The 2024 elections transformed Washington’s political landscape, and AMERIPEN expects federal and state packaging regulations to see significant changes this year. While it is not yet clear just how much impact the new administration’s federal policies will have on ingredients, we do know cosmetic and personal care brands will face an increased patchwork of state packaging requirements demanding strategic adaptation. Here are five critical policies executives should monitor, with practical preparation steps for each:

Extended Producer Responsibility (EPR) will likely be the most pressing policy concern for this year. With five states already implementing EPR laws, and producer payments beginning in Oregon by July, beauty brands should immediately verify their producer registration status with the Circular Action Alliance, Oregon’s producer responsibility organization, to maintain compliance in the state. Producers (manufacturers and brand owners of products) are required to submit a report of their sales in Oregon along with the amount of packaging they’re selling into the state. While fees have not yet been released, Oregon’s will be made public in June with payments due July 1. Companies should visit www.circularaction.org for more information. 

Source reduction mandates prioritize “doing more with less,” which may significantly impact luxury beauty packaging. The California EPR law requires 25% source reduction in single-use plastic packaging, which can be met by various methods including recycled content up to a certain amount, adoption of reusable and refillable solutions, and changing to alternative materials. Beauty brands should document qualified source reduction efforts from the past decade for potential compliance credits while evaluating opportunities for refillable and reusable packaging solutions.

The fragmented landscape of state-specific labeling requirements—covering recyclable claims in California and compostable claims in five other states—is creating significant challenges for companies trying to communicate packaging end-of-life information across state lines. Messaging that satisfies one state’s requirements may violate another’s or conflict with FTC Green Guides. For beauty brands, it’s important to note that California’s new law may mean corporate takeback programs won’t necessarily qualify a product as “recyclable.” (For more detailed information, view AMERIPEN’s claims and labeling webinar series.)

Seven states now have laws for post-consumer recycled (PCR) content rates. Beauty and personal care companies should note that the industry still faces significant challenges securing sufficient qualified PCR content for cosmetic and personal care packaging. Explore exemption options while developing sourcing strategies for increased PCR availability.

PFAS and other chemical regulations already impact packaging across 11 states—and could gain momentum under the Trump administration, with the new head of the Food and Drug Administration voicing support for banning certain chemicals and dyes from the nation’s consumer goods supply. This year, AMERIPEN expects debates after 2024 California legislation expanded scrutiny to everyday materials like PVC and PVDC. Beauty brands should implement chemical tracking systems and engage suppliers to understand manufacturing inputs, particularly as testing requirements for recycled content emerge.

The complexity of these policies necessitates proactive preparation. Beauty brands that strategically adjust packaging designs, enhance data management systems, and collaborate with industry partners will be best positioned to navigate the shifting regulatory maze in 2025.

About the author

Rob Keith joined the American Institute for Packaging and the Environment—AMERIPEN—in 2022.      

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