SOSOO Amenities — Resources
The EU Packaging and Packaging Waste Regulation — Regulation (EU) 2025/40, known as PPWR — enters general force in August 2026. Four months from now. And for properties in the Balearic Islands, it is not even the most pressing regulation you are not complying with.
This guide covers what PPWR requires, how it intersects with Balearic Law 8/2019 (already in force), what CPNP registration means for your supplier relationship, and what you need to do before August to have a compliant programme in place.
Start your compliant amenity programme with SOSOO.
The PPWR replaces Directive 94/62/EC on packaging and packaging waste. Not an update — a structural rewrite of how packaging is regulated across the EU. For the hospitality sector, the most directly relevant provision is Annex V, which lists packaging formats that will be prohibited.
Hotel amenity miniatures appear explicitly in Annex V. Shampoo, conditioner, shower gel, lotion — the single-use bottles standard in hotel bathrooms across Europe. Their prohibition date under PPWR is 1 January 2030.
That date sounds distant. Two things make it less relevant than it appears.
First, PPWR does not only prohibit certain formats at a future date. It also requires that packaging placed on the market from August 2026 meets reusability and recyclability standards. Packaging that cannot demonstrate a certified recycling route, recyclability by design, or a documented reuse pathway will not be compliant — regardless of whether a specific format ban applies yet. The supplier materials your current amenity line uses may not pass this test.
Second, if your property is in the Balearic Islands, you have been non-compliant with regional law since 2019. The EU deadline is not your timeline. Your timeline expired years ago.
Balearic Law 8/2019 on waste and contaminated soil prohibited single-use plastic amenity items before Spain's national framework and years before PPWR. The prohibition covers miniature-format toiletries in individually sealed plastic packaging — standard hotel miniatures — unless made from certified compostable materials. No phase-in. No transitional period. In force since 2019.
Most properties in the Balearics are not compliant with this law. Many are not aware it exists.
Enforcement is real. Balearic inspection authorities have powers under this law that Spanish national authorities do not yet have under PPWR. Under Decree-Law 3/2022, qualifying tourism establishments must also produce a Circularity Plan documenting the percentage of locally sourced and zero-kilometre products in their total procurement. Amenities count.
If your property has not yet addressed this, the question is not whether to act — it is how quickly.
Review your amenity compliance with SOSOO Amenities.
Balearic hotel operators are not managing one regulation. They are managing three simultaneously.
Balearic Law 8/2019 prohibits single-use plastic amenities outright. No miniatures unless certified compostable. Already in force.
Royal Decree 1055/2022 and Law 7/2022 operate at national level. They introduce a scalable plastic levy and extended producer responsibility for packaging placed on the Spanish market. The packaging your supplier uses is your liability as the operator.
EU PPWR (Regulation 2025/40) takes general effect in August 2026. Annex V prohibits hotel miniatures from January 2030. Packaging recyclability and reusability requirements apply from August 2026.
Every Balearic hotel bathroom touches all three.
CPNP — the Cosmetic Products Notification Portal — is the EU mandatory registration system for cosmetic products. Every cosmetic product sold or supplied in the EU must be notified to the CPNP before it goes on the market. This includes hotel amenities.
This is a formulation-level requirement, not a packaging requirement. The actual cosmetic formula must be registered by a qualified Responsible Person — covering the product's full INCI composition, safety assessment, product information file, and labelling documentation.
Most mid-market amenity suppliers in Spain have not completed this process for every product in their range. If your supplier cannot produce a CPNP notification number for each specific product in your bathroom, that product may not be legally compliant on the EU market.
CPNP registration is a baseline requirement for every product in a SOSOO programme. Not an optional premium. The starting point.
A compliant hotel amenity programme in 2026 has four elements in order.
Format compliance first: no single-use plastic miniatures. The replacement is either a certified compostable format (difficult to source at quality), a dispensing system, or a reusable packaging format with a documented refill cycle.
Formulation compliance: every product carries current EU Cosmetic Regulation (EC) No 1223/2009 documentation — safety assessment, stability study, ISO 11930 preservative efficacy test, and CPNP registration for each specific formulation.
Packaging compliance: the packaging demonstrates recyclability by design, a certified recycling route, or a reuse pathway. Permanent vessel programmes — ceramic, glass, stone — satisfy both the single-use prohibition and the PPWR reuse requirement.
Documentation: you can produce, on inspection, formulation records, CPNP registrations, supplier compliance declarations, and packaging recyclability certification. Balearic properties must also maintain Circularity Plan documentation under Decree-Law 3/2022.
Most properties currently cannot produce all four.
Ask your existing supplier these questions. How long it takes them to answer tells you something.
Can you provide the CPNP notification number for each product you supply? This should take under 24 hours. If they cannot, the products may not be legally compliant on the EU market.
What is the recyclability certification on your packaging? Ask for the specific standard, not a marketing claim. "Recyclable" on the label is not a certification.
Do your formulations comply with EU Cosmetic Regulation (EC) No 1223/2009? Request the current safety assessment. Any serious supplier holds this on file.
How does your packaging meet PPWR recyclability requirements from August 2026? Most mid-market suppliers have not worked through this. A vague response is your answer.
A new amenity programme — formulation, packaging, CPNP registration, compliance documentation — takes 14 to 20 weeks from briefing to first delivery. For properties that want a compliant programme before the August PPWR general-effect date, the briefing window closes in May.
Properties that brief in May are at the edge of feasible. Properties that wait until June are planning a mid-season transition. Properties that defer to Q3 are planning for 2027.
The compliance cost of acting in May versus October is the same. The operational disruption is not.
Start your compliant programme — the brief takes under 30 minutes.
For a 40-to-80 room property, the process runs in five stages.
Briefing: 30 to 60 minutes covering property type, guest profile, scent direction, packaging preference, and volume. This is where the programme starts taking shape.
Programme preparation: 4 to 6 weeks for formulation selection or development, packaging specification, CPNP documentation, and brand alignment.
Approval: 1 to 2 weeks for the property to review and confirm the programme specification.
Production and delivery: 8 to 12 weeks for custom formulation. Faster for programmes using certified base formulations.
Operational setup: staff protocol documentation, back-of-house refill station configuration, housekeeping procedure.
Properties that delay because they expect complexity typically find the actual process straightforward once it starts.
What is the PPWR deadline for hotel amenities? PPWR enters general force in August 2026. The Annex V prohibition on hotel miniatures takes effect 1 January 2030. For Balearic properties, Balearic Law 8/2019 already prohibits single-use plastic amenities — there is no future deadline to wait for.
Are refillable dispensers enough to be PPWR-compliant? No. Format compliance is necessary but not sufficient. The formulation must have CPNP registration and EU Cosmetic Regulation documentation. The dispenser packaging must also demonstrate recyclability or a documented reuse pathway.
How long does it take to switch to a compliant programme? 14 to 20 weeks from briefing to first delivery for a custom programme. For an August 2026 target, the briefing window closes in May.
What is CPNP registration and do I need it? Every cosmetic product on the EU market must be registered on the CPNP before it is placed on the market. Your supplier handles the registration, but you carry liability as the operator. Verify registration before signing any supply contract.
Does the Circularity Plan requirement apply to hotel amenities? Under Decree-Law 3/2022, qualifying Balearic tourism establishments must document locally sourced procurement. An amenity programme using Balearic botanicals or Mediterranean actives contributes to this percentage and gives the property a genuinely local story to tell guests.
What does a compliant programme cost relative to single-use? Total cost over a full operating season is typically lower with a well-designed refillable programme. Single-use miniatures cost money every service day regardless of consumption. A refillable system costs only on consumption and changeover days.
Get in touch
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