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Ein Stapel verschiedener Einwegverpackungen aus Kunststoff und Styropor
Feb 18, 2026 7:36:06 AMReading time: 8 Min  |   Legal News

The EU Packaging Regulation

The EU Packaging Regulation applies from summer 2026
The EU has sent a clear signal for more circularity and less packaging waste: With Regulation (EU) 2025/40 on packaging and packaging waste published on 22 January 2025, the final legal framework is in place, which will be binding across the EU as of 12 August 2026. The aim is to avoid unnecessary packaging, strengthen recycling and, in particular, ban certain single-use plastic packaging as of 2030.

The new regulation is a central component of the European Green Deal and represents a significant turning point with concrete need for action for many companies.

What does the new Packaging Regulation regulate?
The Regulation (EU) 2025/40 replaces the previous EU Directive 94/62/EC and applies directly in all Member States, that is, without national transposition laws. It includes, among other things:

  • Ban on certain single-use plastic packaging from 2030
    e.g., takeaway packaging for food and beverages, portion packs in hotels, unnecessary packaging for fruit and vegetables
  • New design and labeling obligations
    to improve sorting, reuse and recyclability
  • Binding reuse targets
    for beverage packaging, hospitality, transport and e-commerce
  • Extended producer responsibility (EPR)
    including clear requirements for collection and take-back systems
  • Obligations for resource-efficient packaging design and for the use of recycled materials


Start of application and transitional periods
The regulation entered into force on 11 February 2025. Most provisions apply as of 12 August 2026. Transitional periods run in part until 2030, especially where infrastructure or conversions require time. The key point is: the direction is set; companies should act now.

Which packaging is affected by the ban?
From 1 January 2030, certain single-use plastic packaging may no longer be placed on the market, such as:

  • Packaging for food and beverages for immediate consumption or takeaway
  • Portion packs for cosmetics or food (e.g., hotel shampoos, sugar sachets)
  • Packaging for fresh fruit and vegetables where no hygiene or protective requirements exist

These measures target packaging considered particularly short-lived and avoidable. At the same time, the regulation contains differentiated exemptions, e.g., for packaging of medicinal products and medical devices, where product safety and hygiene take precedence.

Opportunities and challenges for companies
The new regulation not only changes the regulatory framework, but also sets strategic direction for a future-proof economy:

Challenges:

  • Review and realignment of product and packaging designs
  • Necessary investments in alternative materials and reusable solutions
  • Documentation obligations and evidence along the supply chain


Opportunities:

  • Positioning as a sustainable, responsible company
  • Development of new, circular packaging solutions
  • Strengthening resilience within the supply chain and innovation capacity


A nuanced view of plastics

Not every single-use packaging is automatically environmentally detrimental. Especially in sensitive areas such as healthcare or the pharmaceutical industry, functional plastic packaging is often still essential. The regulation acknowledges this and provides specific exemptions, for example for packaging for medicinal products or medical devices where no equivalent alternative exists.

What matters assessing packaging with nuance and develop sustainable strategies that balance functionality, safety and environmental goals.

Conclusion
With Regulation (EU) 2025/40, the EU sets binding standards for a sustainable packaging industry. The transitional period until August 2026 gives companies time  but is also a clear call to act now. Those who act early can minimize regulatory risks and seize new opportunities for innovation and market positioning.

 

Compliance updates on the new EU Packaging Regulation 

Compliance Update of 4 August 2025

Regulation (EU) 2025/40 (PPWR) on packaging and packaging waste entered into force on 11 February 2025. The first obligations will apply from 12 August 2026.

The new regulation marks an important step toward a more circular, resource‑efficient, and sustainable economy in Europe. It replaces the previous Packaging Directive, which was transposed into national law in Germany through the Packaging Act. With the new regulation, the requirements for companies along the entire packaging value chain become more stringent particularly for manufacturers, distributors, and importers.

However, there is still room for interpretation. For example, it remains unclear what exactly the EU legislator means by “packaged products,” as this term is not defined in the regulation. The term “producer” also leaves room for interpretation. It therefore remains to be seen to what extent these terms will be further specified in terms of their content.

Important note: The specific obligations for companies will likely only be clearly defined in a legally binding manner over the next 18 to 24 months as the implementing acts are adopted.

Conclusion: 

At the present time, due to the numerous specifications in the PPWR that are still pending, it is not yet possible to take concrete implementation measures to ensure compliant adaptation to the requirements. We are closely monitoring further developments and will respond immediately to the upcoming implementing acts in order to promptly incorporate the obligations into your legal register.

Compliance Update of 21 May 2025

On 11 February 2025, Regulation (EU) 2025/40 (PPWR) on packaging and packaging waste entered into force and will apply from 12 August 2026. The new regulation marks an important step toward a more circular, resource‑efficient, and more sustainable economy in Europe. It replaces the previous Packaging Directive, which was transposed into national law in Germany through the Packaging Act. With the new regulation, the requirements for companies along the entire packaging value chain become more stringent particularly for manufacturers, distributors, and importers.

But who exactly falls under which role? And what do the new obligations actually mean in practice? The following article provides you with a clear overview.

Who is considered a manufacturer, distributor, or importer under EU regulation?

Regulation (EU) 2025/40 clearly defines the actors in the supply chain in order to assign responsibilities unambiguously:

  • Distributors
    Distributors are natural or legal persons in the supply chain who make packaging available on the market. “Making available” refers to any supply of filled or unfilled packaging, whether for payment or free of charge, for distribution, consumption, or use on the Union market in the course of a commercial activity. This means that virtually any manufacturing company that supplies goods with packaging to its customers is affected.
  • Importer
    An importer is any person who places packaging from a third country on the European internal market for the first time regardless of whether the packaging is empty or already filled with products. This also affects a wide range of companies that import raw materials, goods, parts, etc. from outside the EU.
  • Manufacturers
    Manufacturers are producers (manufacturers of packaging or packaged products), importers, and distributors.

Important: In practice, companies may fulfill several of these roles at the same time for example, as both a manufacturer and a distributor. Accordingly, they must also comply with the respective obligations..

Overview of the key obligations under Regulation (EU) 2025/40

The new regulation pursues ambitious goals: packaging waste is to be avoided, packaging made reusable or recyclable, and the use of problematic materials reduced. This results in numerous obligations for companies:


1. Eco‑design requirements for packaging:

Manufacturers and importers must ensure that all packaging:

  • are recyclable (according to defined standards),
  • have minimal packaging volume (avoiding unnecessary material),
  • contain a minimum proportion of recycled content (graduated by packaging type),
  • are suitable for reuse systems (where required).

The requirements apply on a product‑ and sector‑specific basis. For certain types of packaging (e.g., transport packaging, single‑use packaging in the food sector), additional specific provisions apply.

2. Obligation to ensure reusability:

In selected areas (e.g., transport packaging, food service, e‑commerce), specific reuse quotas for packaging will apply from 1 January 2030. Manufacturers and distributors must establish corresponding systems or participate in existing ones.

3. Information and labeling obligations
Companies must:
  • provide consumers with clear information on reusability, recyclability, and proper disposal,
  • label packaging with standardized symbols and QR codes,
  • take into account national labeling requirements where these go beyond EU specifications.

4. Registration and data reporting:

All manufacturers, importers, and distributors must:

  • register in national packaging registers,
  • report annual data on packaging volumes, material types, reuse targets, and disposal routes.

This data forms the basis for monitoring and market surveillance by national authorities.

5. Responsibility within the supply chain:

Importers and distributors share responsibility for the compliance of the packaging they place on the market. This means they must ensure that the packaging they distribute meets all the requirements of the regulation otherwise, fines or sales bans may be imposed.

 

6. Conformity procedures:

Producers of packaging, as the first entity in the supply chain, must carry out conformity assessment procedures according to defined standards before placing packaging on the market for the first time. This includes preparing declarations of conformity as well as technical documentation.

 

7. Prohibition of certain packaging and materials:

The regulation contains a list of prohibited types of packaging, such as certain single‑use plastics, substances of concern, and non‑recyclable material combinations. These may no longer be placed on the market from the specified dates.

 

 

Conclusion: Act now and implement obligations

Regulation (EU) 2025/40 brings far‑reaching changes for most companies regardless of whether they manufacture packaging or purchase it and then place it on the market with their products. The focus is on resource efficiency, reuse, and a truly circular economy.

 

Companies should therefore:

  • clearly determine their roles within the meaning of the regulation,
  • be aware of the legal obligations that apply to them,
  • begin implementation and review internal processes as well as supply chains,
  • adapt packaging and its design to the new requirements,
  • register early and prepare for reporting obligations as soon as the national portals become available.

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EILEEN MÜLLER 
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