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Digital Product Passport for Cosmetics — Requirements, Timeline and Preparation

Digital Product Passport for cosmetics: what the EU requires of DPP for cosmetic products. ESPR, INCI data, sustainability information and the expected timeline from 2028 onwards.

Author: myDPP Team

Digital Product Passport for Cosmetics — Requirements, Timeline and Preparation

The cosmetics industry is heading into a fundamental shift in product transparency. With the ESPR (Ecodesign for Sustainable Products Regulation), the EU has built the legal framework to introduce Digital Product Passports (DPP) for nearly all physical products — cosmetics and personal care included. For a sector that already lives with strict labelling rules (INCI lists, safety assessments, batch traceability), the DPP adds a new dimension: digital, machine-readable product data that spans the entire lifecycle.

This article explains what the Digital Product Passport means for cosmetics companies, which data requirements are taking shape, when the obligation is likely to arrive, and how manufacturers, brand owners and importers can prepare.

If you need a general introduction to the topic first, start with our foundational guide: Digital Product Passport in 15 Minutes.

Why cosmetics matter for the DPP

The cosmetics and personal care sector generates over EUR 90 billion in annual revenue in the EU alone. At the same time, it sits at the centre of ecological and health debates:

  • Packaging intensity — cosmetic products carry a high packaging volume relative to product content. Packaging is often made of material mixes that are difficult to recycle.
  • Ingredients under scrutiny — concerns about microplastics in cosmetics, PFAS (per- and polyfluoroalkyl substances) and other substances of concern keep growing.
  • Greenwashing risk — terms like “natural”, “sustainable” or “eco-friendly” are frequently used without a verifiable data basis. The EU Green Claims Directive targets exactly this problem.
  • Complex supply chains — raw materials (essential oils, plant extracts, minerals) are sourced from dozens of countries with differing social and environmental standards.

The DPP aims to bring transparency here — not through more marketing claims, but through verifiable, structured data at the product level.

Legal framework — ESPR and the Cosmetics Regulation

Unlike batteries, which have their own regulation (2023/1542) with an explicit battery passport obligation, the DPP for cosmetics will most likely be governed through the ESPR (Regulation (EU) 2024/1781). The ESPR empowers the European Commission to adopt delegated acts for individual product categories that set out specific DPP requirements.

In parallel, the EU Cosmetics Regulation (EC) No 1223/2009 already imposes extensive requirements on labelling, safety assessment and CPNP notification (Cosmetic Products Notification Portal). The DPP for cosmetics will not replace these existing requirements — it will complement them and make them digitally accessible.

Key regulatory developments at a glance:

  • ESPR — the framework regulation for DPP, in force since July 2024.
  • EU Cosmetics Regulation (revision) — the Commission is working on an update that could strengthen digital labelling, among other things.
  • Green Claims Directive — will regulate environmental claims on products and may link directly to the DPP.
  • Packaging and Packaging Waste Regulation (PPWR) — sets requirements for packaging data that could feed into the DPP.

What data will the cosmetics DPP contain?

The final data requirements depend on the delegated acts, which have not yet been published for cosmetics. Based on the ESPR structure, the existing Cosmetics Regulation and the Commission’s prioritisation studies, the likely data requirements can already be anticipated:

Ingredients and composition

  • Full INCI list (International Nomenclature of Cosmetic Ingredients) in machine-readable format.
  • Concentration ranges for substances under regulatory scrutiny.
  • Information on substances of concern as defined by the ESPR.
  • Data on nanomaterials, where present.
  • Origin of key ingredients (e.g. palm oil, shea butter, essential oils).

Packaging data

  • Material composition of the packaging (primary, secondary and transport packaging).
  • Recyclability of the packaging under PPWR criteria.
  • Share of recycled material in the packaging.
  • Packaging weight relative to product content.

Environmental data

  • Carbon footprint of the product (Product Carbon Footprint).
  • Water consumption in production.
  • PEF indicators (Product Environmental Footprint), once methodologically defined.
  • Information on the product’s biodegradability after use.

Shelf life and use

  • Best-before date or PAO (Period After Opening) indication.
  • Recommended amount and frequency of use.
  • Disposal instructions for product and packaging.

Conformity and safety

  • Reference to the safety assessment under the Cosmetics Regulation.
  • CPNP reference number.
  • Certifications (e.g. Cosmos, Natrue, Ecocert), where applicable.
  • EU conformity information.

Identification and traceability

  • Unique product identifier (likely based on GS1 standards).
  • Batch number and link to the manufacturing batch.
  • Data carrier (QR code or GS1 Digital Link) on the packaging.

Timeline — when does the DPP for cosmetics arrive?

Unlike the battery passport, whose timeline is clearly defined, there is no binding deadline for cosmetics yet. A realistic assessment:

  • 2025-2027 — the European Commission runs prioritisation studies and prepares delegated acts for the first product categories under ESPR (textiles, electronics).
  • 2027-2028 — drafting of the delegated acts for cosmetics and personal care, industry consultations and impact assessments.
  • 2029-2030 — likely entry into force of the DPP obligation for selected cosmetics categories.

An important point to understand: the ESPR foresees that delegated acts for a wide range of product categories should be adopted by 2030. Cosmetics will probably not be in the very first wave (batteries and textiles come first), but not in the last one either.

Companies that only start moving once the delegated act is published will end up under time pressure. Experience from the Battery Regulation shows that the lead time from adoption to obligation can be short.

Specifics for the cosmetics sector

INCI data as a starting point

Compared with many other industries, the cosmetics sector has an advantage: INCI lists are already standardised and mandatory. This means part of the composition data required for the DPP already exists in structured form. The challenge lies in extending this data with environmental and supply chain information.

High SKU counts and short product lifecycles

Cosmetics companies often carry hundreds or thousands of SKUs, with frequent product launches and limited editions. An efficient DPP process must therefore be highly automated, so that passport creation does not become a bottleneck.

Brand diversity and contract manufacturing

Many cosmetic products are made by contract manufacturers. Brand owners must ensure they receive the required data from their manufacturing partners. A clear data-exchange agreement is essential here.

Proximity to consumers

Cosmetic products are used directly by end consumers. The DPP therefore also offers an opportunity: transparent product data can strengthen consumer trust, especially for brands built on sustainability and clean beauty.

Preparation — 5 steps for cosmetics companies

1. Take stock of your existing data

Identify which of the anticipated DPP data already exists in your systems. INCI data, safety assessments and CPNP information form a solid basis. Typical gaps appear in environmental data (carbon footprint, water consumption) and in detailed packaging data.

2. Systematise supply chain data

Start requesting structured data on origin, environmental metrics and composition from raw material suppliers and contract manufacturers. The earlier you begin this process, the smoother later DPP creation will be.

3. Digitise packaging data

The PPWR will impose packaging data requirements independently of the DPP. Use the opportunity to capture and structure packaging data now, since it will feed directly into the DPP.

4. Review your IT infrastructure

Evaluate whether your existing systems (ERP, PIM, PLM) can represent the DPP data or whether a dedicated DPP platform is needed. Solutions like myDPP are designed to aggregate data from multiple sources and generate compliant Digital Product Passports.

5. Launch pilot projects

Select 3-5 representative products and create a pilot DPP. This process reveals where data gaps exist, which processes need adjusting, and how much effort later scaling will require.

Frequently asked questions (FAQ)

Does the DPP replace existing cosmetics labelling (INCI, PAO)?

No. The Digital Product Passport does not replace the physical labelling on the packaging. It adds a digital, machine-readable dimension. INCI lists, PAO symbols and other mandatory information remain on the packaging. The DPP makes this information additionally available in digital form and enriches it with further data.

Does the DPP also apply to small cosmetics brands and handmade products?

The exact thresholds will be set in the delegated acts. It is conceivable that small-volume products or handmade cosmetics will receive simplified requirements. The ESPR in principle allows SME relief to be granted. Even so, smaller companies should prepare, as the underlying obligation is likely to be broadly framed.

What role does the Green Claims Directive play?

The Green Claims Directive will likely require that environmental claims on products be backed by verifiable data. The DPP is a natural vehicle for this data. Companies that maintain a compliant DPP are automatically better positioned to meet the requirements of the Green Claims Directive.

Does every product variant (e.g. different shades) need its own DPP?

That depends on whether the DPP-relevant data differs between variants. If two lipsticks have different ingredients or packaging materials, they need separate DPPs. Variants that differ only in non-DPP-relevant attributes (e.g. label language) could be grouped under a shared passport. The final rules will be clarified by the delegated acts.

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