.svg-1.png)
The EU Packaging and Packaging Waste Regulation introduces new conformity, documentation and traceability responsibilities for packaging placed on the EU market.
Combine cosmetic product compliance and PPWR packaging conformity with one experienced compliance partner.
From 12 August 2026, manufacturers must be able to demonstrate packaging conformity through the required technical documentation and an EU Declaration of Conformity.
TRC supports cosmetic companies in preparing for these obligations and maintaining compliance throughout the product and packaging lifecycle.
Cosmetic companies already manage formulations, raw materials, safety assessments, product information files, labels and regulatory changes to ensure cosmetic product compliance and safety as defined under EU 1223/2009..
The PPWR adds another connected compliance layer: packaging components and materials, packaging systems and product links, supplier specifications and declarations, conformity assessment, technical documentation, EU Declarations of Conformity, versioning and packaging changes.
Managing these obligations separately creates duplication, fragmented documentation and an increased risk that product and packaging records no longer correspond.
TRC provides regulatory support for both the cosmetic product and the packaging in which it is placed on the market.
For existing all-inclusive compliance clients, PPWR services can be added to the current TRC service and PRIMS environment.
For new clients, TRC can establish an integrated compliance process covering both product and packaging requirements.
PRIMS Compliance Software provides the structured data and document-management backbone, while TRC performs the regulatory review, conformity support and ongoing compliance management.
Full services including packaging conformity assessment, technical documentation review, EU Declaration of Conformity authoring, and PPWR Authorised Representative under Article 17. We turn complex packaging requirements into a practical, controlled compliance process, so you can act now and stay compliant as requirements evolve.
For existing all-inclusive compliance clients, PPWR services can be added to the current TRC service and PRIMS environment. For new clients, TRC can establish an integrated compliance process covering both product and packaging requirements. PRIMS Compliance Software provides the structured data and document-management backbone, while TRC performs the regulatory review, conformity support and ongoing compliance management.
TRC establishes the applicable legal roles, identifies the packaging portfolio within scope and reviews the information already available. This can include role assessment, initial portfolio review, identification of packaging components and systems, review of supplier specifications and declarations, identification of essential data gaps and practical onboarding instructions. Clients do not need every future PPWR data point before starting.
TRC supports the manufacturer in assessing packaging against the applicable PPWR requirements. This can include review of composition and component information, applicable substance and material restrictions, packaging minimisation, reusable or refillable status where relevant, available evidence and open compliance points. External testing or specialist expertise can be coordinated where necessary.
TRC prepares and maintains the controlled packaging conformity file based on the available information and evidence. The file can include packaging identification, component and system descriptions, specifications and drawings, material and weight information, supplier declarations, conformity assessment records, version history and links to the relevant products and markets.
Once conformity has been demonstrated, TRC can prepare the controlled draft EU Declaration of Conformity for approval and signature by the manufacturer. TRC can manage the declaration workflow, version control and supporting records through PRIMS.
PPWR compliance is not a one-time assessment. TRC can continuously manage packaging changes, supplier-document follow-up, technical-documentation updates, declaration updates, regulatory monitoring, portfolio-status reporting and authority support. This can be combined with TRC continuous cosmetic compliance and Responsible Person services.
Subject to successful onboarding and acceptance of the technical documentation, TRC can act as the manufacturer’s authorised representative for packaging conformity. The service can include document retention, authority cooperation, management of authority requests and maintenance of the mandate and related compliance records. This role is separate from EPR authorised representation.
TRC manages the PPWR process through PRIMS, the cloud-based compliance-management platform.
PRIMS connects packaging components, packaging systems, cosmetic products and SKUs, specifications and supplier documents, technical documentation, conformity status, declarations, versions, changes, responsible legal entities and mandates.
The result is one controlled source of compliance information rather than separate files, spreadsheets and disconnected service providers.
We were there when the EU Cosmetics Regulation was introduced, and have been a trusted compliance partner ever since for cosmetic brands, manufacturers and other stakeholders in the industry.
With the introduction of the PPWR, we expand with an integrated comprehensive service powered by PRIMS to manage PPWR compliance with clarity and confidence.
TRC coordinates the interdependent product and packaging compliance activities through one service.
PRIMS links packaging directly to the products, versions and markets in which it is used.
Shared information and documents are maintained once and reused across relevant products and packaging systems.
Changes can be assessed for their effect on both cosmetic product and packaging compliance.
Current documentation, declarations and version history remain structured and accessible.
TRC starts with the information already available and guides the client through the remaining requirements.
You do not need to complete a large data project before contacting us.
We can begin with your existing packaging specifications, supplier declarations and product portfolio.
We will identify the essential onboarding requirements and propose a practical service approach.