

As we have observed, the combination of packaging materials, the formulation of the cosmetic product, and contact with the external environment can impact the safety of the finished product. Factors such as the interaction between the cosmetic product and the packaging material, or the barrier effect of the packaging, are crucial. The barrier effect refers to the ability of the packaging to maintain the physical-chemical balance of the cosmetic product without altering it.

Formulation-to-packaging interaction studies help estimate the potential transfer of small amounts of substances from the primary packaging material to the product. These evaluations are typically conducted under targeted test conditions, although there are no standard procedures for cosmetic products. A relevant and thorough analysis can be based on knowledge of both the formulation and primary packaging materials, along with expert evaluation.

Reducing Risks With Recycled Packaging

To ensure the “sustainable and safe” combination is truly effective, it is important to carefully design and verify the adequacy of packaging. This includes assessing the compatibility between the product formulation and packaging materials to prevent the migration of harmful contaminants.

If the packaging supplier cannot provide documentation confirming that no substances migrate, it may be necessary to use multi-layer packaging. In this case, the inner layer in direct contact with the product should be made from virgin material.

It is also crucial to remember that a circular economy can only function effectively if products created with recycled materials are both safe and compliant with regulations.

The industry faces several issues in regard to the use of recycled materials in the creation of new products. Whether food contact plastics contain recycled materials or not, they must always respect the overall migration and specific migration limits under Regulation (EU) 10/2011. This piece of legislation includes an authorised Union List of substances for the manufacture of food contact plastics.

Additionally, the European Food Safety Agency (EFSA) has issued guidance to assist stakeholders when manufacturing articles from recycled plastics. The other key EU legislation stakeholders must consider is the new Regulation (EU) 2022/1616 on recycled plastic materials and articles intended to come into contact with foods.

These should be considered in combination with Regulation (EC) 10/2011 and Regulation (EC) 1935/2004, respectively defining migration limits and the legislative framework for packaging.

Safety remains a critical concern in recycling, as it can introduce challenges. While Good Manufacturing Practices (GMPs) ensure that intentionally added substances (IAS) remain within safety limits when producing virgin plastic, GMPs alone cannot address issues arising from the unintended contamination of raw materials due to improper reuse or inefficient recycling technologies.

Problems also arise in identifying plastics and contamination by non-intentionally added substances (NIAS). Difficulties in detecting and removing NIAS can pose potential health risks.

By following the necessary steps and committing to ensuring the safety and compliance of recycled packaging, you can help guarantee that your cosmetic products are both sustainable and safe for the environment and consumers.

Conclusions

Recycled packaging is becoming increasingly important in the cosmetics industry, as companies seek to reduce their environmental impact and address consumers’ growing concerns about sustainability. Despite the challenges, there are many opportunities to innovate and develop more sustainable cosmetics packaging solutions.

Educating consumers about the importance of recycling and using products with recycled packaging is key to driving positive change in the cosmetics industry and protecting the environment for future generations.

If you’re unsure whether your product complies with the regulations we discussed, don’t hesitate to contact us. Our team is here to help you understand all the key aspects you need to consider.