What actions should we take when national and European regulations overlap?

Example of those relating to the environment :

AGEC (In France) vs PPWR (In Europe)

CLEAR provides an ESSENTIAL comparative analysis to help anticipate compliance

Amid increasing environmental pressures, cosmetic packaging is subject to a dual regulatory framework:

• The French AGEC Act (Anti-Waste for a Circular Economy, 2020),
• The European PPWR regulation (Packaging and Packaging Waste Regulation), which entered into force in January 2025, will apply from 2026. It replaces Directive 94/62/CE on packaging and packaging waste (PPWD).

While the AGEC Act operates at a national level, the PPWR standardises rules throughout the European Union to reduce waste and accelerate the transition to a circular economy.

1. Towards a reduction in packaging waste

Both frameworks share a common goal: reducing packaging volume at source.

• The AGEC Act provides for the gradual phasing out of single-use plastic packaging by 2040, under the “3R” decree (Reduce, Reuse, Recycle). Between 2021 and 2025, it requires:
  • A 20% reduction in single-use packaging, with at least 50% achieved through reuse,
  • The elimination of “unnecessary” single-use plastic packaging.
• The PPWR aims to reduce packaging waste per inhabitant by 5% by 2035, and by 15% by 2040 (compared with 2018). It also requires optimising the weight, volume, and packaging design.

These measures form the first phase of the circular economy and are completed by requirements on recyclability and the use of recycled materials.

2. Recyclability and recycled content

• The AGEC Act targets 100% recyclable plastics by 2025 and promotes the use of recycled materials in packaging (at least 50% of the packaging’s mass must be recycled for it to be deemed “recycled”).
• The PPWR requires all packaging to be recyclable on a large scale from 2030. Packaging will only be deemed recyclable if it contains at least 70% of recycled material.

3. Reuse and refilling systems

Reflecting a wish to introduce a circular logic, both tests aim to encourage reuse programmes.

• The AGEC Act sets a target of 10% reusable packaging by 2027, with the establishment of deposit-return, refill, and reuse schemes.
• The PPWR establishes minimum reuse rates by 2030, depending on packaging type, and imposes sustainability and traceability criteria for reusable packaging.

4. Implementation of an EPR (Extended Producer Responsibility) sector

The EPR scheme requires manufacturers, importers, and distributors of products that generate waste to finance the prevention, collection, and treatment of this waste, with a view to fostering responsibility among producers throughout the product life cycle, and promote eco-design.

• The AGEC Act reinforces EPR by applying the “polluter pays” principle through accredited eco-organisations (CITEO, etc.) and promoting eco-design.
• The PPWR standardises EPR throughout Europe with mandatory digital reporting, uniform performance criteria, and enhanced traceability.

5. Consumer information and transparency

Improving labelling on reusable packaging is a primary goal to make recycling more effective.

• The AGEC Act requires the use of standardised sorting symbols (Triman and Info-Tri) and clear information on product recyclability and the presence of any hazardous substances. It also bans misleading environmental claims.
• The PPWR introduces unified European labelling indicating composition, recyclability, and sorting instructions, and regulates environmental claims to ensure standardised information throughout Europe.

Conclusion

The AGEC Act and the PPWR are complementary. France, a pioneer with the AGEC Act, has an early lead, while the PPWR supports this momentum by providing stricter standardisation throughout Europe. To that end, the DGPR (Directorate-General for Risk Prevention) is currently working to align AGEC provisions with those of the PPWR.
Cosmetic firms will need to adapt their packaging from 2026 onwards to comply with a more demanding, yet innovation-driven and sustainability-focused, landscape.

CLEAR supports you in implementing these regulations. Contact us today to learn more and set the necessary actions in motion.

Sources

Ministry for Ecological Transition-Anti-Waste for a Circular Economy Act-Loi anti-gaspillage économie circulaire

European Commission-Packaging Waste Regulation-Packaging & Packaging Waste Regulation-European Commission

Cosmetics Europe-Packaging and Packaging Waste Regulation (PPWR)-
Packaging and Packaging Waste Regulation (PPWR)-Cosmetics Europe

Cosmed-Timeline of your obligations: AGEC Act and Cosmetic Regulation-Calendrier de vos obligations: loi AGEC et règlementation cosmétique-Cosmed

ECHA-Understanding the Packaging and Packaging Waste Regulation-Understanding the Packaging and Packaging Waste Regulation-ECHA

L’usine nouvelle-Talk Zero impact Packaging – from the AGEC to the PPWR: how to find your way around and remain compliant Talk ZERO IMPACT PACKAGING-DE L’AGEC AU PPWR: COMMENT S’Y RETROUVER ET RESTER CONFORME