Digital Product Passports are creating a new framework for structured and accessible product information across the EU. For beauty and cosmetics, no sector-specific DPP requirement or compliance date has yet been adopted.
Cosmetic products are already subject to extensive EU requirements covering product safety, ingredients, responsible persons, product information and labelling. At the same time, the ESPR and other EU legislation are expanding the use of structured digital product information across the Single Market.
What is the Digital Product Passport for beauty and cosmetics?
A Digital Product Passport is a structured digital record connected to a physical product through a unique identifier and data carrier. Depending on the applicable product legislation, it can provide access to information on product identity, composition, origin, environmental performance, safety, use and end-of-life.
For cosmetics, the EU has not yet adopted product-specific DPP requirements defining mandatory data, granularity, data carrier rules or a compliance date. DPP obligations are introduced progressively through product-specific legislation, and cosmetics are not currently included among the priority product groups of the ESPR Working Plan 2025–2030.
Beauty and cosmetics regulatory framework
Beauty products already operate within a substantial product information and compliance framework. A future DPP could therefore introduce an additional digital layer for data that companies already manage, rather than representing a requirement that has already been defined.
COSMETICS REGULATION (EC) 1223/2009
In force
Sets the core safety, product information and labelling requirements for cosmetic products sold in the EU
ESPR (EU) 2024/1781
In force
Establishes the EU framework for ecodesign requirements and Digital Product Passports
BEAUTY-SPECIFIC DPP
Not yet adopted
No mandatory dataset or compliance date currently established
The current Cosmetics Regulation requires cosmetic products placed on the EU market to comply with requirements covering safety, responsible persons, product information, ingredients and labelling.
Beauty products within the regulatory scope
Under the Cosmetics Regulation, a cosmetic product is a substance or mixture intended to come into contact with external parts of the human body, teeth or oral mucous membranes mainly for cleaning, perfuming, changing appearance, protecting, keeping them in good condition or correcting body odours.
PRODUCTS COVERED CAN INCLUDE
- Skincare products
- Makeup and colour cosmetics
- Haircare products
- Fragrances and perfumes
- Personal care products
- Nail products
- Oral care cosmetics
- Sun care products
Product data already required for cosmetics
Cosmetics companies already manage significant product-level information under Regulation (EC) No 1223/2009. This provides an existing data foundation that can be structured across compliance and future digital product information systems.
PRODUCT IDENTIFICATION
Product identity, function and relevant product information.
INGREDIENTS
Ingredient information and applicable restrictions, including the required ingredient list.
RESPONSIBLE PERSON
Identification and address of the responsible person established in the EU.
SAFETY
Product safety information and documentation supporting compliance.
LABELLING
Nominal content, durability information, precautions for use, batch identification, product function and ingredients, where applicable.
CLAIMS
Information supporting product claims and ensuring they do not attribute characteristics or functions the cosmetic does not possess.
DPP data carrier and Registry
The Digital Product Passport must be connected to a persistent unique product identifier through a data carrier.
The EU DPP framework connects products to digital information through unique identifiers and data carriers. Product-specific legislation determines the exact requirements that apply to each category. The EU Digital Product Passport Registry is already operational, providing the central infrastructure for registering DPP identifiers and associated metadata, while the underlying product information remains decentralised.
If DPP requirements are introduced for cosmetics in the future, their implementation would need to follow the applicable EU DPP framework and the specific requirements established for the product category.
Beauty packaging and digital product information
The Packaging and Packaging Waste Regulation (PPWR) introduces additional requirements relevant to cosmetics packaging, covering areas including recyclability, recycled content, packaging minimisation, substances of concern and harmonised labelling.
The Regulation also introduces the use of QR codes and other standardised, open digital data carriers for certain packaging information and requires digital marking for packaging containing substances of concern according to methodologies to be established by the Commission. For beauty brands, product and packaging information therefore increasingly need to be managed as connected but distinct regulatory data layers.
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