Recyclable, Biodegradable and Refillable: Cosmetic Packaging Claims Outside the Cosmetic Product Safety Report and How to Substantiate Them
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The short answer
A Cosmetic Product Safety Report covers packaging from a safety perspective: the materials in contact with the product, their compatibility and stability, and any migration of substances from the container into the formula. It does not substantiate environmental packaging claims. Recyclable, biodegradable, compostable, refillable and plastic free sit under the Green Claims Code and advertising rules, and each needs its own evidence stating conditions, such as widely recycled in the UK or certified industrially compostable. Vague packaging claims are among the most complained about in beauty.
Key takeaways
- The CPSR treats packaging as a safety question: compatibility, migration and stability in the actual container.
- Environmental packaging claims are outside the safety report and need separate substantiation under the Green Claims Code.
- Recyclable needs a condition: widely recycled, or check locally, and a pump with mixed materials often is not recyclable at all.
- Biodegradable is meaningless without an environment and a timescale, and compostable should say home or industrial.
- Plastic free claims fail when the liner, pump, seal or window is plastic.
- Refillable should mean a refill is actually available, and Extended Producer Responsibility now requires packaging data anyway.
Packaging is where a great deal of beauty's environmental marketing lives, and where a surprising number of brands assume their Cosmetic Product Safety Report has them covered. It does not, or rather it covers something else entirely. Under Regulation (EC) No 1223/2009 and the UK regulation enforced through the Cosmetic Products Enforcement Regulations 2013, the safety report considers packaging as part of the product's safety: what the container is made of, whether it is compatible with the formula, and whether anything migrates from one into the other. Whether that container is recyclable is a different question under a different regime, the Green Claims Code, enforced by the Competition and Markets Authority and mirrored by the Advertising Standards Authority.
This article draws the line and then helps with both sides of it. It explains what the Cosmetic Product Safety Report actually assesses about packaging and why compatibility testing matters more than brands realise, then works through the environmental claims one by one, recyclable, biodegradable, compostable, plastic free, refillable, recycled content and carbon, with the condition each needs to be lawful. It covers Extended Producer Responsibility and why it changes the data you already hold, the microplastics position, a worked example of a carton whose four claims became two better ones, and a checklist for writing packaging claims that survive a complaint.
What does the CPSR assess about packaging?
Part A section 2 covers the physical and chemical characteristics of the materials and the finished product, including the packaging material, and the assessment considers the container the product will actually be sold in. Three questions matter. What is the packaging made of, including the liner, the closure, the pump mechanism and any decoration in contact with the product. Is it compatible with the formula, meaning does the product degrade the container or the container the product, which is why an essential oil rich formula in an unsuitable plastic is a recurring problem. And does anything migrate from the packaging into the product at a level that matters, which is assessed from the material specification and, where necessary, migration data. The packaging also feeds the period after opening: an airless pump supports a longer period than a wide mouthed jar. None of that says anything about what happens to the container after use.
In practice
Tell your assessor the actual pack, including the pump and the liner, not just the bottle. A formula assessed in glass and sold in plastic has been assessed in the wrong container.
Where do environmental packaging claims sit?
Under consumer protection and advertising law rather than cosmetics law. The Green Claims Code sets out that environmental claims must be truthful and accurate, clear and unambiguous, not omit or hide important information, compare fairly, consider the full life cycle and be substantiated. The Advertising Standards Authority applies equivalent principles and has ruled repeatedly on beauty packaging claims. The cosmetic claims criteria also apply where the claim appears on the product, because it is a claim made for a cosmetic. So an environmental packaging claim needs evidence like any other, and that evidence is not in the Cosmetic Product Safety Report; it belongs in the brand's claims table alongside the certifications, specifications and test reports that support it.
The claims, one by one
| Claim | What it needs to be lawful | Common failure |
|---|---|---|
| Recyclable | A statement of where and how: widely recycled, or check locally; the whole pack or the named component | A pump with a metal spring and mixed plastics described as recyclable |
| Recycled content | A stated percentage and which components it applies to | 30 percent recycled implying the whole pack when it is only the bottle |
| Biodegradable | The environment and timescale, with test data to a recognised standard | Biodegradable with no conditions, which is effectively meaningless |
| Compostable | Home or industrial, with certification to a recognised standard | Compostable implying home composting when only industrial facilities work |
| Plastic free | No plastic anywhere, including liners, seals, windows and pump components | A carton described as plastic free with a plastic sachet inside |
| Refillable | A refill actually available and a container designed for it | Refillable where no refill is sold |
| Reusable | A practical second use the consumer will realistically have | Any jar described as reusable |
| Less plastic | A named comparator and a stated reduction | Less plastic than before, with no baseline |
| Carbon neutral packaging | Scope, methodology, offsets and provider | The phrase alone |
| Sustainable packaging | Almost nothing supports this as worded | Used as a heading rather than a claim |
Why recyclable is harder than it looks
Cosmetic packaging is frequently a composite: a bottle of one polymer, a cap of another, a pump with a metal spring, a liner, a label with an adhesive, sometimes a metallised finish. Recyclability depends on whether local facilities accept the material, whether the components separate, and whether the item is large enough to be sorted, which is why small caps and pumps often are not recycled even when their material technically is. Honest claims therefore identify the component and state the condition: bottle widely recycled, pump not currently recyclable, please separate before recycling. That is more words than a brand would like and considerably more credible than recyclable across a pack that mostly is not. Where a brand genuinely has a mono material pack it should say so, because that is a real achievement and a specific one.
Biodegradable, compostable and the microplastics question
Biodegradable is the claim most often made without meaning. Every material degrades somewhere eventually, so the claim is only informative with an environment and a timescale, evidenced against a recognised test standard. Compostable should specify home or industrial, because the two are very different and a consumer with a garden heap cannot process an industrially compostable film. Separately, the EU restriction on intentionally added synthetic polymer microparticles under REACH has changed what may be sold in the EU, banning loose glitter and microbeads from October 2023 and phasing out other cosmetic uses over several years, with Great Britain on a narrower microbead ban and Northern Ireland following the EU. That is a product composition matter rather than packaging, but it sits in the same conversation because brands often raise both together, and the Cosmetic Product Safety Report screens the formula against it.
Ask yourself
Take your pack apart on a desk: bottle, cap, pump, liner, label, carton, any sachet. Now read your packaging claim again. Does it describe all of those, or one of them?
Extended Producer Responsibility changes what you already hold
UK Extended Producer Responsibility for packaging requires obligated producers to collect and report detailed packaging data, including material types and weights, and to pay fees based on what they place on the market, with recyclability assessments influencing those fees. The practical consequence for a cosmetic brand is that the data needed to make an accurate packaging claim is increasingly data the brand must gather anyway. A brand that has compiled material and weight data component by component for its EPR return is a brand that can write an accurate recyclability claim in an afternoon, and one that has not is usually the brand making vague claims, the kind that tips over into greenwashing when it outruns the underlying scientific evidence. Thresholds and obligations depend on turnover and tonnage, so check your position, but treat the exercise as dual purpose.
Does packaging choice affect the safety assessment itself?
More than most brands expect, and in ways that are worth knowing before the moulds are ordered. Compatibility is the first: an alcohol rich formula, a high oil formula or a product containing certain essential oils can soften, craze or leach from an unsuitable plastic, and the assessor will ask for compatibility data where the combination is known to be difficult. Light protection is the second: products containing ingredients that degrade in light are assessed differently in clear glass than in opaque or amber packaging, and a brand that switches to clear bottles for aesthetic reasons may find its stability profile and its period after opening both change. Contamination in use is the third, and the most commercially significant: an airless pump or a tube supports a longer period after opening than a wide mouthed jar, sometimes by six months. And dispensing affects exposure, because a spray produces inhalable droplets that a lotion does not, which changes the exposure model entirely for the same formula. Packaging decisions are therefore safety decisions as well as environmental ones, and product safety under cosmetics regulation should be weighed alongside recyclability when packaging is chosen, since both conversations are cheaper before the pack is chosen.
Refills: the claim that has to be real
Refillable is the packaging claim with the clearest test, because either a refill is available or it is not. Where a brand genuinely operates a refill system, the claim is strong and worth making prominently, but three practical points follow. The refill itself is packaging and must be assessed: a pouch, a cartridge or a bulk container is a pack the Cosmetic Product Safety Report has to consider for compatibility and for the period after opening, and a product decanted by the customer into an older container raises contamination questions the assessment should address, usually resolved with clear directions and a conservative period. The label rules apply to the refill too, including the ingredient list and the Responsible Person address, whatever the customer already has on the original container. And a refill sold as a subscription or in store still needs its own batch coding for traceability. A refillable cosmetic claim, like any other cosmetic claim made about cosmetic products, has to be genuinely true of the system in place rather than aspirational, and the same technical document that governs other environmental claims applies here too. None of this is difficult, and all of it is easier to sort before launch than after a recall question.
A worked example: four claims become two
Secondary and shipping packaging
Brands concentrate on the bottle and forget everything around it, which is where a surprising proportion of complaints and of actual waste sits. Cartons, inserts, void fill, shrink wrap, tissue, stickers, sample sachets, the mailing bag and the tape all count as packaging the brand places on the market, all appear in an Extended Producer Responsibility return, and all are visible to the customer who unpacks them. A brand claiming minimal or plastic free packaging while shipping in a plastic mailing bag with plastic void fill has made a claim its own delivery contradicts, and the customer photographing the unboxing is the one who notices. The two useful exercises are to order your own product and open it as a customer would, listing every item that comes out, and then to ask which of them the product actually needs. Shrink wrap, plastic windows in cartons and decorative inserts are the usual candidates for removal, and removing them is both cheaper and more persuasive than any claim about them.
A checklist for packaging claims
• Name the component each claim applies to.
• State the condition: widely recycled, check locally, industrially compostable.
• Hold the material specification for every component, including liners and pumps.
• Certify compostability to a recognised standard if you claim it.
• Make sure a refill actually exists before saying refillable.
• Give comparatives a named baseline and a number.
• Use your EPR data as the evidence base.
• Keep it all in the claims table with review dates.
• Tell your assessor the real pack so the safety assessment matches what you sell.
Get the packaging right in the safety report and the claims right on the carton
Spectra assesses packaging compatibility, migration and the period after opening as part of every Cosmetic Product Safety Report, and reviews draft artwork including environmental claims against the applicable rules. Certified assessors, 3 to 5 day standard turnaround, Complete Compliance Pack at £295.
Myths we hear
• The CPSR covers my packaging claims. It covers packaging safety; environmental claims need separate evidence.
• Recyclable is a property of the material. It depends on the component, the local facilities and whether the item is sorted.
• Biodegradable is always better. Without an environment and a timescale it means nothing.
• Glass is automatically sustainable. It is heavy to transport and its impact depends on the whole life cycle.
• Nobody checks packaging claims. The CMA and ASA both do, and packaging claims are among the most complained about in beauty.
What to do this week
• Disassemble one pack and list every component and material.
• Compare that list with the claim printed on it.
• Check whether your EPR data already gives you the evidence.
• Remove any component you cannot justify, starting with shrink wrap.
• Rewrite claims to name components and state conditions.
Packaging claims fail because they describe an intention rather than an object. Describe the object, component by component, and the claim becomes both lawful and more persuasive than the vague version it replaces.
Related reading on the Spectra blog
• greenwashing-cosmetic-product-safety-report" target="_blank" rel="noopener">How a Cosmetic Product Safety Report exposes greenwashing
• Natural, organic and chemical free claims in a Cosmetic Product Safety Report
• Clean beauty and the Cosmetic Product Safety Report
• All Spectra articles
Spectra services mentioned in this article
• The Complete Compliance Pack: CPSR, PIF, SDS and SCPN or CPNP (£295)
• CPSR services by product type
• PIF services
• UK and EU Responsible Person
• Contact Spectra
Official sources and legislation
• CMA Green Claims Code
• Advertising Standards Authority
• Extended Producer Responsibility for packaging
• Regulation (EC) No 1223/2009 on cosmetic products, Annex I
• Cosmetic Products Enforcement Regulations 2013
About the author
Spectra Cosmetic Compliance is a UK based cosmetic regulatory consultancy (Spectra Private Limited, Chadwell Heath, Essex) whose certified safety assessors and toxicologists prepare Cosmetic Product Safety Reports, Product Information Files, Safety Data Sheets and SCPN and CPNP notifications, and provide UK and EU Responsible Person cover, for brands selling in the UK, EU, USA, Middle East and Asia. Standard turnaround is 3 to 5 days with a Regulator-Ready Guarantee. Talk to the team on WhatsApp at +44 7468 895676 or at info@spectracomply.com.
Disclaimer: This article is general information, not legal advice. Regulations change and product decisions depend on your exact formulation, claims and market. Have your product assessed by a qualified professional before sale.