L'Oréal expects to cut Extended Producer Responsibility (EPR) fees by roughly $1 million annually by stripping metal design decals from one Garnier haircare shampoo once California's Plastic Pollution Prevention and Packaging Producer Responsibility Act takes effect in 2028.

The calculation, run through the company's in-house EPR calculator, illustrates the financial stakes facing cosmetics manufacturers as two of the world's most demanding packaging rules — the EU's Packaging and Packaging Waste Regulation (effective later this year) and California's SB 54 — move from statute to enforcement.

What do the new rules actually require?

Both frameworks push producers beyond recycling fees into design mandates. L'Oréal Chief Sustainability Officer Marissa McGowan splits them into two types: "typical" EPR, which rewards good design and penalizes bad, and "EPR+," where regulators also dictate material reduction.

California's law and the EU's regulation fall into the stricter bucket. Both target single-use plastic packaging and require it to be entirely recyclable in the coming years.

Single-use plastic dominates cosmetics: serums in droppers, foundation bottles, mascara tubes, sample sachets. For brands shipping millions of units, every gram of substrate counts.

How is L'Oréal positioning itself?

McGowan frames EPR as a "tailwind" because L'Oréal has run voluntary sustainability programs for years. "Because we have had voluntary activity for so long, we're going to be better positioned to manage these incoming regulations," she said.

The company runs a life cycle assessment on every product and routes the data through an EPR cost model. The Garnier decal decision came directly from that exercise.

Outside the lab, L'Oréal partnered with Closed Loop Partners alongside Kraft Heinz, Target, and P&G to retrofit material recovery facilities (MRFs) for small-format rigid plastics — the mascara caps and serum dropper sizes standard recyclers reject.

Last year, it piloted fragrance refill fountains in select Dillard's department stores, letting consumers swap empty bottles for refills instead of buying new.

What is Estée Lauder doing differently?

Estée Lauder Companies — the world's fourth-largest beauty conglomerate — is leaning into glass. VP of Sustainable Packaging and Engineering Rob DiPalma said the company built a recyclability assessment tool for developers and creative teams, plus a dos-and-don'ts list that grows as regulators publish details.

"We give them as much information and tools to work with up front, so that they're making the right decisions based on what we know today, and then we keep evolving it as [more information about the laws] comes out," DiPalma said.

The company has run an EPR compliance algorithm for two decades, originally built with recycler Strategic Materials to validate glass recovery from its smallest fragrance bottles. Plastic EPR has since pushed Estée Lauder toward more glass and paper.

Heritage mechanics complicated the pivot further. Estée Lauder's founder built brand identity on sample sachets and gift-with-purchase packaging — notoriously thin multi-layer laminates. The team spent about two and a half years developing a globally recyclable paper packet and sachet to preserve that mechanic without violating the new rules.

How much will consumers pay?

That question has no firm answer. Sheila Millar, a partner at Keller and Heckman who leads the firm's consumer product regulatory practice, anticipates sticker shock.

"The policy choice has been made by the states, but I think it's disingenuous to say 'producer pays and taxpayers won't have this burden,'" Millar said. "Somebody's going to have to pay for it."

Millar is advising clients on pricing as agencies finalize fee schedules and reporting templates. DiPalma acknowledged costs vary by material and category but expects sustainable packaging "to become more accessible over time." L'Oréal declined to share further information on the topic.

When does compliance actually start?

EU obligations begin later this year. California's program takes effect in 2028. Both frameworks still lack final implementing guidelines, leaving brands to model a legal surface that keeps shifting.

DiPalma flagged the absence of cross-jurisdiction alignment as a major pain point. "If we only focus on [the EU law,] then we're not ready for California two years after it," he said. "It would be so much better if they can harmonize somehow."

Until regulators harmonize, formulators and procurement teams should expect parallel — not unified — compliance work across the EU, California, and the multiple U.S. states running their own EPR programs. The next concrete data points will land when agencies publish fee schedules, material definitions, and reporting templates — the variables McGowan said her team is "aggregating all the costs" around right now.