If you're involved in manufacturing or distributing packaging in the EU, you’re likely aware of the importance of staying compliant with the latest regulations. A new EU Regulation (EU) 2025/40 on packaging and packaging waste has just been adopted, and it introduces significant changes regarding labelling and sustainability. For businesses, this regulation is essential for ensuring that packaging can legally be placed on the EU market. Let’s break down the key requirements, focusing on the labelling aspects and what steps manufacturers, importers, distributors, and EU responsible persons need to take to avoid non-compliance.
Why is this important for you?
This regulation has the potential to impact your product packaging strategies significantly. If your packaging doesn't meet the new sustainability and labelling standards, you risk being denied access to the EU market. In a landscape where consumers are increasingly focused on environmental impact, adhering to these new requirements will help your brand demonstrate commitment to sustainability. Furthermore, ensuring compliance means you avoid costly penalties or disruptions in sales.
Key labelling requirements
From August 2028, packaging placed on the EU market will need to be marked with harmonised labels that provide clear information on the material composition of the packaging. This helps consumers sort packaging waste efficiently, contributing to recycling efforts. Additionally, there are new requirements for compostable, reusable, and recycled-content packaging labels.
Packaging containing substances of concern must be marked using standardised, open, digital-marking technologies, and this applies to various types of packaging, including those that are compostable or contain biobased plastic.
What does it mean to you?
Here’s a rundown of the obligations for different stakeholders involved in the packaging lifecycle:
| Party involved | Obligations |
| Manufacturer | Ensure packaging meets all sustainability, labelling, and material composition requirements. |
| Importer | Verify that imported packaging complies with EU regulations, particularly in terms of sustainability and labelling. |
| Distributor | Ensure the packaging they distribute meets compliance and is appropriately labelled. |
| EU Responsible Person | Act as the point of contact for compliance, ensuring that the packaging meets EU requirements before being placed on the market. |
Timeline
Understanding the timeline for these regulations is critical for planning compliance actions:
| Date | Action Required |
| 12 August 2026 | Commission to adopt implementing acts for labelling specifications and methodologies for digital-marking technologies. |
| 12 August 2028 | Packaging to be labelled with material composition and, for compostable packaging, additional info on home composting. |
| 12 February 2029 | Reusable packaging must bear a label indicating its reusability, with further information provided via a QR code or digital data carrier. |
| 12 August 2028 | Waste receptacles to have harmonised labels for separate collection of packaging materials. |
What should you do?
Start by reviewing your packaging strategies to ensure they meet the new EU sustainability and labelling standards. If you manufacture or import packaging, you’ll need to adapt your processes well before the 2028 deadlines to avoid disruptions. Consider implementing a QR code system on packaging or explore digital-marking technologies to provide clear, accessible information about recyclability or compostability.
It’s also crucial to stay informed about the upcoming implementing acts that will provide further details on labelling requirements and digital marking. Align your internal teams and suppliers early to ensure they understand the obligations.
Looking ahead
The new EU packaging regulations aim to drive the transition to a circular economy and reduce the environmental impact of packaging. While the transition may require some investment and adjustments to your packaging processes, it offers an opportunity to demonstrate your commitment to sustainability, which is increasingly important to today’s eco-conscious consumers.
Don’t let compliance be a last-minute concern. Take proactive steps now to ensure your packaging complies with these new requirements.
Source: EU Regulation (EU) 2025/40
