The European Union has just overhauled its packaging regulations, and the changes are set to reshape how manufacturers, importers, and distributors approach packaging design, recycling, and sustainability. The new Regulation (EU) 2025/40, adopted on 19 December 2024, introduces bold sustainability goals that directly impact every business placing packaged products on the EU market.
For companies in manufacturing and distribution, these changes may feel daunting. The good news is that with early planning and compliance, you can meet the new requirements and enhance your brand's sustainability credentials. This blog post outlines the key changes and what your company needs to do to stay ahead of the curve.
Key changes in the new packaging regulation
The new regulation replaces Directive 94/62/EC and covers the entire lifecycle of packaging. Here’s a summary of the key sustainability requirements that will affect your packaging:
1. Recyclability Requirements
By 1 January 2030, all packaging must be recyclable. To meet this standard, your packaging must:
- Be designed for material recycling
- Allow for the use of high-quality secondary raw materials
- Be capable of being collected separately and recycled at scale
By 2038, packaging must meet recyclability performance grades A or B (the top two tiers), meaning your packaging will need to demonstrate high levels of recyclability.
2. Minimum Recycled Content for Plastic Packaging
The regulation sets ambitious targets for the minimum recycled content in plastic packaging, with milestones leading up to 2040:
| By 2030: | By 2040: |
| 30% for contact-sensitive PET packaging | 50% for contact-sensitive PET packaging |
| 10% for other contact-sensitive plastic packaging | 25% for other contact-sensitive plastic packaging |
| 30% for single-use plastic beverage bottles | 65% for single-use plastic beverage bottles |
| 35% for other plastic packaging | 65% for other plastic packaging |
This means that if your packaging uses plastic, you'll need to plan for incorporating recycled content into your packaging.
3. Packaging Minimisation
From 1 January 2030, your packaging weight and volume must be reduced to the minimum necessary. This includes:
- Prohibiting the use of double walls, false bottoms, and unnecessary layers
- Exceptions apply for protected designs and geographical indications
The aim is to reduce excessive packaging waste and encourage more sustainable packaging choices.
4. Reusable Packaging
Starting 11 February 2025, reusable packaging must meet specific requirements:
- Designed for multiple uses
- Capable of being reconditioned and reused safely
- Recyclable at the end of its life
- Properly labelled to inform consumers of its reusability
This is a big shift for many businesses that rely heavily on single-use packaging, but it presents an opportunity to innovate and offer more sustainable options to your customers.
What’s next? A Date to remember
There are several important dates to keep in mind for compliance. These deadlines are crucial for making the necessary changes to your packaging and business practices:
| Date | Requirement/Deadline |
| 11 February 2025 | New reusable packaging requirements come into force. |
| Reusable packaging must meet design, safety, and recyclability standards. | |
| 31 December 2025 | Member States must report substances that impact recyclability. |
| Last date for submission of data on substances affecting recycling and reuse. | |
| 12 February 2026 | European standardisation organisations must deliver standards for compostable packaging and home compostability. |
| 31 December 2026 | Commission to establish methodology for calculating recycled content in plastic packaging. |
| Report on substances of concern in packaging to be completed by the European Chemicals Agency. | |
| 12 February 2027 | Development of standards for packaging minimisation and reusable packaging rotations. |
| 1 January 2028 | Commission to implement recyclability performance grades (A, B, C). |
| 12 February 2028 | Biobased plastic packaging technology review, including mandatory compostable packaging requirements for some items. |
| 1 January 2030 | All packaging must be recyclable within grades A, B, or C. |
| Minimum recycled content requirements for plastic packaging begin. | |
| Packaging minimisation requirements become mandatory. | |
| 1 January 2035 | Full implementation of recycled-at-scale requirements. |
| 1 January 2038 | Only packaging with recyclability grades A or B allowed on the market. |
| 1 January 2040 | Final phase of regulation implementation, including enhanced recycled content targets. |
Who is responsible for what?
The regulation defines specific responsibilities for each economic operator. Here’s a summary of the key obligations:
| Economic Operator | Obligations |
| Manufacturer | Ensure product compliance with EU regulations and standards. Conduct risk assessments and maintain technical documentation. Affix CE marking where applicable. Provide clear instructions and safety information. Implement corrective actions when necessary. |
| Importer | Verify that the manufacturer has carried out conformity assessments and maintains documentation. Ensure the product has proper labelling and meets EU safety requirements. Keep documentation for at least ten years. Cooperate with authorities for compliance checks. |
| Distributor | Ensure products have the necessary compliance markings, documentation, and instructions before placing them on the market. Cooperate with authorities and take action on non-compliant products. |
| Authorised Representative (EU Responsible Person) | Act as the manufacturer’s point of contact within the EU. Ensure compliance documentation is available to authorities. Cooperate in corrective actions and market surveillance activities. |
5 steps to ensure compliance
- Review your packaging portfolio against the new recyclability and recycled content requirements.
- Plan for increased use of recycled materials in your plastic packaging, starting now.
- Evaluate your packaging design to ensure it meets the minimisation criteria and is suitable for reuse where possible.
- Start developing technical documentation that will be required for compliance, including information about substances impacting recyclability and recyclability performance grades.
- Implement reusable packaging systems where feasible, and ensure all your reusable packaging is properly labelled.
Need help?
At Alura Group, we understand these changes can seem overwhelming. Our team of product compliance experts can help you navigate the new requirements and develop a practical roadmap for compliance. Contact us today to discuss how we can support your transition to the new packaging regulations.
Source: Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024
