EU Regulation 2025/40 on Packaging and Packaging Waste

On 12 August 2026, the new EU Regulation 2025/40 on packaging and packaging waste (Packaging and Packaging Waste Regulation – PPWR) began to apply across the European Union.

The EU regulation brings a fundamental change in the approach to regulating packaging. The new rules will gradually affect the entire life cycle of packaging, from its design and production through placing on the market and use to reuse and recycling.

Although the PPWR has been in effect since 12 August 2026, this does not mean that businesses must comply with all the new obligations immediately. Many requirements will phase in gradually, up to 2040. The specific form of the obligations will also depend on follow-up implementing acts of the European Commission.

The regulation affects a broad range of economic operators. Depending on the specific situation, obligations may arise in particular for manufacturers, importers, distributors and suppliers of packaging, but also for businesses that use packaging for their products.

What matters is not only the general status of the business, but its specific role in relation to a specific item of packaging. A single business can therefore hold different positions for different packaging at the same time, and different obligations may apply to it.

The PPWR introduces requirements in particular on:

• the environmental sustainability of packaging throughout its life cycle,
• the recyclability of packaging,
• the content of recycled materials,
• minimising the weight and volume of packaging,
• preventing the generation of packaging waste,
• reuse and refilling of packaging,
• labelling of packaging,
• restrictions on certain single-use packaging,
• extended producer responsibility,
• registration, collection and treatment of packaging waste.

One of the first practically significant changes is the restriction of PFAS in packaging intended for contact with food. From 12 August 2026, the set limits on the content of these per- and polyfluoroalkyl substances apply. Businesses should therefore have information on the material composition of the packaging they use and verify whether their suppliers meet the new requirements.

In addition, the basic requirement for the recyclability of packaging begins to apply. Further detailed requirements will be refined by follow-up legal acts and methodologies.

Businesses must also be able to identify their suppliers and customers of packaging and retain the prescribed data for five years for single-use packaging and ten years for reusable packaging.

From 2027, rules on the reuse and refilling of packaging are to be developed, and a European Reuse Monitoring Centre is also to be established.

From 2028, harmonised labelling of packaging is expected. The label is meant to give consumers information on the material composition of the packaging and make it easier to sort correctly. The harmonised labelling will also apply to containers intended for the collection of packaging waste.

From 2030, a number of fundamental requirements will take effect, including:

• all packaging will have to meet recyclability requirements,
• minimum shares of recycled material in plastic packaging will begin to apply,
• requirements for minimising packaging and empty space will be tightened,
• binding reuse targets will start to apply,
• certain formats of single-use plastic packaging will be restricted.

The restrictions are expected to concern, for example, selected single-use plastic packaging for fruit and vegetables, certain packaging for food and drinks consumed in the hospitality sector, or selected single-use cosmetic and hygiene packaging in accommodation services.

Further tightening of the requirements on recyclability and recycled content will follow in 2035, 2038 and 2040.

The PPWR itself does not impose on businesses a general obligation to change their general terms and conditions. The obligations set by the regulation primarily concern the properties of packaging, its labelling, documentation, record-keeping and the obligations of individual economic operators.

However, it may be advisable to carry out a review of contractual documentation and supplier relationships, especially if the business purchases packaging, places its own products in packaging on the market, imports packaged products from third countries or uses packaging under its own brand.

In contracts with suppliers, it is advisable to consider in particular adjusting the obligation to provide information and documentation on packaging, to notify changes to its material composition or design, to provide the necessary cooperation, and to regulate contractually the responsibility for costs and damage arising from non-compliance of packaging with the PPWR requirements.

Practical implementation of the PPWR is complicated by the fact that many follow-up rules and methodologies are not yet available. This concerns, among other things, harmonised labelling, the methodology for determining the material composition of packaging, certain aspects of recyclability, and the rules for calculating and verifying the share of recycled material.

The uncertainty is particularly significant for businesses that need to adapt their packaging, production processes, supplier relationships and internal documentation in advance. Changing packaging can take months, and for packaging intended for contact with food the entire process of development, testing and approval can take considerably longer.

The lack of practical information has also been pointed out by the Czech Chamber of Commerce. According to its survey of 384 companies, at the end of July 2026 businesses rated the quantity and quality of available information on PPWR implementation at only 2.3 points out of 10 on average. Almost half of respondents said they gave the available information the lowest possible rating. Only 3.4% of businesses described their preparations as almost or fully completed.

Businesses are advised in particular to carry out a basic audit of their packaging and its supply chain.

In the first phase, they should:

1. map all packaging used and supplied and determine their role under the PPWR;
2. identify the material composition of the packaging and request the necessary data from suppliers;
3. check for the presence of PFAS in packaging intended for contact with food;
4. verify whether the current recyclability requirements are met;
5. check whether the packaging used will be subject to future requirements on recycled content, reuse or packaging minimisation;
6. prepare processes for conformity assessment, technical documentation and the EU declaration of conformity, where they apply to the business;
7. set up records and retention of data on suppliers and customers;
8. monitor further implementing and delegated acts of the European Commission, which will gradually specify the individual requirements.

The regulation is not a one-off change but a long-term transformation of the rules for the packaging industry. For businesses, it will be key to monitor not only the obligations effective from 12 August 2026, but also the timetable of further requirements, and to adapt their packaging, supplier relationships and internal processes in good time.