Cosmetics companies continue to elevate the bar for packaging with innovative designs, material choices and protective elements. But while aesthetic factors drive many packaging decisions, global regulations that dictate requirements for packaging and call for brand owner responsibility for its disposal are becoming increasingly important considerations.
Package Design Requirements
As individual countries continue to pass packaging legislation, a system that’s acceptable in one jurisdiction may not be in another. To ensure compliance across borders, companies should develop a design protocol that guides packaging designers and engineers on the optimal choices for broad acceptance.
• Materials Matter. While metallic hot stamps, laminates and glossy coatings are common in paperboard cosmetic packaging, for greater acceptance in recycling systems, paper with 95% fiber content remains the best choice. For glass packaging, clear, brown or green are most easily recyclable. When utilizing plastic, clear, green or very light blue PET or unpigmented HDPE are the preferred options; whatever the resin choice, it should be used for all components of the container. Similarly, with metals, it’s best to use the same material throughout, ideally all aluminum or steel.
• Recycled Content Credits. A number of countries and local governments incentivize the use of recycled content. For example, French packaging producer responsibility organization (PRO) Ecoemballages offers a fee reduction for recycled content in paperboard while Denmark imposes lower packaging taxes for recycled content in paperboard and plastic. Another PRO, Éco Entreprises Québec, also provides discounts for recycled content in printed materials and is considering expanding the discount to other materials.
• Excessive Packaging. Many cosmetic products are subject to empty space and layer requirements. In Japan, a general limit of 40% free space applies to most cosmetics primary packaging. Cosmetic products on the China market are subject to the mandatory Excessive Packaging Regulations, which limits the empty space ratio to 50% or less for products with a net content greater than 50ml or 50g. South Korea sets limits on the amount of empty space and number of layers a cosmetic package may have. And Canada restricts the sale of prepackaged products that may reasonably mislead a consumer about the quantity of the product.
EPR Fees Add Up
As the number of jurisdictions worldwide implementing Extended Producer Responsibility (EPR) continues to grow, so do the fees cosmetic companies must pay for the disposal of their packaging. The idea behind EPR is to make producers responsible for the cost of recycling it—ideally, incentivizng companies to make package design and material choices that are less harmful to the environment.
• High-Cost Choices. Since fees are based on the packaging’s material and weight, the selection of materials can have a big impact on the amount a company pays. Generally, fees are higher for those materials that are more difficult to recycle. To reduce their obligations, companies should compare the material fees published by the PROs where they sell to determine if suitable, less costly, alternatives could be incorporated into their designs.
• Don’t be a disruptor. Some jurisdictions penalize companies for contaminating the recycling stream with packaging that lowers the value of the material collected. In France, for example, a “disruptor” fee of 50% is imposed on glass packaging with ceramic or porcelain caps or a PET bottle with any aluminum (even on a label). In Canada, while there’s currently no fee penalty, companies must now report disruptor plastics—PVC, PLA, PHA, PHB, non-coded rigid plastics and multi polymer or blended plastics.
Mark It Right When Marketing
Last fall, the Federal Trade Commission (FTC) published a revised version of its Guides for the Use of Environmental Marketing Claims. These guides aim to prevent consumers from being misled by environmental claims through the following principles:
• Avoid Broad Statements. General environmental benefit claims such as “eco-friendly” or “green,” or imagery that conveys far-reaching environmental benefits should be avoided. Instead, use clear qualifying language that limits the claim to a specific benefit or benefits.
• Recycling Claims. Language used in recyclable claims must reflect the availability of recycling facilities for consumers or communities where an item is sold or marketed. If recycling programs for the packaging are available to a “substantial majority” (60% or more) of consumers or communities, then no qualifying text is required. If recycling programs for packaging are available to less than a substantial majority (less than 60%), marketers should qualify the claim based on the level of access consumers have to recycling facilities. For example, “This package may not be recyclable in your area” or “This package is recyclable only in the few communities that have appropriate recycling facilities.”
• Be in the Loop. Under FTC Guidelines, the use of the Möbius Loop (three chasing arrow symbol) alone, with no qualifying text, constitutes a claim that the packaging and product are made of 100% recycled materials and are universally recyclable. Unless all of these claims can be substantiated, qualifying text should accompany the Möbius loop.
Whether products are packed in bottles or tubes, plastic or glass, conveying a brand’s personality through packaging is critical in the battle for consumer attention, and dollars. But since the trend towards environmental regulation of packaging shows no signs of slowing down, companies need to consider a number of other factors in the design process to ensure compliance—and minimize packaging’s impact. Because waste isn’t pretty.
Victor Bell is president of Environmental Packaging International (EPI), a consultancy specializing in global environmental packaging and product stewardship requirements. More info: www.enviro-pac.com