Beauty and cosmetics are already part of the European discussion around the future of product information.
In 2024, the European Commission’s Joint Research Centre identified cosmetics among eleven final-product groups with potential for future action under the Ecodesign for Sustainable Products Regulation. The assessment considered environmental impact, improvement potential, market relevance and existing policy coverage.
While cosmetics were not included among the priority final products in the first ESPR Working Plan, their evaluation shows how the sector could become relevant as the European product framework continues to develop.
Beauty companies also start from a substantial existing information base. They already manage regulated data covering ingredients, product safety, responsible operators, manufacturing, traceability and packaging. The opportunity is to connect these records at product level and make them usable across compliance processes, internal systems and customer-facing channels.
A Digital Product Passport can provide the infrastructure for this connection, linking a product identity with structured information and defining how different stakeholders access it.
The Ecodesign for Sustainable Products Regulation establishes the European framework through which ecodesign and product-information requirements can be introduced for a broad range of physical products.
The Joint Research Centre’s 2024 study identified cosmetics as a potential product group for future ESPR action. However, the study was preparatory and did not bind the European Commission. Cosmetics were not subsequently included among the priority final products in the first ESPR Working Plan for 2025–2030.
No delegated act currently defines these elements for beauty and cosmetics. The sector therefore has no confirmed DPP compliance date or mandatory dataset, but it has already been considered within the European technical assessment of potential ESPR priorities.
The sector already operates under detailed product-information and safety requirements.
Under the EU Cosmetics Regulation, companies must manage information and processes including:
The existing labelling framework covers information such as the Responsible Person’s name and address, nominal content, minimum durability or period after opening, precautions, batch reference, product function and ingredients.
A future DPP would not automatically replace the Product Information File, safety assessment, CPNP notification or physical labelling requirements. It could instead create a structured connection between these existing information sources and a persistent product identity.
No mandatory DPP dataset has been adopted for beauty products. Any list of potential information should therefore be treated as a preparation framework, not as a confirmed legal requirement.
Relevant information domains could include:
Not all this information should necessarily be publicly accessible. An ingredient list may be intended for consumers, while an exact formulation, safety documentation or commercially sensitive supplier information may need to remain accessible only to authorised parties.
Access rights are therefore an important part of preparing a beauty DPP. Companies need to distinguish between public information, data intended for authorities and confidential records available only to specific users.
Beauty products often combine several packaging components, including bottles, jars, pumps, caps, applicators, labels, inserts and secondary cartons. Each component can involve different materials, suppliers and regulatory information.
The Packaging and Packaging Waste Regulation, or PPWR, has applied since 12 August 2026 and introduces phased sustainability, recyclability, labelling and packaging-management requirements.
The PPWR and the ESPR remain separate regulatory frameworks. A Digital Product Passport does not replace packaging compliance, and packaging data should not be confused with future product-specific DPP requirements.
However, companies can build a shared operational foundation. Connecting each product with its packaging components, material specifications and suppliers makes it easier to update information, manage evidence and respond to requirements across different regulations and markets.
A beauty Digital Product Passport could also connect regulated product information with the information and services offered to consumers.
Through a QR code or another data carrier, brands could provide access to content such as:
These experiences should remain connected to governed product data. The objective is not to create a separate marketing page containing manually reproduced information, but to ensure that consumer-facing content remains consistent with the underlying product records.
This becomes particularly relevant as environmental and product-related claims face greater scrutiny. Information presented through a DPP still needs to be accurate, supportable and aligned with the evidence held by the company.
Beauty companies do not need to predict the final regulatory dataset to begin improving how product information is managed.
They can already take several practical steps.
Identify where ingredient, safety, packaging, supplier, batch and product information is currently stored, including spreadsheets, regulatory platforms and internal business systems.
Establish which teams, suppliers and partners are responsible for creating, validating and updating each type of information.
Ensure that formulations, SKUs, packaging components, suppliers and production references can be reliably linked to the correct product.
Separate information intended for consumers from data required by authorities, business partners or authorised internal users.
Identify which documents support product, ingredient and environmental claims and establish how that evidence is maintained when products or formulations change.
A first project can begin with a defined product range, but the structure should be designed to extend across categories, markets and future collections.
The selected infrastructure should allow data to be exported, updated and integrated with existing regulatory, product and commerce systems. This reduces the risk of creating a static solution that cannot adapt when product-specific requirements are adopted.
Beauty and cosmetics companies already manage highly regulated information about product identity, safety, ingredients, manufacturing and packaging.
The operational challenge is connecting information that currently sits across different teams, documents and systems.
Preparing for Digital Product Passports therefore begins with product identity, structured data, clear responsibilities and reliable system connections. These foundations can already improve regulatory processes and the customer experience while preserving the flexibility needed to respond to future requirements.
Renoon supports beauty and cosmetics companies in structuring product and packaging data, defining access rights, connecting existing systems and creating scalable Digital Product Passport processes.
Talk to our team about preparing your beauty products for Digital Product Passports.
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