Last updated: November 2025
On 11 February 2025, the Packaging and Packaging Waste Regulation (EU) 2025/40 (“Regulation”) entered into force, replacing the Packaging and Packaging Waste Directive 94/62/EC. The Regulation will apply from 12 August 2026 and aims to reduce packaging waste. It also introduces a range of sustainability measures, including a requirement for all packaging to be recyclable by 2030.
The Regulation is an integral part of the European Green Deal and the EU Circular Economy Action Plan, and is seen as key to helping the EU transition to a more sustainable and resource-efficient economy. Crucially, the Regulation contains progressive targets for reducing packaging waste, requiring Member States to achieve (compared to 2018) a 5% reduction by 2030, a 10% reduction by 2035 and a 15% reduction by 2040.
What are the key features of the agreed Regulation?
The sustainability and manufacturing requirements include the following:
- All packaging must be recyclable by 1 January 2030.
- Minimum percentage requirements for recycled content in plastic packaging will be required from 1 January 2030, increasing substantially from 1 January 2040. However, exemptions were agreed for compostable plastic packaging and packaging whose plastic component represents less than 5% of the packaging’s total weight from those targets.
- Certain chemicals (including PFAS) are prohibited from being used in food contact packaging.
- Certain packaging items (including labels on fruit, very lightweight plastic bags, and teabags, coffee bags and coffee pods) will need to be compostable by 12 February 2028.
- Empty space in packaging must be reduced to the minimum amount necessary, with a maximum empty space ratio of 50% for transport and e-commerce packaging used to group multiple products. With exceptions, manufacturers and importers must ensure that the weight and volume of packaging are minimized.
Labelling, marking and information requirements include the following:
- Displaying information relating to material composition
- Labelling packaging with a digital code (such as a QR code) containing information on its reusability and enabling packaging to be tracked
Packaging manufacturers will need to draw up an EU Declaration of Conformity confirming that packaging complies with the applicable sustainability and labelling requirements.
Reuse targets and refill obligations include the following:
- Minimum percentage targets for the reuse of a number of types of packaging by 2030 with indicative targets for 2040 — these targets cover certain types of transport and sales packaging, grouped packaging, and sales packaging for alcoholic and nonalcoholic beverages (with exclusions for wines, milk and other beverage types, and with cardboard packaging generally exempted from these requirements)
- An obligation for takeaway businesses to offer customers the option of bringing their own food and beverage containers to be filled at no extra charge by 12 February 2027
- An obligation for takeaway businesses to offer 10% of products in reusable packaging from 2030
Deposit and return system (DRS) obligations include the following:
- Member States must set up a DRS system, and collect at least 90% of single-use plastic bottles and metal beverage containers by 2029. An exemption applies to a member state if they reach a separate collection rate of over 80% in 2026 and if they submit an implementation plan with a strategy for achieving the overarching 90% separate collection target.
Restrictions on certain packaging formats include the following:
- Restrictions on certain types of single-use plastic packaging for fruit and vegetables, food and beverages, condiments within the HORECA sector, for small cosmetic and toiletry products used in the accommodation sector (e.g., shampoo or body lotion bottles), and for very lightweight plastic bags (e.g., those offered at markets for bulk groceries) — these restrictions will add to the restrictions on single-use plastic already provided in the Single-Use Plastics Directive
Member States will be subject to enhanced targets to reduce the amount of packaging waste generated per person (compared to 2018 levels) by 5% by 2030, 10% by 2035 and 15% by 2040.
Why is this important?
The proposal considers the full life cycle of packaging. Therefore, all packaging placed on the EU market will be covered by the Regulation, with different obligations applicable to packaging manufacturers, suppliers, importers, distributors and fulfilment service providers. This Regulation will be relevant to any business selling packaged goods.
Next steps
The Regulation will become directly applicable from 12 August 2026, without the need for a national implementing regulation. We expect the European Commission to publish official guidance relating to the Regulation ahead of this date. Nonetheless, given the broad scope of the new requirements, it is important that businesses are aware of their obligations and begin working towards compliance to avoid potential disruptions and ensure a smooth transition.
