Is Your Packaging Compliant with the New EU Packaging and Packaging Waste Regulation (EU) 2025/40?

The Regulation (EU) 2025/40 on Packaging and Packaging Waste is here! If you sell products in the European Union, it’s time to ensure your packaging meets the new compliance requirements.

This regulation (EU 2025/40) aims to minimize packaging waste, improve recycling rates, and reduce environmental impact. Non-compliant packaging could result in restricted market access or penalties—so taking action now is crucial.

Who Does This Regulation Apply To?

The new rules apply to all packaging and packaging waste of products placed on the European market—including product packaging, some shipping materials, and retail packaging.

• Reusable packaging is not classified as waste.
• Waste refers to packaging that is not reusable.

When Does It Take Effect?
The regulation officially applies from 12 August 2026, but compliance deadlines vary depending on specific requirements.

What are the Key Compliance Requirements?

1. Material Restrictions

• The combined concentration of lead, cadmium, mercury, and hexavalent chromium in packaging must not exceed 100 mg/kg.
• Food-contact packaging cannot contain per- and polyfluorinated alkyl substances (PFAS) above specified limits.
• Plastic packaging must contain a minimum amount of recycled material (ranging from 10–35%, depending on the product) from 1 January 2030. These percentages will increase by 2040. (Exemptions apply to food-contact materials and plastic components under 5% of the total packaging weight.)

2. Labeling & Information Requirements

• Packaging must include a type, batch, or serial number for identification.
• Manufacturers must display their name, registered trade name, trademark, and contact details (postal address + electronic contact method, if available).
• From 12 August 2028, packaging must include a label specifying its material composition to aid recycling.

3. Packaging Design Rules

• By 1 January 2030, packaging must be optimized for minimal weight and volume, ensuring functionality while limiting empty space to 50% max.

4. Recyclability Requirements

• From 1 January 2030, all packaging must be recyclable (if not reusable) with a minimum 70% recycling performance grade.
• This percentage will increase in 2035 and 2038.

5. Reusability of Packaging

• From 12 February 2029, reusable packaging must include a label informing consumers of its reusability, with additional details accessible via a QR code or similar method.

6. Compostability Rules

• From 12 February 2028, certain items—such as fruit & vegetable stickers and tea/beverage bags—must be compostable.

7. Documentation Requirements

• Manufacturers must prepare an EU Declaration of Conformity and technical documentation for their packaging.

What Should You Do Next?
As a product developer selling in the EU, your packaging may require redesign to comply with these regulations. Don’t wait until the last minute—start planning now!

Need expert guidance? Contact us today to schedule a consultation and ensure your packaging is fully compliant.

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