A beauty range is rarely one kind of product. A cream jar, a pack of makeup remover wipes and a rechargeable styling tool sit in the same catalogue, and each one answers to a different producer register.
Choosing EPR software for cosmetics brands comes down to two questions. Can it model a pack that has six separate parts, and how many of your four registers will the provider actually take on. Six tools are ranked below on both.
One beauty catalogue can put you in four separate registers
Most compliance guides treat extended producer responsibility as one duty. For a beauty brand it is four, and they do not share a registration, a fee basis or a deadline.
Lorax EPI, one of the six tools below, puts the consequence plainly on their own registration page. Each waste type, they write, "typically requires separate registrations", and their job is to coordinate those parallel processes so nothing is missed.
That is a competitor describing the problem this page is about.
Packaging is the register every beauty brand lands in
Every jar, tube, pump, carton and mailer you place on a market counts as packaging, so packaging is the one register nobody in beauty avoids.
It is also the one where the fee is calculated from the weight and material of each part, which is why the rest of this page keeps coming back to how well a tool models a pack.
Wet wipes pay for litter rather than for recycling
Makeup remover wipes, cleansing wipes and baby wipes are not just packaging. The Single-Use Plastics Directive, Directive (EU) 2019/904, lists "wet wipes, i.e. pre-wetted personal care and domestic wipes" as a single-use plastic product in its own right.
Two duties follow, and they are different in kind from a packaging fee.
- A marking on the pack. Wet wipes sit in Part D of the annex, alongside sanitary towels, tampons and tampon applicators, so the pack has to carry a marking about the plastic in the product and how to dispose of it. The marking rules put it on the sales and grouped packaging, and drop it for packaging with a surface area under 10 cm².
- A fee that pays for litter. Wipes fall under Article 8(3), where producers cover awareness raising, the cost of "cleaning up litter resulting from those products and the subsequent transport and treatment of that litter", and the cost of data gathering and reporting. The directive does not require separate collection for wipes at all.
So the wet wipes producer duty is not a recycling fee with a different number on it. It pays for cleaning wipes out of the environment, which means the money follows a different formula and a different national body from your packaging fee.
A hair dryer makes you an electronics producer
Put an electrical device in your range and you become a producer of electrical and electronic equipment.
The WEEE Directive, Directive 2012/19/EU, sorts a beauty device into category 5, "small equipment (no external dimension more than 50 cm)", and its indicative list names "electric shavers" and "appliances for hair and body care" outright.
That covers hair dryers, straighteners, curling tongs, electric shavers, electric toothbrushes and most at-home devices. The WEEE categories decide which register you join, and the registration is separate from your packaging one even in the same country.
The battery inside the device is counted on its own
A rechargeable device brings a fourth register with it. Under the EU Batteries Regulation, Regulation (EU) 2023/1542, Article 55 sets up a register of producers and Article 56 sets the producer responsibility, and a portable battery sealed inside a styling tool still counts.
One design rule is worth knowing before your next product brief. From 18 February 2027, Article 11 requires portable batteries to be "readily removable and replaceable by the end-user", using commercially available tools rather than specialised or proprietary ones.
Beauty gets a genuine carve-out here. Article 11(2)(a) covers appliances "specifically designed to operate primarily in an environment that is regularly subject to splashing water, water streams or water immersion".
Those appliances may restrict battery removal to independent professionals, and only where user and appliance safety require it.
An electric toothbrush or a wet-shave razor can qualify. A hair dryer cannot.
Your cream jar counts as contact-sensitive packaging
This is the detail most beauty brands find surprising, and it moves a real number on your packaging.
What contact-sensitive means in the regulation
The PPWR, Regulation (EU) 2025/40, defines contact-sensitive packaging in Article 3(49) as packaging "intended to be used for products falling within the scope of" a listed set of regulations. One of the regulations on that list is Regulation (EC) No 1223/2009, the Cosmetic Products Regulation.
Cosmetics are therefore in the same recycled-content category as food packaging and medical devices. Not by analogy, by name.
The four buckets and where your pack sits
Article 7 sets four minimum recycled-content percentages for the plastic parts of packaging, and contact-sensitive packaging gets the two lowest.
| Plastic part of packaging | From 2030 at the earliest | From 2040 |
|---|---|---|
| Contact-sensitive, PET as the major component | 30 % | 50 % |
| Contact-sensitive, plastics other than PET | 10 % | 25 % |
| Single-use plastic beverage bottles | 30 % | 65 % |
| All other plastic packaging | 35 % | 65 % |
Read the dates carefully. Article 7(1) applies from 1 January 2030 or three years after the relevant implementing act enters into force, whichever is later, and the figures are an average per manufacturing plant and year rather than a per-item test.
One product can carry two different numbers
Most beauty primary packaging is polypropylene or high-density polyethylene, which lands in the 10 % bucket. That is the lowest figure in the whole regulation.
Your secondary packaging does not follow it. The plastic window in a carton, the shrink wrap on a gift set and the moulded tray inside a boxed set are not intended for the product's contact, so they sit in the general 35 % bucket instead.
The result is one SKU carrying two obligations at once, and a fee that can be modulated on recycled content under Article 7(7). That is exactly the sort of split a spreadsheet loses and a component-level tool keeps.
Very small plastic parts drop out of the count
Article 7(5)(b) takes any plastic part representing less than 5 % of the total weight of the packaging unit out of the recycled-content targets. On a pump dispenser the spring, the gasket and the dip tube often fall below that line.
You still have to know each part's weight to prove the part is under 5 %, so the exemption does not save you the measuring work. Article 7(6) puts the proof in the Annex VII technical documentation.
Small formats and hotel miniatures follow their own rules
Beauty sells more small and travel-size formats than any other consumer category, and the regulation treats them separately in three places.
Hotel miniatures leave the market on 1 January 2030
Article 25(1) bans the formats listed in Annex V from 1 January 2030, and one Annex V entry is written about cosmetics.
Point 5 covers "single-use packaging for cosmetics, hygiene and toiletry products for the use in the accommodation sector", where the packaging is "intended for an individual booking only and intended to be discarded before the next guest arrives".
Its examples are shampoo bottles, hand and body lotion bottles and sachets around bar soap.
Two things make this entry sharper than it first looks.
- It is not limited to plastic. Every other Annex V entry begins "single-use plastic packaging" or names plastic carrier bags. Point 5 says only "single-use packaging", and the German and Danish texts of the regulation match. A glass miniature and a paper sachet are caught the same way a plastic bottle is.
- There is no small-company escape. The micro-enterprise derogation in Article 25(4) applies only to point 3 of Annex V, the HORECA formats. It does not reach point 5, so a small brand supplying hotels is in scope on the same date as a large one.
If you supply the hospitality trade, the miniature packaging ban is a product decision rather than a reporting one, and the Commission is due to publish guidelines explaining Annex V by 12 February 2027.
Where the sorting label goes when the pack is too small
From 12 August 2028, or 24 months after the relevant implementing acts, Article 12(1) requires a harmonised pictogram label on material composition. On a 15 ml sample jar or a lipstick bullet there is often nowhere to put it.
Article 12(5) answers that with a three-step fallback, in order.
- Put the label on the packaging itself, printed, affixed or engraved so it cannot easily be erased.
- Where that is "not possible or not warranted on account of the nature and size of the packaging", put it on the grouped packaging.
- Where even that will not work, provide the information through a single electronically readable code.
There is a useful consolidation at the end of the same article. Where EU law already requires product information through a data carrier, one carrier serves both the product and the packaging, as long as the two are easy to tell apart.
Cosmetics is named in the empty space review
Gift sets and boxed collections are where beauty meets the packaging minimisation rules. Today the 50 % empty space ratio in Article 24(1) applies to grouped, transport and e-commerce packaging, not to the sales pack a customer picks off a shelf.
Sales packaging is not untouched, though. From 12 February 2028, Article 24(4) requires empty space in sales packaging to be "reduced to the minimum necessary for ensuring the packaging functionality, including product protection".
Filling materials such as foam inserts and air cushions count as empty space rather than as filling.
Then comes the part worth diarising. Article 24(6) tells the Commission to assess, by 12 February 2032, whether to set an empty space ratio for sales packaging too, "particularly for toys, cosmetics, do-it-yourself kits and electronic products". Cosmetics is named in the text.
How many of your registers each provider will take on
Register coverage is the axis that separates these six tools most sharply, so it is worth seeing before the ranking. The bar below counts how many of the four beauty registers each provider's own site says it handles, and the words beside it say which.
We do not lead this one. ecosistant, Deutsche Recycling and ForSURE each name all four registers on their own sites, Lorax EPI names three, and Repax and Recyda are packaging-centred.
If your priority is handing every register to a single provider, the top of that bar is where to look, and the ranking below says so in each entry.
What the bar does not show is depth. A provider can register you in four schemes and still ask you to supply the component weights yourself, which is the work that actually takes the time.
What we looked for in EPR software for a beauty brand
The ranking weighs two things in order, and it helps to know which before reading it.
- How well the tool models a beauty pack. A serum pump is not one item. It is a bottle, a pump mechanism, a dip tube, an overcap, a label and sometimes a shrink band, in four or five materials. A tool that stores one weight per SKU cannot answer Article 7 or a modulated fee.
- How much of the rest it carries. Register coverage, and whether the provider will register you, file for you or act as your representative, as counted in the figure above.
- Whether it produces the declaration. From August 2026 anyone placing packaging on the EU market must issue a signed EU Declaration of Conformity, so we checked whether each tool generates one or only exports data towards it.
- What it costs to start. Published pricing beats a quote for a brand that wants to try before committing, and it is the axis on which the six differ most.
- What the provider's own site actually claims. Every fact below was read off the vendor's live site rather than inferred, and where a stream or a feature is absent we say it is not named rather than that the tool cannot do it.
Two things we deliberately did not weigh. Cosmetic product compliance itself, meaning the Responsible Person and product notification under Regulation (EC) No 1223/2009, is a separate discipline and none of these tools is an answer to it.
We also did not rank on customer logos, because a beauty brand's problem is its pack structure, not who else bought the software.
The best EPR software for cosmetics brands ranked
Six tools, ordered on the criteria above. Each entry says what the tool is genuinely good at and where it stops.
1. Repax
Repax is built around the shape of the problem in the first section, which is that a beauty pack is a set of parts rather than a single object.
Core stores every product as four reusable layers, from product to assembly to component to material, so a pump bottle is described once as its real parts and each part carries its own weight and material. Change the resin on a cap and every SKU using that cap updates with it.
That structure is what lets one product answer two recycled-content buckets at once, and what makes the under-5 % test in Article 7(5)(b) something you can evidence rather than estimate. It is also our own product, so we lead with it here, and we are straight about where each rival wins.
- Best for beauty brands whose packs have many parts and who want to own the data rather than hand the job over.
- Which of your four registers it covers packaging, as a data and reporting engine. Repax does not register you, does not file on your behalf and does not act as your authorised representative in any stream, so the three providers at the top of the figure above beat us on coverage.
- What it does with a multi-part pack models it component by component, then generates the shape each market and scheme asks for from the same specification.
- Markets and streams built for multi-market EU reporting, with per-market report configurations. Declare issues the EU Declaration of Conformity for packaging only, not battery or electrical conformity.
- Pricing published, with a genuine free tier. Free at €0 a month, Growth at €29, Pro at €59, and a custom tier for high volume, all ex VAT as of August 2026.
- Watch-out Comply, our multi-market scheme workspace, is not released yet. It is on the waitlist for 2026, so do not plan around it.
One detail that is unusually relevant here. The worked examples on our own Declare page are a skincare dropshipper and a factory making glass shampoo bottles for cosmetics brands, because that supply chain is where the declaration question comes up most often.
If you want the mechanics first, the EU Declaration of Conformity checklist walks through what has to be attested.
2. ecosistant
ecosistant is the broadest register coverage on this list, and for a beauty brand with wipes and devices in the range that matters more than any single feature.
Their own stream list runs packaging, WEEE, batteries, textiles, furniture, single-use plastics, and sporting goods and toys in France, though the last few are available only through their managed Premium Service.
They work in two modes, and the choice matters. Premium Service means they run registration, volume reporting and scheme communication for you in up to 30 countries. Self-Service means you get digital manuals, tailored to-do lists and scheme recommendations, and you do the work.
- Best for brands that want one provider holding all four registers, especially into Germany.
- Which of your four registers it covers all four, with single-use plastics available through the Premium Service rather than self-service.
- What it does with a multi-part pack guides and calculates at the level of your reported quantities, rather than holding a component model of each pack.
- Markets and streams the whole EU plus Switzerland, Norway and the United Kingdom, 30 countries in total. They also run a separate WEEE and battery authorised representative service for Germany, which is a legal requirement for a foreign company selling there.
- Pricing published and among the lowest anywhere. Country-Service from €24.90 per country per year, from €17.90 in later years, other streams from €5 per country on top. Europe-Service from €399 for the first year across 30 countries, from €299 to renew. A permanently free Germany plan exists. Premium Service is quoted. All ex VAT, checked August 2026.
- Watch-out what you are buying at the low price points is guidance and scheme access, not a reporting engine. Their own estimate of the underlying scheme fees is €50 to €150 per country for packaging and a minimum around €500 per country for electronics or batteries.
If ecosistant is already your shortlist benchmark, our Repax and ecosistant comparison sets the two delivery models side by side.
3. Recyda
Recyda answers the question a beauty brand asks earliest, which is whether the pack it has designed can actually be recycled and what that will cost. That is a narrower job than the rest of this list, and they do it better than anyone here.
Their recyclability engine scores a pack against Recyclass, CEFLEX, KIDV, the ZSVR Minimum Standard, the APR Design Guide, COTREP and EN 18120, and supports the UK Recyclability Assessment Methodology.
For a multi-material pump or a compact with a mirror, that is the difference between guessing at a fee band and knowing it.
- Best for brands whose fee problem starts at the design stage, and anyone facing a UK recyclability assessment.
- Which of your four registers it covers packaging only. No single-use plastics, WEEE or batteries are named anywhere on their site, so wipes and devices need a second provider.
- What it does with a multi-part pack assesses it against seven design-for-recycling frameworks and calculates the country-specific EPR cost from it.
- Markets and streams 20 or more countries, with the UK, Denmark, Italy, the Netherlands, France and Spain named. Their PPWR product generates a Declaration of Conformity through a review and signature flow, plus an Annex VII technical documentation summary, with an audit log on every status change.
- Pricing demo only, no published figure.
- Watch-out their EPR flow ends at export. They consolidate, calculate, visualise and hand you the declaration report, and they do not claim to submit it to a scheme for you.
Their strength and their limit are both real, and the Repax and Recyda comparison works through where each one fits.
4. Deutsche Recycling
Deutsche Recycling is on this list for one reason that no other provider matched.
If you sell wet wipes into Germany from outside Germany, someone has to act as your authorised representative under the German single-use plastics fund law, and they are the only vendor we have found selling that as a named service.
That role is not a nice-to-have. Their own page states who needs it, namely producers and distributors of single-use plastic products established outside Germany. They act as the representative, take over the producer duties, handle the registration and check the assessments that come back.
- Best for non-German brands with wipes in the range, and anyone who wants the German representative roles handled as a package.
- Which of your four registers it covers all four, including the German single-use plastics fund, plus textiles and labelling duties.
- What it does with a multi-part pack nothing. Their product data pages are empty, so classification and per-product plastic weight remain your job.
- Markets and streams Germany first, with international representation available. They also run the electrical register service and the packaging registration number service.
- Pricing no published price, everything runs through an enquiry.
- Watch-out this is a full-service compliance house rather than software. You will not get a product database, a recyclability score or a self-serve declaration tool, and you will need something else to produce the numbers they file.
An authorised representative is a legal appointment rather than a software feature, which is worth separating in your head before you compare quotes.
5. Lorax EPI
Lorax EPI is the one to look at when the map gets big. They sell an EPR reporting software tier and an outsourced compliance tier, alongside obligation assessment, data screening, registration and fee modelling, so the same provider can grow with you from software to service.
Their registration service is where the four-register problem is stated most clearly by any vendor on this list, and their honesty about sequencing is worth repeating.
Registrations cannot start until accurate packaging data exists, because most schemes want historic or forecast weights at the point of registration.
- Best for brands in many jurisdictions at once, and teams that want an obligation assessment before committing to registrations.
- Which of your four registers it covers three, packaging, WEEE and batteries, plus textiles. Single-use plastics is not named, so wipes are not covered here.
- What it does with a multi-part pack screens and validates the data you supply, then models fees from it, rather than holding a component-level model of its own.
- Markets and streams the widest geographic reach of the six, with a regulatory subscription service that tracks rule changes across markets.
- Pricing demo only, no published figure.
- Watch-out their own process puts accurate packaging data upstream of everything else, which means you still need a way to produce it. That is the gap this page keeps pointing at.
The Repax and Lorax EPI comparison covers the software-versus-service choice in more depth.
6. ForSURE
ForSURE is the cheapest way into all four registers if your brand is still small, and it is the only tool here that lets you find that out for nothing. Their free plan is open to sellers with annual gross revenue under €500,000 and ships reporting templates for Belgium, Germany and the Netherlands.
On coverage they are unambiguous. Their own homepage says the software handles EPR reporting for WEEE, batteries, packaging including single-use plastics, and textiles, and each of those has its own page on their site.
- Best for indie and early-stage beauty brands that already sell a device or a pack of wipes and need all four registers cheaply.
- Which of your four registers it covers all four, named on their own stream pages.
- What it does with a multi-part pack collects product and order data and lets you match products to EPR categories yourself. The categorisation is a user step, not automatic classification.
- Markets and streams EU-wide in ambition, with the free plan's templates limited to Belgium, Germany and the Netherlands.
- Pricing a genuinely free plan under the €500,000 revenue ceiling, then paid plans with no published price.
- Watch-out no self-serve EU Declaration of Conformity tool is listed, so the August 2026 declaration is not solved here. The revenue ceiling also means the free plan stops being available exactly when your range gets complicated.
For a wider view of that segment, the ForSURE alternatives page lines up the small-business options.
Match a tool to what your beauty range contains
The right answer changes with what is actually in your catalogue, so start from the range rather than from the tool.
| What your range contains | Where to start |
|---|---|
| Skincare and colour cosmetics only, several markets | Repax for the pack model and the declaration, since packaging is your only register |
| Multi-part pumps, airless bottles or compacts | Repax for component-level data, with Recyda if a recyclability grade is driving your fee |
| Wet wipes or cleansing cloths, sold into Germany | Deutsche Recycling for the single-use plastics representation, with Repax or Recyda producing the numbers |
| An electrical device such as a dryer or a styler | ecosistant or ForSURE, so the WEEE register is handled by the same provider |
| A rechargeable device with a sealed battery | ecosistant for the German representative roles, and read Article 11 before the next design cycle |
| Hotel, travel and sample formats | Repax, plus a product decision on Annex V point 5 well before 2030 |
| Under €500,000 revenue and just starting | ForSURE's free plan, then Repax's free tier when the declaration becomes the problem |
| Dozens of markets and an internal compliance team | Lorax EPI for reach, with Repax underneath it as the data layer |
Every tool measured against a beauty catalogue
The same six tools, on the axes that decide a beauty brand's shortlist.
| Tool | Registers | Pack modelling | Pricing |
|---|---|---|---|
| Repax | Packaging | Component level | Free, from €29 a month |
| ecosistant | All four | Reported quantities | From €24.90 per country |
| Recyda | Packaging | Seven design frameworks | Demo only |
| Deutsche Recycling | All four | You supply the data | Enquiry only |
| Lorax EPI | Packaging, WEEE, batteries | Screening and validation | Demo only |
| ForSURE | All four | You match categories | Free under €500k |
Pricing checked August 2026, ex VAT. Register coverage counts only what each provider names on their own site.
Frequently asked questions about EPR software for cosmetics brands
Short answers to the questions beauty brands ask most often when they start this work.
What is the best EPR software for cosmetics brands?
Repax, if your priority is modelling a multi-part pack and issuing the packaging declaration. If your priority is having one provider carry all four registers, ecosistant covers the most ground and publishes its prices.
Does a cosmetics brand need more than packaging EPR?
Only if the range goes beyond cosmetics themselves. Wet wipes add a single-use plastics duty, an electrical device adds a WEEE registration, and a battery in that device adds a third. A skincare-only range stays in packaging alone.
Why does cosmetics packaging have a lower recycled content target?
Because PPWR Article 3(49) names the Cosmetic Products Regulation in its definition of contact-sensitive packaging. That puts most cosmetics plastic at 10 %, or 30 % where PET is the major component, instead of the 35 % general figure.
Are hotel shampoo miniatures actually banned?
Yes, from 1 January 2030 under Article 25 and Annex V point 5. Unusually, that entry is not limited to plastic, so glass miniatures and paper soap sachets are caught too, and there is no micro-enterprise exemption.
Where does the sorting label go on a tiny sample jar?
Article 12(5) sets three steps. Put it on the pack, or on the grouped packaging where the pack is too small, or provide the information through a single electronically readable code where neither works.
Do wet wipes pay a recycling fee?
No. Under Article 8(3) of the Single-Use Plastics Directive, wipes producers pay for awareness raising, litter clean-up and reporting. The directive does not require separate collection for wipes, so there is no recycling stream to fund.
Is there free EPR software for a small beauty brand?
Yes, in two shapes. Repax Core has a permanently free tier at €0 a month, and ForSURE offers a free plan to sellers under €500,000 annual gross revenue. ecosistant also runs a free Germany-only plan.
Does any of this software handle cosmetic product notification?
No. The Responsible Person and product notification duties under Regulation (EC) No 1223/2009 are a separate discipline from producer responsibility, and none of the six tools here is built for them.
