COSPATox: A New Guideline to Ensure the Safety of Recycled Plastics in Cosmetic and Cleaning Product Packaging
In line with new legislative trends and growing commitment to environmental sustainability, the packaging industry is undergoing a significant shift toward the use of recycled materials over virgin plastics. This movement has been largely driven by the new EU Regulation 2025/40 on packaging and packaging waste, which prioritizes the use of recycled content in products marketed within the European Union.
This increasing demand for recycled plastics also extends to packaging for cosmetics, detergents, and household care products. However, a major challenge lies in how to ensure the compliance and safety of these materials, particularly in the absence of specific legislation for these applications.
Until now, many companies have chosen to follow Regulation (EU) 10/2011 on plastic materials intended to come into contact with food. This regulation provides a well-established framework with positive lists of authorized substances, specific migration limits, and detailed testing protocols based on the final use of the product.
COSPATox Guideline: A voluntary but rigorous approach
In April 2024, the COSPATox guideline was introduced as a voluntary initiative promoted by a European consortium composed of recyclers, packaging manufacturers, leading brands, and research centers. It aims to establish technical and safety criteria for the use of post-consumer recycled plastics (PCR) in cosmetics and cleaning product packaging.
The main goal of COSPATox is to facilitate the safe incorporation of recycled polyolefins (polyethylene and polypropylene) in these applications. It sets clear guidelines based on toxicological criteria, targeted substance lists, and analytical testing methodologies. While the guideline does not include specific studies for recycled PET in these applications, its use is considered valid by extrapolation due to the extensive experience and scientific evidence available from the food-contact sector.
Substances to Be Assessed and Analytical Methodologies
One of the cornerstones of the COSPATox guideline is its comprehensive approach to contaminant analysis. A targeted list of substances potentially present in recycled materials is established, including:
- Elements, including heavy metals
- Primary aromatic amines
- Polycyclic aromatic hydrocarbons (PAHs)
- Bisphenols (BPA, BPS, BPF, BPB, BPAF)
- Polychlorinated biphenyls (PCBs)
- Phthalates listed in Annex XIV of the REACH Regulation
- Dioxins and furans
Two analytical approaches are considered for their determination: migration testing and residual content analysis.
Migration testing evaluates the potential transfer of substances from the material into simulated contents. Representative simulants include:
- 95% ethanol for lipophilic (fatty) cosmetic or detergent products
- 50% ethanol for polar or water-based products
On the other hand, residual content analysis directly measures the concentration of compounds within the material. In this case, solvents such as dichloromethane are used to extract substances from the polymer, simulating different product interactions.
Additionally, non-targeted analysis of semi-volatile compounds is carried out using techniques like gas chromatography coupled with mass spectrometry (GC-MS), enabling the identification of both known substances and non-intentionally added substances (NIAS).
To complement these tests, COSPATox also recommends the use of bioassays, such as the Ames test, to assess the potential genotoxicity of extracts from recycled materials.
A Key Step Toward the Circular Economy
Implementing the COSPATox guidelines enables companies to incorporate recycled materials into their packaging without compromising consumer safety. This guideline represents a valuable tool to meet regulatory and sustainability demands, while also fostering responsible innovation in packaging design.
At AIMPLAS, we support initiatives that promote real transformation toward a circular economy. Investing in safe and technically validated recycled materials is not only a regulatory and market requirement but also an opportunity to build a more sustainable, safer, and environmentally responsible plastics industry.