EP267. The packaging fees coming for the beauty industry

The cost of beauty packaging is about to change and for many brands it won't be pretty. So ranging from Europe's eco-modulation fees to Australia's single-use plastic bands and the UK's plastic tax, a new wave of regulation is rewriting the rules on what's allowed, what's recyclable and what's going to cost the beauty industry. So if a beauty brand is using materials that are hard to recycle or mix, opaque and labelled, they could soon be paying penalties. Sometimes up to 70 times more for plastic than for paper. But understanding what's actually required isn't straightforward. So regulations differ across regions, recycling infrastructure as we know is patchy, and many packaging choices that look sustainable aren't accepted in local systems. Compostables, frosted glass, coloured plastics, refillables, each of those packaging forms comes with trade-offs that beauty brands often overlook. And at the heart of all of this is a messy, urgent question. How do we design packaging the works for the real world, not just for the marketing team? So in this episode I'm joined by Renata Doubt of A When Packaging Consulting. As a chemical engineer with over 15 years global experience, Renata works with brands to navigate the complex reality of packaging compliance. Together we unpack what these changes mean in today's episode and we look at what's coming next and how beauty brands, especially the indie brands, can make smarter decisions today that will keep the matter of trouble tomorrow. Welcome to Green Beauty Conversations in which I challenge the beauty industry to become sustainable, champion independent and green beauty and encourage you to join me in making beauty better. I'm your host Lorraine Dalmayer. I'm a chartered environmentalist, biologist and the CEO of award-winning online organic cosmetic formulation school Formula Botanica. We have tens of thousands of students in over 190 countries around the world who study with us to become organic beauty formulators and entrepreneurs. Visit our website at formula botanica.com to try our free online formulation course. And if you want to be the first person to know what's happening in Green Beauty, make sure you subscribe to this podcast in your favourite podcast app. So in today's episode, as I already mentioned, I'm joined by Renata Doubt, the director and principal consultant at A When Packaging Consulting, where she helps businesses around the world navigate complex packaging laws and shift towards sustainable practices. A chemical engineer by training, Renata has spent over 15 years working across Europe, the Americas and Asia Pacific, with deep expertise in both manufacturing and recycling systems. Her mission is simple to eliminate packaging waste from landfill by helping brands design smarter, comply better and move beyond the greenwashing to real circular solutions. Hi Renata, how are you doing today? I'm great, how are you learning? I'm good and I'm really looking forward to this conversation because I'm so interested in everything that we're going to talk about. So let's start off with could you please introduce yourself for our listeners? Of course, so my name is Renata. I am packaging consultant and engineer at A When Packaging Consulting here in Sydney, Australia. Amazing, so what do you do? What is your business called? It's all in packaging consulting so we help businesses to choose sustainable packaging for their products. And what got you into beauty? Because obviously we're going to be talking about beauty packaging today, so tell me a little bit about your story. Yeah, so since I started four years ago with this consulting business, several beauty businesses actually start up, so very at the beginning of the journey, they came to me and they want to know what sort of packaging they should choose. They put so much effort in their product like the formulation and so on, so they want to do the right thing about packaging as well, which surprised me a lot because most of my other clients and the other industries, they don't really think about that from the beginning, so I was quite impressed with that. That's good and that doesn't surprise me actually because I think a lot of beauty brands are really starting to think about their footprint and there are a lot of statistics being thrown around about, you know, billions, billions of billions of units of packaging being produced in the beauty industry every year. And I know that all of our listeners care a lot about this as well. So I'm pleased to hear that the beauty brands that are coming to you are very conscientious. So let's dive straight into the sort of main topic of discussion that we're going to talk about today, which is about legislation because you wrote to me and you said we need to be talking about this on the podcast, and I completely agree. So what's happening in terms of regulations around packaging? Yeah, so this year in February was like a big mark in the packaging regulation because the PPPWR, which is the packaging and packaging waste regulation in Europe, was enforced. So it's been around, been discussed a couple of years in Europe and then from this year is enforced, meaning that brands have to pay a fee due to the material they are going to use for their packaging and the amount of packaging they're putting in the market. So it's quite important to everyone to understand that this is already happening in the UK, the EPR, its extended producer responsibility. It's also started like two years ago. Australia we have also a packaging reforming happening in the same direction. So the goal for all of them is to have 100% of packaging recyclable by 2030. Wow, okay, so there's big shifts happening. And when you've talked about Europe, you've talked about the UK, you've talked about Australia. Do you think it's likely that other countries around the world will also start to follow what some of these territories are doing in terms of packaging regulations? Yeah, absolutely. There's also a lot of happening in Canada and some states in the US. So not US is a country, but separate states have been enforced in some different regulation around packaging as well. And what we typically see is the EU comes up with this sort of big legislation and then other countries follow suit eventually. And it takes time, but generally it starts to roll out. So I'm expecting that if we're seeing major change here that will start to see major change around the world. And quite frankly, I think the beauty industry needs it as the many other industries, but of course we're only focusing on beauty on this podcast. So imagine I'm a beauty brand owner. All of this is changing. What do I need to know? So first of all, the market that you are in, so the country that your business is registered. So you go to the regulator and then make a registration with them. Then you have to report the amount of packaging that you place in the market, at least what you placed in the last year. So you have a base for the calculation. And then you find out if you need to pay fees or not. It also depends on the size of your business. It also varies by country and region. It's around like if your revenue is up to two million euros, you most likely not have to pay anything. So if you are considering a small business, but it also depends on if you import over 50 tons of packaging. So if you import basically everything that you sell, you might be entitled to pay fees because this is another thing that you want to avoid that there is a lot of material coming from overseas in each country. So it's coming from overseas and then they have to pay for how to treat this material, how to, you know, the waste management that has to be in place to solve that. So that's why I have to talk about that too. And the recycle content, so maybe something that we have to talk about a little bit today, but recycle content is when the material is not virgin, we call it. So like we have, we have a recycle content. So material that was recycled before in that material. So it helps with circularity. So that's very important. And then after that, you have to report annually the amount of packaging. You place in the market and then based on that, they will calculate the fees. So this year by year. Wow, okay, so there's a lot to consider, but it sounds like many startup brands, many very small brands won't be caught in the net of this type of regulation, thankfully, yet. So what sort of materials are going to be most problematic under these new rules? So especially when you have mixed materials. So the goal is to have 100% recyclable material or packaging in the market. So I would give like five tips to improve your packaging when you are looking for packaging, which is go mono material, mono material means having only one type of material in your whole packaging. For example, it's very common for beauty that you have different type of plastic, then you have a spring inside for the pump. So you have different materials together and this doesn't get separated before being recycled. So it's unlikely to be recycled because it's very hard to separate. So the first thing I would say look for packaging that's entire delete the bottle, want the same material or it's easy to disassemble. So if you have the bottle glass and then the pump plastic, let's say, HDB, if they can be disassembled easily, you can recycle both of them. But if it's not easy to separate, it's also probably not going to be recycled. And will there be more to pay depending on what type of material you use? Like, would you pay more for plastics than for, I don't know, paper? Yes. So countries also have a different fees, but the one most well known and it's also based for other countries is the fees from the Netherlands. So in the Netherlands, for example, the cardboard, the kilo of cardboard is two cents of euros. A kilo of soft plastic is one euro 32 cents. So if now you use soft plastic for a pouch of shampoo, I don't know, because it's the cheapest you can buy, you have to pay much more than do it with the fee. So end up being like another packaging, another the material, for example, and OPET would be easier to recycle. For instance, it was more expensive to buy the packaging, but it would be cheaper in the end because you have to pay less fees on the material. - So will the regulators be using the money that they collect then to reinvest in their recycling infrastructure? What's the main objective? - Yes, so this is one of the goals is to improve the management, waste management, recycled infrastructure. There's a lot of technology now, so the limitation that we have now, for example, to identify the different materials, there's a lot of technology evolving that we can then in the future separate and identify these materials. So what is not recyclable now? Might be a recycle in 10 years. So it is also something important to review your packaging because it's not about the material itself. It's about the combination and the waste system that the packaging is going to be disposed. - Yeah, I completely understand, but you said one thing that I thought was quite interesting, actually, you said that the goal for these regulations was to make all material 100% recyclable. Shouldn't a goal be to make materials 100% reusable? - There's a limitation for reuse and this is mostly because of the systems and the consumer behavior. I personally believe that have reusable packaging is the best option and there is actually a great trend in refillable at the moment. So one thing is recyclable. The other thing is reducing materials, right? That we have the possibility to dispose. So when you have a refillable, you have like a main packaging and then the refill will be less packaging. So refillable is closer to usable. So I guess it's a step forward to get consumers to use to return the packaging to refill it and then at some point reuse them and then you don't need to throw any packaging away anymore. - Yeah, I understand. I think the industry often gets the term circularity and recyclability confused because of course being recyclable doesn't make something circular. It just means you might be able to recycle it once or twice in the case of plastic and then it might turn into tiny pellets that they use in roads. But it's an interesting concept because I think the regulations are maybe starting with the lowest level that they can to try and get everything recyclable and then hopefully they will start to move towards making things reduced and reused higher up in the waste hierarchy. I wanted to talk about something that you mentioned earlier which is about mono materials. Can you explain a little bit more about what that means? - Yes, so we have different plastics. For example, I think it's where the mono material is mostly different to is the plastic. So usually we have a lead which is polypropylene and then the bottle, it's polyethylene. So then this mix, it makes difficult to recycle. So if I have a mono material meaning we have the whole from the pump in the bottle, the lead, everything, the same material you can throw, dispose the entire packaging together and then we will be recyclable. And it has a lot of advance in the building industry around that, especially in the pumps. Was very hard to find pumps that was mono material. Was always a mix of material. And nowadays I have seen different ones in the market that it's possible to have the full packaging mono material. - Okay, that's clever. 'Cause I think probably lots of beauty brands aren't necessarily thinking about mono materials when they first start. So what should beauty brands be thinking about when they choose their packaging? And this is something that you work on with them presumably. - Yeah, yeah. So first of all, I would say look for mono material. So the entire packaging, one type of material, one type of plastic. If you have different materials, for example, you want to have the bottle glass. So you have the pump and the lead, one type of plastic as well. So like PE, okay, just one type. Don't mix it up. I see sometimes that, oh, this is bioplastic, come from sugar cane. So it's more eco-friendly. But then this is a problem because if you mix it with another, with another material, it's a contamination. So then the material that would be recyclable won't be because it's a mixed with a bio material which is not always the same properties that are plastic. So this makes more difficult. Another thing I would say, try to avoid have a small packaging, like very small products, more samples, you know, like in the past that we have a lot of samples, I go to the hotel and you have, you know, oh, this is small bottles. This is also part of the regulation. It's a force that you have to offer refillable options. So they are asking for the hotels and even like restaurants and when you have this, you give away the single use plastics and use items. It's a must that they have reusable option. So you cannot go to a hotel and just have the small samples to use. You have to have a big bottle that you just use the amount you want and then you leave it the rest there. So this is part of the regulation too. - Good, well, we need some regulation on this. We actually recorded some episodes on travel minis a while ago on the podcast. I completely agree. Do you think that many beauty brands are even aware of mono materials? Do you think a lot of brands are thinking about these things when they first start out? - No, from my knowledge. First, they want to have a packaging that of course stand out on the shelf. So looks premium. Of course, there is also the formulation chemical side of the beauty product. So we need some barrier for against the oxygen. So there's a lot of things that you have to think of. So it's not any packaging suitable. But as I said, there is a lot of advanced packaging in this area already because it's a need. And I think the regulation helps with this technology development as well because even if you source from China, and in China, this is not a regulation, but most of their clients are in Europe. So they have to develop a solution for them as well. So I think it's pretty good because it will help even the place that are not following any regulation at the moment. They have access to a better combination of materials and a better packaging that once you didn't know about what's the packaging you could buy. Now you have more options and probably more sustainable options that you can buy. So even though you don't have that entire knowledge about the packaging, you have more options to do right. So I'm sure there are a lot of people listening thinking, OK, well, you've been talking mainly about plastic. But I'm good because I use glass. Is glass problematic? Is that OK? So that's why it's so important to know the market that you are in. So for example, in Australia, if it's not transparent, it's unlikely to be catch in the waste infrastructure, they'll need a waste management, so it won't go to recycling facility. So it can be-- it has to have a transparency, it has to be clear. Even though it has a color, it has to be clear. In Europe, it is not a problem. So I've got a sample from Italy another day. And in Italy, it is recyclable. And it's under the new regulation in Europe. And here, it won't be recyclable because the infrastructure is different. So that's why it's very important to know where are you intent to sell your product and to be aligned with that. And then it comes to the label. So having the proper recycling assessment and label in the market that you are in. Because it's a brand obligation to inform consumers how to dispose it. So you have to have the correct label on your packaging related to your packaging, not only about the product. There's a lot of other certifications that you have to place on that. Yeah, I mean, brands only have these tiny little labels. They often have like 60 ingredients in this tiny bottle. They have to try and cram all of them on in six-point font. And then they have all these other legal obligations they have to put on there, like their place of residence, the weight that's in there, et cetera. Any sensitizers they've included, the name of the brand, the name of the product, how to apply it, where are you gonna fit the recycling information as well? The brands often forget to add that. Yes, yes, often they forget. And usually if you have a box that carries your product inside, I would say to you put in the box. And some places you have to put on the bottle as well. At least you have on the box and you have this communication on your website, on your marketing. It's very important that you guide your clients to do the right thing. And then also show them that you thought about that. You do a lot of work choosing the best packaging that suitable for a product also like the best for the environment. So it's important that you tell them how to dispose it. So they do the right thing, you know, and then the cycle closes well. Yeah, I understand. And just coming back to what you were saying about transparent glass, I'm sure a lot of people aren't even aware of that because I think the general feeling in the beauty industry is if it's made of glass, therefore it's recyclable. But of course, many beauty brands don't use transparent glass because you have to also protect the ingredients inside your formulation from oxidation when they're exposed to light. They can degrade quicker. So a lot of brands are using amber glass, green glass. And then of course, this beautiful mirror on glass, this dark purple violet glass that you see so much with indie brands still. So are you saying that in some countries, those forms of packaging just aren't recyclable at all? Yeah, because we have this carbon content, so it gives the color. the dark color and in a lot of recycling facilities, this makes it impossible to identify that's a glass. So then this glass is then that up in other materials and then you'll be a contamination. So in the end, when you choose glass, thinking it's sustainable, it's gonna be recycled. Actually, it contaminates another stream and then it's actually creating more problems in the system. So it's very important that you look into it as well. Yeah, and you know what, I'm sure a lot of brands aren't even aware of this and a lot of customers as well because I'm sure that they're in the shops going, "Oh, it's my product." Actually, it's in glass. Wow, that's much better because now I know what I can do with it, I can recycle it. So why is there so little information about this? Like, because you know, I see all these countries around the world, I don't think customers, consumers are told you can't recycle different types of colored glass in our country, for instance. I believe it's because of the difference between the countries. So, and the facilities are usually the recycling facilities. They are private owned, right? So it's a business. So you build like a one structure and then the other one builds a different structure and then in the end, you can do some products so you cannot do others. So then it's not homogeneous. The communication of what is right, what is wrong with packaging is hard to say because there's no clear answer. It really depends on where you are. In Australia, even the state you are in, you know, because they also have different infrastructure. There's no national infrastructure. So if you change from one state to another, you also change the beams you have in your building and what you can dispose or not. Wow, I mean, this is a real problem for the beauty industry because ultimately, you know, plastic is not sustainable. I mean, plastic as a material is absolutely fine. We just use far too much of it. Glass, obviously, it has its problems as well. You know, and then what are you left with? Aluminium, different types of metals. You're left with paper and cardboard, but of course, many different types of formulations and liquid they can't go into that. What should the beauty industry be doing? I have a big fan of what's happening with algae and mushrooms. So I have seen in the building industry the outside packaging, of course, not the packaging with the product inside yet. But I think there's a lot of evolution in this because there are highly renewable raw materials, right, the seaweed and the mushroom. It's very easy to grow them. For example, there is this olive oil that it's in this algae packaging that it solves. So there is no waste. So I was wondering, like, can we have this moisturized inside, and you just use that one like every day on your face? And then you don't need to have any waste on that. So I don't know. I believe that we get, at some point, that we have different materials that we can use in the building industry as well. But another thing I would like to say is the plastic. I really believe that plastic, it's not a bad material. It's great. That's why it's so widely used, right? But also the regulations enforce to have this recycled content. So I think this is very important to look into and to buy recycled content materials. Because if you don't buy them, the values too low. So nobody wants to recycle. You know, so then this cycle doesn't really work. So if we have more people looking for recycled content materials, then we have more recycled materials available. And then we use less and less virgin materials. And then you need less. So I believe that at some point we can reach a full circle that we just recycle and reuse what we have in the cycle. But for this, we need really clean streams. So like not mixing all the packaging together, but having different materials separated. So then it's easier to recycle than to have this clean stream. And then we can have this into packaging again. So it's a full circular recycling system. So I guess the beauty industry in the meantime just has to be almost like a detective, don't they? Because you have to figure out where your product's going to be sold. What the waste management facilities are like in that region of the world. Maybe not even on a national level. Like you said, maybe even breaking it down on the state by state level, figuring out how consumers deal with that material. When they, I mean, that's a lot of what is that the brands do when they come to you? Yeah. So I do that very in detail. But as a general rule, I would say monomaterial because this will be suitable for most of the places. Or you can separate well. So disassemble your packaging with different materials and then separate the different materials. This is something that you can be using. Europe can be used here. They can be used in, you know, in the US. The systems are most likely to accept this sort of monomaterial and so on. You know, so I need to be more specific than, yeah, you have to really understand in each area, each country where you are. Yeah. And obviously you undertake that work for many beauty brands. And it sounds like a complicated piece of work, which is why I understand what you do. So to round off this interview then is where can our listeners find out more about you? Where can they come and talk to you and maybe even use your services if they have a beauty brand? Yeah, of course. So we can access my website. It's oinconsulting.com, the Instagram account, oin.consulting. And LinkedIn as an oin consulting, all my names are in that doubt. I have been living in different countries for the last 15 years. So I have knowledge from different areas. So I think that's why it's also for me not so difficult because I have seen different places, different, different infrastructure, different packaging, manufacturing. So yeah, I love what I do. So to me, it's not mysterious. Amazing. Well, we will include all of those notes in the show notes below this podcast episode to go and click through to Renata's website. Thank you so much for joining me today, Renata. It's from really interesting learning all about the new regulations and about what you do. I think it's a much for having me. I would love to hear your thoughts on this episode. Were you aware of the regulatory changes that have been coming in around packaging all over the world which could affect beauty brands? Leave us a comment on our social channels as both the Formula Botanica team and I love hearing from you. And if you want to hear some more episodes about the topics we discussed today, please do delve back into the podcast archives. So some great examples include episode 265, which I recorded only a couple of weeks ago in which I interviewed Carly Snyder of the Pact Collective about the packaging-waste problem in beauty across North America. Or head back to episode 118, in which I put forward my opinion piece about plastic, in which I said, "Plastick itself isn't the enemy. Instead, we are for using so much of it." There's a wealth of information in our old episodes and I do encourage you to go back and listen to them. Thank you for joining Renata and I for this latest episode of Green Beauty Conversations. I really hope you enjoyed it. If you did, please do leave us a five-star review so that other people can enjoy these conversations too. Make sure you subscribe to the podcast on Apple podcasts or Spotify or whatever your favourite podcast app is and stay tuned for the next episode. Follow Formula Botanica at Formula Botanica on Instagram, Facebook, YouTube, TikTok, Pinterest, LinkedIn, and you're everywhere. And come and give me a follow @LaRaineDarmeier on Instagram and LinkedIn. Visit our website at Formula Botanica.com and sign up for our free online formulation course today.