French EPR for Cosmetics & Beauty brands.

Cosmetics brands selling in France face two parallel regulatory layers: EPR (packaging end-of-life — Citeo, Léko, Adelphe) and EU cosmetics regulation (Regulation EC 1223/2009 — CPNP notification, Responsible Person). They are independent but operationally adjacent. This page covers the EPR side; we coordinate with cosmetics-specialist Responsible Persons where needed.

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EPR streams typically in scope for Cosmetics & Beauty

Household packaging

Citeo (general) or Adelphe (often relevant for glass-heavy cosmetic packaging — perfume bottles, premium jars)

All cosmetics packaging placed on the French consumer market is in scope. Includes outer cartons, jars, bottles, tubes, blister packs.

Graphic paper

Citeo or Léko

Printed product leaflets, marketing inserts, brochures distributed in France above the de-minimis threshold.

Adjacent regulatory layers (not EPR — for context)

Beyond EPR, Cosmetics & Beauty brands face additional French and EU regulatory requirements. We list them here so you can see the full compliance map — but these are NOT covered by our EPR mandataire scope. We coordinate with specialists for these layers.

CPNP (Cosmetic Product Notification Portal)

Every cosmetic product placed on the EU market must be notified on the European Commission’s CPNP database before sale. This is separate from EPR and handled by your Responsible Person (RP).

Responsible Person (Article 4 of Regulation EC 1223/2009)

A natural or legal person established in the EU must be designated as Responsible Person for each cosmetic product. This is NOT the same as the EPR mandataire — the cosmetics RP handles product safety; the EPR mandataire handles packaging end-of-life.

INCI labelling

Ingredient labelling in French + English on consumer packaging is mandatory. This is product-conformity law, distinct from EPR labelling (Triman + Info-tri).

PPWR Article 6 (recyclability classes from 2030)

Cosmetic packaging that uses complex laminate films, mixed plastic-glass-metal compositions, or non-recyclable closures faces eco-modulation maluses from 2030 and Grade C ban from 2035. Plan redesign now.

Frequently asked questions

Does Adelphe specifically cover cosmetics packaging?

Yes, for premium glass-heavy formats (perfume, luxury skincare). Adelphe historically served wine, spirits and pharma; cosmetics with glass packaging often register through Adelphe rather than Citeo for the simplified administrative interface. Citeo and Léko also accept cosmetics. The choice depends on packaging composition and operational preference.

My Responsible Person already handles French market access. Why do I need a separate EPR mandataire?

The Responsible Person handles product-side compliance under cosmetics regulation (product safety, CPNP notification, post-market surveillance). The EPR mandataire handles packaging-side compliance under environmental law (Citeo/Adelphe registration, eco-contribution, IDU). They are different legal roles under different regulations, with different ministries supervising. Most RPs do not provide EPR; most EPR mandataires do not provide RP services.

Refill packaging vs single-use — does PPWR change anything?

Yes from 2030. PPWR Article 26 sets reuse targets including for certain cosmetic formats (HORECA take-away applies less to cosmetics directly, but reusable packaging targets phase in for other categories). Cosmetics brands with refillable systems benefit from eco-modulation bonuses already today (Citeo and Adelphe grids reward reusable formats).

Do mini / sample sizes count for EPR?

Yes. Any cosmetic product placed on the French market is in scope of packaging EPR, including miniatures, samples and travel sizes. Free promotional samples are also in scope (the trigger is placing on the market, not invoicing).

French EPR for Cosmetics & Beauty brands.

EPR streams typically in scope for Cosmetics & Beauty

Adjacent regulatory layers (not EPR — for context)

Frequently asked questions

Related

Sources & references